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

Office of Detention Oversight
Compliance Inspection

Enforcement and Removal Operations
Saint Paul Field Office
Grand Forks County Correctional Center
Grand Forks, North Dakota

March 27-29, 2012

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

COMPLIANCE INSPECTION
GRAND FORKS COUNTY CORRECTIONAL CENTER
SAINT PAUL FIELD OFFICE
TABLE OF CONTENTS
EXECUTIVE SUMMARY ........................................................................................................... 1
INSPECTION PROCESS
Report Organization ............................................................................................................. 5
Inspection Team Members ................................................................................................... 5
OPERATIONAL ENVIRONMENT
Internal Relations ................................................................................................................. 6
Detainee Relations ...............................................................................................................6
ICE NATIONAL DETENTION STANDARDS
Detention Standards Reviewed ............................................................................................ 7
Access to Legal Material ..................................................................................................... 8
Admission and Release ........................................................................................................ 9
Detainee Classification System .......................................................................................... 12
Detainee Grievance Procedures ......................................................................................... 14
Detainee Handbook ............................................................................................................ 16
Environmental Health and Safety ...................................................................................... 17
Food Service ...................................................................................................................... 20
Funds and Personal Property ............................................................................................. 22
Medical Care ...................................................................................................................... 24
Staff-Detainee Communication ......................................................................................... 26
Telephone Access .............................................................................................................. 28
Use ofForce ....................................................................................................................... 29

EXECUTIVE SUMMARY
The Office of Professional Responsibility (OPR), Office ofDetention Oversight (ODO)
conducted a Compliance Inspection (CI) of the Grand Forks County Correctional Center
(GFCCC) in Grand Forks, North Dakota, from March 27-29, 2012. GFCCC, which opened in
2006, is owned by the County of Grand Forks and operated by the County Corrections Division
of Grand Forks County. U.S. Immigration and Customs Enforcement {ICE), Office of
Enforcement and Removal Operations (ERO) began housing detainees at GFCCC in October
2006 under an intergovernmental service agreement {IGSA) between the U.S. Marshals Service
(USMS) and GFCCC. Male and female detainees of all security classification levels are
detained at the facility for periods in excess of72 hours. GFCCC has a total capacity of245,
with no specified number dedicated to ICE detainees. GFCCC can accommodate a maximum of
60 detainees based on the availability of bed space. At the time of the inspection, the facility
housed 21 ICE detainees: 21 males and no females. The average length of stay is 17 days. The
average daily detainee population is 15. Additional bed space at GFCCC is reserved for
prisoners received from area law enforcement jurisdictions and USMS inmates. CBM Managed
Services provides food service. Grand Forks County Public Health Services provides medical
care. The facility holds no accreditations.
The ERO Field Office Director in Saint Paul, MN (FOD/Saint Paul) is responsible for ensuring
facility compliance with ICE policies and the ICE National Detention Standards (NDS). There
are no ICE personnel physically located at GFCCC. An Assistant Field Office Director (AFOD)
at the FOD/Saint Paul supervises ICE staff located at the Grand Forks Sub-Office in Grand
Forks, ND. Sub-Office staff is comprised o(b)(7)eupervisory Detention and Deportation Officer
(SDDO)(b)(7)eSupervisory Immigration Enforcement Agent (SIEA), and (b)(7)e Immigration
Enforcement Agents {lEA). There is no ERO Detention Services Manager (DSM) assigned to
cover GFCCC. The GFCCC Administrator is the highest ranking county official at GFCCC and
is responsible for oversight of daily operations. Supervisory staff at GFCCC includes(b)(7)e
Captain (b)(7)eLieutenants, and(b)(7)eSergeants. GFCCC non-supervisory staff is composed of(b)(7)e
Corrections Officers. Grand Forks County Public Health Services medical staff consists of a
Registered Nurse Administrator (RNA) (b)(7)e Registered Nurses (RN), and an Administrative
Medical Technician. (b)(7)e Medical Doctors,(b)(7)eofwhom serves as the Clinical Medical
Authority, and a Dentist provide services under contract.
In November 2010, ERO Detention Standards Compliance Unit (DSCU) contractor, MGT of
America, Inc., conducted an Annual Review of the ICE National Detention Standards (NDS) at
GFCCC. The facility received an overall rating of"Acceptable" and was found to be in
compliance with all 38 standards reviewed.
This is the first inspection ofGFCCC by ODO. ODO reviewed a total of 16 NDS. Four
standards were fully compliant; 43 deficiencies were found in the remaining 12 standards:
Access to Legal Material (1 deficiency), Admission and Release (5), Detainee Classification
System (5), Detainee Grievance Procedures (5), Detainee Handbook (1 ), Environmental Health
and Safety (10), Food Service (3), Funds and Personal Property (2), Medical Care (2), StaffDetainee Communication (5), Telephone Access (2), and Use of Force (2).

Office of Detention Oversight
March 2012
OPR 201206045

1

Grand Forks County Correctional Center
ERO Saint Paul

This report details all deficiencies and refers to specific, relevant sections ofthe NDS. ERO will
be provided a copy of the report to assist in developing corrective actions to resolve the 43
identified deficiencies. Overall, ODO found GFCCC to be orderly and well-managed, however
ODO identified some deficiencies that are significant to the health and well-being ofiCE
detainees and staff; these deficiencies were discussed with GFCCC personnel on-site during the
inspection, as well as during the close-out briefing conducted on March 29, 2012. The majority
of deficiencies identified were administrative in nature (paperwork, logs, postings), rather than
shortcomings with respect to practices and procedures.
GFCCC inmates and ICE detainees are housed together in two-person and eight-person cells.
Toilet and shower areas are adequate for the projected population. There are common areas
where detainees congregate during the day. ODO confirmed GFCCC does not issue identity
documents or wristbands, and observed inmates and ICE detainees wear the same orange
uniforms. This makes it impossible to distinguish ICE detainees from GFCCC inmates, or to
visually determine security classification levels. GFCCC management stated various options for
implementation of identity wristbands are being considered.
GFCCC uses a Minimum, Medium, and Maximum security risk classification system,
comparable to the ICE system that designates Level One (lowest threat), Level Two (medium
threat), and Level Three (highest threat). Interviews with staff and a review of the IGSA
confirmed GFCCC can house all security classification levels ofiCE detainees. A review of the
Detainee Classification System NDS confirmed ICE detainees are not pre-classified by ICE prior
to arrival at GFCCC, and ICE does not provide documentation to assist GFCCC with
classification of detainees at arrival. The lack of narrative and historical information has resulted
in all detainees receiving a Level I classification. During the ODO inspection, the POD/Saint
Paul, Grand Forks Sub-Office began providing GFCCC with necessary background
documentation for current ICE detainees to facilitate appropriate classification. A total of21
male detainees were reclassified and moved to appropriate housing units. Nine detainees were
reclassified to Level 3, six detainees were reclassified to Level 2, and six detainees remained
classified at Levell. ERO management has committed to providing GFCCC staffwith the
necessary documentation to properly classify all current and future detainees.
ODO determined detainees have the opportunity to file informal and formal grievances, and to
appeal grievance decisions. GFCCC staff attempts to resolve all grievances at the lowest level
possible. If a staff member cannot resolve a grievance, it is forwarded to the next highest level in
the GFCCC chain of command. Detainees are free to bypass the informal grievance process and
proceed directly to a formal grievance. Grievance forms are available within the housing units.
Although GFCCC retains copies of detainee grievances, there is no grievance log. During the
ODO inspection, GFCCC initiated a separate filing system for ICE detainee grievances and
created a detainee grievance log. However, due to the lack of an organized grievance file or a
grievance log, ODO was unable to conduct a comprehensive review or perform a quantitative
analysis of detainee grievances.
Review ofthe Environmental Health and Safety NDS confirmed the lack of a running inventory
of chemicals and hazardous substances; the lack of an appropriate, locked storage area for
chemicals and hazardous materials; and the lack of a running inventory of medical instruments

