ICE Detention Standards Compliance Audit - El Paso Service Processing Center, El Paso, TX, ICE, 2009

• June 2, 2016 • Locations: United States of America -> Texas • Topics: Corrections Audits, Immigration

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•

MGT
Of

AME~ICA,

INC.

1333 New Hampshire Avenue NW
Washington, DC 20036
Contract # 04-00-80-3818

ICE National Detention Standards
Compliance Review

•

Facility:

EI Paso Service Processing Center

Inspection Dates:

October 13-15, 2009

Report Date:

October 16, 2009

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)

•

m:l \ell' lIamJlshir~ AI'c. ~'W, Suite :100
Washinglon, He 2003(1
202/ ,i) ~·mo (1)

MGT
OF

AMERICA,

202/ ""·39:11 IfI
wlI'w.MGToIAmerita.com

INC.

October 16, 2009

MEMORANDUM FOR:

FROM:

David J. Venturella
Acting Director
Ice 0 Detention and Rem

ions
b6,b7c

b6,b7c

Lead Compliance Inspe
b6,b7c

SUBJECT:

•

E1 Paso Service Processing Center
Annual Detention Review

MGT of America, Inc. performed an annual inspection for compliance with the ICE Performance Based
National Detention Standards (PBNDS) at the El Paso Service Processing Center located in E1 Paso,
Texas, during the period of October 13-15, 2009. This is an ICE operated Service Processing Center.
The annual inspection was performed under the guidance of
Team members were:

S1!lij!'llll\fl\lter FI.'~
Security
Health Services
Food Services
Safety

b6,b7c

, Lead Compliance Inspector.

'i'~!D1\i!:~
b6,b7c

Type of Review
The review is a scheduled allllual inspection which is performed to determine overall compliance with the
ICE Performance Based National Detention Standards. The facility received a previous rating of
"Acceptable" during the September 2008 inspection which was based on the National Detention
Standards (NDS).

Review Summary

•

The El Paso Processing Center is accredited by the National Commission on Correctional Health Care
(NCCHC), the American Correctional Association (ACA), and the Joint Commission on Accreditation of
Healthcare Organizations (JCAHO).

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)

Pagell

MGT

•

AMIRICA.

Standards Compliance

The following tables provide a performance summary of the standards that were reviewed and the overall
compliance level determined as a result of the 2008 and 2009 annual inspections. The 2009 inspection
was based on the E1 Paso Service Processing Center's compliance with the ICE Performance Based
National Detention Standards and the 2008 inspection was based on the ICE National Detention
Standards.

1008 Inspection NDS Review
Compliant
Deficient
Repeat Deficiency
Non-Applicable

38
0
0
0

2009 Inspection PBNDS Review
Meets Standard
Does Not Meet Standard
Repeat Deficiency
Non-Applicable

41
0
0
0

The 2009 Performance Based National Detention Standards consisted of both Mandatory and NonMandatory components. The following breakdown is provided as a result of the 2009 inspection.

2009 Inspection PBNDS Review Mandatory

•

Meets Component
Does Not Meet Component
Non-Applicable
Total Components
Percentage of Compliance

Non-Mandatory

40
0
0
40

814
24

100%

97.1%

849

Outcome Measures:
The analysis of the Outcome Measures provided is consistent with the overall mission and security level
of the center.

LCI Issues and Concerns
There were no standards identified by the inspection team as "Does Not Meet Standard".

Concerns:
Hold Rooms

•

Standard: Section V. B. "The maximum aggregate time an individual may be held in a Hold Room is 12
hours."

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)

Page 12

'NC

MGT

•

AME"~A.

•

Staff reported there were 97 incidents where detainees were held in a Hold Room for more
than 12 hours while awaiting bed space in the Service Processing Center. Over 18,000
detainees were admitted in the past 12 months.

•

A review of available documentation for the most recent three months identified no incidents
where detainees were held for more than 12 hours.

Staff reported the occasional holding of detainees in Holding Rooms for more than 12 hours was the
result of limited bed space and an ineffective monitoring system. They also reported that a revised
monitoring system has been implemented to ensure the facility's operational policy is consistent with the
standard.

Recommendation
The facility should establish an internal policy and operational practice that records the time of entry and
a
ainees emg e In a 0 mg room.
ey s ou a so eve op a movement p an to ensure
all detainees are removed from a holding room prior to 12 hours.

Visitation

•

Standard: 1.1. "The facility's written rules shall specify time limits for visits, 30 minutes minimum,
under normal conditions. ICEIDRO encourages more generous limits when possible, especially for
family members traveling significant distances. In unforeseen circumstances, such as the number of
visitors exceeding visiting room capacity, the facility administrator may modify visiting periods."
•

Public visitation for detainees averaged approximately 20 minutes based on staff assigned to the
visiting post.

•

The visiting room logbook reflected most general visits lasted less than 30 minutes.

•

There were no concerns identified in relation to the frequency, duration or space for attorney
related visits.

The general visiting room area consists of five non-contact visiting booths and four contact visiting rooms
to service an average population of 772 detainees. Public visiting hours are scheduled seven days per
week. Monday through Friday pubic visiting hours are from 6:00 PM to 9:00 PM. On Saturday and
Sunday public visitation hours are from 11 :00 AM to 3:00 PM and 6:00 PM to 9:00 PM. Detainees are
normally scheduled to receive public visits during one of the (9) three hour visiting sessions. The specific
session during which a detainee can visit is based on the fIrst letter of the detainee's last name.

Recommendation
Expand the public visiting hours to ensure all detainees can receive a minimum of 30 minutes per visit.

Recommended Rating and Justification:

•

The Lead Compliance Inspector recommends that the El Paso Service Processing Center receive a rating
of "Meets Standards". The facility currently complies with 40 of 40 Immigration and Customs
Enforcement, Performance Based National Detention Standards. In addition, the facility is in compliance

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)

Page 13

lNC

MGT
OF

•

AMIRICA

with (100%) percent of the Mandatory components and (97.1 %) percent of the Non-Mandatory
components.

LeI Assurance Statement
The findings of compliance and noncompliance are accurately and completely documented on the G324A Inspection form and are supported by documentation in the inspection file. An out brief was
conducted at the facility and included a discussion of all deficiencies, concerns, and recommendations
noted.
The following were present:
b6,b7c
b6,b7c

, CIEA;
b6,b7c

snno;

, Deputy Field Office Director;
b6,b7c
b6,b7c
, SDnO;
b6,b7c

b6,b7c

, SIEA;

, Assistant Field Office Director; b6,b7c
b6,b7c
SIEA;
,

b6,b7c

b6,b7c
, Nakamoto Group;
, Contract Security;
b6,b7c
b6,b7c
, lEA; b6,b7c Contract Security;
, Contract Security;
b6,b7c
b6,b7c
, Maintenance Supervisor;
SDDO;
Maintenance;
b6,b7c
b6,b7c
b6,b7c
, lEA;
, Chaplain;
, lEA;
b6,b7c
b6,b7c
, lEA;
, Food Service COTR;
, lEA;
b6,b7c
b6,b7c
, SDDO.
and

•

b6,b7c

, Training;
b6,b7c
, Contract
b6,b7c
, lEA;
b6,b7c
, lEA; b6,b7c
, lEA;
b6,b7c
b6,b7c

, Lead Compliance Inspector, October 16, 2009

Signature:

•
FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)

INC

Department Of Homeland Security
Immigration and Customs Enforcement

A Type'

ICE Service Processing Center
ICE Contract Detention Facility
ICE:
Service

B. Current Inspection
of Inspection
Field Office [8 HQ Inspection
Date[s] of Facility Review
October 13-15, 2009

C. Previous/Most Recent Facility Review
Date[s] of Last Facility Review
September 16-18,2008
Previous Rating
D Superior D Good [8 Acceptable D Deficient D At-Risk

, Cen'",

E1 P",o, Tex", 79925

, v'

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

'Field Offke·
Code)

b6,b7c

, (List

Distance from
i Otlice
Less than One Mile

f;;~La"

)nlv
Number

~;:

I NlA

~Ratesp"
: \H

"un"

D~:~w Bed, only)

J. Total Facility Population
Total Facility Intake for previous 12 months
18,229
Total ICE Mandays for Previous 12 months
364,580

Adult Male
Adult Female

Name ofInspector (Last Name, Title and Duty Station)
b6,b7c / LCI / MGT of America, Inc.
Name of Team Member I Title 1 Duty Location
b6,b7c 1 CI-Securitv 1 MGT of America, Inc.
Name of Team Member 1 Title I Duty Location
b6,b7c 1 CI-Safety 1 MGT of America, Inc.
Name of Team Member I Title 1 Duty Location
b6,b7c
1 CI-Health Service 1 MGT of America, Inc.
Name of Team Member 1 Title I Duty Location
b6,b7c 1 CI-Food Service 1 MGT of America, Inc.

Date:

K. Classification Level (rCE SPCs and CDFs Only)

E. ICE Information

>"'"

840

"',

Field Office /
I ~tPonsib~1ities)

I N/A;

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

I Dy" I2J No

p;"
b6,b7c

I Date Ne;;,~ ,p,:e~ed,paoe Added

89151

;:!'!:, State ond

I 91:

I Estimated Man-days Per Year
365,000

1967

~l~~'o

Detention Review Summary Form
Facilities Used Over 72 hours

L-2
169
50

L-I
305
125

L-3
72
4

L. Facility Ca acity
Rated
Operational
Emergency
Adult Male
568
578
800
Adult Female
272
144
400
Facility holds Juveniles Offenders 16 and older as Adults

M. Average Daily P~pulation
ICE
AduItMale
601
Adult Female
171

N. Facilitv Stamm! Level
Security:
ICE: b2High Contract b2High

USMS
0
0

Other
0
0

Support:
ICE:b2High

Indi"te N/A)

Form G-324A SIS (Rev. 9/3/08)

•

Significant Incident Summary Worksheet
For ICE to complete its review of your facility, the following information must be completed prior to the scheduled review dates.
The infonnation on this form should contain data for the past twelve months in the boxes provided. The information on this form
is used in conjunction with the ICE Detention Standards in assessing your Detention Operations against the needs of the ICE and
its detained population. This form should be filled out by the facility prior to the start of any inspection. Failure to complete this
section will result in a delay in processing this report and the possible reduction or removal ofICE' detainees at your facility.

Assault:
Offenders on
Offendersl

o
o
o

Assault:
Detainee on
Staff

•

# Times Four/five Point

Restraints applied/used

Referrals as a result of

Escapes

N/A

NlA

N/A

o
5
# Psychiatric Cases referred for

•

Any attempted physical contact or physical contact that involves two or more offenders
Oral, anal or vaginal penetration or attempted penetration involving at least 2 parties, whether it is consenting or non-consenting
Routine transprutation of detainees/offenders is not considered "forced"
Any incidem that involves four or more detainees/offenders, includes gang fIghts, organized multiple hunger strikes, work stoppages, hostage
situations, mll,jor fifes, or other large scale incidents.

Form

G-324A

SIS (Rev.

9/3/08)

DHS/ICE Detention Standards Review Summary Report

.~~~~~~~~~<~ill

'Ii
I

i I

Fonn G-324A SIS (Rev, 9/3/08)

•

LeI Review Assurance Statement

By signing below, the Lead Compliance Inspector (LCI) certifies that all fmdings of noncompliance with policy or inadequate
controls contained in the Inspection Report are supported by evidence that is sufficient and reliable. Furthennore, findings of
noteworthy accomplishments are supported by sufficient and reliable evidence. Within the scope of the review, the facility is
operating in accordance with applicable law and policy, and property and resources are efficiently used and adequately
safeguarded, except for the deficiencies noted in the report.

Lead Compliance Inspector: (Print Name)

b6,b7c

Title & Duly Location

Lead Compliance Inspector, MGT of America, Inc.

October 16, 2009

Team Members
hint Name. Title. & Duty Location
b6,b7c

Print Name, Title, & Duty Location

CI - Security, MGT of America, Inc.

Print Name. Title, & Duty Location
b6,b7c

, CI - Food Service, MGT of America, Inc.

Print Name, Title, & Duty Location

•

Recommended Rating:

CI - Medical, MGT of America, Inc.

b6,b7c

Print Name, Title. & Duty Location
b6,b7c

CI - Safety, MGT of America, Inc.

Print Name, Title, & Duty Location

[ZJ

Meets Standards
Does Not Meet Standards

Comments:
The average daily population at the El Paso Service Processing Center during the past 12 months was 772. On the last day of the
inspection the detainee population count was 786.
There were no deaths reported at the center during the past year.
Most security posts within the facility are filled by contractual staff employed by DOYON. Approximately 356 DOYON
contractual security personnel are assigned,

•
Fonn G-324A SIS (Rev. 9/3/08)

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

•

[2J

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

Performance-Based National Detention Standards
Worksheets
ICE Service Processing Center
State Facility - IGSA
ICE Contract Detention Facility

Name
EI

Center

b6,b7c

of Review

2009
Headquarters

Operational

OSpecial Assessment

o Other

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07109/07

TABLE OF CONTENTS

.ART

1 SAFETy .•............................•••••••...........................•.••.•......................•.••..... .4
Emergency Plans ............................................................. , .............................. .
Environmental Health and Safety ......................................................................... .
Transportation (By Land) ................................................... , .............................. .

PART 2 SECURITy ...••.••............................••...............................••.•...................... 16
Admission and Release .................................................................................... .
Classification System ...................................................................................... .
Contraband .................................................................................................. .
Facility Security and ControL ............................................................................ .
Funds and Personal Property
Hold Rooms in Detention Facilities ..................................................................... .
Key and Lock ControL .................................................................................... .
opu atlon ounts ......................................................................................... .
Post Orders .................................................................................................. .
Searches of Detainees ..................................................................................... .
Sexual Abuse and Assault Prevention and Intervention .............................................. .
Special Management Units ............................................................................... .
Staff-Detainee COIlllllunication .......................................................................... .
Tool Control. .............................................................................................. .
Use of Force and Restraints ............................................................................. .
~RT

•

3 ORDER .......................•••.•................................•............................•••......... 57
Disciplinary System ...................................................................................... .

PART 4 CARE .............................•.•..•.•............................•..•...........................•...... 60
Food Service .............................................................................................. .
Hunger Strikes ............................................................................................ .
Medical Care ............................................................................................. .
Personal Hygiene ........................................................................................ .
Suicide Prevention and Intervention .................................................................. .
Terminal Illness, Advance Directives, and Death .................................................. .

PART 5 ACTIVITIES ....•.........•..•..•..............................••••............................•••..•.... 93
Correspondence and Other MaiL ...................................................................... .
Escorted Trips for Non-Medical Emergencies ..................................................... .
Marriage Requests ...................................................................................... .
Recreation ............................. , ................................................................. .
Religious Practices ...................................................................................... .
Telephone Access ...................................................................................... .
Visitation ................................................................................................ .
Voluntary Work Program ............. , ............................................................... .

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IOSAs - Rev: 07/09/07

Page 2 of 136

PART 6 JUSTICE ...............•••••.............•.....•..•............•...•..••..••.................••......... 110

•

Detainee Handbook .................................................................................... .
Grievance System ...................................................................................... .
Law Libraries and Legal MateriaL ................................................................... .
Legal Rights Group Presentations .................................................................... .

PART 7 ADMINISTRATION & MANAGEMENT ...........•••......................•................•. 121
Detention Files ......................................................................................... .
News Media Interviews and Tours ................................................................. .
Staff Training .......................................................................................... .
Transfer of Detainees ................................................................................ .

NOTE: FOR EACH STANDARD RATED BELOW ACCEPTABLE, FACILITIES MUST AITACH A PLAN OF ACTION FOR
UV"o " " V
D~'"
,THE
WORKSHEET TO
IDENTIFY AREAS OF IMPROVEMENT, INCLUDING THOSE STANDARDS WHERE AN OVERALL FINDING OF
ACCEPT ABLE WAS ACHIEVED.

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G_324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

Page 3 of136

•

SECTION I

•

SAFETY STANDARDS

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G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

Page 4 of 136

PART 1 -1.
d

ensuees a safe:

th tror,

. . . ; thdr ;_O~~~ving m

respon to any emergency sltuatlons at anse an to mmlrnlze

."
~

.$-5
0:;;.,

I2J

.... J..

'" .!i '"

~~ta~~,~

groups

over other

Remarks

I from,

•
•
•
•
•

Personal abuse

Staff is trained to identify signs of detainee unrest.

•

What type of training and how often?

Corporal punishment
Personal injury

Disease
Property damage

I2J

Each emergency plan is assigned a number and is strictly accounted for.
A list identifYing the location of each emergency plan is maintained by the
Chief of Security or equivalent.

I2J

7. All staff receives training m tho emergency plans during their
orientation training as well as during their annual training.

I2J

~ effectively di",minates infonnation on fadlity dimate, d"am"
.

and moods to the Facility Administrator.

There is a

person or persons

Detailed emergency
response training covering
appropriate areas is
provided during orientation
training and is a required
part of the annual training
curriculum for both ICE
and contract employees.

for emergency

plans and their implementation. Sufficient time is allotted to the person or
group for development and implementation of the plans.

An ICE employee with the
rank of Captain is assigned
this responsibility.

'.lhe

. ,of tho emorg""y plans

"outes

to the facility for staff to use in the event the primary route is impassable.

;tk

Tho plans

•

Confidentiality

•

Accountability (copies and storage locations)

•
•

l issues,

Annual review procedures and schedule
Revisions

10.
.
procedures
for handling

•

y=u

:;;;

Components

I plans

severity.

_~.~~n:o most em:rgency situa~ons,

section with
procedures

with special needs.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

Page 5 ofl36

PARll

1. EMERGENCY

'"'
.
.
th t fu~
d ",.nd, .• >ho;..
. ••• ,. Y
any emergency SltuatlonS at anse an to mmtnllze ........ severity.

Components

Remarks

fo,

15. Staft" tramed to
• from
,
, of
rank. Within 24 hours after release, hostages are screened for medical and
psychological effects.

16. The fudlity
. • a lief of
needed during a hostage crisis.

in the event one is

for staff and

11.

• •• :, •• :' plans
;, 11l "IV""'" .

th afu '1'
to e Cl tty.

12. ThOi

I pl;ms with,

•

Local law enforcement agencies

•

State agencies

•

Federal agencies

13. "the
. ~.'y.
mock emergency
with'
or
departments with which they share mutual aid agreements and Memoranda
o( L
.
The exercises should t e s t '
I plans to
",se" therr
14. All

; 'opi" of the .

&. Emergency plans .
~et; .

emergency
during and after an incident.

18. The Food Service Department maintains at least 3- days' worth of
emergency meals for staff and detainees.
19. Written plans illustrate locations of shut-off valves and switches for
utilities (water, gas, electric).

fSI

20. Written pl~~s. include a Staff Work Stoppage
procedure is available for limited supervisory review.

•

This

provided by the Training
Coordinator.

The fucili!y maintains a
three week supply of
emergency meals.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

Page 6 of 136

PART 1-1.

11lis Detention

ensures a safe.

.• place,

s and,

effectively respond to any emergency situations that arise and to minimize their severity.

• 1!

1i
::Sa

Components

21.

•
•
•
•

-. t ...:;

....

! ~ ~
Q
Iii

Remarks

cover:

WorkIFood Strike

Fire
Environmental Hazard
Detainee Transportation System Emergency

•

ICE-wide Lockdown

•
•
•
•
•
•

Staff Work Stoppage

Internal Searches

•

Facility Evacuation

•
•

Detainee Transportation System Plan

•

Civil Disturbances

Each oftheflfteen

Disturbances

is addressed

I'n me
emergency plans.

Bomb Threats
Adverse Weather

Hostages (Internal)

_ T h e "md,'

for post-emergency

Phm, 'pedIY a

121

PART 1-1.

121 Meets Standard

D Does Not Meet Standard

ON/A

DRepeat Finding

Remarks: (Record significant facts, observations, other sources used, etc.)
On the first dayofthe review the inspection team was able to observe the response to a medical emergency resulting from
a detainee being injured on the recreational yard. All procedures utilized by staff appeared consistent with the standard.

b6,b7c

/ 10-15-09

b6,b7c

Reviewe,', Sign,""

b6,b7c

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09107

Page 7 of 136

PART!

2• ..,,,

HEALTH AND SAFETY

protects detainees,_staff, volunteers, and
from ~l:J;d ~llJ illnes~.by
high facility standards of cleanliness and sanitation, safe work practices,
control of hazardous
and equipment.

This

~'E
'Oi ~

.'"

Z-~

•""t"CI
:'1 :I=
:'1~
=
en
en ~

Components

The H,,]th ",d Sa"'y

The t"ility has a .'",tem fo,

issuing, and maintaining inventories of hazardous materials.

",,'

Remarks

I to, all

toxto,

and caustic substances used/stored in each area of the facility.

[ZJ

Officer has oversight of
hazardous materials and
conducts fire, safety, and
weekly inspections of all
areas. A system is in place.

,
,

up-to-date for every hazardous substance used.

•

The files list all storage areas, and include a plant diagram and
legend.

•

The MSDSs and other infonnation in the files are available to
personnel managing the facility's safety program.
4. All personnel using
toxic,
substances follow the prescribed procedures:

•

and/or

caustic

Wear personal protective equipment.
Report hazards and spills to the designated official.

The MSDS '"

MSDS are
.
at
required locations.
Detainees are trained by staff
on safety precautions and
have access to the MSDS.
Documentation and logs
reviewed indicated detainees
are trained and supervised.

dn the

to staff and

,,"u;'Y

work areas.

[ZJ
6.
superVIsion.

are

•

Quantities are limited.

•
•

Detainees are trained.

always

issued

under

proper

[ZJ

7. All ..
and "combustible"
(liquid and
aerosol) are stored and used according to label recommendations.

[ZJ

and electrical
are installed in
<.
storage rooms and other hazardous areas and meet the National
Electrical r,
.

[ZJ

Staff always supervises detainees using these substances.

9. All

to~;,

and caushc

stoced

the;,

contamers ill a secure area.
IU. Ex,,,s

and toxk liquids '"

disposed of properly in accordance with MSDS.

•

t venda,
I Al
disposes of hazardous
materials .

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

Page 8 of 136

•• ~ HEALTH ANDSAFETY

PART 1- 2:Ei'.,

This. .. h' h f T
da ds f I 'lstatt; d
..
"
k S fro~ ini; ; and ill~es:: d
mamtammg 19 aCI tty stan r o c ean mess an samtation, sa e wor practices, an contro 0 zar ous
and equipment.

~1:

'0: •

Components

~'"
~ ~

'._¥' ,nd ",count fm

II. "."

;with m'thyl

alcohol. Staff receives a list of products containing diluted ~eth~l
alcohol, for example, shoe dye. All such products are cl~ariy
labeled as such. "Accountability" includes issuing such products
to detainees in the smallest workable quantities.

12. Ev"y

and

using

, toxic,

caustIc
receives advanced training, in
OSHA standards, in their use, storage, and disposaL

with

.'" '"

o 1:
"'i,g
~ ~
8

[2J

Remarks

Methyl alcohol is not
authorized in the facility.

~?it!~n of applicable codes,

and regulations of the

National Fire Protection Associatio~~~~~A) and the Occupational
Safety and Health Administration ( n
•

, fir, and safety

I staff,

14. A .
mspectlOns.

15. Th',S~f'!y
reports,

Offi" (~'

contr~L~d

.16.

filos of

actlOns ta en.
.
has
The
;'~i,n

fico

[2J

Officer has the most current
editions of the codes and
regulations and the facility is
in compliance.

17. Th, plan.
0

Monthly fire inspections.

Fire protection equipment strategically located throughout the
facility.

Public posting of emergency
building/room floor plans.

plan

with

accessible

Exit signs and directional arrows.

An area-specific exit diagram conspicuously posted in the

[2J

IZI

[2J

Each building/detainee
housing area has a public
posting of the fire evacuation
plan.

diagrammed area.

in all

18. Fire drills are conducted and documented
facility locations including the administrative area.
19. A sanitation program covers barbering

I 20. Th'..

,has tl"

necessary to

"nd

meet samtatlOn requtrements.
1

2LTh ,

ac,

postoo in th,

barbershop.

, th,

22. "mo>,

,and, .

lofusod

needles and other sharp oh-

23. All it,ms

.~af~ty

,0'

. ',isks ac,

inventoried and a designated individual checks this inventory
weekly.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

Page 9 of 136
------

c~i

1- 2. EN'

lAND
This.'
protects
,.staff,
,and contractors from injury and illness,by,
maintaining high facility standards of cleanliness and sanitation, safe work practices, and control of hazardous
and equipment.
HAL

Components

Remarks

24. Standard cleaning practices include:

•

Using specified equipment; cleansers; disinfectants and

[;8J

detergents.
•

An established
inspections.

schedule

of cleaning

and

25. Spill kits are readily available.

waste

follow-up

contractor

s waste,
27" Staffis teained to prevont contaot with blood and oth" body
fluids and written procedures are followed.

[2J

D He~l~

28, Do the,

[2J

35, Th: Headalth'l E' h '
"I d
'h
d" ,":,
mspectlOns 1 y. ac mspechon mc u es notlUg t e con ltion VI
floors, walls, windows, horizontal surfaces, and equipment.

for

of refuse meet all

regulatory requIrements?

lis,

staff,l by

29, A
inspects for rodents, insects, and vennin.
•

At least monthly.

•

The pest-control program includes preventive spraying for
indigenous insects.
according to

"vatee and'

'30,

a fixed schedule.

are tested at least every two

31. Emergency power
weeks.

•

Other emergency systems and equipment receive testing at
least quarterly.

•

Testing is followed-up with timely corrective actions (repairs
and replacements).

32, Th,

..,

; clean and well maintained.

33.
storage rooms meet th~.
. a~d
structural requirements of the standard. Storage cabinets meet the
physical requirements specified in the standard.

34, Th' Health

program supporbng a

36, The ,

by the El Paso Water
Utilities and the water supply
rating was "Superior".

h'gh I
1

eve

I f' "

staf~,

h" 'I

envrronmenta

,hall:,

,t~:;~

rnveStlgatlOns an compre enSlve surveys VI'
conditions, and provide advisory, consultative, inspection, and
training services regarding environmental health conditions.

[Z]

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet lor IGSAs - Rev: 07/09/07

Page 10 of 136

ThisD<

PART I - 2. \,,,, '
[AND:
dAL
',.staff,
,and contractors from injury'
'
~by
high facility standards of cleanliness and sanitation, safe work practices, and control of hazardous
and equipment.

.'2 ~'S]
~~'"
~ ~ ~
~~
en ~
Iii
i~

Components

d
37'1The ,
'''I'"'"
.';s
d 'f~'d I'
. ;o.""'th
Imp ementmg po lCles, pro=uures, an gut e mes n n
e
environmental health program. These guidelines are intended to
evaluate and eliminate or control as necessary, sources of injuries

I2J

Remarks

The Health Services Unit has
comprehensive operating
procedures and an infectious
control manual.

and modes of transmission of agents or vectors of communicable

diseases.
38,

health and

sofety

shall be

maintained at a level that meets recognized standards of safety and
,
, those Jr, ,'h
•

American Correctional Association,

•

Occupational Safety and Health Administration,

•

Environmental Protection Agency,

•

Food and Drug Administration,

•

National Fire Protection Association's Life Safety Code, and

•

National Center for Disease Control and Prevention.

PART I
121 Meets Standard

•

2. ENVIRONMENTAL IIEALTH AND SAFETY
D Does Not Meet Standard

D NiA

DRepeat Finding

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09107

Page 11 of 136

Remarks: (Record significant facts, observations, other sources used, etc.)
The assigned Health and Safety Officer is a certified trainer in OSHA General Industry Standards. He is using the most
He conducts regular staff training in envrronmental health
safety subjects. He also instructs staff in the procedures of conducting fire and safety inspections. Additionally, he
provides training to staff who supervises detainees on appropriate safety practices.

Arent editions of applicable codes, standards and regulations.

W'I

The facility utilizes a contract vendor that conducts preventive maintenance and makes repairs. The contract includes
utilizing professional and licensed vendors for generator, electrical equipment, and fire alarms inspections; and pest
control, waste/refuse and recyclables removal, hydrant/flow test, and sanitation services for the staff administrative areas.
The Bureau of Customs and Border Protection conducted a Safety and Health Inspection Report dated July 14-15, 2009.
Of the 53 violations cited, 50 have been resolved and two are minor. The most serious violation was the (fire alarm system
in the administrative area) which is pending completion of corrective action.
The EI Paso Fire Department conducted an inspection of the facility and issued a report dated October 7, 2009.
Three minor and one major violation was cited. The minor violations have been resolved and the major violation
(fire alann system in the administrative area) has been submitted for corrective action and is awaiting approval. The
report stated that there has been significant improvement with the fire protection features and with overall safety at

The facility reported 293 detainee injuries for fiscal year 2009. This count includes all referrals for medical attention
regardless of seriousness. The vast majority of referrals were minor and involved injuries related to sports/physical
activities (bruises, scrapes and abrasions).
One issue of concern relates to the kitchen equipment. In the event of an electrical power interruption while the slicer is in
use, it will not automatically reset to the off position when power is restored. This may result in injury if the staff are not
appropriately trained and aware of this condition.
~e

facility appears to be clean, well maintained, and inspected regularly for environmental and safety standards
The staff and detainees are trained to ensure a high level of sanitation and good order.

