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ICE Detention Standards Compliance Audit - El Centro Service Processing Center, El Centro, CA, ICE, 2005

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Office of DetenJion and Removal Operations
U.s. Department of Homeland Sei:urity
425 I Street, NW
Washington, DC 20536

U. S. Immigration
and Customs
Enforcement

MEMORANDUM FOR:

FROM:

b6, b7C

b6, b7C

SUBJECT:
The Headquarters Office of Detention and Removal intends to perform a review of your facility on
July 12, 2005. This review will be perfonned under the supervision of Headquarters staff. The
review is expected to conclude on or about July 14, 2005. The review team will conduct a complete
closeout and share the preliminary findings ofthe review at that time.
In preparation for this inspection, you are requested to provide working space for the review team.
Additionally, a master copy of the facility's Policies and Procedures, Post Orders, and Emergency
Plans should be available to the review team during the review. The Reviewer-in-Charge (RIC) may
request additional materials during or prior to the scheduled review.
The designated RIC for your review is
b6, b7C
regarding this review, please have them contact
Compliance Unit, at (202) 305 b6, b7C .

. Should your staffhave any questions
Chie£: Detention Standards

b6, b7C

OJ]ice (~/Delention and RemoWlI Operations
LS. Department or lIomeland Seeurity
425 I Street. 'Iv.:
Washington. DC 20530

U.S. Immigration
and Customs
Enforcement

MEMORANDUM FOR:

Ronald Smith
Field Office Director
San Diego Field Office

z. "

"' ~' ~ ,

AJ\ "'/

FROM:

JohnP. Torres
Acting DirectoL~"\: )

SUBJECT:

EI Centro Processing Center Annual Detention Review

Headquarters Detention and Removal Operations conducted a detention review of the El Centro
Processing Center July 12-14,2005, in EI Centro, 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 of this 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 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.
Should you or your staff have any questions regarding this matter, please contac
Deputy Assistant Director, Detention Management Division at (202) 305 b2 high

b6, b7C

y,

_{lice ojD<!tcmio/l al/d Removaf OperaliolL'i
L.S. l>epartment of Homeland Security
425 I Street, 1\\\'
Washington, DC 20536

U.S. Immigration
and Customs
Enforcement

MEMORANDUM FOR:

Jolm P. Torres
Acting Director

FROM:

b6, b7C

Reviewer-In-Charg
HQDROIDMDIDS
SUBJECT:

b6, b7C

EI Centro Processing Center Detention Review Summary Report.

The Detention Management Division, Detention Standards Compliance Unit performed a
Headquarters Detention Review of the EI Centro Processing Center in El Centro, California from
July 12-14, 2005. This is an Immigration and Customs Enforcement operated facility. The review
b6, b7C
, Reviewer-In-Charge. Team members
was performed under the guidance of
b6, b7C
included
Denver DRO,
, Phoenix DRO and
, San
b6, b7C
b6, b7C
Antonio
Type of Review

This review is a scheduled Headquarters Review, which is performed to determine overall
compliance with the Immigration Customs Enforcement (ICE) National Detention Standards (NDS).
The facility received a previous rating of "Acceptable" during the July 2004 review.
Review SummarY

The American Correctional Association (ACA) has not accredited the El Centro Processing Center.
The National Commission on Correctional Health Care (NCCHC) and the Joint Commission on
Accreditation of Health Organizations (JCAHO) accredit the facility.
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 2004 and 2005 detention reviews:
2004 Review
Compliant
Deficient
Repeat Deficiency

35
1
1

2005 Review
Compliant
Deficient
Repeat Deficiency

34
3
1

•

•

•

Memorandum for John P. Torres
El Centro Processing Center Detention Review Summary Report
Page 2
Detainee Classification System - Deficient
•

The facility conducts classification at intake. Reclassification after entry is not conducted.
o

Reclassification at 45 and 60-day intervals after arrival is not conducted. Subsequent re
classification at 60 and 90~day intervals is not conducted. Twenty-five detention files
were reviewed which revealed this as a recurring deficiency.

Staff Detainee Communications - Deficient
•
•
•

The facility does not document visits of detainee living and activity areas by department
heads and deportation officers
The facility does not document or consistently track the receipt of detainee request forms
The facility does not maintain copies of the ICE response to detainee request fonns
o

•

The facility could not provide documentation signifying that department heads and
deportation officers conduct unannounced visits to the facility's living and activity areas.
Logs are not maintained tracking detainee request form receipt and response activity.
Copies of detainee request foTITIS are not maintained in detention files .

Tool Control - Deficient
•
•
•

The tool room officer did not have accountability of items on shadow board
Multi purpose tool set missing and not accounted for
Water hoses twenty-five feet in length were found in housing units not under inventory
control

Multiple cutting grinding wheels displayed on the tool room shadow boards were not accounted for
by the tool room officer. Parts belonging to a multi purpose tool set located in the tool room were
missing and not properly accounted for. Water hoses twenty-five feet in length, which could be used
as a security breach, were located within each housing unit unaccounted for. Assessment of the unit
logbooks revealed that housing units were not maintaining inventory of the water hose's.
Hold Rooms - Repeat Deficiency
•

•

Detainees are held longer than twelve hours in hold rooms.
o Review ofthe hold room logbook entries revealed that detainees were held longer than
twelve hours on three occasions during the rating period. The facility was previously
found deficient in this standard. Further improvement is needed to assure that the facility
remains in compliance with the standard by effectively monitoring hold roomslIogs to
assure that detainees are removed from the hold rooms in a timely manner .

Memorandum for John P. Torres
El Centro Processing Center Review Summary Report
Page 3
Si2nificant Observations and Best Practices

Staff Appearance - Significant Observation
TCE and contract security staff dressed appropriately and presented a neat a professional appearance
appearance. They appeared to be 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.
Facility Operation During Unforeseen Incident-Significant Observation
During the annual review, the facility experienced an unforeseen incident with the rupture of a main
fire suppression water line serving the facility (Water used for daily facility operation was never
affected). Facility staff immediately responded to the situation and assured the health and safety of
detainees and employees was maintained. Calls were made to the local police and fire departments
to advise ofthe facility's situation, in the event additional support was requested. Mobile water
generating pumps were set up near irrigation canals immediately outside of the perimeter fence, in
the event that water needed to be pumped into the facility for fire suppression. Facility personnel
immediately worked out particulars that were necessary to have the suppression system repaired and
back into operational order.
Main Entrance Security - Best Practice
Security officers at the facility's main entrance were very keen and attentive to all persons entering
and departing the facility. Officers effectively searched incoming articles within handbags and
computer carriers. Officers requested and verified photo identification of all individuals at entry
prior to the issuance of a visitors pass. Officers subsequently verified the photo identification of
individual's prior to their departure from the facility.
RIC Observations

The ICE Officer-In-Charge, Private Security Project Manager and their entire staff were very
supportive of the review team and assisted the team completely throughout the review.
RIC Issues and Concerns:

Water and gas service valve cover caps on the asphalt surface within the perimeter are not secured.
The metal caps could easily be removed and used as a weapon to cause injury. The facility is
currently preparing for accreditation by the American Correctional Association (ACA). The facility
may experience limitations in their ability to become compliant with the ACA standards without
permanent guidance in place to cDnduct proper oversight and guidance.
Recommended Rating and Justification:

The Reviewer-In-Charge recommends that the facility receive a rating of "Acceptable." The facillty
complies with 34-of-38 applicable ICE National Detention Standards. The facility should respond to
all findings and initiate a Plan of Action in response to the deficiencies.

Memorandum for John P. Torres
El Centro Processing Center Detention Review Summary Report
Page 4

•

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.

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

Department Of Homeland Security
Immigration and Customs Enforcement

Detention Facility Inspection Form
Facilities Used Over 72 hOUTS

A. Type of Facility Reviewed
ICE Sen-ice Processing Center
IZl
ICE Contract Detention Facility
ICE Intergovernmental Service Agreement

I

o
o

i

G. Accreditation Certificates
: List all State or National Accreditation [s] received:
i JACHO, NCCHC
I 0 Check box iffacilitv has no accreditation[s

B. Current Inspection
Type of Inspection
Field Office f2l HQ Inspection
Date[s] of Facility Review
July 12-14, 2005

H. Problems! Complaints (Copies must be attached)
The Facility is under Court Order or Class Action Finding

C. Previous/Most Recent Facility Review

IZI

o

Date[s] of Last Facility Review
July 27-29,2004
Previous Rating
Superior 0 Good IZl Acceptable

o

o Court Order
o Major Litigation

0

Deficient

0

At-Risk

D. Name and Location of Facility
:-lame

C

0

Class Action Order

The Facility has Significant Litigation Pending

£1 Centro Processillg Center
Addres.~ (Street and :\amc)
1115 North Imperial Avenue
City, State and Zip Code
F.I Centro, Caliroroia 92243
County
ImJ)erial
: "ame and Title nfChicf Executive Officer (Warden/OIC/Superintendent)
ee. Actin!!: Officer-ln-ChlI.r2c
b6, b7C
nclude Area Code)
~7~~-3 b6,b7c 6~O~t~~~~__~______________________~

Field Office I Sub-Office (List Office with oversight responsibilities)
San Diego Field Office
DIstance from field Ollief

0

Life/Safety Issues

Check if None.

I. Facility Historv
Date Built
1975
Date Last Remodeled or Cpgraded
Continuous
Date 1\ew Construction ! Bedspace Added
1\one
: Future Construction Planned
: l:8J Yes 0 No Date:
Future Bedspace (# New Beds only)
! Current Bedspace
I 500
Number:
Date:

J.

Total Facilitv Population

Total Facility Intake for previous 12 months
8, 109
Total1CE Ylandays for Previous 12 months

8.5

120 "llles

K. Classification Level (lCE SPCs and CDFs Onlv)
L-2
L-3

E. ICE Information

r--c-:-_-=-_ _ _+----=
L:...:
-l= ---_+-_

257
]\"one

182

10

]\"one

None

Name ofInspeclor (Last :-lame, Title and Duty Station)
i D&D Officer :' HQiDRO
b6, b7C
Name of Team Member; Title I Duty Location
b6, b7C
i DO i Denver Field Office
mber! Title;' Duty Location
b6, b7C
:' SIEA i Phoenix Field Office
Member! Title ! Duty Location
l LCDR / San Antonio Field Office DIHS
b6, b7C

Adult Male
Adult Female

F. CDF/IGSA Information Only
I Date of Contract or IGSA

M. Average Daily PO?}p~ul=:a~ti:::o~u'--_.____:::-:::-:c-=:~-,-___:::-:--__,
ICE
USMS
Other
Adult Male
435
None
None
Adult Female
None
None
None

Contract Number
None
Basic Rates per Man-Day

I

Other Charges: (if :-lone, Indicate Ni A)

L. Facility Ca.T=~~--_.----------~--------~
acit,'
Adult Male

Rated
ODerational
Eme ..gencv
544 -+~~4~5~O~~~=~56..1::!O=:..L...j

Adult Female
l"one
~one
.None
Facilitv holds Juveniles Offenders 16 and older as Adults

o

]\". Facility Staffing Level
Support:

Estimated Man-days Per Year

b2 high

b2 high

Form G-324A (Rev. 8/ 13/04) No Prior Version May Be Csed After 10/ 1104

Significant Incident Summary Worksheet
For 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. Failure to complete this section will
result in a delay in processing this report and the possible reduction or removal of leE' detainees at your facility.

As ault:
Offender o n
Offenders'

Assault:
D taine' on
Staff

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

a

0

0

a

0

0

a

0

0

a

0

2

()

[)

a

a

0

0

a

17

3

0

0

0

0

Actual
II Received
~ Resolved

in fa\·o;'(;f"" -

2
0

Deaths

0

0
Psychiatric ! Medlcal
Referrals

0

A

30

II

4

II

0

0

0

0

Any attempted physical contact or physical contact that inH)l ves two or mor~ offenders
Oral. anal or vagina: penetration or attempted penetration involving at least 2 parties. whether it is consenting or non-<:onscnting
Routine transportati nn of deta inees!(lffe nder~ is not considered " forced"
Any incident that involves four or more detainees/offenders, includes gang fights. organilcd cnult1plc hung(..'!' strikes, work stoppages, hostage situations,
major fires. or nthe, large scale incidents.

Form G-324A (Rev. 8/ 13/04) ;-To Prior Version May Be Used After 1011 104

7.

8.
9.
10.
11.
12.
13.
14.
15.
16.

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

Classific~tion 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
~on-Medical Emergency Escorted Trip
Recreation
Religious Practices
V
Work !'Te, ,"",,m

Detention Files
Disciplinary Policy
E mergency Plans
Environmenral Health and Safety
Hold Rooms in Detention Facilities
Key and L{)ck Control
Population Counts
Post Orders
Security Inspections
Special Management Units (Administrative Segregation)
Special Management Units (Disciplinary Segregation)
Tool Control
Transport<'l tion (Land management)
Use of Force
StafT l Detainee Communication (Added August 2003)
Detainee Transfer (Added September 2004)

All fi nding (Deficient and At-Risk) require l\Titten comment describing the find ing and what i necessary to meet compliance.

Form G-324A (Rev. 8/ 13/04) Ko Prior Version May Be Used After 1011104

RIC Review Assurance Statement

•

By signing below, the Reviewer-In-Charge (RIC) certifies that all fmdings of noncompliance with policy or inadequate controls
contained in the Inspection Report are supported by evidence that is sufficient and reliable. Furthermore, findings of noteworthy
accomplislunents 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: (Printl\amc)

Signa
b6, b7C

b6, b7C

rille & Duty I.ocation

Dale

Detention and Deportation Officer,

Washin~ton,

DC

July 14,2005

Team Members
Print Name. Title, & Duty Location
b6, b7C

Print Name. Title. & Duly Location

DO, Denver Field Office

b6, b7C

Duty Location
b6, b7C

, SIEA, Phoenix Field Office

Print l\ame. Tille. & Duty Location

LCDR, San Antonio Field Office

Recommended Rating:

o Superior
o Good
~ Acceptable
o Deficient
D At-Risk

Comments:

Form G-324A (Rev. 8! 13:'04) No Prior Version May Be Used After 10! 1104

•

" [ADQUARTERS EXECUTIVE REVIEW

,Review Authority
.-;.------- - - - --

--------

- - - - - - - - - - _.__._--_._---------------------,
- - - - - --_.__ ._ .- ..._ --._._-_.._ - - - - - - - - - - - - - - - ..J

The s ignature below constitutes review of this report and acceptance by the Review Authority. OIC/CEO will ha\'c 30 days from
receipt of this report to respond to alllindings and recommendations.

I IIQDRO r x r:ClITIVL RLVII:\\':

r'' h' ".,,,""
I ilk

!)~H,

j)irc:ctor

Final Rating:

o Superior

/ 1\\1\ t\~~

S'gna/lire

I

L.:·\ (;li n ~

r-... '\

\
(I'lca$c I>rint "Jarne)

(

I

t\

.1
' ,/
-J ,. , t')
),
I

DCood
[gJ Acceptable
D Deficient
At-I{jsk

o

COlllments:

rhe Re view Authority (RA) co ncurs with the recommended rating of "Acccptable" made by the
(RIC) as jU5titi ed in the RIC Memorandum and the G-324A Worbhe ets,

Revicv~er-In-Chargc

Form (i·]24A (Rev. S:I iOI) No Prior Version Ma y Be Lsed Ath:r 12/]]:01

e

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

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

Headquarters Detention Review Worksheet

o
o
o

IS]

Local Jail- IGSA
State Facility - IGSA
ICE Contract Detention Facility
ICE Service Processin Center

Name

s_e~~ic_e_p_~_o_c_e_s_sl_n

Address
(Street and Name) __c_e_n_t_e_
E_I_c_e_n_t_ro__
r _____________________________
North
1m
erial
Avenue
1115
fCity, State and Zip Code
: Ei Centro, California 92243
County
Imperial
Name and Title of Chief Executive Officer (Warden/OIC/Superintendent)
Acting Officer-In-Charge
b6, b7C
Name and title of Reviewer-in-Charge
b6, b7C
D&D Officer, HQ/DRO
Date[sj of Review
July 12-14, 2005
Type of Review
Operational
DSpecial Assessment DOther
I:2J Headquarters

o

j
I

;

]

•

Table of Contents

DETAINEE SERVICES STANDARDS

(SECTION I)

•

..•...•..•. _..................................................... 3

ACCESS TO LEGAL MATERIALS .. . .......... ..... ... ... .. .......... .... .. ....... . .... ..... .. ......... .. ......................... .. ................... .
AD\11SSION AND RELEASE .................... .......................................................................................................... .
CLASSIFTCATIO"l SySTEYI ................... ........ .. ...... ................ .. . .. ... ...... ... ........... ...... ....................... ..... ...... ... ..... .
CORRESPOI\DE"ICE AND OTHER MAIL ................ .... .... ......................................................... .... .. .... .. ........ ..... .
DETAll'<EE HANDBOOK .......................... .... ........... ........ ...... .... ......... .... ....... ...... ...... .. ............................ ..... ..... .
FOOD SERvrCE ......... ...................................................... .... ... ... .. ........ .... ....... ... ..... ........... ............ .......... .. ....... .
FUNDS AND PERSONAL PROPERTY ............... ... ... .. ........ ........ ......... ..... .. .... ........................................... .......... .
DETAINEE GRIEVANCE PROCEDURES .. ....... ... ... ...... .............. ..... .. .. .. .... .. ............... .. .................... ..... . .......... ..
GROUP PRESENTATIONS ON LEGAL RiGHTS .. ........ ............ ........................... .. ......................................... .. ... .
ISSUANCE AI\D EXCHANGE OF CLOTH!"lG, BEDDING. AND TOWELS ................................................. .......... .
MARRIAGE REQLJESTS ................ .... .................... .. ......... ........................... ........... ... .................................. .... .. .
NOI\-MEDICAL ESCORTED T RIPS ....................... ........... ... ......... ........................ ... .. ... ... ... ... ....... ...... .............. .
RECREATION ... .............. ............................. .... .... ... ........ ... ........ ................. .. .................................................... .
RELIGIOUS PRACTICES ........ ... ................. ... .... .. ....... ............... .. ............ .. ................ .. ...................... ...... .. .. .. .... .
ACCESS TO TELEPHONES .................. ........................ .... .. ................ ................. ....... ....... ................................ .
VISITATION ......................................................... ....................... .......... ..... .. .......................... ...... ....... .... ....... .. .
VOLU"lTARY WORK PROGRAM ................ .. ........ ... ... ................ ..... .. .... ..... .. ........ ....... .................................... ..

HEALTH SERVICES STANDARDS (SECTION II) ...................................................................... 33
HCNGER STRJKES ... .. .... .. ... .. .... ... ...... ......... ........ ............................ .......... ....................... .. ................... .... ...... ..
MEDICAL CARE .. ....... ... ..... .... ............. .. .... .. ..... .... .. ... ..... ........................................... .... .... ... .. ....... ... ... .. ..~ ....... . .
SUICIDE PREVE"ITION AND Il\TERVE1\TION ... .. .... .. ... ................................... .. ... ...... .. .. .... .. ....... .. : .. ............... ..
TERMl1\ AL ILL1\ESS, ADVANCED DIRECTIVES AND DEATH ......................................... ................................ ..

SECURITY AND CONTROL STA:\"DARDS (SECTIOI\' Ill) .......................................................40
CONTRABAND .... .. ... ................................. ~ .... ... .. .. .... ............ ........... ... .. ..... ......... .... ............. .. .... ...... ... .......... ... .
DETEl'TION FILES ............... ... ................. ....................................................................................................... ..
DISCIPLINARY POLICy .. ..... ........ ....... .. ... ....................... ... ... .. ... .. ......... . .... .. ......... ............ ................................ .
EMERGENCY PLANS .... .... ........................ ..... ........................................................................... .. ......... ... ......... .
ENVIRONMENTAL HEALTH AND SAFETy ...... .......... .... ..................... .. .. ........... .................. .. ...... ........... .. ....... ..
HOLD ROOMS 11\ DETENTION FACILITIES ....... ...... ... .................................................. ................................... ..

