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
Los Angeles Field Office
James A. Musick Facility
Irvine, California

January 8 – 10, 2013

COMPLIANCE INSPECTION
JAMES A. MUSICK FACILITY
LOS ANGELES FIELD OFFICE
TABLE OF CONTENTS
EXECUTIVE SUMMARY ...........................................................................................................1
INSPECTION PROCESS
Report Organization .............................................................................................................7
Inspection Team Members ...................................................................................................7
OPERATIONAL ENVIRONMENT
Internal Relations .................................................................................................................8
Detainee Relations ...............................................................................................................8
ICE PERFORMANCE-BASED NATIONAL DETENTION STANDARDS
Detention Standards Reviewed ............................................................................................9
Environmental Health and Safety ......................................................................................10
Food Service ......................................................................................................................12
Grievance System ..............................................................................................................13
Key and Lock Controls ......................................................................................................15
Law Libraries and Legal Material......................................................................................16
Medical Care ......................................................................................................................17
Use of Force and Restraints ...............................................................................................18

All work associated with food preparation, service, and kitchen sanitation is performed by OCSD
employees. The food service staff consists of a Chief Cook, (b)(7)eSenior Head Cooks, (b)(7)e
Senior Institutional Cooks, and(b)(7)eWarehouse Worker. A crew ofb)(7) inmate workers supports
the food service operation. No ICE detainees work in food service. ODO verified all staff and
inmate workers receive medical clearances and complete training as required by the standard.
Staff and inmate workers wear hair restraints, beard guards, and personal protective equipment.
A review of the master cycle menu confirmed the menu is reviewed annually by the Chief Cook
and certified by a registered dietician. The dietician provides nutritional analysis for both the
regular and special diet menus. ODO confirmed the menu includes two hot meals per day. A
food substitution log documents proper selection of substitutes approved by the Chief Cook.
The food service department consists of two kitchens (east and west) with attached dining rooms.
The breakfast and dinner meals are served in the dining rooms using a “closed line” operation.
In closed line systems, food trays are passed through a slot. A solid barrier prevents servers and
meal recipients from seeing one another, which prevents inconsistent food portions based on
personal relationships, or conveyance of contraband. The noon meal consists of sack lunches
delivered to detainees in the housing units. ODO observed meals transported from the kitchen
by unsupervised kitchen workers on open, unlocked carts. Delivery of meals under staff
supervision and in locked carts protects food safety, and prevents food tampering.
Inspection of storage areas confirmed food was properly and safely stored. ODO verified
temperatures in the walk-in freezer and cooler are in accordance with the PBNDS. Food
preparation equipment is clean, properly installed, and equipped with machine guards and
emergency gas shut-off valves. Knives are secured in metal cabinets in the office of the Chief
Cook, and are inventoried and classified as required by the Tool Control PBNDS. Chemicals
used to maintain kitchen sanitation are properly stored and secured, and Material Safety Data
Sheets are available. Inspection of logs and containers confirmed inventories are maintained,
and proper labeling is in place. ODO observed sanitation is maintained at a high level in all
areas of the food service operation. Cleaning schedules are posted throughout the area, and
ODO observed workers cleaning per the schedules. Documentation confirms daily sanitation
inspections are conducted by food service staff. A yearly inspection conducted by the Orange
County Health Care Agency on May 23, 2012, found JAMF in compliance with California food
service regulations.
JAMF management maintains an electronic grievance log to document and track all formal
grievances submitted by detainees. Detainees are encouraged to resolve grievances informally;
however, detainees may pursue a formal grievance at any time if desired. Detainees are able to
appeal grievance decisions. JAMF staff is trained to handle emergency grievances, ensuring the
safety and welfare of detainees. JAMF management encourages its officers to report grievances
to supervisory personnel for immediate action, with a special emphasis on emergency
grievances.
A review of the grievance logs from January 2012 through December 2012 reflected only three
grievances filed. One grievance was about a lost telephone card bought from the commissary.
There was also one medical grievance and one staff misconduct allegation. JAMF management
addressed the commissary and staff misconduct grievances within five days as required by the
PBNDS; however, the medical grievance was not submitted directly to medical personnel
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designated to receive and respond to medical grievances at the facility. Delivery of a medical
grievance directly to medical personnel ensures continuity of care and privacy protection.
Additionally, the medical grievance was addressed more than five days after receipt of the
grievance. ODO confirmed JAMF staff does not file medical grievances in individual detainee
medical files.
Medical services are provided by Correctional Health Services under a Memorandum of
Understanding between the OCSD and the Orange County Healthcare Agency. The clinic is
open 24 hours a day, seven days a week, and is administered by the Chief of Operations.
Additional personnel in administrative positions include the Director of Nursing, the Nursing
