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ICE Detention Standards Compliance Audit - El Centro Service Processing Center, El Centro, CA, ICE, 2008

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Office of Detention and Removal Operations
U.S. Department of Homeland Security
500 12 Street, SW
Washington, DC 20536

`

MEMORANDUM FOR:

Robin F. Baker
Field Office Director
San Diego Field Office

FROM:

James T. Hayes, Jr.
Director

SUBJECT:

El Centro Service Processing Center Annual Review

The annual review of the El Centro Service Processing Center conducted on June 17-19, 2008,
in El Centro, California, has been received. The Review Authority (RA) has downgraded the
rating to an Acceptable.
The CC-324A worksheets provided by the Reviewer-in-Charge (RIC) indicated the facility
was non-compliant with the Environmental Health and Safety, Key and Lock Control, and
Food Service standards. A Plan of Action is required to address these deficiencies.
The rating was based on the RIC Summary Memorandum and supporting documentation. The
Field Office Director must remedy the deficient standards, 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 CC-324A, Detention Facility Review Form, the CC-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 RA within 30 days.
3) The RA will advise the Field Office Director once the Plan of Action is approved.
4) Once a Plan of Action is approved, the Field Office Director shall schedule a follow-up
on the above noted deficiencies within 90 days.

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

Subject: El Centro Special Processing Center Annual Review
Page 2
The Field Office is responsible for assisting the Intergovernmental Service Agreement (IGSA)
facility to respond to the U.S. Immigration and Customs Enforcement findings when assistance
is requested. Notification to the facility shall include information that this assistance is
available.
Should your staff have any questions regarding this matter, please contact
Deputy Assistant Director, Detention Management Division at (202) 732cc:
b2 high, (b)(6), (b)(7)c

b6, b7c
b2 high

MANAGEMENT REVIEW
REVIEW AUTHORITY
THE SIGNATURE BELOW CONSTITUTES REVIEW AND ACCEPTANCE OF THIS REPORT BY THE REVIEW AUTHORITY. FOD/OIC/CEO WILL
HAVE THIRTY (30) CALENDAR DAYS FROM RECEIPT OF THIS REPORT TO RESPOND TO ALL FINDINGS AND RECOMMENDATIONS.
HQDRO MANAGEMENT REVIEW: (Print Name)

Signature

James T. Hayes, Jr.
Title

Date

Director

FINAL RATING:

SUPERIOR
GOOD
ACCEPTABLE
DEFICIENT
AT-RISK

COMMENTS: The Review Authority has downgraded the recommended rating of “Good” to an “Acceptable”. A Plan of Action is
required to address the deficiencies in the Food Service , Environmental Health and Safety, and Key and Lock
Control standards.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

6415 Calder, Suite B  Beaumont, Texas 77706
409.866.9920  www.correctionalexperts.com
Making a Difference!

June 24, 2008
MEMORANDUM FOR:

FROM:

James T. Hayes, Jr.
Acting Director
Office of Detention and Removal Operations
b6, b7c

Reviewer-In-Charge/SME Security
SUBJECT:

El Centro Service Processing Center Annual Detention Review

Creative Corrections conducted the Annual Detention Review (ADR) of the El Centro Service
Processing Center (ECSPC) located in El Centro, California, on June 17-19, 2008. As noted on
b6, b7c
the attached documents, my team of Subject Matter Experts included:
b6, b7c
b6, b7c
Administration;
, Health Services;
Safety and Environmental
b6, b7c
Health; and
d Services.
A closeout meeting was held on June 19, 2008, during which all concerns and recommendations
b6, b7c
b6, b7c
were discussed with Assistant Field Office Director,
,
,
Assistant Officer in Charge, and key facility staff.
Type of Review:
This review is a scheduled Detention Standard Review to determine compliance with ICE
National Detention Standards for facilities used over 72 hours.
Review Summary:
The El Centro Service Processing Center is accredited by American Correctional Association
(ACA), National Commission on Correctional Health Care (NCCHC), and the Joint Commission
on Accreditation of Healthcare Organizations (JCAHO).
Standards Compliance:
The following statistical information provides a direct comparison of the June 2007 ADR and the
ADR conducted in June 2008.
June 2007, Review
Compliant
38
Deficient
0
At Risk
0
Non-Applicable
0

June, 2008
Review
Compliant
38
Deficient
0
At Risk
0
Non-Applicable
0

 
FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)

1/6

RIC Issues and Concerns
Administration
The overall rating evidenced in the working papers of the ECSPC indicates compliance with all
38 National Detention Standards (NDS). Although there were no deficiencies noted,
considerable attention must continue to be afforded to security and life safety concerns discussed
below.
It is clear that management has identified security and life safety weaknesses, requested funding
for enhancements, and ultimately has received authority for corrective actions. To this end, there
are currently multiple, in-progress contactor projects under the supervision of the Facility
Manager. Consideration should be given to providing additional subject matter expert(s) to
assist with the management of these projects. It is imperative these projects continue to receive
the highest priority from management in order that a safe and secure environment for staff,
detainees, and the public are maintained.
Life Safety
The fire safety program provides staff and detainees a sufficient level of safety.
The fire safety systems throughout the facility, including fire alarms, sprinkler systems, kitchen
hood fire suppression systems, emergency generators and emergency lighting/exit lights, are not
inspected and tested monthly, quarterly, or annually as required by the National Fire Protection
Association (NFPA) standards, NFPA 72, NFPA 25 and NFPA 17A, NFPA 110, and NFPA 70.
There is a contract with Candelaria Corporation (effective 09/19/07) to conduct testing,
inspecting, and maintenance of these systems. On-site inspection and review of documentation
failed to verify Candelaria is fulfilling contracted services as required by the statement of work.
Candelaria was notified of this problem and is scheduled to begin service on Monday, June 23,
2008. Management should provide direct supervision of the contractor to ensure compliance.
Locking mechanisms used in internal security gates, housing units, and processing unit are not
detention grade hardware as required by NFPA 101, A.23.1.2.2.1. A security enhancement
project is currently underway to replace all unauthorized locks.
Review of documentation for fire drills indicated that quarterly drills in the housing units were
not taking place across all shifts. Corrective action was taken and drills are now being conducted
as required. Continued monitoring of the fire drill exercises is essential to ensure staff and
detainees are aware of their responsibilities in emergencies.
Management should consider dedicating a position to supervise life safety/environmental health
program compliance. Dedicated assistance with the management of this program would enhance
safety and security for staff and detainees.
Keys
 
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2/6

b2 high

b2 high

The daily accounting of all keys recently came into compliance with NDS. As a new procedure,
ICE supervisory staff should continue to monitor the program carefully until AKAL staff is more
familiar with the requirement.

b2 high

Locks

b2 high

Vehicle Entrance

b2 high

The review team recommended adding an additional officer position to the vehicle entrance
during the review for added security during construction. Management agreed with this
recommendation and immediately assigned an officer. Because this entrance is very long,
(spanning the length of the facility) it is further recommended this added security post be made
permanent with post orders developed to identify position responsibilities.
The entrance project also includes installation of surveillance cameras and monitors. This
additional technology will help maintain appropriate supervision and security combined with
increased staffing.

 
FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)

3/6

The vehicle entrance project must be closely managed to expedite its completion. The facility is
at higher risk during this project. Vigilance by all concerned cannot be overstated.
Fencing

b2 high

b2 high

Administration Building Security

b2 high

CCTV Control Center

b2 high

Medical Vacancies
There are 30 PHS medical staff positions authorized for ECSPC. Currently, there are six
vacancies. Health care accessibility has not been adversely affected by these vacancies however;
the positions are necessary and should be encumbered as soon as possible.
Title 18 Notification
It is recommended that Title 18 information be posted conspicuously at all facility entrances
notifying all persons entering, that alcohol, firearms, ammunition, explosive devices, and guns
are prohibited.

 
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4/6

Lexis Nexis
Lexis Nexis is provided in English for detainee use. It is recommended that ICE consider
making available the Spanish version of Lexis Nexis given the ethnic demographics of the
detainee population.
Area of Strength
The frequency of daily, weekly, and unannounced rounds to all housing units by Deportation
Officers, Supervisory Deportation Officers, Assistant OIC, and AFOD/OIC is noteworthy as
commendable. The spontaneity of rounds and subsequent documentation evidencing action
taken is without doubt among the best we have evaluated.
The NDS Compliance Team documentation and preparation is also significant. All
documentation and evidence required for the compliance review was made available to the
review team. Local policy and procedures have been well developed establishing a solid
foundation toward standards compliance. The extensive documentation and policy development
ranks well above others we have evaluated.

Recommended Rating and Justification
It is the Reviewer-in-Charge recommendation that the facility receive a rating of “Good.” It is
also recommended by the RIC that a Plan of Action be required for this facility to identify and
implement necessary corrective actions for the RIC Issues and Concerns.
RIC Assurance Statement
All findings of this review have been documented on the Detention Review Worksheet attached
and are supported by the written documentation contained in the review file.

 
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5/6

6415 Calder, Suite B  Beaumont, Texas 77706
409.866.9920  www.correctionalexperts.com
Making a Difference!

June 24, 2008
MEMORANDUM FOR:

FROM:

James T. Hayes, Jr.
Acting Director
Office of Detention and Removal Operations
b6, b7c

Reviewer-In-Charge/SME Security
SUBJECT:

El Centro Service Processing Center Annual Detention Review

Creative Corrections conducted the Annual Detention Review (ADR) of the El Centro Service
Processing Center (ECSPC) located in El Centro, California, on June 17-19, 2008. As noted on
b6, b7c
the attached documents, my team of Subject Matter Experts included:
,
b6, b7c
Administration;
, Health Services;
, Safety and Environmental
b6, b7c
b6, b7c
Health; and
Services.
A closeout meeting was held on June 19, 2008, during which all concerns and recommendations
b6, b7c
b6, b7c
were discussed with Assistant Field Office Director,
,
Assistant Officer in Charge, and key facility staff.
Type of Review:
This review is a scheduled Detention Standard Review to determine compliance with ICE
National Detention Standards for facilities used over 72 hours.
Review Summary:
The El Centro Service Processing Center is accredited by American Correctional Association
(ACA), National Commission on Correctional Health Care (NCCHC), and the Joint Commission
on Accreditation of Healthcare Organizations (JCAHO).
Standards Compliance:
The following statistical information provides a direct comparison of the June 2007 ADR and the
ADR conducted in June 2008.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)

June 2007
Review
Compliant
38
Deficient
0
At Risk
0
Non-Applicable
0

June, 2008
Review
Compliant
38
Deficient
0
At Risk
0
Non-Applicable 0

Area of Strength
The frequency of daily, weekly, and unannounced rounds to all housing units by Deportation
Officers, Supervisory Deportation Officers, Assistant OIC, and AFOD/OIC is noteworthy as
commendable. The spontaneity of rounds and subsequent documentation evidencing action
taken is without doubt among the best we have evaluated.
The NDS compliance team documentation and preparation is also significant. All
documentation and evidence required for the compliance review was made available to the
review team. Local policy and procedures have been well developed, establishing a solid
foundation toward standards compliance. The extensive documentation and policy development
ranks well above others we have evaluated.
Recommended Rating and Justification
It is the Reviewer-in-Charge (RIC) recommendation that the facility receive a rating of “Good.”
RIC Assurance Statement
All findings of this review have been documented on the Detention Review Worksheet attached
and are supported by the written documentation contained in the review file.

2

 
FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)

DETENTION FACILITY INSPECTION FORM
FACILITIES USED LONGER THAN 72 HOURS

A. Type of Facility Reviewed
ICE Service Processing Center
ICE Contract Detention Facility
ICE Intergovernmental Service Agreement

G. Accreditation Certificates
List all State or National Accreditation[s] received:
ACA, NCCHC, JCAHO
Check box if facility has no accreditation[s]

B. Current Inspection
Type of Inspection
Field Office
HQ Inspection
Date[s] of Facility Review
June 17-19, 2008

H. Problems / Complaints (Copies must be attached)
The Facility is under Court Order or Class Action Finding
Court Order
Class Action Order
The Facility has Significant Litigation Pending
Major Litigation
Life/Safety Issues
Check if None.

C. Previous/Most Recent Facility Review
Date[s] of Last Facility Review
June 19-21, 2007
Previous Rating
Superior
Good
Acceptable
Deficient

At-Risk

D. Name and Location of Facility
Name
El Centro Service Processing Center
Address (Street and Name)
1115 North Imperial Avenue
City, State and Zip Code
El Centro, California
County
Imperial
Name and Title of Chief Executive Officer
(Warden/OIC/Superintendent)
b6, b7c

Telephone # (Include Area Code)
(760) 336- b6, b7c
Field Office / Sub-Office (List Office with oversight responsibilities)
San Diego, California
Distance from Field Office
120 miles

I. Facility History
Date Built
1975
Date Last Remodeled or Upgraded
Presently under Construction
Date New Construction / Bed space Added
None
Future Construction Planned
Yes
No Date: Commenced June 2007 to Present
Current Bed Space
544

Future Bed Space (# New Beds only)
Number: N/A Date: N/A

J. Total Facility Population
Total Facility Intake for previous 12 months
5,409
Total ICE Mandays for Previous 12 months
168,492
K. Classification Level (ICE SPCs and CDFs Only)
L-1
L-2
Adult Male
273
137
Adult Female
N/A
N/A

L-3
65
N/A

E. Creative Corrections Review Team
b6, b7c

RIC/SME Security

b6, b7c

SME Administration

b6, b7c

b6, b7c

b6, b7c

L.

SME Safety and Environmental Health

Facility Capacity
Rated

Operational

Emergency

Adult Male
544
480
562
Adult Female
N/A
N/A
N/A
Facility holds Juveniles Offenders 16 and older as Adults

SME Food Service
, SME Health Services

F. CDF/IGSA Information Only
Contract Number
Date of Contract or IGSA
N/A
N/A
Basic Rates per Man-Day
N/A
Other Charges: (If None, Indicate N/A)
N/A
Estimated Man-days per Year
N/A

M. Average Daily Population
ICE
Adult Male
462
Adult Female
N/A

USMS

Other

0
N/A

0
N/A

N. Facility Staffing Level
Security:
b2 high

b2 high

AKAL SECURITY CONTRACT # 8CL-2-C-0003
$59,499,905.52
AHTNA CONTRACT # HSCEOP-07-C-00016
$58, 845.32

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

SIGNIFICANT INCIDENT SUMMARY WORKSHEET
In order for Creative Corrections to complete its review of your facility, you must complete the following worksheet prior to your
scheduled review dates. This worksheet must contain data for the past twelve months. We will use this worksheet in conjunction with
the ICE Detention Standards to assess your detention operations with regard to the needs of ICE and its detainee population. Failure
to complete this worksheet will result in a delay in processing this report, and may result in a reduction or removal of ICE detainees
from your facility.
DESCRIPTION

Jan – Mar

Apr – Jun

Jul – Sep

Oct – Dec

Types (Sexual 1 , Physical, etc.)

P

P

P

P

0

0

0

0

1

3

1

3

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

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

43

37

13

11

19

13

5

6

0

0

0

0

0

0

0

0

17

15

17

5

1

0

0

0

INCIDENTS
Assaults

With Weapon
Without Weapon
Assault:
Detainee on
Staff

Types (Sexual Physical, etc.)
With Weapon
Without Weapon

Number of Forced Moves, incl.
Forced Cell Moves 2
Disturbances 3
Number of Times Chemical
Agents Used
Number of Times Special
Reaction Team Deployed/Used
# Times Four/Five Point
Restraints Applied/Used

0

Number/Reason (M=Medical,
V=Violent Behavior, O=Other)
Type (C=Chair, B=Bed,
BB=Board, O=Other)

Offender / Detainee Medical
Referrals as a Result of Injuries
Sustained.
Escapes
Attempted
Actual
Grievances
# Received
# Resolved in Favor of
Offender/Detainee
Reason (V=Violent, I=Illness,
S=Suicide, A=Attempted
Suicide, O=Other)

Deaths

Psychiatric / Medical Referrals

1
2
3

Number
# Medical Cases Referred for
Outside Care
# Psychiatric Cases Referred
for Outside Care

Oral, anal or vaginal penetration or attempted penetration involving at least 2 parties, whether it is consenting or non-consenting
Routine transportation of detainees/offenders is not considered “forced”
Any incident that involves four or more detainees/offenders, includes gang fights, organized multiple hunger strikes, work stoppages, hostage situations,
major fires, or other large scale incidents

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 2 of 4

DHS/ICE DETENTION STANDARDS REVIEW SUMMARY REPORT
1. ACCEPTABLE

2. DEFICIENT

3. AT-RISK

4. REPEAT
FINDING

5. NOT
APPLICABLE

LEGAL ACCESS STANDARDS
1.
2.
3.
4.

1.

2.

3.

4.

5.

Access to Legal Materials
Group Presentations on Legal Rights
Visitation
Telephone Access

DETAINEE SERVICES
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.

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

HEALTH SERVICES
18.
19.
20.
21.

Hunger Strikes
Medical Care
Suicide Prevention and Intervention
Terminal Illness, Advanced Directives and Death

SECURITY AND CONTROL
22.
23.
24.
25.
26.
27.
28.
29.
30.
31.
32.
33.
34.
35.
36.
37.
38.

Contraband
Detention Files
Disciplinary Policy
Emergency Plans
Environmental Health and Safety
Hold Rooms in Detention Facilities
Key and Lock Control
Population Counts
Post Orders
Security Inspections
Special Management Units (Administrative Detention)
Special Management Units (Disciplinary Segregation)
Tool Control
Transportation (Land management)
Use of Force
Staff / Detainee Communication (Added August 2003)
Detainee Transfer (Added September 2004)

ALL

FINDINGS OF DEFICIENT AND AT-RISK REQUIRE WRITTEN COMMENT DESCRIBING THE FINDING AND
WHAT IS NECESSARY TO REACH COMPLIANCE.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 3 of 4

RIC REVIEW ASSURANCE STATEMENT
BY SIGNING BELOW, THE REVIEWER-IN-CHARGE (RIC) CERTIFIES THAT:
1.

2.

ALL FINDINGS OF NON-COMPLIANCE WITH POLICY OR INADEQUATE CONTROLS, AND FINDINGS OF NOTEWORTHY
ACCOMPLISHMENTS, CONTAINED IN THIS INSPECTION REPORT, ARE SUPPORTED BY EVIDENCE THAT IS SUFFICIENT AND
RELIABLE; AND
WITHIN THE SCOPE OF THIS REVIEW, THE FACILITY IS OPERATING IN ACCORDANCE WITH APPLICABLE LAW AND POLICY, AND
PROPERTY AND RESOURCES ARE BEING EFFICIENTLY UTILIZED AND ADEQUATELY SAFEGUARDED, EXCEPT FOR ANY
DEFICIENCIES NOTED IN THE REPORT.

