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
Atlanta Field Office
Atlanta City Detention Center
Atlanta, Georgia

March 27- 29, 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
ATLANTA CITY DETENTION CENTER
ATLANTA FIELD OFFICE
TABLE OF CONTENTS
EXECUTIVE SUMMARY ............................................................................................... 1
INSPECTION PROCESS
Report Organization ................................................................................................. 4
Inspection Team Members .......................................................................................4
OPERATIONAL ENVIRONMENT
Internal Relations ..................................................................................................... 5
Detainee Relations ................................................................................................... 5
ICE NATIONAL DETENTION STANDARDS
Detention Standards Reviewed ................................................................................ 6
Admission and Release ............................................................................................ 7
Detainee Classification System ................................................................................ 9
Detainee Grievance Procedures ............................................................................ 10
Detainee Transfer ................................................................................................... 13
Food Service .......................................................................................................... 16
Suicide Prevention and Intervention ...................................................................... 18
Use ofForce ..........................................................................................................20
Visitation ............................................................................................................... 21

EXECUTIVE SUMMARY
The Office of Professional Responsibility (OPR), Office ofDetention Oversight (ODO)
conducted a Compliance Inspection (CI) of the Atlanta City Detention Center (ACDC) in
Atlanta, Georgia, from March 27-29, 2012. ACDC is owned and operated by the City of
Atlanta. The facility opened in November 1995. In 2001, ACDC was remodeled and 300 beds
were added. ACDC is contracted to house Federal prisoners under an Intergovernmental Service
Agreement (IGSA) with the U.S. Marshals Service. U.S. Immigration and Customs
Enforcement (ICE), Office of Enforcement and Removal Operations (ERO), uses ACDC to
house male and female detainees of all security classification levels (Level I- lowest threat;
Level II- medium threat; Level III- highest threat) for periods in excess of 72 hours. ACDC
currently reserves two housing units to accommodate males and two housing units to
accommodate females. The average daily detainee population is 61. The average length of stay
for ICE detainees at the facility is 24 days. ACDC has a total bed capacity of 1,314, with 250
beds available for ICE detainees. At the time of the inspection, ACDC housed a total of 105
detainees, including 100 males (19 Level I; 59 Level II; 22 Level III), and five female detainees
(three Level I; two Level II). ACDC provides medical care, which includes a contracted
physician. Trinity Service Group provides food service. In March 2010, ACDC received
accreditation from the American Correctional Association (ACA).
The ICE, ERO, Field Office Director in Atlanta, Georgia (FOD/Atlanta) is responsible for
ensuring facility compliance with ICE policies and the ICE National Detention Standards (NOS).
An Assistant Field Office Director (AFOD) located at the FOD/Atlanta has direct oversight of
ACDC. ICE does not have staff permanently located on-site at ACDC; however, the
FOD/Atlanta is located two city blocks away from ACDC. A Supervisory Detention and
Deportation Officer (SDDO), and a Deportation Officer (DO) from the FOD/Atlanta conduct
scheduled and unscheduled detainee liaison visits at the facility to address case management and
detention issues. These visits are documented in housing unit logbooks and on a Facility Liaison
Visit Checklist to verify proper oversight by the FOD/Atlanta. ODO confirmed detainee
requests and concerns are addressed in a timely manner. There is no Detention Service Manager
(DSM) assigned to ACDC.
ACDC is managed by a Corrections Chief, a Corrections Assistant Chief,(b)(7)eMajors, (b)(7)e
Captains, and(b)(7)eLieutenants. The total number of non-ICE staff employed at ACDC is(b)(7)e
Currently, there are(b)(7)e
vacant correctional officer positions, and(b)(7)evacant civilian position.
The Detention Facilities Inspection Group (DFIG), predecessor to ODO, conducted a Quality
Assurance Review (QAR) at ACDC in November 2008. The DFIG reviewed a total of22
standards and identified 41 deficiencies.
In August 2010, ODO conducted a Follow-up Inspection at ACDC. ODO found 13 repeated
deficiencies in eight NDS.
In June 2011, the ERO Detention Standards Compliance Unit contractor, MGT of America, Inc.,
conducted an annual review ofthe ICE NOS at ACDC. The facility received an overall rating of
"Acceptable," and was found to be in compliance with all 38 standards reviewed.
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During. this Cl, ODO reviewed a total of20 NDS. Twelve standards were found to be compliant
with the NDS, while 25 deficiencies were found in the following eight standards: Admission and
Release (4 deficiencies), Detainee Classification System (1), Detainee Grievance Procedures (5),
Detainee Transfer (5), Food Service (5), Suicide Prevention and Intervention (2), Use of Force
(2), and Visitation (1). No repeat deficiencies were identified during this inspection.
This report includes descriptions of all the deficiencies and refers to the specific, relevant
sections ofthe ICE NDS. The report will be provided to ERO to assist in the development of
corrective actions to resolve the 25 identified deficiencies.
Overall, ODO found ACDC in compliance with the areas and standards inspected. Sixteen of
the 25 deficiencies identified were administrative in nature (paperwork, logs, and posters) rather
than shortcomings with respect to practices and procedures. However, three deficiencies were
significant to the health and well being of ICE detainees. The mental health provider stated she
had not trained any of the correctional supervisors in suicide prevention and intervention within
the year preceding the inspection. Prior to completion of the inspection, the Deputy Chief of
Security submitted a training order requiring all correctional supervisors to receive suicide
prevention and intervention training.
ODO confirmed detainees were not provided the opportunity to shower during intake processing
before entering their assigned housing units. ACDC management stated a water usage restriction
in Atlanta had resulted in the rationing of showers throughout the facility.
ODO verified that ACDC does not offer a common fare program to detainees. Prepackaged and
precooked hot entrees certified as kosher are not available for detainees participating in the
religious diet program. Instead, religious meals consist of staple foods from supplies used for the
main menu. The packages for bread and salad provided on religious diet trays are not labeled
"Parve," which confirms compliance with religious dietary laws. Meals for the religious diet
program are prepared with the same appliances, equipment, and utensils used for cooking meals
for the general population.
The grievance system at ACDC provides for both formal and informal grievances. Facility
officials encourage detainees to resolve their grievances at the lowest level possible; however,
detainees are free to bypass the informal grievance process and proceed directly to filing a
formal grievance. The facility Grievance Officer stated that medical grievances are addressed
directly by the facility medical staff. ODO confirmed, from December 26, 2011, to the date of
the CI, ACDC officials had adjudicated ten formal grievances. The facility maintains a detailed
electronic logbook to track all formal grievances. ODO identified this as a best practice. ODO
verified ACDC officials processed all but two of the grievances in compliance with the NDS.
The two grievances identified contained allegations of officer misconduct. Facility management
reported the two detainee grievances to their Professional Standards Unit, but did not report the
allegations to the FOD/Atlanta or the ICE Joint Intake Center (JIC) for further review and
investigation. This was cited as a deficiency and facility management was advised to
immediately begin reporting all allegations of officer misconduct through the proper channels at
ICE. ODO reported the two misconduct allegations to the JIC and advised facility management