Supervisor, and the Mental Health Administrative Manager. A physician holding the title of
Medical Director (MD) is the designated clinical medical authority. ODO notes all
administrators and the MD are full-time employees responsible for medical operations at JAMF
and the other two facilities operated by the OCSD: the IRC and the TLF. The same medical
policies apply to each OCSD facility, and many staff members serve on a rotation at all three
facilities: JAMF; TLF; IRC. Per the JAMF staffing plan, a physician is on-site one day a week,
and a nurse practitioner is on-site three days a week. On-call coverage is shared by a pool of
physicians and nurse practitioners. A dentist and dental hygienist are on-site five days a week to
provide dental care. Mental health services are provided by a full-time licensed mental health
specialist and a licensed social worker, supplemented by a pool of on-call psychiatrists. These
positions are augmented by registered nurses, licensed vocational nurses, a medical assistant, and
a medical records clerk. ODO finds staffing sufficient to provide basic medical services to
detainees housed at JAMF. Professional licenses were present and primary source verified with
the issuing State boards for authentication purposes.
JAMF currently holds no medical accreditations, citing cost and resources as the reason. The
MD stated to ODO that JAMF management had planned to obtain accreditation from the
Institute for Medical Quality, but it was decided budgetary resources would instead be directed
toward implementation of an electronic medical record system. ODO observed the clinic has an
effective healthcare delivery process. There are three examination/treatment rooms, a one-chair
dental suite, a break room, a nurse’s station, a mental health office, a clerical office, a medication
room, a medical records room, two separate waiting areas (one for males and one for females),
and an inmate/detainee restroom. A detention officer’s desk is located within the clinic for
custody supervision. JAMF does not have an infirmary. In the event a detainee requires medical
care beyond the scope available at JAMF, transfer to the TLF for infirmary housing is arranged.
For higher level care or specialized needs, Western Medical Anaheim Hospital or the University
of California Irvine Hospital is used. Detainees whose mental health needs exceed available
services at JAMF are transferred to the IRC for interim care, or to a local hospital for a higher
level of psychiatric care.
Medical and mental health intake screening and tuberculosis testing take place at the IRC.
Pregnancy testing for female detainees is completed at the IRC. Male detainees are transferred
from the IRC to the TLF within 12 hours for a physical examination; it is determined at the TLF
whether any medical or mental health needs preclude transfer to JAMF. JAMF accepts only
detainees with stable or low-level acuity, and females who are fewer than six months pregnant.
Based on intake screening results, female detainees are transferred to JAMF directly from the
IRC. Prior to clearance for transfer to JAMF, detainees requiring immediate attention for
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medical or mental health issues, or for medications, are referred to a medical provider for
immediate follow-up.
ODO reviewed intake documentation in the medical records of 30 detainees transferred to
JAMF. All records documented that a registered nurse conducted thorough medical and mental
health intake screenings to identify immediate, chronic care, and medication needs. ODO
verified each physical examination is conducted in accordance with the PBNDS and the National
Commission on Correctional Health Care standards.
Detainees request health care services by completing medical request forms available in English
and Spanish, and depositing them in a locked box inside the dining hall. The forms are available
in the housing units or from nursing staff. Completed forms are retrieved by medical staff during
medication distribution rounds, a minimum of twice daily. Each request is date-stamped and
triaged upon receipt. The medical records reviewed by ODO reflected same-day triage, with
medical requests addressed and completed in a timely manner based on the nature of the
complaint. Sick call is conducted on a daily basis, and is performed in the clinic. JAMF does
not charge detainees fees or co-pays for medical treatment.
The MD has instituted an informal internal chart review process; however, there is no external
peer review program as required by the PBNDS. Peer reviews identify weaknesses or errors in
work performance, and enhance or maintain the quality of services provided. The MD stated a
peer review process will be implemented. ODO confirmed medical grievances are not
maintained in individual detainee medical records.
Review of the JAMF chronic care program and documentation contained in individual medical
records confirmed monitoring and follow-up occurs in accordance with the PBNDS. Use of a
“Treatment Plan for Diabetics” form that includes sections for diet, laboratory and medication
orders, glucometer checks, and any activity restrictions is cited by ODO as a best practice. The
form is printed on yellow paper for easy identification in the record.
ODO verified JAMF has Sexual Abuse and Assault Prevention and Intervention (SAAPI) written
policy and procedures in place to prevent sexual abuse and assaults on detainees, to provide
prompt and effective intervention and treatment for victims of sexual abuse and assault, and to
control, discipline and prosecute the perpetrators of sexual abuse and assault. Detainees are
informed of the SAAPI program in the detainee handbook, during orientation via the facility
orientation video, and through conspicuous postings in housing units.
ODO confirmed there have been no detainee deaths or attempted suicides at JAMF since the
previous ODO inspections. All staff receives initial and ongoing suicide prevention training,
which includes the identification of suicide risk factors, recognizing the signs of suicidal thinking
and behavior, referral procedures, suicide prevention techniques, and responding to an inprogress suicide attempt. JAMF uses a curriculum developed locally, and presented by training
and mental health staff. Review of the training files confirmed staff completed initial and
ongoing suicide prevention training covering the above elements required by the PBNDS.