REVIEWER-IN-CHARGE
Reviewer-In-Charge: (Print Name)

Signature

b6, b7c

Title & Duty Location

Date

Reviewer in Charge/SME Security

June, 20, 2008

TEAM MEMBERS
Print Name, Title, & Duty Location
b6, b7c

Print Name, Title, & Duty Location

SME Administration

b7c

Print Name, Title, & Duty Location
b6, b7c

SME Safety and Environmental Health

RECOMMENDED RATING:

SME Health Services

Print Name, Title, & Duty Location
b6, b7c

SME Food Services

SUPERIOR
GOOD
ACCEPTABLE
DEFICIENT
AT-RISK

Comments: While the overall compliance rating evidenced in the working papers of the El Centro Service Processing Center
indicates compliance in all 38 National Detention Standards, considerable attention should continue to be given to security and life
safety concerns discussed in the final report. It is clear that management has identified security and life safety weaknesses, requested
funding for enhancements, and ultimately has received authority for corrective action. To this end, there are currently multiple
contactor projects ongoing. It is imperative these projects continue to receive the highest priority from management in order that a
safe and secure environment for staff, detainees, and the public are maintained.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 4 of 4

ICE Detention Standards
Compliance Review
El Centro Service Processing Center
June 17-19, 2008
REPORT DATE – June 24, 2008

Contract Number: ODT-6-D-0001
Order Number: HSCEOP-07-F-01016
Percy H. Pitzer, Executive Vice President
Creative Corrections
6415 Calder, Suite B
Beaumont, TX 77706
b6, b7c
COTR
U.S. Imm
oms Enforcement
Detention Standards Compliance Unit
801 I Street NW
Washington, DC 20536

 

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)

 

Creative Corrections
6415 Calder, Suite B
Beaumont, Texas 77706

Condition of Confinement Review Worksheet
(This document must be attached to each Inspection Form)
This Form to be used for Inspections of Facilities used longer than 72 Hours

Detention Review Worksheet
Local Jail – IGSA
State Facility – IGSA
ICE Contract Detention Facility
Service Processing Center
Name
El Centro Service Processing Center
1115 North Imperial Avenue
El Centro, California
County
Imperial
Name and Title of Chief Executive Officer (Warden/OIC/Superintendent)
b6, b7c

Name and Title of Reviewer-In-Charge
b6, b7c

Date[s] of Review
June 17-19, 2008
Type of Review
Headquarters

Operational

Special Assessment

Other

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

TABLE OF CONTENTS
SECTION I. LEGAL ACCESS STANDARDS ............................................................................................................................ ..3

ACCESS TO LEGAL MATERIALS ................................................................................................................................................
GROUP PRESENTATIONS ON LEGAL RIGHTS .............................................................................................................................
VISITATION ...............................................................................................................................................................................
ACCESS TO TELEPHONES...........................................................................................................................................................
SECTION II. DETAINEE SERVICES STANDARDS .................................................................................................................... 11
ADMISSION AND RELEASE ........................................................................................................................................................
CLASSIFICATION SYSTEM .........................................................................................................................................................
CORRESPONDENCE AND OTHER MAIL ......................................................................................................................................
DETAINEE HANDBOOK ..............................................................................................................................................................
FOOD SERVICE ..........................................................................................................................................................................
FUNDS AND PERSONAL PROPERTY............................................................................................................................................
DETAINEE GRIEVANCE PROCEDURES .......................................................................................................................................
ISSUANCE AND EXCHANGE OF CLOTHING, BEDDING, AND TOWELS ........................................................................................
MARRIAGE REQUESTS ...............................................................................................................................................................
NON-MEDICAL ESCORTED TRIPS ..............................................................................................................................................
RECREATION .............................................................................................................................................................................
RELIGIOUS PRACTICES ..............................................................................................................................................................
VOLUNTARY WORK PROGRAM .................................................................................................................................................
SECTION III. HEALTH SERVICES STANDARDS ................................................................................................................... 33
HUNGER STRIKES ......................................................................................................................................................................
MEDICAL CARE .........................................................................................................................................................................
SUICIDE PREVENTION AND INTERVENTION ..............................................................................................................................
TERMINAL ILLNESS, ADVANCED DIRECTIVES AND DEATH ......................................................................................................
SECTION IV. SECURITY AND CONTROL STANDARDS ........................................................................................................ 44
CONTRABAND ...........................................................................................................................................................................
DETENTION FILES......................................................................................................................................................................
DISCIPLINARY POLICY ..............................................................................................................................................................
EMERGENCY PLANS ..................................................................................................................................................................
ENVIRONMENTAL HEALTH AND SAFETY ..................................................................................................................................
HOLD ROOMS IN DETENTION FACILITIES .................................................................................................................................
KEY AND LOCK CONTROL.........................................................................................................................................................
POPULATION COUNTS ................................................................................................................................................................
POST ORDERS ............................................................................................................................................................................
SECURITY INSPECTIONS ............................................................................................................................................................
SPECIAL MANAGEMENT UNIT (ADMINISTRATIVE SEGREGATION)...........................................................................................
SPECIAL MANAGEMENT UNIT (DISCIPLINARY SEGREGATION) ................................................................................................
TOOL CONTROL .........................................................................................................................................................................
TRANSPORTATION (LAND) .......................................................................................................................................................
USE OF FORCE ...........................................................................................................................................................................
STAFF/DETAINEE COMMUNICATIONS .......................................................................................................................................
DETAINEE TRANSFER STANDARD .............................................................................................................................................

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

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 2 of 73

SECTION I.
LEGAL ACCESS STANDARDS

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 3 of 73

ACCESS TO LEGAL MATERIALS
POLICY: FACILITIES HOLDING ICE DETAINEES SHALL PERMIT DETAINEES ACCESS TO A LAW LIBRARY, AND PROVIDE LEGAL MATERIALS,
FACILITIES, EQUIPMENT, DOCUMENT COPYING PRIVILEGES, AND THE OPPORTUNITY TO PREPARE LEGAL DOCUMENTS.
COMPONENTS
Y
N
NA
REMARKS
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 Law Library provides
The library contains a sufficient number of chairs, is well lit, and is
seating for 20 detainees, 6 large
reasonably isolated from noisy areas.
tables, is well lit, clean and
orderly.
The Law Library provides 6
The law library is adequately equipped with typewriters and/or
Lexis Nexis stations and 6
computers, and has sufficient supplies for daily use by the detainees.
typewriters for detainee use.
In addition to the physical law library, detainees have access to the Lexis
Nexis electronic law library.
Where provided, the Lexis Nexis library 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 ICE prior to inclusion.
The Facility Recreation
There is a designated ICE or facility employee who inspects, updates, and
Specialists are responsible for
maintains/replaces legal materials and equipment on a routine basis.
oversight of the Law Library.
Detainees are offered a minimum 5 hours per week in the law library.
Detainees are offered
Detainees are not required to forego recreation time in lieu of library
opportunity for at least 5 hours
usage. Detainees facing a court deadline are given priority use of the law
per week in the law library.
library.
Detainees may request materials not currently in the law library. Each
request is reviewed and, where appropriate, an acquisition request is
timely initiated.
Requests for copies of court decisions are
accommodated within 3 – 5 business days.
Detainees are allowed to assit
Detainees are permitted to assist other detainees, voluntarily and free of
others in researching and
charge, in researching and preparing legal documents, consistent with
preparing legal documents.
security.
ECSPC does not have nonIlliterate or non-English-speaking detainees without legal representation
English language law books or
receive access to more than just English-language law books after
non-English Lexis Nexis at this
indicating their need for help.
time.
Detainees may retain a reasonable amount of personal legal material in
the general population and in the special management unit. Stored legal
materials are accessible within 24 hours of a written request.
Detainees housed in Administrative Detention 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.
Facility staff informs ICE Management when a detainee or group of
detainees is denied access to the law library or law materials.
Detainees who seek judicial relief on any matter are not subjected to
reprisals, retaliation, or penalties.

ACCEPTABLE

DEFICIENT

AT-RISK

REPEAT FINDING

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REMARKS:
ECSPC has a very good law library and procedures in place to give ICE detainees access to the library and other legal materials.
Although not mandated by policy, law books and Lexis Nexis in a Spanish version would assist non-English literate detainees with
legal research.
b6, b7c

/ June 19, 2008

UDITOR S SIGNATURE / DATE

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GROUP LEGAL RIGHTS PRESENTATIONS
POLICY: FACILITIES HOUSING ICE DETAINEES SHALL PERMIT AUTHORIZE PERSONS TO MAKE PRESENTATIONS TO GROUPS OF DETAINEES
FOR THE PURPOSE OF INFORMING THEM OF U.S. IMMIGRATION LAW AND PROCEDURES, CONSISTENT WITH THE SECURITY AND ORDERLY
OPERATION OF EACH FACILITY. ICE ENCOURAGES SUCH PRESENTATIONS, WHICH INSTRUCT DETAINEES ABOUT THE IMMIGRATION SYSTEM AND
THEIR RIGHTS AND OPTIONS WITHIN IT.
CHECK HERE IF NO GROUP PRESENTATIONS WERE CONDUCTED WITHIN THE PAST 12 MONTHS.
OVERALL AND CONTINUE ON WITH NEXT PORTION OF WORKSHEET.
YES
NO
NA
COMPONENTS

MARK STANDARD AS ACCEPTABLE
REMARKS

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 timely and proper notification to
attorneys or accredited representatives.
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 provides 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.
Presenters are permitted to meet with small groups of detainees to discuss
their cases after the group presentation. ICE or authorized detention staff
is 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 designee; and the reasons for
suspension are documented. The Headquarters Office for Detention and
Removal, Field Operations and Detention management Division, is
notified when a group or individual is suspended from making
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

ACCEPTABLE

DEFICIENT

AT-RISK

REPEAT FINDING

REMARKS:
ECSPC has had no requests from outside persons or groups to make presentations regarding legal rights. The facility has excellent
policy in place to accommodate authorized requests should they occur.
b6, b7c
/ June 19, 2008
AUDITOR’S SIGNATURE / DATE

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VISITATION
POLICY: ICE SHALL PERMIT DETAINEES TO VISIT WITH FAMILY, FRIENDS, LEGAL REPRESENTATIVES, SPECIAL INTEREST GROUPS, AND THE
NEWS MEDIA.
COMPONENTS
Y
N
NA
REMARKS
Visitation hours are published in
the Detainee Handbook,
displayed at the front entrance,
There is a written visitation schedule and hours for general visitation.
and provided in a "Visitation
Handout" distributed in the front
lobby.
The visitation hours tailored to the detainee population and the demand
for visitation.

The visitation schedule and rules are available to the public.

ECSPC makes the schedule and
procedures available to the
public, both in written form
"Visitation Handout" and
telephonically.

The hours for all categories of visitation are posted in the visitation
waiting area.
A written copy of the rules regulating visitation and the hours of
visitation is available to visitors.
A general visitation log is maintained.

The facility maintains a general
visitation log as well as a
"Attorney Visit" log.

The detainees are permitted to retain personal property items specified
in the standard.
A visitor dress code is available to the public.
Visitors are searched and identified according to standard requirements.
The requirement on visitation by minors is complied with.

The facility allows minor
visitors under direct supervision
of a accompying adult.

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

ECPC does allow minors to
visit.

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.

ECPC does allow minors to
visit.

Detainees in special housing are afforded visitation.

Detainees housing in the Special
Management Unit retain
visitation privileges.

Legal visitation is available seven (7) days a week, including holidays.
On regular business days legal visitation hours are provide for a
minimum of eight (8) hours per day, and a minimum of four hours per
day on weekends and holidays.
On regular business days, detainees are given the option of continuing a
meeting with a legal representative through a scheduled meal.
Private consultation rooms are available for attorney meetings. There is
a mechanism for the detainee and his/her representative to exchange
documents.

Four private consultation rooms
are available for attorney
meetings. Documents may be
exchanged through the secure
document tranfer portal.

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VISITATION
POLICY: ICE SHALL PERMIT DETAINEES TO VISIT WITH FAMILY, FRIENDS, LEGAL REPRESENTATIVES, SPECIAL INTEREST GROUPS, AND THE
NEWS MEDIA.
Detainee search procedures are
There are written procedures governing detainee searches.
contained in the SOP Admisson
and Release, Section 3, C.
When strip searches are required after every contact visit with a legal
ECPC does not require strip
representative, the facility provides an option for non-contact visits with
seaches following visitation.
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.
The decision to permit or deny a tour is not delegated below the level of
Field Office Director.
Provisions for NGO visitation, as stated in the Detention Standards, are
complied with.
Law enforcement officials who request to visit with a detainee are
referred to the ICE Field Office for approval.
Former detainees or aliens in proceedings, requesting to visit with a
detainee, are referred to the OIC or ICE Field Office.
Medical or psycological
examination by a practitioner or
expert not associated with ICE
or the facility is permitted to
provide a detainee with
information useful in
administrative proceedings
(SOP, Visitation, Section O, 5.)

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

ACCEPTABLE

DEFICIENT

AT-RISK

REPEAT FINDING

REMARKS:
ECSPC has four small non-contact visitation rooms, which are used to accommodate all visitations at the facility. The ICE detention
standard regarding visitation encourages each facility to provide a visitation area appropriately furnished and arranged, and as
comfortable and pleasant as practical, although policy and procedures regarding visitation are in full compliance, the visitation area
needs upgrading.
b6, b7c
/ June 19, 2008
AUDITOR’S SIGNATURE / DATE

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DETAINEE TELEPHONE ACCESS
POLICY: ALL FACILITIES HOUSING ICE DETAINEES WILL PERMIT DETAINEES’ REASONABLE AND EQUITABLE ACCESS TO TELEPHONES.
COMPONENTS
Detainees are allowed access to telephones during established facility
waking hours.
Upon admittance, detainees are made aware of the facility's telephone
access policy.

Y

N

NA

REMARKS

Information regarding telephone
access is provided in the
Detainee Handbook, page 12.

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

The ECPC rated capacity is 544,
there are 53 telephones
available.
Procedures require the phones to
be checked daily utilizing the
"Health, Safety, and Security
Shift Report."

The facility administration promptly reports out-of-order telephones to
the facility’s telephone service provider.
The facility administration monitors repair progress and takes
appropriate measures to ensure that required repairs are begun and
completed timely.
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.

Unit phones have privacy panels
in place.
A Detainee may request staff
assistance regarding a private
legal call, use of an office phone
or other special arrangement
may be provided.

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.
The OIG phone number for reporting abuse is programmed into the
detainee phone system and the phone number was checked by the
inspector during the review.

The OIG hotline number is
accessible through the speed
dial process. Instructions are
available at the phone banks, as
well as on the unit bulletin
boards.

In facilities unable to fully meet this requirement initially because of
limitations of its telephone service, ICE makes alternate arrangements to
provide required access within 24 hours of a request by a detainee.
No restrictions are placed on detainees attempting to contact attorneys
and legal service providers who are on the approved “Free Legal
Services List”.
Special arrangements are made to allow detainees to speak by telephone
with an immediate family member detained in another Facility.
Any 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.

Unless

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DETAINEE TELEPHONE ACCESS
POLICY: ALL FACILITIES HOUSING ICE DETAINEES WILL PERMIT DETAINEES’ REASONABLE AND EQUITABLE ACCESS TO TELEPHONES.
COMPONENTS
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.
Detainees in administrative detention and protective custody are
afforded the same telephone 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.

ACCEPTABLE

DEFICIENT

Y

N

NA

REMARKS
ECSPC permits detainees
housed in SMU to make direct
and/or free calls.

ECPC has monitoring
notification posted at the
phones, although phone
monitoring is not on-going at
this time.

AT-RISK

REPEAT FINDING

REMARKS:
The facility has an adequate number of accessible phones available to the inmate population.
b6, b7c
/ June 19, 2008
AUDITOR’S SIGNATURE / DATE

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SECTION II.
DETAINEE SERVICES STANDARDS

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 ASSESSMENT AND CLASSIFICATION
PROCESS; A BODY SEARCH; AND A SEARCH OF PERSONAL BELONGINGS, WHICH WILL BE INVENTORIED, DOCUMENTED, AND SAFEGUARDED AS
NECESSARY.

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

All new arrivals are searched in accordance with the “Detainee Search”
standard. An officer of the same sex as the detainee conducts the search
and the search is conducted in an area that affords as much privacy as
possible.
Detainees are stripped searched only when cause has been established
and not as routine policy. Non-criminal detainees are not strip-searched
but are patted down, unless reasonable suspicion is established.
The “Contraband” standard governs all personal property searches.
IGSAs/CDFs use or have a similar contraband standard. Staff prepares
a complete inventory of each detainee’s possessions. The detainee
receives a copy.

Y

N

NA

REMARKS
The orientation process includes
issuance of the Detainee
Handbook and is supported by
an orientation video. The facility
has procedures in place to
communicate effectively with
different languages, including
an interpreter service
(InterpreTalk).
All new intakes are screened by
medical staff in compliance with
the "Detainee Access to Medical
Care" Standard.
Admission staff use
documentation from the field
agent, the I-216, the Alien
Booking Record (Form I-385),
the medical questionnaire, and
other information contained in
the accompanying A File to
classify each new detainee.
The facility uses form G-1025
"Record of Search” and
conducts searches in compliance
with the "Detainee Search
Standard."
A supervisor must approve any
strip seach even for cause. The
search is documented on Form
G-1025.
ECSPC prepares a complete
inventory of all detainee
personal property (form G-589)
Detainee Personal Property
Receipt. The detainee signs and
receives a copy of the
document.

Staff completes Form I-387 or similar form for CDFs and IGSAs for
every lost or missing property claim. Facilities forward all I-387 claims
to ICE.

An Officer completes Form I387, "Report of Detainee's
Missing Property" if a detainee
claims lost or missing property.

Detainees are issued appropriate and sufficient clothing and bedding for
the climatic conditions.

Initial issue includes bedding
and clothing in number and
weights appropriate for the
facility environment and local
weather conditions.
The facility issues personal
hygiene items during intake.
They are issued and replenished
as needed without charge to the
detainee.
The facility uses Form I-203 to
document releases.

The facility provides and replenishes personal hygiene items as needed.
Gender-specific items are available. ICE Detainees are not charged for
these items.

All releases are properly coordinated with ICE using a Form I-203.
Staff completes paperwork/forms for release as required.

