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
Mira Lorna Detention Center
Lancaster, California

January 10- 12, 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
MIRA LOMA DETENTION CENTER
LOS ANGELES FIELD OFFICE
TABLE OF CONTENTS
EXECUTIVE SUMMARY ........................................................................................... 1
INSPECTION PROCESS
Report Organization ............................................................................................ 6
Inspection Team Members ................................................................................... 6
OPERATIONAL ENVIRONMENT
Internal Relations ................................................................................................ 7
Detainee Relations ............................................................................................... 7
ICE NATIONAL DETENTION STANDARDS
Detention Standards Reviewed ............................................................................ 9
Access to Legal Material ................................................................................... 10
Detainee Classification System .......................................................................... 11
Detainee Grievance Procedure ........................................................................... 12
Detainee Transfer .............................................................................................. 14
Disciplinary Policy ............................................................................................ 16
Environmental Health and Safety ....................................................................... 17
Food Service ...................................................................................................... 20
Medical Care ..................................................................................................... 23
Staff-Detainee Communication .......................................................................... 25
Use of Force ...................................................................................................... 28

EXECUTIVE SUMMARY
The Office ofProfessional Responsibility (OPR), Office ofDetention Oversight (ODO),
conducted a Compliance Inspection (CI) of the Mira Lorna Detention Center (MLDC) in
Lancaster, California, on January 10-12, 2012. ICE houses detainees at MLDC under an
Intergovernmental Service Agreement (IGSA) between ICE and the Los Angeles County
Sheriffs Department (LASD). MLDC is owned by the County ofLos Angeles and managed by
the LASD. The facility is authorized to house adult male ICE detainees of all security
classification levels for periods in excess of 72 hours. MLDC has a total capacity of 1,400,
dedicated entirely to ICE detainees. At the time of the inspection, 604 detainees were housed at
MLDC. There were 98 Levell detainees (lowest threat), 452 Level2 detainees (medium threat),
and 54 Level3 detainees (highest threat); the majority of the detainees are citizens or nationals of
Mexico. LASD provides health care and food services. MLDC holds no accreditations.
The Immigration and Customs Enforcement (ICE) Enforcement and Removal Operations (ERO),
Los Angeles, California Field Office Director (FOD!Los Angeles) is responsible for ensuring
MLDC is in compliance with ICE policies and the ICE National Detention Standards (NDS).
ICE personnel at MLDC include an Assistant Field Office Director (AFOD),(b)(7)eSupervisory
Detention and Deportation Officers (SDDO), and(b)(7)eSupervisory Immigration Enforcement
Agent (SIEA), who manage a permanently-assigned staffof(b)(7)efull-time ICE employees and(b)(7)e
ICE Contract Officers employed by Spectrum Security Services. LASD employs(b)(7)e full-time
staff at MLDC.
The facility property is approximately 50 acres and has its own water tower and steam plant.
There are 18 barracks: 16 can house 68 detainees each, and two worker barracks have a capacity
of156 detainees each. A segregation unit holds a maximum of34 detainees. MLDC averages
500 visitors a weekend. Attorney visits are authorized seven days a week.
MLDC is under contract to receive a rate of $154.08 per detainee, with a guarantee of a
minimum of800 detainees. The rate is reduced to $97.35 per detainee when the population
reaches or exceeds 1,300. ICE ERO field management recommended an audit by the DHS
Office oflnspector General to determine whether ICE is receiving sufficient value for the rate
charged under the current contract, especially when compared with facilities in the same area.
In May 2010, ODO conducted a Quality Assurance Review (QAR) ofthe ICE NDS at MLDC.
During that inspection, ODO recorded 67 deficiencies in 21 ofthe 32 standards reviewed.
In September 2011, the ERO Detention Standards Compliance Unit contractors, MGT of
America, Inc. (MGT) conducted an annual review of the ICE NDS at MLDC. MGT auditors
rated the facility "Acceptable," and determined compliance with 36 of the 38 NDS reviewed.
Two of the standards were not applicable.
ODO reviewed 16 NDS during this CI. Creative Corrections, a national consulting firm
contracted by ICE to provide subject matter expertise on detention management issues, assisted
with analysis ofthe deficiencies noted in the 2010 QAR and the September 2011 ERO annual
inspection to best determine relevant standards for this inspection. MLDC was confirmed to be
Office of Detention Oversight
January 2012
OPR 201200444

