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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 

San Antonio Field Office 

Laredo Processing Center 

Laredo, Texas 


January 24 - 26,2012 


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 

LAREDO PROCESSING CENTER 

SAN ANTONIO FIELD OFFICE 

TABLE OF CONTENTS 

EXECUTIVE SUMMARY ............................................................................................... 1 

INSPECTION PROCESS
Report Organization .................................................................................................5 

Inspection Te81ll Members.......................................................................................5 

OPERATIONAL ENVIRONMENT 

Internal Relations ......................................................................................................6 

Detainee Relations ...................................................................................................6 

ICE NATIONAL DETENTION STANDARDS 

Detention Standards Reviewed .................................................................................7 

Environmental Health and Safety .............................................................................8 


EXECUTIVE SUMMARY 

The Office of Professional Responsibility (OPR), Office of Detention Oversight (ODO)
conducted a Compliance Inspection (CI) of the Laredo Processing Center (LPC) in Laredo,
Texas from January 24-26,2012. LPC was opened in February 1985. LPC is a 59,000 square
foot facility owned and operated by Corrections Corporation ofAmerica (CCA). CCA assumed
ownership ofthe facility in February 2005. U.S. Immigration and Customs Enforcement (ICE)
began housing detainees at LPC in February 1985 under an Intergovernmental Service
Agreement (IGSA) between Webb County, Texas, and the United States Marshals Service
(USMS). Currently, LPC is operated as a dedicated IGSA facility, exclusively housing ICE male
and female detainees of all classification levels for periods in excess of 72 hours. The total
employees. LPC has a
number ofnon-ICE staff employed at LPC isb6, b7c ICE staff consists ofb6, b7c
total of 400 beds, and has an average daily population of 268 with an average length of stay of 8
days. At the time of inspection, LPC housed 310 detainees (259 males and 51 females). CCA
provides medical care and Canteen Correctional Services provides food service. The facility
holds no accreditations.
The ICE Office of Enforcement and Removal Operations (ERO), Field Office Director, San
Antonio, Texas (FOD/San Antonio) is responsible for ensuring facility compliance with ICE
policies and the National Detention Standards (NOS). An Assistant Field Office Director
(AFOD) is physically located at LPC and has oversight responsibility ofthe facility. ICE staff
occupies offices owned by CCA that are located adjacent to LPC. There is currently no
Detention Service Manager (DSM) located at LPC. The previous DSM was promoted and re­
assigned. A vacancy announcement for this position has been issued. On the first day of
inspection, an interim DSM was present at LPC. (b)(7)e DSMs will service the LPC on an
alternating basis until the vacancy is filled. The interim DSMs are normally assigned to
detention facilities in South Texas within the FOD/San Antonio area of responsibility. The
DSMs conduct bi-weekly visits to LPC. Immigration Enforcement Agents (lEA) and
Deportation Officers (DO) visit the facility housing units on a daily basis. The Warden is the
highest ranking official at LPC, and is responsible for oversight of daily operations at the facility.
In addition to the Warden, CCA supervisory staff at LPC includes
(b)(7)e
(b)(7)e

In February 2009, ODO conducted a Quality Assurance Review (QAR) ofLPC. 000 cited 31
deficiencies in 16 ofthe 25 NOS inspected. In July 2010,000 conducted a Follow-up
Inspection at LPC and identified five (16%) repeat deficiencies in five NOS.
In June 2011, ERO Detention Standards Compliance Unit contractor MGT ofAmerica, Inc.
conducted an annual review ofthe ICE NOS at LPC. MGT rated the facility overall as "Good"
and found LPC to be in compliance with all detention standards reviewed. During this CI, ODO
reviewed 16 NOS. A total oftwo deficiencies were identified within the Environmental Health
and Safety standard.