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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 ASSESSMENT AND CLASSIFICATION
PROCESS; A BODY SEARCH; AND A SEARCH OF PERSONAL BELONGINGS, WHICH WILL BE INVENTORIED, DOCUMENTED, AND SAFEGUARDED AS
NECESSARY.
COMPONENTS
Y
N
NA
REMARKS

ACCEPTABLE

DEFICIENT

AT-RISK

REPEAT FINDING

REMARKS:
ECSPC has excellent policy and procedures in place regarding admission and release. Processing staff are professional and diligent in
the performance of their duties.
b6, b7c
June 19, 2008
AUDITOR’S SIGNATURE / DATE

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

COMPONENTS
The facility has a system for classifying detainees. In CDFs and IGSAs,
an Objective Classification System or similar is used.

Y

N

NA

REMARKS
ECSPC has an objective
classification system based upon
directives contained in the

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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

COMPONENTS

Y

N

The facility classification system includes:
 Classifying detainees upon arrival;
 Separating from the general population those individuals who
cannot be classified upon arrival; and
 The first-line supervisor or designated classification specialist
reviewing every classification decision.
The intake/processing officer reviews work-folders, A-files, etc., to
identify and classify each new arrival.

Detainees are assigned a
security level and housing
assignment based upon the DCS
score.

A detainee's classification-level does not affect his/her recreation
opportunities. Detainees recreate with persons of similar classification
designations.
Detainee work assignments are based upon classification designations.
The classification process includes reassessment/reclassification. At
IGSA’s, detainees may request reassessment 60 days after arrival.

Detainees at ECPC are
reassesed 45 to 60 days after
initial classification.
The SDDO for Det Ops. has the
authority to reduce a
classification level on appeal

Procedures exist for a detainee to appeal their classification assignment.
Only a designated supervisor or classification specialist has the
authority to reduce a classification-level on appeal.
Classification appeals are resolved within five business days and
detainees are notified of the outcome within 10 business days.
Classification designations may be appealed to a higher authority, such
as the Warden or equivalent.
The Detainee Handbook or equivalent for IGSAs explains the
classification levels, with the conditions and restrictions applicable to
each.

DEFICIENT

REMARKS
National Detention Standard
titled "Detainee Classification
System.”

All available documentation and
information is utilized by the
intake/processing officer.

Staff uses only information that is factual, and reliable to determine
classification assignments. Opinions and unsubstantiated/ unconfirmed
reports may be filed but are not used to score detainees classifications.
Housing assignments are based on classification-level.

ACCEPTABLE

NA

The detainee may appeal a
SDDO decision to the AFOD.
Detainee Handbook,
Classification Levels, page 4/5.

AT-RISK

REPEAT FINDING

REMARKS:
Detainees are classified using available pertinent information. The detainee classification form and resultant comprehensive custody
score play a major role to further the safety and security of the facility.
b6, b7c
June 19, 2008
AUDITOR’S SIGNATURE / DATE

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CORRESPONDENCE AND OTHER MAIL
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
YES
NO
NA
REMARKS
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
Key information is provided in
the language(s) spoken by significant numbers of detainees. List any
Spanish in all units.
exceptions.
Incoming mail is distributed to detainees within 24 hours or 1 business
day after it is received and inspected.
Outgoing mail is delivered to the postal service within one business day
of its entering the internal mail system (excluding weekends and
holidays).
Staff does not open and inspect incoming general correspondence and
The mailroom officer identifies
other mail (including packages and publications) without the detainee
the detainee, and then opens the
present unless documented and authorized in writing by the Warden or
mail in his presence.
equivalent for prevailing security reasons.
Staff does not read incoming general correspondence without the
Warden’s prior written approval.
Staff does not inspect incoming special Correspondence for physical
contraband or to verify the “special” status of enclosures without the
detainee present.
Staff is prohibited from reading or copying incoming special
correspondence.
Staff is 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 copied.
The AFOD may reject incoming
The official authorizing the rejection of incoming mail sends written
or outgoing mail. The detainee
notice to the sender and the addressee.
and/or sender receives
notification of the rejection.
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 date.
The mail room officer
The procedure for safeguarding cash removed from a detainee protects
documents funds received in the
the detainee from loss of funds and theft. The amount of cash credited to
mail, the detainee may retain
detainee accounts is accurate. Discrepancies are documented and
amounts under $40.00,
investigated. Standard procedure includes issuing a receipt to the
otherwise the detainee is
detainee.
escorted to processing where a
receipt is issued.
Original identity documents (e.g., passports, birth certificates) are
immediately removed and forwarded to ICE staff for placement in Afiles.
Staff provides the detainee a copy of his/her identity document(s) upon
request.

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CORRESPONDENCE AND OTHER MAIL
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.
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.
Every indigent detainee has the opportunity to mail, at government
ECPC places no limitations on
expense, reasonable correspondence about a legal matter, in three one
legal mail.
ounce letters per week and packages deemed necessary by ICE.
ECPC does not sell stamps,
The facility has a system for detainees to purchase stamps and for mailing
outgoing mail is stamped by a
all special correspondence and a minimum of 5 pieces of general
metered machine.
correspondence per week.
The facility provides writing paper, envelopes, and pencils at no cost to
ICE detainees.

ACCEPTABLE

DEFICIENT

AT-RISK

REPEAT FINDING

REMARKS:
Detainees send and receive correspondence in a timely manner.
b6, b7c
/ June 19, 2008
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DETAINEE HANDBOOK
POLICY: EVERY OIC WILL DEVELOP A SITE-SPECIFIC DETAINEE HANDBOOK TO SERVE AS AN OVERVIEW OF, AND GUIDE TO, THE DETENTION
POLICIES, RULES, AND PROCEDURES IN EFFECT AT THE FACILITY. THE HANDBOOK WILL ALSO DESCRIBE THE SERVICES, PROGRAMS, AND
OPPORTUNITIES AVAILABLE THROUGH VARIOUS SOURCES, INCLUDING THE FACILITY, ICE, PRIVATE ORGANIZATIONS, ETC. EVERY DETAINEE
WILL RECEIVE A COPY OF THIS HANDBOOK UPON ADMISSION TO THE FACILITY.
COMPONENTS
Y
N
NA
REMARKS
The handbook consists of 44
The detainee handbook is written in English and translated into Spanish,
pages with an easy to read table
or into the next most-prevalent Language(s).
of contents in the front.
The handbook is supplemented by the facility orientation video, where
one is provided.
All staff members receive a handbook and training regarding the
handbook contents.
All revisions are posted on the
The handbook is revised as necessary and there are procedures in place
detainee bulletin boards
for immediately communicating any revisions to staff and detainees.
immediately and copies included
in the handbook.
The compliance unit completes
There an annual review of the handbook by a designated committee or
annuals reviews of the handbook
staff member.
and makes revisions as needed.
The detainee handbook addresses the following issues:
These issues are covered on page
 Personal Items permitted to be retained by the detainee; and
3.
 Initial issue of clothes, bedding and personal hygiene items.
The detainee handbook states in clear language the basic detainee
Very clear and concise, easy to
responsibilities.
read and understand.
The handbook clearly outlines the methods for classification of
detainees, explains each level, and explains the classification appeals
process.
The section on initial admission
The handbook states when a medical examination will be conducted.
states that ordinarily a medical
screening and an examination
within 14 days.
The handbook describes the facility, housing units, dayrooms, in-dorm
activities, and special housing units.
The handbook describes official count times and count procedures; meal
times and feeding procedures; procedures for medical or religious diets;
All items are fully addressed
smoking policy; clothing exchange schedules; and, if authorized, clothes
throughout the handbook.
washing and drying procedures, and expected personal hygiene
practices.
Razors are issued on a daily basis
The handbook describe times and procedures for obtaining disposable
during shift 3 and must be turned
razors, and allows that detainees attending court will be afforded the
back in after use.
opportunity to shave first.
The handbook describes barber hours and hair cutting restrictions.
Page 11 fully describes the
barbering operations.
The handbook describes the telephone policy; debit card procedures;
Access to telephones are covered
direct and free calls; locations of telephones; policy when telephone
on pages 12 and 13.
demand is high; and policy and procedures for emergency phone calls.
The handbook addresses religious programming.
The handbook states times and procedures for commissary or vending
There is no commissary only
machine usage, where available.
vending machines.
The handbook describes the detainee voluntary work program.
The handbook describes the library location and hours of operation, and
law library procedures and schedules.
The handbook describes attorney and regular visitation hours, policies,
Visiting hours for attorneys are
and procedures.
unrestricted.
The handbook describes the facility contraband policy.
Contraband issues are addressed

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DETAINEE HANDBOOK
POLICY: EVERY OIC WILL DEVELOP A SITE-SPECIFIC DETAINEE HANDBOOK TO SERVE AS AN OVERVIEW OF, AND GUIDE TO, THE DETENTION
POLICIES, RULES, AND PROCEDURES IN EFFECT AT THE FACILITY. THE HANDBOOK WILL ALSO DESCRIBE THE SERVICES, PROGRAMS, AND
OPPORTUNITIES AVAILABLE THROUGH VARIOUS SOURCES, INCLUDING THE FACILITY, ICE, PRIVATE ORGANIZATIONS, ETC. EVERY DETAINEE
WILL RECEIVE A COPY OF THIS HANDBOOK UPON ADMISSION TO THE FACILITY.
COMPONENTS
Y
N
NA
REMARKS
on page 36.
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:
Detainee discipline policies are
 Prohibited acts and severity scale sanctions;
covered in detail on pages 21-31.
 Time limits in the Disciplinary Process; and
 Summary of the 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;
Page 31 & 32 of the handbook
 In CDF facilities: procedures for filing an appeal of a
describes in detail the grievance
grievance with ICE.
procedures and all steps
 Staff/detainee availability to help during the grievance process.
associated with the 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.
There are 14 detainee rights and
The handbook specifies the rights and responsibilities of all detainees.
responsibilities discussed on
pages 43 and 44.

ACCEPTABLE

DEFICIENT

AT-RISK

REPEAT FINDING

REMARKS:
The detainee handbook consists of 44 pages. There is a table of contents at the beginning of the handbook that covers each required
item addressed in this standard. The handbook is very thorough and written in easy to understand language. It provides the detainees
with adequate information to meet their required responsibilities and provides the information necessary for them to address their
concerns. The section on grievance procedures is very thorough and provides all the necessary information for detainees to address
any concern through the grievance process.
b6, b7c
/ June 19, 2008
AUDITOR’S SIGNATURE / DATE

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FOOD SERVICE
POLICY: EVERY FACILITY WILL PROVIDE DETAINEES IN ITS CARE WITH NUTRITIOUS AND APPETIZING MEALS, PREPARED IN ACCORDANCE
WITH THE HIGHEST SANITARY STANDARDS.
COMPONENTS
Y
N
NA
REMARKS
The food service program is under the direct supervision of a
The Food Service Manager is
professionally trained and certified food service administrator.
certified under the Serv-Safe
Responsibilities of cooks and cook foremen are in writing. The Food
Program. The FSA has attended
Service Administrator (FSA) determines the responsibilities of the Food
Food Service Management
Service Staff.
courses.
The Cook Supervisor is on duty on days when the FSA is off duty and
There is a Food Service
vice versa.
Administrator and an Assistant
Food Service
Administrator.There is always
one of the managers on duty.
The FSA provides food service employees with training that specifically
After looking at staff training
addresses detainee-related issues.
records which shows that all
areas are being covered. The
 In ICE Facilities this includes a review of the ICE "Food
present staff have been on their
Service" standard
job since December 2007.
The knife cabinet is in an
Knife cabinets close with an approved locking device, and the on-duty
approved cabinet with an
cook foreman maintains control of the key that locks the device.
approved locking device. All the
food service staff has a key to
the knife cabinet. Remove the
knife cabinet key from all keys
rings so that only the Cook
Supervisor in charge of the
kitchen, has the control of all
knives and tools being issued.
All knives not in a secure cutting room are physically secured to the
workstation and staff directly supervises detainees using knives at these
workstations. Staff monitors the condition of knives and dining utensils.
Yeast, Nutmeg, Cloves, Alcohol
When necessary, special procedures govern the handling of food items
Based Flavorings and Mace are
that pose a security threat.
not utilized in this facility.
Operating procedures include daily searches (shakedowns) of detainee
work areas.
The FSA monitor staff implementation of the facility's population
All food service staff have
counts procedures. Staff is trained in count procedures.
received training in count
procedures. The FSA monitors
the count procedures as the staff
are conducting them.
The detainees assigned to the food service department look neat and
All detainees assigned were in
clean. Their clothing and grooming comply with the "Food Service"
clean and neat clothing for the
standard.
week of the review.
The FSA reviews detainees job
The FSA annually reviews detainee-volunteer job descriptions to ensure
description annually to ensure
they are accurate and up-to-date.
that they are kept up-to-date..
All new detainees assigned to
The Cook Foreman or equivalent instructs newly assigned detainee
food service receives and signs
workers in the rules and procedures of the food service department.
for the rules and procedures of
their new job assignment.

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FOOD SERVICE
POLICY: EVERY FACILITY WILL PROVIDE DETAINEES IN ITS CARE WITH NUTRITIOUS AND APPETIZING MEALS, PREPARED IN ACCORDANCE
WITH THE HIGHEST SANITARY STANDARDS.
COMPONENTS
Y
N
NA
REMARKS
During orientation and training session(s), the CS explains and
demonstrates:
 Safe work practices and methods;
 Safety features of individual products/pieces of equipment; and
 Training covers the safe handling of hazardous material[s] the
detainees are likely to encounter in their work.
The Cook Supervisor documents all training in individual detainee
All training is document and
detention files.
kept on file for each detainee.
Detainees at CDFs are paid in accordance with the “Voluntary Work
Detainees who work in this
Program” standard. Detainee workers at IGSAs are subject to local and
facility are paid according to the
state rules and regulations regarding detainee pay.
policy and procedures within the
Voluntary Work Program
Standards.
Detainees are served at least two
Detainees are served at least two hot meals every day. No more than 14
hot meals a day. There is no
hours elapse between the last meal served and the first meal of the
more then 14 hours between
following day.
dinner and breakfast of the next
day.
Breakfast - 0600
Lunch - 1100
Dinner - 1630
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
The facility considers the ethnic
detainee population when developing menu cycles (Provide
diversity of the detainees i.e.
examples).
Pepper Steak, Stir-Fry Dishes,
Meat Burritos, Tacos, Spanish
Rice, Lasagna, Spaghetti.
A registered dietitian conducts a
A registered dietitian conducts a complete nutritional analysis of every
complete nutritional analysis on
master-cycle menu planned.
all menus that are used in the
daily preparation of all meals.
The FSA has established procedures to ensure that items on the masterApproved recipes are used by all
cycle menu are prepared and presented according to approved recipes.
food service workers and staff.
The Cook Foreman has the authority to change menu items if necessary.
 If yes, documenting each substitution, along with its
The cook supervisor cannot
justification
change any menu items.
 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
There is a common fare menu
cannot be met on the main line.
used. Hot entrees are offered at
 Changes to the planned common-fare menu can be made at the
least three times a week. The
facility level;
common fare meets all the
nutritional requirements for
 Hot entrees are offered three times a week;
daily allowances. All common
 The common-fare menus satisfy nutritional recommended
fare meals are served on
daily allowances (RDAs);

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FOOD SERVICE
POLICY: EVERY FACILITY WILL PROVIDE DETAINEES IN ITS CARE WITH NUTRITIOUS AND APPETIZING MEALS, PREPARED IN ACCORDANCE
WITH THE HIGHEST SANITARY STANDARDS.
COMPONENTS
Y
N
NA
REMARKS
disposable plates and use
 Staff routinely provide hot water for instant beverages and
disposable utensils. There is a
foods;
separate prep area for religious
o Common-fare meals are served with:
diets with all separate utensils.
 Disposable plates and utensils.
 Reusable plates and utensils.
 Staff use separate cutting boards, knives, spoons, scoops, etc.,
to prepare the common-fare diet items.
The Chaplain approves request
A supervisor at the command level must approve a detainee’s removal
from detainees for a religious
from the Common-Fare Program.
diet. With the approval of the
OIC the Chaplain can remove a
detainee from the program as
well.
The Warden, in conjunction with the chaplain and/or local religious
leaders, provides the FSA a schedule of the ceremonial meals for the
following calendar year.
The common-fare program accommodates detainees abstaining from
particular foods or fasting for religious purposes at prescribed times of
the year.
 Muslims fasting during Ramadan receive their meals after
sundown.
The common fare menu
accommodates detainees.
 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 department
The food service program addresses medical diets.
provides medical diets when
prescribed by the medical staff.
The guidelines for proper
Satellite-feeding programs follow guidelines for proper sanitation.
satellite feeding are followed
and they have a good program.
Temperatures are taken on all
Hot and cold foods are maintained at the prescribed, "safe"
foods and are maintained as
temperature(s) while being served.
prescribed and logged on the log
book. Cold foods are 40 or
below and hot foods are 140 or
above.
All foods are nutritionally
All meals are provided in nutritionally adequate portions.
adequate and the portions are
adequate as well.
Food is not used to punish or reward detainees based upon behavior.
No foods are used to reward or
as punishment.
The food service staff instructs detainee volunteers on:
 Personal cleanliness and hygiene;
All procedures are followed as
outlined in the ICE Standards
 Sanitary techniques for preparing, storing, and serving food;
for Food Service.
and
 The sanitary operation, care, and maintenance of equipment.
All persons working within the
Everyone working in the food service department complies with food
food service department
safety and sanitation requirements.
complies with food and safety
requirements.

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FOOD SERVICE
POLICY: EVERY FACILITY WILL PROVIDE DETAINEES IN ITS CARE WITH NUTRITIOUS AND APPETIZING MEALS, PREPARED IN ACCORDANCE
WITH THE HIGHEST SANITARY STANDARDS.
COMPONENTS
Y
N
NA
REMARKS
Standard operating procedures include weekly inspections of all food
The FSA conducts a weekly
service areas, including dining and food-preparation areas and
inspection of all areas and the
equipment.
kitchen supervisor initials off
when any discrepancies have
 Who conducts the inspections?
been corrected.
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.
Food service does take
temperatures and log them on a
temperature log which is kept on
file in the FSA's office.

Standard procedure includes checking and documenting temperatures of
all dishwashing machines after each meal.

Staff documents the results of every refrigerator/freezer temperature
check.
The cleaning schedule for each food service area is conspicuously
posted.

Cleaning schedules were posted
in all areas within the kitchen
and followed to ensure the
cleanliness of all areas of the
kitchen.
All incoming supplies are
inspected by the food service
staff for damage, contamination
and pest infestation prior to
storing the supplies.
The storage areas are secured
when not in use.

Procedures include inspecting all incoming food shipments for damage,
contamination, and pest infestation.

Storage areas are locked when not in use.