~pliance.

b6,b7c

/10-15-09
Reviewer's Signature /
b6,b7c

b6,b7c

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G_324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

Page 12 of 136

,
,

PART 1-3.'
/(BY
preventshatii1 to the gener,] pubHc,
.
and staff by
that'
are
maintained, and operated and that detainees are transported in a secure, safe and humane manner,-~:~~ the
and experienced staff.

ThiS

1'"

Standard NA: Check this box if all ICE Transportation is bandled only by the ICE Field Office or Sub-Office in
control of the detainee case.

....... ... ..
~

Components

1. Transporting
comply with applicable local, state,
and federal motor vehicle laws and regulations. Records support
this finding of compliance.
2. Every transporting officer required to drive a commercial
size vehicle has a valid Commercial Driver's License (CDL)
issued by the state of employment.

~operated.

go~l

I2J

~inspection at
and
annual inspection in accordance with state statutes is available
for review.

I2J

5. D
.
~ are completed
immediately and vehicles are not used until they have been
repaired and inspected is available for review.

I2J

Remarks

licenses were reviewed and one
was not issued by the state of
Texas.

14. b

use a

"Y
Officers report deficiencies affecting operability.

Deficiencies are corrected before the vehicle goes back into
service.
7.

•

Limit driving time to 10 hours in any 15 hour period when
transporting detainees.

•
•

Drive only after eight consecutive off-duty hours.
Do not receive transportation assignments after having been
on duty, in any capacity, for 15 hours.

•

Drive a 50-hour maximum in a given work week; a 70-hour
maximum during eight consecutive days.

•

During emergency conditions (including bad weather),
officers may drive as long as necessary to reach a safe
area-exceeding the lO-hour limit.

18.

Two

I2J

The longest rOlllld trip
transportation provides does not
exceed 10 hours. Policy and
procedures are in place that
address the limits on driving time
and specifically requires
compliance with all Department of
Transportation rules and state
laws.

with valid

(CDL's) required in any vehicle transporting detainees.

•

When buses travel in tandem with detainees, there are two
qualified officers per vehicle.

•

An unaccompanied driver transports an empty vehicle.
, tho
, officer
, bofore tho ,tart
of each detail.

10.

The

confirmed.

, of all

, being

Ii,

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

Page 13 of 136

!
!
,

PART I

prevents ~arm. to. the_
. publi~,
and '''fIby
" that
Me Y'~y' ih~
maintained, and operated and that
are transported· a secure, sate and
mann",
of trained and experienced staff.
Standard NA: Check this box if aU ICE Transportation is handled only by the ICE Field Office or Sub-Office in
control of the detainee case.

Thi,

."t.a" .;,.t.a.

....

Components

II. All
Me
.
vehicle by staff controlling the bus

:;;

05 ~

:;;

'"'

121

12.
ensures that'
transported
does not exceed the vehicle manufacturer's occupancy leveL

121

l3. All
wear their issued body annor in
accordance with the ICE Body Armor policy and/or applicable

121

. the u," of

IRl

One officer remains in the vehicle at all times when
detainees are present.

121

14. The
crew
a visual count once all
passengers are on board and seated.

•

Additional visual counts are made whenever the vehicle
makes a scheduled or unscheduled stop.

15. . . ' <and y'
restrammg eqUlpment on
16.

•

Remarks

i
c to

l the

3. TRANSPORTATION \n,

Me in,."l"e,
. vehicles.

Staff were observed wearing their
issued body armor.

ensure that no one contacts

1 during long, .
17. M"I"
• The meals meet the mmnnum dietary standards,
identified by dieticians utilized by ICE.

18. The
c"w .
,11 Food
'.m"ls befo"
accepting delivery (food wrapping, portions, quality, quantity,
thermos-transport containers, etc.).

•

Before accepting the meals, the vehicle crew raises and
resolves questions, concerns, or discrepancies with the Food
Service representative.

•

Basins, latrines, and drinking-water, containers, dispensers
are cleaned and sanitized on a fixed schedule.

19.

•
•
•
•

, have:
Two-way radios.
Cellular telephones.

Equipment boxes stocked in accordance with the Use of
Force Standard.
Equipment appropriate and necessary fm transporting
detainees with physical disabilities.

20. The vehicles are clean and sanitary at all times .

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G·324A Detention Inspection Form Worksheet for IGSAs - Rev: 07f09I07

Page 14 of 136

(BY

PART 1-3.·
hannto tho

. pubHe.
.
...d statt by
. that
are
maintained, and operated and that
are transported in a secure, safe and humane manner, under the
C'
of trained and experienced staff.
Standard NA: Check this box if aU ICE Transportation is handled only by the ICE Field Office or Sub-Office in
control of the detainee case.

This

Components

Remarks

property of a

.
J.acllty;
1

•

Is inventoried.

•

Is inspected.

•

Accompanies the detainee.

22. The

in the WJitten

Me
S WJ

yome]e "ows

•

Attack

•

Escape

•

Hostage-taking

•

Detainee sickness

•

Detainee death

•

Vehicle fire

•

Riot
Traffic accident

•

Mechanical problems

•

Natural disasters

•

Severe weather

•

Passenger list is not exclusively men or women or minors

PART 1-

l'2I Meets Standard

o Does Not Meet Standard

l(BY

DN/A

DRepeat Finding

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

At the time of the inspection transportation of detainees was being transitioned from ICE employees to DOYON the
Istent with the standard
contract securIty firm. Procedures
b6,b7c
/ 10-15-09
RevIewer's Signature / Date

b6,b7c

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet fur IGSAs - Rev: 07/09/07

Page 15 of 136

•
SECTION II

SECURITY STANDARDS

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

Page 16 of136

11
PART2-4.,

This .

protects the.
when detainees are admitted to or released from a

:;;~ff,

and contractors by

-e

.'!1m

Components

:ilS

III

1.
includes an
I of the facility.
The orientation includes; unacceptable activities and behavior, and
corresponding sanctions. How to contact ICE. The availability of
pro-bono legal services and how to pursue such services. Schedule
of programs, services, daily activities, including visitation,
telephone usage, mail service, religious programs, count
procedures, access to and use of the law library and the general
library; sick-call procedures, and the detainee handbook.

-e

Z-m

$$"g
o:E

..,

Remarks

A video orientation is provided in
English and Spanish that includes
all requirements cited in the
standard.

III

[)j

3. When
, accompanying documentation is used to
identify and classifY each new arrival. In SPCs and CDFs, new
detainees shall remain segregated from the general population
during the orientation and classification period.

[)j

are searched in
~ with I
Search" standard. An officer of the same sex as the detainee
conducts the search and the search is conducted in an area that
affords as much privacy as possible.

[)j

oce
to a strip s"coh only when ,,",onable
has been established and not as routine policy. Non.
detainees are never subjected to a strip search but are
patted down unless cause or reasonable suspicion has been
established. All strip searches are documented on 0-1025, or
equivalent, with proper supervisory approval.

[)j

governs all
property
6. The
searches. IOSAs and CDFs use or have a similar contraband
standard. Staff prepares a complete inventory of each detainee's
possessions. The detainee receives a copy. All identity documents
are inventoried and given to ICE staff for placement in the A-file.
All funds and valuables are safeguarded in accordance with ICE
Policy.

[)j

2. Medical
are performed by medical staff ~rsons
who have received specialized training for the purpose of

secure and

Only medical staff conducts the

·,;",11,""

,~~~::
..

7. Staff completes Form 1-387 or similar form for CD!'s and
IGSAs for every lost or missing property claim. Facilities forward
all 1-387 claims to ICE.

[)j

121

LJ
LJ

U
U

a receipt for personal property secured

[)j

a system to maintain accurate records and
for admission, orientation, and release.

121

8. Detainees are issued
bedding for the climatic
9. All releases are
10.

: and

I with ICE.
release as

Dill'"

11. Each
by the facility.
12. The

, and

. ;'y.: has

No strip searches were reported in
the past 12 months.

.
oflost or stolen
property were reported in the past
12 months. Form 1-387 was
available when needed.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

Page 17 of 136

PART 2-4.

This

IAN-"-

Stand"d
, the
. ,
: '.~~tl,
detainees are admitted to or released from a facility.

, and

",cure and

Components

Remarks

13. ICE ,taft' ent." all
.. to
,
or transfer of all detainees into~' fu~·
;'~ Alien Detention
Module (EADM) within 8 hours of action.

14.AII
.
I "'all b"
and other language(s) as detennined by I

lin
.

lom(

PART 2-4.

'1iMeets Standard

English and Spanish.

lANe

Does Not Meet Standard

N/A

DRepeat Finding

The center has one admission and release area which is divided into two sections to effectively manage the separation of
detainee processing by gender.
b6,b7c
/10-15-09
Reviewer's Signature /

b6,b7c
b6,b7c

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G_324A Detention Inspection Form Worksheet fur IGSAs - Rev: 07/09107

Page 18 of 136

_£

PART2-'.'

'"'''' ~,.

protects ~e_,
.
, ~ta~ _contractors,
, and the
. 'from, ~~, an~ ,
.
to
by requiring a formal classification process for managing and separating detainees that is based on
data.

Components

JIl~
m"tO

::EJ!!

o::EJ!!

me
Ul

(
use the
I. SPC ond CDf
IGSAs use an objective classification
Classification System.
system or similar system for classifying detainees.

Th, fucility'

•
•

ClassifYing detainees upon arrival.

Separating individuals who carulOt be classified upon arrival
from the general population.

•

Thc
'~p
0'
reviews every classification

Th,'

, offic"

etc., to identifY and

each new arrIval.

4. Staff uses only
. that i, factuol, ond. .
to
determine
classification
assIgnments.
OpinIOns
and
unsubstantiated! unconfmned reports may be filed hut are not used

Zli~

=GI-g

:!!
Z

Remarks

I2J

to score detainee classification.

.
do" not affect hi, 0' h"
opportunities. Detaillees recreate with persons of
similar classification designations.

I2J

wo,k
~. D .'
eSlgnations.

I2J

3.
,

assignments are based on
A

are based upon

process
8, I Th~ .
rec assl IcatlOn. The First Reassessment is to be completed 60
Subsequent
daY' to 90 days after the initial assessment.
reassessments are completed at 90 day to 120 day intervals.
Special Reassessments are completed within 24 hours.
9. Tho
.
.
sY'tom
';
. fo,
supervIsor or
processing new arrivals' appeals. _L?_n_~~_~
.
classification specialist has the
' ) reduc a classificationlevel on appeal.
MC
w/in 5
.
doys,
of the outcome within 10 business days.
etamees

~ocumentatlOn
'o,;ow u',' 'd 'fi d 11
1 entt Ie

11.
'
authority such as the

•

may b,

, t o a high"
or eqUivalent.

I2J

classification appeals processed
within the past 12 months.
Detainee files reflected appeals
were heard and documented, but
the files failed to identify if the
timelines were met.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

Page 19 of 136
---------

protects the
contractors, volunteers, and the
facility operations, by requiring a fonnal classification process for managing and separating detainees that is based on
data.

Components

:is
<II

'0 l!
z-;ca
0~'"
~:i c

8 tl

and restrictions applicable

In IGSA's a
uniforms and IDs to reflect classification
similar system is utilized for each level of classification.

Meets Standard

121

Does Not Meet Standard

D N/A

Remarks

not
explain the conditions and
restrictions of the classification
levels including participation in
the voluntary work program.

DRepeat Finding

Remarks: (Record significant facts, observations, other sources used, etc.)
The facility's classification plan ensures that each detainee is placed in the appropriate category (Level J, II, and III).
Classification is detennined by criminal and escape history, history of assaultive behavior, medical and mental status, age,
vulnerability, disruptive group (gang) affiliation and the need to be separated.
b6,b7c

Signature / Date

b6,b7c

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet fur IGSAs - Rev: 07/09/07

Page 20 of 136

pmteets

Thi, .

. ",d ,tsff and

. ",d good orde< by

fucility

controlling, and properly disposing of contraband.

..t 4".

Components

:.=i)l

"
......
••

~
~

~~1

• :. l!
"

" ,:"
The
• for
contraband. Staff inventories, holds, and reports it when
necessary to the proper authority for action/possible
seizure.

[2J

ae
th" is gove<nment P' UP' '" is
evidence for potential disciplinary action or criminal
prosecution.

[2J

St,t! "tum, .P'V~ :" not needed,,'
to the
proper authority. Written procedures cover the return of

,eh

Altered property is
following
I~;" established procedures.

[2J

Hefore confiscating
items, the
Administrator or designated mvestigator contacts a
religious authority.

[2J

Remarks

St,ff
written
contraband that is illegaL

h",d

when

[2J

Documentation was reviewed
to confirm proper procedures
are followed for destroying
hard contraband.

Hard
is illegal (under criminal
) is
retained and used for official use, e.g. training purposes.

•
•

If yes, under specific circumstances and using
specified written procedures. Hard contraband is
secured when not in use.
Soft Contraband is mailed to a third party or stored
in accordance with the Detention Standard on Funds
and Personal Property.

r:~:e De~inee Han~~ook

nO~i~~~:~

procedures
and
property is identified and seized as contraband.
9.

. with Can;"e Unit, only ueo them
contraband detectIOn.

foc

s have not been used ..
Policy on the use of canines is
in place.

PART 2-6.

rzI

Meets Standard

o Does Not Meet Standard

ON/A

DRepeat Finding

Remarks: (Record significant/acts, observations, other sources used, etc.)
Contraband was properly managed in a fashion consistent with the standard.
b6,b7c
/10-15-09
.Viewer's Signature / Date

b6,b7c
b6,b7c

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G_324A Detention Inspection Form Worksheet for IGSAs - Rev: 07109/07

Page 21 of 136
-

PART 2

I TId,

. " ,taff,

UKUL

that pose a risk ofhann are prevented.

);1:1

'"
or assistant administrator and
l. The facility
depafiInent heads visit detainee living quarters and activity

g that facility

;; ~""':;
.$."

t'j

Components

,from hann

" and

• );I •

121

Remarks

areas weekly.

2. At least one male and one female
both males and females are housed.

3. Comprehensive annual
staffing needs and plans.

Mall

<In;: on duty where

analysis

4. Essential posts and
personnel.

a<e filled with

,no
"0
support that specialized training is
provided to the Control Center
Officers. Interviews with staff
confirmed the lack of training.

6.
7.
8.

Policy restricts

~lUll <1\;\;1:'1111

Center.

Detainees do not have access to the

Center.

" Ibe Control Contee.
Communications
.
and
and
will be
.;:
by a secure, well-equipped, and continuously
control center.
Data
10. The
I Centee

.l.

,,;:tY

Cards (Form 0-74 or contract

II .. Recall1i,t,

121

bJ
bJ
bJ

D
D
U

U
U
U

121

, of

, Ib,cllrron' hom,

each employee. Phone numbers are updated as needed.

~2AM

offi,ec ,heck, Ibe ID of evecyone

entenng or eXltmg the faCIlIty.
15. All. visit,
electronically recorded.

16. The ["ility h" a ,ecuce,
17.v,uc,', monito, all
the facility.

I The ""lI1i,t h" Ibe ,,11 ph~ne
numbers for each employee that has
a government issued phone, but
does not have home telephone
nwnbers.

' watch ,,11,

emergency
13..
d
aho~' .~u'ine
be continually recorded
sItuatlons, an Wlusua mCI ents
in permanent post logs and shift reports.

14. The

121

,I Data ",d, wece
not found in the Control Center.

in a visitoe

system.

, traffic

pnd

lSI

121

.,3.2009. ,tafT

was making hourly watch calls. A
review of current logs confirmed
that employees are now making
half-hour watch calls.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for rGSAs - Rev: 07/09107

Page 22 of 136
.

- - ---

This:

'AND'

PART 2-7.
the community,

events that pose a risk ofhann are prevented.

... :;

~ .... a..

."
."

Components

18h·~dacility .. . .

ve Ie es to

•
•
•
•
•
•

.t.a ~

. : and,

;~!.og;,fal1·

areas of the facility. Each entry contains:

The driver's name
Company represented
Vehicle contents

lSI

23. Written procedures govern searches of detainee
units and personal areas.

lSI

24. Housing area searches occur at irregular times.

25. Security officer posts located in o r '
to
detainee living areas to permit officers to see or hear and
respond promptly to emergency situations. Personal contact
and interaction between staff and detainees is required and
facilitated.

lSI

26.

lSI

28. Living areas are
to
continuous staff
observation of cell or room fronts, dayrooms, and recreation
space.

lSI

29. Every search of the SMU and oth.,
documented.

ISJ

30. The SMU

31. All tools entering SMU will be inspected and
by the SMU officer prior to entering the housing unit.

lSI

Delivery date and time
Date and time out
Vehicle license number

facility visit

19.

se"eli each vehicle

me
and

leaving the f",..'H

I 20. The:
"J
a written t;' "J'
; to prevent
the introduction of contraband into the facility or any of its
components.

21. Tlie front

has a

type

with

interlocking electronic doors or grilles .

~~e~d

•

Remarks

.;!
••
Q

..'~J

remain
will ensure that
that public access is denied without proper

post orders for

I office< post.

27. Detainee movement from one area to
controlled by staff.

•

area is

units is

Written procedures are in pla.ce to
comply with this requirement.

I Log book"

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09107

Page 23 of 136

!
I
,

(AND

PART 2-7..
Thi, •.

, and,
s the '
" ~~ff, ,contractors,
is maintained and that events that pose a risk of harm are prevented.

'"
32 . The_,",;~:c_ h" afi

po jICy.

'" . ti
ti
:.!j! • :.! •
:> •

Components

~_'E
~

Remarks

..,

spec! les:

•

Posts to be inspected

•

Required inspection forms

•
•
•

Frequency of inspections

121

Written procedures are included in
the post orders.

Guidelines for checking security features

Procedures for reporting weak spots, in-consistencies, and
other areas needing improvement

~i'

his/her assigned area. The results are documented.

l2SI

ensure that I
; and a fui]'"e to
take corrective action are reported to the appropriate manager.

121

36. Tools bei~g taken into the secure area of the
~'.Y are
inspected and inventoried before entering and pnor to

121

accesses, and drains, etc. undergo frequent, irregular
. These searches are documented.

121

Walls, fences, and exits, including exterior windows, are
inspected for defects once each shift.

121

the

121

; i, kept on file.

34.

35.

departure.

37. Storage and supply rooms; walls, light and plumbing

39. Daily procedures include:

•
•

Perimeter alarm system tests.

•

Documenting the results.

40.

Physical checks of the perimeter fence.
areas receive

41. An offic". i,
II
f:' fa T
secunty lllSpectlOn process covers a areas 0 e Cl tty.

!~~iJ!:nt make monthl;-r.

and Chief of
IY

121 Meets Standard

.• ANI

ON/A

D Does Not Meet Standard

DRepeat Finding

" etc.)
110-15-/09
b6,b7c
Reviewer's Signature / Da

b6,b7c

•

"
FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention inspection Form Worksheet for IGSAs - Rev: 07/09107
Page 24 of 136

PART 2 - 8. FUNDS AND

e",u", that,

property i"

1 and ,

i~valuables, baggage and other persoauel property, and that contraband does not euter a detentiou ",;,i;~ .
Standard NA: (lGSA ONLY) Check this box if all ICE detainee Funds, Valuables and Property are handled
r by the ICE Field Office or Sub-Office in control of the detainee case.

.,t.a"

.t.a
:;: en= ,!l.:;: £ ~

Components

, fund, and
1.
stored. Detainee funds and
designated supervisor(s) only.

';' ...

"ue

10<

. I and
a" accesSIble to

121

2.
' large
are
in a
.
accessible to designated supervisor(s) or processing staff only.

121

FX1

I ~~i~.

Staff 8Oa"h and .

;" e'

the

of arriving detainees,

incl~d:~'::~~~:'_ee'o
and
,
<he Tn
unless otherwise

are p",ent. dW'illg . the
de:a~~~~,.funds and valuables during
.
the
" . Both officers verify funds and

emg'

detainee.

. I, the
.. u'i~go
form that meets th;ICE standard?

Staff. g;ves the
the'"
fo,,",
copies ill the dotailloe's dotent;on file and the pee,o",1
'up ny
.

121

The facility is an SPC.
The
a copy
(one of three sheets from the
original triplicate form) during
the booking process.

7. Staff
medical staff.

s w<;tten

121

to the

121

and their v'

are
9.
Chief of Security or equivalent.
10. Matt
to detainees.

121

to the

8. Staff
property for contraband.

~~Q';~·~h is inventor~:tzn a G-

Two

D
are only accessible to the shift
supervisor.

and

in the presence of the
instructed by the facility administrator.

14.

Remarks

T when

11. CDF/IGSA facility procedures for handling
property claims are similar to the ICE standard.

The facility is an Spc.

12. The facility attempts to notify an
that he/she left property in the facility.

•

By sending written notice to the detainee's last known
address; via certified mail;

•

The notice states that the detainee has 30 days in which
to claim the property, after which it will be considered
abandoned.

I 13.
I 14.

s from each

, for two
It i,
be
when removing/documenting the removal of funds from a
detainee's possession.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet fur IGSAs - Rev: 07/09107

Page 25 of 136

PART2-S.

ensures that,
.
personal
ris :
1 and I
L.~~ •
f.::~:luables. baggage and other p",onnol pmpe"y. and that contraband does not enter a detention fadlity.

Standard NA: (IGSA ONLY) Check this box if all ICE detainee Funds, Valuables and Property are handled
the ICE Field Office or Sub-Office in control of the detainee case.

...'" ..~

Components

'I>

......
• •
."

"'~1
~
l!
'"

15. Statl· i"ue and

property

121

• in a
e mltia s and star

121

,o,o,y G-"":..

[lg

121

every baggage/facility container with an 1-77,
in accordance with the ICE standard.

121

22. Staff
every container used to store property with
a tamper-proof numbered strap.

121

23. A
name, A1-77 number, security tie-strap
number,
number, property description, date issued and date returned.

IZJ

24. In SPCs, the Supervisory Immigration Enforcement
Agent, accompanied by a detention staff member conducts a
comprehensive weekly audit.

121

audits of baggage and non-valuable property as facility policy,
the audits occur each quarter and audits are verified and
entered in the log.

121

being

121

~nd

16. Stat!

the G-589 in

with the ICE standard.
~7 __Th:

:offi,e, : d'

; ~",h ~-589 : 1

G-589 logbook.
reeOT me u es
numbers of receipting officers.

19. The
20. The _,

, the;
ensures that:

•

Detainee funds are, without exception, deposited into the
cash box;

•
•

Every property envelope is sealed.

•

All sealed property envelopes are placed in the safe.

Large, valuable property is kept in the secured locked
",ea.
"taU, t~g~

I
!

' . Ii., estabh'hed,"

25. The

26. The

fadlit~

every

..,

released

ar~~~roperly i~vestigated

27. Staff
Claims
property claims.
missing or damaged property claim reports are filed.

•

Remarks

'I>

121

numerical order.

,,"d

pr~;~;;~ has been reported lost
or damaged .

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09107

Page 26 of 136

'AND.

PART 2

This
ih u'h::.