KEy AND LOCK CONTROL ...................................................... ...... ....... .. ....... .... .. .. ................................. ... ..... .
POPULATIO'J COUNTS ........................ .. ......... .... ............ .. ... ........ .. ..... ........ ..... .... .... ... .. .... .. .... ........ .................. .
POST ORDERS ............................................... ... .. .. ..... .......... .... ... ... .... .. ..................... ........ ... .. .................. ........ .
SECURITY INSPECTJONS ........ .. ..................... ... ....... ... .................... ...................................... ................ ........... .
SPECIAL MANAGEMENT U\JIT (ADMINISTRATIVE SEGREGATION) ....... ............................ ...... .. .. .... ......... ..... .
SPECIAL MANAGEMENT UNIT (DISCIPLINARY SEGlUcGATlON) .. . ....... ... ... ... ....... ... .......... ... .. ... .... .............. .
TOOL CO"lTROL ... .. .. ....... ........... ............................ .. .... ... ................... ... ... .. .. ... ........... ... .. .... .. ... ...... .. .... ........... .
TRA1\SPORTATION (LA"lD) ......... .. ............... ... ........... ............. .. .............. ............ .. .. .. ... ... ... ........... ..... ............ .
USE OF FORCE .............................. .... ....... ....... .. ... ..... ... .... ..... ............................................. . ........................... . .
STAFF/DETAINEE COl\.fML"-i]CATIONS .............. ..... .. ... ... ... .... ..... .. ...... .......... ........ ... ..... ................ ...... .... ........ . .
DETAINEE TRA\,JSFER STANDARD ................ ........................................................... ................. .................. .... .

F or each standard rated below Acceptable, facilities must attach a Plan of Action for bringing
operations into compliance. Each facility should examine the entire worksheet to identify areas of
improvement including those standards where an overall finding of acceptable was achieved.

Page 2
G-324A Detention Inspection Form Worksheet for JCSAs - Rev: 10/18/04

•

For each standard rated below Acceptable, facilities must attach a Plan of Action for bringing
operations into compliance. Each facility should examine the entire worksheet to identify areas of
improvement includi.'1g, those standards where an overall finding of acceptahle was achieved.

Section I
Detainee Services Standards

Page 3
G-324A Detention Inspection Form Worksheet for rGSAs - Rn-: 10/18/04

•

ACCESS TO LEGAL MATERIALS

•

Policy: Facilities holding ICE detainees shall permit detainees access to a law library, and provide legal
materials, faciiities, equipment and document copying privileges, and the opportunity to prepare legal
documents.
Components

Y

N

NA

The facility provides a designated law library for
detainee use.
The law library contains all materials listed in the
"Access to Legal Materials" Standard, Attachment A
The listing of materials is posted in the law library.
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.
In lieu offor in addition to the physical law library, ICE
detainees have access to the Lexus Nexus electronic
law library.
The Lexus Nexus Iibr~1Y. is updated and is current.
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.
There is a designated ICE or facility employee who
inspects, updates, and maintain/replace legal material
and equipment on a routine basis. The designee
properly 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
accommodated within 3 - 5 business days.
The facility permits detainees to assist other detainees,
voluntarily and free of charge, in researching and
preparinq leqal documents, consistent with security.
Staff ensures that illiterate or non-English-speaking
detainees without legal representation receive more
than access to English-language 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 re..quest.
Detainees housed in Administrative Segregation and
Disciplinary Segregation units have the same law library
access as the general population, barring security
concerns. 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.

[gJ

0

0

[gJ

0

0

r2J

0

0

r2J

0

0

r2J

0

0

0

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0

[gJ

0

0

[gJ

0

0

[gJ

0

0

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0

0

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0

0

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0

0

[gJ

0

0

[gJ

0

0

[gJ

0

0

Remarks

SEE REMARKS

Page 4
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

POli cy: Facilities holding ICE detainees shaU permit detainees access to a law library, ,and provide legal
materials, facilities, equipment and document copying privUeges, and the opportunity to prepare legal
documents.

D

o

are not

o
o

ACCESS TO LEG.A L MATERIALS

(gJ Acceptable

o Deficient

OAt-Risk

o Repeat Finding

Remarks: (Record significant facts, observations, alternate source used for verification, etc.)
There were three computers in the law library used for access to Lexus Nexus. The computers are located
behind a wall in a secured room . Inmates have access to the key board and can view the monitor behind the
wall through a window. The disks in the computers were checked for revision dates. The reviewer found that
the computers contained disks in which the Lexus Nexus information was downloaded to. The disks were
labeled as 'INSERTS". The law library officer stated that the ADP personnel down load the Lexus Nexus
information (two disks) to one disk which eliminates the need of changing floppy disks. The reviewer
suggested to the OIC that the AOP personnel may want to add a revision date to the floppy's in which the
Lexus Nexus information is downloaded to.

It should be noted that this faciltty has a complete physical law library in addrtion to the Lexus Nexus.

b6, b7C

b6, b7C

Page 5
G-324A Detention

In~pcction

Form Worksheet [or IGSAs - Rev: 101181114

•

- - -- -- :-=-..-_. _._-_ ._-_..

ADMISSION AND RELEASE

- - - ,.
-- Policy: All detainees will be admitted and released in a manner that ensures their health, safety, and welfare .
The admissions procedure will , among.other things include: medical screening: a file-based assessmenland
classification process; a body search; and a search of personal belongings, wh ich will. be inventoried;
. d?~~.~~nt:~, . a~~_safeguarded as necessary.
.
'. .
Components
Y
rif· · =-J.j.~= -===-~· ijemark~.L.
'11'1 ' processing 1ncilidesan orientation of the facility.
Facility uses a good
The orientation includes; Unacceptable activities and
processing/admission
behavior, and corresponding sanctions. How to contact
check list which is
ICE. The availability of pro bono legal services, and
approved by a supervisor
once completed .
how to pursue such services. Schedule of programs,
~
0
0
services, daily activities, including visitation, telephone
usage, mail service, religious programs, count
procedures, access to and use of the law library and
the general library; sick-call procedures, etc. , and the
detainee handbook.
Medical screenings are performed by a medical staff or
persons who have received specialized training for the
~
0
0
purpose of conducting an initial health screening.
When available, accompanying documentation is used
[8J
0
0
to identify and classify each new arrival.
All new arrivals are searched in accordance with the
Detainee Search" standard . An officer of the same
sex as the detainee conducts the search and the
f2l
0
0
search is conducted in an area that affords as much
privacy as possible.
Detainees are stripped searched only when cause has
been established and not as routine policy. Non-criminal
detainees are never strip-searched but are patted down
X
unless cause or reasonable suspicion has been
established .
The "Contraband" standard governs all personal property
searches. IGSAs/CDFs use or have a similar contraband
~
0
0
standard. Staff prepares a complete inventory of each
detainee's possessions. The detainee receives a copy.
Staff completes Form 1-387 or similar form fo r CDFs and
IGSAs for every lost or missing property claim. Facilities lZl
0
0
forward all 1-387 claims to ICE.
Detainees are issued appropriate and sufficient clothing
[8J
D
0
and beddinQ for the climatic conditions.
The facility provides and replenishes pe rsonal hygiene
items as needed. Gender-specifi c items are available . ~
0
D
ICE Detainees are not charged for these items.
All releases are coordinated with ICE.
~
0
0
Staff completes paperwork/forms for release as required . [8J
0
0

- ..

_

... . .-_. .

' "

J .•

.'

U

-.-.- •.- ........ -. ... .- -=:-=:--=-::--=:C::::--=-:-

ADMISSIONS AND RELEASE -Rating

o At·Risk

.._ _._...•
..

-

..... . ..... . . ..--

- ----..-,

o Repeat Finding

ther sources used, etc.)
b6, b7C

~ . -

b6, b7C

Page 6
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/ 18/04

•

•

CLASSIFICATION SYSTEM
... ".
_.---_.. ..... --. -----. . .. - ".--.-..
" .,. . . ,. - -."
Policy: All facilities will develop and implement a system according to which ICE detainees are classified. The
classification system will ensure that each detainee is placed in the appropriate category, physically separated
from detainees in other categories
-- - _. ."
- -,
NA
Components
Y
N
Remarks
--- - -- -- - - ------ ----- --- ------- ------- ' --- - r--- - -- --The facility has a system for classifying detainees _ In
CDFs and IGSAs, an Objective Classification System
~
0
0
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.
~
0
0
The
first-line supervisor or designated
•
classification specialist reviewing every
classification decision.
The intake/processing officer reviews work-folders, A[6J
0
0
files, etc_, to identify and classify each new arrival.
Staff use only information that is factual, and reliable to
determine classification assignments. Opinions and
[6J
0
0
unsubstantiated! unconfirmed reports may be filed but
are not used to score detainees classifications _
Level 1 and 2 only_
Housing assignments are based on classification0
0
0
level.
A detainee's classification-level does not affect his/her
recreation opportunities. Detainees recreate with
0
~
0
persons of similar classification designations
Detainee work assignments are based upon
0
0
0
classification designations _
The classification process includes
SEE REMARKS
reassessment/reclassification . For IGSA's detainees
may request reassessment between 45 and 60 days
0
C8J
0
after arrival. For CDF's detainees are re-assessed
approximately every 60 days
The classification system includes standard procedures
for processing new arrivals' appeals_ Only a
~
0
0
designated supervisor or classification specialist has
the authority to reduce a classification-level on ajlpeal.
Classification appeals are resolved within five business
[Xl
days and detainees are notified of the outcome within
0
0
10 business days_
Classification designations may be appealed to a
0
0
C8J
higher authority such as the Warden or equivalent.
The Detainee Handbook or equivalent for IGSAs
explains the classification levels, with the conditions
and restrictions applicable to each _
[Xl
~

''" -

,, - -

'-

~' -,

, ~ -------- - -- - - .- -

.,, ~

0

0

Page 7
G·324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

...

•

CLASSIFICATION SY.STEM

o Acceptable

o Deficient

OAt-Risk

o Repeat Finding

Remarks: (Record significant facts, observations, other sources used, etc.)
During the review th is reviewer pulled 25 files at random from the level 2 drawers. Of the 20 files 5 files were
found to be lacking reclassification as required by the standards. The following is a list of the A-Files found
not 10 be in compliance:

b6, b7C

Booked in on 05109/05
Booked in on 05110105
Booked in on 05/02105
Booked in on 12117103 Last reclassification on 02105104
Booked in on 12108/04 Last reclassification on 02117/05

When questioned as to the non-compliance, officers slated that the classification officer was on annual leave
and that
officer was assigned the duties during the classification officer's absence,

b6, b7C

b6, b7C

Page 8
G-324A Detention Inspeetion Form Worksllect for [GSAs - Rn: 10/18/04

_- -- --

CORRESPONDENCE AND OTHERMAIL
Policy: All facilities will ensure that detainees send and receive correspondence in a timely manner, subject to
limitations required for the safety, security, and orderly operation of the facility. Other mail will be permitted.,
subject to the same limitations. Each facility will widely distribute its guidelines concerning correspondence and
other mail.
Components

The rules for correspondence and other mail are posted
in each housing or common area or provided to each
detainee via a detainee handbook.
The facility provides key information in languages other
than English; In the language(s) spoken by significant
numbers of detainees. List any exceptions.
Incoming mail distributed to detainees within 24 hours or
1 business day after it is received and insj)ected.
Outgoing mail is delivered to the postal service within
one business day of its entering the internal mail system
.(excluding weekends and holidays).
IN CDFs: Staff maintain a logbook-recording
acceptance of priority, priority overnight, and certified
mail delivered to the facility for a detainee.
Staff do not open and inspect incoming general
correspondence and other mail (including packages and
publications) without the detainee present unless
documented and authorized in writing by the Warden or
equivalent for prevailing security reasons .
Staff does not ever read incoming general
correspondence without the Warden's prior approval.
Staff does not inspect incoming special Correspondence
for physical contraband or to verify the "special" status
of enclosures without the detainee present.
Staff are prohibited from reading or copying incoming
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
operation, endanger the reCipient or the public, or might
facilitate criminal activity.
Correspondence to a politician or to the media is
processed as special correspondence and is not read or
cOQied.
The official authorizing the rejection of incoming mail
sends written notice to the sender and the addressee.
The official authorizing censorship or rejection of
outgoing mail provides the detainee with signed written
notice.
Staff maintains a written record of every item removed
from detainee mail.
The Warden or equivalent monitors staff handling of
discovered contraband and its disposition. Records are
accurate and up to elate.

Yes

No

NA

[8]

0

0

[8]

0

0

[8]

0

0

fZI

0

0

fZI

0

0

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0

0

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0

0

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0

0

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0

0

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0

0

[gl

0

0

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0

0

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0

0

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0

0

I2J

0

0

RerT131rks

SEE REMARKS

Page 9
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

,

CORRESPONDENCE AND OTHERMAIL
.... . ::.... .' . ..

Policy: All facilities will ensure that detainees send and receiVEH::orresp6ridenteTri a timely manner, subjeetlo
limitations required for the safety, security, atid orderly operation of the facility. Other mail will be permitted,
subject to the same limitations. Each facility will widely distribute its guidelines concerning correspondence and
other mail.

The procedure for safeguarding cash removed from a
detainee protects the detainee from loss of funds and
theft. The amount of cash credited to detainee accounts
is accurate. Discrepancies are documented and
investigated. Standard procedure includes issuing a
receipt to the detainee.
Original identity documents (e.g., passports, birth
certificates) are immediately removed and forwarded to
ICE staff for placement in A-files.
Staff provides the detainee a copy of his/her identity
document(s) upon request.
Staff disposes of prohibited items found in detainee mail
in accordance with the "Control and Disposition of
Contraband" Standard or the similar prevailing policy in
IGSAs and CDFs.
Every indigent detainee has the opportunity to mail, at
government expense: Reasonable correspondence
about a legal matter: Three one ounce 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
minimum of 5 pieces of general correspondence per
week.
The facility provides writing paper, envelopes, and
pencils at no cost to ICE detainees.

~

[J

0

[8J

0

0

[8J

0

0

I:8J

0

0

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0

0

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0

0

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0

0

CORRESPONDENCE
AND OTHER :MAIL~Ra.ting
.
..

[gl Acceptable

o Deficient

D

At-Risk

o Repeat Finding

Remarks: (Record significant facts, observations, other sources used, etc.)
Staff does not maintain a log book for items removed from detainee mail. However, legal contraband is
placed in the detainess's property and is recorded on the detainee' property card. Illegal contraband is
seized and logge nd secured for future disposition. It is this reviewer's opinion that the intent of the
standard ha een et.
b6, b7C
b6, b7C

Page 10
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

__. . __

.__

n_

__

DETAINEE HANDBOOK

.

_00_.

._~

I Policy: Every 6fCwiil"deveI6pasite-specificdeta:inee handbook to serVe as an ov-erView of, and guide to, the
I detention
policies, ru les,. ~nd proc.edureSiri. . e. ff
... . ec. t at the facility. T.he h.and...b.OOk..W
...ill a.l. so
. des.cribethe .s.e... :.....
rv~ces
. :. ; .
programs, and opportumtles
various sources,
'-<?E, prlvateorganlZatu::ms;~vallablethroug.h

I:

Incl~dlrigthefacl"ty,

etc. Every detainee Will fecelveacopy ofthls handbook upofr3dmlSSIonto thefaclhty,. '- ; -

". "_ .,

Components :.

The detainee handbook is written in English and
translated into Spanish or into the next most-prevalent
language(s).
The handbook supplements the facility orientation
video where one is provided
All staff members receive a handbook and training
regarding the handbook contents.
The handbook is revised as necessary and there are
procedures in place for immediately communicating
any revisions to staff and detainees .
There an annual review of the handbook by a
designated committee or staff member.
The detainee handbook address the following issues:
• Persona'- Items permitted to be retained by the
detainee.
• Initial issue of clothes, bedding and personal
hygiene items.
The detainee handbook states in clear language basic
detainee responsibilities .
The handbook clearly outlines the methods for
classification of detainees, explains each level, and
explains the classification appeals process.
The handbook states when a medical examination will
be conducted .
The handbook describes the facility, housing units,
dayrooms , In-dorm activities and special management
units.
The handbook describes ; Official count times and
count procedures Meal times, feeding procedures,
procedures for medical or religious diets, smoking
policy, Clothing exchange schedules and if authorized,
clothes washing and drying procedures and expected
personal hygiene practices_
The handbook describe times and procedures for
obtaining disposable razors and allows that detainees
attending court will be afforded the opportunity to shave
first.
The handbook describes barber hours and hair cutting
restrictions.
The handbook describes: the telephone policy, debit
card procedures, direct and frees calls; locations of
telephones; policy when telephone demand is high: and
pohcyand procedures for emergency phone calls.
The handbook addresses religious programming .
The handbook states times and procedures for
commissary or vending machine usage . (where
available)
The handbook describes the detainee voluntary work
program.
The handbook describes the library location and hours
of operation and law library procedures and schedules.

y-

N

;NA'

[2J

0

0

121

0

0

[2J

0

0

[g!

0

0

L8l

0

0

[gJ

0

0

[g!

0

0

[SJ

0

0

[SJ

0

0

[g!

0

0

L8l

0

0

[SJ

0

0

[gJ

0

0

L8l

0

0

[SJ

0

0

fS!

0

0

[SJ

0

0

[SJ

0

0

·'- Remarks

Page 11
G-324A Detention Inspection Form Worksheet for ICSAs - Rev: 10/ 18/04

.

I

~ --- ..
____

-- ~

._ ~

-

.•.. _. _ _ __

DETAINEEHANDSDOK

--- . .

-_ _ _ .' -0__ __ .•

_._"' ___

Policy: EveryOIC wilJdevelop a site-specific detainee handbook to serve as an overvi.e wof, and guide to, the
detention policies, rules, and procedures in effect at the facility_ Th:ehandbobk will alsodescribetheservices,
programs, and opportunitiesavailablethrough various sources;iricllJdinglhe facility, ICE, private organizations,
will receive a copy of this handbook uporiadmission to the facility.
I etc_ Every detainee
.... -.
.. -- .. . -- -Components ·
Y
N
NA
Remarks.

!

The handbook describes; attorney and regular visitation
hours, policies, and Rl"oced ures.
The handbook describes the facility contraband policy_
The handbook describes the facility visiting hours and
schedule and visiting rules and regulations .
The handbook describes the correspondence policy
and procedures _
The handbook describes the detainee disciplinary policy
and procedures:
Including :
• Prohibited acts and severity scale sanctions _
• Time limits in the Disciplinary Process.
• Summary of Disciplinary Process_
The grievance section of the handbook explains all
steps in the grievance process - Including:
• Informal (if used) and formal grievance
procedures;
The
appeals process;
•
• In CDF facilities: procedures for filing an
appeal of a grievance with ICE .
• Staff/detainee availability to help during the
grievance process.
Guarantee
against staff retaliation for
•
filing/pursuing a grievance.
• How to file a complaint about officer
misconduct with the Department of Homeland
Security
The detainee handbook describes the medical sick call
procedures for general population and segregation
The handbook describes the facility recreation policy
including:
• Outdoor recreation hours.
• Indoor recreation hours.
The handbook describes the detainee dress code for
daily living ; and work assignments.
The handbook specifies the rights and responsibilities
of all detainees.

~
~

0
0
0

0
0
0

~

0

0

[2J

0

0

[2J

0

0

0

0

0

~

0

0

~

0

0

~

0

0

~

DETAINEE HANDBOOK

IX] Acceptable

D Deficient

D

At·Risk

D Repeat Finding

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

b6, b7C

b6, b7C

Page 12
G·324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

.FOOD SERVICE

,

-- .. -_.. _. .
".

'-' - ~'

Every facility will provide detainees in
i, Policy:
accordance with the highest sanitarystandc@s.
~

. '.

- "' ~ "

"

-

-

.~

...

--Components

Y

N

NA

k8J

0

0

k8J

0

0

~

0

0

~

0

0

~

0

0

~

0

0

~

0

0

0

0

[ZI

L2?J

0

0

[ZI

D

0

~

0

0

.,._ ..

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 Food Service
Administrator (FSA) determines the responsibilities of
the Food Service Staff.
The Cook Foreman 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.

•

~

,".,

..

.'- _.'- _

- -- ....-

. --

- ' . -~ . -

its care withm.ltritious and appetizing meals , prepared in
- - -- . ~>

.