ACCEPTABLE

DEFICIENT

AT-RISK

REPEAT FINDING

REMARKS:
The knife cabinet is in an approved cabinet with an approved locking device. However, all the food service staff has a key to the knife
cabinet. It is recommended that the knife cabinet key be removed from all key rings so that only the cook supervisor in charge of the
kitchen has the control of all knives and tools being issued.
b6, b7c
/ June 19, 2008
AUDITOR’S SIGNATURE / DATE

FUNDS AND PERSONAL PROPERTY
POLICY: ALL FACILITIES WILL IMPLEMENT PROCEDURES TO CONTROL AND SAFEGUARD DETAINEES’ PERSONAL PROPERTY. PROCEDURES WILL
PROVIDE FOR THE SECURE STORAGE OF FUNDS, VALUABLES, BAGGAGE AND OTHER PERSONAL PROPERTY; THE DOCUMENTATION AND
RECEIPTING OF SURRENDERED PROPERTY; AND THE INITIAL AND REGULARLY SCHEDULED INVENTORYING OF ALL FUNDS, VALUABLES, AND
OTHER PROPERTY.
STANDARD NA: (IGSA ONLY) CHECK THIS BOX IF ALL ICE DETAINEE FUNDS, VALUABLES AND PROPERTY ARE HANDLED ONLY
BY THE ICE FIELD OFFICE OR SUB-OFFICE IN CONTROL OF THE DETAINEE CASE.
COMPONENTS
YES
NO
NA
REMARKS
Detainee funds and valuables are properly separated, stored, and are
Funds and valuables are
accessible only by designated supervisor(s).
properly separated and stored.
Detainees’ large valuables are secured in a location accessible to
Detainees large valuables are
designated supervisor(s) or processing staff only.
secured at the facility which is

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FUNDS AND PERSONAL PROPERTY
POLICY: ALL FACILITIES WILL IMPLEMENT PROCEDURES TO CONTROL AND SAFEGUARD DETAINEES’ PERSONAL PROPERTY. PROCEDURES WILL
PROVIDE FOR THE SECURE STORAGE OF FUNDS, VALUABLES, BAGGAGE AND OTHER PERSONAL PROPERTY; THE DOCUMENTATION AND
RECEIPTING OF SURRENDERED PROPERTY; AND THE INITIAL AND REGULARLY SCHEDULED INVENTORYING OF ALL FUNDS, VALUABLES, AND
OTHER PROPERTY.
STANDARD NA: (IGSA ONLY) CHECK THIS BOX IF ALL ICE DETAINEE FUNDS, VALUABLES AND PROPERTY ARE HANDLED ONLY
BY THE ICE FIELD OFFICE OR SUB-OFFICE IN CONTROL OF THE DETAINEE CASE.
accessible by designated
supervisors and/or processing
staff.
Staff itemizes the baggage and personal property of arriving detainees
Proper inventory standards are
(including funds and valuables). For IGSAs and CDFs, using a personal
followed.
property inventory form that meets the ICE standard?
When a detainee arrives at this
Staff forwards an arriving detainee’s medication to the medical staff.
facility his medication is given
to the medical department at the
facility.
Audits of baggage and non-valuable property occur each quarter and
audits are logged and verified.
There is always two staff
Two officers are present during the processing of detainee funds and
present when processing any
valuables during in-processing to the facility. Both officers verify funds
detainees in and both staff verify
and valuables.
funds and valuables.
Staff searches arriving detainees and their personal property for
Detainees and their property are
contraband.
searched as required.
Staff procedures follow written policy for returning forgotten property to
detainees.
Property discrepancies are immediately reported to the CDEO or Chief of
Security.
Staff follow written procedures
Staff follows written procedures when returning property to detainees.
when returning property to the
detainees.
All procedures are followed by
CDF/IGSA facility procedures for handling detainee property claims are
all staff when handling
similar with the ICE standard.
detainees property.
The facility attempts to notify an out-processed detainee that he/she left
property in the facility:
 By sending written notice to the detainee’s last known address;
 Via certified mail; and
 The notice state that the detainee has 30 days in which to claim
the property, after which it will be considered abandoned.
The facility disposes of abandoned property in accordance with written
procedures.
 If a CDF/IGSA facility, written procedure requires the prompt
forwarding of abandoned property to ICE.

ACCEPTABLE

DEFICIENT

AT-RISK

REPEAT FINDING

REMARKS
The detention center maintains accurate records for personal property and personal funds. Detainee property is accurately inventoried
and stored according to policy. The work area in which these functions are performed is very neat, well organized and cleanliness is a
high priority.

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b6, b7c
/ June 19, 2008
AUDITOR’S SIGNATURE / DATE

DETAINEE GRIEVANCE PROCEDURES
POLICY: EVERY FACILITY WILL DEVELOP AND IMPLEMENT STANDARD OPERATING PROCEDURES (SOPS) FOR ADDRESSING DETAINEE
GRIEVANCES IN TIMELY FASHION. EACH STEP IN THE PROCESS WILL OCCUR WITHIN THE PRESCRIBED TIME FRAME. AMONG OTHER THINGS, A
GRIEVANCE WILL BE PROCESSED, INVESTIGATED, AND DECIDED (SUBJECT TO APPEAL) IN ACCORDANCE WITH THE SOPS; A GRIEVANCE
COMMITTEE WILL CONVENE AS PROVIDED IN THE SOPS. STANDARD PROCEDURE WILL INCLUDE PROVIDING THE DETAINEE WITH A WRITTEN
RESPONSE TO ANY FORMAL GRIEVANCE, WHICH WILL INCLUDE THE BASIS FOR THE DECISION. THE FACILITY WILL ALSO ESTABLISH STANDARD
PROCEDURES FOR HANDLING EMERGENCY GRIEVANCES. ALL GRIEVANCES WILL RECEIVE SUPERVISORY REVIEW. REPRISAL AGAINST THE
FILER OF A GRIEVANCE WILL NOT BE TOLERATED.

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COMPONENTS
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
lodged a complaint:
 If yes, explain.
Procedures include maintaining a Detainee Grievance Log.
 If not, an alternative acceptable record keeping system is
maintained.
 "Nuisance complaints" are identified in the records.
 For quality control purposes, staff document nuisance
complaints received but not filed.
Staff is required to forward any grievance that includes officer
misconduct to a higher official or, in a CDF/IGSA facility, to ICE.

ACCEPTABLE

DEFICIENT

Y

N

NA

REMARKS
Local policy, Grievance
Procedure, describes all
procedures associated with the
grievance procedures.

There are no documented or
substantiated cases.

AT-RISK

REPEAT FINDING

REMARKS:
Well documented and maintained program. All steps in the process are meeting the expected time frames. The grievance process and
procedures are in place and detainees are being provided the necessary requirements to voice their concerns. Inspection of the log and
monthly reports did not identify any lodged complaints of staff misconduct incidents that would require further investigation.
b6, b7c
/June 19, 2008
AUDITOR’S SIGNATURE / DATE

ISSUANCE AND EXCHANGE OF CLOTHING, BEDDING, AND TOWELS
POLICY: ICE REQUIRES THAT ALL FACILITIES HOUSING ICE DETAINEES PROVIDE CLEAN CLOTHING, BEDDING, LINENS AND TOWELS TO EVERY
ICE DETAINEE UPON ARRIVAL. FURTHER, FACILITIES SHALL PROVIDE ICE DETAINEES WITH REGULAR EXCHANGES OF CLOTHING, LINENS, AND
TOWELS FOR AS LONG AS THEY REMAIN IN DETENTION.
COMPONENTS
The facility has a policy and procedure for the regular issuance and

YES

NO

NA

REMARKS
Local Policy titled, Issuance,

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ISSUANCE AND EXCHANGE OF CLOTHING, BEDDING, AND TOWELS
POLICY: ICE REQUIRES THAT ALL FACILITIES HOUSING ICE DETAINEES PROVIDE CLEAN CLOTHING, BEDDING, LINENS AND TOWELS TO EVERY
ICE DETAINEE UPON ARRIVAL. FURTHER, FACILITIES SHALL PROVIDE ICE DETAINEES WITH REGULAR EXCHANGES OF CLOTHING, LINENS, AND
TOWELS FOR AS LONG AS THEY REMAIN IN DETENTION.
COMPONENTS
exchange of clothing, bedding, linens, and towels.
 The supply of these items exceeds the minimum required for the
number of detainees.

YES

All new detainees are issued clean, temperature-appropriate, presentable
clothing during in-processing. Detainees receive:
 One uniform shirt and one pair of uniform pants, or one
jumpsuit;
 One pair of socks;
 One pair of underwear (Daily change); and
 One pair of facility-issued footwear.
Additional clothing is available for changing weather conditions, or as
seasonally appropriate.
New detainees are issued clean bedding, linens, and towels. They receive
at a minimum:
 One mattress;
 One blanket;
 Two sheets;
 One pillowcase;
 One towel; and
 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 are permitted to exchange outer
garments daily.
Volunteer detainee workers are permitted to exchange outer garments
more frequently.

ACCEPTABLE

DEFICIENT

NO

NA

REMARKS
and Exchange of Clothing,
Bedding, Linen, and Towels
outlines all requirements of this
standard.

There are sufficient amounts of
additional clothing and bedding
materials maintained.

All exchanges are in line with
required standards.

As needed.

AT-RISK

REPEAT FINDING

REMARKS:
Review of policies and procedures indicate that the detainees are afforded the clothing, bedding, and linens as required by this
standard. Observations of the laundry process showed that it is a very efficient and well supervised operation. Inspection of the
clothing storage area found that there were sufficient amounts of supplies on hand for any emergency.
/ June 19. 2008
AUDITOR’S SIGNATURE / DATE
b6, b7c

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MARRIAGE REQUESTS
POLICY: ALL DETAINEE MARRIAGE REQUESTS WILL RECEIVE CASE-BY-CASE CONSIDERATION FROM ICE MANAGEMENT.
COMPONENTS
Y
N
NA
REMARKS
The Field Office considers detainee marriage requests on a case-by-case
Documentation is on file for
basis.
detainees marriage request.
The Field Office Director reviews every marriage request rejected by a
Warden/OIC or IGSA. Rejections are documented.
It is standard practice to require a written request for permission to marry.
Review of files show that all are
in compliance.
The written request includes a signed statement or comparable
documentation from the intended spouse, confirming marital intent.
The Warden/OIC provides a written copy of his/her decision to the
Copies are on file in the OIC.
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
wedding arrangements.

ACCEPTABLE

DEFICIENT

AT-RISK

REPEAT FINDING

REMARKS:
This facility has a sound program in regards to marriage request. The proper documentation is on file and completed according to
standards.
b6, b7c
/ June 19, 2008
AUDITOR’S SIGNATURE / DATE

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NON-MEDICAL EMERGENCY ESCORTED TRIPS
POLICY: THE IMMIGRATION AND CUSTOMS ENFORCEMENT (ICE) MAY PROVIDE DETAINEES WITH STAFF-ESCORTED TRIPS INTO THE
COMMUNITY FOR THE PURPOSE OF VISITING CRITICALLY ILL MEMBERS OF THE DETAINEE’S IMMEDIATE FAMILY, OR FOR ATTENDING FUNERALS.
STANDARD N/A: CHECK THIS BOX IF ALL ICE NON-MEDICAL EMERGENCY ESCORTED TRIPS ARE HANDLED ONLY BY THE ICE
FIELD OFFICE OR SUB-OFFICE IN CONTROL OF THE DETAINEE CASE.
COMPONENTS
YES
NO
NA
REMARKS
The AFOD has been delegated
The Field Office Director considers and approves, on a case-by-case
by the FOD to approve all nonbasis, trips to an immediate family member's:
medical escorted trips for
 Funeral; or
detainees confined at the El
 Deathbed
Centro Service Processing
Center.
The facility recognizes mother, father, brother, sister, spouse, child, stepparent, and foster parent as "immediate family".
The IGSA facility notifies ICE of all detainee requests for non-medical
escorts.

Not applicable to ECSPC.

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.
Each escort includes at least two officers.
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 increase or decrease minimum
restraints in accordance with written procedures and classification level
of the detainee.
Escort officers are precluded from accepting gifts/gratuities from a
detainee, or 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;
 Make no unauthorized phone calls; and
 Know they are subject to search, urinalysis, breathalyzer, or
comparable test upon return.
Standard procedure requires the immediate return to the facility of any
detainee who violates trip rules.

ACCEPTABLE

DEFICIENT

AT-RISK

REPEAT FINDING

REMARKS:
The AFOD has been delegated by the FOD to approve all non-medical escorted trips for detainees confined at the El Centro Service
Processing Center. Appropriate post orders and instructions are available for escort staff.
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RECREATION
POLICY: IT IS ICE POLICY TO PROVIDE ACCESS TO RECREATIONAL PROGRAMS AND ACTIVITIES TO ALL ICE DETAINEES, TO THE EXTENT
POSSIBLE, UNDER CONDITIONS OF SECURITY AND SUPERVISION THAT PROTECT THEIR SAFETY AND WELFARE.
COMPONENTS
The facility has a recreation program and facility.

A recreational specialist (for facilities with more than 350 detainees) tailors
the program activities and offerings to the detainee population.
Regular maintenance keeps recreational facilities and equipment in good
condition.
The recreational specialist or trained equivalent supervises detainee
recreation workers.
The recreational specialist or trainee equivalent oversees recreation
programs for special housing units (SHU) and special-needs detainees.
Dayrooms offer sedentary activities, e.g., board games, cards, television.

Outside activities are restricted to limited-contact sports.
Each detainee has the opportunity to participate in daily recreation.
Detainees have access to recreation activities outside the housing units for
at least one hour daily, 5 days a week.
Staff checks all items for damage and condition when equipment is
returned.

Staff conducts searches of recreation areas before and after use.

Y

N

NA

REMARKS
This facility has a good
recreation program run by Two
recreation staff.

The recreational inmate workers
are supervised by recreation
staff.

There are board games, card
games, as well as television
offered in the dayrooms.

Staff check all items for damage
and report damages to the
recreation staff for repairs or
replacements.
Searches are conducted before
and after recreation times.

All recreation areas under constant staff supervision.
Supervising staff is equipped with radios.
The facility provides detainees in the SHU at least one hour of outdoor
recreation time daily, five times per week.
Detainees in disciplinary/administrative segregation receive a written
explanation when a panel revokes his/her recreation privileges.
Special programs or religious activities are available to 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 offered, check this box. 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?
 If yes, written procedures ensure timely review of all eligible
detainees.
Case officers make written transfer recommendations about every sixmonth 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.
Staff notifies the detainee’s legal representative of his/her decision to
accept/decline a transfer.
If no recreation is available, the ICE Districts routinely review transfer
eligibility for all detainees after 60 days.
The A-file of every detainee who is held more than 60 days without
access to recreation contains either a transfer-waiver signed by the

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RECREATION
POLICY: IT IS ICE POLICY TO PROVIDE ACCESS TO RECREATIONAL PROGRAMS AND ACTIVITIES TO ALL ICE DETAINEES, TO THE EXTENT
POSSIBLE, UNDER CONDITIONS OF SECURITY AND SUPERVISION THAT PROTECT THEIR SAFETY AND WELFARE.
detainee, or the OIC’s written determination of the detainee’s ineligibility
for transfer.
The detainee’s legal representative is notified of the detainee’s/OIC’s
decision.

ACCEPTABLE

DEFICIENT

AT-RISK

REPEAT FINDING

REMARKS:
The facility provides access to recreational programs and activities to all ICE detainees to the extent possible under conditions of
security and supervision that protect their safety and welfare. Indoor and outdoor recreation schedules allow detainee access to
recreation a minimum of one hour daily, five days a week.

/ June 19, 2008
AUDITOR’S SIGNATURE / DATE
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RELIGIOUS PRACTICES
POLICY: FACILITIES WILL PROVIDE ICE DETAINEES OF ALL FAITHS WITH REASONABLE AND EQUITABLE OPPORTUNITIES TO PARTICIPATE IN
THE PRACTICES OF THEIR FAITH, LIMITED ONLY BY THE CONSTRAINTS OF SAFETY, SECURITY, THE ORDERLY OPERATIONS OF THE FACILITY AND
BUDGETARY CONSIDERATIONS.
COMPONENTS
REMARKS
Y
N
NA
Detainees are allowed to engage in religious services.
A variety of religious services
are provided.
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:
If a detainee wishes to observe
 Providing special meals, consistent with dietary restrictions;
their religious holy-day they
 Honoring fasting requirements;
need only put in a request to the
 Facilitating religious services; and
Chaplain.
 Allowing activity restrictions.
Each detainee is allowed religious items in his/her immediate possession.
Volunteer’s credentials are checked and verified before allowing
Volunteer credentials are
participation in detainee programs.
verified including NCIC checks.
Members of faiths not represented by clergy may conduct their own
services within security allowances.
Chaplain conduct rounds to
Detainees in the Special Management Unit are allowed to participate in
provide ministry to the Special
religious practices unless otherwise documented for the safety and
Management Unit.
security of the facility.

ACCEPTABLE

DEFICIENT

AT-RISK

REPEAT FINDING

REMARKS:
The facility provides detainees of all faiths with reasonable and equitable opportunities to participate in the practice of their faith,
limited only by the constraints of safety, security, the orderly operations of the facility and budgetary constraints.

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/ June 19, 2008
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VOLUNTARY WORK PROGRAM
POLICY: IN EVERY FACILITY OFFERING A VOLUNTARY WORK PROGRAM, ICE DETAINEES WILL HAVE THE OPPORTUNITY TO WORK AND EARN
MONEY BY PARTICIPATING. WHILE NOT LEGALLY REQUIRED, ICE AFFORDS DETAINEE WORKERS BASIC OCCUPATIONAL SAFETY AND HEALTH
ADMINISTRATION (OSHA) PROTECTIONS.
CHECK HERE IF ICE DETAINEES ARE NOT AUTHORIZED TO WORK AT THE IGSA FACILITY.
AND MOVE TO NEXT SECTION.
COMPONENTS
Does the facility have a voluntary work program?
 Do ICE detainees participate?

Y

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.
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 and Forty hours a week.
Detainee volunteers generally work according to fixed schedule.
If a detainee is removed from a work detail, staff places the written
justification for the action in the detainee’s detention file.
Staff, in accordance with written procedure, ensures that detainee
volunteers understand their responsibilities as workers before they join
the work program.
The voluntary work program meets:
 OSHA, NFPA, ACA standards
Medical staff screen and formally certify detainee food service
volunteers.
 Before the assignment begins; and
 As a matter of written procedure
Detainees receive safety equipment/ training sufficient for the
assignment.
Proper procedure is followed when an ICE detainee is injured on the job.

ACCEPTABLE

DEFICIENT

N

MARK NA ON FORM G-324A, PAGE 3

NA

REMARKS
Detainees participate in the
facilities voluntary work
program.
Housing Units were neat and
clean.