Office of Detention Oversight
March 2012
OPR 201206045

2

Grand Forks County Correctional Center
ERO Saint Paul

such as sharps, syringes, needles and scissors in the medical department. ODO observed the
chemical storage room in the food service area fully open with inmates working nearby;
inspection of the door confirmed it did not have a locking mechanism. This is a serious safety
concern. Inmate food service workers could potentially enter the storage area, access the
chemicals, and contaminate food, causing harm to staff, inmates, and detainees. When GFCCC
management was informed of the situation, the room was secured and a locking device was
ordered for immediate installation. Prior to the CI, GFCCC had no established procedures for
issuing, maintaining, and accounting for hazardous materials. There were no running inventories
of hazardous materials located in the medical, maintenance, and laundry storage areas. GFCCC
management stafftook immediate action to address the lack of running inventories ofhazardous
materials in these areas. During this CI, the health unit developed and implemented an inventory
system; however, maintenance personnel had not implemented an inventory system for the
maintenance and laundry storage areas prior to completion of the CI.
The food service area was clean and orderly. Detainees are fed via a satellite system. Meals are
prepared in the food service area and delivered to housing units on trays. All menus are certified
by a registered dietitian. Religious and medically-prescribed meals are provided and properly
documented.
An area of concern was identified relating to the release of detainee property when detainees
depart from GFCCC. During the inspection, ODO observed ten detainees being processed for
release. None of these detainees signed for their property as required by GFCCC policy. The
NDS does not require an IGSA facility to obtain a signature from a detainee for receipt of
property upon release; however, GFCCC policy does have this requirement. GFCCC is not
adhering to its own internal policy.
ODO noted an area of concern related to the issuance of clothing to detainees. ODO confirmed
GFCCC issues ICE detainees temperature-appropriate outerwear upon admission, but underwear,
undershirts, and socks are not issued. These items are available for purchase through the
commissary; they must be ordered individually and may take up to a week to be delivered.
GFCCC makes no provision for indigent detainees. The NDS does not specify items to be issued
to detainees housed in IGSA facilities; however, failure to provide clean undergarments is a
major concern due to potential hygiene issues. GFCCC management stated they would work
with the commissary to ensure orders for undergarments would be filled in a more expedient
manner, though GFCCC does not plan to issue undergarments to detainees free of charge.
Medical care is well managed, and the clinic is adequately staffed. An RN performs a medical
screening and a physical examination (PE) at intake. ODO reviewed 21 medical records and
confirmed intake screenings and tuberculosis testing were conducted at arrival in all cases. The
RNA provided proficiency statements signed by the contracted Clinical Medical Authority
attesting that each RN had been trained and approved to perform the hands-on portion of a PE.
In all21 cases reviewed, ODO verified aPE had been conducted within the required 14-day
timeframe, though none of the physicals had been signed by a physician as required by the
National Commission on Correctional Health Care. ODO found the medical department did not
maintain an inventory of sharps, syringes, needles, and scissors. During the inspection, an
inventory system was created and implemented to account for medical instruments. During

Office of Detention Oversight
March 2012
OPR 201206045

3

Grand Forks County Correctional Center
ERO Saint Paul

interviews with ICE detainees and GFCCC supervisory staff, there were no complaints regarding
the care and services provided by medical personnel.
ODO identified a best practice in the area of medical care. At GFCCC, correctional officers
are responsible for distributing medications to detainees. The RNA, as governed by the North
Dakota Board ofNursing, trains officers in proper procedures for medication administration in
the correctional setting. Officers are certified by completing a comprehensive program that
includes Correctional Medical Training I and II, homework, completion ofMedication
Administration Records (MAR), medication dispensation with supervision, and a final test.
Officers complete the program after two months on the job and are re-certified every two
years. ODO cites the GFCCC training program and GFCCC oversight of the performance of
correctional officers as best practices.
ICE staff conducts scheduled and regular unannounced visits each week at GFCCC to address
detainee concerns. These visits are documented on the ICE Facility Liaison Visit Checklist. No
ERO visitation schedules are posted in the housing units. ODO found GFCCC has no process
for documenting unannounced visits by ICE staff. Additionally, GFCCC does not document ICE
staffvisits of any type in the GFCCC visitor logbook. The Visitation NDS requires that facilities
maintain a log of all general visitors. During this CI, the daily arrival and departure time for
each ODO team member was not recorded. ODO verified detainees are able to submit written
requests and questions to ICE and GFCCC staff. ODO confirmed request forms are available
within the housing units, and responses to written requests are timely.
Detainees receive daily indoor recreation with access to fresh air and natural light, and have
access to religious programs, telephon~s, and a law library. At admission, all detainees receive
and sign for an ICE National Detention Handbook and a facility-specific handbook. Both
handbooks are available in English and Spanish. Visitation is offered five days per week. All
personal visits are conducted via a video link between the housing unit and the visitor's lounge.
Personal visits are limited to 30 minutes.

Office of Detention Oversight
March 2012
OPR 201206045

4

Grand Forks County Correctional Center
ERO Saint Paul

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

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

INSPECTION TEAM MEMBERS

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

Office of Detention Oversight
March 2012
OPR 201206045

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

5

ODO, Chicago
ODO, Houston
ODO, Houston
Creative Corrections
Creative Corrections
Creative Corrections

Grand Forks County Correctional Center
ERO Saint Paul

OPERATIONAL ENVIRONMENT
INTERNAL RELATIONS
ODO interviewed the GFCCC Administrator, the GFCCC Captain, the AFOD, and the
Supervisory Immigration Enforcement Officer (SIEA) assigned to the POD/Saint Paul, Grand
Forks Sub-Office. During the interviews, all personnel stated the working relationship between
GFCCC and ICE is excellent, and morale is high.
The Administrator and Captain stated the staffing level at GFCCC is sufficient to handle the
current ICE detainee population. The Administrator stated he is willing to increase the number
of ICE detainees housed at the facility and to provide transportation services. The Captain stated
he has seen ICE staff visiting ICE detainees in each of the housing units, communicating with
them, and addressing their issues or concerns at least once a week.
The AFOD and the SIEA stated GFCCC staff is very accommodating and willing to work with
ICE. The SIEA stated morale among ICE and facility staff is good; communication is open and
occurs several times each week via facility visits, email, and telephone.

DETAINEE RELATIONS
ODO interviewed eight randomly selected detainees to assess the overall living and detention
conditions at GFCCC. ODO received no complaints concerning access to legal materials,
issuance and replenishment of hygiene supplies, sending and receiving mail, recreation,
visitation, religious services, food service, or the grievance process. Detainees at GFCCC are
not issued identity cards or wristbands. GFCCC management stated research is being
conducted on the implementation of an identity wristband program. This program will
differentiate ICE detainees from GFCCC inmates.
All detainees stated they received a facility-specific detainee handbook. Six detainees (75
percent) did not know the identity of their assigned Deportation Officer (DO). ODO found
schedules for DO visits are not posted within the housing units. All detainees stated ICE
officers visit their respective housing unit a minimum of one time each week. All detainees
stated they had never been strip-searched at GFCCC. There were no complaints regarding the
quality of medical services; however, all detainees stated the response time of medical staff is
slow. ODO reviewed records and verified that response times were in accordance with the
NDS.
Six detainees (75 percent) complained of a lack of undergarments. ODO confirmed GFCCC
does not issue undershirts, underwear, or socks to inmates or detainees. Facility staff stated
these items are available through the commissary, but delivery may take up to one week. No
provisions are made for indigent detainees.