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This report details all deficiencies and refers to the specific, relevant sections ofthe ICE NDS.
OPR will provide ERO a copy ofthe report to assist in developing corrective actions to resolve
the two identified deficiencies. Deficiencies were discussed with LPC and ICE staff on-site
during the inspection, as well as during the closeout briefing conducted on January 26,2012
Overall, ODO found LPC to be well managed and in compliance with the standards inspected.
The AFOD at LPC has established an NDS Compliance Team. ODO notes the establishment of
this team as a best practice and a contributing factor to the minimal deficiencies and overall
exceptional level of compliance observed by ODO during this CI. The NDS compliance team
consists of(b)(7)efull-time employees
(b)(7)e
(b)(7)e
The assignments are not permanent. The duties are rotated among
assigned ICE personnel. The NDS Compliance Team provides oversight of the facility's
adherence to the ICE NDS, and works closely with the DSM and the LPC Compliance Officer.
The team conducts facility visits, attends to all detainee correspondence, maintains records and
logs, and addresses issues affecting the health and welfare ofdetainees. The NDS Compliance
Team is supervised by the AFOD. The two deficiencies within the Environmental Health and
Safety standard during this CI were corrected prior to completion ofthe inspection. LPC and
ERO management were receptive to ODO observations and demonstrated cooperation for the
duration of the inspection.
ICE detainees at LPC are afforded access to a law library for up to five hours a week with
additional time available upon request. The ratio oftelephones is one for every 15 detainees in
the larger dormitories, and one for every 12 detainees in the smaller dormitories. This exceeds
the NDS requirement for telephone access. ICE detainees have access to television, outdoor
recreation, reading material, mail, and commissary. LPC offers religious programs and
activities. Public visitation schedules are conspicuously posted in prominent areas throughout
the facility. Schedules are also present in the detainee handbook. The ICE National Handbook
and the facility-specific handbook are provided and distributed in both English and Spanish.
ODO reviewed the Medical Care NDS at LPC and found no deficiencies. Healthcare is
delivered in a clean and secure environment by qualified staff and the clinic is well managed.
ODO reviewed policies, staff credentials, and training records; and observed intake screening,
sick call, and medication disbursement procedures. ODO examined 40 detainee medical records.
Eleven records of detainees with chronic conditions were found to have appropriate monitoring,
care, and intervention with regular follow-up visits to medical providers. Records pertaining to a
detainee housed in a negative pressure room due to active tuberculosis (TB) documented
immediate isolation upon receipt of the X-ray report identifying the potential for active TB.
Texas Department of Health authorities were notified, and the evaluation and treatment ofthe
detainee showed close collaboration between the LPC medical provider and the Texas Health
Department medical staff. ODO determined that staffing and services are adequate for the size
of the population and the level of acuity exhibited by detainees. Although no deficiencies were
identified, ODO offered two recommendations:
1) The Health Services Administrator (HSA) should obtain and maintain a record of
current licenses and/or certifications for all three radiology technicians employed by the
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mobile X-ray company servicing LPC. A deficiency was not cited because the HSA had
a copy of a current certification for the technician who does the majority ofthe X-rays.
The HSA indicated copies ofthe certifications for the other two technicians will be
obtained from the mobile x-ray company within the week.
2) The June 2011 preventive maintenance record for medical equipment does not include
the newly acquired automated external defibrillator (AED). Pursuant to the
recommendation by ODO, the HSA contacted the preventive maintenance contractor and
added the AED to the list of equipment scheduled for a maintenance check.
A review ofthe grievance log confirmed that two informal grievances were filed in 2011, and to
date, one informal grievance has been filed in 2012. There is an established, documented appeal
process in place at LPC; however, none ofthe identified grievances were appealed. Emergency
grievance procedures are detailed in the detainee handbook.
The food service program at LPC is operated by Canteen Correctional Services. ODO verified
all menus were certified by a registered dietician. Religious and medically prescribed meals are
provided and properly documented. Review of required inspections and temperature logs
confirmed full compliance with the Food Service NDS.
A review of the Environmental Health and Safety NDS confirmed the facility maintains a high
standard of sanitation, engages in safe work practices, and controls the handling ofhazardous
materials. ODO verified documentation of inspections, appropriate management of inventories
of hazardous chemicals, and the regular occurrence of fire drills.
Direct observation and staff interviews demonstrate that LPC staff has a clear understanding of
the proper handling, storage and issuance ofhazardous materials, and of the need for inventories.
Weekly and monthly fire inspections are completed. Fire protection equipment is located
throughout the facility, and emergency exit diagrams signed by the local fire marshal and exit
signs are conspicuously posted throughout the facility.
ODO observed an instance where the permanent, manufacturer-affixed label on one spray bottle
was crossed off and a marker was used to identify another product. ODO advised LPC that
bottles containing hazardous substances must be accurately labeled to ensure the substance is
properly used, and to facilitate appropriate medical response in the event of accidental or
intentional misuse. The Safety Officer immediately removed the bottle from circulation, which
corrected the deficiency on the spot. Inspection ofthe lavatory located in the room designated
for barbering revealed both hot and cold water was available; however, the hot water was not
capable of maintaining a constant flow between 105 degrees and 120 degrees. This deficiency
was corrected by LPC management on the second day ofthe inspection. ODO re-tested the
temperature and confirmed compliance with the standard.
ODO reviewed the Special Management Unit standard for Administrative and Disciplinary
Segregation. During the review, there was one ICE detainee in disciplinary segregation. A
review ofthe case confirmed the incident report, investigation, and disciplinary hearing were
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completed in accordance with the NDS. Detainees in the SMU are provided one hour of outdoor
recreation and a shower each day, seven days a week, which exceeds the NDS requirement.
000 reviewed the Use of Force standard at LPC and determined this area was well managed.
LPC has not had a calculated use of force within the past twelve months. The most recent
documented use of force was an immediate use of force that occurred in June 2009. LPC staff
receives annual training in the Use of Force Team Technique. Protective gear is readily
available and medical staff is involved in all non-routine applications of restraint equipment.
aDO review ofthe form used to document after action reviews, the Use of Force Summary &
Review Form, confirmed it covers all aspects ofthe review process, including the justification
for the use of force and notations of all discrepancies.