Job orientations are completed
upon entering the voluntary
work program.

Detainees must be cleared for
work by medical prior to being
considered for the voluntary
work program.

AT-RISK

REPEAT FINDING

REMARKS
The facility offers a voluntary work program that allows the detainees the opportunity to work and earn money for participating.
Detainees are medically cleared and properly placed into employment opportunities. Documentation of job training and medical
screening are appropriately filed.

/ June 19, 2008
AUDITOR’S SIGNATURE / DATE
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SECTION III.
HEALTH SERVICES STANDARDS

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HUNGER STRIKES
POLICY: ALL FACILITIES WILL FOLLOW STANDARD GUIDELINES FOR THE MEDICAL AND ADMINISTRATIVE MANAGEMENT OF ICE DETAINEES
ENGAGING IN HUNGER STRIKES. BY MONITORING OF THE HEALTH AND WELFARE OF THE INDIVIDUAL DETAINEES, FACILITIES WILL STRIVE TO
SUSTAIN THEIR LIVES.
COMPONENTS
Y
N
NA
REMARKS
Reporting procedures are
When a detainee has refused food for 72 hours, it is standard practice for
outlined in Local Operating
staff to refer him/her to the medical department.
Procedure, LOP 811, "Hunger
Strike Protocol" dated 11/05.
LOP manual is reviewed
annually for appropriateness.
This is an ICE facility. Hunger
CDFs and IGSAs immediately report a hunger strike to the ICE.
strike is an event identified in
the DIHS-USPHS Standard
Operating Procedure, DIHS
SOP 310, and “Required
Notifications to ICE".
The facility has established procedures to ensure staff respond
Staff response is outlined in
immediately to a hunger strike.
LOP 811.
There are four designated cells
Policy and procedure require that staff isolate a hunger-striking detainee
in the medical infirmary for
from other detainees.
housing a detainee who declares
 If yes, in an observation room?
hunger strike.
Medical personnel are authorized to place a detainee in the Special
Management Unit or a locked hospital room.
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.

Monitoring is addressed in LOP
811, section C, "Medical
Monitoring.”
Obtaining informed consent for
medical treatment is outlined in
LOP 811, section E, "On Site
Treatment".
Refusal for treatment is
documented on DIHS Form 820.

During a hunger strike, staff document and provide 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.
Staff is directed to record the hunger striker’s fluid intake and food
consumption; Does staff always use Hunger Strike Monitoring Form I839 or similar IGSA form.
The medical staff has written procedures for treating hunger strikers.

.
DIHS Form I-839 is used in this
facility to document food and
fluid intake of a hunger striker.
Medical intervention is outlined
in LOP 811, sections E and F,
"On Site Treatment" and
"Involuntary Treatment.”

Staff documents all treatment attempts, including attempts to persuade
hunger striker of medical risks.
Staff has received training in identification of hunger strikes. Medical
staff receives early training in hunger-strike evaluation and treatment.
Staff remains current in evaluation and treatment techniques.

Hunger strike training is a
mandatory topic during initial
and annual refresher courses for
all SPC, medical and nonmedical staff, including the

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HUNGER STRIKES
POLICY: ALL FACILITIES WILL FOLLOW STANDARD GUIDELINES FOR THE MEDICAL AND ADMINISTRATIVE MANAGEMENT OF ICE DETAINEES
ENGAGING IN HUNGER STRIKES. BY MONITORING OF THE HEALTH AND WELFARE OF THE INDIVIDUAL DETAINEES, FACILITIES WILL STRIVE TO
SUSTAIN THEIR LIVES.
contract AKAL security service
staff. Review of the initial and
annual refresher training logs
reflects training was provided.

ACCEPTABLE

DEFICIENT

AT-RISK

REPEAT FINDING

REMARKS:
Medical services are provided to ICE by the Division of Immigration Health Services, U.S. Public Health Services (DIHS - USPHS).
DIHS- USPHS Standard Operating Procedure, revised October 29, 2007 and Local Operating Procedure dated April 2006 have
procedures outlining staff response and responsibility when a detainee declares a hunger strike.
Hunger strike is an event identified in the DIHS-USPHS Standard Operating Procedure, SOP 310, and “Required Notifications to
ICE". El Centro SPC has a standard operating procedure on hunger strikes, dated April 8, 2008. Hunger strike is a mandatory
training topic for all ECSPC staff, medical staff, and contract security staff for the AKAL company. Training is conducted by the
medical staff during initial and annual refresher training sessions. Review of the topic outline and power point presentation reflects
full compliance with this standard.

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ACCESS TO MEDICAL CARE
POLICY: EVERY FACILITY WILL ESTABLISH AND MAINTAIN AN ACCREDITED/ACCREDITATION-WORTHY HEALTH PROGRAM FOR THE GENERAL
WELL-BEING OF ICE DETAINEES.
COMPONENTS
Y
N
NA
REMARKS
The facility has current JCAHO
Facilities operate a health care facility in compliance with state and local
(September 2006), NCCHC
laws and guidelines.
(July 2006) and ACA (July
2006) accreditations.
Intake medical screening is
The facility’s in-processing procedures for arriving detainees include
outlined in Local Operating
medical screening.
Procedure, LOP 802, "Medical
Intake Screening Process."
All detainees have access to and receive medical care.
Access to medical care is
outlined in the Inmate
Handbook, and in LOP 218,
"Access to Medical Care.”
Interview with the nursing staff
indicates access to medical care
is discussed during the initial
intake screening process.
Review of outside medical
The facility has access to a PHS/DIHS Managed Health Care
referral log reflects appropriate
Coordinator.
and timely scheduling for
specialized services not
available in the facility. The log
reviewed was for calendar year
06/2007 - 06/2008. There were
54 referrals for the review dates.
50 of 54 detainees were sent for
the outside referrals
appointments within a week
after approval by DIHS
headquarters. 4 of the 54 outside
referrals were completed within
30-45 days due to inability to
find a local provider; these 4
specialty referrals were sent to a
San Diego consultant.
There are 6 vacancies (4
The medical staff is large enough to provide, examine, and treat the
nursing, 1 pharmacy technician,
facility’s detainee population.
and 1 mental health social
worker). Interview with the
HSA and the Clinical Director
indicates current nursing
staffing is adjusted to cover
peak hours and evening shifts to
meet the medical mission. The
HSA and AHSA are registered
nurses who performs clinical
duties as needed during the
business hours from 0700-1500.
The facility has sufficient space and equipment to afford detainee privacy
when receiving health care.
The medical facility has its own restricted-access area. The restricted
access area is located within the confines of the secure perimeter.

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ACCESS TO MEDICAL CARE
POLICY: EVERY FACILITY WILL ESTABLISH AND MAINTAIN AN ACCREDITED/ACCREDITATION-WORTHY HEALTH PROGRAM FOR THE GENERAL
WELL-BEING OF ICE DETAINEES.
The medical facility entrance includes a holding/waiting room.
There is two custodial staff
The medical facility’s holding/waiting room is under the direct
assigned to the medical unit at
supervision of custodial staff.
all times.
Detainees in the holding/waiting room have access to a drinking fountain.
Medical records are kept apart from other files. They are:
The facility has electronic
 Secured in a locked area within the medical unit;
medical records which are
accessible only by the medical
 With physical access restricted to authorized medical staff; and
staff.
 Procedurally, no copies made and placed in detainee files.
Pharmaceuticals are stored in a secure area.
Tuberculosis surveillance is
Medical screening includes a Tuberculosis (TB) test.
outlined in LOP 8.30,
 Every arriving detainee receives a TB test during the admission
"Tuberculosis Prevention,
process;
Treatment, and Control.” All
 Detainee’s TB-screening does not occur more than one business
detainees are screened for signs
day after his/her arrival at the facility; and
and symptoms of active TB on
 Detainees not screened are housed separate from the general
admission during intake
population.
screening. On arrival, chest xrays are performed on all
detainees who do not have a
current negative chest x-ray
report on their transfer
documents. 100 of 100 records
reviewed reflected full
compliance with the policy.
Mental Health Screening is
All detainees receive a mental-health screening upon arrival. It is
conducted by the nursing staff
conducted:
on arrival. 100 of 100 records
 By a health care provider or specially trained officer; and
reflects all detainees received
 Before a detainee’s assignment to a housing unit.
mental health intake screening
on admission.
The facility health care provider promptly reviews all I-794s (or
All medical transfer records are
equivalent) to identify detainees needing medical attention.
reviewed by the nursing staff
during intake screening and
referred to the appropriate
provider as needed.
The health care provider physically examines/assesses arriving detainees
100 of 100 records reviewed
within 14 days of admission/arrival at the facility.
reflect physical assessments are
conducted by the midlevel
practitioners within 3 to 12 days
of arrival.
Sick call slips are available in
Detainees in the Special Management Unit have access to health care
the Special Management unit
services.
(SMU) and collected daily by
the nursing staff. Requests are
prioritized for appointments
with the midlevel provider(s).
Staff provides detainees with health services (sick call) request slips
Sick call request forms in
daily, upon request.
English and Spanish are
 Request slips are available in languages other than English,
available in all housing units
including every language spoken by a sizeable number of the
and collected daily by the
facility’s detainee population.
nursing staff.
 Service-request slips are delivered in a timely fashion to the

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ACCESS TO MEDICAL CARE
POLICY: EVERY FACILITY WILL ESTABLISH AND MAINTAIN AN ACCREDITED/ACCREDITATION-WORTHY HEALTH PROGRAM FOR THE GENERAL
WELL-BEING OF ICE DETAINEES.
health care provider.
There is 24-hour nursing
The facility has a written plan for the delivery of 24-hour emergency
coverage. A midlevel
health care when no medical personnel are on duty at the facility, or when
practitioner on-call during nonimmediate outside medical attention is required.
business hours, 7 days per week.
DIHS SOP 3.18.1, "Afer-Hours
The plan includes an on-call provider.
Medical Coverage" identifies
the midlevel provider as first
call and the clinical director as
second call. Interview with the
clinical director indicates he is
on available for telephonic
consultation 24 hours per day, 7
days per week.
The plan includes a list of telephone numbers for local ambulance and
hospital services.
The plan includes procedures for facility staff to utilize this emergency
health care consistent with security and safety.
All SPC, medical and contract
Detention staff is trained to respond to health-related emergencies within
AKAL security staff have
a 4-minute response time.
current CPR certifications on
record.
Where staff is used to distribute medication, a health care provider
Medications are distributed by
properly trains these officers.
the nursing staff.
The medical unit keeps written records of medication that is distributed.
The Form I-819 (or IGSA equivalent) is used to notify the
Procedures and appropriate
Warden/Facility of a detainee that has special medical needs.
notification regarding detainees
with special needs are addressed
in the DIHS SOP 8.20,
"Detainee Special Needs".
Informed consent is outlined in
A signed and dated consent form is obtained from a detainee before
DIHS SOP 2.1, Prerequisites for
medical treatment is administered.
Treatment, section 2.1.1,
"Informed Consent".
Detainees use the I-813 (or IGSA equivalent) to authorize the release of
confidential medical records to outside sources.
The facility health care provider is given advance notice prior to the
release, transfer, or removal of a detainee.
The In-Transit form is used to
Detainee's medical records or a copy thereof, are available and
indicate the detainee's pertinent
transferred with the detainee.
history and medical needs
during transfer.
Medical records are placed in a sealed envelope or other container
labeled with the detainee's name and A-number and marked "MEDICAL
CONFIDENTIAL”.

ACCEPTABLE

DEFICIENT

AT-RISK

REPEAT FINDING

REMARKS:
El Centro Service Processing Center (ECSPC) has current accreditations by the Joint Commission on the Accreditation of Health Care
Organizations (JCAHO) dated September 2006; by the National Commission on Correctional Health Care (NCCHC) dated July 2006;
and by the Commission on Accreditation for Corrections and the American Correctional Association (ACA) dated July 2006. Medical

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Services are provided by the Division of Immigration Health Services U.S. Public Health Services (DHIS - USPHS). DIHS-USPHS
Standard Operating Procedure (DIHS SOP) Manual dated October 29, 2007 has current revisions and annual review documentation.
The Local Operating Procedures manual has current revision dated April 2006 with current annual review documentation.
Interview with the Health Services Administrator (HSA) indicates the medical unit is authorized for 30 staff positions. Current staffing
has six vacancies: four nursing staff, one pharmacy technician, and one mental health social worker. There are three registered nurses
(RNs) scheduled for interviews on June 20, 2008. One nursing position has been filled with a licensed vocational nurse (LVN) who
will report for duty on June 30, 2008. Interview with the HSA, indicated current staffing is adjusted to cover peak hours to meet the
medical mission. The HSA and the Assistant HSA are RNs and performs clinical nursing duties during business hours as needed.
Current staffing consists of 24 full time staff: one Clinical/Medical Director, one HSA, one Assistant HSA, one nurse practitioner, two
physician assistants - certified (PACs), seven RNs, five LVNs, two medical records technicians (MRTs), one dentist, one dental
assistant, one pharmacist and one administrative assistant. The unit is authorized to hire three part time staff for peak time coverage
(one PAC, one RN, and one MRT) until staffing is at full complement. There is a contract psychologist (eight hours per week) and a
psychiatrist (eight hours every two weeks).
Interview with the contract psychiatrist indicated the mental health program is adequate and he is able to conduct monthly mental
health chronic care monitoring of the 20 detainees on mental health chronic care clinic. The psychiatrist indicated he is available for
telephonic consultation at any time seven days for detainees on psychotropic medications or with history of mental illness. The clinical
director makes adjustments of psychotropic medications as needed with consultation with the psychiatrist. There are currently 154
detainees on medical chronic care clinics and review of 50 records indicate 50 of 50 detainees on chronic care are seen at least monthly
or sooner, as scheduled by the midlevel provider.
There is 24-hour nursing coverage and all detainees report to the medical clinic for scheduled medications/pill line except those housed
in the Special Management Unit (SMU). The nursing staff delivers medications at SMU and collects sick call slips daily. Intake
medical and mental health screening is conducted by the nursing staff on admission. All 100 records reviewed reflected medical and
mental health screening were conducted on admission. The detainee is instructed on procedures to access medical care including the
use of the sick call request slips. Sick call request forms are available in English and Spanish. Tuberculosis (TB) screening is
performed using chest x-rays. All detainees are screened for signs and symptoms of active TB on admission during intake screening.
Chest x-rays are performed on all detainees who do not have a current negative chest x-ray reports on their transfer documents. All 100
records reviewed reflected TB screening policy was followed. A review of 100 records reflected the physical examinations were
completed by the midlevel practitioner within 3 to 12 days of admission.
The referral to outside specialty services log was reviewed for the calendar period of June 2007 to June 2008. There were 54 outside
referrals. DIHS notifications to headquarter were done within 1-2 days of the noted order from the practitioner. DIHS approval was
received within 1-2 days of the request. Of the 54, four detainees were sent for the outside specialist appointments within a week after
approval by DIHS headquarters. Four of the 54 outside referrals were completed within 45 days due to the inability to find a local
provider and the availability of appointment at the specialists' office. The four specialty referrals were sent to a San Diego consultant.
All SPC, medical and contract AKAL security staff have current CPR certifications at the time of this review.

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SUICIDE PREVENTION AND INTERVENTION
POLICY: ALL DETENTION STAFF WORKING WITH ICE DETAINEES WILL BE TRAINED TO RECOGNIZE SUICIDE-RISK INDICATORS. STAFF WILL
HANDLE POTENTIALLY SUICIDAL INDIVIDUALS WITH SENSITIVITY, SUPERVISION, AND REFERRALS. A CLINICALLY SUICIDAL DETAINEE WILL
RECEIVE PREVENTIVE SUPERVISION AND TREATMENT.
COMPONENTS
Y
N
NA
REMARKS
Suicide prevention training is
Every new staff member receives suicide-prevention training. Suicidemandatory for all SPC, medical
prevention training occurs during the employee orientation program.
and contract AKAL security
service staff. The training is
reflected in the attendance
records of the initial and annual
refresher training sessions.
Training prepares staff to:
The training topic outline on
 Recognize potentially suicidal behavior;
suicide prevention was reviewed
 Refer potentially suicidal detainees, following facility
and meets the requirement of
procedures; and
this standard.
 Understand and apply suicide-prevention techniques.
A health-care provider or specially trained officer screens all detainees for
100 of 100 (100/100) records
suicide potential as part of the admission process.
reviewed reflects mental health
screening is conducted by the
 Screening does not occur later than one working day after the
nursing staff on arrival.
detainee’s arrival.
Referral procedures are outlined
Written procedures cover when and how to refer at-risk detainees to
in LOP 1703 "Suicide
medical staff and procedures are followed.
Prevention Program."
There is a designated isolation
The facility has a designated isolation room for evaluation and treatment.
cell in the medical unit to be
used for housing the detainee on
suicide watch.
The designated isolation room does not contain any structures or smaller
items that could be used in a suicide attempt.
Medical staff has approved the room for this purpose.
Monitoring of a detainee
Staff observes and documents the status of a suicide-watch detainee at
requiring constant observation is
least once every 15 minutes.
outlined in LOP 1703.

ACCEPTABLE

DEFICIENT

AT-RISK

REPEAT FINDING

REMARKS:
All ECSPC, medical and contract AKAL security staff receive mandatory suicide prevention training at initial and annual refresher
sessions. The training is conducted by the PHS medical staff. Three records of detainees who were previously on suicide watch
reflected the suicide policy procedures were followed. An interview with the contract psychiatrist reflected he has read the suicide
prevention program and the procedures are adequate and in accordance to community mental health standards for suicide prevention,
monitoring and treatment.

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TERMINAL ILLNESS, ADVANCED DIRECTIVES, AND DEATH
POLICY ALL FACILITIES HOUSING ICE DETAINEES SHALL HAVE POLICIES AND PROCEDURES ADDRESSING THE ISSUES OF TERMINAL ILLNESS OR
INJURY, MEDICAL ADVANCED DIRECTIVES, AND DETAINEE DEATH, TO INCLUDE THE PROCEDURES TO ENSURE PROPER NOTIFICATION IS
PROVIDED TO ICE OFFICIALS, FAMILY MEMBERS AND OTHER INTERESTED PARTIES IN THE EVENT OF A DETAINEE BECOMING TERMINALLY ILL
OR INJURED OR DEATH OF A DETAINEE OCCURS. IN ADDITION, THE POLICY WILL COVER PROCEDURES TO BE TAKEN IF THE DEATH OF A
DETAINEE OCCURS WHILE IN TRANSIT.
CHECK THIS BOX IF THE FACILITY DOES NOT ACCEPT ICE DETAINEES WHO ARE SEVERELY OR TERMINALLY ILL. INDICATE NA IN
THE APPROPRIATE BOX FOR THIS PORTION OF THE WORKSHEET. ALWAYS COMPLETE ALL REFERENCES TO DETAINEE DEATH AND
RELATED NOTIFICATIONS.
COMPONENTS
Y
N
NA
REMARKS
Detainees who are chronically or terminally ill are transferred to an
appropriate offsite medical facility.

