u.s. Department of Homeland Security
•

Isabel Detention Center
91 Buena Vista Rd.
Los Fresnos, Texas 78566

U.S. Immigration
and Customs
Enforcement
September 27, 2007

MEMORANDUM FOR:

John P. Torres
Director
Office of Detention and Removal

FROM:

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Deportation Officer
San Antonio

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SUBJECT:

Laredo Processing Center Review

The San Antonio Field Office, Office of Detention and Removal conducted a detention revie
Laredo Processing Center on September 25 th - 2ih, 2007. This review was conducted by DO
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. and this writer. This facility is used for detainees requiring housing over 72 hours.

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Type of Review:
This review is a scheduled Operational Review to determine general compliance with established
Immigration and Customs Enforcement (ICE) National Detention Standards. Several detention
reviews have been conducted at this facility.
Review Summary:
Corrections Corporation of America (CCA) Laredo Processing Center (LPC), located in Laredo,
Texas, is under the direct supervision and control of the San Antonio Field Office. Currently, LPC
has a capacity of 403 beds that houses adult male and female. Prior to the current IGSA, the facility
has no prior accreditations.
Review Findings:
The following information summarizes those standards not in compliance. Each standard is
identified and a short summary provided regarding standards or procedures not currently in
compliance.
Compliant
Deficient
~t-Ris){

Non-~pplicable

-

18
17
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Subject: Detention Review Summary Report
Page 2

Prior to reviewing the facility, 3 of the 38 standards were pre-detennined as not applicable to LPC.
The following are examples of these standards:
1. Non-Medical Escorted Trips: All ICE Non-Medical Emergency Escorted Trips are
handled only by the ICE Field Office or Sub-Office in control of the detainee case.
2. Terminal Ilness, Advanced Directives and Death: This facility does not accept ICE
detainees who are severely or tenninally ill, even though, CCA still needs to incorporate the
ICE standards into current medical policy and procedures (i.e., Death; Medical Care;
Suicide; Hunger strike; etc.).
3. Transportation (Land): All ICE Transportation is handled only by the ICE Field Office or
Sub-Office in control of the detainee case, unless an outside contractor other than CCA is
providing transportation for detainees. Quality Assurance Manager advised the facility is
currently establishing policy with the ICE standard incorporated into its procedures and
operations for emergent transportation of ICE detainees.
These standards were marked as Non-Applicable and an explanation was provided.
Standards Summary Findings:
Detainee Telephone Access - Best Practice:
• Even though, CCA policy does not reflect the verbiage from the standard, ICE and CCA
personnel are to be commended for their attentiveness and collaborated effort in maintaining
this standard in an exemplary level. The smooth operations in this area with the concurrence
from the detainee popUlation, allows this writer to bestow the facility with a "Best Practice"
rating for this standard.
Access to Legal Materials - Deficient:
• The facility is lacking documentation on access and/or denial for the use of the law library.
• No schedule is posted in the housing units and/or detainee handbook.
• Several grievances were submitted for lack of accessibility to the Law Library.
Food Service - Deficient:
• Food Service does not have a Common Fare Program in place to address the special and
religious diets. Currently, there is no accountability system on the special diets being
prescribed by the medical department.
• Food Service Department is utilizing detainees in the food service areas with no voluntary
work program (i.e., policy; job descriptions; payroll; etc.) in place.
Funds and Personal Property - Deficient:
• The facility has not practiced the policy and procedures regarding the handling of abandoned
property.
• Three notables were encountered during the review of this standard:
~ Receipts located inside the sealed clear bag, did not have two signatures verifying the
contents.

FOR OFfiCIAL USE ONLY
(LAW tNFOR\;EfV1ENT SENSITIVE)

Subject: Detention Revilsummary Report
Page 3

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~

Valuables of two detainees that had been released over thirty days were still in the drawer
with no final disposition annotated.
Personal property (other than valuables) was stored in a brown paper bag with no tamper
proof seal or an equivalent form to an 1-77 for accountability purposes. In addition, no
logbook was present.