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ODO verified detainees are screened for suicide potential during the intake process at the IRC.
JAMF staff stated detainees requiring suicide watch are immediately transferred to the TLF,
where appropriate housing is available.
A secure lockbox is located in the dining hall and inside housing units for detainees to submit
ICE requests. The lockbox is checked on a daily basis and is only accessible to ERO staff.
Detainee requests are electronically logged, and responses are provided to detainees within
72 hours of receipt. ERO officers conduct weekly scheduled visits with detainees to address
questions or concerns. Visitation schedules are conspicuously posted in each housing unit.
ODO verified regular and unannounced supervisory and non-supervisory staff visits are
conducted and documented by ERO staff.
Review of the JAMF use of force policy confirmed all requirements of the standard are
addressed. The facility has an Emergency Response Team for calculated use of force incidents.
JAMF does not use a restraint chair or four-point restraints on ICE detainees. ODO confirmed
all intermediate force devices are properly secured, and confirmed there have been no incidents
requiring calculated or immediate use of force involving detainees in the 12 months preceding
the ODO inspection.
All JAMF officers receive initial and annual training in the use of force policy. Review of the
curriculum confirmed it includes all topics required by the PBNDS, including confrontation
avoidance and self-defense tactics. Inspection of training records for(b)(7)eofficers confirmed
completion of training and current certifications in intermediate force devices for all but (b)(7)e
(b)(7)e
officers. (b)(7)e certification had expired on August 2, 2012, and
on October 4, 2012.
The Training Sergeant at JAMF stated
transferred to JAMF in December 2012 and
(b)(7)e
will be attending annual training as soon as practical.

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

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

INSPECTION TEAM MEMBERS

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

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

7

ODO, Phoenix
ODO, Phoenix
ODO, Phoenix
ODO, Phoenix
Creative Corrections
Creative Corrections
Creative Corrections

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OPERATIONAL ENVIRONMENT
INTERNAL RELATIONS
ODO interviewed OCSD supervisory and non-supervisory staff assigned to JAMF, including a
Captain, a Lieutenant, and an Assistant Administrator. ODO also interviewed ERO supervisory
staff, including one AFOD and an SDDO. During the interviews, all OCSD personnel and ERO
staff stated the working relationship between ICE and OCSD is excellent.
All OCSD personnel stated morale is high. The Captain, the Lieutenant, and the Assistant
Administrator all advised that OCSD has adequate personnel assigned to the facility to handle
the current ICE detainee population at JAMF. All stated they consistently see ERO officers
visiting the housing units multiple times each week and communicating with detainees to address
issues or concerns.
The AFOD and SDDO stated morale has greatly improved since the last ODO inspection. The
SDDO stated ERO staff has been increased to accommodate the workload, and a Detention
Removal Assistant has been assigned for administrative support and operational assistance.

