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
Pinal County Adult Detention Center
Florence, Arizona

March 13- 15, 2012

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

COMPLIANCE INSPECTION
PINAL COUNTY ADULT DETENTION CENTER
PHOENIX FIELD OFFICE
TABLE OF CONTENTS
EXECUTIVE SUMMARY ........................................................................................................... !
INSPECTION PROCESS
Report Organization ............................................................................................................. 4
Inspection Team Members ................................................................................................... 4

OPERATIONAL ENVIRONMENT
Internal Relations ................................................................................................................. 5
Detainee Relations ............................................................................................................... 5

ICE NATIONAL DETENTION STANDARDS
Detention Standards Reviewed ............................................................................................ 8
Detention Files ..................................................................................................................... 9
Environmental Health and Safety ...................................................................................... ! 0
Tool Control ....................................................................................................................... 14
Use ofForce ....................................................................................................................... 15

EXECUTIVE SUMMARY
The Office ofProfessional Responsibility (OPR), Office ofDetention Oversight (ODO)
conducted a Compliance Inspection of the Pinal County Adult Detention Center (PCADC) in
Florence, Arizona, from March 13- 15, 2012. The 1,504 bed, 215,745 square foot facility is
owned by the County of Pinal and operated by the Pinal County Sheriffs Office (PCSO).
PCADC houses male and female adults arrested in Pinal County, who are awaiting disposition of
their criminal case; juveniles charged criminally as adults; and inmates from the City of
Florence, the State of Arizona, and the United States Marshals Service.
The facility opened in April 1996 with an initial bed capacity of 472 beds. In July 2006, the
facility added 1,032 beds, which increased the total capacity to 1,504 beds. Currently, 525 (35
percent) ofthose beds are dedicated to male U.S. Immigration and Customs Enforcement (ICE)
detainees of all security classification levels who are in removal proceedings; 68, 100 square feet
of living and dayroom space is set aside for exclusive use by ICE detainees. ICE does not house
female detainees at PCADC. In January 2007, ICE began housing male detainees at PCADC via
an ICE Intergovernmental Service Agreement with Pinal County that was completed in August
2006. The average daily detainee population is 420. At the time of inspection, PCADC housed
466 male ICE detainees (231 Levell lowest-threat detainees; 105 Level 2 medium-threat
detainees; and 130 Level 3 highest-threat detainees). The average length of a detainee's stay is
31 days. Food service is provided under contract by Canteen Correctional Services. Medical
care is provided by ICE Health Service Corps (IHSC). PCADC holds no accreditations;
however, accreditation from the National Commission on Correctional Healthcare (NCCHC) is
pending.
The ICE Office ofEnforcement and Removal Operations (ERO), Field Office Director, Phoenix,
Arizona (FOD/Phoenix) is responsible for ensuring facility compliance with ICE policies and the
National Detention Standards (NDS). An Assistant Field Office Director (AFOD) physically
located at the Florence Service Processing Center (FPC) is responsible for oversight of all ICE
detention matters at PCADC. There are (b)(7)eImmigration Enforcement Agents (lEAs)
permanently stationed at PCADC. (b)(7)e lEAs report to a Supervisory lEA (SIEA) at FPC. The
SIEA is supervised by a Supervisory Detention and Deportation Officer (SDDO) at FPC. The
SDDO reports directly to the AFOD at FPC.
The total number of non-ICE staff employed at PCADC is (b)(7)e The Deputy Chief of Adult
Detention is the highest ranking non-ICE official at PCADC and is responsible for oversight of
daily operations. PCADC staff is comprised of(b)(7)eDetention Officers,(b)(7)eDetention
Supervisors,(b)(7)eDetention Aides,(b)(7)eClerks, (b)(7)e Detention Administrators, (b)(7)eTraining
Specialist, and(b)(7)eParalegal. On-site IHSC medical staff at PCADC consists of a Health
Service Administrator (HSA), an Assistant HSA, a Physician, a Psychiatrist, (b)(7)e Physician
Assistants, a Clinical Social Worker, a Pharmacist, a Pharmacy Technician, (b)(7)e Medical
Technicians, an Administrative Assistant,(b)(7)eRegistered Nurses (RN), and (b)(7)eLicensed
Practical Nurses.
In February 2009, the OPR Detention Facilities Inspection Group (DFIG), predecessor to ODO,
conducted a Quality Assurance Review (QAR) ofPCADC. DFIG staff recorded a total of63
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-------------