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to immediately implement a procedure for proper reporting of officer misconduct allegations to
ICE. ODO review ofthe grievance appeals process confirmed compliance with the NDS.
ODO confirmed, from January 27, 2012, to the date ofthe CI, ACDC had adjudicated 555
informal grievances. ODO found 252 (45%) ofthe 555 adjudicated informal grievances did not
have the dates of resolution provided in the logbook. ODO randomly selected 20 ofthe 252
informal grievances and reviewed the corresponding grievance cases. All 20 grievances were
resolved within 72 hours, which is in compliance with the NDS.
The disciplinary system at ACDC includes graduated severity scales of prohibited acts and
disciplinary consequences, and procedures for appealing findings of guilt. ACDC has a process
to adjudicate low-level infractions through the use of informal resolution, which includes verbal
warnings or written reprimands. Officers may place detainees on time-out restriction within their
assigned cell for up to eight hours. Time-out cell restrictions are cleared through the appropriate
floor supervisor and documented in the unit logbook. ODO reviewed the disciplinary files of
three ICE detainees who were determined to be in violation of facility rules by the Disciplinary
Hearing Board at ACDC. The Disciplinary Hearing Board consists of two security officer
supervisors. The disciplinary files reviewed by ODO contained all appropriate due process
notifications in accordance with the standard. The Disciplinary Hearing Officer maintains a list
of all disciplinary hearings dating back to 2006. The list separates prisoners by custody status
(ICE detainee, local inmate, etc.), expediting the review ofiCE detainee disciplinary cases.
ODO found the medical care at ACDC to be well managed. ACDC has a full service medical
unit to address detainee health care. The clinic is sufficiently staffed to meet detainee health
needs. ODO verified intake screenings, physical examinations, medications, treatments for
special and chronic needs, and follow-up care are provided in accordance with the standard.
Detainee sick call requests are reviewed and triaged in a timely manner. ODO also verified
medical transfer summaries were included in all 30 of the detainee transfer records reviewed
during the Cl. The Director of Nursing stated there have been no hunger strikes at the facility
during the year preceding the inspection. ACDC policies address all components of the Medical
Care standard, and all personnel have received the required training.
ODO confirmed ICE detainees have access to television, outdoor recreation, mail, and
commissary privileges. ACDC offers religious services, and vocational and educational
programs. Detainees have access to the law library and legal materials Monday through Friday
from 9:00am to 2:30 pm. The library operating schedule is posted in each housing unit, and the
latest version ofLexisNexis software is on law library computers. Notary public services and
certified mail are available to all detainees.
Public visitation is available Wednesdays and Sundays according to the first letter of the last
name of each detainee. A visitation sign-up sheet is posted in all housing units on Tuesdays and
Saturdays. Detainees are required to place the name of each prospective visitor on the sign-up
sheet in an available time slot. Detainees are responsible for notifying their visitors of the
reserved time. Visits are limited to 20 minutes. Separate logs are maintained for general visitors
and legal representatives, supplemented by an automated system offering efficient recording and
retrieval of visitor information. ODO identifies this as a best practice.

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INSPECTION PROCESS
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 ACDC. In
addition, ODO may focus its inspection based on detention management information provided
by ERO HQ and ERO field offices, and to issues of high priority or interest to ICE executive
management. Inspection objectives are to evaluate the welfare, safety, and living conditions of
detainees. ·
ODO reviewed the processes employed at ACDC to determine compliance with current policies
and detention standards. Prior to and during 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
inspection-related information from ERO HQ staff to best prepare for the site visit at ACDC.

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 of two categories: deficiencies and areas of concern.
OPR defines a deficiency as a violation of written policy that can be specifically linked to the
NDS, 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

Management and Program Analyst (Team Leader) ODO, Headquarters
Detention and Deportation Officer
ODO, Headquarters
Detention and Deportation Officer
ODO, Headquarters
Contract Inspector
Creative Correction
Contract Inspector
Creative Correction
Contract Inspector
Creative Correction
Contract Inspector
Creative Correction

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OPERATIONAL ENVIRONMENT
INTERNAL RELATIONS
ODO interviewed supervisory ICE and ACDC staff, to include the Corrections Chief,
Corrections Assistant Chief, the FOD, and the AFOD. ODO also interviewed other ICE and
ACDC personnel, including an SDDO, a DO, and an ACDC Correctional Officer (CO). All
ERO and ACDC staff was cooperative and provided assistance throughout the inspection
process.
ICE management stated they have the resources necessary to carry out their duties and
responsibilities. Both ACDC and ICE staff stated morale among ACDC and ICE staff is high,
and the working relationship is mutually beneficial.