".

In ICE Facilities this includes a review of the
ICE "Food Service" standard

Knife cabinets close with an approved locking device
and the on-duty cook foreman maintains control of the
key that locks the 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 (when necessary) govern the
handling of food items that pose a security threat.
Operating procedures include daily searches
(shakedowns) of detainee work areas.
The FSA monitor staffs implementation of the facility's
population counts procedures. Staff are trained in
counts 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-todate.
The Cook Foreman or equivalent 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 methbds.
• Safety features of individual productsl pieces of
equipment
• Train ing covers the safe handling of hazardous
material[s) the detainee are likely to encounter
in their work.
The Cook Foreman documents all training in individual
detainee detention files.
Detainees at CDFs are paid in accordance with the
"Voluntary Work Program" standard. Detainee workers
at IGSAs are subject to local and State rules and
regulations regardinQ detainee pay.

R¢l'i1arks:;;

Conducted by AKAL.

Training records seen.

Training records seen.

k8J

0

0

~

0

0

Observed by reviewer.
Facility is an SPC.

0

0

fZl

Page 13
G-324A Detention Inspection Form Worksheet for ICSAs - Rev: 10/18/04

".'

..
. "

"

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

.....•.

__ ._ -----_

..

--

.. . .. ...

..

_-_.....

•
. ..

.. .
~

. . _--- . .
FOOD ..SERVICE
__ ._ __'___

- - -- ~-

.... _" ...__ ... _. _·._. __ __ _

~ ··_~

_ ~.

'

_~

_ m. _

"

-- -

'

_

--

..-. .

' _'~ "

•

______,__

Policy: Every facility wilLprovide detainees in its care with nutritious arid appetizing meals; prepared in
accordance with the highestsahitary$tandards.
.--...

Components
Detainees are served at least two hot meals every day.
No more than 14 hours elapse between the last meal
served and the first meal of the followina dc!y.
For cafeteria style operations, 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 nutritional
analysis of every master-cycle menu planned.
The FSA has established procedures to ensure that
items on the master-cycle menu are prepared and
presented according to approved recipes.
The Cook Foreman 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 daily allowances (RDAs).
• Staff routinely provides hot water for instant
beverages and foods .
Common-fare meals are served with:
0
Disposable plates and utensils.
0
Reusable plates and utensils.
0
• Staff use separate cutting boards , knives,
spoons, scoops, etc., to prepare the common fare diet items.
A supervisor at the command level must approve a
detainee's removal from the Common-Fare Program.
The Warden , in conjunction with the chaplain and/or
local religious leaders, provide the FSA a schedule of
the ceremonial meals for the following calendar year.

Y

N

NA

~

0

0

0

0

~

~

0

0

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0

0

rzI

0

0

~

0

0

rzI

0

0

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0

0

~

0

0

rgj

0

0

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0

0

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0

0

. ,, ' _

.•

"

Remarks

Not a self serve
operation .

Observed by reviewer.

Page 14
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

r

i·Policy:

•

•

FOOD SERVICE

detaiti~es

~-~- '.

,...- - --, - - ~. - - ---

Every facility will provide
ihits care with nutritious and <appetizing meals, prepared in
accordance with the highest sanitary standards:
--.-

Components

The common-fare program accommodates detainees
abstaining from particular foods or fasting for religious
purposes at prescribed times of the year.
• Muslims fasting during Ramadan receive their
meals after sundown.
• Jews who observe Passover but do not
participate in the Common-Fare Program
receive the same Kosher-for- Passover meals
as those who do participate.
• Main-line offerings include one meatless meal
(lunch or dinner) on Ash Wednesday and
Fridays during Lent.
The food service program addresses medical diets.

' -"

Y

N

NA

I2?J

0

0

I2?J

0

0

satellite-feeding programs follow guidelines for proper
sanitation.

0

0

I2?J

Hot and cold foods are maintained at the prescribed .
"safe" temperature(s) as served .

[gJ

0

All meals provided in nutritionally adequate portions.

[gJ

0

0
0

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

[8J

0

0

[gJ

0

0

[8J

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 working in the food service department
complies with food safety and sanitation requirements.
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 Warden
or designated department head and corrective action is
scheduled and completed
Standard procedure includes checking and
documenting temperatures of an dishwashing
machines after each meal.
Staff documents the results of every refrigerator!
freezer temperature check.
The cleaning schedule for each food service area is
conspicuously posted.
Procedures include inspecting all incoming food
shipments for damage, contamination , and pest
infestation.
Storage areas are locked when not in use.

~

0

0

~

0

0

[2J

0

0

0

[2J

0

I2?J

0

0

I2?J

0

0

~

0

0

[gl

0

0

. . ..

Remarks

I

No satellite feeding .

Conducted by Cook
Supervisor. Observed
inspection memos
completed by Cook
Supervisor.
Health & Safety inspe
31/04 , by b6, b7C
b6, b7C
CSM

SEE REMARKS.

Page 15
C-324A Detention Tnspection Form Worksheet for ICSAs - Rev: 10/18/04

•
IZI Acceptable

o Deficient

FOOD SERVICE

o

Al-Risk

o Repeat Deficiency

Remarks: (Record significant facts, observations, other sources used, etc.)
The dishwashing room at the facility is currently under construction due to plumbing and drainage problems.
The facility uses Styrofoam plates, paper cups and plastic utensils. Cooking equipment and utensils are
washed using the three sink method as described in the Standard.
The facility currently has a staff of 10 employees' in the kitchen. Due to budget constraints, yearly training
has not been available from outside sources. In May of 2005, the FSA implemented a video training system
which exceeds the standard. Staff is required to complete the video training system yearly. Volunteer
workers are also trained with the video system.
The training records of the kitchen staff were checked of which 6 have completed the training and 4 are in the
process.
The reviewer observed recording device's used in the refrigeration units which continuously record
temperature levels and their duration which is very useful during power outages.
The kitchen staff is to be commended on their successful operation.

b6, b7C

b6, b7C

Page 16
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

•

•

FUNDS AND PERSONAL PROPERTY .

Policy: All facilities will implement procedures to control and safeguarddetCiinees'personalproperty.
Procedures will provide for the secure stdrageof funds, valuables, baggage and otherpel sonalproperty; the
documentation and receiptingof surrendered property; and the initialahd regularly scheduled inventorying of all ,'
funds , valuables, and other property.
DStandardNA:(IGSA ONLY)Check this box if aI/ ICE detainee Funds, Valuables'aridPrope.r tYare .
.
handled only by the ICE Field Office or Si.ib~fficein controloftM<letai.ne~9a$e~
.... .
Components
Detainee funds and valuables are properly separated
and stored away. Detainee funds and valuables are
accessible to desiQnated supervisoC(SL 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). For
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
COEO 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 attempts to notify an out-processed detainee
that he/she left property in the facility.
• By sending written notice to the detainee's last
known address;
• Via certified mail:
• The notice state that the detainee has 30 days
in which to claim the property, after which it will
be considered abandoned.
The facility disposes of abandoned property in
accordance with written procedures.
:
• If a CDFIIGSA facility, written procedure
requires the prompt forwarding of abandoned
~rol2ertl to ICE.

Yes

No

NA

~

0

0

~

0

0

rEl

0

0

!Sl

0

0

~

0

0

0

0

0

fZl

0

0

fZl

0

0

fZl I 0

D

0

0

D

1Z1

0

0

..

Remarks '

Page 17
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/0 4

•
~ Acceptable

•

FUNDS AND PERSONAL PROPERTY

o Deficient

OAt-Risk

o Repeat Finding

rd significant fa s, observations, other sources used, etc.)

b6, b7C

b6, b7C

RECOMMENDATION: Currently the method of conducting the weekly audit of the detainee funds is to count
the funds and match the amount to the total of the G-589s. Example, there are 146 G-589s totaling
$12,000.00 and the money is counted to ensure there is $12,000 .00 in cash. The problem is that there is no
record of exactly how many G-589s are suppose to be present. If one was missing, it would not be known
until the detainee was getting cash off his books. There would be better accountability to have a logbook
recording the G-589s in number order and then verifying the G-589 numbers with the numbers in a logbook
of the detainees in custody at the facility. On the audit, there is no need to verify the amount of money; the
shift supervisors count the money every shift change . The number of G-589s on hand need to be verified with
the number of G-589s for the detainees still in custody .

Page 18
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: JO/18/04

•

GROUPt.EGAL RIGHTS PRESENTATIONS

I

Policy: Facilities housing ICE detainees. shall permit authorized persons to make presentatibnstbgroupsdf
detainees for the purpose of informingth¢m of U.S. immigration taw and procedures, consistent with the
security and orderly operation ofea(;h facility. ICE encourages such>presentations, which instruct detainees
.
about the immigration system and their right$: and options Within it.
i:gjCheckhere if No Group Prese~ta:tionswere conductedwithin the past 12months,MarkStan#~t'das
Atcaptabli:!Qverall and continueQiiwithhext portion of worksheet.
.
_ _

_

•• _

__ m

Components .
The Field Office is responsive to requests by attorneys
and accredited representatives for group presentations.
Upon receipt of concurrence by the Field Office Director.
the facility or authorized ICE Field Office ensures proper
notification to attorneys or accredited representatives in
a timely manner.
The facility follows policy and procedure when rejecting
or requesting modifications to objectionable material
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
are available and accessible.
Documentation is submitted and maintained when any
detainee is denied permission to attend a presentation
and the reason(s) for the denial.
When the number of detainees allowed to attend a
presentation is limited , the facility allows a sufficient
number of presentations so that all detainees signed up
may attend.
Detainees in segregation, unable to attend for security
reasons may request separate sessions with presenters.
Such requests are documented.
Interpreters are admitted when necessary to assist
attorneys and other legal representatives .
Presenters are afforded a minimum of one hour to make
the presentation and to conduct a question-and-answer
session.
Staff permits presenters to distribute ICE-approved
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
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 disignee: and, the reasons for suspension are
documented. The Headquarters Office for Detention
and Removal, Field Operations and Detention
management Division is notified when a group or
individual is suspended from making presentations.
The facility plays ICE-approved videotaped
presentations on legal rights, at regular opportunities at
the request of outside organizations.
A copy of the Group Legal Rights Presentation pol icy,
including attachments, is available to detainees upon
request

Yes .·'

0

NA
0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

C

0

0

No

...

.

Remark~
..

Page 19
C-324A Detention .Inspection Form Worksheet for IGSAs - Rev: 10/18/04

-

- ~

.

__ . .-

•

•

GROUP LE.G AL RIGHTS PRESENTATIONS - Ratin

[8J Acceptable

o Deficient

OAt-Risk

o Repeat Finding

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

Per the Recreation Specialist. no Group Presentations were conducted in the past 12 months. The
Recreation
'alist is responsibly for the law library and group presentations.

b6, b7C

b6, b7C

Page 20
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

DETAINEE GRIEVANCE PROCEDURES
p-ro-c-e--:d-u-re-s--:-:(s::--O::-:::CP--'S)":-'-=-fo~'r-a--:-ddressing
. Policy: Every facilitY will develop and implement standa'rd ope-ra-t-:Cin'-g. detainee grievances in timely fashion . Each step in the process will occur within the prescribed time frame.
Among other things, a grievance wil.lbe processed~ investigatedrand decided (subject to appeal) in accordance
with the SOPs; a grievance committee will convene 'as providedirtthe SOPs. Standard procedure will include .
providing the detainee witli awritlen response to any formal grievancejWhich will inClude the basis for the !
decision. The facility will also establfsh standard procedures fdthandling emergencygrieVCit'lCes.> All
grievances will receive superVisor'yreview. Reprisal againslthefiler of agrievancewill notbetoJerated: . ..
_..

.

. .. '.. ': "'-

Components

Y

Written procedures provide for the informal resolution
of oral grievances (Not mandatory) .
• If yes, the detainee has up to five days within
which to make his/her 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 faci lity staff when preparing a grievance.
• Illiterate, disabled , or non-English-speaking
detainees receive special assistance when
necessary.
Every member of the staff knows how to identify
emergency grievances, including the procedures for
expediting them .
There are documented or substantiated cases of staff
harassing, disciplining , penalizing, or otherwise
retaliating against a detainee who lodges a complaint.
• If yes , explain.
Procedures include maintaining a Detainee Grievance
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 CDFIIGSA
facility, to ICE.

•

._--

. ' .

--:-~' c '

NNA '
_ ... -

81

0

D

[8]

0

D

[ZJ

D

0

0

I2?J

0

[3J

0

0

[3J

0

0

.. ..

' .

..

:··Remarks ..·.

DETAINEE GRIEVANCE PROCEDURES

[8J Acceptable

o Deficient

OAt-Risk

o Repeat Finding

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

b6, b7C

b6, b7C

Page 21
G-324A Detention Inspection Form Worksheet for rCSAs - Rev: 10118/04

.

. .

---

ISSUANCE AND EXCHANGE OF CLOTHING, BEDDING, AND TOWELS .

a~I~~~I;i;i-~S

.

. ...... .

cl~an

beddingi Unensand;~~~

No

Remarks, ..

- P-O-Jj-CY-:I-C-E-r- e-q-U-ir-e-s -that
housing ICE detainees provide
clothing ,
to every ICE detainee upon arrivaL Further, facilities shall provide ICE detainees w ith regill~ [ eXChaJ'1~~SOf l
clothfOg linens and towels for as long asthey rematnlndetenbon
.
..... .......... .

. Yes
... ... _ ---_ ... - "--"- _
.- _.._._-_. Components
The facility has a policy and procedure for the regular
issuance and exchange of clothing , bedding, linens and
[8J
towels.
The
supply
of
these
items
exceeds
the
•
minimum required for the number of detainees.
All new detainees are issued clean , temperatureappropriate, presentable cloth ing duri ng in-processing .
Detainees receive
• One uniform shirt and one pair of uniform pants [8J
or one jumpsuit.
• One pair of socks .
• One pair of underwear (Daily change).
• One pair of facility -issued footwear.
Additional clothing is available for chang ing weather
[8J
conditions or is seasonally appropriate .
New detainees are issued clean bedding, linens and
towel. They receive at a minimum :
• One mattress
• One blanket
[8J
• Two sheets
One
pillowcase
•
• One towel
• Additional blankets are issued based on local
weather conditions.
Detainees assigned to special work areas are clothed in
[8J
accordance with the requirements of the job.
Detainees are provided clean clothing , linen and towels.
• Socks and undergarments - exchanged daily.
• Outer garments - twice weekly.
~
• Sheets - weekly.
• Towels - weekly.
• Pillowcases - weekly.
Food service detainee volunteer workers permitted to
~
exchange outer garments daily.
Volunteer detainee workers are permitted to exchanges
~
of outer Qarments more frequently.

I

-

NA
- .. - .--- -

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

ISSUANCE AND EXCHANGE OFCLOTHING,BEDDlNG, AND TOWELS - Rating

[;2J Acceptable

o Deficient

OAt-Risk

o Repeat Finding

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

b6, b7C

b6, b7C

Page 22
G-324A Detcntion Inspcction Form Worksheet for JGSAs - Rev: 10/18/04

.

_C·. _. _ _

I

.••. MARRIAGE: REQUESTS
.~

.

.~

. ... . .

.

Policy: All detainee marriage requests:will receive case-by-case conside!n':ition fronilCE management.
'Compon-ents
.
Y ····' N
NA
Ren1a.rks
--~-I

--the-"Fleld Offic-e considers detainee marriage requests·-----

o o
o o
o o
o o
o o
o o
o o

on a case-by-case basis.
The Field Office Director reviews every marriage
request rejected by a Warden/OIG 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,
confirmin~ marital intent.
The Warden/OIC provides a written copy of his/her
decision to the detainee and his/her legal representative.
When permission is denied, the Warden/OIC states the
basis for his/her decision.
The Warden/OIC provides the detainee with a place and
time to make weddin~ arranqements.
MARRIAGE REQUESTS
~ Acceptable

D

D

Deficient

At-Risk

o Repeat Finding

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

b6, b7C

b6, b7C

..

Page 23
G-324A Detention Inspection Form Worksheet for JGSAs - Rev: ]0/18/04

NON-MEDICAL EMERGENCY ESCORTED TRIPS
Policy: The 1m migration and C usto ms Enforcement (I CE)may provide d~tai heeswithstaff"escortegfri ps into
the community for the purpose of visiting critically ill niembersof thedefainee'simmediatefamily, or for
attending funerals.

cgj Standard NA: Check this .boxifalltCE Non-Medical Emergency Escorted Trips~rehandte'donlyby ··
the ICE Field Office or Sub.,.Office iri control of the detainee case. .
.
Components

Yes

The Warden/OIC considers and approves, on a caseby-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 CDFIIGSA facility notifies ICE of all detainee
requests for non-medical escorts.
The Field Office Director is the approving official for
non-medical 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 supervision required.
Detainees who require overnight housing are placed in
approved IGSA facilities.
Each escort includes at least two officers.
• The detainee remains under constant, direct
visual supervision of escorting 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
I
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 family 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 return to the
facility of any detainee who violates trip rules

I

No

NA

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

i

I

Remarks

0

-----L

Page 24
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

....

NON MEDICALEMERGENGYESCORT

[;gj Acceptable

o Deficient

OAt-Risk

o Repeat Finding

..AT,=-urd significant facts. observations, other sources used, etc.)

b6, b7C

b6, b7C

Page 25
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

. ,!

RECREATION

Policy: It is ICE: policy to provide access.to recreational prcgramsa(1d activities toaIlICE{fet~iriees,to ·the.
extent possible, undercdriditions of securitY aM supervisibh;that protect their safety and w~mare.
Compohents
YN
NA
Rema"ks .....•..... . . . . . .

. . . .>'

Does the facil ity provide:
IZl
0
0
• An indoor recreation program?
• An outdoor recreation program?
A recreational specialist {for facilities with more than 350
detainees} tailors the program activities and offerings to
IZl
0
0
the detainee population.
Regular maintenance keeps recreational facilities and
IZl
0
0
equipment in good condition .
The recreational specialist or trained equivalent
IZl
0
0
supervises detainee recreation workers.
The recreational specialist or trainee equivalent
oversees recreation programs for Special Management
IZl
0
0
Unit and special-needs detainees.
Dayrooms offer sedentary activities, e.g., board games,
IZl
0
0
cards , television.
Outside activities are restricted to limited-contact sports
IZl
0
0
Each detainee has the opportunity to participate in daily
0
0
IZl
recreation.
Detainees have access to recreation activities outside
the housing units for at least one hour daily, 5 days a
0
0
IZl
week .
Staff checks all items for damage and condition when
[8J
0
0
equipment is returned .
Staff conducts searches of recreation areas before and
IZl
0
0
after use.
[8J
All recreation areas under constant staff supervision .
0
0
Supervising staff is equipped with radios.
IZl
0
0
The facility provides detainees in the SMU at least one
hour of outdoor recreation time daily. five times per
D 0
~
week.
Detainees in disciplinary/administrative segregation
receive a written explanation when a panel revokes
0
0
IZl
:
his/her recreation privileges.
Special programs or religious activities are available to
L8l
D 0
detainees.
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 outdoor recreation is offer.e d checkthisbox. No further information is required When outdoor
recreation is offered.
If the facility has no outside recreation , are detainees
considered for transfer after six months?
0
D
0
• If yes , written procedures ensure timely review
of all eligible detainees.
Gase officers make written transfer recommendations
0
0
0
about every six-month detainee to the OIG.
The OIG documents all detainee-transfer decisions,
0
0
0
whether yes or no.
The detainee's written decision for or against an offered
0
0
0
transfer documented in his/her A-file .

o
o

o

o
o

Page 26
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10118/04

RECREATION

Policy: It is ICE policy to provide access to recreational programs and activities to alilCE detainees, tothe
extent possible, uhderconditions of security and supervisiCihthat protect their safety and welfare.
..•.• .••••••.•.••
Staff notifies the detainee's legal representative of
0
0
0
his/her decision to accept/decline a transfer.
If no recreation is available, the ICE District routinely
0
0
0
review transfer eliQibility 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
0
written determination of the detainee's.ineligibility for
transfer.
The detainee's legal representative is notified of the
0
0
0
detainee'slOIC's decision.
RECREATION

l8:J Acceptable
e

b6, b7C

o Deficient

OAt-Risk

o Repeat Finding

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

b6, b7C

Page 27
C-324A Detention inspection Form Worksheet for ICSAs - Rev: 10/ 18/04

.'.