The facility or appropriate ICE office promptly notifies the next of kin of
the detainee’s medical condition, to include:
 The detainee's location; and
 The limitations placed on visiting.

There are guidelines addressing the State Advanced Directive Form for
Implementing Living Wills and Advanced Directives.
 The guidelines include instructions for detainees who wish to
have a living will other than the generic form the DIHS provides
or who wishes to appoint another to make advance decisions for
him or her.
The guidelines provide the detainee the opportunity to have a private
attorney prepare the documents.
There is a policy addressing "Do Not Resuscitate Orders”

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

The facility notifies the DIHS Medical Director and Headquarters’ Legal
Counsel of the name and basic circumstances of any detainee with a "Do
Not Resuscitate" order in the medical record. In the case of IGSAs, this
notification is made through the local ICE representative.

ECSPC has the capability of
providing supportive care for
the detainee with
serious/terminal illness. Only
those detainees requiring
invasive monitoring or
specialty-based medical
treatment beyond the capability
of the facility will be transferred
to the local hospital as outlined
by LOP 801, General Medical
Care, and section on "Scope of
Medical Services.”
Notification of the next of kin
by ICE is outlined in ECSPC
SOP "Terminal Illness, Advance
Directives, and Death" dated
March 24, 2008. DIHS SOP 2.4,
"Notification of Next of Kin and
Local Authorities" addresses
USPHS procedure of notifying
the Assistant Field Office
Director (AFOD).
Outlined in the ECSPC SOP,
section B, "Living Wills" and in
the DIHS SOP 2.6.0 "Advanced
Directives ".
Outlined in DIHS SOP 2.6.1
"Living Wills."
Do Not Resuscitate (DNR)
procedures are addressed in the
ECSPC SOP, section C and in
the DIHS SOP 2.6.2 "Obtaining
Do Not Resuscitate."
Supportive medical care of the
detainee with terminal/serious
illness is within the scope
services outlined in LOP 801,
"Scope of Medical Services.”
Outlined in DIHS SOP 3.10,
"Required Notifications.”

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TERMINAL ILLNESS, ADVANCED DIRECTIVES, AND DEATH
POLICY ALL FACILITIES HOUSING ICE DETAINEES SHALL HAVE POLICIES AND PROCEDURES ADDRESSING THE ISSUES OF TERMINAL ILLNESS OR
INJURY, MEDICAL ADVANCED DIRECTIVES, AND DETAINEE DEATH, TO INCLUDE THE PROCEDURES TO ENSURE PROPER NOTIFICATION IS
PROVIDED TO ICE OFFICIALS, FAMILY MEMBERS AND OTHER INTERESTED PARTIES IN THE EVENT OF A DETAINEE BECOMING TERMINALLY ILL
OR INJURED OR DEATH OF A DETAINEE OCCURS. IN ADDITION, THE POLICY WILL COVER PROCEDURES TO BE TAKEN IF THE DEATH OF A
DETAINEE OCCURS WHILE IN TRANSIT.
CHECK THIS BOX IF THE FACILITY DOES NOT ACCEPT ICE DETAINEES WHO ARE SEVERELY OR TERMINALLY ILL. INDICATE NA IN
THE APPROPRIATE BOX FOR THIS PORTION OF THE WORKSHEET. ALWAYS COMPLETE ALL REFERENCES TO DETAINEE DEATH AND
RELATED NOTIFICATIONS.
COMPONENTS
Y
N
NA
REMARKS
Outlined in ECSPC SOP,
section D and in the DIHS SOP
2.6.4, "Organ Donation.”
Death is a reportable event as
addressed in the DIHS SOP 3.10
"Required Notifications.”
ECSPC SOP, section E, "Death
Occurring in ICE Custody"
addresses the facility's
notification procedures.

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.

ECSPC SOP section G
addresses procedures regarding
disposition of remains.

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 placed in
the subject's a-file.
The facility follows established policy and procedures describing when to
contact the local coroner regarding such issues as:
 Performance of an autopsy;
 Who will perform the autopsy;
 Obtaining state approved death certificates; and
 Local transportation of the body.
ICE staff follows established procedures to properly close the case of a
deceased detainee.

ACCEPTABLE

DEFICIENT

Outlined in ECSPC SOP,
section I, "Death Certificate".
Outlined in ECSPC SOP,
section J, "Authority to Order
Autopsies".

Case Closure is outlined in the
ECSPC SOP, section H.

AT-RISK

REPEAT FINDING

REMARKS:
An interview with the clinical director and the health services administrator indicates the facility has the capability of providing
medical supportive care to the detainee with terminal or serious illness. Any detainee whose condition has deteriorated to an acuity
level requiring invasive monitoring not available at the facility or requiring specialty-based medical treatment will be reviewed by the
clinical director, who will then fill out the required DIHS transfer referral form and notify the AFOD prior to transferring the detainee
to the local hospital. This procedure is outlined in LOP 801, "Scope of Medical Services" and LOP 804, "Authorization for Off-Site
Referral and Hospital Admission.” DIHS honors the Patient Self-Determination Act of 1990, Public Law 101-508; 104 Statute 1388,
which requires that health care institutions inform patients of their right to participate in and direct health care decisions by
implementing, advanced directives. Detainees who wish to execute advanced directives are provided the generic State of California
Advanced Directive forms or are assisted to contact his private attorney to implement living wills/advanced directive decision, as

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outlined in SOP 2.6.0 "Advanced Directives, 6.2.1 "Living Wills."
DIHS USPHS medical staff notifies the AFOD when the detainee is determined to have a serious or terminal illness or in the event of
detainee death. DIHS "Required Notification(s)" to the AFOD include the detainee's wish to execute advance directive/living wills
documents including a "Do Not Resuscitate (DNR) decision. ECSPC SOP "Terminal Illness, Advance Directives and Death"
addresses all the facility's policy and procedures that meets the requirements of this standard.
There were no detainee death records to review during the period of the current DIHS policy revision of April 2006 to present.

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SECTION IV.
SECURITY AND CONTROL

CONTRABAND
POLICY: ALL DETENTION FACILITIES WILL ENSURE THE PROPER HANDLING AND DISPOSAL OF ALL CONTRABAND. DOCUMENTATION OF
CONTRABAND DESTRUCTION IS REQUIRED.
COMPONENTS
Y
N
NA
REMARKS
The facility follows a written procedure for handling illegal contraband.

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CONTRABAND
POLICY: ALL DETENTION FACILITIES WILL ENSURE THE PROPER HANDLING AND DISPOSAL OF ALL CONTRABAND. DOCUMENTATION OF
CONTRABAND DESTRUCTION IS REQUIRED.
COMPONENTS
Y
N
NA
REMARKS
Staff inventory, hold, and report it when necessary to the proper authority
for action/possible seizure.
Contraband that is government property is retained as evidence for
potential disciplinary action or criminal prosecution.
Staff returns property not needed as evidence to the proper authority.
Written procedures cover the return of such property.
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.

ACCEPTABLE

DEFICIENT

AT-RISK

REPEAT FINDING

REMARKS:
All seized contraband is appropriately recorded and stored, pending disposition in the AFOD's office safe.
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DETENTION FILES
POLICY: EVERY FACILITY WILL CREATE A DETENTION FILE FOR EVERY ICE DETAINEE BOOKED INTO THE FACILITY, EXCLUDING ONLY
DETAINEES SCHEDULED TO DEPART WITHIN 24 HOURS. THE DETENTION FILE WILL CONTAIN COPIES AND, IN SOME CASES, THE ORIGINAL OF
SPECIFIED DOCUMENTS CONCERNING THE DETAINEE'S STAY IN THE FACILITY: CLASSIFICATION SHEET, MEDICAL QUESTIONNAIRE, PROPERTY
INVENTORY SHEET, DISCIPLINARY DOCUMENTS, ETC.
COMPONENTS
Y
N
NA
REMARKS
Detention files are well
A detention file is created for every new arrival whose stay will exceed
maintained and arranged by
24 hours.
security level. They contain the
Form I-385, DCS form, medical
questionairre, property
inventory sheet, Record of
Search, disciplinary records,
and other pertient documents
related to the detainees stay.
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 I-77s closed-out during the detainee’s stay
 Disciplinary forms/Segregation forms
 Grievances, complaints, and the disposition(s) of same
Detention files are mainitained
The detention files are located and maintained in a secure area. If not, the
in the Intake/Release
cabinets are lockable and distribution of the keys is limited to
Department. The files are in a
supervisors.
secure area.
The detention file remains active during the detainee’s stay. When the
detainee is released from the facility, staff adds copies of completed
release documents, the original closed-out receipts for property and
valuables, the original I-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 properly
requested by supervisory personnel at the receiving facility or office.
The SDDO and Processing
Officer have keys to the
Detention Files. Removed files
are logged out and in.

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.

ACCEPTABLE

DEFICIENT

AT-RISK

REPEAT FINDING

REMARKS:
Detention files contain information as directed by policy and they are well maintained, orderly, and kept in a secure area of the facility.

/ June 19, 2008
AUDITOR’S SIGNATURE / DATE
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CONTRABAND
POLICY: ALL DETENTION FACILITIES WILL ENSURE THE PROPER HANDLING AND DISPOSAL OF ALL CONTRABAND. DOCUMENTATION OF
CONTRABAND DESTRUCTION IS REQUIRED.
COMPONENTS
Y
N
NA
REMARKS
The facility follows a written procedure for handling illegal contraband.
Staff inventory, hold, and report it when necessary to the proper authority
for action/possible seizure.
Contraband that is government property is retained as evidence for
potential disciplinary action or criminal prosecution.
Staff returns property not needed as evidence to the proper authority.
Written procedures cover the return of such property.
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.

ACCEPTABLE

DEFICIENT

AT-RISK

REPEAT FINDING

REMARKS:
All seized contraband is appropriately recorded and stored pending disposition in the AFOD's office safe.

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ENVIRONMENTAL HEALTH AND SAFETY
POLICY: EVERY FACILITY WILL CONTROL FLAMMABLE, TOXIC, AND CAUSTIC MATERIALS THROUGH A HAZARDOUS MATERIALS PROGRAM.
THE PROGRAM WILL INCLUDE, AMONG OTHER THINGS, THE IDENTIFICATION AND LABELING OF HAZARDOUS MATERIALS IN ACCORDANCE WITH
APPLICABLE STANDARDS (E.G., NATIONAL FIRE PROTECTION ASSOCIATION [NFPA]); IDENTIFICATION OF INCOMPATIBLE MATERIALS, AND
SAFE-HANDLING PROCEDURES
COMPONENTS
Y
N
NA
REMARKS
The facility has a system for storing, issuing, and maintaining inventories
Local policy, Environmental
of hazardous materials.
Health and Safety, dated April
17, 2008 establishes a system
for the control of all hazardous
materials.
Constant inventories are maintained for all flammable, toxic, and caustic
Inventories are maintained on
substances used/stored in each section of the facility.
all hazardous chemicals. The
tool room officer maintains
MSDS's and inventories of all
materials.
The manufacturer’s Material Safety Data Sheet (MSDS) file is up-to-date
for every hazardous substance used.
MSDS's are maintained in all
 The files list all storage areas, and include a plant diagram and
areas where hazardous materials
legend.
are used.
 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; and
 Report hazards and spills to the designated official.
The MSDSs are readily accessible to staff and detainees in work areas.
MSDS's books are available.
The process is well supervised
Hazardous materials are always issued under proper supervision.
and only limited amounts are
 Quantities are limited; and
allowed inside the secure
 Staff always supervises detainees using these substances.
perimeter.
All "flammable” and “combustible" materials (liquid and aerosol) are
stored and used according to label recommendations.
Lighting fixtures and electrical equipment installed in storage rooms and
other hazardous areas meet National Electrical Code requirements.
The facility has sufficient ventilation, and provides and ensures clean air
exchanges throughout all buildings.
All vents and air conditioning
Vents return vents, and air conditioning ducts are not blocked or
ducts are checked daily and
obstructed in cells or anywhere in the facility.
filters changed monthly.
Living units are maintained at appropriate temperatures in accordance
with industry standards. (68 to 74 degrees in the winter and 72 to 78
degrees in the summer.)
Shower and sink water temperatures do not exceed the industry standard
of 120 degrees.
All toxic and caustic materials are stored in their original containers in a
Until they are diluted and placed
secure area.
in marked bottles.
Excess flammables, combustibles, and toxic liquids are disposed of
properly and in accordance with MSDSs.
Staff directly supervise and account for products with methyl alcohol.
Staff receives a list of products containing diluted methyl alcohol, e.g.,
There are no products
shoe dye. All such products are clearly labeled. "Accountability"
containing methyl alcohol.
includes issuing such products to detainees in the smallest workable
quantities.
Every employee and detainee using flammable, toxic, or caustic materials

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ENVIRONMENTAL HEALTH AND SAFETY
POLICY: EVERY FACILITY WILL CONTROL FLAMMABLE, TOXIC, AND CAUSTIC MATERIALS THROUGH A HAZARDOUS MATERIALS PROGRAM.
THE PROGRAM WILL INCLUDE, AMONG OTHER THINGS, THE IDENTIFICATION AND LABELING OF HAZARDOUS MATERIALS IN ACCORDANCE WITH
APPLICABLE STANDARDS (E.G., NATIONAL FIRE PROTECTION ASSOCIATION [NFPA]); IDENTIFICATION OF INCOMPATIBLE MATERIALS, AND
SAFE-HANDLING PROCEDURES
COMPONENTS
Y
N
NA
REMARKS
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
b2 high
the Occupational Safety and Health Administration (OSHA).
b2 high

A technically qualified officer conducts the fire and safety inspections.

The Safety Office (or officer) maintains files of inspection reports.
The facility has an approved fire prevention, control, and evacuation
plan.

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

A sanitation program covers barbering operations.

The barber shop has the facilities and equipment necessary to meet
sanitation requirements.
The sanitation standards are conspicuously posted in the barbershop.
Written procedures regulate the handling and disposal of used needles
and other sharp objects.
All items representing potential safety or security risks are inventoried
and a designated individual checks this inventory weekly.

maintenance of the fire alarm
system, sprinkler system, hood
systems, emergency generators,
and emergency lighting is not
being conducted as required by
NFPA Fire Codes.
There is an alternate Safety
position filled by an ICE, SIEA
Supervisor assigned the
responsibility.
The plan has been approved by
the AFOD and reviewed by the
Federal Fire Department at the
Seely Navel Base and the El
Centro City Fire Department.

Posted evacuation signs needs to
be re-evaluated to ensure proper
placement.

Review of the documentation
indicated that the housing units
were not receiving quarterly
drills from each shift but
corrective actions were taken
and drills are now being
conducted as required.
Local Policy, Environmental
Health and Safety, dated April
17, 2008 fully addresses
barbering operation and
sanitation controls.
Located in the recreation center.

Weekly inspections are
conducted throughout the

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ENVIRONMENTAL HEALTH AND SAFETY
POLICY: EVERY FACILITY WILL CONTROL FLAMMABLE, TOXIC, AND CAUSTIC MATERIALS THROUGH A HAZARDOUS MATERIALS PROGRAM.
THE PROGRAM WILL INCLUDE, AMONG OTHER THINGS, THE IDENTIFICATION AND LABELING OF HAZARDOUS MATERIALS IN ACCORDANCE WITH
APPLICABLE STANDARDS (E.G., NATIONAL FIRE PROTECTION ASSOCIATION [NFPA]); IDENTIFICATION OF INCOMPATIBLE MATERIALS, AND
SAFE-HANDLING PROCEDURES
COMPONENTS
Y
N
NA
REMARKS
facility to identify safety
hazards.
Standard cleaning practices include:
 Using specified equipment; cleansers; disinfectants and
detergents.
 An established schedule of cleaning and follow-up inspections.

The facility follows standard cleaning procedures.
Spill kits are readily available.
A licensed medical waste contractor disposes of infectious/bio-hazardous
waste.
Staff is trained to prevent contact with blood and other body fluids and
written procedures are followed.
Do the methods for handling/disposing of refuse meet all regulatory
requirements?
A licensed/Certified/Trained pest-control professional inspects for
rodents, insects, and vermin.
 At least monthly.
 The pest-control program includes preventative spraying for
indigenous insects.
Drinking water and wastewater is routinely tested according to a fixed
schedule.
Emergency power generators are tested at least every two weeks.
 Other emergency systems and equipment receive testing at least
quarterly.
 Testing is followed-up with timely corrective actions (repairs
and replacements).

ACCEPTABLE

DEFICIENT

Stericycle Inc. provides all
medical waste disposal.

American Pest Control is
contracted to provide all pestcontrol operations.
City provided and tested as
required by standards.

AT-RISK

REPEAT FINDING

REMARKS:
The fire safety program affords staff and detainees a level of safety that presents no imminent life safety concerns.
The fire safety systems throughout the facility to include fire alarms, sprinkler systems, kitchen hood fire suppression systems,
emergency generators and emergency lighting/exit lights are not being inspected and tested on a monthly, quarterly, or annual schedule
as required by the National Fire Protection Association (NFPA) standards, NFPA 72, NFPA 25 and NFPA 17A, NFPA 110, and
NFPA 70. There is a contract with Candelaria Corporation effective 09/19/07 to perform the requirements of testing, inspecting and
maintenance of these systems. On-site inspection and review of documentation failed to indicate services by Candelaria are being
performed and monitored as required by the statement of work. Candelaria Corporation was notified by facility staff of this oversight
and is scheduled to begin contract performance on Monday June 23, 2008. Management should provide direct oversight and
supervision of the contractor to ensure compliance.

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b2 high

Review of documentation for fire drills indicated that the housing units were not receiving quarterly drills from each shift. Corrective
action was taken and drills are now being conducted as required. Continued monitoring of the fire drill exercises is essential to ensure
staff and detainees, are aware of their responsibilities in emergencies.