DETAINEE RELATIONS
ODO interviewed 12 (seven males and five females) randomly-selected detainees. All detainees
stated they were issued a detainee handbook, blankets, and hygiene supplies upon arrival;
however, they were only allowed to shower after they were assigned and placed in a housing
unit. A DO visits detainees in the ACDC housing units two times a week to address detainee
concerns and to respond to detainee written requests within 72 hours via in-house mail.
Schedules for these visits are posted conspicuously in the housing areas. All twelve (1 00%) of
the detainees interviewed reported they have contact with facility staff and all knew the name of
their DO.
One detainee stated he was mistreated by an ACDC officer. ODO reviewed the detainee's
detention file and interviewed facility staff. No information was obtained during interviews or
examination of the detention file to substantiate the allegation.
During interviews, three detainees (25%) stated the food was unappetizing; nine (75%) stated it
was bland. An ODO inspector observed lunch preparation and then sampled the food. The ODO
inspector stated there was nothing unusual regarding the food preparation, and though the food
may have lacked flavor, it was of good quality. Three detainees (25%) stated they had submitted
requests to the DO in March 2012 for special common-fare and vegetarian diets; however, no
documentation could be found to substantiate their claims. ODO directed the detainees to page
24 of the ACDC detainee handbook, which requires the detainee to submit a request to the
Chaplain stating the reason(s) for a religious diet. ODO confirmed food service provides special
meals to detainees whose requests are approved and authorized; however, religious diet foods are
currently prepared on equipment used for making meals for the general population. All
detainees (100%) stated medical care at ACDC was of good quality.

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ICE NATIONAL DETENTION STANDARDS
ODO reviewed a total of 20 NDS and found ACDC fully compliant with the following 12
standards:
Access to Legal Material
Detainee Handbook
Disciplinary Policy
Environmental Health and Safety
Hold Rooms in Detention Facilities
Medical Care
Recreation
Religious Practices
Special Management Unit (Administrative Segregation)
Special Management Unit (Disciplinary Segregation)
Telephone Access
Terminal Illness, Advance Directives and Death
As these 12 standards were compliant at the time of the review, a synopsis for these areas was
not prepared for this report.
ODO found deficiencies in the following eight standards:
Admission and Release
Detainee Classification System
Detainee Grievance Procedures
Detainee Transfer
Food Service
Suicide Prevention and Intervention
Use of Force
Visitation
Findings for each of these standards are presented in the remainder ofthis report.

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ADMISSION AND RELEASE (AR)
ODO reviewed the Admission and Release NDS at ACDC to determine if procedures are in
placed to protect the health, safety, security and welfare of each person during the admission and
release process, in accordance with the ICE NDS. ODO reviewed policies, procedures, and
detention files, observed admission and intake procedures, and interviewed staff and detainees.
ACDC intake and release processing officers complete questionnaires and screening interviews
for each detainee upon arrival. Detailed medical screenings are conducted by the medical care
unit. Copies of both the national and local detainee handbooks are provided in English and
Spanish. Interpreter services are available for translation. ACDC does not use an orientation
video as part ofthe intake process (Deficiency AR-1). The Admission and Release NDS
requires the facility orientation process be supported by a video to provide information about
facility programs and services. ODO recommends ERO and ACDC staff engage in a
collaborative effort to produce a site-specific orientation video detailing information about the
facility.
During interviews with staff and detainees, ODO confirmed detainees are not provided an
opportunity to shower during intake processing (Deficiency AR-2). The NDS requires facilities
to maintain a standard of personal hygiene that prevents the spread of communicable diseases
and other unhealthy conditions within detainee housing units. Every detainee must shower
before entering his or her assigned unit. Lack of shower access during intake processing was
discussed during the review and at the closeout briefing. ACDC management stated a water use
restriction in Atlanta had resulted in the rationing of showers throughout the facility. ODO
advised that the water restriction should not preclude detainees from showering during intake
processing.
The NDS requires that detainee identity documents be inventoried and provided to ICE. ODO
reviewed the ACDC admission policy and interviewed intake processing officers to determine
whether the procedures for handling identity documents are followed. ACDC staff stated
detainee personal property is not maintained at ACDC, and property found during intake
processing is not accepted for storage. Detainee property is maintained at the POD/Atlanta.
ODO verified ACDC has no procedure in place to inventory identity documents, such as
passports or birth certificates, encountered during intake processing (Deficiency AR-3).
A review of 17 active detention files confirmed not all of the required forms and documents
associated or generated during the admission process are maintained in those files. ERO staff
stated that required documents for intake processing and classification do not accompany
detainees to ACDC. In some cases, Form I-216 (Record of Persons and Property Transferred) is
provided to ACDC rather than Form I-203 (Order to Detain or Release Alien). ODO verified
that copies of Form I-203 are maintained in separate classification folders (Deficiency AR-4).
ODO recommends ERO complete the proper forms required for commitment of detainees, and
collaborate with ACDC staff to ensure forms generated during intake processing and custody are
maintained in each detention file. Proper handling of a correctly executed Form I-203 is critical
to the detention process, because Form 1-203 is the document that authorizes detention within a
designated facility.
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•

