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

Office of Detention Oversight
Compliance Inspection

Enforcement and Removal Operations
Phoenix Field Office
Florence Service Processing Center
Florence, Arizona

December 4 – 6, 2012

COMPLIANCE INSPECTION
FLORENCE SERVICE PROCESSING CENTER
PHOENIX FIELD OFFICE
TABLE OF CONTENTS
EXECUTIVE SUMMARY ...........................................................................................................1
INSPECTION PROCESS
Report Organization .............................................................................................................6
Inspection Team Members ...................................................................................................6
OPERATIONAL ENVIRONMENT
Internal Relations .................................................................................................................7
Detainee Relations ...............................................................................................................7
ICE PERFORMANCE-BASED NATIONAL DETENTION STANDARDS
Detention Standards Reviewed ............................................................................................8
Emergency Plans ..................................................................................................................9

EXECUTIVE SUMMARY
The Office of Professional Responsibility, Office of Detention Oversight (ODO) conducted a
Compliance Inspection (CI) of the Florence Service Processing Center (Florence SPC) in
Florence, Arizona, from December 4 to 6, 2012. Florence SPC was built in 1942 to hold
prisoners of war during World War II. Since 1983, the former U.S. Immigration and
Naturalization Service (INS) has used the facility to house adult males detained for
administrative immigration violations. The facility is approximately 140,203 square feet, and
has a capacity of 392 beds. U.S. Immigration and Customs Enforcement (ICE) owns and
operates the facility to house detainees of all security classification levels (Level I – lowest
threat, Level II – medium threat, Level III – highest threat) for over 72 hours. The average daily
detainee population at Florence SPC is 369. The average length of stay is 12 days. At the time
of this inspection, the facility housed 328 male detainees (293 Level I, 35 Level II, 0 Level III).
Florence SPC does not house female detainees.
Asset Protection and Security Services (APSS) is contracted to provide security, transportation,
and food service. Rosemark is the maintenance contractor. Florence SPC holds accreditations
from the American Correctional Association (ACA) and the National Commission on
Correctional Health Care (NCCHC).
The Enforcement and Removal Operations (ERO), Field Office Director (FOD),
Phoenix, Arizona (ERO Phoenix) is responsible for ensuring facility compliance with ICE
policies and the Performance-Based National Detention Standards (PBNDS). An Assistant Field
Office Director (AFOD) is stationed at Florence SPC, and is the highest-ranking ERO official at
the facility. In addition to the AFOD, ERO staff at Florence SPC is comprised of (b)(7)eAssistant
Officers in Charge, (b)(7)e Supervisory Detention and Deportation Officers (SDDO),
Supervisory Immigration Enforcement Agents,(b)(7)eDeportation Officers (DO), and
(b)(7)e
Immigration Enforcement Agents. The AFOD stated there are no vacant positions at
Florence SPC. A permanently-assigned ERO Detention Service Manager monitors facility
compliance with the PBNDS.
The Project Manager is the highest ranking APSS official at Florence SPC, and is responsible for
oversight of security operations, transportation, and food service. In addition to the Project
Manager, APSS supervisory staff consists of(b)(7)eshift commanders,(b)(7)edetention lieutenants,
and(b)(7) transportation lieutenants. Line staff consists of(b)(7)edetention officers(b)(7)etransportation
officers, and(b)(7)estaff members in the Detainee Services Department.
In October 2010, ODO conducted a Quality Assurance Review at Florence SPC. Of the
23 PBNDS reviewed, 17 were in full compliance. The remaining six standards accounted for
11 deficiencies. None of these was repeated during this CI.