. .
.
.
nth, personnel property,
contraband does not enter a detention facility.
NA, (IGSA ONLY) Ch",k this box if aU ICE detainee Fnnds. Valuables and Property are handled
~~~the ICE Field Office or Sub-Office in control of the detainee case.

~:~andard

.......
~

Components

28. Every
property report completed in
accordance with the ICE standard on an 1-387 (or equivalent).
The Facility Administrator receives a copy and staff place the
original in the detainee's A-file, retaining a copy in the
detainee's detention file.

...• •'"'

Uen

"'~1
~
l!
=> en

IZI

IZI Meets Standard D Does Not Meet Standard 0

Remarks

NJA DRepeat Finding

Remarks: (Record significant facts, observations, other sources used, etc.)
Two line items were non-applicable because they specifically addressed IGSA's and CDF's.
b6,b7c

lO-15-.Jl2

b6,b7c

Reviewer's Signature I
b6,b7c

.or

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs _ Rev: 07/09/07

Page 27 of 136

PART 2-9.
ensures th~ ~~ety, security, and

SIr

.. ."

'yholdin

The maximum aggregate time an individual may be confined in a

Hold Room is 12 hours.

~l:;
~~

.s ~
en

121

I 2... The hold mom, ",,,l,,n, i?o:~~~o::~~,:; well

121

I 3"

121

Components

I 1.

The hold mom i,

,in,

a v;ithin dIe secure

perimeter.

well lit, and all activating switches

, The hold mom"ontrun
of detainees held.

'
the room.

g fo' the

I 4,

No
, dO: o,~e;, ,~~ated m,keshift
apparatuses are permltte mst e 0 rooms.

I 5,

. Hold mom wall, and

are escape and tamper

...,<liE!

are not held in hold rooms for more than 12

hours.

121

other at all times.

121

8,
are provided with basic personal hygiene items
such as water, soap, toilet paper, cups for water, feminine
items, diapers and wipes.

121

9.... If the hold room is not equipped with toilet facilities, an
officer is posted within visual or audible range to allow
detainees access to such on a regular basis.

121

s ar~;~v~_ a ~a~ down search for weapons or
10. A!l
contraband before bei;;1!: nh
. the hold room .

lSI

•

M,le and

Remarks

Measure Report cited
97 detainees were held in holding
rooms for more than 12 hours.
Approximately 18,200 detainees
were processed into the facility
during the past 12 months. This
was confinued by the AFOD.
Corrective measures were
implemented during the past year to
ensure detainees are not housed in a
holding foom for more than 12
hours. A review of available
documentation covering the past
three months reflected no incident
where detainees were held in the
holding room for more than 12
hours. The current security firm
providing supervision in the
holding room area has been in
service for approximately six
months.

sin th,

are segregated from each

booking area are used for each
gender group.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07109/07

Page 28 of 136

!-9.1
ThiSD e t e n t i o n , and

I in Hold Romm I
. The maximum aggregate time an individual may be confined in a facility's Hold Room is 12 hours.

.,..,..,.;;

••

Components

:'S

11. When the last,
,has boon,
is inspected for the following:

room

•

Cleaning.

•

Evidence of tampering with doors, locks, windows, grills,

l':l

.,.

~""';

z~l
~
l!

Remarks

'"
D

plumbing or electrical fixtures is reported to the shift
supervisor for corrective action or repair.

12.

•

'UKYJ

Th", is;

An officer assigned to the holding
room area is designated in the

There is a designated officer to remove detainees from
the hold rooms in case of fire and/or building evacuation,

evacuation ~~~ for e~~~~:~g the
emergency situation.

13. An
upon a

em"geney ",vi" is "lied'

14. Single occupant hold rooms
a
l of 37
square feet (7 unencumbered square feet for the detainee, 5
square feet for a combination lavatory/toilet fixture, and 25
square feet for a wheelchair turn-around area).
•

l':l

121

that a medical emergency exists.

If multiple-occupant hold rooms are used, there is an
additional 7 unencumbered square feet for each additional
detainee.

l~fue~~~~~~e~~·~~---t----~---t~The'~hO~ld,~omn~S~~~~j~i·~n1
;"ith1996 according to
plans

with stainles~t-;cl combination l~vatory/toilet fixtures'
modesty panels. They are:
• Compliant with the American Disabilities Act.

•
•

Small hold rooms (1 to 14 detainees) have at least one
combi-unit.
Large hold rooms (15 to 49 detainees) are provided with
at least two combi-units.

~7716~.~
drain(s).

121

reviewed and staff interviews. The
standard does not distinguish
between hold rooms designed
before or after 1998, but does
reference the ICEIDRO Hold Room
Design Guide. The Guide was not
available.

lih.fuee~howrldr~oo~mrus~ha~~e~flo~o'--r---~----~--~I~'ta~tt~~~fh~~ro~o~m~s;w~'r~e~
in 1996. The standard
D

states "Based on the ICE/DRO
Hold Room Design Guide, Hold
Rooms shall be designed and
constructed to comply with the
following criteria: Each Hold Room

shall ha;' floor

D
:,to:, .,uJ, (

d
tamees un er

•

The hold rooms used in this facility
were reportedly designed in 1996.

D
D

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G"324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

Page 29 of 136

SIN
~ ~fety,

This Detention

.
may be confined ill a

. The maximum aggregate time

.'E

H
:;:jl

Components

I 19.

~(und,.~.18) ".

ily held

I, and

'p'" from ,dulls, ""pI

for immediate relatives or guardians.

i.~ ... '"'"'
~ti

o :;: •

d Rooms

~;-Hold Room is 12 hours.

g firrthcr

Remarks

il'l

121

"'"

121

IlSI

121

I (manually
20. Each or by computer)
p::e~;t each detainee
"
placed in :a h~~~
cell.

•

The log includes the required infonnation specified in the
standard.

121

,meol10 'ny

a hold

room for more than six hours.

k
snac s,

''j~"v':'.

"UU

-AI,
Meal are served to juveniles
.with .
..
.
22.""y

•

."'

.<"

or JUice.

illl

of time in
.
temporary

will be housed in a manner that provides for his

or her safety and security.

I~~sl;te
I 24.

Be'o"

occupancy for the hold room will be

~eo'h

: in a foom, an otticer shall
individual 10 screen for obvious mental or

I 25.
I 26.

s to smoke ill a

. . s dosely
superVISIOn, to ensure:

e hold rooms

, <lIT."

•

Continuous auditory monitoring, even when the hold
room is not in the officer's direct line of sight, and

•

Visual monitoring at irregular intervals at least every 15
minutes, each time recording in the detention log, the
time and officer's printed name and any unusual behavior
or complaints under "Comments."

•

Constant surveillance of any detainee exhibiting signs of
hostility, depression, or similar behaviors.

PART 2-9.

t:2l

•

I All hold worns have the

Meets Standard

D Does Not Meet Standard

occupancy posted.

Documentation confinns visual
monitoring at 15 minute intervals.

..~o

DN/A

DRepeat Finding

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 07/09107

Page 30 of 136

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

•

The facility has multiple holding rooms in the Admission/Release area that are located in a direct line of sight by staff. All
lding rooms are equipped in a fashion consistent with the standard. Staff reported detainees had occasionally been held
the holding rooms for longer than 12 hours while awaiting their housing unit assignment. This practice has been
corrected and there was no documentation to indicate detainees are currently held in holding rooms for more than 12 hours.
b6,b7c
/ 10-15-09
Reviewer's Signature! Date

b6,b7c

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet fur IGSAs - Rev: 07109/07

Page 31 of 136

PART 2-10. KEY AND LOCK CONTROL
Thi,

,i
,
,,,
;

!
!

,
,

. by

. facility safety and

: that keY' and locks be

'" -I.- .... '";..
":;:.,
••- OI)$i
~~.s
.-lj

Components

lSI

The
or equivalent, has responsibility for
aU administrative duties and responsibilities relating to keys,
locks etc.

lSI

maintenance

lSI

. and procedures address the issue of
compromised keys and locks.

lSI

7. The security officer, or equivalent, develops policy and
procedures to ensure safe combinations integrity.

lSI

Non-autho,i"d locks (as
.
in the D
not used in detainee accessible areas.

lSI

10. The facility does not use grand master keying systems

lSI

I 2.

13.

,
The
0'
all employees in key and lock control.

14.

The
:',
0'
of all keys, locks and locking devices.
d'"
. .
mamtams
program an
documentation.

all

preventive

I 6.~,'y

I 8.

,Only dead bolt or dead lock functions are used in
detainee accessible areas.

lkeys ,nd10cks cutup

11. All worn or
disposed of
12. Padlocks and/or·

Remarks

1. The
"'.
n,
approved locksmith training program.

I and

Documentation confinns
compliance with this requirement.

~r~~:::lity

not used on ,,11 dooes.

revealed no
being used on cell doors.

13. The
t door lock~ to
' : liv~g quarters,
or areas with an occupant load of 50 or more people, conform

•

Occupational Safety and Environmental Health Manual,
Chapter 3

•

National Fire Protection Association Life Safety Code
101.

I ~e

k ..
act tty ey rmgs
secure area.

115.

•
•
•

•

<inpla"

k'to'l
d"ll
eys III use tS ocate III a

Observation confinued sufficient
keyboards in the Control Center.

I 'ings ace:

Identifiable
Numbers of keys on the ring are cited?
Keys cannot be removed from issued key rings

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07109/07

Page 32 of 136

PART 2-

AND wCK C",nKUL
,by
, that keys and locks be •

, w,;,;,; safety and

This·

.,t,g"

Components

:;=ill

I
{keys are

I 16.

..,

" .,'

I key.

They are located in an area that permits constant officer

•

In an area that does not allow detainee or public access.

. 20. The
. ;c,r has a key accountabilitYTh~O~~~" and
procedures to ensure key accountability.
keys are
physically counted daily.
I 21. All stait members are trained and held
adhering to proper procedures for the handling r>fi,

'"
0

121

IXI

121

Policy and procedures are clear and
specific on key accountability.

Key control training is part of the
annual refresher training
curriculum.

121

Policy and procedures are. l'
for the issuing of any restricted key.

Issued keys are returned immediately in the event an
employee inadvertently carries a key ring home.
When a key or key ring is lost, misplaced, or not
accounted for, the shift supervisor is immediately
notified.

•

Remarks

gun lockers are provided.

•

b2High

system.

. ds

18 .

I 19.

,
,

...~ ~'8l!

121

117. Tho;

for all areas of the

~
"-l,
...••

I and

Detainees are not permitted to handle keys assigned to
staff.

ac,

I 22 .. L".'k~ 'n~ .
'00
mamtame , an mventon .
I 23. E"h f"ility has '.
a staff member
officer.

' of:
. d~tie;'
. If not,
th, collateral
of security

who IS

~ :~~ ~~~:~~~:~c:;s;:~ ~n:~g.

121

25 .. The

of key ,ings into

121

24. The

,ings is not

authorized.

There is a full-time Security Officer
assigned to the facility.

'!()' KEY AI m
[;l Meets Standard

Does Not Meet Standard

DN/A

ORepeat Finding

Remarks: (Record significant facts, observations, other sources used, etc.)
b6,b7c
b6,b7c

10-15-09

Review,,'s Signature I Date

•

b6,b7c

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet fur IGSAs - Rev: 07/09107

Page 33 of 136

,
,

•

PART 2-11.

s the

!:'is.

;~~,ty.

"',:,d'

facility have

.. '"
~

Components

I. 0'.".
; a fmmal count at least once each 8 homs
(no less than three counts per day). At least one of these
counts shall be a face to photo count.

,saf~~, and good ome, oy

etamee accounta

.......
••'"

~~]

::;

'"
0

ll<J
ll<J

U
U

,oetole

and emergency

,";

, omd any oth"'d::;m ;rm , ... I
d
counts are praVl
a equate llltla an
foe
in count procedures, and that training is
periodic
documented in each person's
folder.

I while a fo,mal

3. Th"e is a systemfo,
·... each
those who are outside the housing unit.
counts in,

; take place •

, do not allow,

, in the count.

count folio,", each

recount.

I each,

7.
himlher as present.

cover

8.
counts.

Remarks

2.
cease or are strictly
count is being conducted.

1 lty.

;~ain~~s :n~oO~t_c~:t:; re~:rd ~~:;l

confirmed formal counts were

of the facility.
Initial orientation training and
annual refresher training is
provided on count procedures.

PAiIT2-1I~

Meets Standard

o Does Not Meet Standard

ON/A

ORepeat Finding

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

b6,b7c

10-15-09

Review,,'s Signa""e I

b6,b7c

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

Page 34 of 136

---- - - - -

---

PART 2-12.
This Detention Standard protects'
rand 1
'! ta~~l.i.o/.:
security post knows the procedures, duties, and responsibilities of that post

..• ·.$.g..
1li
•

Components

• :>! •
~
"
en

t:oJ

121

..
01
tis
" fo,
.
all ~ost Orders current ;;~h revisions that take place between
reVlews.

121

IXI

all Post O,d"

121

. has signed and dated the I"t

121

,toall staff.

Eve,y fixed post hasa set of Post O,de,s.

2. In SPCs rut~ .CDF!. Post 01decs Ole
requITed sIx-part folder format.
3. E"h set
' .. the latest
memoranda, etc.) and revISIOns.

in the

insOlts

I 4:. _One.

: of Post O,de"

, and.

OooutS

,m.u ""

~han!:::.

f"ihty

Th.'fucihty

A Post 01de" maste' file is.

I. page of every section.

t:oJ

secure from

121

at the

121

11.
ensure that
the Post
Orders, regardless of whether the assignment is temporary,
permanent, or due to an emergency.

121

12. In SPCs and cms,. each time an omcee
.
a
different post assignment, he or she is required to read, sign,
and date those Post Orders to indicate he or she has read and
understands them.

121

13. Anyone assigned to an anned post qualifies with the post
weapons before assuming post duty.

121

14. Post Orders for armed posts, and for posts that control
access to the institution perimeter, clearly state that:
• Any staff member who is taken hostage is considered to
be under duress, and
• Any order issued by such a person, regardless of his or
her position of authority, is to be disregarded.

121

t01

121

: units track the daily event

121

I~·.

11 'ti:::;. Post O,de" and
etamees at a

~~~f;~~ ,Of the

, Post O,de" a"
secure fr'o~ detainee access.

15. Post U,de" "" "med posts
16. The Post "'dees ""
schedule.

~7.
og.

Th P :tU~~l,~:\ I d s."co'd~ll
. . . "~a
me u e tnstructlOns on mamtammg t le
e ost
logbook.

•

1 officer

oy'

Z~-

:>!.a
en

'0,""-

Remarks

Th~'d
utI Ize .

fold" fOlmat is not

w.""

Review of housing unit post orders
confirmed compliance.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Delention Inspection Fonn Worksheet for IGSAs - Rev: 07109/07

Page 35 ofl36

PART 2 -12. POST

121 Meets Standard

Does Not Meet Standard

ONIA

DRepeat Finding

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

10-15-09
Reviewer's Signature! Date

b6,b7c

(

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet fur JGSAs - Rev: 07/09107

Page 36 of 136

;OF

PART2-~

"nd ,tathnd '

Thi'.

t o'd'"

disposing of contraband.

J!l~

Components

::EJ!!

II)

L Th",e ,'ITe wdtten poliey and

,and,

'!!

z'&;n:s
~G.I-g

o::EJ!!

Remarks

II)

121

property in its

121

by metal

detectors routinely to control contraband.

121

ru'e
,only when the>'e i,
belief or suspicion that contraband may be
concealed on the person, or a good opportunity for

121

No strip searches were reported
during the past 12 months.

th",e db th ':'\.
dm·thealth
au onze y e act tty a mlstrator
(or acting administrator) on the basis of reasonable belief or
suspicion that contraband may be concealed in or on the
detainee's person.

121

No body cavity searches were
reported.

H. "D~y cells" are used for
only when
there is reasonable belief of concealment, with proper
authorization, and in accordance with required procedures

121

with a
, 9.
that may be evidence in
violation of a criminal statute is preserved, inventoried,
controlled, and stored so as to maintain and document the
chain of custody.

121

searches

r ..

"he
,'Poliey.""jdO'n
' ~~~I
east mtruSlve
~~y. "'~'''~1 practtca e, as
by the t}pe of contraband aud the method of suspected

introduction or concealment.

. £oliey, and

of the

,,;quITe, ,taff to ,.void
- ;~arches and to preserve the dignity

being searched, to the extent practicable.

,equITe ,taff

poliev and

. area, work
original order, to the extent practicable.

5.
,

ru'e pat

.,,"d

6. Strir,

concealment has occurred, and when properly authorized by a

Bod~".~itY'h
on y w en

IU.

s '" not u"d in

Canines are not used.

PART 2-13,

[gJ Meets Standard

Does Not Meet Standard

o N/A

DRepeat Finding

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

The El Paso Service Processing Center conducts searches of detainees in a fashion consistent with the standard.
b6,b7c
/10-15-09
Reviewer's Signature /

•

b6,b7c

.'{:;!/

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
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Page 37 of 136

and assaults on detainees, provide prompt and effective intervention and treatment for victims of sexual abuse and
and control, .
perpetrators of sexual abuse and assault

Components

:EJ!
II)

2. For
has been approved by the Field Office Director.

0
i!1O
ll~ Z1l

1{141-g
o:EJ!

Remarks

II)

I::'J

3.
review

4. All
refresher training, in the prevention and intervention areas
required by the Detention Standard.

available for detainees. (Required in SPCs and CDFs.)

are
upon
sexual assaultive and sexual victimization pOleenti,l
housed and counseled accordingly.

Information Brochure is
available to detainees in
Spanish and English. The
brochure is posted in the
housing units. The brochure is
also available in 12 other
languages if required.
screen all

•

presentation were reviewed for
new employees and for annual
training. The training
presentation complies with the
Detention Standard.

detainees for
assaultive
behavior. Medical staffscreen
for a history of sexual
victimization potentiaL
Housing assignments are only
made after these determinations
are completed.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
0-324A Detention Inspection Form Worksheet for IOSAs - Rev: 07109/07

Page 38 of 136

11,i,

PART 2-

"thaI' ,

'A~t~ou,~r;:t,~,~~~)I!WNT~~~--;;buiO

and assaults on detainees, provide prompt and effective intervention and treatment for victims of sexual abuse and

and control, discipline, and prosecute

of sexual abuse and assault.

Remarks

Components

9, All in,idenl, m ,,,u,1 abu,e

0 • •"ault

I In

by a

on a detainee have been documented in the past year.

I
10, All'
o.
, of "xual abm' m ."ault
by staff on a detainee have been documented in the past
year.

, Thec, i, plOmpt a n d '
, ,wh"" any
detainee is sexually abused or assaulted and policy and
procedures for required chain-of-command reporting.

Ih2" Whgh""'"thec,j"
thhexud,l, ",mn,
tda
t orou mvesttgation, ga er an mamtam eVI dence, an
make referrals to appropriate law enforcement agencies for
possible prosecution.
, 13, When thee' i, an
0. plOve~ ",xual
required notifications are promptly made.

•

one

report of a possible sexual
assault on a detainee by a
contract security staff member.
The case was still under
investigation at the time of the
inspection. The detainee
claimed that while sleeping he
may have been touched

, Th,
'
firrthec
~tated fuat it may also have
been a dream.

10vec _, .. ,
~ha,
been one report of possible
sexual assault by a detainee.
The file on the possible assault
was reviewed and an
investigation was still being
conducted at the time of the

The

";"""U" "'0 d'

The possible assault was
reported to loeal and federal
authorities for investigation.

I Event
A
Notification was sent to the
Office of Professional
Responsibility.

, the

m Ule prompt me lea
evaluation of the detainee by
civilian health care staff at a
community hospitaL
Additionally, an investigation
was conducted by local and
ICE authorities, and the
contract employee was placed
on administrative leave. The
facility reported the possible
assault through the chain of
command immediately.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

Page 39 of 136

~£s~~~
thathouse1CE7DRC~~~~~;;;;o
and assaults on detainees, provide prompt and effective intervention and treatment for
of sexual abuse and
and control, discipline, and prosecute the perpetrators of sexual abuse and assault.

Remarks

Components

are

treatment and

121

referred to
local hospita
treatment, and evidence
gathering.

assault is maintained, and such incidents are specifically
logged and tracked by a designated staff coordinator.

lSI

Does Not Meet Standard

Meets Standard

NfA

Prevention, and Intervention
program coorctinator, Sandra
Marinelarena maintains a file

ORepeat Finding

Remarks: (Record significant facts, observations, other sources used, etc.)
The facility's staff receives appropriate and regular training in the recognition and prompt intervention on behalf of
suspected sexual abuse or assault victims. Suspected victims are referred to appropriate community resources and
provided with counseling. Investigations are instituted promptly. Detainees with a history of sexually assaultive
.avior are identified through the classificatio process and housed accordingly.
b6,b7c
/10-15-09
Reviewer's Signature / D

b6,b7c

•

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G"324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

Page 40 of 136

,--------PART2-1S.:
.
staff, contractors, volunteers, and the commWlity from hann
certain
the general population in Special Management Units (SMUs) with an Administrative Segregation section for
for administrative reasons and a Disciplinary Segregation section for detainees segregated for disciplinary

Components

•;"0". pol~cy and

Remarks

IZl

il"I

management umts.

I 2.. A
.
i,pla.oed i n '
,tatu, in
Administrative Segregation only when there is documentation
that it is warranted and that no reasonable alternatives are
available.

act 0 ' _rule

'. . i, ~~ty of a
.' .
classified at a '
, '~~g_n~ , or
as defined in the Detention Standard on

Written policy is clear and specific
in regard to this requirement.

' level,
.

_.I'
I'
U! w-hHealth
d ~are.
d ' dare
llnmcutate y
en a etamee IS a illitte to an
SMU to provide assessment and review as indicated by health

It i~

I~'

6. The
of
to each cell or room
does not exceed the capacity for which it was designed.

7.
Cells and rooms are well ventilated, adequately lit,
appropriately heated and maintained in a sanitary condition at
all times.

8.
logs are maintained in SMUs to
record pertinent information on detainees upon admission to
and release from the unit, and in which supervisory staff and
other officials record their visits to the unit.

9.
t I~g is maintained in each SMU to record all
activities concerning SMU detainees (meals served,
recreation, visitors, etc.).
In SPCs and CDFs, the SMU log records the detainee's name,
A-number, housing location, date admitted, reasons for
admission, tentative release date for detainees in Disciplinary
Segregation, the authorizing official, and date released.

care protocols.