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY AR-1
In accordance with the ICE NDS, Admission and Release, section (III)(A)(l), the FOD must
ensure the orientation process supported by a video (INS) and handbook shall inform new
arrivals about facility operations, programs, and services. Subjects covered will include
prohibited activities and unacceptable [sic] and the associated sanctions (see the "Disciplinary
Policy" Standard).
DEFICIENCY AR-2
In accordance with the Change Notice Admission and Release -National Detention Standard
Strip Strip-Search Policy, dated October 15,2007, the FOD must ensure, effective immediately,
all facilities housing Immigration and Customs Enforcement (ICE) detainees shall permit
detainees to change clothing and shower in a private room without being visually observed by a
staff member, unless there is reasonable suspicion that the individual possesses contraband. A
staff member of the same gender will be present immediately outside the room when the detainee
changes and showers, with the door opened to hear what transpires inside. This includes Service
Processing Center (SPCs), Contract Detention Facilities (CDFs) and those locations having
Intergovernmental Service Agreements (IGSAs) with ICE.
DEFICIENCY AR-3
In accordance with the ICE NDS, Admission and Release, section (III)(E), the FOD must ensure
identity documents, such as passports, birth certificates, etc., will be inventoried, then given to a
deportation officer/INS for placement in the detainee's A-file.
DEFICIENCY AR-4
In accordance with the ICE NDS, Admission and Release, section (III)(H), the FOD must ensure
an order to detain or release (Form I-203 or I-203a) bearing the appropriate official signature
shall accompany the newly arriving detainee. IGSA facilities shall forward the detainee's A-file
or temporary work file to the INS office with jurisdiction. Staff shall prepare specific documents
in conjunction with each new arrival to facilitate timely processing, classification, medical
screening, accounting of personal effects, and reporting of statistical data.

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DETAINEE CLASSIFICATION SYSTEM (DCS)
ODO reviewed the Detainee Classification System NDS at ACDC to determine ifthere is a
requirement for a formal classification process for managing and separating detainees based on
verifiable and documented data, in accordance with the ICE NDS. ODO reviewed facility
policies, detention files, the detainee handbook, and interviewed ERO and facility staff.
ACDC staff stated tha (b)(7)e officers are assigned classification duties, and the (b)(7)eofficers have
received both formal and on-the-job training. ICE classifies all detainees prior to their arrival at
ACDC, and the facility adheres to the previously assigned classification levels when determining
detainee housing unit assignments. ICE detainees are placed in housing units with detainees
having comparable criminal records and disciplinary histories. A color-coded uniform and
wristband system is used to visually identify each classification level.
ODO reviewed 15 randomly-selected detention files and found Form I-203 or I-203a (Order to
Detain or Release), Form I-213 (Record of Deportable/Inadmissible Alien), and both initial and
re-assessment worksheets were not contained in any of the 15 files (Deficiency DCS-1). ODO
found copies ofthese forms in separate classification folders. ODO recommends ERO
collaborate with ACDC staff to ensure forms generated during intake processing and custody are
maintained in each detention file.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY DCS-1
In accordance with the ICE NDS, Detainee Classification System, section (III)(B), the FOD must
ensure the officer [assigned to intake/processing] will place all original paperwork relating to the
detainee's assessment and classification in his/her A-file (right side), with a copy placed in the
detention file.