1

Mira Loma Detention Center
ERO Los Angeles

in full compliance with six ofthe 16 NDS reviewed: Admission and Release, Detainee
Handbook, Special Management Units (Administrative and Disciplinary), Suicide Prevention
and Intervention, Telephone Access, and Tool Control. ODO recorded 41 deficiencies in the
remaining 10 standards: Access to Legal Material (1 deficiency); Detainee Classification System
(3); Detainee Grievance Procedures (2); Detainee Transfers (4); Disciplinary Policy (1);
Environmental Health and Safety (5); Food Service (13); Medical Care (1); Staff-Detainee
Communication (6); and Use ofForce (5).
MLDC has been under contract to INS and then ICE since I997. Although the 4I deficiencies
reported during this CI were fewer than the 67 deficiencies reported during the May 20 I 0 QAR,
the high number of deficiencies contrasts with comparable detention facilities housing ICE
detainees during the same period. Facilities previously inspected by ODO with similar time in
service and population size have demonstr:ated significantly better compliance progress. For
example, ODO conducted a QAR ofthe Northwest Detention Center (NWDC) in Tacoma,
Washington, in March 20IO. ODO cited 49 deficiencies in 28 ofthe 4I Performance Based
National Detention Standards (PBNDS) inspected. In January 20II, ODO performed a FollowUp Inspection at NWDC that reported only five recurring deficiencies in four PBNDS. ODO
conducted a CI ofNWDC during the same period as this CI at MLDC. The CI at NWDC
verified full compliance with 13 of I5 PBNDS reviewed, and found two deficiencies in the
remaining two standards. Improving conditions of confinement at detention facilities is the core
objective ofthe ODO and ICE mission, measured by continued improvement noted during
regular inspections. NWDC clearly demonstrates these expected improvements, while MLDC
continues to have a high number of deficiencies despite previous ODO inspections.
Prior to receiving a security classification, detainees at MLDC are housed in two barracks fenced
off from the remaining detainee population. After classification, detainees are moved into the
appropriate general population. LASD staff stated when detainees arrive at the facility after
hours on Friday, they are held in the in-processing barracks until Monday when LASD staff
returns to work. As a result, it is possible for multiple, unclassified detainees to spend an entire
weekend together. The failure to promptly classify detainees can result in commingling
detainees with incompatible security levels. This presents a threat to detainee safety, and does
not comply with the NDS.
During a walk-through, ODO observed there were no LASD officers present in a designated
Level 3 housing unit. Level 3 detainees represent the highest security risk due to criminal
history and/or propensity for violence, so this matter raised serious safety concerns.
Additionally, ODO observed unsupervised Level 3 detainees traversing common areas and
interacting with Level I detainees. During the Closeout Briefing, ODO discussed these
observations and raised these concerns with LASD and ICE management as potential life/safety
issues in need of immediate attention.
According to the ICE Staff-Detainee Communication NDS, the procedure for submitting
requests is not to be used for submitting formal grievances. Detainees at MLDC use the same
LASD form titled "Inmate Complaint/Services Request Form" to submit both requests and
formal grievances to LASD staff. An LASD Sergeant stated that LASD personnel initially
review the form. LASD officials then decide if the matter should be handled as a request or

Office of Detention Oversight
January 2012
OPR 201200444

2

Mira Lorna Detention Center
ERO Los Angeles

processed as a formal grievance. This procedure can lead to disputes. Currently, an LASD
Officer assigned to MLDC is under investigation by LASD Internal Affairs for allegedly
throwing away detainee grievances rather than taking appropriate action in compliance with the
NDS. ERO employs a process similar to LASD for deciding if matters should be handled as a
request or a formal grievance. ERO staff stated detainees use an ICE request form for submitting
formal grievances because ERO does not provide dedicated grievance forms to detainees. An
SDDO stated an ICE officer reviews ICE request forms to determine whether matters will be
handled as requests or grievances. Due to discrepancies in these processes, ODO could not
verify grievance statistics provided for 2011.
The facility maintains an electronic grievance log to document and track formal grievances filed
by detainees. According to the grievance log, during calendar year 2011, LASD received and
processed 150 formal grievances from detainees housed at MLDC. Ofthe 150 formal
grievances, 58 (39 percent) pertained to complaints against staff, 16 (11 percent) pertained to
disciplinary matters, 12 (8 percent) pertained to personal property, 10 (7 percent) pertained to
policy and procedures, five (3 percent) pertained to mail, five (3 percent) pertained to work
assignments, five (3 percent) pertained to clothing and hygiene issues, four (3 percent) pertained
to housing and classification matters, three (2 percent) pertained to money and inmate accounts,
three (2 percent) pertained to meals and food service, two (1 percent) pertained to mental health
services, two (1 percent) pertained to detainee programs, and two (1 percent) pertained to facility
conditions and sanitation issues. The remaining 23 grievances (16 percent) were complaints
related to miscellaneous topics. As stated previously, due to an LASD Officer allegedly
throwing away detainee grievances, these statistics may not encompass all grievances submitted
during calendar year 2011.
ODO identified 13 deficiencies in the Food Service NDS, more than any other NDS reviewfd
during this CI. Three deficiencies had life/safety ramifications: detainees were observed
working around steam kettles with steam lines that were not covered or insulated with a heatresistant material; the meat grinder was not equipped with an anti-restart device; the fire
suppression system was not connected to the fire annunciation panel in the facility's control
center. Fire suppression and fire alarm systems are required to alert central control when
triggered to facilitate immediate staff response in the event of an emergency.
Detainees are served two hot meals and one cold meal each day. During interviews, many
detainees complained about food quality. LASD personnel and ICE staff stated detainees are
routinely critical of food service. ODO confirmed while on-site there had been an issue with
moldy bread being served to detainees. LASD officials stated the issue had been resolved by
properly rotating and dating bread upon arrival at the facility. ODO confirmed there is no
established schedule or procedure for stock rotation, to include the dating of food products.
Proper stock rotation ensures food items are used timely and food safety is maintained prior to
expiration dates.
ODO observed trash and food debris in the dry storage room and in the cluttered and
disorganized pot/pan room. Cluttered and unsanitary conditions in any area of the food service
department promote pest infestation and food borne illnesses.