Th", rue,
, polioy ,nd
to ,onteol and
~~~SMU entrances, contraband, tools, and food carts, in
""><dan,,, with the Detention Standard on Facility Security

121

to
f when a detainee
is admitted to SMU.
Documentation reviewed supports
compliance.

_ ,r,

10. In SPC, and CDFs,,' sop,mte.log i,
. I in tho
SMU that all persons'
the unit must sign and record:

•
•

The time and date of the visit, and
Any unusual activity or behavior of an individual
detainee, with a follow-up memorandum sent through
the fucility administrator to the detainee's file.

Visits to SMU and a review of the
logbook con tinned compliance.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

Page 41 of 136

-~-

PART2-IS.:

.:;~ from the general Popul,tiO'-in S~':'~:;Mao,gement Unils (SMu~d!~. an
.

- ". .
" -1.-

ll~

Components

~~in~ained on each d~t~inee
•

.: from herm "'

secti;nc~tain

segregated for administrative reasons and a Disciplinary Segregation section for detainees segregated for disciplinary

Unit
in an SMU:

t •

~ri
is

~t~

• :. II

Remarks

In spes form 1-888 (Special Management Housing Unit

Record) is prepared immediately upon the detainee's
placement in the SMU.

•

In CDFs and !GSA facilities form 1-888 or a comparable
form is used.

In SPC"
• By the end of each shift, the special housing ooit officer

I2l

12,~Upo':. a.
th' ; ,elea"hfrm~ thes':'U.the
officer attaches
e entlre ousmg runt record to the
Disciplinary
Administrative
Segregation
Order
0'
Segregation Order and forwards it to Ibe Supervisor for
inclusion in the detainee's detention file.

I2l

,.po~i~y and
. : Ibe
detainees may retan:. in ea~h type of segregation.

I2l

records:

Whether the detainee ate, showered, exercised, and took
any medication, and

Any additional information, for example, if the detainee

•

compliance with this requirement.
Observation and staff interviews
verified adherence to policy.

medical condition, ha, exhibited suicidal 0'
h"
assaultive behavior, etc.
When a health care provider visits an SMU detainee, he
or she signs that individual's record, and the housing
officer initials the record after all medical visits
completed and no later than the end of the shift.

13. The" Me

14. Th"e Me
/ K~~~~ :~:h
privileges detainees may
type of segregation.
(In Administrative Segregation, detainees generally receive
the same general privileges as detainees in the general
population, as is consistent with available resources and
safety and security considerations.)

I2l

Policy and procedures are specific
in establishing privileges detainees
may have in each type of
segregation.

15.
. in
Segregation are
opportunities to spend time outside their cells (over and
above the required recreation periods), for such activities as
socializing, watching TV, and playing board games and may
be assigned to work details.

I2l

Documentation and observation
confirmed compliance.

16. Detainees in SMUs are personally observed at least
every 30 minutes in an irregular schedule and more often
when warranted for some cases (violent, mentally disordered,
bizarre behavior, suicidal) .

I2l

Documentation confinned
compliance.

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07(09107

Page 42 of 136

PART 2

15.

S~::.<I~

This

,,,"d!~'rut Adrnin:S~:V:ann~,

population in
1>
for administrative reasons and

.:::~;;

d;,

., '"11

t'"
;Iii

Components

""':1, see~ each

~ .......
'"
-1,

••
.s

"'~i

~ ~

Remarks

, daily.

I2l

' visits each SMU

I2l

A "v;ew u,
comp lance.

I2l

compliance.

I2l

.
was
. for any
.
or disallowed general visits for, a detainee in an
SMU who violated visiting rules or whose behavior indicated
the detainee would be a threat to the security or good order of
the visiting room in the past year.

I2l

17 .. Thoshiit

and holidays.
,

~\ The facility
at

. (01 ,

C.N,

19 .. A h"lth caco
' visits every
"
in an SMU
at least three times a week, and detainees are provided any
medications prescribed for them.
In

,pr,

Irm,

o,h

,01"

care professional visits the SMU at least once each workday
and questions each detainee to identifY any medical problems
or requests. Any action taken is documented in a separate
logbook, and the medical visit is recorded on the detainee's
SMU Housing Record (FornI 1-888).
20.
'
. in SMUs Ole
adequate meals per day,
population menu.

~ee nutritionally
from the general

' in SMUs may shave md show," tlrr" times
and receive other basic services (laundry, haiT care,
clothing, bedding, linen) on the same basis as the
general population.
21.

or m~ta~ health reasons
22. ?~Iy fOl d 'd
are
ellie such items as clothing, mattress,
bedding, linens, or a pillow. If a detainee is so disturbed that
he or she is likely to destroy clothing or bedding or create a
disturbance risking harm to self or others, the medical
department
notified immediately and a regimen of
treatment and control instituted by the medical officer.
, I,tt,,, th,
23.
; io ,n SMU may weit, and
same as the general population.

24. 'I
pnvl eges.

SMU

"tain

25.

•

f",

fur detainees segregated for disciplinary

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07f09107

Page 43 of 136

PART 2
.

15. SPECIAL MANAGEMENT

'. ,taff,. ,ont",t=,

u"",
. y from hann

s,and the

th~ ~~er~l population in Special Management Units (SMUs) with an

g , ...tam

section for

for adnllnistrative reasons and a Disciplinary Segregation section for detainees segregated for disciplinary

Remarks

Components

I 26.

was
for any
restricted or disallowed general visitation for a detainee in
Administrative Segregation status because the detainee was
charged with, or committed, a prohibited act having to do
with visiting guidelines or otherwise acted in a way that
indicated the detainee would be a threat to the orderly
operation or security of the visiting room in the past year.

I 27. Und...

i, a

!ZI

121

I 28 " In SPdC,' ..'nd
.
CDFd~"
' m
'. _"
yaohd
VIO1ent an
;r-~: ~ etamees are not penmtku to use t e
V.

visitation room ourmg normal visitation hours.

I 29 .. In SPC, and CDF,. violent and .
ace
limlted to non-contact VISIts and, ill extreme cases, not
pennitted to visit.
in SMUs are not denied legal

I 30. .
vlsttatlOn.

~ere

are policy and

for a situation where

"~~i~~ security' pre;autions for legal visitation have to be

and for advising legal service providers and
assistants prior to their visits.

121

I 32.

sin SMUs are allowed visits by members of the
clergy, upon request; unless it is determined a visit presents a
risk to safety, security, or orderly operations.

I 33.

! in SMUs have access to reading
including religious materials. In SPCs and CDFs, the
Recreation Specialist offers each detainee soft-bound, nonlegal books on a rotating basis, provided no detainee has
more than two books (excluding religious material) at any
one time.

I 34.
in SMUs have access to I:gal
, in
accordance with the Detention Standard on Law Libraries and
Legal Material.
Detainees are pennitted to retain a
reasonable amount of personal legal material in the SMU,
provided it does not create a safety, security andlor sanitation
hazard. Detainee requests for access to legal material in their
personal property are accommodated as soon as possible and
always within 24 hours ofa detainee's request.

•

lSI

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0-324A Detention Inspection Form Worksheet for IOSAs - Rev: 07109/07

Page 44 of 136

PART 2

Thi'.

~:::

15.

from the "Me';'

...

"'~
$ •

Components

-~ -t i...

::;:S t!::;:~

Remarks

Except for detainees with
documented security concerns,
detainees are escorted to the Law
Library. Services and legal
materials are provided upon request
when compelling security concerns
have been identified.

I 35.

.dn
Segregation or Disciplinary
Segregation have the same law library access as the general
population, unless compelling and documented security
concerns require limitations.

I 36.

. g c..-tam

section for
and a Disciplinary Segregation section for detainees segregated for disciplinary

, to, le."al

Policy and

121

Ito be

,by

I, staff,. contractors.
I,.and the
in Special Management Units (SMUs) with an

certain circumstances.

I 37. H,
•
•
•

Supported by compelling security concerns,
For the shortest period required for security, and

Fully documented in the SMUhousing logbook.

ICE/DRO is

I 38.

, the

",I, nfo'

law library access is denied.

" in tho SMU i,

,from th,

to ensure
.The !~i!it~u~~S b~o~~~t a~'!rrt never participate m
activities in the same location at the same time. (For
example, recreation for detainees in protective custody is
separated from other detainees.)

I 40.

; in the SMU ruee
i ,t lea" one hom of
recreation per day, scheduled at a reasonable time, at least
five days per week. Where cover is not provided to mitigate
inclement weather, detainees ace provided weatherappropriate equipment and attire.

: 41. "lhe recreation privilege is denied or suspended only ifit
would lUlfeasonably endanger safety or security.
Ordinarily, a detainee is denied recreation privileges only
with the facility administrator's written authorization that
documents why the detainee poses an lUlfeasonable risk even
when recreating alone. For an immediate safety or security
situation, the shift supervisor may verbally authorize denial of
an instance of recreation.
When a detainee in an SMU is deprived of recreation (or any
usual authorized items or activity), a report of the action is
forwarded to the facility administrator.

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07109107

Page 45 of 136

from the
I fc

reasons and a Disciplinary

section for detainees segregated fur disciplinary

Components

42. "Ti;- case oro

denied

Remarks

"is

reviewed at least once each week, as part o~~ the reviews
required for all detainees in SMU status. The reviewer
documents whether the detainee continues to pose a threat to
self, others, or facility security and, if so, why.

43. Denihall of
.
h' f;e;:;!~'dmOfe. than 15 days
d ~e
requIres t e concurrence
t e L-;~:"':~ ~ a mmlstrator and
health
It is expected that such denials shall rarely
~O""

W'"'

f2l

IZl

Written procedures are in place to
comply with this requirement.

The facility notifies ICEJDRO when a detainee is denied
recreation privileges for more than 15 days.
44. Ordinarily, detainees in Administrative Segregation have
telephone access similar to detainees in the general
population, in a manner consistent with the special security
and safety requirements of an SMU.
Detainees in Disciplinary Segregation may be restricted from
to make general calls as part of the
.
however, ordinarily, they are permitted
make -_':' and/or free and legal calls as described in the
Standard on Telephone Access, except for
compelling and documented reasons of safety, security, and
good order.

I ~~~~., telephones

45.
, a Wfitte~ o,d" i
j and
I by
a supervisor before a detainee is placed in Administrative
If exigent circumstances make
that
Segregation.
impracticable, the order is prepared as soon as possible.
A copy of the order is given to the detainee within 24 hours,
unless delivery would jeopardize the safety, security, or
orderly operation of the facility.

If the segregation is for protective custody, the order states
whether the detainee requested the segregation and whether
the detainee requests a hearing.
The order remains on file in the SMU until the detainee is
released from the SMU, at which point the releasing officer
records the date and time of release on the order and forwards
it to the chief of security or supervisor for the detainee's
detention file. (An Administrative Segregation Order is not
required for a detainee a'Waiting removal, release, or transfer
within 24 hours.)

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07109/07

Page 46 of 136

•

PART 2-15.

This

:::~

from the general population in

"UNU.

S~:C~:;Management Units (SM~~th an

'h~"y

.'0

segregated for administrative reasons and a Disciplinary Segregation section for detainees segregated for disciplinary

...••
."

;
."

Components

:;1:1
00

46. The" rue,

,;,.$.g
... "" ,:;
Z

Remarks

•Q :;I ~•

w>"itten p,",educe, fo, the

regular review of all detainees in Administrative Segregation.

A supervisor conducts a review within 72 hours of the
detainee's placement in Administrative Segregation to
determine whether segregation is still warranted. The review
includes an interview with the detainee, and a written record
is made of the decision and the justification. In spes and
,

CDFs, Fonn (1-885) is used.

me ",e

. but

not at the detainee's request, continued detention requires the
authorizing signature of the facility administrator or assistant
facility administrator on the 1-885.

lSI

I 49. lf~. 30';' h" b~n ~n
th.·
the. fa
more an
ys an 0 ~ects to IS status,
CI Ity
administrator reviews the case to determine whether that
status should continue, taking into account the views of the
detainee. A written record is made of the decision and the
justification. A similar review i, done every 30 days
thereafter.

lSI

50. When a detainee has been held in
..
Segregation for more than 30 days, the facility administrator
notifies the Field Office Director, who notifies the ICEIDRO
Deputy Assistant Director, Detention Management Division.

lSI

When a detainee has spent seven days in Administrative
Segregation, and every week thereafter for the first 60 days
and at least every 30 days thereafter, a supervisor conducts a
similar review, including an interview with the detainee, and
documents the decision and justification.
reviewing authority who concludes a detainee should he
from Administrative Segregation, submits thot
to the facility administrator (or designee) for
approval.

47. A copy of the

,"nd'

fm ",h ceview

is given to the detainee, unless, in exceptional circumstances,
this provision would jeopardize security. The detainee is
given an opportunity to appeal a review decision to a higher
authority within the facility.

I ~8.

d~y, in
"
After seven
Segregation, the detainee may
the right to appeal to
",d
the
facility
administrator
the
conclusions
recommendations of any review conducted. The detainee
may use any standard form of written communication (for
example, detainee request form), to file the appeaL

'-to,

Written procedures are in place to
comply with this requirement.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G·324A Detention Inspection Fonn Worksheet for IGSAs· Rev: 07/09/07

Page 47 of 136
-

PART 2-15.
detainees,

" and the
y from hann by
g certain
detainees from the general population in Special Management Units (SMUs) with
~;~ti-;n' for
. segregated for administrative reasons and a Disciplinary Segregation section fur detainees segregated for disciplinary

Remarks

Components

writing,

the

Deputy

Assistant

Director,

IZI

121

!21

Management Division, for consideration of whether it would

be appropriate to transfer the detainee to a facility where he
or she may be placed in the general population.
I 52 A
ds p["ed in
order of the Institutional

I fc

"i1;

"~..:.o.~{~::~~Y b,;:
.ntl~t:l

~:_~ J~

act.
The maximum of a 60 day sanction in Disciplinary
'"

of a

confirmed compliance.

for a violation associated with a single incident.

I 53.

Aft" the fue' 30 days in
'::1
the
facility administrator sends a written justification to the Field
Office Director, who may decide to transfer the detainee to a
facility an could be placed in the general population.

I 54.

Be",,, a
e i~ pl~oed m . .
Segregation,
written order is completed and signed by the chair of the
(or equivalent). A copy is given to the detainee within
14 lhmus(m.t"" ([eliv,,~ would jeopardize safety, security, or
the orderly operation of the facility).
The IDP chainnan (or equivalent) prepares the Disciplinary
Segregation Order (1-883 or equivalent), detailing the reasons
for Disciplinary Segregation and attaching all relevant
documentation.
When the detainee is released from the SMU, the releasing
officer records the date and time of release on the
Disciplinary Segregation Order, and forwards the completed
order to the chief of security or supervisor for insertion into
the detainee's detention file .

•

121

A review of detainee files
confirmed compliance.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

Page 48 of 136

PART 2-15.

" ". . 0

, s~~;. contractors,

Thi"

S ,by. .

in Special Management Units (SMUs) with an

from the

egregabon sectIOn or
reasons and a Disciplinary Segregation section for detainees segregated for disciplinary

.::::~ segregated for

..
..
"q ~
'" .. '"
~

Components

:>l!!

z-zl;
"'~i
~ :>l !!

lSI

Remarks

55, The facility has implemented written procedures for the

regular review of all Disciplinary Segregation cases.
A supervisor interviews and reviews the status of each
detainee in Disciplinary Segregation every seven days and
documents his or her findings on a Disciplinary Segregation

Review Form (1-887).

At each formal review, the detainee is to be given a written
copy of the
; , unl"" ,

officer's decision and the basis for this
,would b,

Written procedures are in place to
;,h

The reviewer may recommend the detainee's early release
upon finding that Disciplinary Segregation is no longer
necessary to regulate the detainee's behavior. Early release
and return to the general population requires approval of the
facility administrator. All review documents are placed in the
detainee's detention file.

PART 2-15.

0""

[Zl Meets Standard

D Does Not Meet Standard

Remarks: (Record significant fa

ON/A

DRepeat Finding

er sources used, etc)
b6,b7c

b6,b7c
10-15-09
Reviewer's Signature /
b6,b7c

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G"324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 07109/07

Page 49 of 136
-- ---

PART2-16.",

"u~

This Detention Standard enhances security, safety, and orderly facility operations by encouraging and requiring
direct and written contact among staff and detainees, as well as infonna1 supervisory observation of living and working

It also requires the posting of Hotline informational posters from the Department of Homeland Security Office of the

Inspector General.

.I!~

''''
:E~

Components

GlC

1. Th,
Fiold om".
,nsm" thot
weekly announced and lUlannounced visits occur.
, Staff
I 2. kl .: "~t~ ano

Zi~

$:;

o
c

J!!

121

• and

121

, for use

121

fot

121

of the

121

from a

121

.
are
.
in writing upon
I U.
admission to the facility of their right to correspond with
ICEIDRO staff regarding their case Ot conditions of
confinement.

121

11. OIG Hotline Informational Posters are mounted in all
appropriate common areas (recreation, dining, etc.) and, in
SPCs and CDFs, in all housing areas.

121

wee Y VISits WIt

etamees.

1 visits; .,

lin

areas.

I 4.

" : ICE staff

condition~'~f confinement.

and note current
: Forms are

~~ ICE/DRO detainees.

6. ;h;'s;:;:~?~,eats
sta
as

7. A secure box is
in an
detainee's to place their Detainee Request Forms.
~IY

ICE staft· ato abl' to

. , th'

box containing Detainee Request Fanus,

stalf

to a

facility within 72 hours and document the response in a log.

12. Daily telephone serviceability checks are documented in
the housing unit logbook.

PART 2-16.:

121 Meets Standard

D Does Not Meet Standard

Remarks

Notification is provided in the
detainee handbook.

Housing unit logbooks revealed
serviceability checks were
documented daily.

'"
D N/A

DRepeat Finding

Remarks: (Record significant facts, observations, other sources used, etc.)
b6,b7c
10-15-09
Reviewer's Signature / Date

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection FOim Worksheet for IGSAs - Rev: 07109/07

Page 50 of 136

PART 2-17. TOOL
protects detainees, staff, contractors, and
, tram harm
) ~rder:y tac~l.ity
by maintaining control of tools, culinary utensils, and medical and dental instruments, equipment, and supplies.

., '"

...
.t-a
~iI;; ~.:; £ ~
~

Components

1.
~} Th,,, i, ,n
..
who. i,
responsible for developing a tool control procedure and an
inspection system to insure accountability.

I2J

~
~

"",

i,
I 2. If th,
outside the secure
perimeter, the warehouse receives all tool deliveries.
If the warehouse is located inside the secure perimeter the
facility administrator shall develop site-specific procedures,
for example; storing tools at the rear sallWort until picked

up and receipted by the tool control officer.

4. A me",1 0' pl"'ioohiti"ak'" m,
, fo' all 'ools
issued, and when a tool is issued from a
board the
receipt chit shall be visible on the shadow board.
Tool'

All tools are received at the
warehouse which is located
outside the secure perimeter. Th,
tool control officer is the only one
authorized to receive tools from
the warehouse.
On-site observations and a review
of documentation continued
compliance.

The tool

control officer immediately -places certain tools (band saw
, 'UU"! m ,ocmo'
OW"O', u'" "'" uu •
3. (MANDATORY) The use of tool,s, keys, medical
equipment, and culinary equipment is controlled.

I2J

Remarks

121

I2J

121

I fo",

Facility Maintenance Department
Medical Department
Food Service Department

•
•
•

Electronics Shop
Recreation Department
Annory

7.1h"

individual site confinned
compliance

',"1 for the regular inventory of all

tools.

•

The policy sets minimum time lines for physical
inventory and all necessary documentation.

•

ICE facilities use MIlS bar code labels when required.

I2J

Policy and procedures are in place
and documentation confinns
adherence to policy.

121

On-site observations and a review
of documentation confinued
compliance.

I2J

The facility has a tool classification system. Tools are
classified according to:
Restricted (dangerous/hazardous)
Non Restricted (non-hazardous).

9. Department heads are responsible for implementing
proper tool control procedures as described in the standard.

•

""h

, posted on ,11 tool

6. Tool
'co
boards, tool boxes and tool kits.

•
•

Observation visits to each
individual site confmned
compliance.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
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Page 51 of136

PART 2:t7.TOOL (

Th;, [

!"oteot,
.
• ,udY, oontr3OtN,. and
, from hmn and,
.
tOn~~:1~.r3OHity
by maintaining control of tools, culinary utensils, and medical and dental instrwnents, equipment,
supplies.

., ..
~

Components

10. There are F
' and
in. p~~ce ,to ensure
that all tools are properly marked and readily identifiable.

II. Ihe.

san

n'"

'<i

Z~·

.$-l!
~:E ~

!!!

Remarks

121

"nd,
of documentation confirmed that
procedures are in place.
Approximately 100 tools were
checked for compliance and two
tools in the Electronic Shop were
identified that did not have the
proper marking. Upon return to
the location both tools had been
appropriately marked.

121

On-site observations and a review
of documentation confirmed
compliance.

121

121
121
121

001 "omge

•

The system
accountable.

•

Tools are stored on shadow boards in which the
shadows resemble the tool.

•
•
•

Shadow boards have a white background.

that all

ensures

stored tools

Restricted tools are shadowed in red.
Non-restricted tools are shadowed in black.
Commonly used tools (tools that can be mounted) are
stored in such a way that missing tools are readily
noticed.

""i"

12. Tool,
from
removed from shadow boards.
13. Tool, not
locked drawer or

to a

hove the;'
, boaed aee "a"d ill a

14. St,dle pack"" "0"0 uno" look and key.
,fmthe'
,of tool, to
15. Eaohfuoihty hue
staff and detainees.
, th, ;"u,
I 16. Th,,, are
" , and
to
of lost tools~- Th;'poHcy
procedures include:

•
•
•

Verbal and written notification.
Procedures for detainee access.

[jj

121

Necessary documentation/review for all incidents of
lost tools.

17. Meaken 0' worn om
man

.,' 1 and
"e
manner.

18. All
m oontract;:epa;" and
workers under contract with ICE, or other visitors, submit
an inventory of all tools prior to admittance into or
departure from the facility. The inventory is reviewed and
verified prior to the contractor entering/departing the

During the past 12 months one
missing tool was reported. A
contract employee was disciplined
for failure to follow the
established written procedures for
reporting a lost tool.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet fur IGSAs - Rev: 07/09/07

Page 52 of 136

PART 2-17_ TOOL ,-v,uaVL

This.
• h

' st.a:ff, contractors, .. ~u
I ~~nn and I
.
maintaining control of tools, culinary utensils, and medical and dental instnunents, equipment,

.. .
~

Components

"!;

Z~"

.~-i!
~ ~ ~

Remarks

A 100 too' wa'" '0", used in 'ho
loading dock area of Food
Services was not identified as a
restricted tool. Additionally, the
water hose was not on the facility
restricted tool inventory list or
tagged properly. The hose was
reported as being secured daily in
a locked storage area and was
identified on a general inventory

19. Hoses longer than three feet in length are

a restricted tool.

::;'

121

J;,

implemented on the last day of the
inspection to comply with the
restricted tool requirements. The
hose was identified as a restricted
tool, properly marked, and has
been added to the Food Service
restricted tool list.
20. Scissors used for in-processing detainees are tethered
to the furniture (e.g. table, counter, etc.) where they are

121

PART 2-17. TOOL CONTROL
Gl Meets Standard

D Does Not Meet Standard

DN/A

DRepeat Finding

Remarks: (Record significant facts, observations, other sources used, etc.)
The facility has an established tool control management system in place, but there was one "Restricted Tool" that was not
properly identified. The staff had not properly identified a water hose located on the loading dock of the Food Services
area as a "Restricted Tool". The hose was not accounted for in a fashion consistent with the standard. Other areas
uant to the standard.
reviewed were found to be properly
b6,b7c

10-1

b6,b7c

Reviewer's Signature I D

b6,b7c

•

tI"

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-J24A Detention Inspection Form Worksheet fur IGSAs - Rev: 07109/07

Page 53 of 136

PART 2-18.

EAND
Ho,,:, oft"
••ffo",
o~_ others, for prevention of escape or serious property

This Detention
. ."t,ff,o
_,
Hof;
have failed, and only for protection of sel£:
.
, or to maintain the security and orderly operation of the f""mt .

". ~

Remarks

Components

~~liCY.

., The ".ility h" a U" of Fo"e

I 2.

.po~'2'
stat!
in an
immediate-use-of-force situation without a supervisor's

presence or direction.

I 3.

When 'lie
, is in ,n "eo that is
.oo be
isolated (e.g., a locked cell, a range), posing no direct threat
to the detainee or others, policy requires that staff must try
to resolve the situation without resorting to force.

I Imme
4
d' e ".!oli:Y
late
_~_

a~se;,s 'bh[" .

IS leaSt e 10 most cases.

I :vOi~:c:~:~t~edures.
•

"the< than

s to the

Ranking detention official, health professional, and
others confer before every calculated use of force.

lSI

Specific policy and procedures are
in place fOf the Use of Force.

I 6.

When a detainee must be forcibly moved andlor
restrained and there is time for a calculated use of force,
I uses the Use-of-Force Team Technique.
Under staff supervision.

Staff members are trained in the
Use-of-Force Team Technique.
S. All use-of-force
reviewed.

are

, of the
ood

All"", u, MC" .
d ood
at ,
forwarded for review use of force
minimmn, shall include the medical examination through
the conclusion of the incident. All calculated uses of force
incidents must be audio visually recorded in its entirety
from the beginning of the incident to its conclusion. Any
breaks in recording, e.g., dead batteries, tape exhausted, are
fully explained on the video.

staff interviews confirmed
compliance.

10. Staff,
•

Does not use force as punishment.

•

Attempts to gain the detainee's voluntary cooperation
before resorting to force

•

Uses only as much force as necessary to control the
detainee.

•

Uses restraints only when other non-confrontational
means, including verbal persuasion, have failed or are
impractical.

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention inspection Form Worksheet for IGSAs - Rev: 07/09/07

Page 54 of 136

, -I".
, This

; AND

1~~~O':;:~';'or,IIpreventIon
, .

"talf to us.

have failed, and only fur protection of self,
, or to maintain the security and orderly operation 01 I

, or

...••.. • .

Authority as medically

I2J

,T.runs ~Jlow written
at attempt to prevent illJury an exposure to

I2J

'" II

I!.

m,y ?nly b •.. us.•dfor
'

. ,resolv.,
escape or senous property

Remarks

purpos.s

12. \~'AN~ATORYJ

proce ures

....

;;l., ~~]•

Components

when authorized by the
necessary.

communicable disease(s).

13:

with using

pomt restramts

•

Dressing the
temperature.

•
•
•
•

A bed, mattress, and blanket/sheet.

detainee

appropriately

for

the

Checking the detainee at least every 15 minutes.
Logging each check.

I2J

Repositioning detainee often enough to prevent
soreness or stiffhess.

Written policy is in place that
complies with all of the
requirements of this standard The
facility does not currently use four
or five point restraints.

Medical evaluation of the restrained detainee twice per
eight-hour shift.
When qualified medical staff are not immediately
available, staff position the detainee "face-up."

14 Th~
POSlttO

S~ift~r

the

con 1tlOn every two ours.

He/she allows the detainee to use the restroom at these
times under safeguards.
15.

, check"

~6~i~:I'staff once the detainee is und~ control.

contact

17. When the
..
non-lethal weapons: .OJ

use of

•

Medical staff is consulted before staff use pepper
spray/non-lethal weapons.

•

Medical staff reviews the detainee's medical file
before use ofa non-lethal weapon is authorized.

18.
.
F.orce
~h:n not in use are
stored in areas where access is limited to authorized
personnel and to which detainees have no access .

•

c~~;~~~~;iih ~ll ~~~Uir:mn:~

of
this standard in case the
operational practice changes and
restraints are applied.
restraints in the'iast 12 months.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
I

G-324A Detention Inspection Form Worksheet for IGSAs· Rev: 07/09/07

Page 55 of 136
,

Thi'.

PART2-IS.USE'
• staff to use necessary
[ for~:, after all
: efforts to
resolve a
have failed, and only for protection of self, detainees, or others, for prevention of escape or serious property
or to maintain the security and orderly operation of the facility.

. '""

~.a

Components

19. If
.
Fo,,,
Special Management Unit

(SMI::

$ •

:E~
M' ,tm,d in th,
they are stored and

maintained the same as Class R tools.

20. Sp,.oi~l

121

~-~

ti
,!:;!£ ~
~

takon

wh,n

121

to "vi'~ any "" of fo,,, and
of restramts.

121

I 24. All
··.in,
confrontation-avoidance techniques and the use of force to
control detainees.

I2J

121

~~;n

Medical personnel are consulted

,g',";i' worn

; with

Oll" '

22. Staff

ovary "" of fo,,,.
type of restraints was used during the incident.

~~ n~n~:outine

..
f i ' ~nd "aff
mtervlews con Irm t 1at
b2High

121

•

Remarks

what

Medical staff is consulted prior to
restraining a pregnant detainee.

Tho ",o.u,

, polioy i"

m regard to the proper use of
restraints.

. . Spocialized training i, given to offioe" '","'ing they
certified in all devices
for use.
I 25. All "aff
to "" DC 'pmy
not only in its use, but also in the decontamination of
individuals exposed to it. This training must be documented
in the staff training record.

26. The "" 0«
purposes only.

Ito

27. The
'"
I in the "" o( ,ott
and hard restraints.
28. In spes, the Use of Force form is used. In. other
facilities (IGSAs! CDFs) this form or its equivalent is used.

PART 2

!2l Meets Standard

The ",Oi~ity do,"
..
canines for any purpose.

IS. USE OF FORCE AND RESTRAINTS

D Does Not Meet Standard

DN/A

DRepeat Finding

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

10-15-0
ReVIewer's Signature / Date

b6,b7c

<J(f,

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
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Page 56 of 136

•

SECTION III

•

ORDER STANDARDS

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G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07109/07

Page 57 of 136

PART 3-

Thi' _

rule~ and regulations and ~~~:::::~iPI~~';:~~tionS' to contr~:o~e behavi~b%fthose who do not.

" '":;
t'"

Components

:;:~

1.1he t.e~lity h" ""itt", - -

')"tem u'mg

progressive levels of reviews and appeals.
~.

The facility rule: '
e capnClOUS or feta tatory.

~~e fOll~Wing sanctions:
•

' with

Remarks

121

""fffrom

corporal punishmen t

•
•
•
•
•
•

~ ....
••""
"'~El
~ ~ .s

' to

o"n

clothing deprivation

121

bedding deprivation

Policy is clear and specific in
establishing what sanctions are
prohibited and cannot be imposed.

denial of personal hygiene items
loss of correspondence privileges
deprivation of legal access and legal materials
deprivation of physical exercise

The rul" dO~ d'
__
d Md
. ed
f~;
are e ne ill wntmg an commUIllcat to a
detainees verbally and in writing.

121

The information can he found in the
detainee handbook and all housing
units.

121

These topics are posted and
included in the detainee handbook.

121

I 5. The
items
posted in
and English or other dominate languages used in the

•

Rights and Responsibilities

•

Prohibited Acts

•

Disciplinary Severity Scale

•

Sanctions

6.. When mino, rule'

acts occur,

infonnal resolutions are encouraged.
7.
. Md Noti" of
forwarded to the designated supervisor.

U . nee. .

8. 'd

nee

I ;'thin 24 h(" ~~ the

IllCI ent.
The mt DISClP mary ommlttee UD
equivalent does not convene before investigations end.

9.. Mfr

mlllor m actlOllS.

•

p,oeessi,u,ed to

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
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Page 58 of 136

PART 3pmmotes, eo", ,nd orderlyliving'

t for ,

, by:

rules and regulations and imposing disciplinary sanctions to control the behavior of those

who do not.

' to

Remarks

Components

10. A
panel (or equivalent in
infractions. The panel:
•

Conducts hearings on all charges and allegations referred
by the UDC

•

Considers written reports, statements, physical evidence,
and oral testimony

•

Hears pleadings by detainee and staff representative

•

Imposes only authorized sanctions

11. A ----staff representative is available7
detainee facing a disciplinary hearing

[2J

for a

12. The facil~ty'
postponements or
continuances when conditions warrant such a continuance.
Reasons are documented.

[2J

13. The dmation of punishment set by the Facility
as recommended by the disciplinary panel
not exceed established sanctions. The maximum time in
i"ipli",,·y segregation does not exceed 60 days for a single
offense.

CSJ

14.
govern the
source information.
Procedures
recognizing "substantial evidence".

~ of
include criteria

committee/panel reports, etc., are

for

and distributed

as required.

Current policy establishes 60 days
as the maximum sanction that can
be imposed for a single offense.

Distcibution of']l fin,]
documentation for the disciplinary
process is coordinated through the
classification officer.

PART 3 -19. DISCIPLINARY SYSTEM

1Zl Meets Standard

o Does Not Meet Standard

D NJ A

DRepeat Finding

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

b6,b7c
10-15-09
Reviewer's Sigo,ture/D,t,

•

b6,b7c

(

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07f09/07

Page 59 of 136

•

SECTION IV

CARE STANDARDS

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
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Page 60 of 136

PART 4, 20. FOOD

ensures .that.
.
hygienic food service operation.

i and

Components

Remarks

The food .service program is under the .dire~_t supervision
of a professionally trained and certified Food Service
Administrator (FSA). The Responsibilities of cooks and
cook foremen are in writing. The FSA detennines the
responsibilities of the Food Service Staff.

The Cook Foreman is on duty on days when the FSA is
off duty and vice versa.

u«
i thdme. "
Food Service A mlstrator
(AFSA) are certified and have
Food Managers Certification.
In addition they have 23 years
and 11 years of professional
food service management
experience respectively.

is on
The AFSA or
duty each day. During
a Cook II is
as the
"Lead" in food service.

The FSA
that

food ",vice
'. with training
.al~ ,,-1 issues. In ICE
addresses
a review of the "Food Service"

.
this

standard

I 4.

) Knife

, close' .

d~~~::~d the on-duty cook foreman
control of the key that locks the device. Knives and keys
are inventoried and stored in accordance with the
Detention Standard on Tool Control

All kn~ves not in a secure ~.~~ti~E/oom are
secured to the workstation and staff directly supervises
detainees using knives at these workstations. Staff
monitor the condition or I
..-lini" utensils

, y ~asan
collection of knives and tools.
The tools are "etched",
inventoried, signed out to staff
using unique (to each staff
member) chits, and inventoried
at each shift change.
Additionally, each knife goes
into a secure pass through to a
secure cutting room where the
knife is cabled to a work
station.

are used in a secure
cutting room and are cabled to
the work station. They are

i in a
locked metal cabinet in a
locked dry goods storage room.
All food items are issued to
staff by another staff member.

Tliefood ite?,,,rre

7.
of detainee work areas.

The FSA

staff'

daily

121

' ,of the fadlity

population count procedures. These procedures are in
writing. Staff is trained in count procedures.

The FSA anffd ,is
h ;,Sl~lu""isal'.'tthe

secunty sta III gat lermg l
detainees into the designated
area for count. The actual

countis,

iby,

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

Page 61 of 136

PART 4 - 20. FOOD
This
ensures that
sanitary and hygienic food service operation,

.. :; -",<loll!
••
."

n'"

Components

for

detainee;'a~~e~~;

'0 em""

121

loo

~ ~ !!

Remarks

,,"ff.
D

to work in food service. Th,y
are visually observed when
begilll1ing their shift by a
member of the food service
staff for any obvious signs of
hygiene or health issues.

' job

they '" ,

.....

faC~~t~,thand

all
in the
for all
persons working in food service. Detainees and other
persons working in food service are monitored each day
for health and cleanliness by the food service supervisor
or designee. Detainee clothing and grooming comply
with the "Food Service" standard.

10. Th, FSA ;

1 and

, b:;::d s"vi.",
[d

M"c~
~e job

1;2009 ..and

.:1""

.
at that

time.
,
,

I
I

11 asslgne
Th: C~o:.
orill,ih"ru1es an d proce du~:;~
etamee warkers
ures
the food service department.
'and
..
12.
the Cook
(CS)
explains
and
demonstrates:
-yo
• Safe work practices and methods.

•

Safety features of individual products! pieces of
equipment.

•

Training covers 'he safe handling of hazardous
material[s] the detainee are likely to encounter in
their work.

13. The Cook Foreman
detainee detention files.

14.

15.

all training in

;; and CLJFs are paid in accordance with
the "Voluntary Work Program" standard. Detainee
workers at IGSAs are subject to local and State rules and
regulations regarding detainee pay.
are served at least two hot meals every day:
No more than 14 hours elapse between the last meal
served and the first meal of the following day.

121

lSI

121
121

. , the
The detainees
kitchen are participants in the
Voluntary Work Program and
are paid $1 in cash each day.

No more than 12 hours ?lapse
between the end of the dinner
meal and the beginning of the
breakfast meal.
The facility utilizes a "blind
serving line" where detainees
cannot visually see those
serving their food. This type of
serving setup does not require a
sneeze guard. Also, the facility
does not have a salad bar.

16. For
operations, a transparent "sneeze
guard" protects both the serving line and salad bar line.

17. Th' ~",Ii'y h" ,
35:day menu 'yCj~. lGSA,
use a 35 day or similar system for rotating meals.

lSI

121

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

Page 62 of 136

PART 4-20. FOOD
",e
This
""sures that
~."sarutary andh"
.
yglemc food'
servtce operation.

t that is

. "'i]'"

"t~'"

Components

:.§
ilS

18.

, shat!
to
"~~2A analysis that meets U.S.
complete
Recommended Daily Allowances (RDA), at least
annually, of every master-cycle menu planned by the
FSA. The dietitian must certify menus before they are
incorporated into the food service program. If necessary,
the FSA shall modify the menu in light of the nutritional

lSI

~ ....••"'"

Remarks

Thdood,

analysis to ensure nutritional adequacy. The menu will
need to be revised and re-certified by the registered
dietician in that event.

contracted with a
Dietician, licensed in the state
of Texas. Her services include;
1) Review oftlIe regular and
therapeutic diet menus. 2) A
nutritional analysis of the five
week menu cycle. 3)
Recommendations and
suggestions on possible
00

. fM

intake.

19. Th, FSA has ,

,"su': that items

Of th"wo

on the master-cycle m~:u are prepared and presented
according to approved recipes.

Th, Cook

, has the

If yes, documenting each substitution, along with its
justification, with copy to the FSA

21. All

[ZJ

lSI

[ZJ

items if necessary.

•

, meals

observed, the lunch meal on
10/14/09, did not have the
vegetable soup prepared and
served or a suitable substitute.
All other items were prepared
and served according to the
menu and substitution list.

"tood

,and adb'"

preparation" procedures.

22. A Common Fare menu

to detainees, at no
charge, whose dietary requirements cannot be met on the
main.

•

Changes to the planned Common Fare menu can be
made at the facility level.

•
•

Hot entrees are offered three times a week.

•

Th, Common Fare menus

satisfy
recommended daily allowances (RDAs).

nutritional

Staff routinely provides hot water fo, instant
beverages and foods.
0

Common Fare meals are served with:

Disposable plates and utensils.

Reusable plates and utensils.

Staff use separate cutting boards, knives, spoons,
scoops, etc., to prepare the Common Fare diet items.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07109/07

Page 63 of136

J diet that is

that detainees are

Ibis

din

a sanitary and hygienic food service operation.

Components

I
I 23.

s whose
.. ; beliefs ,equi,e the
to particular religious dietary laws are referred to the
Chaplain or FSA.

at the
level must approve a
24. A ':-'1'
detainee's removal from the Common Fare Program.
25. T h e '

,in'

.,q '"
~

.... Ioo

:>is

••
~~1

Remarks

'"
"IT

I3J

request for a meal
accommodation to the

with the

cllaPlain"~~d/o;local religious leaders provides the FSA

his designee (Chaplain)
provides the FSA with a list of
the ten federal holidays (one

a schedule of the ceremonial meals for the following
calendar year.

'mne,

I3J

The chaplain is currently
preparing a list of religious
holidays that require a
ceremonial meal. That will
allow longer range planning by
food service.

26. r;:e
..
fr Fa". 1 "d
i'
fior re r1910llS
'
a stammg
om partlcu ar 00 s or fastmg
purposes at prescribed times ofthe year.

I 27.
I 28.

•

Muslims fasting during Ramadan receive their meals
after sundown.

•

Jews who observe Passover but do not participate in
the Common Fare Program receive the same Kosherfor- Passover meals as those who do participate.

•

Main-line offerings include one meatless meal
(lunch or dinner) on Ash Wednesday and Fridays
during Lent.

lbe

diets.
programs follow guidelines for proper

sanitation.

lSI

•

,
disciplinary
""d
medical holding are the only
units that receive satellite
feeding .

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07109107

Page 64 of 136

PART 4 - 20. FOOD
This •
ensures that·
sanitary and hygienic food service operation.

I is

"$'"'":;

Components

~~
00

••
."Q,l11!
~ :. l!
....

loo

Remarks

al the
.
29. Hot and ,old foods are
. .
"safe" temperature(s) as served See Detention Standard
on Food Service for guidance.

lin

IZI

I Alii
.. ,hoI
food items served at the two
meals observed were in
compliance with established
temperature guidelines. Two
cold food items were above the
maximum temperature for cold
foods; however, those items
were served and I or discarded
within a four hour
'h

concern.

30. All meals I

~11 mo"'~wo~eServed(exce~~
e soup Iste m component
19) in portions equal to, or
slightly greater than the
portions
on the
certified menus.
t

31. Food is. nol used to punish", reward

based

u~behaVIOr.

The toad

•
•
•

",vi" smn.

IZI

on:

Personal cleanliness and hygiene;
Sanitary techniques fa, preparing, storing, and
serving food, and;
The sanitary operation, care, and maintenance of
equipment.

33. Everyone working in the food service .,,}-'
complies with food safety and sanitation requirements.

34.

rORY) The. facility
written
procedures for the administrative, medical, andlor dietary
personnel conducting the weekly inspections of all food
service areas, including dining, storage, equipment, and
food~preparation areas.

to the Facility
35. Reports of discrepancies are
Administrator 0' designated department head and
corrective action is scheduled and completed.

36. ;~~~

includes
of ,II

IZI

T.
appropnate
use,ofh,;,
restraints, beard nets, and
disposable aprons was
observed.

The health and safety officer
and a representative of medical
inspect the food service
department weekly.
are
Reports 01 I .
provided to the FSA who
prepares a corrective action
plan for the COTR
(Contracting Officer Technical
Representative).

121

IZI

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs _ Rev: 07/09107

Page 65 of 136

This Detention

PART 4-20. FOOD:
..
la.

ensures that,

a sanitary and hygienic food service operation.

••
<o:,g

land

....

.
;;

•• •"'~1•
:;!a
~ 00

Components

:<;

Remarks

aft'". "ch :::~I~, in

with tho

Detention Standard on Food

37.

, Staff
'. tho ".,ult, of ev,"y
refrigerator! freezer temperature check, in accordance

lSI

[>j

lSI

with the Detention Standard on Food Service.

fo, "ch food

38. The .
39.

area is

alI .
for

damage,

and

contammatlOn,

, locked when not in u".

40.

; along with

41. Food ",vice

detention·~;;ff.·

42. ~~, The ICE 7.

on_~~t~_ensures that

supervision.

participate III

43. Monu,

t~;h:

pdo, to

~ Fo;d Service Program.

being incorporated into

. In spes only: Ihe FSA prepares
for the Common Fare
quarterly estimate is factored into

food
p",t

ICE

A co,t

.'] cost

th;'

. This
quarterly

budget.

lSI

doors where food is prepared, stored, or served to protect
against insects and other rodents.

lSI

fo, "food

lSI

45. When

,.only food

. ' ,t,ff p,epace tho "ck

detamee transportatIOn.

I 46.
I 47.

Ai,

. .

receIpt

48. Stock

. level, aco

and

correct overage and shortage problems.

49. Staff

with

all

I by

"'_

the COTR as the FS~ is a
contracted food service
provider. The FSA only
provides food service
management. Budgeting and
product procurement are
accomplished by ICE
personnel.

The food,'

ICE

and

lSI

and
will
provide sufficient space and time fo'
to eat
meals in a relatively relaxed, unregimented atmosphere.

lSI

requirements.

. , the

u"d on ou"ido

with the ICE

Staff

wo"

dining room for each of the
meals observed.

Identify

explain any shortcomings.

50. Dining room

orders sufficient food 1
maintain a 15 day supply.
Security staff in the dining
room allowed from 20-27
minutes for each group of

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

Page 66 of 136
-

- _U,

r~.

'Ibis
a sanitary

rvvv

O~A ,.~~

I.,

Me Y'

I diet tilat is

land]

II
$.@l

Components

:.:=
~

ell

'<i ."
Z ~ -

.'" :.:~ i.
~

Remarks

,
,

external source shall
'VA'!. An
conduct arumal inspections to ensure tilat the food
service facilities and equipment meet governmental
health and safety codes.

IZI

• shall
: tile fo?d t)vi~e
note needed
actlOn s, 1 any, in a written
report to the Facility Administrator.

IZI

owy u'"'o ,'UMO auu t;;;U°fa T
'
d
'.~~ mamtenance 0
e
Cllty, eqUIpment, an
. shall be used in the food service department.
Material Safety Data Sheets (MSDSs) will be maintained
on all flammable, toxic, and caustic substances used.

IZI

Corrective action is taken on deficiencies, if any.

52,

00,

54,

•

I til,:,~~~~,u:2~is
,
contro III e
epartment,
contracting the services of an outside extenninator.

:.:

ell

S to

51.

lin

food service operation.

eat.

A monthly inspection is
conducted by the Military and a
corrective action plan is
developed for any
discrepancies noted.

factTIty IS
' contract
IfoC' ed WI'til
EcoLab pest Elimination
Division.

FOOD:

t2I Meets Standard

D Does Not Meet Standard

ON/A

DRepeat Finding

Remarks: (Record significant jacts, observations, other sources uSe!l etc.)

There were two non-compliant line items in this standard. The first involved the failure of staff in food service to prepare
(or substitute) a single menu item during one of the two meals observed. The second non-compliant component was
regarding the temperature of two cold food items. These food items were served above the minimum temperature, but
within the time frames required.
b6,b7c
b6,b7c
I 10-15-09
Reviewer's Signature I Date

•

b6,b7c

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07109107

Page 67 of 136

ART 4-21.
..
.
'~'~Md
~My detoin"" who is on , hunge, strike.

,oy

J!l~
~'"
c

Components

lEJ!I
In

'i,he~; ~

eaten or

Za;ta

0$'"

J!I

!f
z

Remarks

Th~

. .' h" d d' food, £
ff' to h:vet ot
ours, It IS stan aT practIce or sta to re er urn

121

I 2.

referral to the medical
department when they have
refused food for 72 hours.
Medical and security staffs
were interviewed and
understood the policy.

<""pm" via the eh,in of

::,J_ to
"0'

d;~inee

stn es

or her to the medical department.

I
~

~~lil~~l

to
Field Office

notify the Field Office
Director.

I 3,

Th~, f"ility ha:

:;'

I ~~i~~kY ~nd "from oth;:;q~i~e, that

to ensure staff
st." iwlate ,

121

5.'

,pl,,:a,

Th"
d'
:',
unme late response,