In March 2012, ERO Detention Standards Compliance Unit contractor, the Nakamoto Group,
Inc., conducted an annual review of the PBNDS at Florence SPC. Florence SPC received an
overall rating of “Meets Standards,” and was found compliant with all 41 standards reviewed.
During this CI, ODO reviewed 16 PBNDS. ODO determined 15 standards were fully compliant.
ODO found only one deficiency, in the Emergency Plans standard. Specifically, the PBNDS
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Emergency Plans standard requires that an integrated training exercise for the Command Post,
Hostage Negotiation Team (HNT), and Special Response Team (SRT) be conducted every six
months. At the time of inspection, ODO verified Florence SPC conducted only one training
exercise for calendar year 2012.
This report details the deficiency identified by ODO and refers to the specific, relevant sections
of the PBNDS. ERO will be provided a copy of this report to assist in developing corrective
actions to resolve the deficiency. This deficiency was discussed with Florence SPC personnel
on-site during the inspection, as well as during the closeout briefing conducted on
December 6, 2012.
ODO attributes Florence SPC’s high level of compliance with the PBNDS and the low number
of deficiencies identified in this CI to ERO leadership and staff who are very well educated
regarding the requirements of the 2008 PBNDS. ODO also attributes the low number of
deficiencies to the presence of a dedicated ERO standards compliance team, in addition to the
presence of an on-site Detention Service Manager.
The Florence SPC staff-detainee communication policy allows detainees to have informal and
unrestricted access and interaction with ERO and facility staff. ERO visitation schedules are
conspicuously posted in all detainee housing units. Detainees can also submit formal written
questions, concerns, or requests to ERO and facility staff by completing a request form. From
January 1 to November 30, 2012, the facility received and processed over 13,500 formal requests
from detainees. ODO reviewed 35 randomly-selected formal requests submitted by detainees
during this time period, and verified all 35 requests were documented and recorded in the
electronic request log, answered with a response to the detainee in a timely manner, and a copy
of the request was placed and maintained in the detainee’s detention file. Furthermore, ODO
reviewed the Facility Liaison Visit Checklists from January 1 to November 30, 2012, and
confirmed ERO officers consistently conduct scheduled and unannounced visits multiple times
each week to interact with detainees, address their questions or concerns, and monitor the living
conditions in the housing units, including the SMU. In addition, the AFOD informed ODO that
ERO officers frequently spend an entire day interacting with detainees during their staff-detainee
communication visits, and observe various detainee recreational activities.
The facility maintains an electronic grievance log to document and track all formal grievances
submitted by detainees. The grievance log reflects that Florence SPC received and processed a
total of 57 formal grievances from January 1 to November 30, 2012; 22 pertained to staff
treatment, 12 to funds and personal property, six pertained to medical-related issues, four to mail,
and three to detainee searches. The remaining ten formal grievances were divided among issues
such as commissary, food service, laundry, segregation, and visitation. ODO reviewed ten
randomly-selected formal grievances submitted by detainees during this time period and verified
that all ten requests were documented and recorded in the electronic grievance log and answered
with a timely response to the detainee. Copies of the grievances were placed in the detainees’
detention files. ODO reviewed all six formal medical grievances and verified they were
responded to in a timely manner and placed in the detainees’ medical files. Medical grievances
are handled and processed only by medical staff. In addition, the medical department maintains
its own grievance log to document and track all medical grievances.