Office of Detention Oversight
January 2012
OPR 201200444

3

Mira Lama Detention Center
ERO Los Angeles

ODO observed a food service worker carrying cigarettes in the cooking area. MLDC prohibits
tobacco in areas occupied by detainees, who are prohibited by MLDC rules from consuming
tobacco products. MLDC provides designated smoking areas for employees separate from
detainee areas. Possessing tobacco in the cooking area is not an NDS deficiency; however, it is a
violation of facility policy. This would be a deficiency ifMLDC transitions to the ICE PBNDS,
which will become the standard ifthe current LASD contract is renewed.
ODO observed large accumulations of food purchased from the commissary and stockpiled by
several detainees in the housing units. ODO learned that detainees are permitted to select and
order up to $175.00 worth of goods in a single commissary purchase. MLDC is a cash facility.
Detainees are permitted to retain $70.00 on their person and withdraw $70.00 every day. LASD
staff stated it is a violation for a detainee to possess more than $70.00. Operationally, ifMLDC
converted from a cash facility to a debit card operation, this would reduce the opportunities for
gambling, extortion, and a variety of other offenses among the detainees, and between detainees
and staff.
The medical department has 24-hour nursing coverage. Provider service is supplemented by a
cadre ofLASD physicians who provide on-call services during non-business hours, including
weekends and holidays. The on-call physicians can be reached by telephone or telemedicine, a
system through which nursing staff present cases and physicians interview and assess detainees.
At the time ofthe CI, there were 118 detainees with Keep-on-Person (KOP) medications. A
nurse is assigned the sole duty of reassessing detainees on the KOP program weekly, to include a
pill count of remaining medications to verify compliance. This reduces the risk of misuse of
medications and is identified by ODO as a best practice.
A full time dentist is also on duty five days a week. MLDC dental personnel routinely provide
care for detainees within 24 hours of a referral. MLDC achieves this by having a dentist and
dental assistant at the facility. ODO cites this as a best practice.
ODO confirmed there have been no suicide attempts, hunger strikes, or deaths during the past
year at MLDC.
ERO supervisory staff, the AFOD, an SDDO, and an SIEA, conduct unannounced visits
throughout the facility. ICE non-supervisory personnel do not conduct weekly announced visits,
or regular unannounced visits, to address detainee concerns and inquiries. ODO reviewed the
Facility Liaison Visit Checklists and noted the checklists are completed weekly, documenting
visits by ERO personnel. Each completed checklist displays the name of the visiting ERO
officer and the time ofthe visit. Detainees and LASD staff stated ERO officers do not visit the
housing units to address issues or to communicate with detainees. An lEA confirmed that
Spectrum contract officers visit the housing units and complete the Facility Liaison Visit
Checklists, which are then signed by an ERO officer. The Change Notice to the National
Detention Standards Staft7Detainee Communication Model Protocol, dated June 15, 2007,
requires that ERO officers conduct liaison visits.

Office of Detention Oversight
January 2012
OPR 201200444

4

Mira Lorna Detention Center
ERO Los Angeles

As a best practice, LASD supervisory personnel hold town hall meetings on Saturdays to allow
detainees to voice their needs and concerns. ICE personnel do not work on Saturdays, and are
not present at the meetings. During the closeout briefing, ODO recommended that LASD
consider rescheduling the meetings to facilitate attendance by ICE officials in order to
demonstrate to detainees that LASD and ICE are working together to resolve issues affecting the
quality of life at MLDC.
LASD has designated a Recreational Specialist (RS) to address the physical activity needs ofthe
detainees. The RS organizes intramural athletic events and oversees detainee recreation at
MLDC. This is an area of improvement since the May 2010 QAR, which identified the lack of
an RS as a deficiency.
While touring MLDC, ODO noticed the housing units were dirty and in a state of disarray. ODO
observed milk cartons and perishable food items strewn about the housing units. According to
LASD policy, perishable items must be collected one hour after a meal is served. The large
number of perishable items and dairy containers observed in the housing units indicates that this
procedure is not being followed.
ODO observed trash on the floors of multiple housing units. ODO observed towels on floors
around shower stalls and remnants of used bars of soap obstructing shower floor drains,
preventing natural drainage. While touring the barbershop lavatory, ODO noticed stains and
grime on the sink and walls, and litter on the floor. A high level of sanitation and cleanliness
throughout the facility is critical to preventing communicable diseases, and can improve detainee
morale. ODO considers this to be an area of concern. ODO recommends the facility inspect the
barbershop and detainee living areas on a regular basis to assess sanitation levels, and ensures
methods are in place to provide adequate sanitation.
This report includes descriptions of all identified deficiencies and refers to the specific, relevant
ICE NDS. The report will be provided to ERO to develop corrective actions to resolve the 41
identified deficiencies.

Office of Detention Oversight
January 2012
OPR 201200444

5

Mira Loma Detention Center
ERO Los Angeles

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. In addition, ODO
may specifically target detention management issues based on 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 MLDC 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 MLDC.