: .. .,'

RELIGIOUS PRACTICES >."

." :c:.:

Policy: Facilities will provide ICE detainees ,Of all faiths with reasonable. and equitable opportunities t tr

I participate in the practicesoftheir faith , iirnitedbhly by the constraints of safety, security, the ordertyoperatiOn~f
of the facility arid budgetary considerations.

,

y

Components

Detainees are allowed to engage in religious services.
Space is available for detainees to conduct religious
services.
The facility allows detainees to observe the major "holy
days" of their religious faith .
• List any exceptions.
The facility accommodates recognized holy-day
observances by:
• Providing special meals, consistent with dietary
restrictions.
• Honoring fasting requirements.
• Facilitating religious services.
• Allowing activity restrictions.
Each detainee is allowed religious items in his/her
immediate possession.
Volunteer's credentials are checked and verified before
allowing Q.articipation 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 safet'. and securLtyof the facility.

..

N

Remarks

NA

r2J
r2J

0
0

0
0

r2J

0

0

[2J

0

0

[2J

0

0

[2J

0

0

[Xl

0

0

[Xl

0

0

-- . -' - - ' ~

. ____. _ _. __ .

:. ··, RELIGIOUS PRACTICES

[gj Acceptable

o Deficient

OAt-Risk

o Repeat Finding

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

b6, b7C

b6, b7C

Page 28
G-324A DctClllion Inspection Form Worksheet for IGSAs - Rev: 10/18/04

' ,>'

~L C'J:.

DETAINEE TELEPHONE ACCESS

<

Policy: All facilities housil1glCEdetaineeswill permit detainees' reasonableaf'lde~uitable access to
.
.
..
telephones.
.. :: .

y

Components

N

NA

(8J

0

0

(8J

!2J

0
0

0
0

!2J

0

0

(8J

0

0

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

(8J

0

0

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

!2J

0

0

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

!2J

0

0

(8l

0

0

0

0

0

(8l

(8J

0
0

0
0

0

0

!2J

(8J

0

0

[8J

0

0

0

[8J

[2J

0

0
0

(8J

0

0

!2J

0

0

(8l

0

0

!2J

0

0

[2J

0

0

Detainees are allowed access to telephones during
established facility waking hours.
Upon admittance. detainees are made aware of the
facility's telephone accesspolicy.
Access rules are posted in housing units.
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.
Special 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 request by a detainee.
No restrictions are placed on detainees attempting to
contact attomeys and legal service providers who are
on the approved "Free Legal Services Lisf.
Special arrangements are made to allow detainees to
speak by telephone with an immediate family member
detained in another Facility.
Any telephone 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 consultation calls.
Detainees in disciplinary segregation are allowed
phone calls to consular/embassy officials.
Detainees in disciplinary segregation are allowed
phone calls for family emergencies.

.

Remarks

Page 29
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/ 18/04

..

DETAINEE TELEPHONE ACCESS

•

Policy: All facilities housing ICE detainees will permit detainees'reasonable and equitable acces$·to
.....
telephones.
.. ..:,. :, :.:-::'
Remarks ·C.:'. . -::<.
Components
Y
N
NA

Detainees in administrative segregation and protective
custody afforded the same telephoning privileges as
those in general population.
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.

I:3J

0

0
Not monitored.

0

0

rgj

DETAINEE TELEPHONE ACCESS

fSl Acceptable

o Deficient

o At·Risk

o Repeat Finding

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

INS Detention Standard, dated 06/03/00 , refers to reasons which may cause telephone use restriction. The
Standard also states the OIC may suspend telephone privileges during an emergency. The Standard
contain~/
co
nent requiring the documentation of telephone restrictions .

b6, b7C

b6, b7C

Page 30
G·324A Detention Inspection Form Worksheet for IGSAs - Rey: ] 0/]8/04

•

VISITATION

Policy: ICE s~allpermitdetainees to visitwith family, friends, legal representatives, special interest groups and
the news medIa.
'.
.'
..
Components

Y

N

NA

!8J

0

0

!8J

0

0

The visitation schedule and rules are available to the
public.

l~l

0

0

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

[SI

0

0

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

[SI

A general visitation log is maintained.

[SI

0
0

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

[SI

A visitor dress code is available to the public.

[SI

Visitors are searched and identified according to
standard requirements.

[gj

0
0
0
0
0

The requirement on visitation by minors is complied
with.

[gj

0

0

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.

0

0

[gj

0

0

!2l

[gj

0
0

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

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.

0
0
0

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

[gj

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.

!2l

0

0

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

[gj

0

0

0

0

0

~

0

0

0

0

[gj

[gj

0

0

(2)

0

0

Private consultation rooms are available for attorney
meetings. There is a mechanism for the detainee and
his/her representative to exchange documents.
There are written procedures governing detainee
searches.
When strip searches are required after every contact
visit with a legal representative, the facility provides an
option for non-contact visits with legal representatives.
Prior to each visit, legal service providers and
assistants are identified per the standard .
The current list of pro bono legal organizations is
posted in the detainee housing areas and other
appropriate areas .

Remarks

No contact visits.

Page 3 1
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

•

VISITATION

::. , . ...

Policy: ICE shall permit detainees tovisitwith family, friends, legal representatives, specialinterestgroups~Dd '
.. :::: ......
the news media.
The decision to permit or deny a tour is not delegated
below the level of Field Office Director.

~

0

I 0

Provisions for NGO visitation as stated in the Detention
Standards are complied with .

~

0

0

Law enforcement officials, requesting to visit with a
detainee, are referred to the ICE Field Office for
approval.

~

0

i

Former detainees or aliens in proceedings, requesting
to visit with a detainee, are referred to the OIC or ICE
Field Office.

~

0

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

~

0

I

0

I

0

i

0

VISITATION

f2J Acceptable
..I-R~"lCri

b6, b7C

o Deficient

o At·Risk

o Repeat Finding

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

b6, b7C

Page 32
G-324A Detention Inspection Form Worksbeet for IGSAs - Rev: 10/18/04

VOLUNTARY WORK PROGRAM

•

Policy: In every facility offering a voluntary work program , ICE detainees willhavetheopportun itytowork and
earn money by participating . While hOt legally required, ICE affords detaineeWorkefsbasicOccupational ·
Safety and Health Administration (OSHA) protections.

o

..

Check here if ICE detainees~r~notalJthorized to workatthe IGSAfacility. Mark NAon Form G.
324A, page 3 and move to nexts.e ttion.
.

y
Components. ..
Does the facility have a voluntary work program?
I t8l
• Do ICE detainees participate?
Detainee housekeeping meets neatness and cleanliness
t8l
standards.
Detainees have the opportunity to participate in special I
details, however, are never allowed to work outside the I ~
secure perimeter.
Written procedures govern selection of detainees for the I
Voluntary Work Program.
:
• The same procedures apply for replacement [g)
workers as for "new" workers.
• Staff follows written procedures.
Where possible, physically and mentally challenged
[g)
detainees participate in the program.
The facility complies with work-hour requirements for
detainees, not exceeding:
[g)
•
Eight hours a day.
• Forty hours a week.
Detainee volunteers generally work according to fixed
[ZJ
schedule.
If a detainee is removed from a work detail. staff places
the written justification for the action in the detainee's
0
detention file.
Staff, in accordance with written procedure, ensures that
detainee volunteers understand their responsibil ities as
0
workers before they join the work program.
The voluntary work program meets:
• OSHA standards
0
• NFPA standards
• ACA standards
Medical staff screens and formally certifies detainee food
service volunteers.
0
• Before the assignment begins
• As a matter of written procedure
Detainees receive safety equipmenU training sufficient for
0
the assignment
Proper procedure is followed when an ICE detainee is
I:8l
injured on the job

!

I

I

N

. filA

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

Remarks

Page 33
G-324A Det ention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

VOLUNTARY WORK PROGRAM
I

i
I

~ Acceptable
Remarks: (

b6, b7C

o Deficient

OAt-RisK

•

.: ..

o Repeat Finding

significant facts, observations, other sources used, etc)

b6, b7C

Page 34
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

..

Section II
Health Services
Standards

•

Page 35
G~324A

Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

,

I"

I Poiicy:

•

FOOD SERVICE

detaii1¢~s

Every facility will provide
ihits care with nutritious and appetizing meals, prepared in
accordance with the highest sanitary standards:
.- ...
.- . .
- ..Components
Y
N
NA
Remarks
- ,

The common-fare program accommodates detainees
abstaining from particular foods or fasting for religious
purposes at prescribed times of the yeaL
• Muslims fasting during Ramadan receive their
meals after sundown .
• Jews who observe Passover but do not
participate in the Common-Fare Program
receive the same Kosher-for- Passover meals
as those who do participate.
• Main-line offerings include one meatless meal
(lunch or dinner) on Ash Wednesday and
Fridays during Lent.
The food service program addresses medical diets.

I:8J

0

0

~

0

0

satellite-feeding programs follow guidelines for proper
sanitation.

0

0

~

Hot and cold foods are maintained at the prescribed ,
"safe" temperature(s) as served.

[8J

0

0

All meals provided in nutritionally adequate portions.

[8J

0

0

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

[8J

0

0

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 working in the food service department
complies with food safety and sanitation requirements.
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 Warden
or designated department head and corrective action is
scheduled and completed.
Standard procedure includes checking and
documenting temperatures of all dishwashing
machines after each meal.
Staff documents the results of every refrigeratorl
freezer temperature check.
The cleaning schedule for each food service area is
conspicuously posted.
Procedures include inspecting all incoming food
shipments for damage, contamination , and pest
infestation.
Storage areas are locked when not in use.

0

0

0

~

0

0

~

0

0

0

[8J

0

[8J

0

0

~

0

0

~

0

0

0

0

0

' -

,

No satellite feeding.

Conducted by Cook
Supervisor. Observed
inspection memos
completed by Cook
Supervisor.
Health & Safety inspection
report, 08/31/04, by b6, b7C
, CSM
b6, b7C

SEE REMARKS.

Page 15
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: t 0118/04

•
[gJ Acceptable

o Deficient

.FOOD SERVICE .

•

OAt-Risk

o Repeat Deficiency

Remarks: (Record significant facts, obseTvations, other sources used, etc.)
The dishwashing room at the facility is currently under construction due to plumbing and drainage problems.
The facility uses Styrofoam plates, paper cups and plastic utensils. Cooking equipment and utensils are
washed using the three sink method as described in the Standard.
The facility currently has a staff of 10 employees' in the kitchen. Due to budget constraints, yearly training
has not been available from outside sources. In May of 2005, the FSA implemented a video training system
which exceeds the standard. Staff is required to complete the video training system yearly. Volunteer
workers are also trained with the video system.
The training records of the kitchen staff were checked of which 6 have completed the training and 4 are in the
process.
The reviewer observed recording device's used in the refrigeration units which continuously record
temperature levels and their duration which is very useful during power outages.
The kitchen staff is to be commended on their successful operation.

b6, b7C

b6, b7C

Page 16
G-324A Detention Inspection form Worksheet for IGSAs - Re,,: 10/18/04

•

•

FUNDS AND PERSONAL PROPERTY

Policy: All facilities will implement procedures to control and safeguatddetaineEiS' personal .property.
Procedures will provide for the secure storage of funds, valuables, baggageandotherpersonaLproperty; the
documentation and receipting of surrendered property; and the initial and regularly scheduled invent6ryingofall
funds , valuables, and other property
.
D .StandardNA:(IGSA ONLY)Check thiS box if all ICE detainee Funds, VahJablesaridPropenyari
.h andled only by the ICE Field Office or Sub-OfficeihcontrdIOf"t~~detaifle~~<i~e~
..
No
NA
Yes
Components _~
Remarks
Detainee funds and valuables are properly separated
and stored away. Detainee funds and valuables are
0
LR1
0
accessible to designated supervisor(s) only.
Detainees' farge valuables are secured in a location
accessible to designated supervisor(s) or processing
~
0
0
staff only
Staff itemizes the baggage and personal property of
arriving detainees, including funds and valuables). For
[ZJ
0
0
IGSAs and CDFs, using a personal property inventory
form that meets the ICE standard?
Staff forwards an arriving detainee's medicine to the
[ZJ
0
0
medical staff
Staff searches arriving detainees and their personal
[2J
0
0
P!o~~t1Y for contraband.
There is a written policy for returning forgotten property
0
0
0
to detainees and staff follows procedures?
Property discrepancies are immediately reported to the
[gJ
0
0
CDEO or Chief of Security.
Staff follows written procedures when returning property
[ZJ
0
0
to detainees.
CDFIIGSA facility procedures for handling detainee
[8J I D
0
property claims are similar with the ICE standard.
The facility attempts to notify an out-processed detainee
that he/she left property in the facility.
• By sending written notice to the detainee's last
known address;
f25J
0
0
Via
certified mail;
•
• The notice state that the detainee has 30 days
I
in which to claim the property, after which it will
be considered abandoned.
The facility disposes of abandoned property in
accordance with written procedures .
0
0
~
• If a CDFIIGSA facility, written procedure
requires the prompt forwarding of abandoned
property to ICE.

I
Page 17
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

-

•
[8J Acceptable

•

FUNDS AND PERSONAL PROPERTY

D Deficient

OAt-Risk

o Repeat Finding

rd significant fa s, observations, other sources used, etc.)

b6, b7C

b6, b7C

RECOMMENDATION: Currently the method of conducting the weekly audit of the detainee funds is to count
the funds and match the amount to the total of the G-589s. Example, there are 146 G-589s totaling
$12,000.00 and the money is counted to ensure there is $12,000.00 in cash. The problem is that there is no
record of exactly how many G-589s are suppose to be present. If one was missing, it would not be known
until the detainee was getting cash off his books. There would be better accountability to have a logbook
recording the G-589s in number order and then verifying the G-589 numbers with the numbers in a logbook
of the detainees in custody at the facility . On the audit, there is no need to verify the amount of money; the
shift supervisors count the money every shift change . The number of G-589s on hand need to be verified with
the number of G-589s for the detainees still in custody.

Page 18
G-324A [)etention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

•

•

GROUP LEGAL RIGHTS PRESENTATIONS

i
I

Policy: Facilities housing ICE detainees$hall permit authorized petsonsto make presentatiOTistbgroupsof
detainees for the purpose of infQrmingthl;!m of U.S. immigration law and procedures, consistent with the
security and orderly operation ofeac;h facility. ICE encouragessuch>presentations, which instruct detainees
about the immigration system andtheir rights and options within it.
.
[3JCheckhere if No Group Prese.J:1ution~were conducted Within the past 12months' MarkStan~~t'(i.as
Ae:e:eptabll! C)verall and continti~H~nwithi1ext portion of worksheet.
. .
..
Components
Yes
No
NA
Remarks
.....
--~ . , -

The Field Office is responsive to requests by attorneys
and accredited representatives for Qroup presentations.
Upon receipt of concurrence by the Field Office Director.
the facility or authorized ICE Field Office ensures proper
notification to attorneys or accredited representatives in
a timely manner.
The facility follows policy and procedure when rejecting
or requesting modifications to objectionable material
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
are available and accessible.
Documentation is submitted and maintained when any
detainee is denied permission to attend a presentation
and the reason(s) for the denial.
When the number of detainees allowed to attend a
presentation is limited , the facility allows a sufficient
number of presentations so that all detainees signed up
may attend.
Detainees in segregation , unable to attend for security
reasons may request separate sessions with presenters.
Such requests are documented.
Interpreters are admitted when necessary to assist
attorneys and other legal representatives.
Presenters are afforded a minimum of one hour to make
the presentation and to conduct a question-and-answer
session.
Staff permits presenters to distribute ICE-approved
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
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 disignee; and. the reasons for suspension are
documented. The Headquarters Office for Detention
and Removal, Field Operations and Detention
management Division is notified when a group or
individual is suspended from making presentations.
The facility plays ICE-approved videotaped
presentations on legal rights, at regular opportunities at
the request of outside organizations.
A copy of the Group Legal Rights Presentation policy,
including attachments, is available to detainees upon
request

"._.. ._.-.. _....-

-

. ..

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

Q

0

0

Page 19
G-324A Detention Inspection Form Worksheet for lGSAs - Rev: 10/18/04

•

•

GROUP LEGAL RIGHTS PRESENTATIONS - Ratin

[g] Acceptable

o Deficient

OAt-Risk

o Repeat Finding

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

Per the Recreation Specialist, no Group Presentations were conducted in the past 12 months. The
Recreatio~,.
'alist is responsibly for the law library and group presentations.

b6, b7C

b6, b7C

Page 20
G-324A Detention Inspection Form Worli..sheet for IGSAs - Rev: 10/ 18/04

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

DETAINEE GRIEVANCE PROCEDURES

_.._..

_--_ ...-

. Policy: Every facility will develop and implement standard operating procedures (SOPs) for addressing
. detainee grievances in timely fashi6h. Each stepin the process will occur within the prescribed time frame :
Among other things, a grievance wilrb.e processed,jnvestigated, and decided (subjectto appeal) in accordahce
with the SOPs; a grievance committee will convene 'as providediri the SOPs. Standard procedure will include
providing the detainee withawrittert response to 3rlY formal grievance; which will include the basis for the '
decision. The facility wi ll also establish standard procedures for handling emergency grievances. A.II
_griev~nces will receive supervis0r')rrevi_eIN. Reprisal againstthefiler" ?f~gr!~nCeWili notfl~ 'tolei'at~(':jo

" j

Y.___ ~_ · NA ·· > ..

.. ... ._.___ _--:-_ _ C
_o_m
-:-;-p_o:-" ----.,
ents
Written procedures provide for the informal resolution
of oral grievances (Not mandatory).
•
If yes . the detainee has up to five days within
which to make his/her concern known to a
member of the staff.
Detainees have access to the grievance committee (or
equivalent in IGSA), using formal procedures.
•
Detainees may seek help from other detainees
or facility staff when preparing a grievance.
•
Illiterate, disabled , or non-English-speaking
detainees receive special assistance when
necessary.
Every member of the staff knows how to identify
emergency grievances, including the procedures for
expediting them .
There are documented or substantiated cases of staff
harassing, disciplining , penalizing , or otherwise
retaliating against a detainee who lodges a complaint.
•
If yes, explain.
Procedures include maintaining a Detainee Grievance
Log.
•
If not. an alternative acceptable record keeping
system is maintained.
•
"Nuisance compla ins" 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 CDFIIGSA
facility, to ICE.

o

o

rgJ

o

o

~

o

o

0

··· ~emarks ...···•·•·•• "__

o

r8J

o

o

rgJ

o

o
----_.j

DETAINEE GRIEVANCE PROCEDURES

t8l Acceptable

o Deficient

OAt-Risk

o Repeat Finding

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

b6, b7C

b6, b7C

Page 2 1
G-324A Detention Inspection Form Worksheet for IGSAs - Rev : 10/18/04

ISSUANCE AND EXCHANGE OF CLOTHING:SEDDING, AND TOWELS

. ..........•

-P-O-li-CY-'-' I-C-E- r-e-q-U-ir-e-s that a;l-f~~I;i~~~S housing ICE detairieesprovide clean clothing , bedding; lin~nsandt£:~l~n l
to ev'!ry ICE detainee upon arrival. Further, facilities shall provide ICE detainees with reguJarexChaJ'l~~$: of l
clothing, linens, and towels for as long as they remain In detentIOn
...•...... ...
. Remarks · .
Yes
No
NA

> ..

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 of facility-issued footwear.
Additional clothing is available for changing weather
conditions or is seasonally app!~priate.
New detainees are issued clean bedding, linens and
towel. They receive at a minimum :
•
One mattress
•
One blanket
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 - twice weekly.
•
Sheets - weekly.
•
Towels - weekly.
•
Pillowcases - weekly.
Food service detainee volunteer workers permitted to
exchange outer garments daily.
Volunteer detainee workers are permitted to exchanges
of outer gannents more frequently.