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DETAINEE GRIEVANCE PROCEDURES (DGP)
ODO reviewed the Detainee Grievance Procedures NDS at ACDC to determine if a process to
submit formal or emergency grievances exists, and responses are provided in a timely manner,
without fear of reprisal. In addition, the review was conducted to determine if detainees have an
opportunity to appeal responses, and if accurate records are maintained, in accordance with the
ICE NDS. ODO interviewed staff, and reviewed logbook, forms, detainee grievance policy and
procedures, and the detainee handbook.
ACDC has an informal grievance system in place allowing detainees to have grievances
addressed at the lowest level possible in the most efficient and timely manner. A designated
Informal Grievance Officer is responsible for addressing all informal detainee complaints.
Detainee grievance forms are located inside each housing unit. Detainees can also request a
form from the Corrections Officer assigned to each housing unit. Although it is not required by
the 2000 NDS, facility management requires detainees to file an inmate grievance form for all
informal grievances. The Informal Grievance Officer is responsible for the collection of
grievance forms. Detainees who have submitted grievance forms have the opportunity to discuss
grievances with the Informal Grievance Officer. Interpretive services are available when
necessary. Detainees are able to bypass or terminate the informal grievance system and proceed
directly to the formal grievance process at any time.
The facility maintains an electronic informal grievance logbook that has four columns: (1) full
name of the detainee, (2) complaint or oral grievance, (3) date received by ACDC, and (4) date
of resolution. Some dates within the logbook were missing, and it could not be determined when
certain informal grievances were resolved. The logbook did not confirm all grievance outcomes,
such as whether the grievance was resolved, not resolved, withdrawn, or appealed. Some
resolutions were provided in the complaint or oral grievance column, but not all grievances had
resolutions listed. A report of the results is not placed in the detention file after an informal
grievance is heard by the IGO (Deficiency DGP-1).
ODO reviewed the ACDC detainee handbook and facility written policy pertaining to detainee
grievance procedures. ODO confirmed ACDC does not have procedures for identifying and
handling emergency grievances (Deficiency DGP-2). ODO recommends the facility implement
policy and procedures for identifying and handling an emergency grievance. Written procedures
ensure facility personnel and detainees are aware of the steps necessary to quickly respond and
resolve an emergency grievance. An emergency grievance relates to an immediate threat to an
ICE detainee's safety or welfare. Once the receiving facility staff is approached by a detainee
and determines that he/she is in fact raising an issue requiring urgent attention, emergency
grievance procedures will apply.
The facility has a procedure in place allowing detainees to submit formal, written grievances.
The facility maintains a secure grievance box in every housing area where detainees can deposit
completed grievance forms. There are procedures in place to address illiteracy, disability, or
non-English speakers who wish to file a formal grievance. Assistance is available from ACDC
correction officers. The facility maintains a detailed electronic logbook to track all formal
grievances. ODO identifies this as a best practice. The Formal Grievance Officer stated the
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facility does not maintain copies of completed formal grievances or appeals in detention files for
the three year minimum required by the NDS (Deficiency DGP-3).
ODO reviewed ten completed formal grievances from the three months preceding the inspection
and found two grievances contained allegations of officer misconduct. ODO verified the two
identified allegations of officer misconduct had been forwarded to the ACDC Professional
Standards Unit; however, ACDC management had not reported the allegations to ERO or the JIC
for further review and investigation (Deficiency DGP-4). ODO reported the two misconduct
allegations to the JIC and advised facility management to immediately implement a procedure
for proper reporting of officer misconduct allegations to ICE. ODO also recommended ERO
review all facility grievance logs to identify and report all grievances alleging officer misconduct
to the JIC.
The facility has a procedure in place to appeal a formal grievance to the next level of authority if
a detainee does not agree with an initial decision. According to the local detainee handbook,
appeals are heard by the Facility Commander or a designee. Ofthe ten completed formal
grievances reviewed by ODO, one had been appealed to the Facility Commander, and the appeal
procedures had functioned according to ACDC policy. However, the facility detainee handbook
does not provide the procedures for detainees to appeal facility grievance decisions to ICE
management (Deficiency DGP-5).
Facility policy and the detainee handbook notify detainees that facility staff will not harass,
discipline, punish, or otherwise retaliate against any detainee filing a grievance. The notice also
informs detainees ofthe consequences of establishing a pattern of filing nuisance complaints or
otherwise abusing the grievance system.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY DGP-1
In accordance with the ICE NDS, Detainee Grievance Procedures, section (III)(A)(!), the FOD
must ensure, if an oral grievance is resolved to the detainee's satisfaction at any level of review,
the staff member need not provide the detainee written confirmation of the outcome, however the
staff member will document the results for the record and place his/her report in the detainee's
detention file.
DEFICIENCY DGP-2
In accordance with the ICE NDS, Detainee Grievance Procedures, section (III)(B), the FOD
must ensure each facility shall implement procedures for identifying and handling an emergency
grievance. An emergency grievance involves an immediate threat to a detainee's safety or
welfare. Once the receiving staff member approached by a detainee determines that he/she is in
fact raising an issue requiring urgent attention, emergency grievance procedures will apply.
DEFICIENCY DGP-3
In accordance with the ICE NDS, Detainee Grievance Procedures, section (III)(E), the FOD must
ensure a copy of the grievance will remain in the detainee's detention file for at least three years.
The facility will maintain that record for a minimum of three years and subsequently, until the
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detainee leaves [ICE] custody.

DEFICIENCY DGP-4
In accordance with the ICE NDS, Detainee Grievance Procedures, section (III)(P), the POD must
ensure staff must forward all detainee grievances containing allegations of officer misconduct to
a supervisor or higher-level official in the chain of command. CDPs and IGSA facilities must
forward detainee grievances alleging officer misconduct to [ICE]. [ICE] wiii investigate every
allegation of officer misconduct.
DEFICIENCY DGP-5
In accordance with the ICE NDS, Detainee Grievance Procedures, section (III)(G)(4), the POD
must ensure the facility shall provide each detainee, upon admittance, a copy ofthe detainee
handbook or equivalent. The grievance section of the detainee handbook will provide notice of
the following:
4. The procedures for contacting the [ICE] to appeal the decision of the OIC of a CDP or an
IGSA facility.