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 ongoing process of incorporating best practices in nationwide
detention facility operations.
OPR classifies program issues into one of two categories: deficiencies and areas of concern.
Specific deficiencies and areas of concern are highlighted in bold with sequential numbers in this
report. OPR defines a deficiency as a violation of written policy that can be specifically linked
to the ICE NDS, or to ICE policy or operational procedure. OPR defines an area of concern as
something that may lead to or risk a violation of the NDS, or 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 ofDetention Oversight.

INSPECTION TEAM MEMBERS

b6, b7c

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

Office of Detention Oversight
January 2012
OPR 201200444

6

ODO, Phoenix, AZ
ODO, Phoenix, AZ
ODO, Phoenix, AZ
ODO, Phoenix, AZ
Creative Corrections
Creative Corrections
Creative Corrections
Mira Lorna Detention Center
ERO Los Angeles

OPERATIONAL ENVIRONMENT
INTERNAL RELATIONS
ODO interviewed ICE and LASD staff at MLDC. LASD staff and ICE supervisory personnel
stated they maintain a positive working relationship with each other and morale is good. LASD
personnel stated ICE supervisors and officers rarely visit detainees in the housing units. ODO
confirmed Spectrum Contract Officers visit the housing units daily, but ICE officers do not.
Although ICE and LASD staff described their relationship as good, ODO was alerted to issues
between the two agencies and observed tension in day-to-day operations. ICE staff stated they
have experienced problems with LASD in the past regarding detainee grievances. One particular
incident of alleged abuse by LASD deputies was reported via the grievance process on July 4,
2011. An ICE detainee reported LASD deputies had humiliated him by placing a hairnet,
garbage, bologna, and currency on his head while laughing at him. The ICE detainee also
alleged during the incident, LASD deputies called him a "faggot" and a "crybaby." ICE staff
stated they made multiple attempts to follow up on the grievance, but LASD had been
uncooperative. Spectrum Contract Officers stated the detainee had directly provided them with
the original detainee grievance form prepared subsequent to the incident. Spectrum Contract
officers stated they made a photocopy of the document and placed the original in the Detainee
Grievance Box. Spectrum Contract Officers relinquished the photocopy to ICE staff. ICE staff
made numerous requests to see the original grievance, but LASD would not provide it. ICE has
only a photocopy of the original grievance.
The American Civil Liberties Union (ACLU) has an active lawsuit against LASD. Per open
source documents, the ACLU lawsuit alleges inmate abuse in LASD detention facilities.
ICE ERO field personnel recommended an audit by the DHS Office oflnspector General to
determine whether ICE is receiving sufficient value for the rate charged under the current
contract. ICE management stated that operational costs provided by LASD are inconsistent with
other facilities in the region. ICE management stated MLDC charges $154.08 per detainee and
adheres to the NDS, while the Adelanto Detention Facility (ADF) in neighboring San Bernardino
County charges $99 per detainee and adheres to the more stringent 2008 PBNDS. The capacity
at ADF is scheduled to expand from approximately 650 beds to 1,300 beds in July 2012.

DETAINEE RELATIONS
ODO interviewed 30 randomly-selected ICE detainees to assess the overall living and detention
conditions at MLDC. Eleven detainees (37 percent) could not identify their Deportation Officer
(DO) and twelve detainees (40 percent) did not know how to contact a DO. ODO verified ICE
officers are not visiting the detainee housing units as required per the Staff-Detainee
Communication NDS. Fifteen detainees (50 percent) complained about food. Detainees stated
they are given the same food every day and two of the three meals served are cold meals. ODO
confirmed detainees are not served two cold meals a day. Breakfast and dinner are served hot;
lunch is served cold. Detainees also indicated that the food is bland and the portions are small.
ODO verified all menus are certified by a registered dietitian. Six detainees (20 percent) stated it
Office of Detention Oversight
January 2012
OPR 201200444

7

Mira Lorna Detention Center
ERO Los Angeles

takes between four and seven days to be seen by medical staff after submitting a medical request.
ODO found MLDC to be in compliance with the Medical Care NDS with regard to detainees
being seen promptly after medical requests are submitted. Twelve detainees (40 percent) stated
it takes a week to get a reply after a grievance or request is submitted. ODO confirmed that
written responses to formal detainee grievances were not provided in a timely manner as required
bytheNDS.
There were no detainee complaints concerning access to telephones, access to legal materials, the
issuance and replenishment of hygiene supplies, the issuance of detainee handbooks, visitation,
religious services, or the sending and receiving of mail.

Office of Detention Oversight
January 2012
OPR 201200444

8

Mira Lorna Detention Center
ERO Los Angeles

ICE NATIONAL DETENTION STANDARDS
ODO reviewed a total of 16 NDS and found MLDC fully compliant with the following six
standards:
Admission and Release
Detainee Handbook
Special Management Unit (Administrative and Disciplinary)
Suicide Prevention and Intervention
Telephone Access
Tool Control
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 ten areas:
Access to Legal Material
Detainee Classification System
Detainee Grievance Procedures
Detainee Transfers
Disciplinary Policy
Environmental Health and Safety
Food Service
Medical Care
Staff-Detainee Communication
Use ofForce
ODO findings for each ofthese standards are presented in the remainder of this report.