deficiencies among the 21 NDS reviewed. In February 2010, ODO conducted a Follow-up
Review of PCADC to ascertain whether PCADC had addressed the deficiencies noted in the
2009 QAR. Reviewers documented five (8 percent) repeated deficiencies among four of the
NDS reviewed: Detention Files, Environmental Health and Safety, Medical Care, and Security
Inspections.
In January 2011, ODO conducted a Focus Review ofPCADC and reviewed a total of26 NDS.
The selection ofPCADC for an ODO Focus Review was based on an analysis of the totality of
criteria and circumstances related to the facility, including an elevated number of incidents and
complaints in comparison to other detention facilities across the country. During the Focus
Review, ODO identified 22 deficiencies in 11 standards, including: Access to Legal Material;
Detention Files; Environmental Health and Safety; Key and Lock Control; Recreation; Security
Inspections; Special Management Unit (Administrative Segregation); Staff-Detainee
Communication; Tool Control; Use ofForce; and Visitation. A majority of these deficiencies
were minor, with minimal impact regarding life-safety issues and the overall operational
readiness ofthe facility. The remaining 15 standards reviewed were found to be fully compliant.
In June 2011, the ERO Detention Standards Compliance Unit (DSCU) contractors, MGT of
America, Inc., conducted a Compliance Review of the ICE NDS at PCADC. The facility
received an overall rating of"Acceptable."
During this Compliance Inspection, ODO reviewed a total of 19 NDS. Fifteen standards were
found to be fully compliant; while 14 deficiencies were found in the remaining four standards:
Detention Files (1 deficiency), Environmental Health and Safety (8), Tool Control (3), and Use
of Force (2). Four deficiencies are repeat deficiencies from the 2011 ODO Focus Review,
including one deficiency in the Environmental Health and Safety standard, one deficiency in the
Tool Control standard, and two deficiencies in the Use ofForce standard.
This report details all deficiencies and refers to specific, relevant sections of the ICE NDS. OPR
will provide ERO a copy of the report to assist in developing corrective actions to resolve the 14
identified deficiencies.
Overall, ODO found PCADC to be well-managed and in compliance with the standards
inspected. A majority ofthe 14 deficiencies identified were related to inventory control, and
management of hazardous materials and chemicals used in the facility. Details of these
deficiencies are described in the Environmental Health and Safety section of this report.
All detainees are initially processed and staged at FPC prior to being admitted into PCADC. At
FPC, detainees are booked and classified. Detainee property is inventoried and stored, except for
monetary funds under $200, which detainees are allowed to carry on their person with them to
PCADC. Detainees receive an initial medical screening and a chest X-ray at FPC to rule out
tuberculosis (TB). Upon arrival at PCADC, detainees receive additional medical screenings and
a physical examination from IHSC staff to identify chronic conditions.
Detainees at PCADC access medical care by completing and submitting a sick-call request slip.
Requests are triaged daily to determine priority of care. Detainees in segregation are visited by