Detainee Grievance Procedures - Deficient:
• Upon review of the grievance forms and log, three grievances were reviewed and
discrepancies were noted referencing the final disposition. The formal grievances were
forwarded and/or did not display a resolution. Unfortunately, all three detainees had been
released (deport) from the facility, therefore, no follow-up was conducted.
• The facility is not adhering to grievance procedures and/or providing training to their
personnel, therefore staff in unable to resolve the detainees' complaints at any level
(Informal/Formal) in an orderly and timely manner.
• The grievance officer is making the entries into the logbook, but unfortunately the grievances
are not being dealt with as "Informal" or "Formal".
Issuance and Exchange of Clothing. Bedding. and Towels - Deficient:
• The facility does not meet the excess-clothing inventory of 200 percent of the maximum
funded detainee capacity allowing adequate clothing exchanges and for unforeseen
circumstances (i.e., more frequent exchanges in hot and humid climates, etc.).
• The exchange (clothing/linen/towel) schedule does not meet the exchange frequency as per
the standard.
• Detainees are not provided with sufficient amounts to ensure proper hygiene and exchange
limits.
• Laundry schedule needs to be revised to accommodate the detainee population for the
laundering services.
Religious Practices - Deficient:
• The schedule that is currently posted in the housing units but is not adhering to listing a
variety of denominations. In addition, the facility was unable to provide a record
(logbook/form) of any detainee participating in the Religious Program.
• According to detainee population, chaplain (designee) does not introduce or make visible of
oneself in housing areas and addressing if counseling services are needed. After checking
log books, the chaplain is not making the rounds throughout the facility.
• Common-fare program is in operation, but the Chaplain (designee) (not assisting in
accommodating/verifying a detainee's religious dietary requirements) and Food Service
department are not adhering to the religious diet procedures mentioned in CCA Policy in
accordance to ICE standard.
Voluntary Work Program - Deficient:
• Currently, the facility is utilizing the detainees to work throughout all areas (i.e., food
service; janitorial; maintenance; etc.) with no established policy and/or procedures in place
for the voluntary work program.
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Subject: Detention Review Summary Report
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tilt

•

During the review, CCA established policies and forms, to include the work areas (job
descriptions) and training for the program. The program shall commence, soon after all
personnel has received training. Due to classification, selective detainees will participate in
work assignments. Policy indicates that detainees are still responsible for clean-up in all
common settings and/or areas such as sleeping, dayroom, program and service. This
responsibility will be considered as acquired "Life Skills" and not receive monetary
compensation. Detainees will receive familiarization and/or instruction for use of
chemical/tools utilized for cleaning these areas. The contractor will furnish such equipment.

Disciplinary Policy - Deficient:
• Currently, CCA staff is adhering to the set procedures of the CCA Corporate Policy for the
Disciplinary process, but policy is not in accordance to the ICE standard. The forms being
utilized are not the appropriate forms to establish the Disciplinary file in the correct manner.
The form "Notice of Rights" is not being served on any detainee.
• The proper forms are not being utilized and no folders are being established for each detainee
processed through the disciplinary program.
Emergency Plans - Deficient:
• Unfortunately, CCA plans do not have the ICE Detention Standards incorporated into the
facilities emergency response plans. The facility is operating under CCA corporate
emergency plans that are not site-specific.
• Diagrams need to be revised and/or established safe harbor areas and evacuation paths.
• The ICE personnel have not received familiarization training on Emergency Plans and/or
facility floor plan, in case of emergency response from ICE. San Antonio Field Office
Special Response Team has already conducted a threat assessment of facility for their
response plans, but information not to be utilized for on-site ICE personnel. The facility is
lacking a memorandum from the San Antonio Field Office, listing the authorized chemical
agents to be utilized by CCA staff on ICE detainees during an emergent situation(s).
• Emergency Plans were not signed by proper authority.
./' Contractor will address the aforementioned and will submit the Emergency Plan package
for ICE approval.
Environmental Health and Safety - Deficient:
• Currently, the accountability is only from the concentrated form to the dilution stage of
chemicals, but staff is not maintaining accountability of the usage per clean-up or housing
unit (morning/evening clean-up).
• Specified protective equipment (i.e. googles, gloves, etc.) utilized for standard cleaning was
not available in some Food Service and janitorial (housing unit) areas.
• The contractor shall maintain a more effective process concerning chemicals in regards to
dilution, storage and general control or accountability of chemicals.
• No designated area has been established for the barbershop. Currently, detainee popUlation
is performing their own barbering services in the housing units. Sanitation ofbarbering
equipment is not annotated in a logbook or whether it is being conducted appropriate.
• The following is a listing of some notables the facility is lacking regarding the environmental
health and safety program:

iliH UfFICIAl USE O~J:\r

(L/WV

t]JF()~iCErv1ENT SE[~Si fiVE)

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Subject: Detention Review Summary Report
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* A person has been designated to oversee the Health and Safety program, but
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has not received any adequate OSHA training.