Office of Detention Oversight
January 2012
OPR 201200444

9

Mira Lorna Detention Center
ERO Los Angeles

ACCESS TO LEGAL MATERIAL (ALM)
ODO reviewed the Access to Legal Material NDS at MLDC to determine if detainees have
access to a law library, legal materials, courts, counsel, and equipment to facilitate the
preparation oflegal documents. ODO reviewed local policies, procedures, and the detainee
handbook; inspected the areas designated for law library use; and interviewed staff and
detainees.
The law library is located in a building separate from the housing units. The space is quiet with
adequate furnishings, equipment, and supplies to effectively support legal research and case
preparation. The law library contains published and unpublished legal material for detainee use,
but the unpublished materials do not have cover sheets that identify the submitter, preparer, or
the date of preparation. There is also no statement that ICE did not prepare, and is not
responsible for, the contents (Deficiency ALM-1). A cover sheet and this statement inform
detainees the material has not been published and information within the material may not be
accurate.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY ALM-1
In accordance with the ICE NDS, Access to Legal Material, Section (III)(D), the FOD must
ensure unpublished material has a cover page that: 1. Identifies the submitter and the preparer of
the material; 2. States clearly that ICE did not prepare, and is not responsible for, the contents of
the material; and 3. Contains the date of preparation.

Office of Detention Oversight
January 2012
OPR 201200444

10

Mira Lorna Detention Center
ERO Los Angeles

DETAINEE CLASSIFICATION SYSTEM (DCS)
ODO reviewed the Detainee Classification System NOS at MLDC to determine ifthere is a
formal classification process for managing and separating detainees based on verifiable and
documented data. ODO interviewed staff and reviewed detention files to determine compliance
with the NDS. All officers assigned to classification duties were trained in the facility's
classification process.
Detainees are housed in two barracks located within a security fence prior to being classified by
LASD staff and placed into general population. LASD staff stated detainees who arrive after
hours on Friday are held in the in-processing barracks until Monday when LASD staff returns to
work (Deficiency DCS-1). As a result of the current procedures at MLDC, a detainee can
remain unclassified for an entire weekend prior to receiving an appropriate security
classification. This potentially exposes Level 1 detainees to Level 3 detainees, which is a
life/safety issue due to the criminal history or propensity for violence exhibited by Level3
detainees.
During a walk-through, ODO observed there were no LASD officers present in a designated
Level 3 housing unit. Additionally, ODO observed unsupervised Level 3 detainees traversing
common areas and interacting with Level 1 detainees (Deficiency DCS-2). Level 3 detainees
represent the highest security risk due to criminal history and/or propensity for violenc~, so this
matter raised serious safety concerns. During the Closeout Briefing, ODO discussed these
observations and raised these concerns with LASD and ICE management as potential life/safety
issues in need of immediate attention.
ODO reviewed 25 randomly-selected detention files. LASD staff indicated that an LASD officer
is assigned to review and approve the classification form. The classification forms were not
approved by a first-line supervisor, as required by the standard (Deficiency DCS-3).

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY DCS-1
In accordance with the ICE NOS, Detainee Classification System, section (III)(A)(l), the FOD
must ensure all detainees are classified upon arrival before being admitted into the general
population. ICE will provide CDFs and IGSA facilities with the data they need from each
detainee's file to complete the classification process. All officers assigned to classification duties
shall be trained in the facility's classification process.
DEFICIENCY DCS-2
In accordance with the ICE NDS, Detainee Classification System, section (III)(E)(3), the FOD
must ensure Level three detainees are always monitored and escorted.
DEFICIENCY DCS-3
In accordance with the ICE NDS, Detainee Classification System, section (III)(A)(3), the FOD
must ensure the first-line supervisor will review and approve each detainee's classification.
Office of Detention Oversight
January 2012
OPR 201200444

11

Mira Loma Detention Center
ERO Los Angeles

DETAINEE GRIEVANCE PROCEDURES (DGP)
ODO reviewed the Detainee Grievance Procedures NDS at MLDC 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. ODO interviewed staff
and detainees, and reviewed policies, grievance logs, and grievance statistics provided by LASD
staff.
The facility attempts 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. Detainees at MLDC use the same LASD form titled "Inmate
Complaint/Services Request Form" to submit both requests and formal grievances to LASD
staff. Detainees have the option of submitting completed complaint forms by placing them in the
locked complaint boxes located in all housing units, or by handing them directly to a staff
member. The facility accepts all formal complaints submitted by detainees, regardless of the
form used. Complaints are accepted in any written format. An LASD Sergeant stated that
LASD personnel initially review the form. LASD officials then decide ifthe matter should be
handled as a request or processed as a formal grievance. All formal grievances are reviewed by a
supervisor, at a minimum by a Sergeant. The grievance committee consists oftwo LASD
Sergeants and an LASD Lieutenant.
Responses to formal grievances are verbally provided to detainees. Detainees sign the bottom
portion of the complaint form acknowledging that a discussion ofthe grievance response
occurred; however, written responses to formal grievances are not provided to detainees
(Deficiency DGP-1).
The facility maintains an electronic grievance log to document and track formal grievances filed
by detainees. Original copies of all formal grievances are maintained in a master file for six
years; however, copies of formal grievances were not placed or maintained in the detainees'
detention files (Deficiency DGP-2). This deficiency was also identified during the May 2010
QAR.
Currently, an LASD Officer assigned to MLDC is under investigation by LASD Internal Affairs
for allegedly throwing away detainee grievances rather than taking appropriate action. ERO
employs a process similar to LASD for deciding if matters should be handled as a request or a
formal grievance. ERO staff stated detainees use an ICE request form for submitting formal
grievances because ERO does not provide dedicated grievance forms to detainees. An SDDO
stated an ICE officer reviews ICE request forms to determine whether matters will be handled as
requests or grievances. Due to discrepancies in these processes, ODO could not verify grievance
statistics provided for 2011.