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an RN and a Physician Assistant, who make face-to-face rounds to identify and address
immediate medical needs. Detainees who require a higher level of medical care are transported
to the Anthem Florence Hospital in Florence, Arizona, or the Mountain Vista Hospital in Apache
Junction, Arizona. The CasaGrande Medical Center and Maricopa Community Hospital are
also used, when necessary. The clinic at PCADC has four treatment rooms to provide full
privacy during examinations or medical encounters; however, PCADC does not have a negative
air pressure or reverse air-flow room to contain and isolate detainees with TB.
ODO confirmed ERO officers regularly conduct scheduled and unannounced visits to the
housing units on a weekly basis. ERO officers document their visits on the ICE Facility Liaison
Visit Checklist to demonstrate consistency of their visits and compliance with the Change Notice
National Detention Standards Staff/Detainee Communication Model Protocol, dated June 15,
2007. Completed telephone serviceability worksheets showed ERO officers test the telephones
in the detainee living areas on a weekly basis.
PCADC has an effective grievance system that accommodates formal and informal grievances.
Detainees are free to bypass the informal grievance process and file a formal grievance directly.
Detainees are also provided the opportunity to appeal grievance decisions not resolved to the
detainee's satisfaction. Grievances against PCADC staff are reviewed by ERO. All formal
grievances are documented in a grievance log. From July 1, 2011, to February 29, 2012, the
facility received and processed 129 formal grievances submitted by ICE detainees.
Ofthe 129 formal grievances filed by ICE detainees, 46 (36 percent) pertained to complaints
against staff, 17 (13 percent) pertained to commissary matters, 13 (1 0 percent) pertained to
medical issues, 13 (10 percent) pertained to food service, 8 (6 percent) pertained to mail room
and property issues, 8 (6 percent) pertained to maintenance, 7 (5 percent) pertained to laundry, 5
(4 percent) were appeals to grievance decisions, 3 (2 percent) pertained to searches, 3 (2 percent)
pertained to legal complaints, 2 (2 percent) pertained to telephone service, 2 (2 percent)
pertained to religious service, and 2 (2 percent) pertained to recreation. ODO reviewed each of
the 129 grievances and verified that all (1 00 percent) were answered in a timely manner.
During the inspection, there were seven ICE detainees housed in administrative segregation and
three ICE detainees housed in disciplinary segregation. ODO confirmed the segregation units
were clean, well ventilated, and adequately lit, with appropriate climate control. ODO
interviewed all detainees in administrative and disciplinary segregation. All detainees stated
they understood why they were placed in segregation. Detainees in administrative and
disciplinary segregation stated they had been consistently seen by medical staff, fed three times a
day, and provided recreation. Detainees in disciplinary segregation stated they had no
complaints regarding the sanctions imposed against them.

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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 NDS or the ICE Performance Based National
Detention Standards (PBNDS), as applicable. The NDS apply to PCADC. In addition, ODO
may focus its inspection based on detention management information provided by the ERO
Headquarters (HQ) and ERO field offices, and on issues of high priority or interest to ICE
executive management.
ODO reviewed the processes employed at PCADC 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 (JICMS), the ENFORCE Alien Booking Module (EABM), and the
ENFORCE Alien Removal Module (EARM). ODO also gathered facility facts and inspectionrelated information from ERO HQ staff to prepare for the site visit at PCADC.

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

INSPECTION TEAM MEMBERS

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

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

4

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

Pinal County Adult Detention Center
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OPERATIONAL ENVIRONMENT
INTERNAL RELATIONS
ODO interviewed the PCADC Deputy Chief of Adult Detention, the PCADC Captain for Policy
and Compliance, the ERO AFOD, an ERO SDDO, and an ERO SIEA. During the interviews, all
personnel from PCADC and ERO stated the working relationship between PCADC and ERO
officers is excellent, and morale among PCADC and ERO staff is good. The Deputy Chief and
the Captain both stated they consistently see ERO officers visiting the housing units multiple
times each week and communicating with ICE detainees to address their issues or concerns. The
Deputy Chief further stated he has observed ERO officers visiting the housing units to
communicate with ICE detainees.
The AFOD stated ERO is adequately staffed to manage and handle the current detainee
population at PCADC. The Deputy Chief stated the facility is currently understaffed, and 30
additional PCADC Detention Officers have been requested.

DETAINEE RELATIONS
000 randomly selected and interviewed 32 male ICE detainees, including one Level 1
detainee, ten Level 2 detainees, and 21 Level 3 detainees, to assess the overall living and
detention conditions at PCADC. ODO received no complaints concerning access to legal
materials, issuance and replenishment of hygiene supplies, facility sanitation, sending and
receiving of mail, recreation, visitation, meal and food service, or the grievance process.
Fifteen detainees (47 percent) stated they have never seen their Deportation Officers since being
detained at PCADC; however, ODO observed ERO officers visiting the housing units pursuant
to a weekly visitation schedule posted conspicuously in the detainee living areas. Facility
visitation logbooks indicated the presence ofERO officers conducting unannounced visits in the
housing units on a weekly basis, in addition to the scheduled visits.
Five detainees (16 percent) stated medical personnel at PCADC have been unresponsive to their
medical requests. The complaints of these five detainees with the corresponding dispositions
follow:
1. A detainee complained he had filed a medical grievance, because medical officials were not
responsive to his complaint of a hernia. ODO reviewed the medical records ofthis detainee
and verified he had been on narcotic pain medication at a different facility. PCADC staff had
observed the detainee doing dips, push-ups, sit-ups, and working out on exercise equipment
for 45 minutes. Pursuant to their observations and medical review, facility officials
determined the detainee's complaint lacked credibility. The IHSC HSA advised that the
detainee was evaluated by a Physician, and the Physician noted there were no masses.
Furthermore, medical records did not indicate the detainee had submitted or filed a medical
grievance pertaining to pain caused by a hernia.