Office of Detention Oversight
March 2012
OPR 201206045

6

Grand Forks County Correctional Center
ERO Saint Paul

ICE NATIONAL DETENTION STANDARDS
ODO reviewed a total of 16 NDS and found GFCCC fully compliant with the following four
standards:
Detainee Transfers
Special Management Unit (Administrative)
Special Management Unit (Disciplinary)
Suicide Prevention and Intervention
As these standards were compliant at the time of the review, synopses for these areas were not
prepared for this report.
ODO found deficiencies in the following 12 standards:
Access to Legal Material
Admission and Release
Detainee Classification System
Detainee Handbook
Detainee Grievance Procedures
Environmental Health and Safety
Food Service
Funds and Personal Property
Medical Care
Staff-Detainee Communication
Telephone Access
Use ofForce
Findings for each of these standards are presented in the remainder of this report.

Office of Detention Oversight
March 2012
OPR 201206045

7

Grand Forks County Correctional Center
ERO Saint Paul

ACCESS TO LEGAL MATERIAL (ALM)
ODO reviewed the Access to Legal Material NDS at GFCCC to determine ifthe facility permits
detainees access to a law library, and provides legal materials, facilities, equipment, document
copying privileges, and the opportunity to prepare legal documents. ODO reviewed policies,
procedures, and the detainee handbook; inspected the law library; and interviewed staff and
detainees.
GFCCC maintains a dedicated space for the law library. This space is equipped with adequate
furnishings, one computer, and equipment and supplies to support legal research and case
preparation. ODO verified the computer contained current versions ofLexisNexis and word
processing software. Detainees are afforded up to five hours of law library access per week, and
can print documents with the assistance of a staff member.
Upon admission, GFCCC provides detainees with an ICE National Detention Handbook and a
facility-specific handbook. Both handbooks inform detainees about the availability of legal
materials and the procedures for requesting law library access. The GFCCC handbook does not
address procedures for requesting time in the law library beyond five-hours per week, procedures
for requesting legal reference materials not maintained in the law library, or procedures for
notifying an employee that library material is missing or damaged. The rules and procedures
governing access to legal materials were not posted in the law library (Deficiency ALM-:-1).

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY ALM-1
In accordance with the ICE NDS, Access to Legal Material, section (III)(Q)(l-6), the FOD must
ensure the detainee handbook or equivalent, shall provide detainees with the rules and
procedures governing access to legal materials, including the following information:
1. that a law library is available for detainee use;
2. the scheduled hours of access to the law library;
3. the procedure for requesting access to the law library;
4. the procedure for requesting additional time in the law library (beyond the 5 hours per
week minimum);
5. the procedure for requesting legal reference materials not maintained in the law library;
and
6. the procedure for notifying a designated employee that library material is missing or
damaged.
These policies and procedures shall also be posted in the law library along with a list of the law
library's holdings.

Office of Detention Oversight
March 2012
OPR 201206045

8

Grand Forks County Correctional Center
ERO Saint Paul

ADMISSION AND RELEASE (A&R)
ODO reviewed the Admission and Release NDS at GFCCC to determine if the procedures
followed in admitting and releasing detainees protect the health, safety, and welfare of each
person. ODO also conducted the review to determine if, during the admissions process,
detainees undergo screening for medical purposes; have their files reviewed for classification
purposes; submit to a standard body search; and personally observe and certify the examination,
categorization, inventorying, and safeguarding of all personal belongings. Finally, ODO
conducted the review to determine if, during the release process, detainees return clothing,
bedding, and other facility-issued items; participate in identity-verification procedures; and
complete documents in accordance with facility procedures, including certifying receipt of all
inventoried personal property, including funds and valuables. ODO reviewed policies and
detention files, interviewed facility staff and detainees, and observed the admission and release
process.
During the admission process, intake officers create an electronic detention file that is used
during detainee classification interviews. Detailed medical screenings are conducted by an RN
from the facility medical staff within the timeframe established by the NDS. GFCCC does not
routinely conduct strip searches of detainees. Supervisor-approved strip searches are conducted
only ifthere is reasonable suspicion that contraband is being concealed. The facility provides
detainees with the ICE National Detainee Handbook and the facility-specific handbook, as well
as a uniform, two blankets, a towel, and hygiene supplies. The facility does not have a sitespecific orientation program (Deficiency AR-1), or an orientation video for ICE detainees
(Deficiency AR-2). Having a site-specific orientation program and an orientation video informs
detainees about facility rules, programs, and services.
ODO noted an area of concern relating to the issuance of clothing to detainees. ODO found,
although GFCCC issues ICE detainees temperature-appropriate (outer) clothing upon admission,
undergarments, to include underwear, undershirts, and socks, are not issued by the facility.
These items are available for purchase through the commissary; however, the items must be
ordered individually and may take up to one week to be delivered. GFCCC makes no provision
for indigent detainees. Although the NDS does not specify items to be issued to detainees
housed in IGSA facilities, this is a major concern due to potential hygiene issues. This was
brought to the attention of GFCCC management during the inspection. GFCCC management
stated they would work with the commissary to ensure orders for undergarments would be filled
in a more expedient manner; however, there was no plan to issue undergarments free of charge to
detainees.
On August 15, 2011, GFCCC converted its recordkeeping system for detention files from a paper
system to an electronic system. ODO reviewed five detention files. Each file contained
biographical information, the Alien File number, and the admission and release date. None of
the files contained paperwork related to detainee classification, adverse behavior, special
requests, complaints, or other information considered appropriate for the facility record
(Deficiency AR-3). This documentation is essential to maintaining a complete record of the
time a detainee is in custody.

Office of Detention Oversight
March 2012
OPR 201206045

9

Grand Forks County Correctional Center
ERO Saint Paul

GFCCC does not use Form I-387, Report of Detainee's Missing Property, for arriving detainees
to claim property that has been lost or left behind. ODO requested records of claims for missing
property filed by detainees during the 12 months prior to the Cl. Both ICE and GFCCC staff
stated there were missing property claims made during the 12 months prior to the CI; however,
the claims were not documented due to the informal resolution of each case (Deficiency AR-4).
ODO instructed staffthat all missing property claims must be documented regardless of the
circumstances. A form to report missing property allows a detainee to file a claim, and
establishes a record that assists the detainee and the facility in better managing the claims
process. Due to the lack of documentation, ODO had no means to verify the number of claims
filed.
ODO observed GFCCC officers processing ten detainees for release. Staff returned funds and
personal property to detainees, reclaimed facility-issued clothing and bedding, and closed files.
None of the ten detainees were fingerprinted during the release process (Deficiency AR-5). A
detainee fingerprint verifies the detainee's identity and ensures the release is authorized.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY AR-1
In accordance with the ICE NDS, Admission and Release, section (III)(A), the FOD must ensure
every new arrival shall undergo screening interviews, complete questionnaires and other forms,
attend the facility's site-specific orientation program, and comply with other admission
procedures (issuance of clothing, towels, bedclothes, etc.).
DEFICIENCY AR-2
In accordance with the ICE NDS, Admission and Release, section (III)(A)(l), the FOD must
ensure the orientation process supported by a video ([ICE]) and handbook shall inform new
arrivals about facility operations, programs, and services. Subjects covered will include
prohibited activities and unacceptable [sic] and the associated sanctions.
DEFICIENCY AR-3
In accordance with the ICE NDS, Admission and Release, section (III)(A), the FOD must ensure
staff will open a detainee detention file as part ofthe admissions process. This file will contain
all paperwork generated by the detainee's stay at the facility.
DEFICIENCY AR-4
In accordance with the ICE NDS, Admission and Release, section (III)(I), the FOD must ensure
the officer shall complete Form I-387, "Report of Detainee's Missing Property" when any newly
arrived detainee claims his/her property has been lost or left behind. IGSA facilities shall
forward the completed I-387s to [ICE].
DEFICIENCY AR-5
In accordance with the ICE NDS, Admission and Release, section (III)(J), the FOD must ensure
staff must complete certain procedures before any detainee's release, removal, or transfer from
the facility. Necessary steps include completing and processing forms, closing files,

Office of Detention Oversight
March 2012
OPR 201206045

10

Grand Forks County Correctional Center
ERO Saint Paul

fingerprinting; returning personal property; and reclaiming facility-issued clothing, bedding, etc.
[ICE] will approve the IGSA release procedures.
NOTE: Under section (III) ofthis standard, the letter J occurs twice. This citation refers to the
second letter J.