Office of Detention Oversight
January 2012
OPR 201200444

12

Mira Lama Detention Center
ERO Los Angeles

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY DGP-1
In accordance with the ICE NOS, Detainee Grievance Procedures, section (I), the FOD must
ensure every facility will develop and implement standard operating procedures (SOP) that
address detainee grievances. Among other things, each SOP must establish a reasonable time
limit for providing written responses to detainees who filed formal grievances, including the
basis for the decision.
DEFICIENCY DGP-2
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.

Office of Detention Oversight
January 2012
OPR 201200444

13

Mira Lema Detention Center
ERO Los Angeles

DETAINEE TRANSFER (DT)
ODO reviewed the Detainee Transfer NDS at MLDC to determine iftransfers of detainees from
one facility to another are responsibly managed with regard to notification, detention records,
safety and security, and protection of detainee funds and property. ODO interviewed ERO staff
and reviewed documents in the Alien File (A-File) of a detainee who was in the process ofbeing
transferred out ofMLDC to another ICE detention facility.
Detainees are informed orally of their transfer moments before departing from MLDC; they do
not receive a written notification (Deficiency DT-1 ). It is important that detainees are notified of
their inter-facility transfers via a Detainee Transfer Notification Sheet so they can relay the
address and telephone number ofthe new detention facility to family and friends. This
deficiency was also identified during the May 20 I 0 QAR.
ODO confirmed the Detainee Transfer Checklist is not used by ERO at MLDC to prepare for
permanent transfers (Deficiency DT-2). This deficiency was also identified during the May
2010 QAR. A detainee deemed medically unfit to be housed at MLDC due to psychiatric
reasons was transferred from MLDC to the Los Angeles Staging Facility. The ODO review
determined that all required documents were maintained in the A-File except the Detainee
Transfer Checklist. It is important that ERO officers at MLDC use the Detainee Transfer
Checklist to ensure required tasks are completed prior to a detainee's transfer from the facility,
such as notifying the detainee's attorney (if applicable), completing the Detainee Transfer
Notification form, fingerprinting and photographing the detainee, releasing the detainee's
personal property, and transmitting the Form I -216 to the receiving detention facility via
facsimile.
ODO requested a copy ofthe medical transfer summary sheet for the transferred detainee, but it
was never provided. ODO could not determine whether a medical transfer summary had been
prepared by medical staff, or if the transfer summary had accompanied the detainee at the time
the transfer occurred (Deficiency DT-3). Due to insufficient record keeping at MLDC, ODO
was unable to determine whether all property had been returned to the detainee prior to departure
from the facility (Deficiency DT -4). A medical transfer summary, prepared by medical staff,
must accompany the detainee to his or her new detention facility so the medical staff can quickly
identify any medical conditions that need immediate care or attention. Furthermore, ensuring
detainee's personal property, funds and valuables are properly signed out and accurately
documented prevents a detainee from claiming his or her property was misplaced by the facility
prior to the transfer.
ODO notes that ICE Policy 11022.1, Detainee Transfers, was implemented on January 4, 2012.
At the time of this inspection, ODO did not cite any deficiencies related to the policy. ODO
emphasizes the importance ofERO staffto be fully acclimated and in compliance with this
Detainee Transfer Policy.

Office of Detention Oversight
January 2012
OPR 201200444

14

Mira Lorna Detention Center
ERO Los Angeles

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY DT-1
In accordance with the ICE NDS, Detainee Transfer, section (III)(A)(3), the FOD must ensure, at
the time ofthe transfer, ICE will provide the detainee, in writing, with the name, address and
telephone number ofthe facility he/she is being transferred to. The Detainee Transfer
Notification Sheet shall be used for this purpose. The detainee will also be instructed that it is
his/her responsibility to notify family members. A copy of the transfer notification sheet will be
placed in the detainee's detention file.
DEFICIENCY DT-2
In accordance with the ICE NDS, Detainee Transfer, section (III)(D), the FOD must ensure the
Detainee Transfer Checklist shall be filled out in order to insure that all procedures are
completed, and shall be placed in the detainee's A-file or work folder. If any procedure cannot
be completed prior to the transfer of the detainee, that transfer will not take place unless the
authorized official at the receiving field office has expressly agreed to waive that portion of the
procedure. This waiver should be noted on the checklist.
DEFICIENCY DT-3
In accordance with the ICE NDS, Detainee Transfer, section (III)(D)(3)and(6), the FOD must
ensure a transfer summary sheet, prepared by the sending facility's medical staff, must
accompany the transferee. Either the USM 553 Form or a facility-specific form may be used,
provided it shows: a. TB clearance, including PPD and chest X-ray results, including test dates;
b. Current mental and physical health status, including all significant health issues; c. Current
medications, with specific instructions for medications that must be administered en route; and
d. The name and contact information ofthe transferring medical official.
DEFICIENCY DT-4
In accordance with the ICE NDS, Detainee Transfer, section (III)(E)(l), the FOD must ensure
the following items shall always accompany a detainee to the receiving SPC, CDF, or IGSA
facility: cash, and small valuables such as jewelry, address books, phone lists, correspondence,
dentures, prescription glasses, small religious items, pictures, etc.