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2. A detainee complained medical staffwas unresponsive to his complaints of pain associated
with two lost dental fillings. Medical records confirmed a Dentist evaluated the detainee a
week after admission to PCADC. The Dentist advised the detainee to seek routine dental
care upon release from the facility. Medical staff provided the detainee with over-thecounter pain medication. Per the ICE NDS, a facility is not required to provide routine dental
treatment unless dental treatment has been inaccessible to the detainee for prolonged periods
resulting from detention of over six months.
3. A detainee stated he had been receiving medical treatment for hypertension, and complained
the medical staff continuously changed his prescription due to allergic reactions. The
detainee objected to medical staff changing his medications. Medical records confirmed that
medical officials are addressing the issue and are continuing to discuss it with the detainee to
resolve the issue.
4. A detainee complained medical staff at the facility was unresponsive to efforts to retrieve a
knee brace from the family of the detainee for relief from a previous knee injury. ODO
verified through medical records that a medical doctor had evaluated the detainee and found
no medical reason for a knee brace. The medical record did not contain any information
regarding the family members' possession of a knee brace.
5. A detainee complained, after filing three sick-call requests in two weeks, there had been no
response from the medical staff to any ofthe submitted requests. ODO alerted the medical
staff of the complaint, and medical officials determined the detainee had incorrectly filed the
sick-call requests. Medical staff immediately examined the detainee, and explained the sickcall process.
Three detainees stated facility officials issued them the Spanish version ofthe PCADC
handbook. These detainees wanted the English versiori of the handbook. According to these
detainees, PCADC staff told them there were no English versions available. ODO verified
through PCADC staff the PCADC handbook can be printed on-site immediately upon request,
because the master copy is electronically saved as a computer file. During the inspection,
PCADC officials printed three copies ofthe facility handbook in English, and the handbooks
were provided to the three detainees requesting an English version.
Two detainees stated, despite submitting written requests, the PCADC Chaplain had not
facilitated or arranged a visit by a Muslim Imam. ODO verified the PCADC Chaplain has
communicated with Muslim leaders in Phoenix and Tucson in an attempt to facilitate this
request. The Muslim leaders will not provide an Imam on a pro bono basis, and PCADC will not
pay to have an Imam come to the facility. ERO officials are aware of this situation and have
been attempting to negotiate a pro bono Imam visit to Florence for several years in order to
provide religious services to Muslim detainees in the facility; however, the negotiations have
been unsuccessful.
Although two detainees complained of"dropped" telephone calls, the remaining detainees
expressed satisfaction with the detainee telephone system and knew how to use the telephones to
contact consular officials, attorneys, and family members. A diagnostic report from the on-site

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telephone service representative indicated the detainee telephone system was functioning
properly. ODO successfully conducted random test calls to verify the operability ofthe
telephones located in the detainee living areas.

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ICE NATIONAL DETENTION STANDARDS
ODO reviewed a total of 19 NDS and found PCADC fully compliant with the following 15
standards:
Access to Legal Material
Detainee Classification System
Detainee Grievance Procedures
Detainee Handbook
Detainee Transfers
Disciplinary Policy
Food Service
Hold Rooms in Detention Facilities
Hunger Strikes
Issuance and Exchange of Clothing, Bedding, and Towels
Medical Care
Special Management Unit (Administrative Segregation)
Special Management Unit (Disciplinary Segregation)
Staff-Detainee Communication
Telephone Access
As these standards were compliant at the time ofthe review, synopses for these areas were not
prepared for this report.
ODO found deficiencies in the following four areas:
Detention Files
Environmental Health and Safety
Tool Control
Use of Force
Findings for each ofthese standards are presented in the remainder of this report.