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HOLD ROOMS IN DETENTION FACILITIES
POLICY: HOLD ROOMS WILL BE USED ONLY FOR TEMPORARY DETENTION OF DETAINEES AWAITING REMOVAL, TRANSFER, EOIR HEARINGS,
MEDICAL TREATMENT, INTRA-FACILITY MOVEMENT, OR OTHER PROCESSING INTO OR OUT OF THE FACILITY.
COMPONENTS
Y
N
NA
REMARKS
The hold rooms are situated within the secure perimeter.
The hold rooms are well ventilated well lighted, and all activating
switches are located outside the room.
The hold rooms contain sufficient seating for the number of detainees
held.
Bunks, cots, beds, or other related make-shift sleeping apparatus are
precluded from use inside hold rooms.
The walls and ceilings of the hold rooms are tamper and escape proof.
Documentation of supervision
Individuals are not held in hold rooms for more than 12 hours.
and 15 minute checks
maintained electronically.
Male and females are segregated from each other.
Females are not confined at
ECSPC.
Detainees under the age of 18 are not held with adult detainees.
Detainees are provided with basic personal hygiene items such as water,
soap, toilet paper, cups for water, feminine hygiene items, diapers and
wipes.
In older facilities, officers are within visual or audible range to allow
Detainees are within view of
detainees access to toilet facilities on a regular basis.
supervisory staff.
All detainees are given a pat down search for weapons or contraband
before being placed in the room.
Officers closely supervise the detention hold rooms using direct
supervision (Irregular visual monitoring.).
 Hold rooms are irregularly monitored every 15 minutes.
 Unusual behavior or complaints are noted.
When the last detainee has been removed from the hold room, it is given
a thorough inspection.
There is a written evacuation plan that includes a designated officer to
remove detainees from hold rooms in case of fire and/or building
evacuation.
An appropriate emergency service is called immediately upon a
determination that a medical emergency may exist.

ACCEPTABLE

DEFICIENT

AT-RISK

REPEAT FINDING

REMARKS:
Intake and release processing is conducted in a professional manner. Detainees are searched appropriately and interviewed by staff to
determine classification, housing, separation, and medical/psychiatric concerns.

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KEY AND LOCK CONTROL
(SECURITY, ACCOUNTABILITY AND MAINTENANCE)
POLICY IT IS THE POLICY OF THE ICE SERVICE TO MAINTAIN AN EFFICIENT SYSTEM FOR THE USE, ACCOUNTABILITY AND MAINTENANCE OF
ALL KEYS AND LOCKS.
COMPONENTS
Y
N
NA
REMARKS
The security officer[s], or equivalent in IGSAs, has attended an approved
locksmith training program.
The security officer, or equivalent in IGSAs, has responsibly for all
administrative duties and responsibilities relating to keys, locks etc.
The security officer, or equivalent in IGSAs, provides training to
employees in key control.
The security officer, or equivalent in IGSAs, maintains inventories of all
keys, locks and locking devices.
The security officer follows a preventive maintenance program and
maintains 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.

Every lock in the facility is
physically inspected by the
Security Officer.

.

Only dead bolt or dead lock functions are used in detainee accessible
areas.
Only authorized locks (as specified in the Detention Standard) are used in
detainee accessible areas.

b2 high

Grand master keying systems are prohibited.
All worn or discarded keys and locks are cut up and properly disposed of.
Padlocks and/or chains are prohibited from use 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, Ch. 3;
 National Fire Protection Association Life Safety Code 101.
The operational keyboard is sufficient to accommodate all the facility key
rings, including keys in use, and is located in a secure area.
Procedures are in place to ensure that key rings are:
 Identifiable;
 The numbers of keys are cited; and
 Keys cannot be removed.
Emergency keys are available for all areas of the facility.
The facilities use a key accountability system.
Authorization is necessary to issue any restricted key.
Individual gun lockers are provided.
 They are located in an area that permits constant officer
observation.
 In an area that does not allow detainee or public access.
The facility has a key accountability policy and procedures to ensure key
accountability. The keys are physically counted daily.

b2 high

Combination of the automated
Key Watch Control/Issue
Cabinet and conventional check
out from the Control Center. It

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KEY AND LOCK CONTROL
(SECURITY, ACCOUNTABILITY AND MAINTENANCE)
POLICY IT IS THE POLICY OF THE ICE SERVICE TO MAINTAIN AN EFFICIENT SYSTEM FOR THE USE, ACCOUNTABILITY AND MAINTENANCE OF
ALL KEYS AND LOCKS.
COMPONENTS
Y
N
NA
REMARKS
is noted that the daily
accounting procedures of all
keys throughout the facility was
effective June 16, 2008
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.

ACCEPTABLE

DEFICIENT

AT-RISK

REPEAT FINDING

REMARKS:

b2 high

/ June 19, 2008
AUDITOR’S SIGNATURE / DATE
b6, b7c

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POPULATION COUNTS
POLICY: ALL DETENTION FACILITIES SHALL ENSURE AROUND-THE-CLOCK ACCOUNTABILITY FOR ALL DETAINEES. THIS REQUIRES THAT THEY
CONDUCT AT LEAST ONE FORMAL COUNT OF THE DETAINEE POPULATION PER SHIFT, WITH ADDITIONAL FORMAL AND INFORMAL COUNTS
CONDUCTED AS NECESSARY.
COMPONENTS
Y
N
NA
REMARKS
Staff conduct a formal count at least once each shift.
There are 6 formal counts every
twenty-four hours.
Activities cease or are strictly controlled while a formal count is being
conducted.
Certain operations cease during formal counts.
All movement ceases for the duration of a formal count.
Formal counts in all units take place simultaneously.
Detainee participation in counts is prohibited.
A face-to-photo count follows each unsuccessful recount.
A face-to-photo count is
conducted after an unsuccessful
recount and at the 10:30PM
count. The 8:30AM, 3:30PM
and 10:30PM Face to Photo
Count was observed by the
reviewers with no concerns
noted.
Officers positively identify each detainee before counting him/her as
present.
Written procedures cover informal and emergency counts.
 They are followed during informal counts and emergencies.
The control officer (or other designated position) maintains an out count record of all detainees temporarily leaving the facility.
This training is documented in each officer’s training folder.

ACCEPTABLE

DEFICIENT

AT-RISK

REPEAT FINDING

REMARKS:
Count procedures and detainee compliance with count procedures are very effective. Movement in the units is curtailed during counts.
Out counts are managed by the control center officer and are documented with count slips no different from those conducted in the
living units. Local policy, counts and post orders, effectively outlines appropriate count practices.

b6, b7c
/ June 19, 2008
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POST ORDERS
POLICY: ICE PROVIDES OFFICERS ALL NECESSARY GUIDANCE FOR CARRYING OUT THEIR DUTIES. THIS GUIDANCE INCLUDES THE POST
ORDERS ESTABLISHED FOR EVERY POST, WHICH ARE REVIEWED AT LEAST ANNUALLY, AND GIVEN TO EACH OFFICER UPON ASSIGNMENT TO
THAT POST.
COMPONENTS
Y
N
NA
REMARKS
Every fixed post has a set of post orders.
Each set contains the latest inserts (emergency memoranda, etc.) and
revisions.
Post orders are available to all
One individual or department is responsible for keeping all post-orders
staff on each of the 38
current with revisions that take place between reviews.
established posts.
The IGSA maintains a complete set (central file) of post orders.
The SPC maintains a central file
of post orders
The central file is accessible to all staff.
The OIC or Contract / IGSA equivalent initiates/authorizes all post-order
changes.
The OIC or Contract / IGSA equivalent has signed and dated the last
page of every section.
A review/updating/reissuing of post orders occurs regularly and at a
minimum, annually.
Procedures keep post orders and logbooks secure from detainees at all
Post orders are secured when
times.
not is use.
Every armed-post officer qualifies with the post weapon(s) before
assuming post duty.
Armed-post post orders provide instructions for escape attempts.
Each set of post orders includes
The post orders for housing units track the event schedule.
a specific chronology of duties
to be preformed by the staff
member.
The log is kept by the control
Housing-unit post officers record all detainee activity in a log. The post
center office and the unit
order includes instructions on maintaining the logbook.
officer.

ACCEPTABLE

DEFICIENT

AT-RISK

REPEAT FINDING

REMARKS:
Post orders are up to date and available to all staff.
All 38 sets of post orders were reviewed. They are well written and adequately explain general and specific duties related to each post.
Documentation is maintained indicating signatures of all post orders reviewed.

b6, b7c
/ June 19, 2008
AUDITOR’S SIGNATURE / DATE

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SECURITY INSPECTIONS
POLICY: POST ASSIGNMENTS IN THE FACILITY'S HIGH-RISK AREAS, WHERE SPECIAL SECURITY PROCEDURES MUST BE FOLLOWED, WILL BE
RESTRICTED TO EXPERIENCED PERSONNEL WITH A THOROUGH GROUNDING IN FACILITY OPERATIONS.
COMPONENTS
YES
NO
NA
REMARKS
The facility has a comprehensive security inspection policy. The policy
specifies:
Contract guard services conduct
 Posts to be inspected;
daily inspections, and the
 Required inspection forms;
Deportation Operations
 Frequency of inspections;
Supervisor conducts weekly
 Guidelines for checking security features; and
inspections.
 Procedures for reporting weak spots, inconsistencies, and other
areas needing improvement
Every officer is required to conduct a security check of his/her assigned
area. The results are documented.
Documentation of security inspections is kept on file.
Procedures ensure that recurring problems and a failure to take
corrective action are reported to the appropriate manager.
The front-entrance officer checks the ID of everyone entering or exiting
the facility.
All visits are officially recorded in a visitor logbook or electronically
recorded.
The facility has a secure visitor pass system.
Every Control Center officer receives specialized training.
The Control Center is staffed around the clock.
Policy restricts staff access to the Control Center.

Local policy restricts access to
the control room and an
approved list of staff authorized
access is posted outside of the
Control Room.

Detainees are restricted from 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; and
 Name of employee responsible for the vehicle during the visit
Officers thoroughly search each vehicle entering and leaving the facility.
The facility has a written policy and procedures to prevent the
introduction of contraband into the facility or any of its components.
Tools being taken into the secure area of the facility are inventoried
before entering and prior to departure.
The SMU entrance has a sally port.
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 is documented.
Storage and supply rooms, walls, light and plumbing fixtures, accesses,
and drains, etc., undergo frequent, irregular searches. These searches are
documented.

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SECURITY INSPECTIONS
POLICY: POST ASSIGNMENTS IN THE FACILITY'S HIGH-RISK AREAS, WHERE SPECIAL SECURITY PROCEDURES MUST BE FOLLOWED, WILL BE
RESTRICTED TO EXPERIENCED PERSONNEL WITH A THOROUGH GROUNDING IN FACILITY OPERATIONS.
COMPONENTS
YES
NO
NA
REMARKS
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; and
 Documenting the results.
Visitation areas receive frequent, irregular inspections.

ACCEPTABLE

DEFICIENT

AT-RISK

REPEAT FINDING

REMARKS:
All vehicles and visitors are appropriately searched, identified, recorded, and processed into the facility at the front entrance or through
the vehicle sally port. The sally port is currently undergoing a security enhancement project of installing new perimeter fencing,
automated slide gates, camera surveillance, and intrusion detection. At the request of the review team, management agreed to assign
one additional officer to this post temporarily to provide additional supervision during the construction process.

b6, b7c
/June 19, 2008
AUDITOR’S SIGNATURE / DATE

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SPECIAL MANAGEMENT UNIT (SMU)
ADMINISTRATIVE SEGREGATION
POLICY: THE SPECIAL MANAGEMENT UNIT REQUIRED IN EVERY FACILITY ISOLATES CERTAIN DETAINEES FROM THE GENERAL POPULATION.
THE SPECIAL MANAGEMENT UNIT WILL CONSIST OF TWO SECTIONS. ONE, ADMINISTRATIVE SEGREGATION, HOUSES DETAINEES ISOLATED
FOR THEIR OWN PROTECTION; THE OTHER FOR DETAINEES BEING DISCIPLINED FOR WRONGDOING (SEE THE “SPECIAL MANAGEMENT UNIT
[DISCIPLINARY SEGREGATION]” STANDARD).
COMPONENTS
Y
N
NA
REMARKS
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.
Detainees placed in the SMU
In exigent circumstances, staff may place a detainee in the SMU
are provided a copy of detention
(administrative) before a written order has been approved.
orders within 24 hours of their
 A copy of the order given to the detainee within 24 hours.
placement.
The OIC (or equivalent) regularly reviews the status of detainees in
A review of 11 discipline files
administrative detention.
for the past three months
verifies a detainee’s placement
 A supervisory officer conducts a review within 72 hours of the
in the unit is reviewed within 72
detainee’s placement in the SMU (administrative).
hours.
A supervisory officer conducts another review after the detainee has
spent seven days in administrative segregation, and:
 Every week thereafter for the first month; and
 Every 30 days after the first month.
 Does each review include an interview with the detainee?
 Is a written record made of the decision and the justification?
The detainee is given a copy of the decision and justification for each
Interviews of detainees confined
review.
in the SMU revealed they are
provided a copy of the detention
 The detainee is given an opportunity to appeal the reviewer's
order.
decision to someone else in the facility.
The OIC (or equivalent) routinely notifies the Field Office Director (or
A review of disciplinary files for
staff officer in charge of IGSAs) any time a detainee's stay in
the past three months revealed
administrative detention exceeds 30 days.
no detainee has remained in the
 Upon notification that the detainee's administrative segregation
SMU for more than 60
has exceeded 60 days, the FD forwards written notice to HQ
consecutive days.
Field Operations Branch Chief for DRO.
The OIC or equivalent) reviews the case of every detainee who objects
to administrative segregation after 30 days in the SMU.
 A written record is made of the decision and the justification.
 The detainee receives a copy of this record.
Detainees are provided copies of
The detainee is given the right to appeal to the OIC (or equivalent) the
the decision to continue their
conclusions and recommendations of any review conducted after the
confinement in the SMU. They
detainee have remained in administrative segregation for seven
are also provided written
consecutive days.
notification of their right to
appeal the decision.
Administratively segregated detainees enjoy the same general privileges
as detainees in the general population.
The SMU is:
 Well ventilated;
 Adequately lighted;
 Appropriately heated; and
 Maintained in a sanitary condition.

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SPECIAL MANAGEMENT UNIT (SMU)
ADMINISTRATIVE SEGREGATION
POLICY: THE SPECIAL MANAGEMENT UNIT REQUIRED IN EVERY FACILITY ISOLATES CERTAIN DETAINEES FROM THE GENERAL POPULATION.
THE SPECIAL MANAGEMENT UNIT WILL CONSIST OF TWO SECTIONS. ONE, ADMINISTRATIVE SEGREGATION, HOUSES DETAINEES ISOLATED
FOR THEIR OWN PROTECTION; THE OTHER FOR DETAINEES BEING DISCIPLINED FOR WRONGDOING (SEE THE “SPECIAL MANAGEMENT UNIT
[DISCIPLINARY SEGREGATION]” STANDARD).
COMPONENTS
Y
N
NA
REMARKS
All cells are equipped with beds.
 Every bed is 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?
Detainees in the SMU are
The segregated detainees have the same opportunities to
permitted to exchange bedding
exchange/launder clothing, bedding, and linen as detainees in the
and clothing three times per
general population.
week.
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;
A review of SMU daily activity
 Recreation privileges in accordance with the “Detainee
logs revealed they are provided
Recreation" standard;
three meals per day and eat only
 Non-legal reading material;
with disposable utensils.
 Religious material;
Detainees in SMU are afforded
 The same correspondence privileges as detainees in the general
the same privileges as those in
population;
the general population.
 Telephone access similar to that of the general population; and
 Personal legal material.
A health care professional visits every detainee at least three times a
week.
 The shift supervisor visits each detainee daily.
 Weekends and holidays.
Procedures comply with the “Visitation" standard.
 The detainee retains visiting privileges; and
 The visiting room is available during normal visiting hours.
Visits from clergy are allowed.
Detainees have the same law-library access as the general population.
 Are they required to use the law library Separately, or
As a group?
 Are legal materials brought to them?
The SMU maintains a permanent log of detainee-related activity, e.g.,
meals served, recreation, visitors etc.
SPC procedures include completing the SMU Housing Record (I-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 I-888 (or local equivalent).

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SPECIAL MANAGEMENT UNIT (SMU)
ADMINISTRATIVE SEGREGATION
POLICY: THE SPECIAL MANAGEMENT UNIT REQUIRED IN EVERY FACILITY ISOLATES CERTAIN DETAINEES FROM THE GENERAL POPULATION.
THE SPECIAL MANAGEMENT UNIT WILL CONSIST OF TWO SECTIONS. ONE, ADMINISTRATIVE SEGREGATION, HOUSES DETAINEES ISOLATED
FOR THEIR OWN PROTECTION; THE OTHER FOR DETAINEES BEING DISCIPLINED FOR WRONGDOING (SEE THE “SPECIAL MANAGEMENT UNIT
[DISCIPLINARY SEGREGATION]” STANDARD).
COMPONENTS
Y
N
NA
REMARKS
Staff record whether the detainee ate, showered, exercised, and took any
applicable medication during every shift.
 Staff logs record all pertinent information, e.g., a medical
condition, suicidal/assaultive behavior, etc;
 The medical officer/health care professional signs each
individual's record during each visit; and
 The housing officer initials the record when all detainee
services are completed or at the end of the shift.
A new record is created for each week the detainee is in Administrative
Segregation.
 The weekly records are retained in the SMU until the
detainee's return to the general population.

ACCEPTABLE

DEFICIENT

AT-RISK

REPEAT FINDING

REMARKS:
The SMU operates within standards and accepted correctional practices. The unit is clean, well ventilated, and detainees are afforded
the same privileges as detainees in the general population. Medical staff and security supervisors visit the unit on a daily basis and
members of the clergy make routine visits as well. Logs and forms of activities and events in the unit are maintained and contain
accurate information.