DETAINEE RELATIONS
ODO interviewed 14 randomly-selected male and seven randomly-selected female ICE detainees
to assess the overall living and detention conditions at JAMF. All detainees interviewed stated
they received a detainee handbook and adequate hygiene supplies upon arrival.
One detainee could not identify a Deportation Officer by name. However, all detainees
interviewed stated that an ICE official visits each housing area daily, and all detainees were
aware of how to contact a Deportation Officer. ODO confirmed through review of facility
visitation logs that ICE personnel frequent the housing units. Six detainees complained it takes
medical personnel too long to respond to sick call requests; however, medical records confirmed
all sick call requests are triaged within the 48-hour period required by the PBNDS. During
interviews, a detainee stated he observed medical personnel responded immediately to a detainee
in the housing unit who complained of having an allergic reaction to food.
ODO received no complaints concerning religious services, food service, recreation, visitation,
access to telephones, or sending and receiving mail. All detainees stated they were treated with
dignity and respect by personnel at JAMF.

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ICE PERFORMANCE-BASED
NATIONAL DETENTION STANDARDS
ODO reviewed a total of 16 PBNDS and found JAMF fully compliant with the following nine
standards:
Correspondence and Other Mail
Detainee Handbook
Emergency Plans
Personal Hygiene
Recreation
Sexual Abuse and Assault Prevention and Intervention
Staff-Detainee Communication
Suicide Prevention and Intervention
Visitation
As these standards were compliant at the time of the review, a synopsis for these areas was not
prepared for this report.
ODO found deficiencies in the following seven standards:
Environmental Health and Safety
Food Service
Grievance System
Key and Lock Control
Law Libraries and Legal Material
Medical Care
Use of Force and Restraints
Findings for each of these standards are presented in the remainder of this report.

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ENVIRONMENTAL HEALTH AND SAFETY (EH&S)
ODO reviewed the Environmental Health and Safety standard at JAMF to determine if the
facility maintains high standards of cleanliness and sanitation, safe work practices, and control of
hazardous materials and substances, in accordance with the ICE PBNDS. ODO toured the
facility, interviewed staff, and reviewed policies and documentation of inspections, hazardous
chemical management, generator testing, and fire drills.
Sanitation is maintained at a high level throughout the facility. The medical area, dining rooms,
and food service department were observed to be exceptionally clean.
ODO reviewed the fire prevention, control, and evacuation plan at JAMF and determined it
addresses all requirements of the PBNDS. The Orange County Fire Authority last inspected
JAMF on January 9, 2012, and found no deficiencies. JAMF management stated the 2013
inspection will be scheduled in the near future. ODO confirmed monthly fire drills are
conducted on each shift and documentation is on-file. Pest control invoices are current.
Barbering is conducted in a designated area, and hair care sanitation regulations are
conspicuously posted. Documentation confirms requirements for handling medical waste are
met, and inventories and records for disposal of sharp objects are accurate.
Tests of drinking and waste water are not conducted (Deficiency EH&S-1). Annual State
testing certifies drinking water is safe and waste water contains no toxins harmful to the
environment upon discharge.
The emergency electrical power generators at JAMF are tested on a weekly basis to ensure their
readiness to perform in the event of an emergency. The tests include inspection of oil and water
levels, and hose and belt integrity, but the tests are 30 minutes in duration rather than 60 minutes
required by the standard (Deficiency EH&S-2). This deficiency was cited during the
August 2011 ODO inspection. JAMF management provided ODO with a memorandum from the
ERO Detention Management Division waiving the requirement for 60-minute testing due to a
limitation of 20 hours per year operation time for testing purposes imposed by the local air
quality management district.
ODO reviewed procedures in place for control, storage, and issuance of hazardous materials. A
master index and documentation of review is available. Material Safety Data Sheets are included
in the index and are maintained in all areas where these substances are used. Inspection
confirmed inventories of cleaning agents maintained and distributed from the central warehouse
to the housing units, laundry area, and medical services are accurate in all areas. In addition,
ODO confirmed the accuracy of inventories of chemicals supplied by the Safety Manager for use
in the barbershop and housing units. However, during inspection of the operations department,
ODO found hazardous substance inventories were inaccurate (Deficiency EH&S-3). In the
plumbing area, the inventory for “Sizzle,” a lime, rust, and scale remover, documented that five
containers were available; ODO found 16. The plumber adjusted the inventory when the
inaccuracy was brought to his attention. In the mechanical services work area, the inventory for
“Quick Seal,” an adhesive caulk, listed 17 containers were on hand when only 11 containers
were present. In the Heating/Ventilation/Air Conditioning (HVAC) work area, ODO found a
medium-sized tank of compressed nitrogen for which there was no inventory, and there were two
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containers of refrigerant present that were listed on an inventory maintained elsewhere within the
operations department. During the August 2011 ODO review, a deficiency was cited for the
failure of the operations department to maintain an inventory. Though inventories have been
implemented, a repeat deficiency is cited in light of the identified inaccuracies. In addition to
this deficiency, ODO noted the storage areas in the operations department work areas are
disorganized and disorderly. ODO recommends a system of review be instituted to ensure
accountability for the accuracy of inventories and the orderly storage of hazardous substances.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY EH&S-1
In accordance with the ICE PBNDS, Environmental Health and Safety, section (V)(E), the FOD
must ensure, at least annually, a state laboratory shall test samples of drinking and wastewater to
ensure compliance with applicable standards. A copy of the testing and safety certification shall
be maintained on-site.
DEFICIENCY EH&S-2
In accordance with the ICE PBNDS, Environmental Health and Safety, section (V)(F), the FOD
must ensure, at least every two weeks, emergency power generators shall be tested for one hour,
and the oil, water, hoses and belts of these generators shall be inspected for mechanical readiness
to perform in an emergency situation.
Power generators are inspected weekly and load tested quarterly at a minimum, or in accordance
with manufacturer’s recommendations and instruction manual. Among other things, the
technicians shall check starting battery voltage and amperage output.
Other emergency equipment and systems shall be tested quarterly, and needed follow-up repairs
or replacement shall be accomplished as soon as feasible.
DEFICIENCY EH&S-3
In accordance with the ICE PBNDS, Environmental Health and Safety, section (VI)(C), the FOD
must ensure every area shall maintain a current inventory of the hazardous substances
(flammable, toxic, or caustic) used and stored there. Inventory records shall be maintained
separately for each substance. Entries for each shall be logged on a separate card (or equivalent)
filed alphabetically by substance. The entries shall contain relevant data, including purchase
dates and quantities, use dates and quantities, and quantities on hand.