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DETENTION FILES (DF)
ODO reviewed the Detention Files NDS at PCADC to determine if files are created containing
all significant information on detainees housed at the facility for over 24 hours. ODO
reviewed detention files, logbooks, policies and procedures, toured the admissions and release
area and property room, and interviewed staff.
ODO reviewed 20 active detention files and ten archived detention files to determine if
required documentation was present. As part of the intake process, staff creates a detention
file when a detainee arrives and is admitted to the facility.
ODO observed detention files had been closed without inserting required release
documentation. Specifically, all of the archived detention files reviewed by ODO did not
contain copies of completed release documents, such as Form I-203, Orders to Detain or
Release Alien, reflecting the date and time the detainee was ordered released from the facility
by an ERO official (Deficiency DF-1). It is important that copies of completed documents be
placed in the detention file of a released detainee to ensure the correct detainee has been
released from custody.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY DF-1
In accordance with the ICE NDS, Detention Files, section (III)(E)(2), the FOD must ensure staff
will insert into the released detainee's detention file copies of completed release documents, the
original closed-out receipts for property and valuables, the original I-385 and other
documentation.

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ENVIRONMENTAL HEALTH AND SAFETY (EH&S)
ODO reviewed the Environmental Health and Safety NDS at PCADC to determine if the facility
maintains high standards of cleanliness and sanitation, safe work practices and control of
hazardous materials and substances. ODO toured the facility, interviewed staff, and reviewed
policies and documentation of inspections, hazardous chemical management, and fire drills.
The staff member assigned responsibility for the PCADC environmental health and safety
program recently resigned. Sanitation at the facility was observed to be at a high level.
Documentation maintained by PCADC confirmed weekly fire and safety inspections had been
conducted. During the inspection however, it was determined that certain chemicals used in the
facility were not properly stored or inventoried (Deficiency EH&S-1). This is a repeat
deficiency. During the 2011 ODO Focus Review, ODO found the inventory for hazardous
materials located in the laundry area was not maintained.
During this CI, ODO observed the following areas to be deficient concerning the storage and
inventory of chemicals:
•

There were no running inventories for chemicals used in the detainee housing units.

•

The chemical DEPOT PAC SYSTEM, a germicidal detergent, was not accounted for on the
laundry room's running inventory. During the inspection, facility staff added the chemical to
the inventory.

•

In the custodial room, ODO found discrepancies in the amount of chemicals documented on
the running inventory and the amount actually on hand. Specifically, a random count showed
240 germicidal detergents were on hand, but the running inventory indicated 307 were
available. In addition, ODO determined inventories were inaccurate for heavy-duty cleaning
solvents and glass cleaners. A container ofECO LAB ORANGE FORCE 4 was not included
in the running inventory. Facility staff indicated inventories of chemicals in this area would
be reviewed and updated.

•

In the maintenance area, ODO observed the chemical PERMATEX on a work counter. The
running inventory showed the chemical was last taken out ofthe storage cabinet and used on
April21, 2011; however, its presence on the counter and the available amount reflected the
product had been used since that date. A container of LIQUID WRENCH SUPER had four
ounces available; however, the inventory showed ten ounces remained. ODO counted nine
Therma Pipe Bearing Grease tubes, though the inventory indicated five were on hand. One
tube of this flammable substance was found and moved from a non-fireproof cabinet to a fire
proof cabinet during the inspection, while the other eight tubes were already stored in a
fireproof cabinet. ODO also observed JASCO, TSP, a liquid concentrate solvent labeled
"Danger- May cause burns to eyes, skin irritant, harmful if swallowed." This chemical was
not recorded on an inventory sheet and was removed from the facility during the inspection.