D

D

D

D

o

D

o

o

o

o

o

o

o
o

o
o

ISSUANCE AND EXCHANGE OFClOTHING,BEDDING, AND TOWELS -

r8J Acceptable

o Deficient

OAt-Risk

RitTtiQ .

o Repeat Finding

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

b6, b7C

b6, b7C

Page 22
G-324A Detention Inspection Form Worksheet for JGSAs - Rev: 10/18/04

MARRIAGE REQUESTS
Policy: All detainee marriage requests.WiIl receive case-by-case consideratioh fronilCE manage:r;nelit.
'Components
y ' ' :N
NA
Remarks
--~-j

--the Field Offic"e considers detainee mardage requests"--

on a case-by-case basis.
The Field Office Director reviews every marriage
request rejected by a Warden/OIG 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 Warden/OIG provides a written copy of his/her
decision to the detainee and his/her le~al representative.
When permission is denied, the Warden/OIG states the
basis for his/her decision.
The Warden/OIG provides the detainee with a place and
time to make wedding arrangements.

o
o
o
o
o
o
o

o

o
o
o
o
o
o

MARRIAGE REQUESTS

[gJ Acceptable

o Deficient

OAt-Risk

o Repeat Finding

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

b6, b7C

b6, b7C

.

Page 23
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

NON~MEDICAL

EMERGENCY ESCORTED TRIPS

Policy: The Immigration and Customs Enfbrcement (ICE) may proVided~taineeswith st!:lff:'-escortect]tlb~ into
the community for the purpose of vi$iting critically ill members of theti~airi~e~simrttediate f:am.ilY, or for
attending funerals.
~ Standard NA: Check this box ifalUCE Non-Medical Emergency EscortedTripsareharidfedonlyby.
the ICE Field Office or Sub-Offlce iri control of the detainee case.
.
.
"
,

Components

Yes

The Warden/OIC considers and approves, on a caseby-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 CDFItGSA facility notifies ICE of all detainee
requests for non-medical escorts.
The Field Office Director is the approving official for
non-medical 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,!=j ., the kind of supervision required
Detainees who require overnight housing are placed in
approved IGSA facilities.
Each escort includes at least two officers,
• The detainee remains under constant, direct
visual supervision of escortinq 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 family 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 return to the
facility of any detainee who violates trip rules,

No

NA

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

I

Remarks

0

Page 24
G-324A Oetention Inspection Form Worksheet for IGSAs - Re,,; 10/18/04

i :·.: "::

NON MEDICALEMERGENGYESCORT

[8J Acceptable

o Deficient

D

At-Risk

o Repeat Finding

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

b6, b7C

b6, b7C

Page 25
G-324A Detention Inspection Form Worksheet for IGSAs - Rev : 10/18/04

>RECREATION

. :1

Policy: It is ICE polity to provide access to r:ecreatibt@ programs and activities toaIiICEg~ainees;to ;th~
extent possible,undercoriditions of security arid supervisibh'that protect their safety and welfare.
... ..•. . .•.•... '

<,

CQmpo!tents
YN
NA
Remat~s
Does the facility provide:
[gJ
0
0
• An indoor recreation program?
• An outdoor recreation program?
A recreational specialist (for facilities with more than 350
[gJ
detainees) tailors the program activities and offerings to
0
0
the detainee population.
Regular maintenance keeps recreational facilities and
[gJ
0
0
equipment in good condition .
The recreational specialist or trained equivalent
[gJ
0
0
su~ervises detainee recreation workers.
The recreational specialist or trainee equivalent
oversees recreation programs for Special Management
r8l
0
0
Unit and special-needs detainees.
Dayrooms offer sedentary activities, e.g ., board games,
[gJ
0
0
cards, television.
Outside activities are restricted to limited-contact sp_orts.
r8l
0
0
Each detainee has the opportunity to participate in daily
[8J
0
0
recreation.
Detainees have access to recreation activities outside
the housing units for at least one hour daily, 5 days a
0
r8l
0
week .
Staff checks all items for damage and condition when
[8J
0
0
equipment is returned.
Staff conducts searches of recreation areas before and
[gJ
0
0
after use.
All recreation areas under constant staff supervision.
0
0
0
Supervising staff is equipped with radios.
r8l
0
0
The facility provides detainees in the SMU at least one
hour of outdoor recreation time daily. five times per
0
0
0
week.
Detainees in disciplinary/administrative segregation
i
receive a written explanation when a panel revokes
0
0
r8l
his/her recreation privileges.
Special programs or religious activities are available to
0
0
0
detainees.
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 outdoor recreation is offer.ed checkthisbox. No further information is r.equired .When OlJtdOOT ·
ree reationisoffered.
If the facility has no outside recreation , are detainees
considered for transfer after six months?
• If yes , written procedures ensure timely review
of all eli~ible detainees.
Case officers make written transfer recommendations
about every six-month detainee to the OIC.
The OIC documents all detainee-transfer decisions,
whether yes or no.
The detainee's written decision for or against an offered
transfer documented in his/her A-file .

o
o

o
o

o

o

o

o
o
o

o
o
o

o

o

o

Page 26
C-324A Detention Inspection Form Worksbeet for ICSAs - Rev: 10/18/04

RECREATION
Policy: It is ICE policy to provide access to recreational programs and activities to all ICE detainees, tottle
extentpossible; uhderconditions of security and supervisidtrthat profect their safety and welfa:re;
. 2 ~}

Staff notifies the detainee's legal representative of
his/her decision to accept/decline a transfer.
If no recreation is available. the ICE District routinely
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 OIG's
written determination of the detainee's.ineligibility for
transfer.
The detainee's legal representative is notified of the
detainee's/Ole's decision.

0

0

0

0

0

0

0

0

0

0

0

0

RECREATION

L8J Acceptable
e

b6, b7C

o Deficient

OAt-Risk

o Repeat Finding

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

b6, b7C

Page 27
C-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

•

RELIGIOUS ·PRACTICES

..

,.

. .. :.
.. .... , .

Policy: Facilities will provide ICE detainees Of all faiths with reasonable. and equitable opportunities 10'
participate in the practices of their faith, lirnitedohly by the cbhstraintsof safety, security, the orderly.operatiOns
of the facility and budgetary considerations.
. '...
Remarks
>'
.
......
y
,N
NA
Components
__ . ____ _.. _ ___.c ..__. __ .' ....:;:0.. .:::__'......
Detainees are allowed to engage in religious services.
Space is available for detainees to conduct religious
services.
The facility allows detainees to obselVe the major "holy
days" of their religious faith .
• List any exceptions.
The facility accommodates recognized holy-day
observances by:
• Providing special meals, consistent with dietary
restrictions.
• Honoring fasting requirements.
• Facilitating religious services.
• Allowing activity restrictions.
Each detainee is allowed religious items in his/her
immediate possession.
Volunteer's credentials are checked and verified before
allowing participation in detaineep!ograms.
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 securityof the facility.

[2]
[g1

0
0

0
0

[2]

0

0

[8J

0

0

[8J

0

0

[g]

0

0

~

0

0

~

0

0

. . ,RELIGIOUS PRACTICES '

r;gJ Acceptable

o Deficient

D

At-Risk

o Repeat Finding

rd significant facts, obseN8tions, other sources used, etc.)

b6, b7C

b6, b7C

Page 28
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

•

DETAINEE TELEPHONEACCESS .•....• •.. ............
.

"'

.

Policy: All facilities housir"lglCEdetaineeswill permit detainees' reasonable and equitable access to
telephones.

. ".

_

. . ..

Components

Y

N

NA

k8J

0

0

k8J
L8J

0
0

0
0

L8J

0

0

L8J

0

0

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

k8J

0

0

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

k8J

0

0

L8J

0

0

k8J

0

0

~

0

0

BJ
k8J

0
0

0
0

0

0

~

~

0

0

[8J

0

0

0

~

['g]

0

0
0

['g]

0

0

tZl

0

0

[8J

0

0

~

0

0

~

0

0

Detainees are allowed access to telephones during
established facility waking hours.
Upon admittance, detainees are made aware of the
facility's telephone access policy.
Access rules are posted in housing units.
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.

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

I

Detainees are afforded a reasonable degree of privacy
for leQal phone calls.
A procedure exists to assist a detainee who is having
trouble placinQ a confidential call.
The facility provides the detainees with the ability to
make non-collect (special access) calls.
Special 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 request by a detainee.
No restrictions are placed on detainees attempting to
contact attorneys and legal service providers who are
on the approved "Free LeQal Services Lisr.
Special arrangements are made to allow detainees to
speak by telephone with an immediate family member
detained in another Facility.
Any telephone 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 consultation calls .
Detainees in disciplinary segregation are allowed
phone calls to consu lar/embassy officials.
Detainees in disciplinary segregation are allowed
phone calis for family emergencies.

..
•••.. · ·.· ··.· ·

. •••.•

Remarks

Page 29
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

.

DETAINEE TELEPHONE ACCESS

•

Policy: All facilities housing ICE detainees will permit detainees'reasonable and equitable acc¢~$ ,t6
.. .,
telephones.
Components .
Detainees in administrative segregation and protective
custody afforded the same telephoning privileges as
those in general population.
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.

Y

N

NA

IZJ

0

D

Remarks ' .............

Not monitored.

D

0

IZJ

DETAINEI$TELEPHONE' ACCESS
~ Acceptable

o Deficient

OAt-Risk

o Repeat Finding

Remarks: (Record Significant facts, observations, other sources used, etc.)
INS Detention Standard, dated 06f03fOO , refers to reasons which may cause telephone use restriction . The
Standard also states the OIC may suspend telephone privileges during an emergency. The Standard
contain~
nent requiring the documentation of telephone restrictions .

b6, b7C

b6, b7C

Page 30
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: J 0/18/04

•

VISITATION

Policy: ICE shallperrnitdetainees to viSitWith family, friends, legal representatives , special interest groups and
the news media.

...

y

N

NA

[8J

0

0

~

0

0

The visitation schedule and rules are available to the
public.

~

0

0

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

~

0

0

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

~

A general visitation log is maintained.

~

0
0

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

~

0

A visitor dress code .is available to the public.

~

Visitors are searched and identified according to
standard requirements.

~

0
0

0
0
0
0
0

The requirement on visitation by minors is complied
with .

~

0

0

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.

0

0

[8J

0

0

[8J

[8J

0
0

Components

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

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

[8J

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.

[8J

0

0

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

f2!:J

0

0

0

0

0

~

0

0

0

0

[8J

~

0

0

[:gJ

0

0

Private consultation rooms are available for attorney
meetings. There is a mechanism for the detainee and
his/her representative to exchange documents.
There are written procedures governing detainee
searches.
When strip searches are required after every contact
visit with a legal representative, the facility provides an
option for non-contact visits with legal representatives.
Prior to each visit, legal service providers and
assistants are identified per the standard .
The current list of pro bono legal organizations is
posted in the detainee housing areas and other
appropriate areas.

'

"

Remarks

No contact visits.

Page 31
G-324A Dctcntion Inspection Form Worksheet for IGSAs - Rev: 10/t8/o4

•

VISITATION

::

-

--- :::--,_:-:-::--

Policy: ICE shall permit detainees tovisiFwith family, friends, legal representatives,specialinterestgroups'~r(j
the news media_
,~ -: ~

The decision to permit or deny a tour is not delegated
below the level of Field Office Director_

r2J

0

Provisions for NGO visitation as stated in the Detention
Standards are complied with .

r2J

0

Law enforcement officials, requesting to visit with a
detainee, are referred to the ICE Field Office for
approval.

[gJ

0

Former detainees or aliens in proceedings, requesting
to visit with a detainee. are referred to the OlC or ICE
Field Office.

r2J

0

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

[gJ

0

0
I

I
!
t

0
0
0
0

VISITATION!
~ Acceptable
:....ff'?F.l~d

b6, b7C

o Deficient

OAt-Risk

o Repeat Finding

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

b6, b7C

Page 32
G-324A Detention Inspection Form Worksbeet for IGSAs - Rev: 10/18/04

VOLUNTARY WORK PROGRAM

•
..

Policy: In every facility offeringavolulltary work program , ICE detaineeswillhavetheopportunitytowork and ··
earn money by participating . While not legally required, ICE affords detainee 'wotk~rsbas ic Occupational
Safety and Health Administration (:OSHA) protections.
.
.
..

Check here if ICE detaineeS ,are notauthorized to work~tthe IGSAfaciiity.
324A, page 3 and move to next$e~tion ;
.

D

Mark NA.oni=ormG~:
..

Componerit$>
Does the facility have a voluntary work program?
• Do ICE detainees Qarticipate?
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 Qrocedures.
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 Q.ro!:jram.
The voluntary work program meets:
• OSHA standards
• NFPA standards
• ACA standards
Medical staff screens and formally certifies detainee food
service volunteers.
• Before the assignment beg ins
• As a matter of written procedure
Detainees receive safety equipment! training sufficient for
the assiqnment
Proper procedure is followed when an ICE detainee is
injured on the job.

Y

N

INA

[2;'l

0

0

[2;'l

0

0

f2J

0

0

~

0

0

[8J

0

0

[2;'l

0

0

[gJ

0

0

[2;'l

0

0

[2;'l

0

0

~

0

0

~

0

0

[8J

0

0

~

0

0

Remarks

Page 33
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

\

I

\

VOLUNTARY WORK pROGRAM
i
I

[8J Acceptable
Remarks: (

b6, b7C

o Deficient

OAt-RisK

•

..

o Repeat Finding

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

b6, b7C

Page 34
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

--,-

Section II
Health Services
Standards

Page 35
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

HUNGER STRIKES

!

.

I Policy:

... ..... ... ....

.

All facilities will follow standiard guidelines for the medical and administrative management of ICE;/
i detainees engaging in hunger strikes. By monitoring of the health and welfare of the individual detainees.
..
facilities wilL strive to sustain their lives. .
. ..... . __._ _
.-:--.,---j
_ . .
,-.,. -.- -. . ... , .-.-- ---- .
y
Remarks
components
NA I·•. c . _.... .....
_. c- --~--c-----l
When detainee has refused food for72tiours~TUs---+---+-~·· .
PHS policy 811 updated
standard practice for staff to refer him/her to the med ical
6/05
ICE policy present
department.
"'- ".'

'-~

.

~-.

a

o

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

o

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

o
o
o

o

o
o

o o
o o
o o
o o
o o
o o
o o

Medical staff records the weight and vital signs of a
hunger-striking detainee at least once every 24 hours.
The OIC of the facility obtains a hunger striker's consent
before medical treatment.
A signed Refusal of Treatment form is required of every
detainee who rejects medical evaluation or treatment.
During a hunger strike, staff documents and provides
the hunger-striking detainee three meals a day.
Staff maintains the hunger striker's supply of drinking
water/other beverages
During a hunger strike, staff removes all food items from
the hunger striker's living area.

Detainee's admitted to
the Infirmary

See below

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

o

o

Per PHS policy - no
reference made in ICE
policy.

The medical staff has written procedures for treating
hunger strikers.

o

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

o

o
o

1 documented attempt in
the past 12 months.

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.

See below

o

o

Page 36
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

HUNGER STRIKES
~ Acceptable

o Deficient

o Repeat Finding

OAt-Risk

Remarks: (Record significant facts, observations, other sources used, etc.)
Refusal forms - 215 forms completed - 315 missing either complete documentation on form or required
signatures. 215 supportive documentation noted in SOAP notes (by providers) 315 not referenced in SOAP
notes.
Refusal Charts:

b6, b7C

eMR primary source of Medical Record Access - forms kept in Hard COPt of charts - 5/5 not currently
scanned into the eMR due to no scanner available. «(Jc\~. ~~ oLe"". t'A.A'I., 1'Al.....-l~,
115 MAR did not reflect refusal of medication per signed refusal form (marked as given but re'tusal form
signed)

'J ... ~\
~)

Training last done 2003 for all staff; 2004 2 people had training; 2005 1 person trained Plan to hold training
today at 1400 7114105.

b6, b7C
LCD
nis, RN 7-14-05
Auditor's Signature I Date

Le.02.

b6, b7C

eN

Page 37
C-324A Detention Inspection Form Worksheet for ICSAs - Rev: 10/18/04

•

.

AC,CESS TO MEDICAL CARE

Policy: Every facility will establish and maintain an accredited/accreditati0rt.-Wb[th{health program for the
..
general well-being of 'ICE detainees.·
ComponentS . "

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.
All detainees have access to and receive medical care.
The facility has access to a Managed Health Care
Coordinator.

y

.N

NA

r&I

0

0

1:81

0

0

I8l

0

0

0

0

I8l

r8I

0

0

I8l

0

0

I

~

0

0

I

~

0

0

18)

0

0

r81.

0

0

The medical staff is large enough to provide. examine, !
and treat the facility's detainee population.
The facility has sufficient space and equipment to afford
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.
The medical facility entrance includes a holding/waiting
room .
The medical facility's holding/waiting room under the
direct supervision of custOdial staff.
Detainees in the holding/waiting room
have access to a toilet and a drinking fountai n.
Medical records are kept apart from other files , They
are:
• Secured in a locked area within the medical
unit.
With
phYSical access restricted to authorized
•
medical staff.
• Procedurally. no copies made and placed in
detainee files.
Pharmaceuticals are slored in a secure area.
Medical screening ill·eludes a Tuberculosis (TB) test.
• Every arriving detainee receives a TB test.
During the admission process,
• Detainee's T B-screening does not occur more
than one business day after his/her arrival at the
facility.
• Detainees not screened are housed separate
from the general population.
All detainees receive a mental-health screening upon
arrival. It is conducted:
• By a health care provider or specially trained
officer;
• Before a detainee's assignment to a housing
unit.
The facili ty health care provider promptly reviews all 1794s (or equivalent) to identify detainees needing
medical attention,
The health care provider physically examines/assesses
arriving detainees within 14 days of admission/arrival at
the facility.

-

Remarks

.-:-::':: .

Handbook - PHS lOP

1021
CD and Mid·level
providers in clinic
daily

l
Unit locked in an area
w here detainee's do not
have access.

1:81

0

0

~

0

0

I2l

0

0

[gj

0

0

0

[gJ

0

~

0

0

•

Locked door/room/Pill
line
All detainee's are X-ray'd
upon arrival prior to being
placed in th.e general
population within 12
hours on a routine basis.

Form present in hard
copy of chart - not being
scanned into eMR.
1{1 done; 6/7 left before
day 14.; 15115 chronic
charts done

Page 38
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10118/04

ACCESS TO MEDICAL CARE

Policy: Every facility wiHestablish and ) naintain anaccredited/accreditation-worthy health .p rogram fo{ the
general well-being of ICE detainees.
Detainees in the Special Management Unit have access
to health care services.
Staff provides detainees with health- services (sick call)
request slips daily, upon request.
• Request slips are available in the languages
other than English , including every language
spoken by a sizeable number of the facility's
detainee population.
• Service-request slips are delivered in a timely
fashion to the health care provider.
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
emergencies within a 4-minute response time.
Where 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
Warden/Facility of a detainee that has special medical
needs.
A signed and dated consent form is obtained from a
detainee before medical treatment is administered .
Detainees use the 1-813 {or IGSA equivalent) to
authorize the release of confidential medical records to
outside sources.
The facility health care provider is given advance notice
_Qfior 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".

[gJ

I0

0

I

[gJ

I

0

0

[gJ

0

0

[8J

I:8J

0
0

0
0

f81

D

D

[gJ

0

0

[ZI

0

0

[gJ

0

0

[8J

0

0

~

0

0

~

0

0

[gJ

0

0

~

0

0

[8J

0

0

Rounds daily by medical
- sick call slips available
Spanish
Box available in the Mess
Hall for detainee's to
request medical attention.
Emergencies are called
into the unit by officers.