* No Housekeeping Plan available for the site-specific facility.
Hold Rooms - Deficient:
• Currently, no hold room logs or accountability is in place to address the annotation of
behavior or compaints. The logs are needed for accountability ofeach specific detainee (i.e.;
time in; meals; medical clearance; time out; etc.). The only annotation referencing the hold
rooms is logged into the Central Control logbook.
Key and Lock Control - Deficient:
• Unfortunately, CCA policy and procedures do not have the ICE Detention Standards
incorporated into the facilities normal daily operations. The facility is operating under CCA
corporate policy.
• Emergency key box is not anchored to a secure area in Central Control.
• Currently, no authorization cards for the restricted boxes are in place.
• No drop-safe is available for the "Dump or Flush" of keys, to be utilized during emergent
situations (i.e., facility takeover; hostage; riot; etc.).
• During the review, the pharmacy was left open and unsecured throughout the day with all
medical staffhaving access to the area with no restrictions and/or accountability (i.e., keys;
pharmaceuticals; etc.).
• The following is a listing of some notables the facility is lacking regarding key control:
* Keys have not been identified (restrictive/institutional/emergency/vehicle/gun locker),
* Preventive maintenance program, and
* Training has not been established and/or presented to staff
Special Management Unit (Administrative Segregation) - Deficient:
• Unfortunately, CCA policy and procedures do not have the ICE Detention Standards
incorporated into the facilities normal daily operations. The facility is operating under CCA
corporate policy.
• SMU facility procedures conducted and services rendered are not accordance to ICE
standards, furthermore, files are not being established for segregation or disciplinary
purposes. The appropriate forms, segregation orders and/or reviews are not being performed
appropriately.
Special Management Unit (Disciplinary Segregation) - Deficient:
• Unfortunately, CCA policy and procedures do not have the ICE Detention Standards
incorporated into the facilities normal daily operations. The facility is operating under CCA
corporate policy.
• SMU facility procedures conducted and services rendered are not accordance to ICE
standards, furthermore, files are not being established for segregation or disciplinary
purposes. The appropriate forms, segregation orders and/or reviews are not being performed
appropriately.

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~~~~e~t: Detention Revii Summary Report

•

Tool Control- Deficient:
• The following is a listing of some notables the facility is lacking regarding tool control:
* No Tool Classification (Janitorial RestrictedINon-restricted)
* No Tool identification (etched on tools)
* No shadowing in the janitorial rooms/closets
* No Fonn for lost tools
* No Disposition for excess and/or broken tools
Use afForce - Deficient:
• CCA staff needs training and/or familiarization referencing the revised "Use afForce"
policy and procedure.
• Unfortunately, CCA policy and procedures do not have the ICE Detention Standards
incorporated into the facilities nonna1 daily operations. The facility is operating under CCA
corporate policy.
• The "Use of Force" policy and "Emergency Plans" are in dire need of revision, due to the
reason that verbiage "Warning shots" and "Deadly force" to prevent an escape is being
utilized in current procedures and the ICE standard is not referenced.
• The facility is lacking a memorandum from the San Antonio Field Office, listing the
authorized chemical agents to be utilized on ICE detainees during an emergent situation(s).
Detainee Transfer - Deficient:
• The Transfer notification fonn is not being utilized at the facility by ICE personnel. The
detainees are not given prior notice of transfer to another facility.

RIC Observations:
This review is an overview of the facility. Unfortunately, CCA policy and procedures do not have
the ICE Detention Standards incorporated into the facilities nonna1 daily operations. The facility is
operating under CCA corporate policy. The atmosphere of the facility is anxious and ready to
experience the challenge.
RIC Issues and Concerns:
While the facility is experiencing a high turnover in regards to admission, releases and actual
duration of stay for detained popUlation, the facility administrators and personnel express an
excellent attitude and teamwork concept. The main concern that takes precedence is familiarizing
all staff (Management; detention; support; etc.) with the revised policy, procedures, plans and
support documentation with the incorporated ICE standards, due to the fact that staff is the
foundation of a Facility operating efficiently and effectively. The facility personnel is practicing and
adhering with the current CCA corporate policies and plans, which are not site-specific.
Knowledgeable and trained staff is the key to a successful operation.
Recommended Rating and Justification:
It is this Reviewers' recommendation that the facility receive a rating of "deficient". The rating is
based ofthe tour ofthe facility, revised standard operating procedures and available documentation
and equipment and also the assertion that the contractor will remedy all deficiencies with success.
The detention functions are being adequately perfonned. Although deficiencies may exist, they do
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SUbject: Detention Revii Summary Report
Page 7

not detract from the acceptable accomplishment of the vital functions. Internal controls are such that
there are no performance breakdowns that would keep the program from accomplishing its mission.
The rating will remain deficient until a follow-up review is conducted within 90 days.
It is the recommendation of this Reviewers' that a follow-up review be conducted within that time
frame.