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INSPECTION PROCESS
000 inspections evaluate the welfare, safety, and living conditions of detainees. ODO primarily
focuses on areas ofnoncompliance with the ICE National Detention Standards (NDS) or the ICE
Performance Based National Detention Standards (PBNDS), as applicable. The NDS apply to
LPC. In addition, 000 may focus its inspection based on detention management information
provided by 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 LPC to determine compliance with current policies
and detention standards. Prior to the inspection, ODO collected and analyzed relevant
al1egations and detainee information from multiple ICE databases including the Joint Integrity
Case Management System (JICMS), the ENFORCE Alien Booking Module (EABM), and
ENFORCE Alien Removal Module (EARM). ODO also gathered facility facts and inspection­
related information from ERO HQ staff to prepare for the site visit at LPC.

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 the 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

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Office of Detention Oversight
January 2012
OPR 201203586

Special Agent (Team Lead)
Special Agent
Special Agent
Contract Inspector
Contract Inspector
Contract Inspector

5

ODO, Houston
ODO, Houston
ODO, Houston
Creative Corrections
Creative Corrections
Creative Corrections
Laredo Processing Center
ERO San Antonio

OPERATIONAL ENVIRONMENT 

INTERNAL RELATIONS
000 interviewed ICE and LPC supervisory staff, including the LPC Warden and the AFOD
who oversees ERO operations at LPC. Overall, ODO found there is good communication
between LPC and ICE staff. Morale of both LPC and ICE staffis good. All ICE staff and LPC
personnel are bilingual. The AFOD stated that one year ago, he created an NDS Compliance
Unit to focus on NDS compliance issues. According to the AFOD, the most significant
challenges faced by ICE are the lack of a transportation contract, and the shortage of available
office space. ODO observed a Mission Support Specialist utilizing a supply storage area as an
office, and two Deportation Officers using an employee break room as an office.
The Warden, who has occupied the position since 2006, stated that the morale ofLPC staff is
high and employee turnover is low. He further stated that some LPC personnel tend to remain
employed with CCAlLPC for several years and subsequently find employment with ICE ERO or
other local law enforcement agencies. The Warden stated emergency exercises are conducted on
a monthly basis. Each year, LPC coordinates a large-scale emergency training exercise that
involves the Laredo Fire Department, local hospitals, local law enforcement agencies, and ICE.
The Warden stated this annual training exercise is a model for large-scale coordination and
cooperation ofemergency personnel in the Laredo area.

DETAINEE RELATIONS
ODO interviewed 20 male and 11 female detainees randomly selected from all classification
levels. No detainees reported sexual or physical abuse at LPC. Six of30 detainees (20%) stated
they had not received the local detainee handbook and two (7%) stated they had not received the
National Handbook. ODO verified that all detainees had received handbooks during admission,
and the handbooks are available in both English and Spanish. Detainees acknowledge receipt of
the handbook by signing a facility form that is placed within their detention files. Four of30
detainees (13%) reported not knowing the identity oftheir Deportation Officer, or how to make
contact with a DO. ODO verified that schedules for DO visits (with names) are conspicuously
posted within all ofthe housing units. ODO confirmed ERO staff conducts daily visits to the
housing units. No detainees complained about food service or lack of recreational opportunities.
All detainees were aware of the grievance procedures and knew how to obtain grievance forms.