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DETAINEE TRANSFER (DT)
ODO reviewed the Detainee Transfer NDS at ACDC to determine if the Detainee Transfer NDS
procedures and notification requirements are followed when ERO transfers a detainee. ODO
also reviewed ICE Policy 11022.1, Detainee Transfers, to determine ifERO staffmakes all
notifications and provides all documents required by the policy. ODO reviewed procedures,
detention files, and interviewed ICE and facility staff.
According to ERO staff, transfers are made within the POD/Atlanta area of responsibility
(AOR), and mainly between ACDC and the Irwin County Detention Center. Transfers are for
operational purposes and are not retaliatory against detainees. Although there are no transfers of
detainees outside of the POD/Atlanta AOR, copies ofiCE Policy 11022.1 were provided to ERO
staff. ODO verified the medical transfer summary sheets (USM 553) are completed properly and
accompany detainees during transfer.
According to ERO staff, ICE is responsible for initiating and processing detainee transfers. If an
attorney-client relationship has been established, a Form G-28 (Notice of Appearance as
Attorney or Accredited Representative) is retained in the A-file; ERO is required to
communicate with the attorney of record and provide notice of any transfers. ODO found, when
legal counsel represents a detainee and the Form G-28 has been filed, ERO does not document
whether the attorney has been notified of the transfer (Deficiency DT -1). Notification of the
attorney of record is required to be in writing, recorded in the detainee's A-File, and documented
in ENFORCE. ODO discussed the significance of proper notification with ERO staff. Proper
notification allows the attorney of record to maintain contact with a client during immigration
proceedings.
ODO interviewed ERO and facility staff regarding transfer notification procedures to determine
whether appropriate notifications are provided to detainees based on the prevailing security
concerns. ACDC staff stated they are unaware ofthe notification procedures and the paperwork
required for transfers. ERO staff stated detainees are not provided transfer notifications; a
review of detention files confirmed copies of notifications are not maintained in each detainee's
detention file (Deficiency DT-2). The NDS requires each transferring detainee to be notified
and served a transfer notification, so long as security requirements permit doing so. Providing,
in writing, the name, address, and telephone number of the facility the detainee is being
transferred to ensures detainees have essential information about their detention, and allows the
detainee to notify family members once the detainee reaches the new facility.
In preparation for transfer, the sending field office is required to review detainee records and
complete required transfer paperwork. A transfer checklist (checklist) must annotate the
processes and procedures to be completed, and the copies of documents required to accompany
detainees to the receiving facility. ACDC staff was unaware ofthe checklist, and ERO staff
stated checklists are not placed in the detainee's A-file or corresponding work folder (Deficiency
DT-3).
ERO is responsible for initiating and preparing the required paperwork and transfer of records.
According to ERO staff, transfer paperwork, including Form 1-203, and Form 1-216, Record of
Person and Property Transfer Manifest, are completed and provided to the receiving facility for
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transfers within the AOR. However, in some cases, when the A-files are with the immigration
court, the documents are not matched up with the A-files. Since there are rio corresponding
work-folders, the transfer paperwork is not maintained in the corresponding work-folders
(Deficiency DT -4).
The standard requires a Form G-391, Official Detail, to be completed and furnished to authorize
movement/removal of detainees from the holding facility; however, ERO and ACDC staff stated
Form G-39Is are not used to authorize removal of a detainee (Deficiency DT-5). During the
review and at the close-out briefing, ODO discussed the importance of having properly executed
paperwork. ODO recommends the facility receive training from ERO on the records required for
detainees transferred in or out of ACDC.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY DT-1
In accordance with the ICE NDS, Detainee Transfer, section (III)(A){l ), the FOD must ensure,
when legal counsel represents a detainee, and a G-28 has been filed, ICE shall notify the
detainee's representative of record that the detainee is being transferred from one detention
location to another. This notification shall be recorded in the detainee's A-file, if available, or
work file and the notification shall be notated in the comments screen in DACS. For security
purposes, the attorney shall not be notified of the transfer until the detainee is en route to the new
detention location. The notification will include the reason for the transfer and the name,
address, and telephone number ofthe receiving facility. In the interest of safety and security, the
notification will not include specific travel details, (e.g., the day oftravel, mode oftravel, etc).
Where special security concerns exist (e.g. the detainee has a serious criminal history) ICE has
discretion to delay the notification, but only for a period oftime that is justified by security
concerns.
DEFICIENCY DT-2
In accordance with the ICE NDS, Detainee Transfer, section (III)(A)(3), the FOD must ensure,
for security purposes, specific plans and time schedules shall never be discussed with the
detainee involved. The detainee shall not be notified of the transfer until immediately prior to
leaving the facility. At that time, the detainee shall be notified that he/she is being moved to a
new facility within the United States and not being deported. Reasonable efforts should be made
to make this communication in a language the detainee understands. Following transfer
notification, the detainee shall normally not be permitted to make or receive any telephone calls
or have contact with any detainee in the general population until the detainee reaches the
destination facility. In certain cases, the detainee may be housed in Administrative Segregation
24 hours prior to being transferred. (Note: ifthe detainee is under eighteen years of age, special
notification procedures may apply. Please check with the juvenile coordinator for your field
office.)
At the time ofthe transfer, ICE will provide the detainee, in writing, with the name, address and
telephone number of the facility he/she is being transferred to. The attached Detainee Transfer
Notification Sheet shall be used for this purpose. The detainee will also be instructed that it is

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his/her responsibility to notify family members. A copy of the transfer notification sheet will be
placed in the detainee's detention file.
DEFICIENCY DT-3
In accordance with the ICE NDS, Detainee Transfer, section (III)(D), the FOD must ensure the
attached Detainee Transfer Checklist shall be filled out in order to insure that all procedures
are completed, and shall be placed in the detainee's A-file or work folder. If any procedure
cannot be completed prior to the transfer ofthe detainee, that transfer will not take place
unless the authorized official at the receiving field office has expressly agreed to waive that
portion of the procedure. This waiver should be noted on the checklist.
DEFICIENCY DT -4
In accordance with the ICE NDS, Detainee Transfer, section (III)(D)(7), the FOD must ensure
a properly executed I-203/I-203A, G-391 and I-216 will accompany the transfer. The I-203
will include the detainee's detention category on it. It will further indicate ifthe detainee
has a criminal conviction, a history of violence, is an escape risk or has special medical
problems that may require attention during the transfer. The I-203 will be annotated if the
detainee is on prescription medication.
The I-203 should also indicate the time of arrival as estimated by the sending field office.
The receiving field office may request that copies ofthe I-20311-203A be faxed directly from
the sending field office to the IGA/IGSA that will be detaining the alien.
DEFICIENCY DT-5
In accordance with the ICE NDS, Detainee Transfer, section (III)(D)(8), the FOD must ensure no
detainee shall be removed from a facility, including field office detention areas, unless a Form
G-391 is furnished, authorizing the movement. The G-391 must be properly signed and shall
clearly indicate the name of the detainee(s), the place or places to be escorted, the purpose of
the trip and other information necessary to efficiently carry out the detail. IGSA facilities
may use a local form as long as the form provides the required information.
All completed G-391 's [sic] shall be filed in order (monthly) and the forms for the
previous month shall be readily available for review. All G-391 's shall be retained for a
minimum of 3 years.