RIC Assurance Statement:
All findings ofthis review have been documented on Form G-324A and are supported by the written
documentation contained in the review file.

iUi; ','J; , :C!AL USE ONLY
tUWv' UJ ' l f\i1ENT SENSITIVE)

Department Of Homeland Security
and Customs Ifn,t-n,.. ,,~.rn<

Detention Facility Inspection Form
Facilities Used Over 72 hours

Reviewed
ICE Service Processing Center
ICE Contract Detention Facility
ICE
Service

G. Accreditation Certificates
List all State or National Accreditation[s] received:

IZI

B. Current Inspection
Type oflnspection
IZI Field Office D HQ Inspection
Date[s] of Facility Review
-Septrueber -25 - 27, 2007
C. PreviouslMost Recent Facility Review
Date[s] of Last Facility Review
September 25, 2006
Previous Rating
D Superior D Good IZI Acceptable D Deficient D At-Risk

D. NameandL ocatIOn 0 fF acility
Name
Corrections Corporation of America - Laredo Processine Center
Address (Street and Name)
4702 East Saunders
City, State and Zip Code
Laredo, Texas 78041
County
Webb
Name and Title of Chief Executive Officer (Warden/OIC/Superintendent)
Warden
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Telephone # (Include Area Code)
(956
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Field Office / Sub-Office (List Office with oversight responsibilities)
San Antonio, Texas
Distance from Field Office
170 Miles

.

E ICE Information
Name of Inspector (Last Name, Title and Duty Station)
I DO I PIDC
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Name of Team Member I Title I Duty Location
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I DO I SNA
Name of Team Member I Title I Duty Location
I
I
Name of Team Member I Title I Duty Location
I
I
DIy
F CDFIIGSA I norma
f
f Ion 01
Contract Number
Date of Contract or IGSA
IGA # 79-02-0106
04/01105
Basic Rates per Man-Day
$ 59.79
Other Charges: (If None, Indicate N/A)
,
,
N/A;
Estimated Man-days Per Year
118,625

I

Check box if facility has no accreditation[ s]

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

1 FaCI
Tlty History
Date Built
0811984
Date Last Remodeled or Upgraded
1995
Date New Construction I Bedspace Added
N/A
Future Construction Planned
DYes IZI No Date:
Current Bedspace
Future Bedspace (# New Beds only)
403
Number: N/A
Date:

I

J. Total Facility Population
Total Facility Intake for previous 12 months
15,411 (Sept. 01106 thru Sept. 01107)
Total ICE Mandays for Previous 12 months
142,179 (Aug. 06 thru 07)
K. Classification Level (ICE SPCs and CDFs Only)
L-1
L-2
L-3
I AdultMa1e
176
24
13
I Adult Female
38
1
0

L. Facility Capacity
Operational
Rated
Emerf~ency
Adult Male
333
333
390
Adult Female
70
70
90
D Facilitv holds Juveniles Offenders 16 and older as Adults
M

·
opuIatIOn
. Average D al·1y P

I AdultMale
I Adult Female

USMS

Other

N/A
N/A

N/A
N/A

N. Facility Staffing Level

port:
b2High, b7e

FOR OFFlCI/\L 1 ::-:f C!iJLY
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ICE
298
59

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Form G-324A SIS (Rev. 7/9/07)

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

o
Assault:
Offenders on
Offenders!

Assault:
Detainee on
Staff

Number of Forced Moves,
inc!. Forced Cell moves3

# Times FourlFive Point
Restraints applied/used
Offender / Detainee Medical
Referrals as a result of
'uries sustained.

o

o

o

o

5

2

o

o

o

o

o

o

o

o

o

o

o

o

o

o

o

o

o

o

o

o

o

o

o

o

o

o

o

o

o

o

o

o

o

o

o

o

o

o

o

o

0

o

o

o

0

o

o

o

0

2

5

o

o

o

2

Escapes
Actual
Grievances:

# Received
# Resolved in favor of
Offender/Detainee
Reason (V=Violent, I=IlIness,
S=Suicide, A=Attempted

Deaths

Psychiatric / Medical
Referrals

# Medical Cases referred for
Outside Care
# Psychiatric Cases referred for
Outside Care

0
0

o

o

o

0

o

o

o

16

5

6

13

0

o

o

o

Any attempted physical contact or physical contact that involves two or more offenders
Oral, anal or vaginal penetration or attempted penetration involving at least 2 parties, whether it is consenting or non-consenting
Routine transportation of detainees/offenders is not considered "forced"
Any incident that involves four or more detainees/offendl'!;1 ~nclude,§ g~V& fig~ts:_ organized multiple hunger strikes, work stoppages, hostage situations,
f' l,
I.; ! ;, L. t' ~:, :,' U ['1 I
major fires, or other large scale InCIdents.