Facility staff informed ODO, a comprehensive and thorough inspection of chemicals at PCADC
will be conducted to ensure inventory and control requirements are met.
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ODO observed 16 cases ofNEUTRA PAC 4, a floor finish, and PORTION PAC 314 MI STRIP
PAC, a floor finish remover, stored in the custodial room. The Custodial Officer stated he could
not produce Material Safety Data Sheets (MSDS) for these chemicals. In addition, no MSDS
was available for the chemical OATEY #5 Solder Paste, located in the maintenance area
(Deficiency EH&S-2).
In a custodial closet, ODO observed a carrying cart for brooms, rags, and cleaning supplies used
by inmate workers throughout the facility. An aerosol spray can of METAL-SHEEN, a
flammable chemical, was observed on the cart. The product was not included on any inventory,
and, despite clearly being labeled flammable, was not stored in a flammable liquids storage
cabinet. ODO observed an aerosol can of DUSTER PLUS on a cabinet in the HSA's office.
This item, also labeled flammable, was not included on any inventory and was not stored in a
cabinet designated for storing flammable liquids (Deficiency EH&S-3). ODO noted the aerosol
cans were removed from the facility during the inspection.
ODO reviewed the placement and containment of hazardous materials used in the laundry
department, and observed chemicals were secured behind a locked cage. However, four plastic
containers containing the chemicals were placed directly on the concrete floor without being
enclosed by four-inch sills (Deficiency EH&S-4). It is critical and important that hazardous
materials and chemicals are enclosed by four-inch sills or placed on four-inch depressed floors to
prevent the liquids from spreading in the event of a spill or leak.
ODO was provided with a memorandum from the Public Works Director/Town Engineer, dated
March 13, 2012, indicating the Town ofFlorence augments water characteristics with a
disinfecting agent (chlorine) to meet the Safe Drinking Water Act's National Primary Drinking
Water Regulations. The memorandum further states water supply responsibility terminates at the
meters serving the facility. As a result, documentation for the testing and certification of
drinking and wastewater inside PCADC, as required by the NDS, was not produced
(Deficiency EH&S-5).
The facility's emergency electrical power generator is tested by an outside company, GENTECH, on an annual basis rather than quarterly, as required by the NDS. Review of
documentation for bi-weekly tests conducted by facility staff showed the start and stop times are
not consistently recorded. Therefore, ODO could not verify or confirm if the tests lasted a
minimum of one hour, as required by the NDS (Deficiency EH&S-6).
PCADC has an eyewash station located in the medical department. The maintenance area, which
controls and stores most of the hazardous chemicals, does not have an eye hazard warning sign
posted in the area (Deficiency EH&S-7), or an eyewash station (Deficiency EH&S-8). The
maintenance area has an increased probability of injury, caused by the handling of hazardous
materials and chemicals.

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STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY EH&S-1
In accordance with the ICE NDS, Environmental Health and Safety, section (III)(A), the FOD
must ensure every area will maintain a running inventory of all hazardous (flammable, toxic, or
caustic) substances used and stored in that area. Inventory records will be maintained separately
for each substance, with entries for each logged on a separate card (or equivalent). That is, the
account keeping will not be chronological, but filed alphabetically, by substance (dates,
quantities, etc.)
DEFICIENCY EH&S-2
In accordance with the ICE NDS, Environmental Health and Safety, section (III)(B), the FOD
must ensure every area using hazardous substances will maintain a self-contained file ofthe
corresponding Material Safety Data Sheets (MSDSs). The MSDSs provide vital information on
individual hazardous substances, including instructions on safe handling, storage, and disposal,
prohibited interactions, etc. Staff and detainees must have ready and continuous access to the
MSDSs for the substances with which they are working while in the work area.
Because changes in MSDSs occur often and without broad notice, staff must review the latest
issuance from the manufacturers of the relevant substances, updating the MSDS files as
necessary.
The MSDS file in each area should include a list of all areas where hazardous substances are
stored, along with a plant diagram and legend. Staffwill provide a copy of this information and
all MSDSs contained in the file, forwarding updates upon receipt, to the Maintenance Supervisor
of designate.