Medical Staff present in
clinic
24hrs/7days/365days
On-call schedule

3132 charts

Strong Social Worker
program (Pokr and T8)
Per policy

Page 39
C-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

I}{ Acceptable

•

ACCESS TO MEDICAL CARE

o Deficient

o Repeat Finding

o At·Risk

Remarks: (Record significant facts, observations, other sources used, etc.)
Great dental program - tool control and chemicals - sick call processes
Pharmacy with strong program - temperature log missing a few days of temperature checks.
Sick call seen within 48 hours of recieveing requests. Urgent requests seen that day/evening - remaining
are scheduled for the next day
Chronic Care noted during intake screening - scheduled to be evaluated by Mid-level within that shift or the
next morning. Urgent care seen immediately or provider on-call notified and orders received and/or they
come in.
Pill Line and Lab processes meet requirements - Staff well versed on protocols and procedures for tool
control and sharps. No deviations noted.
Refusal forms 3/5 incomplete -

b6, b7C

;

;

b6, b7C

b6, b7C

b6, b7C

A#

b6, b7C

Currently only items scanned into eMR is the Lab results - equipment not available to scan (consents, refusal
forms, consultations, or other items) 100% of 32 charts reviewed.

b6, b7C
b6, b7C

1-

b6, b7C

b6, b7C

b6, b7C
HIV charts:
chart 212 charts audited 7-13-05.

follow up education related to lab results not documented in
shown a chart 7-14-05 a chart with completed documentation.

Policies for NOS Review al/ current and documented reviewed as of 06/05. However, the majority of the
remaining policies in the LOP PHS had not been updatedlreviewed since 10/02. Cover sheet of LOP book
last signed from administrative review 3/10/04. Some policies missing the attachments.

LCDR
, RN 7-14-2005
b6, b7C
Auditor's Signature I Date

b6, b7C

Page 40
G-324A Detention 1nspection Form Worksheet for ICSAs - Rev: 10/18/04

SUICIDE PREVENTION AND

.

d

Policy: All detention staff working with ICE detainees will be trained to recognize suicide-risk indicators. Staff I
will handle potentially suitidalinaividuals with seri'sitivity, supervision, and referrals . Adinically suicidal detainee !
will receive preventive supervision and treatment:
_._--_... ... "' - -' - - "
.-- " _.- . . ..
··· Remarks .
NA · ..
Components
Y
N
.._--_. . . ,----- "".- -- ----- .
Every new staff member receives suicide-prevention
Done all staff 8/2004
training. Suicide-prevention training occurs during the
~
0
0
employee orientation program .
Copy of training provided
Train ing prepares staff to:
prepared by Social
Recognize
potentially
suicidal
behavior;
•
Worker.
Refer
potentially
suicidal
detainees,
following
•
~
0
0
facility procedures;
• Understand and apply suicide-prevention
technLques.
A health-care provider or specially trained officer
screens all detainees for suicide potential as part of the
admission process.
r2J
0
0
• Screening does not occur later than one working
day after the detainee's arrival.
Written procedures cover when and how to refer at-risk
PHS LOP 1703 revised
0
~
0 and
detainees to medical staff and procedures are followed .
reviewed 6/05
The facility has a designated isolation room for
SSU and SMU has
~
0
0
evaluation and treatment.
padded room
The designated isolation room does not contain any
structures or smaller items that could be used in a
~
0
0
suicide attemgI.
Medical staff has 8PQroved the room for this ~urpose.
0
~
0
Staff observes and documents the status of a suicide0
0
0
watch detainee at least once every_ 15 minutes
_

i

INTERV~NTION - ------ - .- .-.._- -

.,

- .~ -

- - -- -- - - -_ ._._._.. - .. . SUICIDE PREVENTION AND INTERVENTION

S

Acceptable

o Deficient

o Repeat Finding

OAt-Risk

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

4 charts reviewed
100% compliance on Q 15 minute checks
414 charts with inconsistent Q 2hours nursing noted recorded.

Strong training program with Social Worker.
1/4 charts with consent not signed by Medical Staff - given to Medical Records Clerk.
MARs noted with blank spaces (average 4 to 6 days) upon investigation these detainees noted to have left
the camp, encouraged staff to note that on MAR 's once they are removed and placed back in the chart. This
will eliminate any questions related why the medications were not given on those days verses blank boxes.

b6, b7C
LCDR
RN 7-14-2005
Auditor's Signature! Date

LC1

b6, b7C

(2.tJ

Page 41
C-324A Detention Inspection Form Worksheet for ICSAs - Rev; 10118/04

. ..
. ..
._-TERMINALIL.LNESS, ADV~NCED DIRECTIVES, AND DEATH
---- .
Policy All facilities hOlJsing ICE detainees.shall have policies and proceduresadqr~$sirtgtheissues .oftenninal ·
iIlness:orinjuryjmedicaladvanceO{j1rectives, and' detainee death, to inClude the procedures to ensure proper .
notifica.tion is p~ovidedto .I CE officials, family mem?ers and othetjnter~sted partie~ int~e event of adetai~ee
becommg tennmally III or Injuredordeath of a det.:nnee occurs. In addition, thepohcy will cover proc:eduresto
be taken if the death of a detainee occurs while in transit
.. .
.. ..... •.••..

.- '

o
•

• •

Check this box if the Jacility<doesnot accept ICE detalneeswho are severelyortertniilallYilJ.
Indicate NA in the appropriate box for this portion of the worksheet ALWAYS completeallreter@~e$
. ..•.
to detainee death and related notifications.
>.
Y ······ N
NA . "- -,, . RernaTks
Components
··
. .. . ...... _ -.. .
ICE Policies available
Detainees, who are chronically or terminally ill, are
PHS LOP 821 revised
transferred to an appropriate offsite medical facility.
0
0
!8l
6/05
Infirmary in medical who
The facility or appropriate ICE office promptly notifies
house 10 beds (4
the next of kin of the detainee's: medical condition .
!8l
0
0
Isolation rooms)
• The detainee's location .
• The limitations pJaced on visiti1}g.
There are guidelines addressing State Advanced
Directive Form for Implementing Living Wills and
Advanced Directives.
• The guidelines include instructions for detainees [gI
0
0
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
0
~
0
have aprivate attorne"y prep_are the documents.
There is a policy addressing "Do Not Resuscitate
PHS LOP 828-A
~
0
0
Orders"
A _

_

_ ___

_

_

~

_

_

• _

_

_ · ·,,·.. _

· · _ · ____

·· ~

.~

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
Department of Veterans Affairs notified.
An original or certified copy of a detainee's death
certificate is Qlaced in the subject's a-file.

,,~

~

0

0

~

0

0

[gI

0

0

!8l

0

0

!8l

0

0

r8J

0

0

C8J

0

0

C8J

0

0

.

None in camp since
approximately 2003

Page 42
G-324A Dctcntion Inspection Form Worksheet for IGSAs - Rev: 10/18/04

TERMINAL ILLNESS, APVANCED DIRECTIVE;$,
ANDDE~"fH
...
____
__ ... _ _ .... _ _
· ,~

c. ~

__ _

---,_-,--~

PolicyAII · facilitieshousitigl:C13detainees .shall:~ave policiesand··procedures addressing the.issues otterminal

illness or injury, mediCaladlt~hCeddired,ve's;anddetainee death; to include thepr6cedures to ensuteproper
notification is providedtolCEofficials, farriilylJl~rl1bers anddther interested parties in the event a detainee .
addition, thePolicywincover Pf9cedures to
becoming terniinally HI or injured or deathofadetainee occurs;
. . .
be taken if thedeathofadetainee occLirswh ilein transit.

?f

In·

.

," . ,,-

.

.

...:

... ....

.

..

o

Check thisboxifthefacil.i ty does' .,ot accept ICE detaii1eesw~()~...isiev~telYor t~i'rl(irtallynt.
Indicate NA in the appropriate bOxforlhlsportion of the wotksheetALWAYS eomplete>attre"ferences
to detainee
death and related notifications.
··
. . ..
. .
. .. - - -- ...- -- .• .- - --. >~
Componen~S:
Y
N
NA
Remarks
. >.
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.

o

o

o

o
- - - --~

TERMINAL ILLNESS;ADVANCEDDJRECTJVESjAf,JD DEATH

fi§ Acceptable

o Deficient

o At·Risk

.

o Repeat Finding

Remarks: (Record Significant facts, obselVations, other sources used, etc.)
Policies are reflective of requirements for Detention Standards - have not had any cases since approximately
2003 - unable to review charts or documentation for compliance.

LCDR
Auditor

b6, b7C

RN 7-14-2005
ate

b6, b7C

Page 43
C-324A Detention Inspection Form Worksheet for IGSAs • Rev: 10/18/04

•
Section III

Security and Control

Page 44
G-324A Detention Inspection Form Worksheet for IGSAs - Re\,; 10/18/04

•

CONTRABAND ,.

•••

Policy: All detention facilities will ensure the proper handling and disposalof allcol'ltraband. Obcu mentation of
··
.
contraband destruction is required .
...
. ..""
y
..
······ Remarks >
N
Components
NA
,<.,.
The facility follows a written procedure for handling
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 retums property not needed as evidence to the
proper authority. Written procedures cover the return of
such property.
Altered property is destroyed following documentation
and using established procedures.
Before confiscating religious items. the OIC or
designated investigator contacts a religious authority.
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 official use, e.g. training
purposes.
If yes , under specific circumstances and using
specified written procedures. Hard contraband is
secured when not in use.

~

0

0

~

0

0

~

0

0

~

0

0

l2J

0

0

[?j

0

0
I

I

0

r8J

I

0

CONTRABAND

[gJ Acceptable

o Deficient

o

At·Risk

o Repeat Finding

Remarks: (Recor1significant facts, obsefV8tions, other sources used, etc)
b6, b7c

7/14/05

Page 45
C -324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/ 18/04

!

•

•

DETENTION FILES

_ i ~:_'

.. ..
-... ,.... ... ... . .... .
.
,
.
Policy: Every facility Will create a detentionfilefor every ICEd~tainee bookedintofhefacility, excluding only
detainees scheduled to depart with~n24 hours. The detention file will containcopiesahd, in somecases, th,~
original of specified documentscdhcemil'lgthe detainee's stayihthe facility: classification sheet, m~diCat
questionnaire, property inventory sheet, disCiplinary documents, etc.
. ... ...... .

ComponentS .
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 1-77s closed-out during the
detainee's stay
• Disciplinary forms/Segregation 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 supervisors.
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 or office.
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.

:.......

.

Y

N

NA

tEl

0

0

t8J

0

0

tEl

0

0

.

Remarks ::...:'. . . .,.

Checked 15 files.

J

t2J

0

D

t2J

0

D

tEl

0

0

tEl

D

D

~

D

D

Secured in Processing,
only the Processing
Officer and SIEAn have
keys.

DETENTION FILES
~ Acceptable

o Deficient

OAt-Risk

o Repeat Finding

Remarks: (Recqrd s 'gnificant facts, observations. other sources used, etc.)
b6, b7C

7/14/05

Page 46
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

I -.-- -- '--- '

•

DISCIPLINARY POLICY

hOUSI~~ I~Edetainees~te

"

im-;~s~ di$clplineondetaihees Whos~' l:>ehaviOr is !

Policy: All facilities
authorized to
not incompliance with facHlty rules and regulations .
Components' .
Y
The facility has a written disciplinary system using
L8J
progressive levels of reviews and appeals.
The facility rules state that disciplinary action shall not
r2J
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 items are conspicuously posted in
Spanish and English or other dominate languages used
in the facility:
•
Rights and Responsibilities
•
Prohibited Acts
•
Disciplinary Severity Scale
•
Sanctions
When minor rule violations or prohibited acts occur,
informal resolutions are encouraged.
Incident reports and Notice of Charges are promptly
forwarded to the designated supervisor.
Incident reports are investigated within 24 hours of the
incident. The Unit Disciplinary Committee (UDC) or
equivalent does not convene before investigations end.
An intermediate disciplinary process is used to
adjudicate minor infractions.
A disciplinary panel (or equivalent in IGSAs) adjudicates
infractions. The panel:
•
Conducts hearings on all charges and
allegations referred by 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.

...____ . .

N

'NA

0

0

0

0

o

o

o

o
o

o

o
o
o

o
o
o
o

o

o

o
o

o
o

.J

.

Remarks

- -.-.-- ----- ...

~

-- ...

· ··· ··

These items are not
posted in the bulletin
boards. They are in the
detainee handbook,
however per the
standard, they are
suppose to be posted.

Page 47
G-324A Detention Inspection Form Worksbeet for lGSAs - Rev: 10/18/04

"-

-

-

•

•

------------=D::-:Ic=S-=C-=IP=-=-L-::IN-:-A=-=R=-:Y-=-=-PO=U:-=C7:
y : - - - -- - - - --

-

._ . . ._-, ._-

I Policy: All facilities housing ICE detainees are authorized to impos~~~~cip-line-on ~~e-~ine~-s-w-h-o~ebehaVi()rjs
not in compliance with facility rules and regulations.

'

~-----'-'.::..:..::..:...::.=:.:.:.:.c:.:=C"--o:.::.::.m..c.p.:.co.::..n'--e:.:::nc::.ts~'--'-=-=-=~-=--'-=--"c=;:=·cc.r-~Y-c-----...~N· - -·NA

The duration of punishment set by the OIC, as
recommended by the disciplinary panel does not exceed
established sanctions. The maximum time in disciplinary
segregation does not exceed 60 days for a single
offense,
Written procedures govern the handling of confidentialinformant information , Standards include criteria for
recognizing "substantial evidence"
All forms relevant to the incident, investigation,
committee/panel reports, etc " are completed and
distributed as required.

r;gJ

0

0

o

o

o

o

..
REUllarks ·- --c_.__
Disciplinary Panel
Chairman states
detainees are never
given more than 3 days
DIS time.

DISCIPUNARYPOLICY

rgJ Acceptable

o Deficient

D

At-Risk

o Repeat Finding

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

b6, b7C

7/14/05

Page 48
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

__ . _u___

•

•

EMERGENCY (CONTINGENCY)PLANS . . . .

...'. . .

.

I

~~-I~~Y All facilities holding ICE detairieeswill respond to emergencieswith'aprE:determiried standardized PI~~'t~JI

minimize the harming of human life aridthe destruction of property. Itis recommended that SPCs and CDFs¢h~r:
i~toagreement, via Memorandum. . olunde. rstanding (MOU), with federal , local and state agenc. ies to a.5$
. isfrn I
times of erlJergency.
_. . ._ ____ _ .._ _._.
_ .
.
...
Componeflts
Y
.N
NA
Remarks ••' '.
;
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 ty~e 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 applicable 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).

0

o

0
Not in Emergency Plans,
however it is in the
Detainee Handbook.

[gl

0

o
o

o
o

o

o

o

o

o

o

o

o

o

o

o

o

0

0

0

0

0

0

[gl

0

0

See Note below

Page 49
G-324A Detention lnspection Form Worksheet for IGSAs - Re,': 10/18/04

•

•

EMERGENCY (CONnNGENCY) PLANS
.

..

.

:

PolicyAILfacilities holding ICE detainees willrespond to emergencies withapred~t¢rmined$tandatdizedplan to i
minimize the harming of human life and the destruction of property It is recommendedthatSPCs and CDFs enter . I!
into agreement, via Memorandum afUnderstanding (MOU), with federal, loealano state agencies to assist in
,
times ofemergeD:s:y-'___________
Y
N.
Remarks
Componenb;
. r-J~ · I

>

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

[g1

0

0

EMER(iENCY (CONTINGENpY) PLANS

[g] Acceptable

o Deficient

OAt-Risk

o Repeat Finding

b6, b7C

7/14/05

The written plans showing the shut-off valves and switches for all utilities are excellent. The
drawings are CAD drawings of all buildings with the shut-offs clearly marked.

The CCTV control room runs mock drills every shift. They run different scenarios to be prepared for
actual incidents. The mock drills cover all possible scenarios such as bo~hreats, civil
disturbances, HAZ-MAT incident, hostage situation, etc. Excellent preparedness tool.

~

Page 50
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

•

•

ENVIRONMENTAL HEALTHAND SAFETY ······
.

. .

..

.

.

..

.

_

... _- .. .

- .

.'

.. ..

Policy: Every facility will control flammable, toxic, and .caustic materialsthrbugh~hazardous materials. .
program. The program will include; among other things, the identification and labelihg ofHazardousmaterialsi rl
: accordance with applicable stan~afcls (e ..g., National Fire protection Assodati6hlNPP,A]); identiftcationoJ
incompatible materials , and safe~hi3ndlingprocedures
. .. ... . . . ..
".
.
- .. __ _ 0. _ ., __ •

'- ' . 0 . . -._. _ _ .

Y

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 used/stored in each
section of the facility.
The manufacturer's Material Safety Data Sheet (MSDS)
file is up-to-date for every hazardous substance used.
• The files list all storage areas, and include a
plant diagram and legend.
• The MSDSs 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 MSDSs are readily accessible to staff and
detainees in the work areas.
Hazardous materials are always issued under proper
supervision .
• quantities are limited.
• Staff always supervises detainees using these
substances.
All "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 properly 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
Occupational Safety and Health Administration (OSHA).

N '

NA
..... , . .

0

0

0

[2J

0

0

Remarks
Brand new system put
into place - unable to
trend at this time.
Listed on cabinets and
MSDS books.
Random check done on 3
items in Maintenance - .
2 cleaning items.
Random check done on 2
items in dental - all with
MSDS and signout logs

[2J

0

0

[8J

0

0

I:R1

0

0

PHS + ; available around
the camp .

[8J

0

0

Control room in
maintenance with signout
books.

[8J

0

0

Yellow cabinets flocked inventory sheets present

I:R1

0

0

I:R1

0

0

rgj

0

0

[SJ

0

0

Not kept in camp or used
by detainee's. These
items are kept in
Maintenance and used by

2?J

0

0

Recent training of Safety
Officer noted.

t?,J

0

0

\

I

Page 51
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

•

•

ENVIRONMENTALHEAlTHAND SAFETY .

. ..

Policy: Every facility will controlflEtmmable, toxIC, and caustic materialsthronghahazardoHs materials
program. The program will include, aitlong other thihgs , the ideritificationandlarn:Hirig bfhazardous material$ in
accordance with applicable standards (e.g., National Fire Protection Association [NFPAJ); identificatiOliof
incornpatiblematerials, and safe-handling proCedlJr~5
.>
Remarks ............ .
ComponentS
Y
N
NA
A technically qualified officer conducts the fire and
[gJ
0
0
safety inspections.
The Safety Office (or officer) maintains files of
Strong documentation inspection reports; Including corrective actions taken.
weak on followup actions
0
~
0 for deviations from
expected ranges.
The facility has an approved fire prevention, control , and
0
0
~
evacuation plan.
The plan requires:
• Monthly fire inspections.
• Fire protection equipment strategically located
throughout the facility.
• Public posting of emergency plan with
accessible building/room floor plans.
• Exit signs and directional arrows
• An area-specific exit diagram conspicuously
posted in the di(!grammed area.
Fire drills are conducted and documented monthly.
A sanitation program covers barberinll o~erations.
The barbershop has the facilities and equipment
necessary to meet sanitation requ irements.
The sanitation standa rds are conspicuously posted in
the barbershop.
Written procedures regulate the handling and disposal
of used needles and other sharp objects
All items representing potential safety or security risks
are inventoried and a designated individual checks this
inventory weekly
Standard cleaning practices include:
• Using specified equipment; cleansers:
disinfectants and detergents.
• An established schedu le of cleaning and followup inspections.
The facility follows standard cleaning procedures
Spill kits are readily available.
A licensed medical waste contractor disposes of
infectious/bio-hazardous waste.

Staff are trained to prevent contact with blood and other
body fluids and writtenprocedures are followed .
Do the methods for handling/disposing of refuse meet
all regulatory requ irements.
A licensed/CertifiedlTra ined pest-control professional
inspects for rodents, insects, and vermin .
• At least monthly .
• The pest-control program includes preventive
spraying for indigenous insects.
Drinking water and wastewater is routinely tested
according to a fixed schedule.

rg]

0

0

rg]
~

[gJ

0
0
D

0
0
0

rg]

0

0

rg]

0

0

[8J

0

0

Strong documentation

Dental with Strong
program

[gJ

0

0

~
[8J

0
0

0
D

~

0

0

rg]

0

0

~

0

0

[8J

0

0

0

0

0

Has a break in contract
due to "unfunded" for
several months - current
now

Use city water - annual
reports present

Page 52
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

•

•

t=NVIRONMENTAL HEALTH AND SAFETY

Policy: Every facility will control f\amrh~bJe,tbxic, and callstic materials throughahazardolls materials
program. The programwill include, amo[l~ldther:things , the identification and labeling ofhatardousmaterial.S·iTl.•
accordan.ce with applicable standards (e.!}.; National Fire Protection Association [NFPA]): identificationOF I
. ' .;
incompatible materials; and safe-halidlingprocedures
c
Y
NA
Remarks ....:::.......... !
Components <

.N

Emergency power generators is tested at least every
two weeKS.
• Other emergency systems and equipment
receive testing at least quarterly.
• Testing is followed-up with timely corrective
actions (repairs and replacements) .