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Florence SPC policy requires officers to conduct and document 15-minute checks of detainees
placed on suicide watch, in accordance with the PBNDS.
ODO reviewed the facility’s suicide prevention training plan, and noted all required elements are
covered in accordance with the PBNDS. ODO reviewed training records for (b)(7)econtract
security staff, (b)(7)eERO officers, and(b)(7)emedical staff. ODO confirmed all staff timely
completed required training in suicide prevention and intervention.
Florence SPC designated a Supervisory Immigration Enforcement Agent as the Sexual Abuse
and Assault Prevention and Intervention (SAAPI) coordinator. ERO and APSS personnel are
required to attend pre-service and annual training on the SAAPI program. ODO reviewed a
random sample of training records for(b)(7)e RO and(b)(7)eAPSS staff members, and confirmed
completion of required SAAPI training. ERO and APSS staffs also receive training in sexual
harassment, the Prison Rape Elimination Act, and the SAAPI PBNDS. ODO interviewed ERO
and APSS staffs, and verified their knowledge with respect to the SAAPI program and how to
handle any information received concerning possible sexual abuse or assault.
During the intake process, detainees are screened to identify sexual abuse victimization history
and identification of potential sexual aggressors. Florence SPC separates detainees identified
with a history of predatory or abusive sexual behavior from detainees with a history of
victimization.
During the intake process, staff provides detainees with a tri-fold brochure with information and
guidance for reporting any kind of sexual abuse or misconduct by other detainees or staff.
Detainees are also informed of the SAAPI program in the detainee handbook, which contains
detailed and comprehensive information addressing nonconsensual sexual acts, abusive sexual
contact, non-contact sexual abuse, staff sexual misconduct, and staff sexual harassment. In
addition, the handbook provides instructions for reporting sexual assault, and the toll-free and
speed dial numbers to the DHS Office of Inspector General Hotline. Florence SPC runs a daily
video in the housing units that addresses SAAPI. ODO observed SAAPI informational postings
in the intake area, the medical department, the kitchen, all housing units, and the segregation
unit. The informational postings are provided in both English and Spanish, and include toll-free
telephone numbers for reporting incidents.
The SAAPI coordinator informed ODO of four incidents of reported sexual abuse and assault
from January 2012 to November 2012, all classified as detainee-on-detainee. Documentation
indicates Florence SPC personnel complied with current ERO policy and the PBNDS in all of
the reported incidents. Three of the incidents involved allegations of verbal sexual harassment or
inappropriate comments with no physical contact, and were deemed unsubstantiated. One
incident involved an allegation of inappropriate physical contact. ODO verified the SAAPI
coordinator and AFOD made notifications to the ICE Joint Intake Center telephonically within
two hours of the alleged incident, and in writing within 24 hours via the ICE Significant Event
Notification database. ODO reviewed the documentation, and confirmed ERO investigated the
incident internally and notified the local police. The local police interviewed the alleged victim
and perpetrator, and filed a report regarding the one allegation of inappropriate physical contact.
No criminal charges were filed. There were no witnesses to this incident, and the allegation was
deemed unsubstantiated by investigating authorities.
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At the time of the inspection, there were four detainees in administrative segregation (AS) and
none in disciplinary segregation. One of the four detainees was placed in AS at his own request
for protective custody; the remaining three detainees were in AS for medical observation. ODO
reviewed AS documentation for these detainees and verified facility officials issued AS orders to
all four detainees. In addition, ERO supervisory staff members timely perform AS status
reviews, and the FOD was notified of the two detainees who were placed in AS for over 30 days.
Furthermore, ERO Headquarters was also notified of the one detainee who had been placed in
AS for over 60 days. ODO observed the Special Management Unit (SMU) at Florence SPC to
be clean, well-lit, and temperature appropriate. ODO also reviewed SMU housing records, and
confirmed custody and medical staff consistently monitor detainee living and health conditions
in the SMU.
Florence SPC has a comprehensive written policy governing the use of force, including the
five-level use of force continuum. The facility does not use four-point restraints, restraint chairs,
or any electro-muscular disruption devices. ODO was informed there were eight use-of-force
incidents from January 1 to December 4, 2012. Seven involved immediate uses of force and one
involved a calculated use of force. ODO reviewed written documentation and video recordings,
and confirmed full compliance with the PBNDS and facility policy. Medical personnel
performed medical examinations on involved detainees immediately following the incidents.
After-action review teams convened the first workday following the incidents. ODO confirmed
required documentation was forwarded to the AFOD as required.