Office of Detention Oversight
March 2012
OPR 201206045

11

Grand Forks County Correctional Center
ERO Saint Paul

DETAINEE CLASSIFICATION SYSTEM (DCS)
ODO reviewed the Detainee Classification System NDS at to determine if the facility
implements the NDS-provided Detainee Classification System. ODO also conducted the review
to determine ifthe facility's systems, established locally, have classification criteria that are
objective, and all procedures meet ICE requirements. Finally, ODO conducted the review to
determine if the classification system ensures each detained alien is placed in the appropriate
category and physically separated from detainees in other categories. ODO interviewed GFCCC
and ICE staff, reviewed policies and ICE detainee detention files, and observed the classification
process at GFCCC.
A written facility policy is used to classify inmates and ICE detainees upon admittance to
GFCCC. All GFCCC officers are trained in the classification system. During classification,
GFCCC intake officers conduct National Crime Information Center (NCIC) database queries for
warrants. If an outstanding warrant exists, ICE is notified. Original detainee assessments and
classification paperwork are not entered into the electronic detention file (Deficiency DCS-1).
Placing assessment and classification documentation into the detention file is essential to
maintaining a complete record, and makes historical classification information available for
future reference if reclassification is necessary.
ODO reviewed five detention files. None ofthe files had been reviewed or approved by a firstline supervisor (Deficiency DCS-2). Supervisory reviews provide assurance that each detainee
has received the appropriate classification prior to being given a housing assignment.
Interviews with GFCCC and ICE staff verified ICE detainees are not classified by ICE prior to
arrival at GFCCC. ICE relies on GFCCC to classify detainees; however, review ofthe GFCCC
classification process confirmed information necessary to assist with classification is not
provided by ICE (Deficiency DCS-3). Necessary information may include supporting
documentation, such as charging documents, Form I-213 (Record ofDeportable I Inadmissible
Alien), conviction documents, or criminal history records. This information identifies detainees
with a history of violence and prevents commingling ofLevel3 detainees with Level 1 detainees,
which protects detainees, staff, and visitors.
During the inspection, ODO informed ICE staff of the lack of documentation provided to
GFCCC for classification purposes. ICE staff took immediate action and provided GFCCC with
the necessary documentation to reclassify all detainees currently housed at GFCCC. A total of
21 male detainees were reclassified and moved to appropriate housing units. Nine detainees
were reclassified to Level 3, six detainees were reclassified to Level 2, and six detainees
remained classified at Level 1.
The GFCCC detainee handbook provides detainees with instructions on how to request
reclassification; however, GFCCC does not have a written policy that provides staff with a clear,
comprehensive understanding of rules, policies, and procedures relating to reclassification
requests, which can occur at any time (Deficiency DCS-4).

Office of Detention Oversight
March 2012
OPR 201206045

12

Grand Forks County Correctional Center
ERO Saint Paul

GFCCC does not have a procedure allowing new arrivals to appeal their classification levels
(Deficiency DCS-5). An appeals process that provides a detainee the opportunity to revisit an
inappropriate classification level promotes a safer environment for detainees that have been
incorrectly classified at a higher level than necessary.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY DCS-1
In accordance with the ICE NDS, Detainee Classification System, section {III)(B), the FOD must
ensure the officer will place all original paperwork relating to the detainee's assessment and
classification in his/her A-file (right side), with a copy placed in the detention file.
DEFICIENCY DCS-2
In accordance with the ICE NDS, Detainee Classification System, section (III)(C)(l-3), the FOD
must ensure, in all detention facilities, a supervisor will review the intake/processing officer's
classification files for accuracy and completeness. Among other things, the reviewing officer
shall ensure that each detainee has been assigned to the appropriate housing unit. In addition, the
reviewing officer will recommend changes in classification due to:
1. incidents while in custody;
2. a classification appeal by a detainee or recognized representative (see below); or
3. specific, articulable facts that surface after the detainee's in-processing.
DEFICIENCY DCS-3
In accordance with the ICE NDS, Detainee Classification System, section {III)(D), the FOD must
ensure [ICE] offices shall provide non-[ICE] facilities with the necessary information for the
facility to classify [ICE] detainees. Because [ICE] selectively releases material from the
detainee's record to persons who are not [ICE] employees (e.g., CDF or IGSA facility
personnel), non-[ICE] officers must rely on the judgment of the [ICE] staff who select material
from the files for facility use.
DEFICIENCY DCS-4
In accordance with the ICE NDS, Detainee Classification System, section (III)(G), the FOD must
ensure all facility classification systems shall ensure that a detainee may be reclassified any time
and the classification level redetermined.
DEFICIENCY DCS-5
In accordance with the ICE NDS, Detainee Classification System, section (III)(H), the FOD must
ensure all facility classification systems shall include procedures by which new arrivals can
appeal their classification levels.

Office of Detention Oversight
March 2012
OPR 201206045

13

Grand Forks County Correctional Center
ERO Saint Paul

DETAINEE GRIEVANCE PROCEDURES (DGP)
ODO reviewed the Detainee Grievance Procedures NDS at GFCCC to determine if the facility
developed and implemented standard operating procedures (SOP) that address detainee
grievances. ODO also conducted the review to determine if, among other things, the SOP
establishes a reasonable time limit for: (i) processing, investigating, and responding to
grievances; (ii) convening a grievance committee to review formal complaints; and (iii)
providing written responses to detainees who filed formal grievances, including the basis for the
decision; as well as to determine ifthe SOP also prescribes procedures applicable to emergency
grievances. Finally, ODO conducted the review to determine if all grievances receive
supervisory review, and include guarantees against reprisal. ODO interviewed staff and
detainees, and reviewed policies, the facility-specific handbook, and detainee grievances.
ICE detainees are afforded the opportunity to file informal and formal grievances, and to appeal
decisions. Forms for filing grievances are available within housing units. GFCCC uses the
general Inmate Request Form as the method for filing grievances. GFCCC staff attempt to
resolve detainee grievances and complaints at the lowest level possible. Detainees are free to
bypass or terminate the informal grievance process and proceed directly to filing a formal
grievance. GFCCC staff accepts oral grievances. The results of oral grievances made to staff
members are not documented, and copies ofthe staff members' reports are not placed in the
detainees' detention files (Deficiency DGP-1).
There is no procedure for identifying and handling emergency grievances (Deficiency DGP-2).
Emergency grievance procedures provide staff with clear instruction on how to handle issues
requiring urgent attention.
Upon resolution of a written grievance, both informal and formal, the grievance form is filed in a
general file containing all facility Inmate Request Forms. GFCCC does not maintain a separate
grievance log (Deficiency DGP-3), and copies of grievances are not placed or maintained in the
detainees' detention files (Deficiency DGP-4). Due to the lack of an organized grievance file or
a grievance log, ODO was unable to conduct a comprehensive review or perform a quantitative
analysis of detainee grievances.
During this CI, a separate grievance form was formulated specifically for ICE detainees and
distributed to the housing units. A filing system was created to maintain ICE detainee grievances
separate from the Inmate Request Form file. GFCCC management instituted an ICE detainee
grievance log.
The facility-specific handbook does not provide notice ofthe opportunity to file informal and
formal grievances, or the procedures for filing grievances and appeals. The handbook also omits
information regarding assistance in preparing a grievance, and procedures for contacting ICE to
appeal the decision of the Officer in Charge or the Facility Administrator (Deficiency DGP-5).
The Administrator stated a facility committee will be formed to revise and update the handbook
to comply with the NDS.