Office of Detention Oversight
January 2012
OPR 201200444

15

Mira Lorna Detention Center
ERO Los Angeles

DISCIPLINARY POLICY (DP)
ODO reviewed the Disciplinary Policy NDS at MLDC to determine if sanctions imposed on
detainees who violate facility rules are appropriate, and ifthe discipline process includes due
process requirements. ODO interviewed staff and reviewed policy, disciplinary records, and the
MLDC Detainee Handbook.
The facility uses graduated severity scales for prohibited acts and disciplinary consequences.
Policy requires that minor transgressions be informally settled whenever possible. The ODO
review confirmed incidents are investigated within 24 hours by a supervisor, and detainees are
advised oftheir rights, to include the right to an appeal.
According to facility policy, detainees are subject to suspension of correspondence privileges for
72 hours as a disciplinary sanction (Deficiency DP-1). Use of deprivation of correspondence
privileges as a disciplinary sanction is prohibited by the NDS. While written policy provided for
it, ODO did not find any instances where this sanction had been imposed at MLDC. ODO
recommends updating facility policy to ensure suspension of correspondence privileges is no
longer considered an appropriate sanction, and informing all staff of the change in policy.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY DP-1
In accordance with the ICE NDS, Disciplinary Policy, section (III)(A)(3), the FOD must ensure
staff may not impose or allow imposition ofthe following sanctions: corporal punishment;
deviations from normal food services; deprivation of clothing, bedding, or items ofpersonal
hygiene; deprivation of correspondence privileges; or deprivation of physical exercise unless
such activity creates an unsafe condition.

Office of Detention Oversight
January 2012
OPR 201200444

16

Mira Lorna Detention Center
ERO Los Angeles

ENVIRONMENTAL HEALTH AND SAFETY (EH&S)
ODO reviewed the Environmental Health and Safety NDS at MLDC to determine if the facility
maintains high standards of cleanliness and sanitation, safe work practices, and control of
hazardous materials and substances. ODO toured the facility, interviewed staff, and reviewed
policies and documentation of inspections, hazardous chemical management, and frre drills.
The facility maintains a master index ofhazardous substances and a master file of Material
Safety Data Sheets; however, a copy had not been forwarded to the local fire department, and
semiannual reviews ofthe contents ofthe index had not been conducted (Deficiency EH&S-1).
This deficiency was also identified during the May 2010 QAR. During the inspection, MLDC
forwarded a copy of the master index to the local fire department. To achieve full compliance
with the standard, MLDC must conduct semi-annual reviews ofthe index.
Review of the electrical power generator log confirmed biweekly tests had not been conducted
consistently between October 2011 and January 2012. In addition, quarterly tests and repairs by
an external generator servicing company had not occurred (Deficiency EH&S-2). Routine
testing and servicing of electrical power generators helps ensure operability in the event of a
power failure.
Observation ofbarbering operations confirmed there are no disposable covers for headrests on
the barber chairs (Deficiency EH&S-3). Inspection of barber kits used by detainee barbers
revealed combs, clipper blades, and clippers were not thoroughly cleaned and disinfected to
remove hair, debris, and film (Deficiency EH&S-4). The NDS prohibits common use of
brushes, neck dusters, shaving mugs, and shaving brushes. ODO observed items such as neck
dusters and small clipper brushes in the barber kits, promoting common use (Deficiency
EH&S-5). ODO recommends that immediate steps be taken to assure proper sanitation of
barbering equipment, including the disposal of disposable combs. Adherence to sanitation
regulations is critical to minimize the risk of cross-contamination related to the use of shared hair
care equipment.
In addition to these deficiencies, ODO observed other sanitation and housekeeping concerns.
The barbershop lavatory had litter on the floor and there were stains and grime on the sink, walls,
and toilet. The countertops and cabinets in the barbershop were covered with dust and hair. The
floors in detainee living units throughout the complex were observed to be littered with trash and
food debris. Towels were observed on the floors around the shower stalls and remnants ofused
bars of soap had collected around shower floor drains, inhibiting drainage. Sanitation of detainee
housing units and barbershops is critical to preventing the spread of communicable infections
and disease. ODO considers this to be an area of concern. ODO recommends the facility inspect
the barbershop and detainee living areas on a regular basis to assess sanitation levels and to
ensure methods are in place to provide adequate sanitation in all detainee living areas.