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Form G-324A SIS (Rev. 7/9/07)

l~-

2.
3.

-]tccessto Legal Materials
Group Presentations on Legal Rights
Visitation
T

5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.

Admission and Release
Classification System
Correspondence and Other Mail
Detainee Handbook
Food Service
Funds and Personal Property
Detainee Grievance Procedures
Issuance and Exchange of Clothing, Bedding, and Towels
Marriage Requests
Non-Medical Emergency Escorted Trip
Recreation
Religious Practices
V
Work PrClor",m

Health Services
18.
19.
20.

Hunger Strikes
Medical Care
Suicide Prevention and Intervention
Terminal
Advanced Directives and Death

NIA

22.
23.
24.
25.
26.
27.
28.
29.
30.
31.
32.
33.
34.
35.
36.
37.
38.

Detention Files
Disciplinary Policy
Emergency Plans
Environmental Health and Safety
Hold Rooms in Detention Facilities
Key and Lock Control
Population Counts
Post Orders
Security Inspections
Special Management Units (Administrative Segregation)
Special Management Units (Disciplinary Segregation)
Tool Control
Transportation (Land management)
Use of Force
Staff 1Detainee Communication (Added August 2003)
Detainee Transfer (Added September 2004)

All findings (Deficient and At-Risk) require written comment describing the finding and what is necessary to meet
compliance.

: f

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Form G-324A SIS (Rev. 7/9/07)

RIC Review Assurance Statement

By signing below, the Reviewer-In-Charge (RIC) certifies that all findings of noncompliance with policy or inadequate controls
---containe-dtn: the Inspection Report are supported by evidence that is sufficient and reliable. Furthermore, findings of noteworthy
accomplishments are supported by sufficient and reliable evidence. Within the scope of the review, the facility is operating in
accordance with applicable law and policy, and property and resources are efficiently used and adequately safeguarded, except for the
deficiencies noted in the report.

Reviewer-In-Charge: (Print Name)
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Title & Duty Location

Deportation Officer-PIDC
Team Members
Print Name, Title, & Duty Location

Print Name, Title, & Duty Location
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DO, SNA
Print Name, Title, & Duty Location

Print Name, Title, & Duty Location

Recommended Rating:

D Superior
DGood
D Acceptable
IS] Deficient
D At-Risk

Comments;

r~iln

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Form G-324A SIS (Rev. 7/9/07)

HEADQUARTERS EXECUTIVE REVIEW

I Review·Authority
The signature below constitutes review of this report and acceptance by the Review Authority. OIC/CEO will have 30 days from
receipt of this report to respond to all findings and recommendations
...

~QDRO-mCECt1TIVEREVIEW:

Ga

(please Print Name)

E. Mead

Title

Actin Director

Final Rating:

D Superior
DGood
D Acceptable
IZI Deficient
D At-Risk
DNoRating

Comments:
The Review Authority concurs with the RIC recommended rating of "Deficient".
A Plan of Action is required to address the deficiencies found in the RIC worksheets:
Access to Legal Materials
Food Service
Funds and Personal Property
Detainee Grievance
Issuance and Exchange of Clothing, Bedding and Towels
Religious Practices
Voluntary Work Program
Disciplinary Policy
Emergency Plans
Environmental Health and Safety
Hold Rooms
Key and Lock Control
Special Management Units (Administrative and Disciplinary)
Tool Control
Use of Force
Detainee Transfer
RA Downgraded to Deficient:
Admission and Release (strip search)
Visitation (automatic srrip search without alternatives)
Access to medical care (pharmacy unsecure, emergency response time training)
Post Orders
Security Inspections
Issues and Concerns:
Terminal Illness, Advanced Directives and Death (Written proceedures and/or policies re: deaths while in custody)
Suicide Prevention
Contraband
Detention Files

Form G-324A (Rev. 8/1/01) No Prior Version May Be Used After 12/31/01