Office of Detention Oversight
March 2012
OPR 201206045

14

Grand Forks County Correctional Center
ERO Saint Paul

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY DGP-1
In accordance with the ICE NDS, Detainee Grievance Procedures, section (III)(A)(l), the FOD
must ensure the detainee is free to bypass or terminate the informal grievance process, and
proceed directly to the formal grievance stage. If an oral grievance is resolved to the detainee's
satisfaction at any level of review, the staff member need not provide the detainee written
confirmation of the outcome; however the staff member will document the results for the record
and place his/her report in the detainee's detention file.
DEFICIENCY DGP-2
In accordance with the ICE NDS, Detainee Grievance Procedures, section (III)(B), the FOD
must ensure each facility shall implement procedures for identifying and handling an emergency
grievance. An emergency grievance involves an immediate threat to a detainee's safety or
welfare. Once the receiving staff member approached by a detainee determines that he/she is in
fact raising an issue requiring urgent attention, emergency grievance procedures will apply.
DEFICIENCY DGP-3
In accordance with the ICE NDS, Detainee Grievance Procedures, section (III)(E), the FOD must
ensure each facility will devise a method for documenting detainee grievances. At a minimum,
the facility will maintain a Detainee Grievance Log.
DEFICIENCY DGP-4
In accordance with the ICE NDS, Detainee Grievance Procedures, section (III)(E), the FOD must
ensure a copy of the grievance will remain in the detainee's detention file for at least three years.
The facility will maintain that record for a minimum of three years and subsequently, until the
detainee leaves [ICE] custody.
DEFICIENCY DGP-5
In accordance with the ICE NDS, Detainee Grievance Procedures, section (III)(G)(l-4), the FOD
must ensure the facility shall provide each detainee, upon admittance, a copy of the detainee
handbook or equivalent. The grievance section of the detainee handbook will provide notice of
the following:
1. The opportunity to file a grievance, both informal and formal.
2. The procedures for filing a grievance and appeal, including the availability of assistance
in preparing a grievance.
3. The procedures for resolving a grievance or appeal, including the right to have the
grievance referred to higher levels if the detainee is not satisfied that the grievance has
been adequately resolved. The level above the CDF-OIC is the [ICE]-OIC.
4. The procedures for contacting [ICE] to appeal the decision of the OIC of a CDF or an
IGSA facility.

Office of Detention Oversight
March 2012
OPR 201206045

15

Grand Forks County Correctional Center
ERO Saint Paul

DETAINEE HANDBOOK (DH)
ODO reviewed the Detainee Handbook NDS at GFCCC to determine if the Officer in Charge
developed a site-specific detainee handbook to serve as an overview of, and guide to, the
detention policies, rules, and procedures in effect at the facility. ODO also conducted the review
to determine if the handbook describes the services, programs, and opportunities available
through various sources, including the facility, ICE, private organizations, etc. ODO reviewed
the standard to determine if every detainee receives a copy ofthis handbook upon admission to
the facility. Detainees are expected to behave in accordance with the rules set down in the
handbook, and will be held accountable for violations; therefore, ODO conducted the review to
determine if facility staff advise every detainee to become familiar with the material in the
handbook. ODO interviewed staff and detainees, and reviewed the facility handbook.
Detainees receive the ICE National Detention Handbook and a GFCCC facility-specific
handbook upon admittance. Handbooks are available in both English and Spanish. Detainees
must sign to acknowledge receipt and affirm responsibility to tum the handbook in to GFCCC
staff upon release or transfer from GFCCC.
The facility-specific handbook informs detainees about the programs and services GFCCC
offers, and provides information concerning contraband, prohibited acts, sanctions resulting from
misconduct, grievance and appeal processes, correspondence and mail, access to legal materials,
telephone access, recreation, and visitation. The last revision ofthe English version of the
handbook occurred on March 3, 2011. The Spanish version was last revised on July 1, 2009
(Deficiency DH-1). GFCCC staff stated a revision ofthe Spanish version ofthe detainee
handbook was not conducted at the time of the English revision due to not having a Spanish
speaking employee on staff to translate the material. ODO informed the Administrator of this
finding, who stated a committee would be formed to update and address revisions to both the
English and Spanish handbooks.
Other omissions from the handbook are reported as Deficiencies ALM-1, DGP-5, and SDC-5.

STANDARD/POLICY REQUIREMENT FOR DEFICIENT FINDINGS
DEFICIENCY DH-1
In accordance with the ICE NDS, Detainee Handbook, section (III)(I), the FOD must ensure an
appointed committee will conduct annual reviews ofthe handbook, after the annual reviews and
revisions by facility department heads and the OIC.

Office of Detention Oversight
March 2012
CPR 201206045

16

Grand Forks County Correctional Center
ERO Saint Paul

ENVIRONMENTAL HEALTH AND SAFETY (EH&S)
ODO reviewed the Environmental Health and Safety NDS at GFCCC to determine if the facility
established a hazardous materials program for the control, handling, storage, and use of
flammable, toxic, and caustic materials. This program is meant to protect detainees, staff, and
visitors, preventing breaches in safety and security. Among other things, ODO conducted the
review to determine ifthe facility includes the identification and labeling of hazardous materials,
in accordance with applicable regulations, standards, and codes (Occupational Safety and Health
Administration (OSHA), National Fire Protection Association, etc.); and provides warnings of
incompatible materials, etc. ODO toured the facility, interviewed staff, and reviewed procedures
and documentation of inspections, hazardous chemical management, and fire drills.
ODO observed facility sanitation to be satisfactory. Reports for water quality testing and pest
control were current and readily available. Facility policy does not establish procedures for
issuing, maintaining inventories, or accounting for hazardous materials (Deficiency EH&S-1 ).
ODO discovered running inventories of hazardous materials were not maintained in the medical,
maintenance, or laundry storage areas (Deficiency EH&S-2). Maintaining strict accountability
of all hazardous substances protects detainees, staff, and visitors.
Material Safety Data Sheets (MSDS) are kept in a master file and throughout the facility, but
there is no master index of all hazardous substances at GFCCC (Deficiency EH&S-3). In the
event of an emergency, a master index assures responders can quickly identify the quantity,
locations, and types of hazardous substances throughout the facility.
Facility policy and the NDS require all flammable or toxic chemicals be stored in secured areas.
The facility policy also requires toxic or flammable supplies to be returned to locked storage
closets or supply rooms immediately after use. ODO observed bleach, powdered cleanser, and
other concentrated cleaning substances in unsecured storage. ODO observed paint cans and
spray paint stored on an open shelf in the maintenance area, and aerosol cans of flammable
cooking spray unsecured in the food service area (Deficiency EH&S-4).
Exit diagrams are not posted in the main hallway and were found in only two of five housing
units (Deficiency EH&S-5). Monthly fire drills are conducted in the housing units, but are not
conducted in the food service, medical, or administration areas (Deficiency EH&S-6).
Emergency keys are not tested as part of fire drills, and emergency exit doors are not unlocked
during fire drills (Deficiency EH&S-7). Verifying the operability of emergency keys assures
expeditious egress in the event of an emergency necessitating evacuation.
Due to limited space, GFCCC does not have a dedicated barbershop. Barbering occurs in
housing unit dayrooms that lack lavatories, as well as hot and cold running water (Deficiency
EH&S-8). ODO verified barbering tools are sanitized with disinfectant solution between uses;
however, sanitation regulations are not available in housing units and are not posted in the
dayrooms (Deficiency EH&S-9). Po stings serve to remind detainees of sanitation requirements.
An inventory of medical instruments such as sharps, syringes, needles, and scissors was not
maintained in the medical area (Deficiency EH&S-10). These items pose significant safety and
Office of Detention Oversight
March 2012
OPR 201206045