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/June 19, 2008
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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
REMARKS
Officers placing detainees in disciplinary segregation follow written
procedures.
The sanctions for violations committed during one incident are limited
A review of discipline packets
to 60 days.
for the past three months
revealed no detainee has been
sanctioned to more than 60 days
of disciplinary segregation.
A completed Disciplinary Segregation Order accompanies the detainee
into the SMU.
 The detainee receives a copy of the order within 24 hours of
placement in disciplinary segregation.
Standard procedures include reviewing the cases of individual detainees
Weekly and monthly reviews
housed in disciplinary detention at set intervals.
are conducted in accordance
 After each formal review, the detainee receives a written copy of
with policy requirements.
the decision and supporting reasons.
The conditions of confinement in the SMU are proportional to the
amount of control necessary to protect detainees and staff.
Detainees in disciplinary segregation have fewer privileges than those
housed in administrative segregation.
Living conditions in disciplinary SMUs remain the same regardless of
behavior.
 If no, does staff prepare written documentation for this action?
 Does the OIC sign to indicate approval.
All detainees confined in the
Every detainee in disciplinary segregation receives the same humane
SMU receive humane treatment
treatment, regardless of offense.
regardless of the offense.
The quarters used for segregation are:
 Well-ventilated.
 Adequately lighted.
 Appropriately heated.
 Maintained in a sanitary condition.
All cells are equipped with beds that are securely fastened to the floor or
wall of the cell.
The number of detainees confined to each cell or room is limited to the
number for which the space was designate.
 Does the OIC approve excess occupancy on a temporary
basis?
When a detainee is segregated without clothing, mattress, blanket, or
pillow (in a dry cell setting), a justification is made and the decision is
reviewed each shift. Items are returned as soon as it is safe.
Detainees in the SMU have the same opportunities to exchange
clothing, bedding, etc., as other detainees.
Detainees in the SMU receive three nutritious meals per day, selected
from the Food Service's menu of the day.
 Food is not used as punishment.
Detainees are allowed to maintain a normal level of personal hygiene,
including the opportunity to shower and shave at least three times/week.
Detainees receive, unless documented as a threat to security:

Detainees confined in

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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
REMARKS
disciplinary
segregation are
 Barbering services;
afforded
the
opportunity for
 Recreation privileges;
barber
services,
recreation,
 Other-than-legal reading material;
leisure
and
religious
materials,
 Religious material;
and
correspondence
privileges.
 The same correspondence privileges as other detainees; and
 Personal legal material.
When phone access is limited by number or type of calls, the following
Detainees are required to submit
areas are exempt:
a request to staff to make
 Calls about the detainee's immigration case or other legal
official calls. Requests are
matters;
processed and the detainee is
 Calls to consular/embassy officials; and
permitted to contact official
 Calls during family emergencies (as determined by the
personnel.
OIC/Warden).
A health care professional visits every detainee in disciplinary
segregation every week day.
 The shift supervisor visits 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 are notified of security concerns
arising before a visit.
Visits from clergy are allowed.
 The clergy member is given the option of visiting/not visiting
the segregated detainee.
 Violent/uncooperative detainees are denied access to religious
services when safety and security would otherwise be affected.
SMU detainees have law library access.
 Violent/uncooperative detainees retain access to the law
library unless adjudicated a security threat in writing.
 Legal material brought to individuals in the SMU on a caseby-case basis.
 Staff documents every incident of denied access to the law
library.
All detainee-related activities are documented, e.g. meals served,
recreation activities, visitors, etc.
The SPC's, the Special Management Housing Unit Record (I-888or
equivalent), is prepared as soon as the detainee is placed in the SMU.
 All I-888s are filled out by the end of each shift.
 The CDF/IGSA facility use Form.
 I-888 (or equivalent local form).

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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
REMARKS
SMU staff record whether the detainee ate, showered, exercised, took
medication, etc.
 Details about the detainee logged, e.g., a medical condition,
suicidal/violent behavior, etc.
 The health care official sign individual records after each visit.
 The housing officer initials the record when all detainee
services are completed or at the end of the shift.
 A new record is created weekly for each detainee in the SMU.
 The SMU retains these records until the detainee leaves the
SMU.

ACCEPTABLE

DEFICIENT

AT-RISK

REPEAT FINDING

REMARKS:
Detainees are required to submit a request to staff in order to make official calls. Requests are processed and the detainee is permitted
to contact official personnel.

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/June 19, 2008
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TOOL CONTROL
POLICY: IT IS THE POLICY OF ALL FACILITIES THAT ALL EMPLOYEES SHALL BE RESPONSIBLE FOR COMPLYING WITH THE TOOL CONTROL
POLICY. THE MAINTENANCE SUPERVISOR SHALL MAINTAIN A COMPUTER GENERATED OR TYPEWRITTEN MASTER INVENTORY LIST OF TOOLS
AND EQUIPMENT AND THE LOCATION IN WHICH TOOLS ARE STORED. THESE INVENTORIES SHALL BE CURRENT, FILED AND READILY AVAILABLE
FOR TOOL INVENTORY AND ACCOUNTABILITY DURING AN AUDIT.
COMPONENTS
Y
N
NA
REMARKS
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 the:
 Maintenance Department;
 Medial Department;
 Food Service Department;
 Electronics Shop;
 Recreation Department; and
 Armory.
The facility has a 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.
The facility has a tool classification system. Tools are classified
according to:
All tools are classified as
 Restricted (dangerous/hazardous); and
restricted in the facility.
 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.
Tools in all departments are
 The system ensures that all stored tools are accountable.
stored in a secure manner and
 Commonly used tools (tools that can be mounted) are
are easily identifiable.
stored in such a way that missing tool is readily notice.
Each facility has procedures for the issuance of tools to staff and
detainees.
The facility has policies and procedures to address the issue of lost tools.
The policy and procedures include:
Tools are issued to staff only.
 Verbal and written notification;
Detainees are not permitted to
handle or use tools.
 Procedures for detainee access; and
 Necessary documentation/review for all incidents of lost tools.
Broken or worn out tools are surveyed and disposed of in an appropriate
and secure manner.
All private or contract repairs and maintenance workers under contract to
ICE, or other visitors, submit an inventory of all tools prior to admittance
into or departure from the facility.

ACCEPTABLE

DEFICIENT

AT-RISK

REPEAT FINDING

REMARKS:
Staff responsible for the development and maintenance of the tool control program demonstrates a very good understanding of
procedures and benefits of the proper handling and control of tools. During the past year, there were no instances where a tool was
lost or could not be accounted for.

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Detainees are not allowed to use any tools and they are not assigned voluntary work duties in the maintenance section. Tools are
accounted for each day by a minimum of two staff members.
b6, b7c
June 19, 2008
AUDITOR’S SIGNATURE / DATE

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TRANSPORTATION
LAND TRANSPORTATION
POLICY: THE IMMIGRATION AND NATURALIZATION SERVICE WILL TAKE ALL NECESSARY PRECAUTIONS TO PROTECT THE LIVES, SAFETY, AND
WELFARE OF OUR OFFICERS, THE GENERAL PUBLIC, AND THOSE IN ICE CUSTODY DURING THE TRANSPORTATION OF DETAINEES. STANDARDS
HAVE BEEN ESTABLISHED FOR PROFESSIONAL TRANSPORTATION UNDER THE SUPERVISION OF EXPERIENCED AND TRAINED DETENTION
ENFORCEMENT OFFICERS OR AUTHORIZED CONTRACT PERSONNEL.
STANDARD NA: CHECK THIS BOX IF ALL ICE TRANSPORTATION IS HANDLED ONLY BY THE ICE FIELD OFFICE OR SUB-OFFICE IN
CONTROL OF THE DETAINEE CASE.
COMPONENTS
Transporting officers comply with applicable local, state, and federal
motor vehicle laws and regulations. Records support this finding of
compliance.
Every transporting officer required to drive a commercial size bus has a
valid Commercial Driver's License (CDL) issued by the state of
employment.
Supervisors maintain records for each vehicle operator.
Officers use a checklist during every vehicle inspection.
 Officers report deficiencies affecting operability; and
 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;
 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, there are two
qualified officers per vehicle.
 An unaccompanied driver may transport an empty vehicle.
Before the start of each detail, the vehicle is thoroughly searched.
Positive identification of all detainees being transported is confirmed.
All detainees are searched immediately prior to boarding the vehicle by
staff controlling the bus or vehicle.
The facility ensures that the number of detainees transported does not
exceed the vehicles manufacturer’s occupancy level.

YES

NO

NA

REMARKS

A review of staff training
records verifies all transporting
officers possess a valid
CDL.
Staff assigned to transport
vehicles performs safety
inspections prior to each trip.

Written procedures specifically
limit driving times for transport
officers.

Staff ensures all detainees are
accounted for after each
stop.

Protective vests are provided to all transporting officers.
The vehicle crew conducts a visual count once all passengers are on
board and seated.
 Additional visual counts are made whenever the vehicle makes
a scheduled or unscheduled stop.
Policies and procedures are in place addressing the use of restraining
equipment on transportation vehicles.
Officers ensure that no one contacts the detainees.
 One officer remains in the vehicle at all times when detainees
are present.
Meals are provided during long distance transfers.
 The meals meet the minimum dietary standards, as identified by

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TRANSPORTATION
LAND TRANSPORTATION
POLICY: THE IMMIGRATION AND NATURALIZATION SERVICE WILL TAKE ALL NECESSARY PRECAUTIONS TO PROTECT THE LIVES, SAFETY, AND
WELFARE OF OUR OFFICERS, THE GENERAL PUBLIC, AND THOSE IN ICE CUSTODY DURING THE TRANSPORTATION OF DETAINEES. STANDARDS
HAVE BEEN ESTABLISHED FOR PROFESSIONAL TRANSPORTATION UNDER THE SUPERVISION OF EXPERIENCED AND TRAINED DETENTION
ENFORCEMENT OFFICERS OR AUTHORIZED CONTRACT PERSONNEL.
STANDARD NA: CHECK THIS BOX IF ALL ICE TRANSPORTATION IS HANDLED ONLY BY THE ICE FIELD OFFICE OR SUB-OFFICE IN
CONTROL OF THE DETAINEE CASE.
COMPONENTS
dieticians utilized by ICE.
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 discrepancies with the Food Service
representative;
 Basins, latrines, and drinking-water containers/dispensers are
cleaned and sanitized on a fixed schedule.
Vehicles have:
 Two-way radios;
 Cellular telephones; and
 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;
 Inspected; and
 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 includes women or minors

ACCEPTABLE

DEFICIENT

YES

NO

NA

REMARKS

Vehicle trip boxes include
emergency plans and
procedures.

AT-RISK

REPEAT FINDING

REMARKS:
The transport operation at the facility is well managed and supervised. Transport staff and supervisors are knowledgeable of bus
operations and transport procedures.
b6, b7c
June 19, 2008
AUDITOR’S SIGNATURE / DATE

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USE OF FORCE
POLICY: THE U.S. DEPARTMENT OF HOMELAND SECURITY AUTHORIZES THE USE OF FORCE ONLY AS A LAST ALTERNATIVE AFTER ALL OTHER
REASONABLE EFFORTS TO RESOLVE A SITUATION HAVE FAILED. ONLY THAT AMOUNT OF FORCE NECESSARY TO GAIN CONTROL OF THE
DETAINEE, TO PROTECT AND ENSURE THE SAFETY OF DETAINEES, STAFF AND OTHERS, TO PREVENT SERIOUS PROPERTY DAMAGE AND TO
ENSURE INSTITUTION SECURITY AND GOOD ORDER MAY BE USED. PHYSICAL RESTRAINTS NECESSARY TO GAIN CONTROL OF A DETAINEE WHO
APPEARS TO BE DANGEROUS MAY BE EMPLOYED WHEN THE DETAINEE:
COMPONENTS
YES
NO
NA
REMARKS
Written policy authorizes staff to respond in an immediate-use-of-force
Local policy, 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 uses 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.

Local policy, Use of Force.

While all uses of force are
reviewed, 4 after actions
conducted in 2008 did not reveal
the signature of the AOIC,
SDDO, and Health Services
Administrator.

Staff:



Do not use force as punishment;
Attempt to gain the detainee's voluntary cooperation before
resorting to force;
 Use only as much force as necessary to control the
detainee; and
 Use restraints only when other non-confrontational means,
including verbal persuasion, have failed or are impractical.
Medication may only be used for restraint purposes when authorized by
the Medical Authority as medically necessary.
Use-of-Force Team follows written procedures that attempt to prevent
injury and exposure to communicable disease(s).
Standard procedures associated with using four-point restraints include:
 Soft restraints (e.g., vinyl);
 Dressing the detainee appropriately for the temperature;
 A bed, mattress, and blanket/sheet;
 Checking the detainee at least every 15 minutes;
 Logging each check;
 Turning the bed-restrained detainee often enough to
prevent soreness or stiffness;
 Medical evaluation of the restrained detainee twice per
eight-hour shift; and
 When qualified medical staff is not immediately available,
staff position the detainee "face-up".
The shift supervisor monitors the detainee's position/condition every two

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USE OF FORCE
POLICY: THE U.S. DEPARTMENT OF HOMELAND SECURITY AUTHORIZES THE USE OF FORCE ONLY AS A LAST ALTERNATIVE AFTER ALL OTHER
REASONABLE EFFORTS TO RESOLVE A SITUATION HAVE FAILED. ONLY THAT AMOUNT OF FORCE NECESSARY TO GAIN CONTROL OF THE
DETAINEE, TO PROTECT AND ENSURE THE SAFETY OF DETAINEES, STAFF AND OTHERS, TO PREVENT SERIOUS PROPERTY DAMAGE AND TO
ENSURE INSTITUTION SECURITY AND GOOD ORDER MAY BE USED. PHYSICAL RESTRAINTS NECESSARY TO GAIN CONTROL OF A DETAINEE WHO
APPEARS TO BE DANGEROUS MAY BE EMPLOYED WHEN THE DETAINEE:
COMPONENTS
YES
NO
NA
REMARKS
hours.
 He/she allows the detainee to use the rest room at these
times under safeguards.
All detainee checks are logged.
In immediate-use-of-force situations, staff contacts medical staff once the
detainee is under control.
When the OIC authorizes use of non-lethal weapons:
 Medical staff is consulted before staff use pepper
spray/non-lethal weapons.
 Medical staff reviews the detainee's medical file before use
of a non-lethal weapon is authorized.
Special precautions are taken when restraining pregnant detainees.
Women are not confined at this
facility.
 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 is 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 and Officers are certified in all
devices they use.
In SPCs, is the Use of Force form is used? In other facilities (IGSAs /
CDFs) is this form or its equivalent used?

ACCEPTABLE

DEFICIENT

AT-RISK

REPEAT FINDING

REMARKS:
There has been no calculated use of force within the past year and only four incidents of the immediate use of force within the past
year. All uses of force were reviewed and determined to be appropriate. The AFOD, Assistant OIC, and Supervisory Detention and
Deportation Officer, and Health Services Administrator should sign the after action report at the completion of each review.
b6, b7c
/June 19, 2008
AUDITOR’S SIGNATURE / DATE

STAFF DETAINEE COMMUNICATIONS
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 ANSWER IN AN ACCEPTABLE
TIME FRAME.
COMPONENTS
Y
N
NA
REMARKS
The ICE Field Office Director ensures that weekly announced and
Rounds are conducted at
unannounced visits occur at the IGSA.
minimum weekly.
Detention and Deportation Staff conduct scheduled weekly visits with
Rounds are conducted at
detainees held in the IGSA.
minimum weekly.
Scheduled visits are posted in ICE detainee areas.
Visiting staff observe and note current climate and conditions of
confinement at each IGSA.

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STAFF DETAINEE COMMUNICATIONS
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 ANSWER IN AN ACCEPTABLE
TIME FRAME.
COMPONENTS
Y
N
NA
REMARKS
ICE information request Forms are available at the IGSA for use by ICE
detainees.
The IGSA treats detainee correspondence to ICE staff as Special
Correspondence.
ICE staff responds to a detainee request from an IGSA within 72 hours.
ICE detainees are notified in writing upon admission to the facility of
their right to correspond with ICE staff regarding their case or conditions
of confinement.

ACCEPTABLE

DEFICIENT

AT-RISK

REPEAT FINDING

REMARKS:
ICE staff and ICE detainees interact daily at the ECSPC.
Postings are in all housing areas regarding:
 OIG Hotline Information
 Sexual Harassment/Assault Prevention and Reporting
 Pro-Bono Legal Telephone Numbers and Consulate Office Telephone Numbers

b6, b7c
/ June 19, 2008
AUDITOR’S SIGNATURE / DATE

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DETAINEE TRANSFER STANDARD
POLICY: ICE WILL MAKE ALL NECESSARY NOTIFICATIONS WHEN A DETAINEE IS TRANSFERRED. IF A DETAINEE IS BEING TRANSFERRED VIA
THE JUSTICE PRISONER ALIEN TRANSPORTATION SYSTEM (JPATS), 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, WHETHER THE
DETAINEE’S ATTORNEY IS LOCATED WITHIN REASONABLE DRIVING DISTANCE OF THE FACILITY, AND WHERE THE IMMIGRATION COURT
PROCEEDINGS ARE TAKING PLACE.
COMPONENTS
Y
N
NA
REMARKS
When a detainee is represented by legal counsel or a legal representative,
and a G-28 has been filed, the representative of record is notified by the
The notification is recorded in
detainee’s Deportation Officer.
the detainees A-file, and noted
in the comments section of the
 The notification is recorded in the detainee’s file; and
DACS.
 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 allowed discretion regarding the timing of the
notification when extenuating circumstances are involved.
The attorney and detainee are notified that it is their responsibility to
Notification is provided via the
notify family members regarding a transfer.
"Detainee Transfer Notification"
Facility policy mandates that:
 Times and transfer plans are never discussed with the detainee
prior to transfer;
ECSPC SOP Detainee Transfer,
 The detainee is not notified of the transfer until immediately
prior to departing the facility; and
 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.
The G-391 "Order to Escort
Form G-391 or equivalent authorizing the removal of a detainee from a
Alien" is provided to processing
facility is used.
and Escort Officers.
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;
and
 A medical transfer summary is completed and accompanies 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.
Information pertaining to
For medical transfers, transporting officers receive instructions regarding
scheduled medications,
medical issues.
ambulatory conditions, etc. is
relayed to the transport officers.
Detainee’s funds, valuables, and property are returned and transferred
Funds (cash) are given directly
with the detainee to his/her new location.
to the detainee. Personal
property, jewelry, legal
materials does accompany the
detainee in transport.
"Request for Bed/Designation"
Transfer and documentary procedures outlined in Section C and D are
and "Preperation and Transfer of
followed.
Records" are followed.

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DETAINEE TRANSFER STANDARD
POLICY: ICE WILL MAKE ALL NECESSARY NOTIFICATIONS WHEN A DETAINEE IS TRANSFERRED. IF A DETAINEE IS BEING TRANSFERRED VIA
THE JUSTICE PRISONER ALIEN TRANSPORTATION SYSTEM (JPATS), 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, WHETHER THE
DETAINEE’S ATTORNEY IS LOCATED WITHIN REASONABLE DRIVING DISTANCE OF THE FACILITY, AND WHERE THE IMMIGRATION COURT
PROCEEDINGS ARE TAKING PLACE.
COMPONENTS
Y
N
NA
REMARKS
Meals are provided in
Meals are provided when transfers occur during normally schedule meal
compliance with the "Land
times.
Transportation" standard.
An A File or work folder accompanies the detainee when transferred to a
different field office or sub-office.
Files are forwarded to the receiving office via overnight mail no later
than one business day following the transfer.

ACCEPTABLE

DEFICIENT

AT-RISK

REPEAT FINDING

REMARKS:
The Detainee Transfer standard is in full compliance.

b6, b7c
June 19, 2008
AUDITOR’S SIGNATURE / DATE

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