DEFICIENCY EH&S-3
In accordance with the ICE NDS, Environmental Health and Safety, section (III)(F)(l), the FOD
must ensure any liquid or aerosol labeled "Flammable" or "Combustible" must be stored and
used as prescribed on the label, in accordance with the Federal Hazardous Substances Labeling
Act, to protect both life and property.
DEFICIENCY EH&S-4
In accordance with the ICE NDS, Environmental Health and Safety, section (III)(F)(3)(c), the
FOD must ensure every hazardous-material storage room will: Be constructed with either a fourinch sill or a four-inch depressed floor.
DEFICIENCY EH&S-5
In accordance with the ICE NDS, Environmental Health and Safety, section (III)(N), the FOD
must ensure a state laboratory will test samples of drinking and wastewater to ensure compliance
with applicable standards.

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DEFICIENCY EH&S-6
In accordance with the ICE NDS, Environmental Health and Safety, section (III)(O), the FOD
must ensure power generators will be tested at least every two weeks. Other emergency
equipment and systems will undergo quarterly testing, with follow-up repairs or replacement as
necessary.
The biweekly test of the emergency electrical generator will last one hour. During that time, the
oil, water, hoses and belts will be inspected for mechanical readiness to perform in an emergency
situation. The emergency generator will also receive quarterly testing and servicing from an
external generator-service company. Among other things, the technicians will check starting
battery voltage, generator voltage and amperage output.

DEFICIENCY EH&S-7
In accordance with the ICE NOS, Environmental Health and Safety, section (III)(T)(l), the FOD
must ensure protective eye and face equipment will be required where there is a reasonable
probability of injury that can be prevented by such equipment. These areas of the facility will be
conspicuously marked with eye hazard warning signs.

DEFICIENCY EH&S-8
In accordance with the ICE NDS, Environmental Health and Safety, section (III)(T)(2), the FOD
must ensure OSHA-approved eyewash stations will be installed in designated areas throughout
the facility. All employees and detainees in those areas will be instructed in their use.

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Pinal County Adult Detention Center
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TOOL CONTROL (TC)
ODO reviewed the Tool Control NDS at PCADC to determine if tools are properly classified,
identified, inventoried, stored and issued. ODO reviewed policies, interviewed staff, and
inspected tools, inventories, and all areas where tools are stored and maintained.
ODO verified staff is trained in the use and control of tools. Procedures for the survey and
destruction ofbroken or worn tools are in place. A designated staff member is responsible for
the facility's tool control system. Tools are classified either as Class A or Class B, with
restricted tools identified and described in the PCADC Tool Control Policy. According to the
PCADC Tool Control Policy, tools classified as Class A pose a great risk to the security and
orderly running of the facility, and require stringent supervision. In contrast, tools classified as
Class B do not pose a great risk and may be stored and issued with less stringent provisions.
During the inspection, ODO found two large, undocumented items. The first item was a scissor
lift (man lift) parked in front ofthe maintenance building. The second item was a fork lift found
in the same area. Both of these items were located inside the facility on the loading dock
between the maintenance and food service areas. The Tool Room Officer indicated both ofthese
items would have been classified as Class A tools. Neither of the lifts were marked
(Deficiency TC-1), stored (Deficiency TC-2), or inventoried (Deficiency TC-3) to ensure
accountability. Both ofthese items could be used in an escape attempt or in a manner that could
cause harm or injury to staff or detainees. Proper control and accountability ofthese items is
critical. During the inspection, the Tool Room Officer took immediate action to correct these
deficiencies by marking both items and including them on the tool inventory.

STANDARD/POLICY REQUIRMENTS FOR DEFICIENT FINDINGS
DEFICIENCY TC-1
In accordance with the ICE NDS, Tool Control, section (III)(D), the FOD must ensure the OIC will
establish written procedures for marking tools, making them readily identifiable.
DEFICIENCY TC-2
In accordance with the ICE NDS, Tool Control, section (III)(E), the FOD must ensure the OIC
will establish written procedures for storing tools. The tool-storage system will ensure
accountability. Commonly used, mounted tools shall be stored so that a tool's disappearance
would not escape attention.
DEFICIENCY TC-3
In accordance with the ICE NDS, Tool Control, section (III)(F), the FOD must ensure the OIC
will schedule, and establish procedures for, the regular inventorying of all tools. Facilities shall
use AMIS bar code labels as necessary.