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GRIEVANCE SYSTEM (GS)
ODO reviewed the Grievance System standard at JAMF to determine if a process to submit
formal or emergency grievances exists, and responses are provided in a timely manner, without
fear of reprisal. In addition, the review was conducted to determine if detainees have an
opportunity to appeal responses, and if accurate records are maintained, in accordance with the
ICE PBNDS. ODO reviewed the grievance system logs and grievances filed by ICE detainees,
and conducted interviews with the JAMF Grievance Coordinator and the ICE Grievance
Coordinator.
Detainees are encouraged to resolve grievances informally; however, detainees may pursue a
formal grievance at any time. Detainees are able to appeal grievance decisions. JAMF staff is
trained to handle emergency grievances, which ensures the safety and welfare of detainees.
JAMF management encourages its officers to report grievances to supervisory personnel for
immediate action, with a special emphasis on emergency grievances.
A review of grievance logs from January 2012 through December 2012 reflects three grievances
were filed. Only formal and medical grievances are recorded in a log and are reviewed by the
Grievance Officer (Deficiency GS-1). Although staff is not required to provide a detainee a
written response to a verbal or informal grievance, the PBNDS require staff to document the
results in individual detention files and any logs or data systems the facility has established to
track such actions.
All three grievances filed were formal grievances. There was a grievance for a lost telephone
card bought from the commissary, a medical grievance, and a grievance alleging staff
misconduct. The Commissary replaced the telephone card, and JAMF management investigated
the staff misconduct allegation within five days as required by the PBNDS. However, the
medical grievance was not submitted directly to medical personnel designated to receive and
respond to medical grievances at the facility (Deficiency GS-2). Delivering a medical grievance
directly to medical personnel ensures continuity of care and privacy protection. Additionally, it
took more than five days to address the medical grievance (Deficiency GS-3). ODO confirmed
medical grievances are not placed in individual detainee medical files (Deficiency GS-4). This
is a repeat deficiency from the August 2011 ODO inspection. Placement of documented
dispositions in detainee medical files ensures medical staff is aware of all pertinent actions when
reviewing individual medical records.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY GS-1
In accordance with the ICE PBNDS, Grievance System, section (V)(C)(1), the FOD must ensure,
if an oral grievance is resolved, the employee need not provide the detainee written confirmation
of the outcome but shall document the result for the record in the detainee’s Detention File and
in any logs or data systems the facility has established to track such actions.