17

Grand Forks County Correctional Center
ERO Saint Paul

security risk, so strict accountability is critical. GFCCC management instituted an inventory
system prior to completion ofthe Cl.
GFCCC management stated the facility emergency power generator is automatically
programmed to run a test cycle every other Monday. Documentation from the service contractor
verified the tests are run every other week, but records of each test are not generated. ODO
recommends GFCCC management produce documentation to substantiate compliance with the
standard.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENCT FINDINGS
DEFICIENCY EH&S-1
In accordance with the ICE NDS, Environmental Health and Safety, section (III), the FOD must
ensure every facility shall establish a system for storing, issuing, and maintaining inventories of
and accountability for hazardous materials.
DEFICIENCY EH&S-2
In accordance with the ICE NDS, Environmental Health and Safety, section (III)(A), the FOD
must ensure every area will maintain a running inventory of the hazardous (flammable, toxic, or
caustic) substances used and stored in that area. Inventory records will be maintained separately
for each substance, with entries for each logged on a separate card (or equivalent).
DEFICIENCY EH&S-3
In accordance with the ICE NDS, Environmental Health and Safety, section (III)(C), the FOD
must ensure the Maintenance Supervisor or designate will compile a master index of all
hazardous substances in the facility, including locations, along with a master file ofMSDSs.
He/she will maintain this information in the safety office (or equivalent) with a copy to the local
fire department. Documentation of the semi-annual reviews will be maintained in the MSDS
master file. The master index will also include a comprehensive, up-to-date list of emergency
phone numbers (fire department, poison control center, etc.).
DEFICIENCY EH&S-4
In accordance with the ICE NDS, Environmental Health and Safety, section (III)(G)(l), the FOD
must ensure all toxic and caustic materials shall be stored in secure areas, in their original
containers, with the manufacturer's label intact on each container.
DEFICIENCY EH&S-5
In accordance with the ICE NOS, Environmental Health and Safety, section (III)(L)(3)(h), the
FOD must ensure every institution will develop a fire prevention, control, and evacuation plan to
include, among other thing [sic], the following: Conspicuously posted exit diagram
conspicuously posted for and in each area.
DEFICIENCY EH&S-6
In accordance with the ICE NDS, Environmental Health and Safety, section (III)(L)(4), the FOD
must ensure monthly fire drills will be conducted and documented separately in each department.

Office of Detention Oversight
March 2012
OPR 201206045

18

Grand Forks County Correctional Center
ERO Saint Paul

DEFICIENCY EH&S-7
In accordance with the ICE NOS, Environmental Health and Safety, section (III)(L)(4)(c), the
FOO must ensure emergency-key drills will be included in each fire drill, and timed. Emergency
keys will be drawn and used by the appropriate staffto unlock one set of emergency exit doors
not in daily use. NFPA recommends a limit of four and one-half minutes for drawing keys and
unlocking emergency doors.
DEFICIENCY EH&S-8
In accordance with the ICE NOS, Environmental Health and Safety, section (III)(P)(1), the FOO
must ensure the operation [Barbershop] will be located in a separate room not used for any other
purpose. The floor will be smooth, nonabsorbent and easily cleaned. Walls and ceiling will be
in good repair and painted a light color. Artificial lighting of at least 50-foot candles will be
provided. Mechanical ventilation of 5 air changes per hour will be provided if there are no
operable windows to provide fresh air. At least one lavatory will be provided. Both hot and cold
water will be available, and the hot water will be capable of maintaining a constant flow of water
between 105 degrees and 120 degrees.
DEFICIENCY EH&S-9
In accordance with the ICE NOS, Environmental Health and Safety, section (III)(P)(4), the FOO
must ensure each barbershop will have detailed hair care sanitation regulations posted in a
conspicuous location for the use of all hair care personnel and detainees.
DEFICIENCY EH&S-10
In accordance with the ICE NOS, Environmental Health and Safety, section (III)(Q)(l ), the FOO
must ensure an inventory will be kept of those items that pose a security risk, such as sharp
instruments, syringes, needles, and scissors. This inventory will be checked weekly by an
individual designated by the medical facility Health Service Administrator (HSA) or equivalent.

Office of Detention Oversight
March 2012
OPR 201206045

19

Grand Forks County Correctional Center
ERO Saint Paul

FOOD SERVICE (FS)
ODO reviewed the Food Service NDS at GFCCC to determine if detainees are provided with
nutritious, attractively presented meals, prepared in a sanitary manner, and ifthe facility
identifies, develops, and manages resources to meet the operational needs of the food service
program. ODO reviewed available documentation, interviewed staff, inspected the food service
area, and observed meal preparation and service.
All work associated with preparing meals is performed by contractor CBM Managed Services.
No ICE detainees work in the food service area. The facility has a satellite feeding operation
involving preparation of meals in the central kitchen and delivery to housing units on trays.
ODO verified all menus are certified by a registered dietitian, and religious and medically
prescribed meals are provided and properly documented. Required temperature logs were
current. The temperature of food served during a monitored noon meal was within the required
range. Knives are kept in a double-locked storage locker, signed in and out by food service staff,
and tethered to a work table when in use. Sanitation ofthe kitchen area was acceptable. ODO
verified the local health department inspects the food service operation semi-annually.
The facility has not provided training for contract food service employees in custody matters or
the ICE detention standards (Deficiency FS-1). During the close-out briefing, GFCCC
management stated food service staff would receive training the week following the CI.
Documentation of pre-employment medical examinations was available for the inmate workers,
but not for CBM Managed Services staff (Deficiency FS-2). Medical clearance of personnel
working in food service operations serves the critical purpose of preventing transmission of
communicable diseases. GFCCC management stated medical examinations will be performed
on CBM Managed Services staff as soon as arrangements can be made.
Within the food service and preparation area, the door to a room designated as the chemical
storage area did not have a lock and could not be secured (Deficiency FS-3). This is a serious
safety concern. Inmate workers assigned to food services can access chemicals, which could
potentially contaminate food, causing harm to staff, inmates, and detainees. ODO informed
GFCCC management of the situation. GFCCC management immediately secured the room, and
a locking device was ordered for installation.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY FS-1
In accordance with the ICE NDS, Food Service, section (III)(B)(l), the FOD must ensure the
facility training officer will devise and provide appropriate training to all food service personnel
in detainee custodial issues. Among other things, this training will cover [ICE]'s detention
standards.
DEFICIENCY FS-2
In accordance with the ICE NDS, Food Service, section (III)(H)(3)(a), the FOD must ensure all
food service personnel (both staff and detainee) shall receive a pre-employment medical

Office of Detention Oversight
March 2012
OPR 201206045

20

Grand Forks County Correctional Center
ERO Saint Paul

examination. The purpose of this examination is to exclude those who have a communicable
disease in any transmissible stage or condition.

DEFICIENCY FS-3
In accordance with the ICE NDS, Food Service, section (III)(H)(ll)(c)(l), the FOD must ensure
all toxic, flammable, and caustic materials shall be segregated from food products and stored in a
locked and labeled cabinet or room. Cleaning and sanitizing compounds shall be stored apart
from food products.