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FOOD SERVICE (FS)
ODO reviewed the Food Service NDS at ACDC to determine if detainees are provided with a
nutritious and balanced diet, in a sanitary manner, in accordance with the ICE NDS. ODO
reviewed policy and documentation, interviewed staff, observed meal service and tray delivery,
and inspected food storage and preparation areas.
The facility contracts with Trinity Services Group for management of the food service operation.
Documentation of inspections, production sheets, and temperature logs verified compliance with
the standard. All menus, including special diet menus, are certified by a registered dietitian. The
facility has a satellite system of meal service involving preparation of meals in the central
kitchen and delivery on trays to housing units. ODO verified service-time guidelines and
temperature requirements were met to ensure food safety.
ODO observed knives secured in the knife cabinet all had plastic handles with metal cables. The
cables were not mounted through steel shanks (Deficiency FS-1). Plastic handles can be easily
broken, allowing unauthorized removal and introduction of knives into the facility, which is a
life-safety issue. The knives were immediately removed from service when brought to the
attention ofthe Food Service Administrator.
ACDC does not offer a common fare program in full compliance with the standard. Prepackaged
and precooked hot entrees certified as kosher are not available for detainees participating in the
religious diet program. Instead, religious meals consist of staple foods from supplies used for the
main menu (Deficiency FS-2). The packages for bread and salad provided on religious diet
trays are not labeled "Parve," which confirms compliance with religious dietary laws
(Deficiency FS-3). Meals for the religious diet program are prepared with the same appliances,
equipment, and utensils used for cooking meals for the general population (Deficiency FS-4).
The meat slicer and the meat grinder are not equipped with an anti-restart device (Deficiency
FS-5). Equipment powered by electricity stops working when power is interrupted. Once power
is restored, the equipment restarts automatically, which presents a significant safety hazard to
food service workers.

STANDARD/ POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY FS-1
In accordance with the ICE NDS, Food Service, section (III)(B)(2), the FOD must ensure the
knife cabinet must be equipped with an approved locking device. The on-duty cook foreman,
under the direct supervision ofthe CS [Cook Supervisor], shall maintain control of the key that
locks the device.
Knives must be physically secured to workstations for use outside a secure cutting room. Any
detainee using a knife outside a secure area must receive direct staff supervision.

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To be authorized for use in the food service department, a knife must have a steel shank through
which a metal cable can be mounted. The facility's tool control officer is responsible for
mounting the cable to the knife through the steel shank.

DEFICIENCY FS-2
In accordance with the ICE NDS, Food Service, section (III)(E)(4), the FOD must ensure, to the
extent practicable, a hot entree shall be available to accommodate detainees' religious dietary
needs, e.g., kosher and/or halal products. Hot entrees shall be offered three times a week and
shall be purchased precooked, heated in their sealed containers, and served hot. Other cooking is
not permitted in the common-fare program.
DEFICIENCY FS-3
In accordance with the ICE NDS, Food Service, section (III)(E)(5), the FOD must ensure, with
the exception of fresh fruits and vegetables, the facility's kosher-food purchases shall be fully
prepared, ready-to-use, and bearing the symbol of a recognized kosher-certification agency. Any
item containing pork or a pork product is prohibited. Only bread and margarine labeled "pareve"
or "parve" shall be purchased for the common-fare tray.
DEFICIENCY FS-4
In accordance with the ICE NDS, Food Service, section (III)(E)(8), the FOD must ensure
common-fare meals shall be served with disposable plates and utensils, except when a supply of
reusable plates and utensils has been set aside for common-fare service only. Separate cutting
boards, knives, food scoops, food inserts, and other such tools, appliances, and utensils shall be
used to prepare common-fare foods, and shall be identified accordingly. Meat and dairy food
items and the service utensils used with each group shall be stored in areas separate from each
other. A separate dishpan shall be provided for cleaning these items, if a separate or threecompartment sink is not available.
DEFICIENCY FS-5
In accordance with the ICE NDS, Food Service, section (III)(H)(l2)(c)(4), the FOD must ensure
machines shall be guarded in compliance with OSHA standards:
4. Meat saws, slicers, and grinders shall be equipped with anti-restart devices.