~~~ until the detainee has

.
meals for 72 hours and
then they are housed in the
health services unit's short stay
isolation room.

. , Ihe

on ~ hung... strike
may be placed in a single
occupancy cell within the
health services unit by medical
staff or in the SMD.

Special Management Unit or a locked hospital room.

121
.

,taff

the we>ght ,nd vital "gns of a

services l~~;ll-'~pe;~ting
procedures require weights and
vital signs at least every 24
hours.

hunger-striking detainee at least once every 24 hours.

obtains a hunger

The. ";"ity

121

consent before medical trea1ment.
form is
of every
8. A signed Refusal of 1 J
detainee who rejects medical evaluation or treatment, or two
staff/provider signatures indicating detainee refusal to sign
form.
_~y the medical
, staff
9. Unless otherwise
delivers three meals per day to the detainee's room, regardless
of the detainee's response to a verbally offered meal and
document those meal offers.

•

tU~!:' Ihe

Poliey,

121

•

Us'

betoce

Refusal forms are required for
any refusal of evaluation or
trea1ment.

I PO,liey

121

medical treatment.

delivery of three meals per day
to the detainee's room,
irrespective of a detainee's
verbal rejection .

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet fur JGSAs - Rev: 07/09/07

Page 68 ofI36

ART4-21.

pmt"'"
.
'health and
any detainee who i, on a hung'" strike.

III

, supply of

III

Remarks

"'z"

I A constan~. s~.P?}?_'
available in
.

"0' : s.trike, staff remov" all food items from
ilVlng area.

121

I r;~~;,~~;,
I of all
food
~.:':.~ and food purchases
are prohibited.

. to re,;;:d ;;"n~~;~~i~:iM ,fluid ~take
consumptIOn on e unger
ollltormg arm

121

Staffs record food and fluid
intake on an 1-839 form.

II. During a
the hunger

~ta~ is, .
00

"!!

121

10. Stafl'
the hung".
water/other beverages.

12d

z-;ns
~~
0."
• c .::i
::is

Components

:by,

1-839 or equivalent.

13. The .

"aff h"

fa'

. '''''L

counseling him or her of the medical risks.

121

~ll
treatment attempts in the
electronic medical record. The
health record of the only
hunger striking detainee housed
at this facility over the past
year was reviewed and
appropriate documentation was
included.

~~~s recei~~' :r7~~tation and

Medical staff receives training in hunger-strike evaluation and
treatment and remain up-to-date on these techniques.

of hunger striking

14. Stafl
' all treatment attempts in the
record, including attempts to persuade the hunger striker by

and annual
All statf receives
recognizing the signs of a hunger striker and on
for referral for medical assessment.

; 'n"

~"~e:~

121

annual training in the
recognition, referral, and
management of hunger strikers.
The lesson plans for each were
reviewed and were complete.

PART 4-21.1

121

Meets Standard

o Does Not Meet Standard o N/A

D Repeat Finding

Remarks: (Record significant facts, observations, other sources used, etc.)
The facility's policy and procedures are appropriate to ensure the health and well being of detainees engaging in a hunger
strike.
All staff receive adequate training in the recognition, referral, and management in the area of hunger strikes.
There was one hWlger striking detainee since the previous inspection and a review of documentation revealed appropriate
management.
b6,b7c

/ 10-15-09
Reviewer's Signature / Date
b6,b7c

b6,b7c

•

(

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detentioninspeclion Form Worksheet for iGSAs - Rev: 07/09/07

Page 69 of 136

_CARE
PART 4-22.
.
i have access to a
: of health care
so that their health care needs are met in a tllllely and effictent manner.
; that

Remarks

Components

1. The
. ~;Y'
, a health care facility in compliance
with state and local laws and guidelines.

; 2.

Ibe

'~.J'

procedures of arrivmg

[gJ

detainees include medical screening.

The

National Commission on
Correctional Health Care,
and the Joiot Commission
on Accreditation of
Healthcare Organizations.

lis
by nurses during

The

Y) The essential positions needed to

s43

perform the health services mission and provide the required

scope of services are described in a staffing plan that is
reviewed at least annually by the health authority.

<Vft'/ Newly.

informed, orally ana in
..
understand), about how to access

will be

(i?, a language they can
services.

o
5. Detainees will have access to and receive
i 24hour emergency medical, dental, and mp.ntfll hplllth services.

6. New direct care :stau Will
. tests prior
to their job assignment and periodically thereafter and will be
offered the hepatitis B vaccine series.

positions that include a
physician, dentist, mid-level
practitioners, a registered
pharmacist, registered
nurses, licensed vocational
nurses, social workers,
health information
technicians, and a variety of
clinical and administrative
support staff. There are
eight vacancies. The
essential positions were
filled at the time of the

receive oral and written
information on accessing
health care services. If a
detainee speaks a language
that is not familiar to the
medical staff, an interpreter
service is utilized.
>s by on-site
medical professionals are
provided 24 hours per day,
seven days per week.

s of

medical staff were reviewed
and all had documentation
of initial and annual TB
testing when appropriate.
Hepatitis B vaccination is
offered to all medical staff.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet fur IGSAs - Rev: 07/09/07

Page 70 of 136

PARf4-22.

ensures that

Thi,

. CARE

:. have access to a

. of_ h:~ltb care

and health education, so that their health care needs are met in a timely and efficient manner.

ll~

z1i~

c
:ES

~."
~

Components

0~'"
~:Ec
S

:!!
z

Remarks

willb,
7. I:',"lth ""
qualified personneL whose duties
descriptions ",d who "e properly licensed, certified,

.
I ,,,"o,d, .of
staff were reviewed
and all had current and
verified professional
licenses. Since some
medical professionals are
officers in the Public Health
Service, licenses are
permitted for states other
than Texas. Job

go~~n~~in~~ ~~

Th'.

credentialed, and/or registered in compliance with applicable
state and federal requirements.

121

8. The, f~'ility,.
copy of the

, upon
; ,"~h
handbook or equivalent,

~~ri~~a~~~sc~:p~~F~ith the standards establish~ b; ~~~
and Joint Commission.

of."'i~al,

all n,wly.

The.

121

lSI

When screening is performed by a detention officer,
the facility maintains documentation of the officer's
special training.

11.
~)~ If language difficulties prevent the
health care provider/officer from sufficiently communicating
with the detainee for purposes of completing the medical
screening, the officer obtains translation assistance.

. ;'J'
sufficient space and equipment to afford
12. The
each detainee privacy when receiving health care.

•

handbook is available in
English and Spanish. A
local supplement is also
provided and was under
revision at the time of the

receive initial medical, dental and mental health screening by
a health care provider or a detention officer specially trained
to perform this function.

•

m whic~

procedures for access to health care services are explained (in
a language they can understand).

10. Within 12 ho""

121

lSI

have current-and verified
licenses. Licenses are
verified by contacting the
local professional boards.
All newly admitted
detainees receive medical,
dental, and mental health
screening by nurses.
Detention officers do not
perform these screenings.

services are available.
Many documents are
available in an additional
27 languages by using the
Division of Immigration
Health Services' (DIHS)
"Global Drive" and
connecting with the DIHS
database.
The facility has
.
space for providing detainee
privacy.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

Page 71 of 136

_CARE

PART 4-22.
This Detention

ensures that

s have access to a

of h~lth care

and health education, so that their health care needs are met ill a timely and efficient manner.

~~c

Components

::EJ!
VJ

~3.

Th,

. I f'.,mty h.., it, own

II facility entrance

~.ectTh,
.'.' ,~"u,y'd' ,I "aff.
supervlslOn 0 custo 13

tOi

ther.
'.
iet and a ct'';.
r fig ountam.

17.

•

0~'"
~:;

Remarks

-'0

care is

IZI

""vi"

has a holding room.

mom und" th,

room have access to a

direct supervision of
contract security service
staff.

I A toiI,t and w,'"
are available to detainees in
the holding room.

The facility

", kept 'part from oth" fih They

electronic medical record

•
•
•

~~~ained

Secured in a locked area within the medical unit.
With physical access restricted to authorized medical
staff.

IZI

Procedurally, no copies made and placed in detainee
files.

: to'm i,
.') A 'ig~'d" ,nd dated
from a detainee before medical treatment

administered.

use the 1-813 (or IGSA
19.
authorize the release of confidential medical
outside sources.

to
to

IZI

call Case Tracker. Access
to medical infomlation is
restricted to health
professionals and the
computerized system is
password protected. No
medical information is
placed in detainee files.
Medical treatment consent
forms are signed and dated
when medical intake
screening is performed.
The document is then
scanned into the electronic
health record. Additional
consents are obtained when
special procedures are
performed.

ThoI-813 fonn is used to

20. The.tacil~ty health care p
.
is given advance notice
prior to the release, transfer, or removal of a detainee.

authorize release of medical
records.

p",

IZI

•

din

a health a service building
that is within the secure
perimeter.

are:

•

.,ea.

The restricted access area is located within the confines of the
secure perimeter.

I 14. Th,
room.

0
t!
z-;cu

personnel they receIve
advance notice of detainee
movement except on rare
occasions .

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

Page 72 of 136

PART 4-22.
This u

• CARE

.
ensures that
:. have access to a continuum of h~~th care
and health education, so that thell' health care needs are met in a timely and efficient manner.

-=:;

0
1!
.'!l~ Zli-l!l
n
c
:;J!
U)
8 ~

Components

Remarks

A USM 533 .'
summary form IS used to
relay information to
receiving facilities. Copies
of medical records are only
transferred with signed
authorization from the
detainee.

will b,.
.
"
21. A .
appropnate. All detainees will be transferred with a copy of
their transfer summary.

121

22. . '1 bId
contamer a e e

\~~;~.~'dm,,,,al'd'
dA
,;;oth'~
etamee s name an
-num er an

transferred with the

Wit 1

U~L.

121

envelope-~h~~i;~arked

with the detainee's name,
file nwnber, and labeled
Medical ConfidentiaL

23.

~he~t

s (TB) test.

121

,
i

I
24. All
arrival. It is conducted:

•
•

upon

Bya health care provider or specially trained officer;

121

Before a detainee's assignment to a housing lll1it.

25. Th'
. ;~>: health '""
794s (or equivalent) to identify
attention.

reviews all 1needing medical

26.
'J Each
",' health '""
.
conducts a health appraisal and physical examination on each
detainee within 14 days of arrival. If there is documentation
of one within the previous 90 days, the facility health care
provider may determine that a new appraisal is not required.

•

hY
means of a_
x-ray
the time of intake screening.
The facility has a contract
with the University of
Maryland to read the x-rays
within 6 hours. Detainees
are not placed in a housing
unit lll1til the TB clearance
has been obtained.

121

performed by nurses
time of medical intake
screening and before the
detainee is placed in a
housing lll1it.

A health care provider
performs the intake
screening.

oflg
random detainees were
reviewed and all 18 had
health appraisals performed
within 14 days of arrival.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection form Worksheet for IGSAs - Rev: 07/09/07

Page 73 of 136

This Detention

ensures that

PART 4-22.
. , have access to a

of health care

and health education, so that their health care needs are met in a timely and efficient manner.

z"li c

::;13

0::;13

f/)

I 27.

.'!l~

Components

CIt

-g

Remarks

in the Special
Management Unit are
visited by a medical
provider each day and have
the same access to health
care as the general
population.

f/)

"CO"

.
, in the
t Unit hav'
to the same level of health care as detainees in the general

population.

121

I 28.

St,ff'

with h,nltl,·

reque~;~li~~'daily, upon request.

slips are available in the

•

~~::able number oft~e ~~~~l~

•

I A ,upp'y

(,i,k ,,11)
other

29,.
' Th, fadlity h" n ;v.itten plan fo' tll<
delivery of 24-hour emergency health care when no medical
personnel are on duty at the facility, or when immediate
outside medical attention is required.

and

Spanish language sick call
request slips are available in

, ,poken by ,

Service-request slips nc, delivered in n timely
fashion to the health care provider.

30. Th, plnn

121

detainee fills out the request
and places them in a locked
box in the food service
department during meal
times. The requests are
collected by nursing staff on
a daily basis and triaged.
Sick call request slips in
other languages are
available on the DIHS share
drive.

~h'; 24 hmrr on·
site medical coverage.
Policy is available to direct
staff on how to access
outside medical providers in
emergency situations.

I2l

posted in the health services
unit.

121

for ambulances
and contract hospitals.

lon-call provider.

I 31., Th: £.l"~_ .

, a list of telephone numbers for local
ambulances and hospital services.

I 32. The phn .

for facility staff to utilize
health
care
consistent
with security and
this emergency
safety.

121

•

are considered when
obtaining emergency health
care. This was observed
during an emergency that
occurred during the
inspection .

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

Page 74 of 136

PART 4-22.
ensures that

_CARE

: have access to a

of health care

so that their health care needs are met in a timely and efficient manner.

Remarks

Components

'
':'~",
11 ,,,,,d h"~ ,ruee
trame, at east aruma y, to respon to
situations within fOUf minutes and to properly use first aid
kits, available in designated areas.
33 be

WI il

121

reviewed
which revealed that during
orientation and annual
training all detention and
health care staff receive
first aid and basic life

support training. First aid
kits are located throughout
the facility and are
inventoried regularly.
J',

," "'"

'WH "

" ' " " '"

provider properly trams these officers.

35,

121

,will be
in
accordance with sound standards and facility needs for safety
and security.

stored,

, "nd

, • """" ca.

inventoried,

dispensed,

and

administered

121

•

to distribute medications.
Officers are never permitted
to distribute medications.
Pharmaceuticals and
nonprescription medications
are stored in the facility's
phannacy. The pharmacy is
climate controlled.
Controlled substances and
medications that are subject
to abuse are administered
by licensed health care
professionals. Controlled
substances are inventoried
regularly. An inventory of
bulk stock controlled
substances revealed
accurate counts .

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
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Page 75 of 136

PART4-22.!

This

ensures that

. CAR.

of h~lth care

_have access to a

i h'~fllth education, so that their health care needs are met in a timely and efficient manner.

Components

Remarks

36.
., E"hJa,,~ity.h"S w"tten~oli:y and
procedures for the management of pharmaceuttcals that
include:
•

A formulary of all prescription and nonprescription
medicines stocked or routinely procured from
outside sources.

•

A method for obtaining medicines not on the
formulary.

•

Prescription practices, including'
that
.
Me
.
o.;Iv ~hen
indicated and that prescription are reviewed before

storage, distributi~~ and
disposal. Procedures are
also in place for the storage
and inventory of controlled
substances as well as
needles and syringes.

being renewed.

•

receipt,
distribution,
storage,
Procurement,
dispensing, administration, and disposal of
medications.

•

Secure storage and perpetual inventory of all
controlled substances (DEA Schedule II·V),
syringes, and needles .

37. All pharmaceuticals are stored in a secure area with the
features:
•

•

A secure perimeter;

•

Access limited to authorized medical staff (never
detainees);

•

Solid walls from floor to ceiling and a solid ceiling;

•

A solid core entrance door with a high security lock
(with no other access); and

•

A secure medication storage area.

38. In SPC~ and CDFs, the
through wwdow.

•

has ,

Pharmaceuticals are stored
in a secure area. The walls
are concrete blocks that run
from the floor to a solid
ceiling. The phannacy door
is metal with a high security
locking device.
Medications are stored in
this area.

The
a pass
window.
The phannacy is managed
by a registered phannacist.
Medications are only
administered by licensed
medical professionals. Pill
lines are routinely run four
times per day and in some
cases, on an as needed
basis. Distribution of
medication is recorded on a
standard Medication
Administration Record .

pass-

•

Administration and management in accordance with
state and federal law.

•

Supervision by properly licensed personnel.

•

Administration of medications by personnel properly
trained and under the supervision of the health
services administrator, or equivalent.

•

Accountability for administering or distributing
medications in a timely manner and according to
physician orders.

The facility's pharmacy has
written policy and
procedures that adequately
address the DIHS
formulary, requesting nonformulary medications,
medication ordering
procedures; and medication

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G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07109/07

Page 76 of 136

This

,J h

r",,' 4 - 22.
I
. CARe
_have access to a
of h~lth care
so that their health care needs are met in a timely and efficient manner.
that

,lth

J!l~
&'C

Components

~ c
::OJ!

II)

lofprocedures" estai\~ hed y
b n: with
e
"IT,
provider. Written records of all medication given to detainees
39.
.
mstructions an

I2l

1!
:g«D"g
o

Zl1«l

o::OJ!

Remarks

is recorded O~l a standard
Medication Administration
Record.

II)

are maintained.

:0etamees.

may not he

•

In facilities that are medically staffed 24

hours a day, the health care provider distributes
medication.

I2l

hours a day, medication may be distributed by
detention officers, who have received proper

Detainees are not pennitted
to deliver or administer
medications.

training by the health care provider, only when
medication must be delivered at a specific time
when medical staff is not on duty.

41. Th, faC;i,ity_
'd
d' 'b·
d,Of th,
d th
gIven any 0 teer reqUITe to Istn ute me lcatlOn, an
e
officer has available for reference the training syllabus 0'
other guide 1
•
1 Dy the health authority.
Th,

I2l

Officers are not permitted to
distribute medications.

,thata,

has special medical needs.

I2l

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

121

•

Medications that are not
classified as "Keep on
Personl'_S~~~!_are only
' "Y

,he]d

with 'f:cility administrators
to notifY staff of detainees
with special needs.
Additional meetings are
held if the need arises. The
minutes of the meetings
were reviewed and were
thorough.
When possible, the facility
strives to accommodate
examinations by
independent medical
services providers prior to
the issuance of a court
order. In either case,
detainees are transported to
an off-site facility for
independent examinations .

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Page 77 of 136

PART 4-22.

This Detention Standard ensures that

LCARE

have access to a

of health care

and health education, so that their health care needs are met in a timely and efficient manner.

Components

~.e
U)

I ;~~)

that

o "Eftl
tl~ Z41

:gCp"g
o~.e

!!;

a~d;;;sl) t1~eac~::~~~e:~s ~f '7~~:i:~:n a~~

communicable diseases, including prevention, education,
identification, surveillance, immunization (when applicable),
treatment, follow-up, isolation (when indicated),
reporting to local, state, and federal agencies. Plans include:

,nd

•

Coordination with public health authorities;

•
•

Control, treatment, and prevention strategies;

Ongoing education for staff and detainees;

121

Remarks

The facility foHows the
DIHS Infection Control
Manual and Local
Operating Procedures
(LOP) for the management
of infectious diseases. The
combination of these
policies adequately
addresses all items in this

. Sin"

•
•
•

Management of tuberculosis, hepatitis A, B, and C,

my infection, avian influenza, and
Reporting communicable diseases to local and/or
state health departments in accordance with local
and state regulations.

with a communicable disease are
I 45.
isolated according to local medical operating procedures.

121

46. All new arrivals receive TB screening in
guidelines of the Centers for Disease Control (CDC). Unless
a chest x-ray is the primary screening method, the PPD
(mantoux method) is the primary screening method. (For a
detainee on whom the PPD is contraindicated; a chest x-ray
will be needed. Detainees not screened are housed separate
from the general population.

~ t~at ensures
48. A transportation system will be
.
timely access to health care services that are only available
outside the facility, including: prioritization of medical need,
urgency (ambulance versus standard), and transfer of medical
information .

•

diagnosed
a
communicable disease are
isolated in one of the three
negative pressure isolation
rooms within the health
services unit.

Th, fuoility utili,,, , oli"t

121

'''-"loc'.d.'n

47. Detainees with symptoms
,afTB
fo,
a negative pressure isolation room and
no negative pressure
TB disease. Detainees at facilities
isolation room are referred to an appropriate off-site facility.

"'g

ofthe manual and LOP,
additional policies have
been approved for the
management of the HINI
virus.

Media relations;

121

x-ray forTB screening. No
detainee is placed in a
housing unit until the x-ray
has been interpreted. The
facility's contract requires a
reading within six hours of
the receipt of the digital
film.
The health services unit has
three negative pressure
isolation rooms.

The

121

••,

emergency and standard
modes of transportation to
transfer detainees to outside
facilities.

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Page 78 of 136

PART 4-22.
• CARE
This'
ensures that
have access to a
.
and health education, so that their health care needs are met in a t1~

,,,,1.

of health care
manner.

Components

Remarks

49· · I'
~ho ... '·"b do",.. aceordO<'
h
I
me d lea superVlSlOU Wlll e tr~:ltp.rl
ance WIt a p an
approved by licensed physician, physician assist, nurse
practitioner, dentist, or mental health practitioner that
includes directions to health care and other involved

Detainees requiring more
frequent or special
monitoring are housed in
the health services unit's
short stay unit. Detainees
are admitted to the unit and
orders are written for other
health care providers to
follow.

personneL

50.

All female detainees receive

hove " " " to

routme
management,

~~rival. ~li;:~I~:un

care, a lctlon
counseling and assistance,

nutrition, and postpartum follow-up.

?1.

hypertensio~

periodi~ ~are

as
)and diabetes)
receive
and treatment that includes monitoring of medications,
laboratory testing, and chronic care clinics, and others will be
scheduled for periodic routine medical examinations, as
determined by the health authority

•

detainees are scheduled for
OB/GYN appointments
with a contract specialist.
Facility staff, with the
concurrence of the medical
director, follow the
recommendations of the
specialist. No deliveries are
performed in the facility
and high risk pregnancies
are referred to a more
appropriate medical facility.
are scheduled for detainees
requiring close supervision
or monitoring. Physicians,
Nurse Practitioners,
Physician Assistants or
licensed social workers
place the detainees in the
clinics. The health records
of 10 detainees with chronic
care problems were
reviewed and all had
appropriate and timely
follow up .

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

Page 79 of 136

PART 4-22.

This

ensures that

• "ARE
of h~lth care services,

have access to a

and health education, so that their health care needs are met in a timely and efficient manner.

Remarks

Components

, , ; ofth,d'" w';:'~;,

52. Thfi: d '
"
'f'
d 0' oth" 'h
[IstafT
'dW',ill
'I
be not! e III \Vfltmg 0 any etamees w ase speCIa me tea
or mental health needs requiring special consideration in such
matters as housing, transfer, or transportation.