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

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

INSPECTION TEAM MEMBERS

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

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Special Agent (Team Leader)
Section Chief
Special Agent
Special Agent
Contract Inspector
Contract Inspector
Contract Inspector

6

ODO, Phoenix
ODO, Phoenix
ODO, Phoenix
ODO, San Diego
Creative Corrections
Creative Corrections
Creative Corrections

Florence Service Processing Center
ERO Phoenix

OPERATIONAL ENVIRONMENT
INTERNAL RELATIONS
ODO interviewed the AFOD, the SDDO of the American Correctional Association (ACA) and
PBNDS compliance team, and the APSS Project Manager. During the interviews, ERO and
APSS leadership stated the working relationship between the two entities is excellent, and the
morale of ERO and APSS staff is very good.
The APSS Project Manager stated he consistently observes ERO staff visiting the housing units
multiple times each week, and communicating with ICE detainees to address their issues or
concerns. The Project Manager praised the leadership of the AFOD, and said the
professionalism of the ERO staff has resulted in the facility’s high level of compliance with the
PBNDS. The SDDO praised the members of his ACA compliance team for doing an excellent
job ensuring the facility maintains a high level of compliance with the PBNDS.

DETAINEE RELATIONS
ODO interviewed 11 Level I detainees, and five Level II detainees, housed at Florence SPC, for
a total of 16 detainee interviews. The periods of detention for these 16 detainees ranged from
five days to six months. All of the detainees said they received a total of three hours of
recreation daily. In addition, all confirmed they received a complete supply of personal hygiene
items upon admission, and the hygiene items are replenished daily at no cost to the detainees.
All were satisfied with the quality and quantity of the food at the facility. No detainees
complained about the adequacy of medical care, and no detainees stated they had been victims of
or observed any verbal, physical or sexual abuse by staff or other detainees. All stated they had
access to religious services, regular visitation by family members, free access to the law library,
and access to grievance forms.
All but one detainee confirmed facility officials provided them with national and facility-specific
detainee handbooks in both English and Spanish. ODO reviewed the detention file associated
with the detainee claiming he did not receive a detainee handbook, and verified the detainee
signed a receipt indicating he had indeed received both the national and local detainee
handbooks.
Nine detainees knew the identity of their DO, and all knew how to contact a DO, if necessary.
The seven detainees who claimed they did not know the identity of their DO stated they did not
care to know or did not have a need to know the identity of their DO. All detainees said they
frequently see and observe ERO officers visiting the housing units each week to communicate
with detainees.
All 16 detainees interviewed stated they were able to use the detainee telephone system. Three
detainees who were housed in the same pod complained they sometimes had difficulty hearing
through the detainee telephones in that pod. ODO notified facility officials of the matter; the
officials promptly issued a work order and repaired the telephones. ODO verified the telephones
were working properly upon completion of the repairs.

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ICE PERFORMANCE-BASED
NATIONAL DETENTION STANDARDS
ODO reviewed a total of 16 PBNDS and found Florence SPC fully compliant with the following
15 standards:
Admission and Release
Classification System
Detainee Handbook
Environmental Health and Safety
Food Service
Grievance System
Hunger Strikes
Law Libraries and Legal Material
Medical Care
Sexual Abuse and Assault Prevention and Intervention
Special Management Units
Staff-Detainee Communication
Suicide Prevention and Intervention
Telephone Access
Use of Force and Restraints
As these standards were compliant at the time of the review, a synopsis for these standards was
not prepared for this report.
ODO found one deficiency in the Emergency Plans PBNDS. The finding for this standard is
presented in the remainder of this report.

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EMERGENCY PLANS (EP)
ODO reviewed the Emergency Plans standard at Florence SPC to determine if a contingency
plan has been developed to quickly and effectively respond to any emergency situations, and
minimize their severity, in accordance with the ICE PBNDS. ODO interviewed ERO and APSS
staffs, reviewed emergency plans and memoranda of understanding, and inspected command
post equipment.
An SDDO is responsible for the development and implementation of the facility’s emergency
plans. ODO confirmed the emergency plans are well organized, and access is strictly controlled.
ODO verified the emergency plans were developed in cooperation with local, state, and federal
law enforcement agencies and memoranda of understanding exist formalizing the inter-agency
agreements. An SDDO maintains a list identifying the location of each emergency plan in the
command center. Interviews of the AFOD, SDDO, Immigration Enforcement Agents, the ICE
Facility Operation Specialist, and APSS contract security staff confirmed they are
knowledgeable about the emergency plans. ERO and APSS staff receives training on the plans
as part of orientation, during annual refresher training, and periodically as part of daily and
weekly staff briefings. ODO confirmed Florence SPC has not encountered an incident that
would require the activation of the facility emergency plans.
ODO verified Florence SPC emergency plans include all contingency-specific plans required by
the PBNDS. The plans are comprehensive and cover all mandated elements. Procedures are in
place requiring documentation and accurate recording of events, staff responses, and command
decisions during and immediately after emergency situations. Post-action debriefings are
required, involving analytical discussion, to ensure actions taken were appropriate and in
accordance with policy and the PBNDS. Florence SPC maintains a current roster of all staff
telephone numbers, as well as law enforcement and other emergency responders.
ODO verified no integrated training exercise for the Command Post, HNT, and SRT were
conducted in 2012 (Deficiency EP-1). Training exercises every six months as required by the
PBNDS reinforces staff readiness and integrated responses in the event of a hostage situation.
Though no hostage situation training exercises were conducted, ODO notes Florence SPC
conducted an extensive Anthrax Disaster Drill in September 2012. The drill, hosted by the ICE
National Emergency Management Division, in partnership with ERO Phoenix, included training
and several practical exercises.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY EP-1
In accordance with the ICE PBNDS, Emergency Plans, section (V)(E)(5)(b)(5), the FOD must
ensure training exercises integrating the activities of the Command Post, HNT and SRT shall
occur every six months to underscore the importance of a total facility response to a hostage
situation. As participants collaborate and interact, they will experience how the other operational
teams think and function, as well as what each can contribute in a crisis.

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