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DEFICIENCY GS-2
In accordance with the ICE PBNDS, Grievance System, section (V)(C)(3), the FOD must ensure
formal written grievances regarding medical care shall be submitted directly to medical
personnel designated to receive and respond to medical grievances at the facility.
DEFICIENCY GS-3
In accordance with the ICE PBNDS, Grievance System, section (V)(C)(3)(2)(c), the FOD must
ensure designated medical staff shall act on the grievance within five working days of receipt
and provide the detainee a written response of the decision and the rationale.
DEFICIENCY GS-4
In accordance with the ICE PBNDS, Grievance System, section (V)(E), the FOD must ensure
medical grievances are maintained in the detainee’s medical file.

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LAW LIBRARIES AND LEGAL MATERIAL (LL&LM)
ODO reviewed the Law Libraries and Legal Material standard at JAMF to determine if detainees
have access to a law library, legal materials, courts, counsel, and document copying equipment to
facilitate the preparation of legal documents, in accordance with the ICE PBNDS. ODO
interviewed detainees and staff, reviewed local policies and the facility handbook, and toured the
law library at JAMF.
ODO confirmed a Law Library Coordinator conducts updates on the computer systems and
performs weekly systems checks. Weekly inspections of library computers ensure updates are
timely and systems are operating properly. This prevents periods of inaccessibility.
The law library is required to maintain specific materials listed in the standard unless those
materials are no longer published. ODO reviewed the legal reference materials at the law
library, to include computers containing Lexis-Nexis. ODO confirmed the library does not
maintain, either in hard-copy format or electronically, seven of the 30 publications required
under the standard (Deficiency LL&LM-1). ERO is required to provide these additional
materials. ERO management did not provide ODO a timeline for the purchase and delivery of
the missing publications.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY LL&LM-1
In accordance with the ICE PBNDS, Law Libraries and Legal Material, section (V)(E)(2)(b)(2),
the FOD must ensure, as an alternative to obtaining and maintaining the paper-based publications
in Attachment A, a facility may substitute the Lexis/Nexis publications on CDROM. Any
materials listed in Attachment A which are not loaded onto the Lexis/Nexis CDROM must be
maintained in paper form.
Immigration Law and Crimes; Guide for Immigration Advocates; Human Rights Watch – World
Report; UNHCR Handbook on Procedures and Criteria for Determining Refugee Status;
Affirmative Asylum Procedures Manual; AILA’s Asylum Primer, 4th edition; Federal Civil
Judicial Procedure and Rules; United States Code, Title 28, Rules, Appellate Procedure
Pamphlets I + II; Federal Criminal Code and Rules; Criminal Procedure (Hornbook) By LaFave,
Israel and King; Legal Research in a Nutshell, 9th edition by Cohen and Olson; Black’s Law
Dictionary, latest standard edition, in 2007, 8th edition; Mexican Legal Dictionary and Desk
Reference by Jorge Vargas; Directory of Nonprofit Agencies that Assist Persons in Immigration
Matters; Other Translation Dictionaries Depending on the Most Common Languages; Detainee
Handbook and Detainee Orientation Materials; Self-help Materials. Materials provided by
outside organizations after clearance by District Counsel; Telephone Books (Yellow pages) for
local areas and nearby metropolitan areas where counsel may be located.