53,

, ,nd

, will hove " " " to

'"-fUlm'I" , "'ntd"d c",c

o a lcense ' entlst.

Th,

,"n" _y

, uno"

meetmg Wlth Ie
administrators were
reviewed. The minutes
identify detainees with
special needs, but do not
divulge medical information
beyond the administrator's
need to know.

'd '""",u" uU ,""0'''"
proYl e routme an d

emergency dental care. The

54,

with

~'ntal

{h' to't'

h"lth

problems will be referred to a mental health provider as
needed for detection, diagnosis, treatment, and stabilization to
prevent psychiatric deterioration while confined.

55. Crisis
services are available for
who experience acute mental health episodes.

•

dentist has trained medical
staff to perform routine
dental screenings during the
initial physical examination.
Training records of those
providers approved to
perform examinations were
reviewed and all were found
to have completed the
training.

Social
Worker and a Licensed
Masters Social Worker.
Both provide mental health
services to detainees
requiring mental health
evaluation. A contract
psychiatrist and behavioral
health center provide
services that are beyond the
scope of the on-site
practitioners or health
services unit.

eri,i,
are provided by University
Behavioral Health .

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
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Page 80 of 136

PART 4-22.

.GAR~

This Detention

ensures that
_have access to a
.
_ of h~~lth care
and health education, so that their health care needs are met in a timely and efficient manner.

Components

J!l~

n
::EJ!
II)

Z ...

"!!
~

0~'"
~::E0

:$
z

II)

~e~lth treatment ~ -: ~~ comprehensive evaluation by a
licensed mental health provider within 14 days of the referral.

,~" XJ
fo,
m mental
purposes may be authorized only by a qualified
medical or mental health provider, after reaching the
conclusion that less restrictive measures are not successful.
The facility has -written procedures that specify:

•

The conditions under which restraints may be
applied;

•

The types of restraints to be used;

•

How a detainee in restraints is to be monitored;

•

The length of time restraints are to be applied;

•

Requirements for documentation, including efforts
to use less restrictive alternatives; and

•

After-incident review.

•

The medical authority or mental health provider
completes a Post-Restraints Observation Report
form DIHS-867 or similar form.

,
t

1 bedaltb 'd'
56. _" . 1 anldi mbenla1
.
tb
• and
proccuures WI l e con ucte m settmgs
at respect
detainees' privacy, and female detainees will be provided
female escorts for health care by male health care providers.

121

Remarks

examinations are conducted
by medical providers of the
same sex. When this is not
possible an escort of the
same gender as the detainee
is always present.
Adequate privacy is
provided to female and
male detainees.
health records revealed that
in six cases no more than 24
hours passed before a
comprehensive evaluation
by a licensed mental health
provider. The remaining
detainee was evaluated
within six days for mild
anxiety.
Ih' VlHS
I P?li,y
and Procedure Manual
outlines the appropriate use
of medical and mental
health restraints as outlined
in this standard. However,
the facility's health
authority has elected not to
use medical or mental
health restraints. Should
the use of restraints become
unavoidable, the DIHS
standard operating
procedure would be utilized
as would the facility's
policy on use of force and
restraints. When restraints
are used for correctional
purposes health care
personnel monitor post
application and routine
checks as required.

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Page 81 of136

PART 4-22.
. CARE
ensures t!tat
i. have access to a
_ of. h~lt.h care
and health education, so that their health care needs are met in a bmely and efficient manner.

Thi,

J!l~
~"
c

Components

:!i.l!
III

Zt;C'iS
•.~"
:!i C

.l!

!f
z

III

'Ma~:a~liCY

5Y.
of
psychotropic medications to detainees complies with
applicable laws and regulations and the authorizing physician
or psychiatrist will:

•

Specify the duration of therapy;

•

Obtain an order authorizing the administration of the
drug from a Federal District Court.

•

Document that less restrictive intervention options
have been exercised without success;

•

Monitor the detainee for adverse reactions and side
effects; and

•

Prepare treatment plans foe
alternatives as soon as possible.

less

j h"lth ,
61d ~n e~'h d .'.
. . " the,
an
act tty A mmtstrator
the contents, number,
location(s), use protocols, 'nd procedures foe monthly
inspections of first aid kits.

•

. ,!,ould be

'h',,'" 'h
121

restrictive

60. An initial dental
exam should be perfonned
,
within 14 days of the
arrival. If no on-site dentist
is available, the initial dental screening may be performed by
a physician, physician's assistant, nurse practitioner or trained
RN.

62. An automatic
for use at the facility .

and Procedure
outlines the appropriate use
of chemical restraints (force
psychotropic medications)
as outlined in this standard.
However, the facility's
health authority has elected
not to use forced
medications.

""0 oe,

vern"

Remarks

121

restraints become
unavoidable, the DIRS
standard operating
procedure would be
utilized. Additionally, the
detainee would be
transferred to the contract
crisis intervention center
where their policies
regarding forced
psychotropic medication
would apply. In all cases,
less restrictive intervention
options would be employed.

Th, hoolth ",oeds of 18
detainees were reviewed
and all 18 had initial dental
screening performed within
14 days of arrival. The
dentist has trained providers
in the performance of dental
screening. Training records
were reviewed and were
complete.

121

The
hog
the content
and location of first aid kits.
Kits are inventoried at least
monthly.

121

The i : ' J ,
automatic
external defibrillators.

"'.

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G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

Page 82 of 136

This

PART 4-22.
. CARE
of health -care
ensurestiUit
have access to a
and health education, so that their health care needs are met in a timely and efficient manner.

Components

Z.ftI

::;3

o:E

I{ICII'g

Remarks

63. If ,
""tm'nt,
will b,
consulted in detennining whether forced treatment will be
administered, except in emergency circumstances, in which

"nd health
"nu

other facility and medical staff as

lSI

' m""

'd:';;;"

• J Th, health
. ,will
system of internal review and quality assurance.

for

waste. A
licensed biohazardous waste
management contractor,
Stericycle transports the
waste from the facility.

H"Ith
m

PART--.r::-22.

t2l Meets Standard

121
!

'~f'nd

are

lSI

,.,

with the facility
administrator.

65.
w"t, will b,
and medical and
equipment decontaminated in
accordance with sound medical standards and compliance
with applicable local, state, and federal regulations.

I th,

right to refuse any
medication, treatment or
examination. Iflife
sustaining procedures are
indicated, ICE will be
notified to determine if
forced treatment will be
administered,

case, ICE/DRO will be notified as soon as possible.

64. In SPCs Md CDFs, tl"
. will m'" " I"st '

Does Not Meet Standard

improvement program
administered by the
Division of Immigration
Health Services.

:ARE
D N/A

DRepeat Finding

Remarks: (Record significant facts, observations, other sources used, etc.)
Health care in the facility is provided in a clean environment, of adequate size, and is appropriately staffed.
Services are provided by a combination of Division ofImmigration Health Services and contract licensed health care
professionals. Medical, dental, and mental health needs are met in a timely and efficient manner.
Regular and appropriate care is provided to detainees with chronic care or special needs that are identified during the intake

s",,,nmg and phy,i"I '"'''

Acc,,, to modi "I, m,nm! health ""d d,n,,1 "" i, uninhibit,d.

b6,b7c
I 10·15-09
Reviewer's Signature /

•

b6,b7c

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G-324A Detention Inspection Form Worksheet fur IGSAs - Rev: 07/09f07

Page 83 of 136

PART 4 - 23~PERSONAL HYGIENE
of adequate bathing facilities and the issuance and exchange of clean clothing, bedding, linens, towels, and
hygiene items.

Remarks

Components

, fa< the cogular .
I. The" is a poliey and I
and exchange of clothing, bedding, linens, towels, and

personal hygiene items.
The supply of these items exceeds the minimum required for
the number of detainees.

2. All new
are ~Clean, temperatureappropriate, presentable clothing during in-processing.
Detainees receive, at a minimum:
~

one jumpsuit.

•

One pair of socks.

•

One pair of underwear (daily change).

•

One pair of facility-issued footwear.

·.

·is·
for
and as is seasonally appropriate.

section V.S, at an SPC the
standard clothing issue
·s two
.
shirts and two pairs of
unifonn pants or two
jumpsuits; two pairs of
socks; two pairs of
underwear; and one pair of
facility-issued footwear.
Detainees at the facility only
receive one unifonn shirt and
one uniform pair of pants.

New
aco issued dean
towels, at a minimum:
•

One mattress

•

One blanket

•

Two sheets

•

One pillow

•

One pillowcase

•

One towel

•

Additional
conditions.

blankets,

based

local

weather

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

•

[8]

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

Page 84 of 136

PART 4-23.
Thi,
of

en""e, that,
. , isable
. ~
bathing facilities and the issuance and exchange of clean clothing,

Components

<: 1!
il~ Zi~
:.1.'"§ e~ :.1 _= ~

en
6.

Toilet

•
•

<=l

.
• the
linens, towel;, and

Remarks

' are;

Clean

Adequate in number and can be used without staff
assistance 24 hours per day when detainees are
confined in their cells or sleeping areas.
ACA Expected Practice 4-ALDF-4B-OS requires that
toilets be provided at a minimum ratio of one for
every 12 male detainees or one for every 8 female

12]

up to one-half of the toilets.
7.

are:

•
•

Clean

Operable with temperatures between 100 and 120
degrees Fahrenheit.

ACA Expected Practice 4-ALDF-4B-08 requires one
washbasin for every 12 detainees.
ACA Expected Practice 4-ALDF-4B-09 requires a
minimum ratio of one shower for every 12 detainees.

ace ~
fT.
withd
~
aCl lhes, support, an assIstance
for self-care and
personal hygiene.
j dean,
, lin"" ""d towek
9.

•

Socks and undergarments - daily.

•
•

Outer gannents - twice weekly.

•
•

Towels - weekly.

12]

workers are permitted to

12]

are permitted to exchanges
II.
of outer garments more frequently.

12]

Sheets - weekly.
Pillowcases - weekly.

10. Food ,,,vice
exchange outer garments daily.

YAK14 - 23:PEi
[21 Meets Standard

•

Detainees are issued socks (2
pairs) and undergannents (2
pair) and have the
opportunity to launder them
in housing unit washing
machines. These clothing
items are replaced as needed.

o Does Not Meet Standard

HYGIENE
DN/A

DRepeat Finding

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
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Page 85 of 136

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

In the Outcome Measures Report (10/09), the Center reported that 904 detainees were diagnosed with hygiene related
AaJth conditions. The Health Services Administrator explained that the vast majority of these are minor conditions
-.,olving lice, scabies and fungus. The facility monitors and addresses personal hygiene conditions of the detainees.
Detainees are issued hygiene items at intake and they are replenished as needed in accordance with the detainee handbook.
b6,b7c
10-15-09
Reviewer's Signature (Date

b6,b7c

•

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Page 86 of 136

lIuOIIAND INI

PART 4-24.

IIUN

.
.
:' health and well being V]
situations of risk and to intervene with appropriate sensitivity,

!Suicide "'
and treatment.

"l!
~=.!!c. .

Components

Remarks

:OS
VJ

i I. The. f,cility Ii" , written micide
intervention program approved and

.
Md
by the health

authority and Facility Administrator and reviewed annually.

12.
•

, ,lim! include
address:
Intake screening and referral requirements;

•

The identification and supervision of suicide-prone

•

Staff training requirements;

•

The management and reporting of suicidal incidents,

At,

The

!21

suicide prevention and

intervention policy was reviewed and
has been approved by the Assistant
Field Office Director and the Health
Services Administrator.

The facility's policy includes adequate
guidance for the screening, referral,
housing, monitoring, and follow up of
detainees exhibiting suicidal behavior.
Training requirements are also
outlined in the policy.

suicide watches, and deaths;
•

Provision of safe housing for suicidal detainees;

•

Debriefing of any suicides and suicide attempts by

administrative, security, and health services staff;
•

Guidelines for returning a previously suicidal detainee to
a facility's general population, upon written authorization
of the clinical director.

•

Reporting guidelines for facility personnel
suspected suicidal behavior is observed; and

when

Written procedures for the proper handling of detainees who
exhibit suicidal behavior.
3. ,_~~~y new staff
suicide-prevention
training. Suicide-prevention training occurs during the
employee orientation and annual training.

•

[3J

I All stan wiln I
contact
receives orientation and annual
training in suicide prevention and
intervention. Training logs were
reviewed and were complete.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

Page 87 of 136

"un AND 'N'

PART 4 - 24,

' health ""d well,be~g l,

pm'ec"

•"UN
, 'we'"" uy •

"wu

, I signs

situations of nsk and to intervene with appropriate senSItivity, supervision, referral, and treatment.

Components

I 4.'
•

•

Remarks

prepares
Effective methods for identifying the warning signs and
symptoms of impending suicidal behavior,

Demographic, cultural, and precipitating factors of
suicidal behavior,

•

Responding to suicidal and depressed detainees,

•

Effective communication between correctional and health
care personnel,

•

Necessary referral procedures,

•

1·lousing observation and suicide-watch level procedures,

•

Follow-up monitoring of detainees who have already
attempted suicide, and

•

Reporting and written documentation procedures.

lSI

5. A
provider or
.
trained oUlceT screens
all detainees for suicide potential as part of the admission

mental health and'~:i~fd~' prevention
screening on all arriving detainees
during the intake screening process.
Health records of seven detainees
identified as having mental health
issues during intake screening were
reviewed and all had appropriate and
timely follow up by a licensed mental
health professional. Training records
of medical staff were reviewed and all
had documentation of suicide
prevention training.

The , '," :;::~:,
I' of
I mmlgratlon nt"<tl~l , ervtces po lCY
on suicide prevention were reviewed
and both contain appropriate guidance
on the prompt referral of potentially
suicidal detainees to the medical staff.

process.

Screening does not occur later than one working day
after the detainee's arrival.

•

Documentation exists that "specially trained officers"
have completed training in accordance with a syllabus
approved by the medical authority.

C8l

6, ,i,",,,
" when ",d how ,efe, a'-ri,k
detainees to medical staff and procedures are followed.

8, The
' ..,
and treatment.

room for

.s ,"

lSI

detainee to the general population, upon written
of the clinical director or appropriate health care professional.

The training plan and computerized
program were reviewed and the
staff to
detainees

e • Di'«','c',,-''nSala' ,eesntnhina'ta'°tenlaY' the
lb
Clinical
y
suicide watch.

lSI

d' I ' suni,ha:, "d
'
deSlgnate lSO ation room lor SUlCl e
watch within the short stay unit.

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
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Page 88 of 136

PARr 4-24,
This'

",u,' AND '""

~OOd'u,
,
' senSltiVlty,
.. , " '
situatIons 0 f rt'sk;;;d~to mtervene
WI'tit appropnate
'0

Components

~J!
Ul

0
'!!
Z1;RI
.. ~'O
.. ~ c

,un

9, The'
'
coorn doc< not
'any
structures or smaller items that could be used in a suicide
attempt.

10,

/StaIT

11. ~'"H

, for'

.rl t ""cide l,

Remarks

The sukide watch

IZI

IXI

not

contain small or sharp items.
Detainees on suicide watch are placed
in a suicide prevention
and
given a suicide
blanket.

room is I~cated in the
health services unit and has been
approved by the health authority.

Th"

• r-r

; ~dev~v 15 ' t the st~tus of a

l,st~IT'

; ev:r;~~s of

minutes. This was

l~
At, 'f'"
I
"d 1 d ' ' ~ staft;
d' I
o servatlon 0 nnmment y SUlCI a etamees y
me lea
or detention staff shall occur no less than every 15 minutes.
The Clinical Director (CD) may recommend constant direct
supervision. If a detainee is clinically evaluated and
determined to be at risk for suicide, medical staff shall
document the status of the detainee in the medical record at
least
) hours, unless otherwise
i by the Co.

IZI

Thisi" ~'

In CDF,m

.' oodi';;, tit fa' T
,;S not
sta, e Cllty
shall report to ICE/DRO any detainee who has
been identified as suicidal. ICEIDRO, shall consult with the
CD or designated medical authority for immediate evaluation
(with constant observation until evaluation), or for transfer to
a local psychiatric facility or emergency room by ambulance

14,

h II be

bl suicid"

<suicide

PART 4-24.

121

Meets Standard

IZI

attempt s a
su ~ect to a morta tty review process.
critical incident debriefing shall be provided to all affected

When detainees are placed on suicide
watch a constant one-Oll-one direct
observation by a security officer is
instituted. Medical staff clinically
evaluate and document the status of a
detainee as required by the detention
standards.

D Does Not Meet Standard

I AND I.,
D N/A

, :Cent"

that has 24 hour on-site
coverage. However, detainees that
require services beyond the scope of
the facility's health services staff are
referred to local behavioral health
center for evaluation and treatment.
The facility's policy requires a
mortality review process on every
completed or serious suicide attempt
• ouo.

DRepeat Finding

Remarks: (Record sIgnIfIcant facts, observatIons, other sources used, etc.)
The facility's security and medical staffs receive frequent and appropriate training in the screening, identification, referral,
and management of suicidal detainees.
Staff were observed performing suicide screening and suicide watch, and displayed appropriate sensitivity and
professionalism.

r suicid, attempt, reported ,in" th, previous in'pection,

There have boon no complet

b6,b7c

/ 10-15-02

b6,b7c

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Page 89 of 136

PART 4-25.•

~:~
.

IIVC". AND UCA. rt

';".
ca«
addr=es termmal ;)lne". fa.al
and advance directives and provides specific guidance in the event of a detainee's death.

Check this box if the facility does not accept ICE detainees who are severely or terminally ill.
NA In the appropriate box for this portion of the worksheet. ALWAYS complete all references
to detainee death and related notifications.

.'!I~
~"
~ c

Components

:liS
1.
.
who are
or
1 ill, are
transferred to an appropriate off-site medical facility.

I2J

Z'5

12ft1

0~"
~:Ii c

8 ~
D

Remarks

When required, detainees
chronically or tenninally ill are
transferred to appropriate offsite health care facilities

I 2.

.',~ of.he

The ~~i~ity or
e ICE office promptly notifies
the next-of-kin of the detainee's: medical condition.

•
•

I2J

The detainee's location.

,.,

i vmee

, m ~ou.'y me
next of kin of the detainee's

The visiting hours and rules at that location.

medical condition, location, and
visitation rules.

I 3.

There are guidelines addressing State Advanced
Directive Form for Implementing Living Wills and Advanced
Directives.
• These guidelines include instructions for detainees who
wish to have a living will.

I2J

Policy requires use of the
State's advance directive forms.
A private attorney may assist in
the preparation of the forms;
however, the facility reserves
the right to seek administrative
or judicial review.

.~n~~ese guidelines provide the detainee the opportunity to

a private attorney prepare the documents, at the
expense.
"Do No.
;'; d ~~" ;, a polky

, ""

I2J

'
,w;,h, "Do No.
,
•. o'd"m
medical record receive maximal therapeutic efforts short of
resuscitation.

121

. : of!he '.:~~~'S pohey
on Tennmal Illness
Advance Directives addresses
Do Not Resuscitate Orders

!ho.

5, I:

I;,?o

~ f ohey o~

Tho

, "

I 6 The,:::;~;'~e~~~
and
Headquarters'
Counsel of the name and basic
circumstances of any detainee with a "Do Not Resuscitate"
order in the medical record. In the case of IGSAs, this
notification is made through the local ICE representative.

•

;~i:'~'

I2J

Directives
as well as Department of
Immigration Health Services
(DIHS) local operating
procedures requires maximal
therapeutic efforts short of
resuscitation.

s!he

l~~ notify the
Clinical
DIHS Medical Director,
Governing Body, and ICE
general counsel.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

Page 90 of 136

PART4-~.,

.~Du~~on

I illness, mtal
ellS",OS
",~es speCl
"'fic gut'dan'
' ,s dooth.
an d advance <lirectlves
an:at
prOVl
ce m th e event 0f a detamee
Check this box if the facility does not accept ICE detainees who are severely or terminally ill.
NA In the appropriate box for this portion of the worksheet. ALWAYS complete all references
to detainee death and related notifications.

, ,

fijury,

'0 'ECll
J!l~ zlt
~..,

Components

• c
::is
<II

:i or~~ ~C_i~~~_h~~ :::~:es.

8,. The ~"dHty h., ,w"'..
to?otifY,ICE
officials, deceased family members and consulates, when a
detainee dies while in custody_

9, lbe, m,,;hty h" ap?H,y and
death of a
while in transport.

Remarks

<II

The

; the ;"ues

IZI

0~'"
~ ::i C

' to

organ donation and permits
donation of organs to a
detainee's relatives. The
donation of blood products is
not permitted.

~
b.or me P~';':'VH
Tennmal Illness, Advance
IZI

Directives and Death requires
notification of the AFOD, Next
of Kin and consulates.

I transport
~ohcy:
; deathffi
by ICE via ground and

, the

. At all

IZI

air transport as well as the
Justice Prisoner Air
IT
System (JPATS) .

IZI

lonn
with the provisions detailed in this standard.

11. In the event that neither ~~l~ nor consulate claims the
remains, the Field Office schedules an indigent's burial,
consistent with local procedures.

• If the detainee is a U.S. military veteran, the Department
of Veterans Affairs notified.
12. An original or
copy of a detainee's death
certificate is placed in the subject's A-File.