Office of Detention Oversight
March 2012
OPR 201206045

21

Grand Forks County Correctional Center
ERO Saint Paul

FUNDS AND PERSONAL PROPERTY (F&PP)
ODO reviewed the Funds and Personal Property NDS at GFCCC to determine if the facility
provides for the control and safeguarding of detainees' personal property, including the secure
storage of funds, valuables, baggage, and other personnel property; a procedure for
documentation and receipting of surrendered property; and the initial and regularly scheduled
inventories of all funds, valuables, and other property. ODO reviewed policies and detention
files, interviewed facility staff, and observed the processing of funds and personal property.
GFCCC funds and personal property policy and procedures provide for the accounting,
inventory, and safeguarding of detainee property from admission to release. ODO verified funds
and valuables currently held were properly inventoried, logged by supervisory staff, and stored
in a secured area. GFCCC has a commissary, and detainees and family members can deposit
money into detainee accounts. GFCCC does not have written procedures for auditing detainee
funds, valuables, and personal property (Deficiency F&PP-1). Written procedures for auditing
personal property facilitate appropriate safeguards. GFCCC does have written procedures for the
return of funds, valuables, and personal property to detainees being transferred or released.
ODO identified an area of concern relating to the release of detainee property when detainees are
being released from GFCCC. During the inspection, ODO observed ten detainees being
processed for release. None ofthese detainees signed for their property as required by GFCCC
policy. While the NDS does not specifically require that an IGSA receive a signature from
detainees for receipt of property upon release, GFCCC policy does. GFCCC is not complying
with its own internal policy.
GFCCC does not a have a written policy or procedure for detainee property that is reported
missing or damaged (Deficiency F&PP-2). Having written procedures that provide guidance to
staff on how to deal with detainee property reported missing or damaged facilitates consistent
processing of detainee claims.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY F&PP-1
In accordance with the ICE NDS, Funds and Personal Property, section (III)(F), the FOD must
ensure each facility shall have a written procedure for inventory and audit of detainee funds,
valuables, and personal property.
DEFICIENCY F&PP-2
In accordance with the ICE NDS, Funds and Personal Property, section (III)(H)(l-7), the FOD
must ensure each facility shall have a written policy and procedures for detainee property
reported missing or damaged. All CDFs and IGSA facilities will have and follow a policy for
loss of or damage to properly receipted detainee property, as follows:
1. All procedures for investigating and reporting property loss or damage will be
implemented as specified in this standard;
2. Supervisory staff will conduct the investigation;

Office of Detention Oversight
March 2012
OPR 201206045

22

Grand Forks County Correctional Center
ERO Saint Paul

3. The senior facility contract officer will process all detainee claims for lost or damaged
property promptly;
4. The official deciding the claim will be at least one level higher in the chain of command
than the official investigating the claim;
5. The [sic] will promptly reimburse detainees for all validated property losses caused by
facility negligence;
6. The [sic] will not arbitrarily impose a ceiling on the amount to be reimbursed for a
validated claim; and
7. The senior contract officer will immediately notify the designated [ICE] officer of all
claims and outcomes.

Office of Detention Oversight
March 2012
OPR 201206045

23

Grand Forks County Correctional Center
ERO Saint Paul

MEDICAL CARE (MC)
ODO reviewed the Medical Care NDS at GFCCC to determine if all detainees have access to
medical services that promote detainee health and general well-being. ODO also conducted
the review to determine ifthe medical facility strives for accreditation with the Joint
Commission on the Accreditation of Health Care Organizations. ODO toured the medical
clinic, reviewed policies and procedures, examined medical records, verified medical staff
credentials, inspected staff clinical files, and interviewed staff.
The clinic is operated by the City of Grand Forks Public Health Services and holds no
accreditations. ODO verified staffing is sufficient to meet detainee needs. Staffing consists of
n RNA,(b)(7)e staff
(b)(7)e Physicians, one of whom serves as the Clinical Medical Authority
(b)(7)e
RNs, and(b)(7)eAdministrative Medical Technician. Dental care is provided by a Dentist from
the local community who visits the facility once a month. Emergency consultant and mental
health services are available at Altru Hospital approximately two miles from the facility. Oncall services after hours are provided by an RN or a Physician.
Intake medical screenings and tuberculosis (TB) testing are performed by an RN. A review of
21 detainee medical records verified intake screenings and TB testings were conducted upon
arrival in each case. PEs are conducted by an RN who has been trained by the Physician to
perform this function. ODO verified each ofthe 21 detainee records reviewed contained
requisite PE documentation, and each detainee received a PE within the required 14-day
timeframe; however, in each case, a Physician had not reviewed or signed the PE (Deficiency
MC-1). The RNA stated, going forward, every PE would be reviewed and signed by a
Physician. All other requirements of the .NDS and Immigration Health Service Corps
Performance Improvement criteria were met.
Detainees access health care services by completing sick call request slips available within the
housing units and during daily medication distribution. The requests are turned in to
correctional officers, who forward them to medical (Deficiency MC-2). This process creates
the potential for impeding access to medical care and violates patient confidentiality by
allowing correctional officers access to medical information documented on the request forms.
ODO recommends placing secure lock boxes in housing areas accessible only by medical
staff.
GFCCC correctional officers are responsible for distributing medications to detainees. The
RNA, as governed by the North Dakota Board of Nursing, trains officers in proper procedures
for medication administration in the correctional setting. ODO verified officers are certified
by completing a comprehensive program that includes Correctional Medical Training I and II
as the didactic. component, along with homework, completion ofMedication Administration
Records (MAR), dispensation of medication with supervision, and a final test. Officers
complete the program after two months on the job and are re-certified every two years.
Review of MARs confirmed officers properly document medication distribution. In one case
where medication was given one hour late, the officer was counseled and re-trained by the

Office of Detention Oversight
March 2012
OPR 201206045

24

Grand Forks County Correctional Center
ERO Saint Paul

RNA. ODO cites the GFCCC training program and GFCCC oversight of the performance of
correctional officers as best practices.
ODO notes one area of concern. The sick call request form used by all GFCCC prisoners
includes a statement indicating that submission of the form constitutes agreement to pay a visit
fee. The form states "All inmates are responsible for their medical care costs not covered by
insurance or detaining entity, including medications." GFCCC does not charge ICE detainees
for medical services; however, reference to a fee on the sick call form may dissuade detainees
from requesting necessary health care. ODO recommends stating on the form that detainees
will not be charged for medical services.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY MC-1
In accordance with the ICE NDS, Medical Care, section (III)(D), the FOD must ensure health
appraisals will be performed according to NCCHC [National Commission on Correctional .
Health Care] and JCAHO [Joint Commission on Accreditation ofHealthcare Organizations]
standards. NCCHC standard J -E-04 states the hands-on portion of the health assessment may
be performed by an RN only when the nurse completes appropriate training that is approved
by the responsible physician. All findings must be reviewed by a physician when the RN
completes the physical.
DEFICIENCY MC-2
In accordance with the ICE NDS, Medical Care, section (III)(M), the FOD must ensure all
medical providers shall protect the privacy of detainees' medical information to the extent
possible while permitting the exchange of health information required to fulfill program
responsibilities and to provide for the well-being of detainees.

Office of Detention Oversight
March 2012
OPR 201206045

25

Grand Forks County Correctional Center
ERO Saint Paul

STAFF-DETAINEE COMMUNICATION (SDC)
ODO reviewed the Staff-Detainee Communication NDS at GFCCC to determine if procedures
are in place to allow formal and informal contact between key facility staff and ICE staff and
ICE detainees, to permit detainees to make written requests to ICE staff and receive an answer in
an acceptable time frame. ODO interviewed staff and detainees, and reviewed policies, request
logs, detention files, and the GFCCC detainee handbook.
ICE staff conducts scheduled and unannounced visits each week at GFCCC. A scheduled visit is
conducted each Friday to complete the ICE Facility Liaison Visit Checklist, monitor living
conditions, and visit with detainees. Unannounced visits occur at least one time each week to
allow for informal communication between staff and detainees. GFCCC has no process for
documenting unannounced visits by ICE staff (Deficiency SDC-1).
ODO observed written ICE visitation schedules are not conspicuously posted in detainee living
areas (Deficiency SDC-2). It is important that a visitation schedule for ICE staff is
conspicuously posted in detainee housing units, so detainees can be made aware of the
opportunity to ask questions or directly address ICE staff.
Request forms are available within the housing units. Detainees use these forms to submit
written questions, requests, and concerns to ICE staff. The requests are collected by facility staff
and provided to ICE in a timely manner. ODO reviewed a copy ofthe ICE detainee request log
and verified responses to written requests are timely. ODO found GFCCC does not have written
procedures regarding the routing of detainee requests to ICE (Deficiency SDC-3). Written
procedures regarding the routing of ICE detainee requests educates GFCCC staff regarding the
routing process, and contributes to proper processing of requests. GFCCC does not document
the requests in a logbook. GFCCC staff stated copies of detainee requests are not maintained in
detention files (Deficiency SDC-4). Maintaining a record of the requests allows GFCCC
management to accurately monitor the request process.
A review of the GFCCC handbook does not provide guidance to detainees on submitting written
questions, requests, and concerns directly to ICE (Deficiency SDC-5).