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SUICIDE PREVENTION AND INTERVENTION (SP&I)
ODO reviewed the Suicide Prevention and Intervention NDS at ACDC to determine if the health
and well-being of detainees are protected by training staff in effective methods of suicide
prevention, in accordance with the ICE NDS. ODO reviewed the Suicide Prevention and
Intervention policy and training curriculum, interviewed the Director of Nursing, a mental health
provider, and correctional staff, reviewed medical and facility staff training records, and
inspected a room used for suicide watch.
The ACDC Suicide Prevention Awareness training curriculum covers the required elements,
including recognizing signs of suicidal thinking, facility referral procedures, suicide-prevention
techniques, responding to an in-progress suicide attempt, identification of suicide risk factors,
and the psychological profile of a suicidal detainee. ODO inspection oftraining records
confirmed all medical staff and (b)(7)e o (b)(7)erandomly selected correctional staff had completed
training in suicide prevention and intervention; the (b)(7)e files lacking documentation belonged to
correctional supervisors. The mental health provider who conducts the training stated she had
not provided training to any correctional supervisors during the year preceding the CI. The
Training Supervisor stated correctional supervisors had been removed from the mandatory
training cycle for line staff (Deficiency SP&I-1). Prior to completion ofthe inspection, the
Deputy Chief of Security submitted a training order requiring all correctional supervisors to
receive suicide prevention and intervention training. ODO recommends the facility improve its
tracking of compliance with training requirements to ensure all personnel are trained on a
periodic basis.
ODO verified screening for suicide potential occurs as part of intake screening, and detainees at
risk for suicide are referred to medical and mental health staff, housed, and monitored in
accordance with the standard. ODO was informed there have been no suicides in the past year;
however, there have been seven documented suicide watches within that timeframe. At the time
of the inspection, there was one detainee on suicide watch in the Special Management Unit
(SMU). This detainee was initially moved to the SMU for monitoring because he was refusing
to take his medications. ACDC notified ICE the detainee was placed in the SMU; however,
when his status was changed to suicide watch, ICE was not notified (Deficiency SP&I-2). The
NDS and facility policy require ICE notification when a detainee is determined to be suicidal.
Review ofthe detainee's medical file confirmed that staff followed facility policy and the NDS
related to housing requirements and observation ofthe detainee every 15 minutes.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY SP&I-1
In accordance with the ICE NDS, Suicide Prevention and Intervention, section (III)(A), the FOD
must ensure all staff will receive training, during orientation and periodically, in the following:
recognizing signs of suicidal thinking, including suspect behavior; facility referral procedures;
suicide-prevention techniques; and responding to an in-progress suicide attempt. All training
will include the identification of suicide risk factors and the psychological profile of a suicidal
detainee.

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DEFICIENCY SP&I-2
In accordance with the ICE NDS, Suicide Prevention and Intervention, section (III)(C), the FOD
must ensure, in CDFs or IGSA facilities, the OIC shall report to INS any detainee clinically
diagnosed as suicidal or requiring special housing for suicide risk.

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USE OF FORCE (UOF)
ODO reviewed the Use of Force NDS at ACDC to detennine if necessary use of force is utilized
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 of the facility, in accordance with the ICE NDS.
ODO interviewed staff and reviewed local policy, training records, and use of force
documentation generated during the year preceding the cr.
The various types of force and required authorization are clearly defined in the ACDC Use of
Force policy. When a detainee must be forcibly removed from a cell or other area, ACDC policy
calls for a calculated use of force employing the team technique. Appropriate protective gear
and video-recording equipment are available and accessible. The equipment is maintained in the
Special Housing Unit and the Shift Commander's Office.
ODO confinned there were no immediate force incidents and one incident involving calculated
force against a detainee during the year preceding the CI. Events leading up to the calculated
force incident were recorded by a fixed security camera system in the housing unit. Review of
the video recording confinned the detainee refused to obey an order to return a broom and dust
pan to the utility closet, and instead took the items into his cell. The officer secured the door and
called for assistance. A calculated use of force occurred in the fonn of a cell extraction. ACDC
staff had access to the required video camera recording equipment as required by the standard;
however, the cell extraction was not recorded as required by the NDS. The fixed camera system
did not capture the incident, because it occurred out of camera range. The handheld video
camera was not used for unknown reasons (Deficiency UOF-1). A video recording of a
calculated use of force incident provides critical visual documentation that verifies whether the
force used was necessary and appropriate.
Use of force documentation is not centrally maintained by a designated individual (Deficiency
UOF-2). The use of force cover sheet, detainee statement fonn, staffwitness fonns, initial
incident report, photographs, investigative findings, and recommendations are maintained by a
designated Lieutenant; however, the fonn documenting completion of a medical assessment is
maintained by the Medical Department. After-action evaluation reports are maintained by the
Major. Assignment of responsibility for all use of force documentation to one individual
provides accountability and assures that records are easily retrievable.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY UOF-1
In accordance with the ICE NDS, Use ofForce, section (III)(A)(2)(b), the FOD must ensure INS
requires that all incidents of use of force be documented and forwarded to INS for review. The
videotaping of all calculated used [sic] of force is required.
DEFICIENCY UOF-2
In accordance with the ICE NDS, Use ofForce, section (III)(J)(4), the FOD must ensure all
facilities shall have a designated individual to maintain all uses [sic] of force documentation.
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VISITATION (V)
ODO reviewed the Visitation NDS at ACDC to determine if authorized persons, including legal
and media representatives, are able to visit detainees within security and operational constraints,
in accordance with the ICE NDS. ODO reviewed the local policy and detainee handbook,
inspected the visiting area, and interviewed staff and detainees.
The facility has written visiting procedures, including a schedule and hours of visitation.
Detainees are notified ofvisitation rules and hours by way of the detainee handbook, and visiting
information is available to the public by way of a telephone recording and postings. Separate
logs are maintained for general visitors and legal representatives, supplemented by an automated
system offering efficient recording and retrieval of visitor information. ODO cites this as best
practice. Visitation is non-contact, with the exception of professional visits involving attorneys.
A copy of a completed Form G-28 (Notice of Appearance as Attorney or Accredited
Representative) is not forwarded to ICE for inclusion in a detainee's A-file (Deficiency V-1).
Maintaining a completed Form G-28 in a detainee's file serves to permanently document the
legal representation history of each detainee.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY V-1
In accordance with the ICE NDS, Visitation, section (III)(I)(8), the FOD must ensure, once an
attorney-client relationship has been established, the legal representative shall complete and
submit a Form G-28, available in the legal visitors' reception area; Staff shall collect completed
forms and forward them to [ICE]. The completed form G-28 will become a permanent part of
the detainee's A-file. It will remain valid until [ICE] receives written notice of the relationship's
termination from either the detainee or the legal representative. Staff will place these documents
in the A-file, on top of the Form G-28.

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