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ICE NATIONAL DETENTION STANDARDS 

ODO reviewed a total of 16 NDS and found LPC fully compliant with the following
15 standards:
Access to Legal Material
Admission and Release
Detainee Classification System
Detainee Grievance Procedures
Detainee Handbook
Detainee Transfers
Food Service
Hold Rooms in Detention Facilities
Medical Care
Special Management Unit - Administrative Segregation
Special Management Unit - Disciplinary Segregation
Staff-Detainee Communication
Telephone Access
Use of Force
Visitation
As these standards were compliant at the time ofthe review, a synopsis for these standards was
not prepared for this report.
ODO found deficiencies in the following standard:
Environmental Health and Safety
Findings for this standard are presented in the remainder ofthis report.

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ENVIRONMENTAL HEALTH AND SAFETY (EH&S)
aDO reviewed the Environmental Health and Safety NDS at LPC to determine if the facility
maintains high standards of cleanliness and sanitation, safe work practices, and control of
hazardous materials and substances. aDO toured the facility, interviewed staff, and reviewed
policies and procedures, documentation of inspections, hazardous chemical management and
inventories, and fire drills.
aDO observation and interviews of LPC staff indicated that LPC staff had a clear understanding
ofthe proper handling, storage, and issuance of hazardous materials, and ofthe need for
inventories. A master file for Material Safety Data Sheets (MSDS) is maintained in the Safety
Office, and aDO found MSDS posted throughout the facility. Employees receive training in
handling flammable, toxic, and caustic materials during basic orientation and in-service refresher
training. The facility follows Occupational Safety and Health Administration (OSHA)
Standards, as well as National Fire Protection Association's 101 Life Safety Code to maintain
compliance with all current applicable codes.
Weekly and monthly fire inspections are completed. Fire protection equipment, emergency exit
diagrams (signed by the local fire marshal), and exit signs were observed conspicuously posted
throughout the facility. aDO verified the emergency generator is checked weekly and
maintained by a licensed contractor. Documentation of annual inspections by the local fire
marshal was available. Reports for water testing and pest control were current. Facility
sanitation is maintained at a high level.
aDO observed the permanent, manufacturer-affixed label on one spray bottle was crossed off
and a marker was used to identifY another product (Deficiency EH&S-l). Spray bottles
containing hazardous substances must be accurately labeled to ensure the substance is properly
used, and to facilitate appropriate medical response in the event of accidental or intentional
misuse. This bottle was immediately removed from circulation by the Safety Officer and
disposed of, correcting this deficiency during the review.
Inspection ofthe lavatory located in the room designated for barbering operations confirmed
both hot and cold water were available; however, the hot water temperature was determined to be
93 degrees when initially tested, 12 degrees below the minimum temperature threshold of 105
degrees (Deficiency EH&S-2). A constant flow of hot water is necessary to ensure proper
sanitation requirements are met. When advised ofthe deficiency, the Maintenance Supervisor
reported a boiler was undergoing repair. The boiler was repaired on the second day ofthe
review. Prior to completion ofthe CI, the water temperature was re-checked and found to be
within the standard.

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STANDARDIPOLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY EH&S-l
In accordance with the ICE NDS, Environmental Health and Safety, section (I1I)(J), the FOD
must ensure the OIC will individually assign the following responsibilities associated with the
labeling procedure:
1. 	 IdentifYing the hazardous nature ofmaterials adopted for use;
2. 	 Requiring use of properly labeled containers for hazardous materials, including any and
all miscellaneous containers into which employees might transfer the material;
3. 	 Teaching staff the meaning ofthe classification code and the MSDS, including the safe
handling procedures for each material,; [sic] and impressing on staff the need to ensure
containers are properly labeled; and
4. 	 Placing correct labels on all smaller containers when only the larger shipping container
bears the manufacturer-affixed label;

DEFICIENCY EH&S-2
In accordance with the ICE NDS, Environmental Health and Safety, section (III)(P)(l), the FOD
must ensure the sanitation of barber operations is ofthe utmost concern because ofthe possible
transfer of diseases through direct contact or by towels, combs and clippers. The following
standard, among others, will be adhered to: Both hot and cold water will be available, and the hot
water will be capable ofmaintaining a constant flow ofwater between 105 degrees and
120 degrees.

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