D

r8J

D

No contract in place for
quarterly checks due to
"unfunded"
Not done since 8/04.
Automated weekly
generator tests
scheduled - no
documentation available.

ENVIRONMENTAL HEALTH AND SAFETY
Acceptable

o Deficient

OAt-Risk

o Repeat Finding

Remarks: (Record significant facts, observations, other sources used, etc.)
Fingernail clippers located in each housing unit (9) with 2 or 3 sets in each unit secured. Check out is done
by detainee 's with Security taking 10 card - items are soaked upon return for 5 minutes in soluation before
another detainee is aI/owed to use them. However, chemicals were removed from units Monday - nothing
available for cleaning during rounds 7-13-05 - problem corrected by closeout and clippers pulled back to the
Barber Shop on 7-14-05.
Chemical found in locker in the SMU 7113105 - to be removed based on current practice to control chemicals
resently put into place - 7114105 follow up - chemicals still in Locker SMU -lEA to removed immediately.
Strong documentation Fire Drills and Diaster Drills
Shower in SMU 7113105 noted to have 3 open bott/es of shampoo and - 3 bars of soap on shower head.
Follow up 7114105 nothing noted left in shower unit. Concerns expressed related to infection control and
potential contraband.
Cleaning tools (mops, buckets, and brooms) securely stored in locked cages outside housing units - however
there is not inventory list or methods to document when items are out for accountability.
Fire Extinguishers - Monthly inspection systems 1 tags recently changed with only one or two dates on 75%
of extinguishers
Lockout-Tagout checklist - paperwork supported practice. (old tags unable to tell what item they were forcurrent tags had item listed on them.)
AED secured around camp - Training records reflected current and annual training for Officers and Security
Staff.
Temperature, Lighting and noise checks done routinely - however, when scores fell out of range for
exceptable levels there was no way to determine if the problem had been address or corrected. No action
plan or follow up.

L'-t>~

Auditor

b6, b7C

I

w
Page 53

G-324A Detention Inspection Form Worksbeet for IGSAs - Rev: 10/18/04

•

•

HOLD ROOMS IN DETENTION FACILITIES

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

I

_ Components
The ho ld room is situated in a location within the secure
jlerimeter.
The hold rooms weil ventilated, well lighted and all
activating switches located outs ide the room.
The hold rooms contain sufficient seating for the
number of detainees held.
No bunks/cotslbeds or other related make shift
sleepinQ apparatuses are perm itted 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
all times .
Every effort is made to ensure that detained detainees
under the age of 18 are not held with adutt deta inees.
Detainees are provided with basic personal hygiene
items such as water, soap, toilet paper cups for water,
feminine hygiene 'tems, diapers and wipes .
In older facil ities officers are within visual or audible
range to allow detainees access to toilet facilities on a
reqular 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 visua l monitoring .)
0
Hold rooms are irregularly monitored every 15
minutes.
0
Unusual behavior or complaints are noted.
When the last detainee has been removed from the
hold room , it is given a thorough inspection
• Clean ing.
• Evidence of tamperi ng with doors, locks,
windows, grills, plumbing or ele ctrica l fixtures is
reported to the shift supervisor for corrective
action Dr repair.
There is a written evacuation plan .
0
There is a deSignated officer to remove
detainees from the ho ldrooms in case of fire
andlor building evacuation ,
An appropriate emergency service is called
immediately upon a determination that a medical
emergency may exist.

Y

N

[J

0

NA

,

0

[1

0

0

[1

0

0

[J

0

0

(8]

0

0

[8l

0

0

D

0

f2l

0

0

0

0

f2l

0

0

0

0

0

[S]

0

0

0

D

0

t8J

0

0

j 0

0

0

·

I
I

Remarks

[1

No females held in Hold
rooms.

0

--

HOLD ROOMS IN DETENTION FACILITIES

o Acceptable

o Deficient

OAt-Risk

o Repeat Findings

Page 54
G-324A Detention Inspection form Worksheet for

--

r(;SA~

- Re,': 10/18/04

HOLD ROOMS IN DETENTION FACILITIES
-gnificant facts, observations, other sources used, etc)
b6, b7C

7/14/05

Although there were a few detainees being held in the hold rooms slightly longer than 12 hours, the
vast majority were out of the cells in leass than 12 hours.

Page 55
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

.-:-:-=-:-::=:-:-:::-=-:c:=-=

-,--------.

KEY AND LOCK CONTROL
(S ECURITY. ACCOUNTA~llITYAND MAINTENANCE)

!----

. Policy It is the · policy of the ICE Service to maintain an efficient system for the use, accountability and
maintenance
of all keys and locks,
._. . _._.
Components

- ....

-- y

N

The security officer, or equivalent in IGSAs, has
responsibly for all adm inistrative duties and responsibilities
relatinQ to keys , locks etc,
The security officer, or equivalent in IGSAs , provides
training to employees in key control.
The security officer, or equivalent in IGSAs, maintains
inventories of all keys, locks and locking devices .
The security officer follows a preventive maintenance
program and maintains all preventive maintenance
documentation.
Facility pOlicies and procedures address the issue of
compromised keys and locks.
The security officer, or equivalent in IGSAs. develops
policy and procedures to ensure safe combinations
integrity.
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 deta inee accessible areas .
The fac ility does not use grand master keying systems .
All wom or discarded keys and locks cut up and properly
disposed of .
Padlocks and/or chains are not used on cell doors.
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?
Keys cannot be removed from issued key rings
Emergency keys are ava~able for all areas of the facility,
The facilities use a key accou ntability system.
Authorization is necessary to issue any restricted key.

I NA
:

The security officer[s], or equivalent in IGSAs, has
attended an approved locksmith training program ,

0

t'8:J

0

t'8:J

0

0

[gj

0

0

t'8:J

0

i

t'8:J

0

I0

t'8:J

0

0

t2l

0

0

t'8:J

0

0

(2J

0
0

(2J

0
0
0

(2J

0

0
0

IZl

0

0

(8]

0

0

IZl

0

0

IZl
IZl
IZl

0
0
0

0
0
0

[8J

Remarks
The standard states must
have attended the BOP
Locksmith Course , The
security officer has
attended a commercially
available course,

0

·

·
·

On duty ICE supervisor.

Page 56
G-324A lletenCion Inspection Form Worksheet for IGSA s - Rev : 10118/04

.

~

"KEY AND LOCK CONTROL--(SECURITY, ACCOUNTABILITY AND MAINTENANCE)

r---------------------

Policy It is the policy of the ICE Service to maintain an efficient system fOr the use, accountability and
maintenance of all keys and locks
'-'- --"-"'- - "-"---'

---"'- '

Components
Individual gun lockers are provided .
• They are located in an area that permits constant
officer observation.
• In an area that does not allow detainee or public
access.
The facility has a key accountability policy and procedures
to ensure key accountability. The keys are physically
counted daily.
All staff members are trained and held responsible for
adhering to proper procedures for the handling of keys.
•
Issued keys are returned immediately in the
event an employee inadvertently carries a key
ring home.
• When a key or key ring is lost, misplaced, or not
accounted for, the shift supervisor is
immediately notified.
• Detainees are not permitted to handle keys
assigned to staff.

.:-:-:- ~- ..

Y

N

NA

0

~

0

0

~

0

o

o

-

.

.

'

.....
RemarkS.>
The gun boxes are in an
area that visitors have
access to. They are
under constant officer
observation.
See Note Below.

KEY AND LOCK CONTROL

o Deficient

[gJ Acceptable

OAt-Risk

o Repeat Finding

Remarks: (Record S!lnificant facts, obseTVations, other sources used, etc.)
b6, b7C

.

7/14/05

The control officer counts key rings every shift, but not keys. There is no written records of daily key
counts.

Page 57
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

I

_...-- -

.

'POPULATION COUNTS

. '

...

.-

.

'l

..

POliCY
.. :.A .·lIdetel'1tion faciliUe~.Shal.l. ensure aroti09.-the-clock a~countabil.ity fo.rall.de.~~inee·s : ThiS reqU.ires th~t:· .1
they conduct at least one formal count of the detainee population per sMt, with addltlonalformal andlnfOrmal ..
~unts conducted as necessary.
;..
...
..
....._- .
.' - . ..
..
"
Y
NA
Remarks
Components
N

j

1:

-

~

"--'

once

~opulation

[S] Acceptable

o Deficient

[j

[2l

0
0
0
0
0

0
0
0
0
0
0
0

[2J

0

0

0

0

0

[gJ

0

0

[2l

0

0

0
0
0

Staff conducts a fo rmal count at least
each shift.
Activities cease or are strictly controlled while a formal
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 units take place simultaneously.
Officers do not allow detainee participation in the count.
A face-to-photo count follows each unsuccessful
recount.
Officers positively identify each detainee before
counting him/her 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 officers training
folder.

[gJ
~

[gJ

0

..

Food Service Outcounts

Counts
OAt-Risk

o Repeat Finding

Remarks: (Ree rd si nifieant facts, observations. other sources used, etc.)
I

b6, b7C

..-

7/15/05

Page 58
G-324A Detention Inspection Form Worksheet for IGSAs - Re\,; 10/18/04

r--

--- "-

POST ORDERS --

'

" -

, "

--

I Poiicy':ICE provides Qffiters all necessary911ida-nce'fo-r carrying out theirdlJt-ieS. -Thisguidanceincludesthe
post orders established for every post, which are reviewed atleast annually;andgi'ileri1o each officer upon
"
1:2 "
assignment to that post.

,,-,----,----,-----=-C- =-o.:. :.:,m-ponents

I--_ _ _

Every Fixed post has a set of post orders.
Each set contains the fatest inserts (emergency
memoranda, etc.) and revisions.
One individual or department is responsible for keeping
all post-orders current with revisions that take place
between reviews_
The IGSA maintains a complete set (central file) of post
orders.
The central fife accessible to all staff.
The ole or Contract IIGSA equivalent
initiate/authorizes all post-order changes_
The OIC or Contract I fGSA equivalent has signed and
dated the last page of every section.
A review/updating/reissuing of post orders occurs
re..9ularlyand at a minimum, annually,
Procedures 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,

----R~tnafks_:_
, : _~--j!

y- -

N

NA

~

0
0

[]
0

o
o
o

o
o
o

0

0

0

0

0

0

0

0

0

!8J

No armed posts ,

0

~

No armed posts,

0

0

0

0

~

o
o
!8J

POST ORDERS><

!Xl Acceptable

o Deficient

OAt-Risk

o Repeat Finding

ant facts, observations, other sources used, etc.)
b6, b7C

7/14/05

Checked 12 posts and all officers had signed the post orders.

Page 59
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

II

i

SECURITY INSPECTIONS

. .-----------~
p o rICY: ' p ost assignments in the facIlity's high-riskareas, where special sebl.lrityprocedures mustbe followed,
will be r~~tri~t.f:)sJ to experienced personnel with a thClrDugh groLindinginfacilityo)erations:..
.
Components
Yes
NA
No
Remarks
.
- ---. The facility has a comprehensive security inspection
policy. The policy specifies:
• Posts to be inspected
• Required inspection forms
[gl
0
0
• Frequency of inspections
Guidelines
fo
r
checking
security
features
•
• Procedures for reporting weak spots,
inconsistencies, and other areas needing
improvement
Every officer is required to conduct a security check of
[gJ
0
0
his/her assigned area. The results are documented.
[gJ
Documentation of security inspections is kept on file .
0
0
Procedures ensure that recurring problems and a failure to
[gJ
take corrective action are reported to the appropriate
0
0
manager.
The front-entrance officer checks the 10 of everyone
[gJ
0
0
entering or exiting the facility.

---------

~---~---

All visits officially recorded in a visitor logbook or
electronically recorded .
The facility has a secure visitor pass system.
Every Control Center officer receives specialized train ing.
The Control Center is staffed around the clock.
Policy restricts staff access to the Control Center.
Detainees do not have access to the Control Center.
Communications are centralized in the Control Center.
Officers monitor all vehicular traffic entering and leaving
the facility
The facility maintains a log of all incoming and departing
vehicles to sensitive areas of the facility. Each entry
contains:
• The driver's name
• Company represented
• Vehicle contents
• Delivery date and time
• Date and time out
• Vehicle license number
• Name of employee responsible for the vehicle
durinQ the facility visit
Officers thoroughly search each vehicle entering and
leavinjj the facility.
The facility has a written policy and procedures to prevent
the introduction of contraband into the facility or an y of its
components.
Tools being taken into the secure area of the facility are
inventoried before entering 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.
Every search of the SMU and other housing units
documented.

[gJ

[81

0

0
0
0
0
0
0
0
0

[8J

0

0

[81

0

0

~

0

0

[81

0
0
0

0
0
0
0
0

[gJ
[gI

[8]
~
[81
[81

0
[81
~
~

0
0
0

0
0
0

0

0
0

Page 60
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

..

..

SECURITY IN'SPECTIONS

~
.