•

Performance of an autopsy.

~~~~?:t~es. The~e have been no
deaths of detainees at this
facility since the

IZI

, Got
providing an indigent's burial
when the family or consulate
does not claim the body, Policy
also requires notification of the
Department ofVeteratls Affairs
if the detainee was a U. S.
military veteran.

IZI

a copy of the
death certificate to be placed in
the detainee's A-File.

Section J of the policy on
Detainee Deaths provides
guidance as to who can order an
autopsy, contacting the local
coroner, obtaining death
certificates, and transportation
of the body.

13. The faci.lity follows established policy and procedures
describing when to contact the local coroner regarding sllch
issues as;

•
•
•
•

; polky

IZI

Person(s) to perform the autopsy.
Obtaining State approved death certificates.
Local transportation of the body.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
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Page 91 of136
-

------------------------------------------

PART 4-25.
.
ensures
~:and advance directives and provides

.. ~.;. AND

nealm care
.
guidance in the event of a detainee's death.

II illness, fatal

Check this box if the facility does not accept ICE detainees who are severely or terminally III.
NA in the appropriate box for this portion of the worksheet. ALWAYS complete all references
to detainee death and related notifications.

Remarks

Components

I 14. ICE stoff follows

OHOI '0' "yon

close the case of a deceased detamee.

D
IV~~,

PART 4-25.

Detainee Death provides
adequate procedures for
properly closing the case of a
deceased detainee.

AND

U~AI M

Remarks: (Record significant facts, observatfons, other sources used, etc.)
The facility's policy and procedures provide appropriate guidance for the management of detainees who are seriously or
terminally ill.
Detainees are provided the opportunity to prepare advance directives and participate in organ donation programs for
relatives .
•

equate guidance is provid

10-15-0~_

b6,b7c
/
Reviewer's Signature /

b6,b7c

•

detainee death, appropriate notifications, and case closure.
b6,b7c

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
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Page 92 of 136

•
SECTION V

ACTIVITIES STANDARDS

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

Page 93 of 136

PART

5-26.

;ANDol

will be

ensures that
government offices,

~A-

able to

1 with therr
, the wmmunity, legal
the safe and orderly operation Dfthe facility.

Components

Remarks

L
.ily
[1 P
"\,;/ and procedures
.
correspondence and other mail. The rules for correspondence
and other mail are posted in each housing or common area or
provided to each detainee via a detainee handbook.

121

The
;_~y
key information in
Spanish, and other languages spoken by a significant nwnber
of detainees.

IZl

fZl

121

fZl

IZl

Incoming mail is

I to

within 24 hours

or I business day after it is received and inspected.
one business day of its entering the internal mail system
(excluding weekends and holidays).
5. Staff maintains a logbook-recording
-of
priority, priority overnight, and certified mail delivered to the
facility for a detainee.

6. Staff does not open and inspect incoming general
correspondence and other mail (including packages and
publications) without the detainee present unless documented

and authorized in miting by the Facility Administrator or
for prevailing security reasons.

Staff does not read incoming

without the

correspondence

"orr aoe, not in'pect . .

1 C,

for physical contraband or to verify -ili~- '~.l"
enclosures without the detainee present.

9. St,ffis
outgoing
present

10. St,ff

only

status of

to . inspect

outgoing

correspondence or other mail without the
.
present
when there is reason to believe the item might present a threat
to the facility's secure or orderly operation, endanger the
recipient or the public, or might facilitate criminal activity.

II.
to ,
0' to the meille is
processed as Special Correspondence and is not read or
copied.
12. The offidal

: the

sends written notice to the
13. The
outgoing mail
notice.

t'h

fZl

pnd

I from
0'
Correspondence

121

'approval.

, of
addressee.

, m,il
of
written

a writtenrecord of every item removed
14. Staff
from detainee mail.

fZl

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

Page 94 of 136

PART 5-26.
, AND ", n~"/ MAIL
ensue.. that
W.!!I b~ able to
with their
, the
,~Iegal
government offices, and consular officials consistent with the safe and orderly operation of the facilitv_

This

JIj]

. :;,

16. The procedure for safeguarding cash removed from a
detainee protects the detainee from loss of funds and theft.
The amount of cash credited to detainee accounts is accurate.
Discrepancies are documented and investigated. Standard
procedure includes issuing a receipt to the detainee.

I2J

19. Staff
,u,
.
.
,found in
.
mail
in accordance with the Detention Standard on "Contraband",

I2J

to mail, at
20. Every
h" lbe
government expense:
At least five pieces of special
correspondence per week; lbree one ounce letters per week
Packages deemed necessary by ICE.

I2J

18.

(for example,

and
I to

i and

) "e
in the A-files.

00'"

the detainee a copy of his or her

upon request.

~e f~d!ity
.,

h" a system foe

to pmch'"

and for mailing all Special Correspondence and a
of 5 pieces of general correspondence per week.

22. The"

paper,

pencils at :~~~':t to ICE detainees.

23. SMU

.; hove lbosame

as general population.
g have

24.

access to

, ,nd

I2J

PART 5-26.

121

Remarks

I2J

bi,th .
ICE stafffo'

:!;

staff
handling of
contraband and its disposition.
Records are accurate and up to date.

17.

:;,e om:; ,e
o '"

Components

15. The

Zi~
c

D Does Not Meet Standard

Meets

AND

"on~,./

fo,
Stamps are not
purchase, but metered mail is
provided upon determination of
the cost to mail and the receipt
of appropriate funds. A system
is in place for mailing all
Special Correspondence and a
minimum of 5 pieces of general
correspondence per week.

M, ~L

D N/A

DRepeat Finding

Remarks: (Record slgmflcant facts, observations, other sources used, etc.)
Two staff is assigned to ensure mail services are provided on a scheduled basis consistent with the standard.
b6,b7c

th/1O

b6,b7c

.View,," Sign,hrro
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Page 95 of 136

PART 5-27.

,.~ro

s to
community by providing
the community to visit critically ill members of the immediate family or to attend their

This

Standard NA: Check this box if aU ICE Non-Medical Emergency Escorted Trips are handled only by the ICE Field
Office or Sub-Office in control of the detainee case.
~

... ...;;

Components

..t'E...

:;:a

s and approves, on a
1. The Field Om,e
case-by-case basis, trips to an immediate family member's:

~~] ~

lSI

Detainees who require overnight housing are placed in
1 f(j';:'A facilities.

lSI

Each escort detail includes at least two

7. The detainee remams under ,on stant, drreot visual
supervision of escorting staff.

lSI

8. Escorting
report
.
to. the
originating facility as a matter of procedure and the ranking
supervisor on duty has the authority to issue instructions for
completion of the trip.

lSI

121

•
•

Funeral

Remarks

Deathbed

I 2.

The
. l~.'J
as .
family member" a
parent (including stepparent or foster parent), brother, sister,

I 3.

'[he
. t~eility
requests for non-medical escorts.

ICE of all detainee

ICE Service Processing Center.

I 4.

The
VllU;cr reviews the file
before forwarding a detainee's request, with recommendation,

to the approving official. Each recommendation addresses
the individual's suitability fo, travel, e.g., tl" kind of
supervision required.

~
9.

decrease
instruction,
detainee.

0<
, ha~, the .
d
to.th
written
restramts m accor ance WI
procedures ""d classification level of the

do. not accept
.
1O. Escort
detainee, detainee's relative or friend f~ any reason .

•

from a

housing are coordinated with
approved IGSA facilities.

This requirement is clearly
specified in policy.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs· Rev: 07/09/07

Page 96 of 136

PART 5 - 2_'. :

n',

.~co

"nd thocommunity~,

. , ties with th,,,

emergency staff-escorted trips into the commWlity to visit critically ill members of the immediate family or to attend their

Standard NA: Check this box if all ICE Non-Medical Emergency Escorted Trips are handled only by the ICE Field
Office or SulrOffice in control of the detainee case.

.. ... ..
~

••
:::$

Components

$
on

"'il

Remarks

11. E"o,t·
ensure that·
Conduct themselves in a manner that does not bring

discredit to ICE/DRO.
0
0

Do not violate federal, state, or local laws.

Do not purchase, possess, use, consume, or administer

IZl

narcotics, other drugs, or intoxicants.

Do not arrange to visit family or friends unless
before the trip.

Make no unauthorized phone calls.

Know they are subject to search, urinalysis, breathalyzer,
or comparable test upon return to the facility.

12. The facility
.
subjects a detainee returning from
an escorted trip to a search, urinalysis, breathalyzer, etc.

~
..

requires the
.
of any detainee who violates trip rules.

14. Th, Field Office Di,,"o, i, the,
"P',

IZl

return to the

IZl

l offioial fo, all

IZl

non-medical escorted trips.

15.

, <UIU 1
tests are
not routinely administered on
detainees returning from an
escorted trip.

ICE

with Ih,

Standards:
0

Transportation (Land Transportation

Restraints applied strictly in accordance with the
of Force Standard.

c_,

U"
,

-.'.

o Does Not Meet Standard

[:;] Meets Standard

ONIA

DRepeat Finding

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

Appropriate non-medical escorted trips are authorized at the facility after receiving approval in a manner consistent with
the standard.
110-15-09
Reviewer's Signature I Date

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G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

Page 97 of 136
----

PART 5-28.
Th~s_

.$.a ..•
~

1" "

Components

The Field Office

::;:=I;;

or Facility

considers detainee marriage requests on a case-by-case basis.

I 2..
I,

. 1Office

reviews every

3, It is standard practice to require a written request for
permission to marry.

The. written request
documentation

.......
•

"'~1
~
l!

lSI

a signed
0'
the intended spouse,

from

lSI

and his or her legal

lSI

~hen
.
. is
.
th,
.
the basis for his or her
. along with instructions
on how the detainee can file an appeal

lSI

,with a

lSI

request

lSI

to approve a

lSI

5,
or her decisi~n to the
representative.

Th,

The

must submit a
written marriage request
The process includes a
requirement for a written

"lh1 I"

Remarks

request

rejected by a Facility Administrator or IGSA. Rejections are
documented.

, ,ewew

<a,

ensures. that each·
request from an
based on internal guidelines for approval of such
.

. &,

spouse stating their desire and
intention to marry the detainee.
This written statement may be
paft of the request, but is
usually submitted several steps
later in the approval process.

' a w;itten copy of hi,

de;ar~ee

. .

, the

place and time'~~ make wedding arrangements.

the

process .

. iCE official on-site is tl;: only offi~er

'.0'

request to marry.

PART 5-28.

r2I

Meets Standard

Does Not Meet Standard

ON/A

Remarks: (Record significantfacts, observations, other sources used, etc.)
The chaplam reported that during the period from September 2008 through September 2009 forty-four marriage requests
were approved, two requests were denied, and twenty six detainees were married. The approved requests that did not result
in a marriage were the result of the detainee being transferred or the intended spouse changing his/her mind.

I
/10-15-09
b6,b7c
Reviewer's Signature /

b6,b7c

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

Page 98 of 136

PARTS-29.
"hat each,
.
access to
I ""d '
constraints of safety, security, and good order.
H outdoor recreation is offered check tbis box. Items 20-27 should then be marked "N/A~.

Thi,

.
.. .. :1.-.:;;
...
""
• toll.
~

n'"

Components

Th'

•
•

An indoor recreation program .

Remarks

'"
D

IS]

and

equivalent

IS]

oversees
0' tmin."
fo' Special Management Unit and

IS]

131

An outdoor recreation program .
,

k""p,

t in good,

Th, recreational specialist

trained

detainee recreation workers.

IS]
"

, within

" 0 y'

, 2.
specialist (for
more than 350
detainees) tailors the program activities and offerings to the
detainee population.

•

Th,

recreation

Two recreational specialists are
on staff.

;.L

Dayrooms offer

activities, e.g., board games,

cards, television.

Outside

Ea:h

ace

, has tho

.., .

• y

, in daily

IS]

131

14. ne
. ;., y . '
"
hour of outdoor recreation time daily, five times per week.

IS]

15. .
.
in
receive a written
privileges.

IS]

10. Staff checks all items for damage and
equipment is returned.

12,

areas are under

[3,

, ."

when

a,eas b,fo" and

I with "dios.
in the SMU at le"t on,

when a panel revokes his 'or her

basketball, soccer, volleyball,
running and"l1r .

Th, :ao~:ty ,

9. Detainees have access to recreation activities outside the
housing units for at least one hour daily.

1 L Staff
after use.

offered include: foosball, ping
pong, chess, checkers,
battleship, television, movies,
and puzzles.

standard by providing an
opportunity for each detainee
to participate in outside
recreation one hour each day /
seven days a week.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
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Page 99 of 136

PART 5-:
~

Standard ensures that each .

This.

I and exercise programs and '

has access

within

the constraints of safety, security, and good order.

If outdoor recreation is offered check tbis box. Items 20-27 should then be marked "N/A".

..$.a..."

~il
:. ~= •c •
'"

Components

...

~ .. t;

are

programs or

:!!
Z

:~~ut every: .

transfer decisions, whether yes or no.

, off"ed

' of hi' 0'

an
program
17. A;1
. have
i before entering a secure portion
Wlth ocumentahon
, are
of the f"i1
Ig.
",enot
0' ttiend, at '
to serve as volunteers.

en,,,,e timely "view of all

19. If Y". weiUon

no outside recreation,
months?

20. '"
considered for

,to the
22. The Facility Administrator documents all detainee-

, ~~':::~

23.

"0. '

the

"',

'-~~

g
. ,': /e al; .

dCEFieJd om"

Ifno

routinely review transfer eligibility for all detainees after 60

daY'.
26. Doe, the A-file of ev."y
' . ' held moce than 60 day,
Without access to recreatIOn contams either a transfer-waiver
signed by the detainee or the Facility Administrator's written
determination of the detainee's ineligibility for transfer.

"h,

l ~e?al. representative

27.1he

is
decision.

-;1;1

PART 5-29.
121 Meets Standard

Remarks

uv,'

D Does Not Meet Standard

ON/A

DRepeat Finding

Remarks: (Record significantfacts, obsefl'ations, other sources used, etc.)
The facility has a well rounded recreational program that utilizes a variety of inside and outside recreational activities.
b6,b7c

10-15-09

b6,b7c

Review,,', Signato" I D

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•

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Page 100 of 136

PARTS-30.1
This

ensures that detainees 01' •
; beltets :
to participate in the practices of their respective faiths, constrained only by concerns about safety, security,
orderly operation of the facility, or extraordinary costs associated with a specific practice.

•
tl'E z'S ~ -!I•
--lI
~ri ~ij

Components

~hen

are
to engage in
available, these services are
languages ,,..1,- within the facility.

,""

2. ~Spo" is
serVlCes.

,in

~~ys~~ =~~i!l~:~:SSfaith.
•

in major

Remarks

lSI

Both Protestant and Catholic
services are offered in Spanish.

, th' mojo, "hoty

Lis~y exceptions.

,. ,n,

":",,,y

observances by:

•

Providing special
restrictions.

•
•
•

Honoring fasting requirements.
Facilitating religious services.

Ea~h detainee. is

meals,

consistent

with

dietary

lSI

Currently the facility
accommodates approximately
eight different religious
affiliations with meal variances.

Allowing activity restrictions.
religious items in hislher
possessIon; refer to the Funds and Personal

are checked and
allowing participation in detainee programs.

, u,

,"i""

not

i by.

to present their own services within

8. ..

-:J request

lSI

ill>

application process, submit
fingerprints, and pass a NCIC
background check.
Additionally, each volunteer
must complete a training session
in November prior to entering
the facility.

Unit moy

in the Sr,edoi 1

partlclpate m re IglOUS ':':
for the safety and
.

.;~'

before

un ess
UIC; facility.

documented

JUS

121 Meets Standard

o Does Not Meet Standard

DN/A

Finding

Remarks: (Record significant facts, observations, other sources used, etc.)
The provision of religious services at this facility involves a chaplain, assistant chaplain (vacant) and an administrative

ossi,t,nt.
b6,b7c

/lO~15~09

,view,,'S Sign,t",e /

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Page 101 of 136

PART 5-31.
This D

.
ensures that.
may maintain ties with their
them reasonable and equitable access to telephone services.
."

Components

•

:OS
If)

1.
.
are
to access to
t:~
established facility waking hours, including access to
devices.

2. ypon
facility's telephone access policy.

4.
, rul", .'
number, are posted if'

are made aware of the

ISJ

, policy is

ISJ

:~~ ISJ

"nd

of the

at a

,.ratio of one

in the facility population.

ISJ

7.
"c
I d~ily by tacilily st,tt to cns",c
that they are in good working order.

Remarks

If)

l·uni".

"!!

CHon w
,ne. ""my ~'Kes a
mformahon to detamees in languages spoken by
rl;,

z'Sjcu
~
."
.:0 c

ISJ

3.
. thc
in the Detainee Handbook.
,
,
,

: and others in the '

are located a

from

televisions.
9. Th~e~~!l~e'
"
promptly reports out-of-order
telephones to
facility's telephone service provider.

10. The facil~t~
"
monitor~ ~~pair progress and
takes appropriate measures to ensure that the required repairs
are begun and completed timely.

121

ISJ

All
; ta
rooms are not inspectedo:~
A telephone keypad in one
the admission/release holding
rooms was inoperable (Room
#5). When the number "1" was
depressed it did not work. The
telephone is programmed to
allow the automated message
to continue in English when
pressing the number" I" on the
keypad. As a result of the
inoperable keypad, the
telephone was not fully
functional and the user could
not proceed on that telephone
when requesting options via the
English language. Telephones
were inspected daily in the
housing units as evidenced in
the logbook.

The telephone in the holding
room that had an inoperable
ke)pad was reported for repair
on the same day.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

Page 102 of 136

PART '-31.
.
ensures that
may
l ties with their
them reasonable and equitable access to telephone services.

This

.. ,rutd olh"s in lhe

' by

"!!
JIl~
z-;ca
&"

Components

& c
:i.e

IJ)

11,

,deg,ee "'I

' who is having

I2J

wilh lhe ,bility to

I2J

fV1

I2J

as soon as

I2J

to return emergency phone calls as

I2J

lhe

f 1 '

access) calls.

IJ)

14. Special Access calls are at

~5,
In
ecause

' exists to ,,,ist ,

13, The

I2J

trouble placing a confidential call.
make non-collect

' fo,

legal phone calls.

12, A

:i
o .e

0&"

'to i;;"

Remarks

t lhi"

imitatlOIls 0f

to ,
hours of a request by a

• ICE makes
' """ w.thm L4

16, No
'rl:g;t':e~i
on
to
contact attorneys and
service providers who are on the
approved "Free Legal Services List",

to
17. _~p7_~~al. arrangements are made to allo,:v
speak by telephone with an immediate family member
detained in another Facility.
18,Mll
"
,

-=
20.

The m;ility has a system fo, taking ond
telephone messages.
~~one

call messages are given to

possible.
21.
.
are
soon as possible.

22"

,in

calls relating to the
matters, inCluding consultation calls.

23,.

are
l_~?~~~
case or other legal

'dn"
calls for family emergencies.

25,
'
.in.
"
custody are afforded the same
general population.
26, When

1 plione

I2J

or,

1 plione

I2J

pnVI eges as l h
at 'III

I2J

,"tnd

"!'~'m..e."ll,."e'

, cis

posted by detainee telephones, including a recorded message
on the phone system, that phone calls made by the detainees
may be monitored. Special Access calls are not monitored.
27. The ~IG p~on~,
h fo' .:'
programme mto e etamee p one system.
must verify that the number is operable.

•

ore

calls to

24,.

abuse is
reVlewer

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
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Page 103 of 136
.

,
,

Detention
ensures
them reasonable and equitable access

services.

Components

and report on the serviceability of facility phones. This is
documented on a weekly basis

[2] Meets Standard

Remarks

D Does Not Meet Standard

N/A

DRepeat Finding

Remarks: (Record significant facts, obseNations, other sources used, etc.)
Although there was one detainee telephone identified as inoperable, a system is in place to ensure all housing unit
telephones are inspected on a daily basis.
Detainees have access to the telephone as required by the standard.

b6,b7c

110-15-09

b6,b7c

Reviewer's Signature / Date

•

b6,b7c

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
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Page 104 of 136

-----------------------------------------------------------------

PART 5-32.
en,,,,esthat
\Vllf be able ro maintam ti", through
. with therr
legal representatives, and consular officials, within the constraints of safety, security, and good order.

Components

, the

Remarks

There is a written
hours for general visitation.

The visitation hours are tailored to the
population and the demand for visitation. The minimum
duration for a visit is 30 minutes.

D
Based on a '
.
logbooks and interviews with
staff assigned to visitation the
minimum duration of a visit for
a detainee is frequently less than
30 minutes. This limited

.. ,Hme;,rl"",,,,,

..~ ",e

The
.
public.

•
4.

I 6.
7.

to the

The ho",,[o<aU '
s of .
ace postoo in the
visitation waiting area.
A Mitten copy of the rul",
, and the
hours of visitation is
to
in English,
Spanish, and other major languages spoken in the facility.
A geneml

fZI

[2J

, log

D
are
to cetam
property items specified in the standard.
e to the public.

19.

ace
requirements.

land

I 10.

on
The
with.
Ill. At
. .. . whe" theee is no
"
fo, vi,its by
mlllors, ICE arranges for "~i~~~' by children and
stepchildren, on request, within the first 30 days.

112. Afte, that time, on cequ""'t, ICE
a
when possible, to a facility that will allow minor
visitation. At a minimum, monthly visits are allowed.
13.

. ~ a visit is. de~ied, to either a general population
detainee or SMU detainee, the denial is documented.

fZI

limitation of space and the
number of requests for
visitation. The standard states in
Section 5, Subsection I, "In.
unforeseen circumstances, such
as the number of visitors
exceeding visiting room
capacity, the facility
administrator may modifY
visiting periods."

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
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Page 1050f136

5-32•• "",~"~,,
TIll,
that
will be able to
, ties
community, legal representatives, and consular officials, within the constraints

en",,"

15 1:
ll~ zlt"
m"
mC

Components

:is
II)

sin,

mm"
G:i c

security,
~

121

~ p", .~e
d
. p,ioe t~ e~~h d visit, legal ,,,,vice
proVl ers an aSSIstants are 1 enti e .

121

122. The current list ofp<o bono 1eg~1'
' . ' i, posted
ill the detaillee
areas and other appropnate areas.

121

I 23. SPCs and CDF, ,hall .suhmit .Mitteu <equ"t,. foe toW's
from domestlc or mternatIonal organIzatlons and
associated with detention issues to the appropriate Field
Office Director for approval.

121

15. Le~a1•.

ore

,"ven (7) dal" a week,

116. On "guIru.
,~:i:/ega1 visitation hOllis
for a minimum of eight
hours per day and a minimum

order.

Remarks

II)

14.

with their

of four hours per day on weekends and holidays.

17.

O~regular

'
days,
are given the option
of continuing a meeting with a legal representative

through a scheduled meal.

I 1'.

.
rooms are
lUI
meetings. There is a mechanism for the detainee and
his/ller representative to exchange documents.

119. The"

searches.

I 20. ~_~gal.representativesand·

are su~je~t.t0 a non-

intrusive search - such as a pat-down search of the person

or a search of the person's belongings - at any time for
the purpose of ascertaining the presence of contraband.

I 24.

Stand~ds;a;~rC~:p~ied with.

as ,tated in the

~::inee,

to vi,it with a
are referred to the ICE
Administrator
for approval.
, 26.
0' alien, ;n
.
.:.to
visit with a detainee, are referred to the
..,
Administrator or ICE Field Office.

I 25.

PA1~T

!2.1

•

Meets Standard

5-32•

~,.~,.~

o Does Not Meet Standard o N/A

DRepeat Finding

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Page 106 of 136
-

the

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

facility recently revised the visitation hours for the general public to expand the opportunity for detainees to receive
visits.

Legal Visits: Sufficient space and time is provided to ensure legal visits are available consistent with the standard.
General Visits: The visiting area is limited in space and includes five non-contact booths and four contact visiting rooms
for general visitation. A total of nine detainees can receive general visits at one time. Visiting hours are restricted based
on a schedule that identifies specific days for each detainee based on the first initial of their last name.
/ 10-15Reviewer's Signature

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•

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Page 107 of 136

c~.,

.!;~,o,
D

-".

secunty~'~~d~good

Whil:U~;~~~galIY

and within the constraints of safety,
order.
required
affords working detainees basIc Occupational Safety and Health AdministratIon (OSHA) protections.

Check here if ICE detainees are not authorized to work at the IGSA facility. Mark NA on Form G-324A, page
3 and move to next section.

":n~ -...,tf
:;: .
...

i
Components

1. Th, tacility hoe a .
2.

{work

16I

Detainee
levels of
moots
neatness, cleanliness and sanitation standards.

3. At

are never

121

i: ... ...

." "'
1o.

to work outside the

Level I

secure perimeter.

'PLS ao? LUrs ..
.
. I d a; leve~d I ;:'v' the
opportumty to parttclpate m speCla etal S outS1 e e secure
perimeter under direct supervision.

govern selection
Voluntary Work Program.

•
•
5.

I 6.

121

participate in special details
outside the secure perimeter
under direct supervision.
Mexican Nationals are
excluded from consideration
due to the facility's close
proximity to the Mexican
border and the ability of the
Mexican Nationals to blend in
with the local population.

121

' fa>
detainees that are either
physically or mentally
challenged to participate in the
Voluntary Work Program.
There have been very few
requests for such
accommodations.

' wock

to a fixed

schedule.

8. ~a .
oi"fi' ':omhawo~kd:ta~ ~':_P'~':'
e 'WrItten Just! catIOn or t e actIOn m e ; "
detention file .

•

121

; with the
of Mexican

for

• Eight hours a day.
week.
• ", "h
7.

for the

The same procedures apply for replacement workers as
for "new" workers.
Staff follows 'Written
and
~'"
etamees
the program.

Jhe ,~'dlity
d' with
etamees, not excee mg:

Remarks

121

FOR OFFiCIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
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Page 108 of 136

PART S - 33. .

~~orK opportunities

H~'

wi~in constr~ints

~d~~~l~r'der.

and
the
of safety, security:
While not legally required
do so, ICE/DRO affords working detainees basic Occupational Safety and Health Administration (OSHA) protections.

Check here if ICE detainees are not authorized to work at the IGSA facUity. Mark NA on Form G-314A, page
3 and move to next section.

...'••" ..
~

Components

Remarks

:'5

St'ff. in .

, with ""itt",

• "'""" that

detainee volunteers lll1derstand. their responsibilities as
workers before they join the work program.

tgJ

•

OSHA standards

•

NFPA standards

121

•

A~A

11.

..
staff soc"n and
serVIce volunteers;

•

Before the assignment begins

121

•

As a matter of written procedure

12.

. "toty
for the assignment

training sufficient

121

when an ICE detainee is

121

o
o

10.

13. Pmp".
•

, toad

' is

mjured on the Job.

PARTS

33. VOLUNTARY WORK PROGRAM

D Does Not Meet Standard

CZI Meets Standard

DN/A

DRepeat Finding

Remarks: (Record significantfacts, observations, other sources used, etc.)
There was one non-compliant line item noted on this standard. Levell Mexican National detainees are prevented from
participating in outside work details.
The facility allows for both male and female detainee participation in the Voluntary Work Program.
b6,b7c

10-15-09

Reviewer's Signature / O

•

b6,b7c
b6,b7c

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
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Page 1090f136

•

SECTION VI

JUSTICE STANDARDS

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G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

Page 110 of 136

PART 6 - 34. DETAINEE HANDBOOK
,

This Detention
that, upon
every
be
that describe such matters as the facility's rules and sanctions, disciplinary system, mail and visiting procedures,
system, services, programs, and medical care, in English, Spanish, and other languages and that detainees
receipt of those materials.

•

~"E
-S.g ~~~
<
~~."

~ =
:O:j!
~:o:~

Components

10>

ha, a
Ea,h
Th'.
recelves a copy of the local handbook and the ICE
National Detainee Handbook.

[Z]

2. T h o '
is wdtt,n in
and
translated into Spanish, and other
spoken by
numbers of detainees in th~f" ...i1it,

[Z]

I 4.

"".

L6.

fa<

. ,,<;:

.
.
are read to
' ~ho cannot
read, or they are provided the material via audio or video
recordings.

5. Ih,
where one is

; tho fu,iIity

Remarks

. vidoo

I2J

[Z]

An,
.
,is
in English and Spanish,./:"

[Z]

Tho
not
been revised since May 2006
and does not reflect current
schedules in all areas.

[Z]

agent is
oversee the handbook.

[Z]

basi'

[Z]

10. Tho
fo'
f ~I~ady
l th, h
classification o
etamees, exp ams eac level, and
explains the classification appeals process.

[Z]

The
is
as necessary and there are
procedures in place for immediately communicating any
revisions to staff and detainees.

; fo, E, ;<, and
Spanish. Th~AT~:r.Language
Line service is available for
other languages.

There is an annual review of tho
designated committee or staffmember.

8. The

•
•
•
9.

address the following issues:

Personal Items pennitted to be retained by the detainee.
Initial issue of clothes, bedding and personal hygiene
items.
How to access care.
Th,
.
states in clear
detainee responsibilities.

stat" wh,n a

II.
conducted.

12. Tho
dayrooms, In-dorm
units .

•

by a

..
th,
activities and s~~ial

, will bo

manage:~~

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

Page 111 of 136

I'AKI'

Thi,

6 - 34.

. : that,., upon

every

that describe such matters as the facility's rules and
,
services, programs, and medical care, in English,
of those materials.

....

is]

Components

~ §
~

offici,1 oount tim" ",d count
procedures, meal times, feeding procedures, procedures

13, Tho

for medical or religious diets, smoking policy, clothing
exchange schedules and if authorized, clothes washing

'"
IZI

' ,written

',be,

and that detainees

'nd nth"

';I
'E
;Z;i~
~~.

mal'I an d'"
VlSIting proc odures,

:<;
Z

Remarks

and drying procedures and expected personal hygiene
practices.

'
tim:' ",d
razors and

14, Tho,

. me

,ooun WHI "e

The i"uoo,

detain:~

that

Handbook (0512008) addresses

,"w", Inc

I to ,n,ve

first.

_15, 'Ihe

IZI

wo,k

IZI

li~ra;~~;o~::~s and sc~:~:l;~urs of IZI

b"b" hou" ""d h'rr outting

restrictions.

The I

; the

policy, debit ",d

procedures, direct and frees calls; locations of telephones;
policy when telephone demand is high; and policy and
procedures for emergency phone calls.
17. The handbook addresses religious programming.

,t,t" tim" ,nd
commissary or vending machine usage.

18, Tho
,

19, Tho

the

I,!

program.
: 20. operation and law

handbook does not describe
times and a procedure for
obtaining disposable razors
under Personal Hygiene.
Additionally, it does not explain
that detainees attending court
will be afforded the opportunity
to shave first.

There is no commissary.

1 21. Tho
attorney ,nd
'
hours, policies, and procedures, location'.~fili~ list of pro
bono legal organizations; group legal rights presentations
schedule and sign up procedures.

IZI

The hours identified in the
handbook do not reflect current
regular visiting hours.

122, ~e
,
m ormatIOn.

IZI

units on 1 I,

23,

•

local ICE contact

~:;~o~::~dS

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

Page 112 of 136

PART 6 - 34. UJHiUNEE
!

that,. upon

every

'VI\.

. be

that describe such matters as the facility's rules and sanctions, .
system, services, programs, and medical care, in English,
receipt of those materials.

system, mail and visiting procedures,

and other languages and that detainees

Components
24. The

th, fadlity

Remarks

hours and

schedule and visiting rules and regulations.

D
25. Th,
procedures.

th,

, polioy and

121

The disciplinary policy and
procedures are posted in the
housing units on bulletin boards.

The grievance process has been
revised and is not included in
the detainee handbook. A
designated ICE officer now
handles all grievances.

and procedures, including:
•

Prohibited acts and severity scale sanctions.

•

Time limits in the Disciplinary Process.

•

Summary of Disciplinary Process.

27. The grievance~of the handbook
in the grievance process - Including:

s all steps

•

Infonnal (if used) and formal grievance procedures;

•

The appeals process;
In CDFs procedures for filing an appeal ofa grievance
with ICE.

•

Staf£'detainee availability to help during the grievance
process.

•

Guarantee against staff retaliation for filing/pursuing a
grievance.

•

How to file a complaint about officer misconduct with the
Department of Homeland Security.

I 28.

J ,10k
for general population and segregation.

I 29.

n pvu'Y

including:
•

Outdoor recreation hours.

•

Indoor recreation hours.

•

In dorm leisure activities.

•

Rules for television viewing.

/30.

s the detainee dress code fur .daily
living; and work assignments and the meaning of colorcoded uniforms.

nights and

I 32.

,in 1
are n~~gc~nsistent with the
current schedule. The current
visiting hours are posted in the
housing units on bulletin boards.

d to 'ign foc the

[ZI

Outdoor recreation hours are not
standard for each housing unit.
Officers in the units announce
recreation times each day.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07109/07

Page 113 of 136

fiiS

rAJU

6 -34,

'b
h
th't'th,ur:;n'I"
'I evde,y ,
dibe'l'
il 'd' "",:itten ~--.
that des en e sue matters as e utel tty S ru es an sanctions, SClP mary system, rna an Vlsltmg prv=uures,
system, services, programs, and medical care, in English, Spanish, and other languages and that detainees
Ai.. of those materials.

I
Components

Remarks

accountability.
33. Orientation materials are provided to illiterate
either orally or via audio/video tapes in a language they
can understand.

PART 6 - 34,"'j)jf

i2l Meets Standard

o Does Not Meet Standard

D N/A

ORepeat Finding

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

The facility's detainee handbook has not been updated since May 2006. Areas that need to be updated include: Visitation,
Staffl'Detainee Communication, Law Library, Count, Barbering Services, Personal Hygiene (use of razors), Clothing
Exchange, Grievance Procedures, and other pertinent topic revisions. Many of the updates, such as Visiting Hours, Law
Library Access and ICE staff contact information, are posted in English and Spanish on housing lUlit bulletin boards.
Specific times for recreation and meals varies each day per housing unit (rotating schedules) and the housing officers
announce these activities to the detainees on a daily basis.

•

assigned ICE officer with oversight duties of the detainee handbook has completed a draft update. There is no
'cation that it will be produced and distributed while copies of the current handbook are still available. An updated
msert to the current detainee handbook that addresses the specific updates/revisions required may resolve this issue. The
current use of housing unit bulletin boards also serves to inform the detainees of any changes and updates.
b6,b7c
10-15-09
Reviewer's Signature / Date

b6,b7c

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

Page 114 ofl36

PART 6 - 35. U~~

, treated !amy oy \-.

protects
may file fonnal grievances and receive timely responses.

i]
~."

Components

ace

I about the

,."my ,

end

""d

Every member of the staff knows how to identifY
emergency grievances, including the procedures for
expediting them.

Staff shall not harass,
gunish or otherwise
retaliate agamst a detainee who files a complaint or
grievance.

ISl

with
equivalent).

I 3. The.'
ill

•

process
each new
copy of the detainee handbook (or

,"oction of the

Informal and formal grievance

procedures;

and'
Staffi'detamee availability to help during the grievance
process

•

How to file a complaint about officer misconduct with the
Department of Justice.

How to file an emergency grievance.

,fnnh,:

have access to the
equivalent in IGSA), using

, (m

procedures.

Detainees may seek help from other detainees or facility
staff when preparing a grievance.

•

Illiterate, disabled, or non-English-speaking detainees
receive special assistance when necessary.
~~J

ha~ writt~. procedures for.
.
a tIme-sensitive emergency gnevance.

addresses the grievance
process, but it requires some
minor updates.

. ,of

oral grievances (Not mandatory). If yes, the detainee has
up to five days within which to make his or her concern
known to a member of the staff.

•

Remarks

all steps

Guarantee against staff retaliation for filing/pursuing a
grievance.

_jwhich

.•" a

the grievance process - Inducting:

•

"'<v.

•

..:

2. The I

formal grievance system.

•
•
•

~~."

:0: ~ ~~~
~

Zl$=

Grievances are addressed in
staff training.

include maintaining a Detainee Grievance
Log.

If not, an alternative acceptable record keeping system is
maintained.

•
•

"Nuisance complains" are identified in the records.
For quality control purposes, staff document nuisance
complaints received but not filed.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

Page 115 of 136
I

: 6-35.'
Thi,'

' ~ig»~""d ,

, uywhich

'='yuy,.

fannal grievances and

~
'"
.1:ft ;i;t;a
-1
'" z~
);ill ~

Components

10. If,
. , who
.
".~"~,"'" o~ nung
complaints or otherwise abusing the grievance system,
the Facility Administrator may authorize staff to refuse to
process subsequent complaints. This authority may not
even to an acting
Administrator.

.
'0'
~;:ifi~?a~'
th~~
officer misconduct to a higher
. or, in a CDF/IGSA
facility, to ICE.

11 Sl,th

12.

. ,of, w,!,"'"
.• <h

•n

" "",

, with the
to ,ep'"
.
of officer misconduct to a supervisor or higher-level
official in his or her chain of command, andlor to
ICEIDRO Office of Professional Responsibility and/or
the nH<
n, ',1.

~);i~

[8J

Remarks

13. St,tt

14. In
~whe",
, doo, no' ncoeptthe
grievance committee's deCision, he/she files an appeal
with the ICE Facility Administrator.

•

In all facilities written procedures cover detainee appeals
and are included in the detainee handbook
. In SPCslCDFs, the detainee has a reasonable
after the incident or informal-grievance outcome to file a
formal grievance.

PART 6-35. GRIEVANCES¥:

121 Meets Standard

D Does Not Meet Standard

DN/A

DRepeat Finding

Remarks: (Record sign{ficant facts, observations, other sources used, etc.)
The facility has recently designated an ICE officer to serve as the grievance officer. This change has not been
communicated formally to the detainee population via a detainee handbook update or by posting it on the housing bulletin
boards. An updated Grievance Procedure draft document is available for inclusion in the detainee handbook and posting
on the bulletin boards.
There were 175 grievances submitted by detainees in fiscal year 2009. There were 168 processed as informal and they
received an informal resolution. Seven (7) formal grievances were referred to the Detainee Grievance Committee for
review. Six (6 ) were resolved in favor of the detainee and one (\) was denied. The denied grievance has not been
appealed.
b6,b7c

10-15-09

b6,b7c

Review,,', Sign'Me I
b6,b7c

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs _ Rev: 07/09/07

Page 116 of 136

,
,,

,
,
,
,

PART ti-,ti. LAW

Thi,

u"n~

iAND
. '''~"
~ their access to courts,
0
t!
Z1UCIS

:lEJ!I

o:IEJ!I

Components

IJ)

Tho
use.

I law hbmy fo, detain"

J!I~

121

:Bcp-g

IJ)

2. The law library contains all materials listed in the
"Access to Legal Materials" Standard, Attachment A.
The listing of materials is posted in the law library.

•

In lieu o£'or in addition to the physical law library, ICE
detainees have access to the LexllS Nexus electronic law
library.

If the
CD-ROM service alternative is used
for the publications in Attachment A, the facility provides

•

Operable computers and printers, in sufficient numbers in
order to provide access

•
•

Photocopiers, and

121

Attachment A was not posted in
the law library, but was located in
a binder labeled "Attachment A"
which was available to all
detainees in the law library.

Supplies for both.

4. roe d.
hl,.a I d fr
. u>cn•••, i, well
It an IS reasona Y ISO ate
om nOISY areas.
5. The la",;:b~~~;t~'
computers or
and has
for daily
use by the detainees.
. D .
1_ with ~e means to save legal work
in a private electronic format for future use.
.
whe"
to
7. The. f~\ility
.. updates
applicable and legal
are
current.
8. O~tside persons . an~
.
are
.
to
submit published legal material for inclusion in the legal
library. Outside published material is forwarded and
reviewed by the ICE prior to inclusion.

~:~~ies

9. Th,,, i, a ·
ICE 0' '~''';'fei;j'
.wh~
inspects, updates, and maintain/replace
;"~aterial and
equipment on a routine basis. The
properly
disposes outdated supplements and replaces damaged or
missing material promptly.
.. , 5 hom, pe, week in the
10.
are
law library.
Detainees are not reqUITed to forego
recreation time in lieu of library usage. Detainees facing
a court deadline are given priority use of the law library.
II.
.
may request
not
' in the ~aw
library. Each request is reviewed and where appropriate
an acquisition request is initiate and timely pursued.
Request for copies of court decisions are accommodated
within 3 - 5 business days .

•

Remarks

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09107

Page 117 of 136

This:

' Ilgull>

.M""

lAND

PART 6 - 36. LAW

u; ensuring their accesg to courts,

.. -m:IE

ll~
."

Components

.. 0

:lEJ!
to ",sist oth"
.
12. Th'f:,'i~ity
voluntarily and free of charge, in researching ""d

Zi~

:!!
z

IZJ

ary or

IZJ

t"li,f ona".:, matl<",,, oot

IZJ

Remarks

preparing legal documents, consistent with security.
13.

~ta~ ensure that .
or
.
detainees without legal representatioll. rece~ve more than

access to English-language law books after indicating
their need for help.

14. D '

m,y "t,in ,

,mount of

legal material in the general population and in the special

unit. Stored legal materials are accessible
,oro ,;tteo
.

within

15. D' : r
s
in
. h .h
, law rb and
lSClP mary egregatJon umts ave t e same
1 rary
access as the general population, barring security
concerns. Detainees denied access to legal materials are
documented ""d reviewed routinely fot lifting of
sanctions.

16. All d,niol, ", ."o,,;to tl"

dully,

17. FadlitY;d·'

t~.';.a rm

group 0 etamees
law materials.

, who

retaliation, or

stamp~_to

eme access to

'~'k'

subjected to

19.'

. d . d

with free

mail related to legal matters.

PART 6 - 36. LAW

[SI Meets Standard

-r

""d

; AND

D Does Not Meet Standard

o N/A

DRepeat Finding

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

b6,b7c
/ 10-15-09
Reviewer's Signature /

b6,b7c

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09107

Page 118 of 136

PART 6-37. ,

r.ru:s .

protects:

.1<''''"''' .

ri~ts by ~suring

""u",,,

their access to .

'by'

persons

organizations fur the purpose of informing them of U.S. immigration law and procedures.

Components

'!!
:t»'g

Z1;1IS

:EJ!

o:EJ!

II)

J!l~

Remarks

II)

( here If N:cceptable overall and continue on with next

The Field Office is responsive to requests by
and accredited representatives for group presentations.

!!;

PO~i:~S~f worksheet. Mark:

I2J

2. Upon receipt of concurrence by the Field Office 1 .
the facility or authorized ICEIDRO Field Office ensures
proper notification to attorneys 01 accredited
representatives in a timely manner.

3. The facility follows policy and procedure when rejecting
provided or presented by the attorney or accredited
representative.
4.

announcing t-'~
appear in common
areas at least 48 hours in advance and sign-up sheets are
available and accessible.

I2J

ha~e access to group presentations on
.
inunigration law, procedures and detainee options.
Documentation is submitted and maintained when any
detainee is denied permission to attend a presentation and
the reason(s) for the denial.

I2J

Wh,n th, . r . oJ h 'fa T
II
to a';r,,,,d a
presentatlOn IS lImte, t e CI Ity a ows a su IClent
nUlllber of presentations so that all detainees signed up
may attend.

I2J

m
unabl, to att,nd fOI
.
reasons lllay request separate seSSlOns With presenters.
Such requests are documented.

I2l

are
when necessary to ","ist
attorneys and other legal representatives .

I2J

ai,
.a
, of on, hoUl to mak,
the presentation and additional time to conduct a
question-and-answer session.

I2J

10. Staff p~~mit presenters to

•

I2J

) sheets are
not provided. Every Monday,
Wednesday, and Friday
approved presentations are
provided to the detainee
population. Notification is made
through the orientation video
and on the day of the
presentation via intercom.

,I
,

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07109/07

Page 119 of 136

access
inunigration law and procedures.

protects
organizations for the purpose of infonning

persons

Remarks

Components

i
were
Acceptable overall and continue on with next
to meet
groups
of detainees to discuss their cases after the group
presentation. ICE/ORO or authorized detention staff are
present but do not monitor conversations with legal
providers.

[2l

12. Group

presenters
suspended are notified