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY SDC-1
In accordance with the ICE NDS, Staff-Detainee Communication, section (III)(A)(l), the FOD
must ensure each facility shall develop a method to document the unannounced visits, and ICE
will document visits to IGSAs.
DEFICIENCY SDC-2
In accordance with the ICE NDS, Staff-Detainee Communication, section (III)(A)(2)(b), the
FOD must ensure the ICE Field Office Director shall devise a written schedule and procedure for
weekly detainee visits by District ICE detention and deportation staff. The ICE officer will also
visit the facility's Special Management Unit to interview any ICE detainees housed there,
monitor housing conditions, review detainees' classification and basis for placement in the SMU,
Office of Detention Oversight
March 2012
OPR 201206045

26

Grand Forks County Correctional Center
ERO Saint Paul

and review all records in this regard. Written schedules shall de developed and posted in the
detainee living areas and other areas with detainee access.

DEFICIENCY SDC-3
In accordance with the ICE NDS, Staff-Detainee Communication, section (III)(B), the FOD must
ensure all detainees shall have the opportunity to submit written questions, requests, or concerns
to ICE staff using the attached detainee request form, local IGSA form or a sheet of paper. The
OIC must ensure that adequate supplies of detainee requests and writing implements are
available. All facilities that house ICE detainees must have written procedures to route detainee
requests to the appropriate ICE official.
DEFICIENCY SDC-4
In accordance with the ICE NDS, Staff-Detainee Communication, section (III)(B)(2)(a-g), the
FOD must ensure all requests shall be recorded in a logbook specifically designed for that
purpose. The log, at a minimum, shall contain:
a. The date the detainee request was received;
b. Detainee's name;
c. A-number;
d. Nationality;
e. Officer logging the request;
f. The date that the request, with staff response and action, is returned to the detainee; and
g. Any other site-specific pertinent information.
In IGSAs, the date the request was forwarded to ICE and the date it was returned shall also be
recorded. All completed Detainee Requests will be filed in the detainee's detention file and will
remain in the detainee's detention file for at least three years.

DEFICIENCY SDC-5
In accordance with the ICE NDS, Staff-Detainee Communication, section (III)(B)(3), the FOD
must ensure the facility shall provide each detainee, upon admittance, a copy of the detainee
handbook or equivalent. The handbook shall state that the detainee has the opportunity to submit
written questions, requests, or concerns to ICE staff and the procedures for doing so, including
the availability of assistance in preparing the request.

Office of Detention Oversight
March 2012
OPR 201206045

27

Grand Forks County Correctional Center
ERO Saint Paul

TELEPHONE ACCESS (TA)
ODO reviewed the Telephone Access NDS at GFCCC to determine if the facility permits them
to have reasonable and equitable access to telephones. ODO interviewed facility staff and
detainees, and conducted functionality tests oftelephones in detainee housing units.
ODO verified detainees have reasonable and equitable access to telephones at GFCCC. An
operability check of the telephones in detainee housing units was conducted, and all telephones
were in good working order. The detainee handbook provides information on telephone access;
however, access rules were not posted in the housing units (Deficiency TA-l).
GFCCC does not have a written policy addressing the monitoring of detainee telephone calls.
The detainee handbook notifies detainees that calls are subject to monitoring, and similar notices
are placed near the telephones. If detainees wish to make an unmonitored telephone call to a
legal representative, they can do so by making the request through the housing unit officer, who
will take the detainee to a private room to make the telephone call. The procedure for obtaining
an unmonitored call to a court, legal representative, or for the purpose of obtaining legal
representation, is not posted in the housing units (Deficiency TA-2). It is important that these
notifications are posted to ensure attorney-client privilege is given the appropriate
accommodation.

STANDARD/POLICY REQUIREMENT FOR DEFICIENCT FINDINGS
DEFICIENCY TA-l
In accordance with the ICE NDS, Telephone Access, section (III)(B), the FOD must ensure, as
described in the "General Provisions" standard, the facility shall provide telephone access rules
in writing to each detainee upon admittance, and also shall post these rules where detainees may
easily see them.
DEFICIENCY TA-2
In accordance with the ICE NDS, Telephone Access, section (III)(K)(l-2), the FOD must ensure
the facility shall have a written policy on the monitoring of detainee telephone calls. If telephone
calls are monitored, the facility shall notify detainees in the detainee handbook or equivalent
provided upon admission. It shall also place a notice at each monitored telephone stating: 1. that
detainee calls are subject to monitoring; and 2. the procedure for obtaining an unmonitored call
to a court, legal representative, or for the purposes of obtaining legal representation.
A detainee's call to a court, a legal representative, or for the purposes of obtaining legal
representation will not be aurally monitored absent a court order. The OIC retains the discretion
to have other calls monitored for security purposes.

Office of Detention Oversight
March 2012
OPR 201206045

28

Grand Forks County Correctional Center
ERO Saint Paul

USE OF FORCE (UOF)
ODO reviewed the Use of Force NDS at GFCCC to detennine if necessary use of force is
utilized only after all reasonable efforts have been exhausted to gain control of a subject, while
protecting and ensuring the safety of detainees, staff and others, preventing serious property
damage, and ensuring the security and orderly operation of the facility. ODO toured the facility,
inspected equipment, and reviewed the local policies, use of force files, training records, and
other pertinent documentation.
GFCCC has a written policy governing the use of force. The facility has four-point restraints
and X26 and M26 Tasers, but there has never been an instance involving the use of four-point
restraints or Tasers on an ICE detainee. ODO verified each of th (b)(7)estaff members authorized
to carry a Taser is trained in its proper use and deployment.
ODO was infonned there were no use of force incidents of any type involving ICE detainees
within the 12 months preceding the CI. ODO inventory ofGFCCC use-of-force team protective
gear found jumpsuits and gloves are not available (Deficiency UOF-1). Use ofthese items can
prevent injury to staff members and limit exposure to communicable diseases.
ODO confinned after-action reviews of use of force incidents are conducted routinely; however,
GFCCC policy does not address or provide written procedures for conducting after-action
reviews (Deficiency UOF-2). After-action reviews provide critical analysis to detennine ifthe
force used was necessary, appropriate, and in compliance with policy. Written procedures assist
with the completion of reviews consistent with established guidelines.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY UOF-1
In accordance with the ICE NDS, Use ofForce, section (III)(A)(4)(a), the FOD must ensure,
when a detainee must be forcibly moved and/or restrained during a calculated use of force, the
use-of-force team technique shall apply. The team technique usually involves five or more
trained staff members clothed in protective gear, including helmet with face shield, jumpsuit,
flack-vest or knife-resistant vest, gloves, and foreann protections. Team members enter the
detainee's area together, with coordinated responsibility for achieving immediate control ofthe
detainee.
DEFICIENCY UOF-2
In accordance with the ICE NDS, Use of Force, section (III)(K), the FOD must ensure written
procedures shall govern the use-of-force incident review, whether calculated or immediate, and
the application of restraints. The review is to assess the reasonableness ofthe actions taken
(force proportional to the detainee's actions), etc. IGSA will pattern their incident review process
after [ICE]. [ICE] shall review and approve all After Action Review procedures.

Office of Detention Oversight
March 2012
OPR 201206045

29

Grand Forks County Correctional Center
ERO Saint Paul