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Pinal County Adult Detention Center
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USE OF FORCE (UOF)
ODO reviewed the Use of Force NDS at PCADC to determine if necessary use of force is used
only after all reasonable efforts have been exhausted to gain control of a subject, while protecting
and ensuring the safety of detainees, staff, and others, preventing serious property damage, and
ensuring the security and orderly operation ofthe facility. ODO interviewed staff and reviewed
local policies, training records, and use of force documentation.
PCADC policy differentiates between situations where immediate or calculated use of force is
authorized. According to the ICE NDS, an immediate use of force situation is created when a
detainee's behavior constitutes a serious and immediate threat to self, staff, another detainee,
property, or the security and orderly operation ofthe facility. In that situation, staff may respond
without a supervisor's direction or presence. Calculated use of force is appropriate when the
detainee is in a cell or other area with a securable door or grill, even ifthe detainee is verbalizing
threats or brandishing a weapon, provided staff sees no immediate danger of the detainee causing
harm. The calculated use of force affords staff time to strategize, resolving situations in the least
confrontational manner.
The facility has a restraint chair, but does not use four-point restraints. Hand-held cameras are
available at (b)(7)e officer stations for documenting use of force incidents. Cameras are
inventoried and checked at the beginning of each shift. These checks are documented on an
inventory sheet and in the officer's permanent logbook. Both documents are located in the
control center. Oleoresin Capsicum (OC) spray is used by PCADC staff trained in its
deployment. Facility policy and training lesson plans expressly prohibit the use of electromuscular disruption devices on ICE detainees.
Since March 2011, there has been one incident involving a calculated use of force and 17
incidents involving immediate uses of force. Documentation for 16 ofthe 17 immediate use of
force incidents had been forwarded to the PCSO Internal Affairs unit for investigation; therefore,
only one immediate use of force incident could be reviewed by ODO during the inspection.
ODO viewed the video recording from a fixed security camera showing an immediate use of
force incident that began when a detainee refused to obey an order from PCADC staff. In the
video, detainees dispersed when directed by staff. Although the detainee remained noncompliant with direction, ODO observed the detainee made no aggressive actions to necessitate
an immediate use of force. The PCADC officer deployed OC spray despite ample time and
opportunity to avoid confrontation, and to contact a supervisor for possible activation of the
calculated use of force team (Deficiency UOF-1). The incident was reported to the Joint Intake
Center, and ERO staff generated a Significant Incident Report.
Review of the video recording involving the calculated use of force incident showed the detainee
talking to himself and laughing uncontrollably. PCADC staff stated the detainee was asthmatic,
so use of OC spray was not an option. The detainee had smeared feces on his naked body and a
cup ofurine was within reach. Supervisory staff requested a calculated use of force team to
restrain and move the detainee from his cell for transport to a hospital. Use of force team
members wore white paper coveralls, rubber gloves and surgical masks; however, they did not
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wear required protective gear, such as a helmet with a face shield, a protective vest, or forearm
guards (Deficiency UOF-2). All calculated use of force incidents present the risk of harm to
staff that is best mitigated by wearing appropriate protective gear. Paper coveralls, rubber
gloves, and surgical masks would not have provided adequate physical protection for the officers
involved ifthe detainee had become combative.

STANDARD/POLICY REQUIREMENT FOR DEFICIENT FINDINGS
DEFICIENCY UOF-1
In accordance with the ICE NDS, Use of Force, section (III)(A)(2)(a), the FOD must ensure
calculated use of force is appropriate when the detainee is in a cell or other area with a securable
door or grill, even if the detainee is verbalizing threats or brandishing a weapon, provided staff
sees no immediate danger of the detainee causing harm. The calculated use of force affords staff
time to strategize, resolving situations in the least confrontational manner.
DEFICIENCY UOF-2
In accordance with the ICE NDS, Use afForce, section (III)(A)(4)(a), the FOD must ensure,
when a detainee must be forcibly moved and/or restrained during a calculated use of force, the
use-of-force team technique shall apply. The team technique usually involves
(b)(7)e
trained staff members clothed in protective gear, including helmet with face shield, jumpsuit,
flack-vest or knife-resistant vest, gloves, and forearm protectors. Team members enter the
detainee's area together, with coordinated responsibility for achieving immediate control of the
detainee.

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Pinal County Adult Detention Center
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