~~~~hrl~----~-1

Removal, Field Operations and Detention management
Division is notified when a group or individual is
suspended from making presentations.

13.
opportunities at

to detainees upon

fonnatted presentations.

[2J Meets Standard

o Does Not Meet Standard

Remarks: (Record significant

D N/A

DRepeat Finding

ons, other sources used, etc)
b6,b7c

/ 10-15-09
Reviewer's Signature I Date
b6,b7c

•

b6,b7c

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

Page 120 of 136

•

SECTION VII

•

ADMINISTRATION & MANAGEMENT STANDARDS

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Page 121 of 136

'v,~

PART 7-38.
Thi~

t
. t and
into a facility for more than 24 ~ours a file of all .

'.fu'~ity

AD.

I for every new arrival whose

. 'Fil'. is

stay will exceed 24 hours.

2. Th,

, File

,eith,,"

copies of documentation and forms
admissions process.
3.

The

,about

0
"E
$~
Zi.g
m."

Components

FILES

m:IE

~
Z

:lES

~ ~

I2J

th~:person.

l fo, each

Remarks

generatedd:;~" the

File also

generated durmg the detainee's custody.

•
•
•
•

Special requests

A1 '-' G_'iR9R andlor 1-778 or IGSA equivalent, closed-out

u".m. '

,,'uy

Disciplinary forms/Segregation forms
Grievances, complaints, and the disposition(s) of same

4. The
secured area.

Files ore located and
.
in a
If not the cabinets are lockable and

distribution of the keys is limited to supervisors.

5. Th, Wh ~il~.
,aot;vo.d~'i~gth~" . T' ,
stay.
en e etamee IS re ease
om e act 1ty,
staff add copies of completed release documents, the

original closed-out receipts for property and valuables,
the original 1-385 or equivalent and other documentation.

6. Th, om", do,ing th,
7.

File makes a

that the file

be archived.

S,,'f mak, ,opi:' and

"nd~

from th, fil,

"'},
by supervIsory personnel at
the receiving facility or office.
8.

A
" s"m 'ave acoess to th,
" Files and
other departmental requests are accommodated by
making a request for the file. Each file is properly logged
out and in by a representative of the responsible
department.

s and data a<e

9.
from unauthorized access.

10. Unl'" "toa" 01

I ~Y '''lUte m

regulation, a detainee must sign a release-of-information
consent form prior to the release of any information, and
a copy of the form i, maintained in the detainee's
Detention File.

I!.

•

, is subject to th,
da" on
same Privacy A,t regulations as the contents of
traditional paper Detention Files and A-files.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention inspectioh Form Worksheet for IGSAs - Rev: 07/09/07

Page 122 of 136

PARI 7 - 38. ue, en,

This

into 'a fucility for more than

,v,, FICE"

:_ ,f~_~~l_ity managemen!. ~:__

2;~ours a fi~e~:all

~~e

Components

''"

;; added to a detainee's

~:2 e

8 6i

:!!
z

121

ensures tha~
12. The
.' .
or ':~"
necessary eqUipment and supplies,
copier and
copier supplies are available; all
maintained
in good wor1cing order and that equipment h" the
the volume ofwark.

Zi~

:25
If)

13. Jhe
.
rrect certam

' for each

information about that person.

Remarks

detention File.

14.

I file, Me purged ,fier six years by,·

or
not

15. Field .offi"!.·
. files on
.
housed in IGSA Facilities as needed. These files are
maintained for a minimum of 18 months.

121

purg!:;~e~:i~';:;,~n;"e

states in SEA.
"Archived files may be purged
after six years, and the material
preferably burned, if possible,
and at least shredded."

PART 7 - 38. ue, en "V I FICES
[;] Meets Standard

D Does Not Meet Standard

D N/A

DRepeat Finding

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

The inspection team determined the compliance level based on the standard. The standard states in part "archived files
may be purged after six years". The worksheet states "Archived files are purged after six years." The facility currently
does not purge archived files after six years by shredding or burning.
b6,b7c
Il()...15-09
Reviewer's Signature /

b6,b7c
b6,b7c

•

-u

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07109107

Page 123 of 136

-------------------------------PART 7 -3'.
ens"'es that the public and the media are

This

AN'"

uu~"
of events within the

"'J

areas of

interviews and tours.

Components

Remarks

The
held UlIiee
all
mtenl1ews
by
reporters,
other
news
media
representatives, academics and others not covered by the
Detention Standard on Visitation.

!ZI

IZl

tEl

All
ace
I with the News
Interview Authorization fonn (or equivalent) and filed in
the detainee's A-file with a copy in the facility's
Detention File.
The .Held Office Director
with
, to allow an '
,who
was the center of a controversy, or special interest, or

l<:..::.I

high profile case.

.Sl~ed.
forms are
and'
in the
detainee's a-file from any media representatives who
photographed or recorded any detainee in any way that

would individually identify him or her.

5. All pres~ pool~ are
in the Detention

to the

•

A press pool may be established when the Field Office
Director and facility administrator deteouine that the
volume of interview requests warrants such action.

•

All media representatives with pending or requested,
tours, or visits were notified that, effective immediately
and until further notice, all media representatives must
comply with the press pool guidelines established by the
Field Office Director.

•

All material generated from such a press pool is made
available to all news media, without right of first
publication or broadcast.

PART 7 -39.

o Meets Standard

....

0 Does Not Meet Standard

'AND'

D N/A

Finding

Remarks: (Record significant facts, obseNations, other sources used, etc.)
b6,b7c

/10-15-09
Reviewer's Signature I D
b6,b7c

b6,b7c

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs _ Rev: 07/09/07

Page 124 of 136

ifhls

ART 7 - 40. STAFF TRAINING
are
,=u
. '~~~~tI;'
refresher

that

t in their .

I duties

~'E

~~!
~
~~."
z
~~
en ~~£
i~

Components

~~~ing~'~~d annual tr~nj;: ~~y all staff, contractor~~:a~
volunteers.

Remarks
,ofl

lesson plans, and records
support compliance with this

component.
I 2.

, ie,

The amount_ and content of1

duties and function of each .

twith tl,e.
and the degree of

direct supervision that individual receives.

13.

At leaet one
for the
.

,nn

..
I with
.
coordinates and :,versees

the.

I ",d \",idedby,,'

",d

D
~eIC~
. '"
emor Ie IdTrammg

~~~

The

trainers course.

a 40-hour training-for-

time training personnel

Th: f,d!ity

'~:;"'fth"ie
facility

administrator.

S. c'n acem'" and. ..

"oo,d i,

security services have
assigned training staff that are
qualified and certified as
trainers.

,hoe

reviewed and approved the
training plan and lesson plans
for ICE staff. The DOYON
contract controls the training
for its employees and it
complies with the ICE Staff
Training Detention Standard.

of ,11

formal trammg actlvlttes m:

•
•
•

•

Individual training folders,
Other training records systems, and/or
Electronic systems.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07f09/07

Page 125 of 136

,
,

ART 7 - 40. STAFF TRAINING
and
are competent in their
requiring that they receive initial and

refresher training.

ll]

•
•
•
•
•

•
•
•
•
•
•

Each new employee, contractor, and

~."

Components

d duties

Zi~
e00
_
~ ;;: =

= ~

i = ~ '"
'"

Remarks

provided an orientation prior to assuming duties. Whtle
tailored specifically for staff, contractors, and volunteers,
the orientation programs include, at a minimum:
Working conditions

Cultural diversity/understanding staff & detainees
Code of ethics
Persormei policy manual

.d.' ""
Drug-free Workplace

Health-related emergencies

Signs of Suicide risk and precautions
Suicide prevention and intervention

Hunger strikes

IZI

Use of Force

All subjects are covered in
training.

Keys and Locks
Overview of the criminal justice system

Tour of the facility

•
•
•
•
•
•
•

•
•

•

Facility goals and objectives
Facility organization
Staff rules and regulations
Sexual harassment/sexual misconduct awareness
Personnel policies
Program overview
Orientation ,,"d training on detainee handbook end
detainee rights.
Requirement of special-needs detainees.
National Detention Standards

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Page 126 of 136

ART 7 - 40. ".~ •.
; that st~ff, contractors, and'

This:

are competent III I

requiring that they receive initial and ongoing refresher training.

Remarks

Components

7.
contact receive a
•

Working conditiolls

•

Cultural diversity/understanding staff & detainees

•

Code of ethics

•

Personnel policy manual

•

Employees' rights and responsibilities

•

Overview of the criminal justice system

•
•

Tour
Facility goals and objectives
Facility organization

•
•
•
•
•

All subjects are covered in
training.

Staff rules and regulations
Sexual harassment/sexual misconduct awareness
Persormel policies
Program overview
National Detention Standards.
Key and Lock Control.
Suicide risk and prevention .

•

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Page 127 of 136

,-----------~ART7-40.

This
t s~ff, contractors, and'
requiring that they receive initial and ongoing refresher training.

I duties

are competent in their .

Components

Remarks

and

contractors) who have regular or daily detainee contact
will receive training on the following subjects, at a
mmlmwn:
•

Security procedures and regulations

•

Code of Ethics

•

Health-related emergencies

•

Drug-free workplace

•

Signs of suicide risk and hunger strike

•

Suicide precautions

•

Use-of-force regulations and tactics

•

Report writing

•

Detainee rules and regulations

•
•

Key control
Rights and responsibilities of detainees

Safety procedures
Emergency plan and procedures
•

Interpersonal relations

•

Social/culturallifestyles of the detainee population

•

Cultural diversity/understanding staff & detainees

•

Communication skills

•

Cardiopubnonary resuscitation (CPR)lFirst aid

•

Counseling techniques

•

Sexual harassment/sexual misconduct awareness.

•

National Detention Standards .

•

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Page 128 of 136

ART 7 - 40. STAFF TRAINING
I This L '
ensures that st~ff, contractors, and
are
requiring that they receive initial and ongoing refresher training.

,t in their

dduties

Remarks

Components

e at least 40 hours
e health care
of formal orientation before undertaking their
assignments. At a minimum, the orientation program
includes:

•

The purpose, goals, policies and procedures for the
facility and parent agency security and contraband
regulations

•

Key control; appropriate conduct with detainees

•

Responsibilities and rights of employees

•

Standard precautions

•

Occupational exposure

•

Personal protective equipment

•

Bio-hazardous waste disposal

•

Overview of the detention operations.

•

National Detention Standards.

•

Medical grievance procedures and protocol.

•

Requirement for special needs detainees.

All subjects are covered in
training.

Code of Ethics
•

Drug free workplace

•

Hostage situations and staff conduct if taken hostage.

•

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Page 129 of 136

ART 7 - 40. STAFF
ensures tha~
and volunteers are competent in their
that they receive initial and
refresher training.

Thisu

Remarks

Components

10.

lduties

personnel (including

will

training on the following subjects, at
•

Security procedures and regulations

•

Supervision of detainees

•

Searches of detainees, housing units, and work areas

•

Signs of suicide risk, precaution, prevention and
intervention.

•

Code of Ethics

•
•

Drug-free workplace

•

Suicide precautions

•

Self-defense techniques

•

Use-of-force regulations and tactics

•

Report -writing

•

Detainee rules and regulations

•

Key control
Rights and responsibilities of detainees

120 hmm i,
Management and Supervisory
Staff.

Staff is trained by certified
instructors.

Safety procedures
•

Emergency plans and procedures

•

Interpersonal relations

•

Social/culturallifestyles of the detainee population

•

Cultural diversity/understanding staff & detainees

•

Communication skills

•

Cardiopulmonary resuscitation (CPR)/first aid

•

Counseling techniques

•

Sexual abuse/assault awareness

•

National Detention Standards.

I 11.
•
12.

Specialized
assignments.
..

Teams (SRTs) receive:

training
It and

before

undertaking
J'Y

their

staff receive:

•

Management and Supervisory training

13.

"-.J
authorized to use firearms
receive training that covers their use, safety, and care and
constraints on their use -- before being assigned to a post
involving their possible use .

•

rsJ

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Page 130 of 136

ART7 40.
ensures that staff, contractors,

This

! 1

d duties

are competent in their

requiring that they receive initial and ongoing refresher training.

Remarks

Components
to use

firearms demonstrate competency m their use at least
annually.
15.

1.U.l\.I~ PersOimei
to use
agents receive training in the use of chemical agents and
in the treatment of individuals exposed to a chemical
agent before being assigned to a post involving their
possible use.

[::sJ

IZI

year.
trained by
certified instructors.
instructors.
agent training is required
annually. Special Response
Team members receive
additional training on
. ,I a"nts.

16. All statf
orientation and annual
on the
facility's drug-free workplace program. 1 YP1CHI contents
are:
•

Staff, contractors, and volunteers prohibited from:

•

Using illegal drugs.

•

Possessing illegal drugs except in the authorized
performance of official duties.

•

Procedures to be used to ensure compliance.
Opportunities available for treatment and/or counseling
for drug abuse.

•

Penalties for violation of the policy.

17.

~ae: staf~is I

and I~~derstand

the~ ~~c:ti;~g drug-fr:~

workplace program, and a copy of the signed
acknowledgement is maintained in that person's
personnel file.

I 18. ther~afte~, reg~ding t~e facility's 'code of ethics.
Typical contents are:
•

Staff, contractors, and volunteers prohibited from:

•

Using their official positions to secure privileges for
themselves or others.

•

Engaging in activities that constitute a conflict of interest.

•

Accepting any gift or gratuity from, or engaging in
personal business transactions with a detainee or a
detainee's immediate family.

•

Acceptable behavior in the areas of campaigning,
lobbying or political activities .

•

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Page 131 of 136

ART 7 - 40. STAFF TRAINING
.,and
are competent in j
ensures that S";U;
t they receive initial ,..1

Components

19. Newst,ff ace
to
in writing that
they have reviewed and understand
.. work rules,
ethics, regulations, conditions of employment, and related
documents, and a copy of the signed acknowledgement is
maintained in that person's personnel file.

20.

Remarks

!ZI

~WK'}. All staff in frequent contact with
detainees is trained at least annually to respond to health-

related emergencies within four minutes. The training is
provided by a responsible medical authority in
.uW, the f"~;I;'
..
•

•

Recognizing of signs of potential health emergencies and
the required responses.
Administering first aid and cardiopuhnonary resuscitation
(CPR).

•

Obtaining emergency medical assistance through the
facility plan and its required procedures.

•

Recognizing signs and symptoms of mental illness,
suicide risk, retardation, and chemical dependency.
The facility's established plan and procedures for
providing emergency medical care including, when
required, the safe and secure transfer of detainees for
appropriate hospital or other medical services, including

Training is conducted by
Health Services supervisors.

by ambulance when indicated.

21. All st,ff in.
• '~nt~.'twi.'"
rnce trained at
least annually on the facility's Sexual Abuse and Assault
Prevention and Intervention Program, to include:

•

Understanding that sexual abuse or assault is never an
acceptable consequence of detention.

•

Recognizing housing or other situations where sexual
abuse or assault may occur.

•

Recognizing the physical, behavioral, and emotional
signs of sexual abuse or assault and ways to prevent such
occurrences.
Knowing how to report knowledge or suspicion of sexual
abuse or assault and make intervention referrals in the
facility's program.

•

C8J

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Page 132 of 136

This

ART 7-40. STAFF TRAINING
and
are competent in their assigned duties
ensures that st~tl; •
that they receive initial and
refresher training.

<;; 'E
~] Z<;:=

...=
:;
= l!

..:

[ZJ

Training is conducted by
Health Services supervisors.

[ZJ

Training is conducted by
Health Services supervisors.

[ZJ

t ...
:; ~

Components

~?~~~,~ll '''ff in

I 22.

are

Remarks

,on",t with

at least

on the fucility's

Suicide Prevention and Intervention Program, to include:

•

IdentifYing the warning
impending suicidal behavior,

•

Demographic, cultural, and precipitating factors of
suicidal behavior,

•

Responding to suicidal and depressed detainees,

SignS

and symptoms of

and health ,,,,

•
•
•

Referral procedures,

•

Follow-up monitoring of detainees who have attempted

Housing observation and suicide-watch level procedures,

and
suicide.

23. All 'mff istrain,d dur!"g

and

recognize the signs of a hunger strike and on th,
procedures for referral for medical assessment.

, tor tho ,,,, ,nd
Orientation training shall b,

. All 'm!f is train,d in proper

handling of keys.
accomplished before staff is issued keys, and key control
shall be among the topics covered in annual training.
Ordinarily, such training is done by the Security Officer
or Key Control Officer.

25.

ongoing (at least
training, all
facility staff is made aware of their responsibilities to
control situations involving aggressive detainees. At a
minimum, training shall include:

•
•
•
•
•
•
•
•
•

The requirements of this Detention Standard
The use of force continuum

•
•

•

Communication teclmiques
Cultural diversity
Dealing with the mentally ill
Confrontation-avoidance teclmiques
Approved methods of self-defense
Force cell-move teclmiques
Communicable diseases, particularly precautions to be
taken for use of force
Application of restraints (progressive and hard)

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Page 133 of 136

This

ensures that st~tl;

fr 'hand

that they receive initial and

. .

t in their

are

Components

26.

I duties

re es er trammg.

Remarks

are
to continue their education
aul professional development through incentives such as
salary enhancement, reimbursement of costs,
administrative leave.

and

7-40.STA~~~~--------~

I.2l Meets Standard

o Does Not Meet Standard

D N/A

DRepeat Finding

Remarks: (Record significant/acts, observations, other sources used, etc.)
ICE and contract staff assigned to work at the facility receives the required training on the subjects detailed in the ICE
PBNDS on Staff Training. The facility administrator approves the training plan and lesson plans for ICE staff. The staffs
that work for contract agencies are governed by their respective contracts. They receive the same training and utilize the
same lesson plans as ICE staff. Health care professionals also receive the same standard training. In addition to classroom
training the facility provides mandatory training topics through its Virtual University (VU) computer lab.
The VU serves as a best practice in the field of training.

b6,b7c

b6,b7c
10-15-09
eviewer's Signature / Date
b6,b7c

•

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Page 134 of 136

PART 7 -41.'

'Ibis
en""''''
S "'
; from , uO~::''''Y.
are
I and,
managed in regard to notifications, detainee records, safety and security, and protection of detainee funds and

::OJ!
If)

When a
0' : l.~;
representative, and a G-28 ~J~E>~ been filed,
representative of record is notified by the detainee's
Deportation Officer within 24 hours of transfer.

•
•

The notification is recorded in the detainee's file

!!
z

Remarks

If)

. and the

extenuating

The attorn.y and
are
that it is. thei'
responsibility to notify family members regardmg a
transfer.

When the A-File is not available, notification is noted
within ENFORCE.

, the "ason foc the

o~~~er :~tification

3. ~he . .
t e tlmmg of
circumstances are involved.

•

o::liEJ!!

I 4.

-e

-e ... ~
~.1Jc z:cu'g

Components

when

; tha"

Times and transfer plans are never discussed with the
detainee prior to transfer.
The detainee is not notified of the transfer until
immediately prior to departing the facility.

•

The detainee is not permitted to make any phone calls or
have contact with any detainee in the general population.

with a completed
lhe
"
Transfer Notification Form.

7. Form G-391 or
detainee from a fucility is used

. the

I oj a

8. For medical transfers:

•

The Division of Immigration Health Services (DIHS)
Medical Director or designee approves the transfer.

•

Medical transfers
ICE/DRO office.

•

medical transfer summary
accompanies the detainee.

•

Detainee is issued a minimum of 7 d,Y' worth of
prescription medications.

are
with a
summary sheet in a sealed envelope with the detainee's
name and A-number and the envelope is marked Medical
Confidential.

10. For
transfers, transporting officers receive
instructions regarding medical issues.

rue.

coordinated through the local

completed

and

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Page 135 of 136

-----

t OF UI:I.
from one fucility
.
.
in regard to notifications, detainee records, safety and security, and protection df detainee funds and personal

PART 7 - 41. "

Tiil,D

..,

Components

I
11.

, and
, and property are
" fund"
transferred with the detainee to his or her new location.

12.

, and
C and D are followed.

, in Section

=:2 c

:2J!

8 ~

IZJ

[Xl

IZJ

13.

0
1!
J!lli Z1i~
n

Remarks

eo'

new
are able to make a telephone call at the
government's expense within 12 hours ofarrival.
14. Mea" Me v

I when

occur during

15. An A-Fde 0' wo,k fold,,;
; Ibe
.
transferred to a different Field Office or sub-office.
a,.
16.
to the
am" via
overnight mail no later than one business
following
the transfer.

PART 7 -41.

~ Meets Standard

Does Not Meet Standard

D N/A

Finding

.markS: (Record significant facts, observations, other sources used, etc.)
Detainee transfers are completed by both ICE personnel and contract security personnel from DOYON.
b6,b7c

/1 0-15-09
Review,,', SignahITe

b6,b7c

~
b6,b7c

•

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Page 136 of136