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MEDICAL CARE (MC)
ODO reviewed the Medical Care standard at JAMF to determine if detainees have access to
healthcare and emergency services to meet health needs in a timely manner, in accordance with
the ICE PBNDS. ODO toured the clinic, reviewed policies and procedures, verified medical
staff credentials, and interviewed the Chief of Operations, Director of Nursing, Nurse
Supervisor, Mental Health Administrative Manager, and MD. ODO examined 30 medical
records of detainees in the following categories: chronic care, healthy, mental health patients,
and sick calls scheduled on January 3, 2013. All records were reviewed for compliance with
requirements of the PBNDS, including sick call timeliness and transfer documentation. Any
records older than a year were checked for annual tuberculosis testing and physical
examinations.
The MD has instituted an informal internal chart review process; however, there is no external
peer review program as required by the PBNDS (Deficiency MC-1). Peer reviews identify
weaknesses or errors in work performance, and enhance or maintain the quality of services
provided. The MD informed ODO that a peer review process will be implemented.
Medical grievances are not maintained in detainee medical records (Deficiency MC-2). JAMF
administrative personnel stated placement of medical grievances in medical records is prohibited
by JAMF internal policy, consistent with Board of State and Community Corrections,
Correctional Standards Authority guidelines stipulating that all grievances are to be maintained
by the Sheriff’s Department. This is a repeat deficiency. Failure to follow the standard impedes
tracking and retrieving detainee medical grievances.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY MC-1
In accordance with the ICE PBNDS, Medical Care, section (V)(X)(3), the FOD must ensure the
administrative health authority shall implement an intra-organizational, external peer review
program for all independently licensed medical professionals. Reviews are conducted at least
every two years.
DEFICIENCY MC-2
In accordance with the ICE PBNDS, Medical Care, section (V)(Z), See Grievance System
Detention Standard. In accordance with ICE PBNDS, Grievance System, section (V)(E), the
FOD must ensure medical grievances are maintained in the detainee’s medical file.

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James A. Musick Facility
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USE OF FORCE AND RESTRAINTS (UOF&R)
ODO reviewed the Use of Force and Restraints standard at JAMF to determine if necessary use
of force and the use of restraints are used only after all reasonable efforts have been exhausted to
gain control of a subject, while protecting and ensuring the safety of detainees, staff, and others,
preventing serious property damage, and ensuring the security and orderly operation of the
facility, in accordance with the ICE PBNDS. ODO toured the facility, interviewed staff,
inspected equipment, and reviewed the local policies and training records.
Review of the JAMF use of force policy confirmed all requirements of the standard are
addressed. The facility has an Emergency Response Team for calculated use of force incidents.
JAMF staff does not use a restraint chair or four-point restraints on ICE detainees. The facility
inventory of intermediate force devices includes Tasers, oleoresin capsicum (OC) spray, and the
pepper ball gun system of OC delivery. ODO confirmed all intermediate force devices are
properly secured. The JAMF Security Sergeant stated, in the 12 months preceding the ODO
inspection, there were no incidents involving calculated or immediate use of force, or the use of
intermediate force devices on ICE detainees. A review by ODO of facility and ERO
documentation confirmed this information.
All JAMF officers receive initial and annual training in the use of force policy. Review of the
curriculum confirmed it includes all topics required by the PBNDS, including confrontation
avoidance and self-defense tactics. In addition, all officers complete training in the use of
intermediate force devices. Inspection of training records by ODO for(b)(7)eofficers confirmed
completion of training and current certifications in intermediate force devices for all but (b)(7)e
officers. (b)(7)e certification expired on August 2, 2012, (b)(7)e on October 4, 2012
(Deficiency UOF&R-1). The Training Sergeant stated the officers requiring a training update
transferred to JAMF in December 2012, and both officers will be attending annual training as
soon as practical. In the interest of safety, ODO recommends the officers complete
recertification training as soon as possible.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY UOF&R-1
In accordance with the ICE PBNDS, Use of Force and Restraints, section (V)(D)(2), the FOD
must ensure any officer who is authorized to use specialized intermediate force devices shall be
specifically trained and certified to use that device. Training in the use of chemical agents also
shall include treatment of individuals exposed to them.
Training shall also cover use of force in special circumstances (detailed below).
All employees who participate in a calculated use-of-force move shall have received prior
training.
The employee will receive training on an annual basis, and documentation of that training will be
maintained in the employee’s training record for as long as he or she is employed by the facility.
The employee must also maintain certification.

Office of Detention Oversight
January 2013
OPR 201302468

18

James A. Musick Facility
ERO Los Angeles