.. -

~~~;~~~-;;ost

assignments in the facility's high-risk areas, where speCial-security procedures must be followed,
will be restricted to ex~er!~nced personnelwith a thoroug.!1g,rpunding in facllity();>erati9t;1.~ .. _
Compdneilts
Yes
NoNA
><> Remarks
Storage and supply rooms; walls, light and plumbing
fixtures , accesses, and drains. etc. undergo frequent,
irregular searches. These searches are documented.
Walls, fences , and exits, including exterior windows. are
inspected for defects once each shift.
Daily procedures include:
• Perimeter alarm system tests.
• Physical checks of the perimeter fence.
• Documentingthe results .
Visitation areas receive frequent, irregular inspections.
.

o
o

p

o
o

o

o
o o

SEClJ~ITY INSPECTIONS

[8] Acceptable

b6, b7C

o Deficient

OAt-Risk

o Repeat Finding

7/14/05

The front security officers performed their duties in a very professional and through manner. The
system of logging all employees into the facility, moving their Personal Data Cards (Form G-74) from
the out box to the in box is exactly to standards. The process is reversed when the employee leaves
the facility. This creates excellent accountable of all personnel inside the facility.

Page 61
G-324A Detention Inspection Form Worksheet for IGSAs - Uev; 10/18/04

II

SPECIAL MANAGEMENT UNit (SMU) ··
Administrative Segregation
.•..
.. ... : ..: .
Policy: The Special ManagemenlUnitrequired in every facility isolatesccertain detainees from the general
population: The Special ManagehienFUnit .will consist of two sections. One, Administrative Segt$g:a;fion,
houses detainees isolated for their own protection; the other for detaineesbeingdi~ciplinedf6r wrongdoing (seEl
the "SpeciaIManagementUnit[Disciplinai'ySegregation]" stan;dard). .. .:' :: <c
·.:
. .

COrriponent$ .

Y

..

'. .

The Administrative Segregation unit provides
non-punitive protection from the general population and
individuals undergoing disciplinary 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 ole (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 ole (or equivalent) routinely notifies the Field
Office Director (or staff officer in charge of IGSAs) any
time a detainee's stay in administrative detention
exceeds 30 days.
•
Upon notification that the detainee's
administrative segregation has exceeded 60
days, the FD forwards written notice to HQ
Field Operations Branch Chief for ORO.
The ole 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
in administrative segregation for seven consecutive
days.

NNA

o

o

o

o

o

o

o

D

o

0

o

0

o

0

o

0

Remarks ...:.: / >
.

Page 62
G-324A J)ctcntion Inspection Form Worksheet for IGSAs - Rev: 10/18/04

SPECIAL MANAGEMENT UNIT (SMut .....
Administrative
Segrelfation
..
... ....... .
Policy: The Special Management Unit required in every facility isolates certain detainees fr'otTl the general
population. The Special ManagemenfUnit will consist of two sections. One, Administrative SegrE!gatlon,
houses detainees isolated for their oWllprotection; the other for detainees being disciplinedforwrongdoing(see
the "Special Management Unit[Discipliii<irySegregationj" standard) . .
..•...
..
Components
.....•.
Administratively segregated detainees enjoy the same
general privileges as detainees in the general
population.

The SMU well ventilated.
•
Adequately lighted.
•
Appropriately heated .
•
Maintained in a sanitary condition.
All cells are equipped with beds.
•
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?
•
Do 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 exchange/launder clothing, bedding,
and linen than detainees in the ~eneral population.
Detainees receive three nutritious meals per day.
•
From the general population's menu of the day.
•
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 .
•
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.
• 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.
•
The shift supervisor visits each detainee daily
• Weekends and holidays.

Y

N .·.··1 <NA

0

t8J

0

t8J I D

D

·.··

Remar~s
....
Detainees in
administrative
segregation do not get to
see television as the
general population does.

o

~

o

o

o

o

o

o

0

0
The amount of recreation
exceeds the recreation
standard of 5 hours per
weeks. The average is 7
hours a week.

I8l

0

D

o

D

Page 63
G-324A Detention Inspection Form Worksheet

fOT

ICSAs - Rev: 10/18/04

SPECIAL MANAGEMENT UNITlSMU)
Admini,~trative Seg ~egatior1 ·

Policy: The Special Management Unit required>in every faCility isolates certain detainees from the general
population, The Special ManagemenfUnit wiiVconsist of two .sections. One, Administrative Segregation,
houses detainees isolatedfortheir ownprotecti6ri; the other for detainees being disciplined for wrongdoing (see
2
the "Speci$iManagement l.Jnil[Disciplina.ry .Segregationj" staI'l9ard).

compottents

• i»

Procedures comply with the "Visitation" standard.
• The detainee retains visiting privileges.
• The visiting room available during normal
visiting hours.
Visits from clergy are allowed.
Detainees do not have less law-library access than the
general population .
• Are they requ ired 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,
recreation. 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 officer/health 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 ,

y

N

NA

~

0

0

t8J

0

0

!SJ

0

D

[8J

0

D

k8J

0

0

[8J

0

0

0

0

0

Remarks

... .

,</'

SPECIAL MANAGEMENT UNIT{SMU) ··
Administrative Seg regatioh

fSI Acceptable

o Deficient

D

At-Risk

o Repeat Finding

Remarks: (ReCaj signi Icant facts, observations, other sources used, etc)
b6, b7C

7/14/05

Page 64
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

I

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

Y

N

NA

Officers plaCing detainees in discipli~ary segregation
follow written procedures.
The sanctions for violations committed during one
incident do not exceed 60 days.

~

[j

0

0

0

0

0

[SJ

I0

0

t8l

0

0

t8l

0

0

t8l

0

0

[8J

0

0

[@

0

0

0

0

0

0

[SJ ' 0

0

0

0

A
completed
Disciplinary
Segregation
Order
accompanies the detair,ee into the SMU .
The detainee receives a copy of the order
within 24 hours of placemert in disciplinary
seQreQation
Standard procedures include reviewing the cases of
individual detainees housed in disciplinary detention al
set intervals.
After each formal review, the detainee receives
a written copy of the decision and reasons for it.
The conditions of confinement in the SMU are
proportional to the amount of control necessary to
protect detainees and staff.
Detainees in discip linary segregation have fewe r
privileges than those housed in administrative
segregation .
Living conditions in disciplinary SMUs modified to
reinforce acceptable behavior.
• If yes. does staff prepare written
documentation for this action .
Does the ole sign 10 indicate approval.
Every detainee in disciplinary segregation receive the
same humane treatment, regardless of offense.
The quarters used for segregation are :
Well-ventilated .
Adequately lighted
• Appropriately heated.
Maintained in a sanitary cond~ion.

·

.

I

·
··
·
·

All cells are eq uipped with beds.
The beds securely fastened to the fl oor or wall of
the cell .
The number of detainees confined to each celi 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 ,
maffress, blanket, or pillow, (in a dry cell setting) a
j ustification is made and the decision is reviewed each
shift. Items are returned as soon as tt is safe .
Detainees in the SMU have the same opportun it ies to
exchange clothinQ , bedd inQ, elc., as other detainees.

·

0

I
!

t8l

Remarks

This facility nonnally does
not eXce€d 3 days in DIS
status.

i

0

i
!

I
,i

t8l

I
I
I

t8l

~-

Page 65
G-324A Dctfntion Inspection Form Work..hcct for IG SAs - Rev: 10/18/04

SPECIAL NlANAGEMENT UNIT ·
(Discipli"~ry Segre~~tlon)

•

·
...... . .......
,....
.•...••.
. .. ......•. •.. . . . >,
... ...•
Policy: Each facility will establishappecial Management UnifinwhichfdiJspla.tecertzilhdetainees from the:
general population. The Special Ma;:lCigement Unit\Nill have twbsec!ions;onefor detainees in AdministrC,lt;y~f
Segregation~ the other for detainees being segregat~d for disciplinaryreasC:kls.
cc..
. ... .. .

Components

Y

Detainees in the SMU receive three nutritious
meals/days.
• 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 times/week.
The detainees receive, unless documented as a threat
to security:
•
Barbering services.
•
Recreation privileges.
•
Other-than-Iegal 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,
limits do not 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 OIClWarden)
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 service 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.
• ViolentJuncooperative 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 \0 individuals in the
SMU on a case-by-case basis.
•
Staff document every incident of denied
access to the law library.

[8J

N

NARemarks

o

o

D

o

o

o

D

o

o

o

o

D

o

o

0

D
SMU detainees use the
law library during the
evening shift.

~

0

0

Page 66
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

•

. <' SPECIAL MANAGEMENT UNIT ....<
(DiSCiplin~t.¥ Segregation)

i

:.

:> . . ...

.....

... .

. '.

..

Policy: Each facility will estaolish aSpecial Management Unit in Whrch to isolate certain detainees fr'omthe
general .population. The SpeCial ManagernenfUnit wilKhave.two secti6iis,oneJordetaineesiil Aciministrative
Segregation; the. Ptherfor detainees beingsegregatedfof' di$ciplinaryr'e<3~on*.» ··
.' ..
.. '
N ·:··••: NA
Components
Y
REunarks « '•.
All detainee-related activities are documented, e.g.,
meals served recreation activities, visitors, etc.
Is the SPC's, the Special Management Housing Unit
Record (1-888or equivalent) is prepared as soon as the
detainee is placed in the SMU .
• All 1-8885 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, suicidal/violent behavior,
etc.
• The health care official sign individual records
after each visit.
• The housing officer initials the record when all
detainee services are completed or at the end
of the shift.
• A new record is created weekly for each
detainee in the SMU.
The
SMU retains these records until the
•
detainee leaves the SMU.

[8J

0

0

[g]

0

0

[8J

D

0

SPECIAL MANAGEMENT UNIT
(Disciplinary Segregation)

~[8J Acceptable

o Deficient

OAt-Risk

o Repeat Finding

Remarks: (Record sig ificant facts, observations, other sources used, etc.)
b6, b7C

7/14/05

The SMU was very clean and orderly. The officers assigned were very knowledgable in regards to
policy and their post orders.

Page 67
G-324A Detention Inspection Form Worksheet for TGSAs - Rc'v: 10/ 18/04

•

•

TOOL CONTROL

.. :,

...

Policy: It is the policy of all facilities that all employees shall be responsible for complying With the toolcontrol
policy. The Maintenance SLJpervisorshali maintain a computer generated or typewHtten Master Inventbiy list of
tools and equipment and the locatiorHnwhichtools are stored. TIi~"Seinventories shall becLlrrent, filedand
readily available for tobl inventory~r\daccountabilityduring an audit>
.
Remarks·
Components
Y
N
NA
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
• Armory
The facility has a facility policy for the regular inventory
of all tools.
• The policy sets minimum time lines for physical
inventory and all necessary documentation.
• ICE facilities use AMIS bar code labels when
required .

I
I

i

0

0

['8J

0

0
See notes below.

0

I fZl

[3J

0

0

0

I

I

The facility has a tool classification system. Tools are
classified according to:
• Restricted (dangerous/haz:ardous)

•

['8J

0

[8J

0

['8J

0

0

l'8J

0

0

[8J

0

0

0

0

D

~

0

0

~

0

0

~

0

0

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.
I
• Commonly used tools (tools that can be
I
mounted) are stored in such a way that
I
missing tool are readily notice.
Each facility has procedures for the issuance of tools to
staff and detainees.
The facility has policies and procedures to address the I
I
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 worn 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.

All tools are considered
restricted and no
detainees are allowed to
handle tools.

Page 68
G-324A Detention Inspection Form Worksheet for TGSAs - Rev: 10/18/04

•

TOOL CONTROL

o Acceptable

[81 Deficient

o At·Risk

•

o Repeat Finding

I

Remarks : (l1ecord igni(fcent facts, observations, other sovrces vsed, etc.)

b6, b7C

7114/05

All areas must have inventories that reflect the proper amount of tools that are presently on hand.
There were multiple metal cutting grinder wheels on one hook. The officer was asked how many were
inventoried, he stated 3. There were 8 blades on the hook.
Several multi tool sets were misSing parts and not properly accounted for, however, upon re-inspection
the second day, it was already being corrected. The facility needs to be reminded that proper tool
accountability needs to always be a top priority.
There are water hoses, approximately 25 feet long which could be used in an escape, in all housing units
that are currently not marked nor being Inventoried. Neither the housing un it officers nor the tool room
officer are accounting for these items.

Page 69
G·J24'\ Detention Inspection Form \Vorksheet for IGSA •• Rc,': 1011 8/04

.

•

TRANSPORTATION
(land Transportation)

•

-

-

;~

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

Policy The Immigration and Naturalization Service will take all necessary precautions to protect the lives,
safety, and welfareofoLlrofficers, thegel1~ralpublic , and those in ICE Ctl stcdy diJrihg the transportationot l
deta inees. Standatds>have · been established for professional transportation under thesupeNisicn>:of i
experienced and trainedDetention Enforcement Officers or authqrized contract personnel.
. .. · 1

D Standard NA: Check this bOxifalllCETransportation are handled only by,the ICE Field Office or
Sub-Office in control of the detainee case.
.
•.<:::.:
..
--_ .
Components >
Yes
No ·. NA ·
.... Remarks
.. -.'.__.- .. -- -_._.--.
.
Transporting officers comply with applicable local, state.
and federal motor vehicle laws and regulations . Records
~
D D
support this finding of compliance.
Every transporting officer required to drive a commercial
[g]
size bus has a valid Commercial Driver's License (CDL)
D 0
issued by the state of employment.
[g]
SupeNisors maintain records for each vehicle operator.
C
0
Officers use a checklist during every vehicle inspection.
• Officers report deficiencies affecting operability.
[gJ
0
0
• Deficiencies are corrected before the vehicle
goes back into service.
Transporting officers:
• Limit driving time to 10 hours in any 15 hour
period .
• Drive only after eight consecutive off-duty hours .
• Do not receive transportation assignments after
having been on duty, in any capacity, for 15
hours.
r8J
D 0
• Drive a 50-hour maximum in a given work week ;
a 70-hour maximum during eight consecutive
days.
• During emergency conditions (including bad
weather). officers may drive as long as
necessary and safe to reach a safe
area-exceeding the 10-hour limit.
Two officers with valid CDLs required in any bus
transporting detainees.
• When buses travel in tandem with detainees,
0
0
0
there two qualified officers per vehicle.
• An unaccompanied driver transport an empty
vehicle.
Before the start of each detail, the vehicle is thoroughly
[g]
0
0
searched.
Positive identification of all detainees being transported is
[8J
D 0
confirmed .
All detainees are searched immediately prior to boarding
0
0
D
the vehicle by staff control/ing the bus or vehicle.
The facility ensures that the number of detainees
transported does not exceed the vehicles manufacturers
0
0
D
occupancy level.
Protective vests aref'.rovided to all transportina officers.
0
0
0
The vehicle crew conducts a visual count once all
passengers are on board and seated .
0
0
• Additional visual counts are made whenever the 0
veh icle makes a scheduled or unscheduled
stop.
.

- ". ~--

- -

- ."

.~

~---- . -

.,

Page 70
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

.-. -.. ,

- _.,

-

._

C' , ._ •

•

•

TRANSPORTATION
(Land Transportat1on)
_.....

....

-

" ':

-- - ,<..

Policy Tile Immigration and NaturalizatiohServic,e will takealihecessaryprecautioQstb protect the lives;
safety; and welfare olour officers, the general public, and thoseii:rICEc(Jstody during the transportation of
detainees. Standards have beenestabl isn ed for professional transportation under the " supervision of ,
experienced and trained Detention Ejiforcerrient Officers or authoriZ:edcontractpersonnel.
:

. .' -;: . ....

o StandardNA:

by

oJfie~or

Check this boxlfalllCETransportationareharidled only
the ICE-Field
Sub-Office In control of the detaillee caSE!;
,, --- ------ ------"-':-'-_,- .
,:
NAReriiarks >
Components
Yes
No
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 all 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, quality,
quantity, thermos-transport containers, etc.) .
• Before accepting the meals, the vehicle crew
raises and resolves questions, concerns, or
the
Food
Service
discrepancies
with
representative.
latrines,
and
drinking-water
• Basins,
containers/dispensers 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
facility:
• 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
• Passenger list is not exclusively men or women
or minors

(gJ

0

0

~

0

0

[gJ

0

0

[gJ

0

0

~

0

0

[gJ

0

0

~

0

0

[g]

0

0

Page 71
G-324A Detention Inspection Form Worksbeet for IGSAs - Rev: t 0/18/04

"

•

-----=-::-:-=~-=-=-:~:-:-:---

[g] Acceptable

TRANSPORTATION
(Land Transportation)

o Deficient

•

-- -,-,.,- --

OAt-Risk

o Repeat Finding

Remarks: (Record sig ificant facts, observations, other sources used, etc)
b6, b7C

7/14/05

Page 72
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

•

USEOF FORCE

. . ..

•
...

.

.

....

Policy: TheU .S. DepartmentofHomelapdSecurity authori4e:s the use6f force only as a lastaltemative after all
other reasonable effortstdreSQlve asit@ticin have failed . Only that amount of force necessary to gain control
of the detainee, to protectandensurethe safety of detaineies; staffand others,to prevent seridusproperty
damage and to ensure institution secutityandgood order maybe used> PhysicalrElstraints nece$Sary'togain
control of a detainee who ..appears to be,<langerous
may beemployedwhen
the. .. detainee:
.
··· c · · ····
.'
.
... ..•.. .. ..

Components
.. .. .. .. .
.•

Yes

Written policy authorizes staff to respond in an
immediate-use-of-force situation without a supervisor's
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 the detainee or others, officers must try to
resolve the situation without resorting to force.
Written policy asserts that calculated rather than
immediate use of force is feasible in most cases.
The facility 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
I'ersuasion, have failed or are impractical.
Mecication 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).

No

NARemar~~>
.
.

o

o

o

o

o

o

o

o

o

o

o
o

o
o

o

o

o

o

o

o

Page 73
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

•

.... USE OF FORCE .

..

.

.

Policy:The U.S. Department of Homeland Security authorizes the use of force only asa last alternativeal'ter.all
other .reasonable effOrts to resolveasituationhave failed . .Onlythatamount of force necessary to gaincOritrol
of the detainee, to protect and ensure the safety of detainees, staff and others, to preventserious property
damage .and toensureinstitutiorlsecurity and good order rilaybells~d . Physical restraints necessary to gain
control ofa detainee who appearstbbe dangerous may be empl()y~dwhen the detainee:
Remarks
···.'•.:>... ...
NA
Components
Yes
No
,
.
Standard procedures associated with using four-point
restraints include:
• Soft restraints (e.g., vinyl)
• Dressing the detainee appropriately for the
temperature.
• A bed, mattress, and blanket/sheet.
• Checking the detainee at least every 15
minutes.
• Logging each check.
• Turning the bed-restrained detainee often
enough to prevent soreness or stiffness.
• Medical evaluation of the restrained
detainee twice per eight-hour shift.
• 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 safeQuards.
All detainee checks are loqqed.
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,
confrontation-avoidance 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 I CDFs) this form or its equivalent is
used.

~

0

0

~

0

0

~

[gJ

0
0

0
0

~

0

0

0

0

0

0

0

0

0

0

0

1ZI

0

0

[gJ

0

0

0

0

0

[gJ

0

0

Page 74
C-324A Detention Tnspection Form Worksheet for IGSAs - Rev: 10/18/04

USEOF FORCE

(2J Acceptable

o Deficient

OAt-Risk

D

Repeat Finding

Remarks: ;ecord si nifjnt facts, observations, other sources used, etc.)
b6, b7C

7/14/05

No recorded calculated uses of force in the last several years. The use of force forms for immediate
use of force was reviewed and complete.

Page 75
G-324A Detention Inspection Form Worl\sheet for IGSAs - Rev: 10/18/04

•

STAFF DETAINEE COMMUNICATIONS
I '- ~=:~=.
, Policy: Procedures must be in place to allow for formal and informal contact between key facility staff and
ICE staff and ICE detainee and to permit detainees to make written requests to ICE staff and receive an
f answer in an acceptable time frame. <, ., .
.....
.... .. --...
.-- --'..
....
-- ".'"
----- ---.
j
Remarks
Y ..
N... - .
I
.. C.C;!!!,.p.4?nents __ ...
_. ., ._-_
- . - .._.
.. .
. The ICE Field Office Director ensures that weekly
0
0
0
announced and unannounced visits occur at the IGSA.
No evidence provided
Detention and Deportation Staff conduct scheduled
~
0
0
weekly visits with detainees held in the IGSA.
Scheduled visits are posted in ICE detainee areas.
0
0
0
Visiting staff observe and note current climate and
0
0
0
conditions of confinement at each IGSA.
ICE information request Forms are available al the
[gJ
0
0 English and Spanish
IGSA for use by ICE detainees.
The IGSA treats detainee correspondence to ICE staff
t8l 0
0
as Special Correspondence.
No evidence provided
ICE staff respond to a detainee request from an IGSA
0
0
0
within 72 hours .
ICE detainees are notified ion writing upon admission to
[gJ
the facility of their right to correspond with ICE staff
0
0
regarding their Case or conditions of confinement.
~ .--.- .""

-~

-

. - -~- ,"'"

...

..

. , ._. _

_

_ _ .0 • • •

- - -.

--- .~

,.- ,

~-

. -

NA- __

--~.--.

-

_._

"

Staff Detainee Communications

o Acceptable

D

[8J Deficient

Repeat Finding

Remarks: (Record significant facts, observations, other sources used, etc.)
The facility could not provide logs, detainee request form copies or other proof to clearly demonstrate that the
facility is in compliance with this standard .
b6, b7C

Page 72
G·324A Detention Inspection Form Worksheet for IGSAs - Re\': 10/18/04

I

•

•

---_. - - - - - - - - - DETAINEE TRANSFERSTANDARD
Policy: ICE-wiljmake all necessary notifications whenad::c:.e'::"'t-=-a---'-in"--e::"e'--=i'---"s---'-'tr"'a=-n-sf-e-rr-e-d-,-I-C-f -a-dc----e-ta-in-e'---e-.c--i$~b-e~i-ng

I transferred via the Justice Prisoner Alien Transportation System (J PATS) , ICE will adhere to JPATS

, protocols. In deciding whether to transfer a detainee, ICE will take into consideration whether the detainee
is represented before the immigration court In such cases, the Field Office Director will consider the
detainee's stage within the removal process, whetherthedetainee's attomeyis lOCated Within reasonable
~~j~i_n~_~~~~anc~_of t~: facility, and where,th~imr:':ligr~ti.?~ c~~~proce.edings are_t~k~g£llac.~' ~_

Components
When a detainee is represented by legal counselor a
legal representative, and a G-28 has been filed, the
representative of record is notified by the detainee's
Deportation Officer.
•
The notification is recorded in the detainee's file
•
When the A File is not available, notification is
noted within DACS
Notification includes the reason for the transfer and the
location of the new facility,
The deportation officer is aI/owed discretion regarding
the timing of the notification when extenuating
circumstances are involved.
The attorney and detainee are notified that it is their
responsibility to notify family members regarding a
transfer.
Facility policy mandates that:
•
Times and transfer plans are never discussed
with the detainee prior to transfer.
•
The detainee is not notified of the transfer until
immediately prior to departing the facility_
•
The detainee is not permitted to make any
phone calls or have contact with any detainee in
the general population.
The detainee is provided with a completed Detainee
Transfer Notification Form.
•
Form G-391 or equivalent authorizing the
removal of a detainee from a facility is used.
For medical transfers:
•
The Detainee Immigration Health Service (or
IGSA)(DIHS) Medical Director or designee
approves the transfer.
•
Medical transfers are coordinated through the
local ICE office.
• A medical transfer summary is completed and
accom~anies the detainee.
Detainees in ICE facilities having DIHS staff and
medical care are transferred with a completed transfer
summary sheet in a sealed envelope with the detainee's
name and A-number and the envelope is marked
Medical Confidential.
For medical transfers, transporting officers receive
instructions regarding medical issues.
Detainee's funds and valuables and property are
returned and transferred with the detainee to his/her
new location.
Transfer and documentary procedures outlined in
Section C and D are followed.
Meals are provided when transfers occur during
normally schedule meal times_

Y

N __

NA

[gJ

0

0

o
o

o
o

o

o

o

o

o
o

o
o

o

o

19]

0

0

[8J

0

0

0

0

0

[8J

0

0

[gJ

0

0

Remar~___ ._.. _ _

Page 77
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10118/04

I

r

•

•

DETAINEE TRANSFER S1A'NDARDC·'· --· '-·-------· -~

-'Policy:-TcE wmmakeali--necessarynotifications when a (!etaineeis transferred,

If adetain~i $ :,beihg
transferred via the Justice PrisonerAI,ien Transportation Systei:n (.cJPATS},l CEwill adhere to JPAtS . ..•.
protocols, In deciding whether to trap!;fer a detainee, ICE will takeinto ,(;()nsideration whetherthedetaJrl¢e
is represented.before the immigr'a~IQttccurt. In such cases , theF'le(dOfficeDirector will consider the " .
detainee's stage within the removalprbcess, whether the detainee's attorney is located wifhirl reasonable
driving distance of tMfacility, and Where the ~mm~gr.~tion court pro(;~edings are taking place.
Component$
Y
>N NA
Remarks
An A File or work folder accompanies the detainee when
transferred to a different field office or sub-office,
Only when case are
A Files are forwarded to the receiving office via
transferred, not when
overnight mail no later than one business day following
detainee is a room and
the transfer.
board,

o

o

o

o

Pl:itaineit'Transfer Standard
~ Acceptable

o Deficient

OAt-Risk

o Repeat Finding

Remarks: (Reeon si nificant facts, obselVations, other sources used, etc)
b6, b7C

7/14/05

Page 78
G-324A Oetention Inspection Form Worksheet for IGSAs - Rev; 10118/04

Office of Detention and Removal Operations

{J.S. Department of Homeland Security
801 ! Street, NW
Washington, DC 2053!

u.s. Immigration

and Customs
Enforcement

MEMORANDUM FOR:

Nora Antunez
Field Office Director
fce
b6, b7C

FROM:

Deputy Assistant Director
Detention Management Division
SUBJECT:

EI Centro Service Processing Center Plan of Action

The El Centro Service Processing Center Plan of Action dated April 10,2006, has been
received. The Plan was developed in response to a Review conducted by Headquarters on July
12-14,2005.
The Review Authority (RA) has evaluated the document and concurs with the Plan of Action,
as written, and this review is closed. The Field Office must now 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
witbin five business days of receipt of this memorandum. Notification shall include a
copy of this memorandum.
2) The Field Office Director is responsible for ensuring that the facility complies with its
proposed Plan of Action. A certified Detention Reviewer shall be assigned to followup on the deficiencies identified in the G324A, Detention Facility Review Form and the
Reviewer-In-Charge (RIC) Summary Memorandum within 90 days.

.

3) The Field Office shall schedule the next annual review before July 12,2006.
Should you or your staff have any questions regarding this matter, please contac
b6, b7C Deputy Assistant Director, Detention Management Division at (202) 732-

c
(b)(2)High, (b)(6), (b)(7)(C)

www.ice.gov

b6, b7C
b6,b7c