Office of Detention Oversight
January 2012
OPR 201200444

17

Mira Lorna Detention Center
ERO Los Angeles

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY EH&S-1
In accordance with the ICE NDS, Environmental Health and Safety, section (III)(C), the POD
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 must maintain this information in the safety office (or equivalent), with a copy to the
local fire department. Documentation ofthe 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-2
In accordance with the ICE NDS, Environmental Health and Safety, section (111)(0), the POD
must ensure power generators will be tested at least every two weeks. The bi-weekly test ofthe
emergency electrical generator will last one hour. During that time, the oil, water, hoses and
belts will be inspected for mechanical readiness to perform in an emergency situation. The
emergency generators will also receive quarterly testing and servicing from an external generator
service company. Among other things, the technicians will check starting battery voltage,
generator voltage and amperage output.
DEFICIENCY EH&S-3
In accordance with the ICE NDS, Environmental Health and Safety, section (III)(P)(2), the POD
must ensure each barbershop will be provided with all equipment and facilities necessary for
maintaining sanitary procedures ofhair care. Each shop will be provided with appropriate
cabinets, covered metal containers for waste, disinfectants, dispensable headrest covers,
laundered towels and haircloths.
DEFICIENCY EH&S-4
In accordance with the ICE NDS, Environmental Health and Safety, section (III)(P)(4)(a), the
POD must ensure all scissors, combs or other tools (except clippers) will be thoroughly washed
with soap and hot water to remove film and debris, and effectively disinfected immediately after
use on each detainee and before being used for the service of any other detainee.
DEFICIENCY EH&S-5
In accordance with the ICE NDS, Environmental Health and Safety, section (III)(P)(4)(f), the
POD must ensure the common use ofbrushes, neck dusters, shaving mugs and shaving brushes
will be prohibited.

Office of Detention Oversight
January 2012
OPR 201200444

18

Mira Lorna Detention Center
ERO Los Angeles

FOOD SERVICE (FS)
ODO reviewed the Food Service NDS at MLDC to determine if detainees are provided with a
nutritious and balanced diet, in a sanitary manner. ODO interviewed staff, inspected storage
areas, observed meal preparation and service, and reviewed policy and relevant documentation.
The MLDC food service program is staffed by county employees and consists of a Food Service
Administrator,(b)(7)e Cook Supervisor, (b)(7)e Senior Cook Foremen, and (b)(7)e Intermediate Food
Service Workers. Food service operations are supported by detainee work crews. (b)(7)e security
officers perform custody and security functions. Kitchen assignments are rotated every six
months to promote comprehensive knowledge in food service operations for all assigned staff.
The facility employs a satellite service system for the morning and noon meals. The evening
meal is served in the detainee dining hall. Review oftemperature logs confirmed compliance
with the standard. ODO verified all menus were certified by a registered dietitian.
ODO found three deficiencies with life/safety ramifications. Detainees were observed working
around steam kettles with steam lines that were not covered or insulated with a heat-resistant
material (Deficiency FS-1 ). Proper covering or insulation of steam lines is critical to prevent
burns and other injuries. The meat grinder is not equipped with an anti-restart device
(Deficiency FS-2). Equipment powered by electricity stops working when the electrical power
is interrupted. Once power is restored, the equipment restarts automatically, which presents a
significant safety hazard to staff and detainee workers. The fire suppression system is not
connected to the fire annunciation panel in the facility's control center (Deficiency FS-3). Fire
suppression and fire alarm systems are required to alert central control when triggered to
facilitate immediate staff response in the event of an emergency.
ODO observed cloves in the food preparation area not properly secured and inventoried
(Deficiency FS-4). Cloves are a desirable commodity in the general population because they can
be used to make cigarettes, which pose a health risk when smoked. Potentially dangerous items
such as cloves require special handling for the secure and orderly operation of the facility, and
the health of detainees. Numerous perishable food items were not properly labeled (Deficiency
FS-5), including leftover food in walk-in cooler #2 and in the cold food box behind the main
serving line, as well as peaches in the cold food box. The label on leftover pudding in the walkin cooler did not include a time limit for consumption. Perishable food items must be properly
labeled to promote freshness and food safety, and to prevent food-borne illnesses.
Documentation of medical clearances to work in the kitchen was provided for detainee food
service workers; however, documentation of medical clearances for food service staffwas not
available (Deficiency FS-6). LASD staffwould not provide evidence of physical examinations
due to a perceived violation of privacy. ODO notes that compliance with the standard would be
satisfied by documentation that a physical examination has been completed and that medical
clearance to work in food service has been granted. There is no requirement to produce the
results ofthe physical examination itself.

Office of Detention Oversight
January 2012
OPR 201200444

19

Mira Lama Detention Center
ERO Los Angeles

Trash and dirt were observed on the floor behind pallets throughout the dry storage area. In
addition, trash and food debris were observed on the floor in the comers ofthe cluttered and
disorganized (Deficiency FS-7). Cluttered, unsanitary conditions in food service areas can
promote pest infestation and food-borne illnesses.
The facility does not have a three compartment sink (Deficiency FS-8); however, a system has
been established for cleaning, rinsing, and sanitizing utensils and equipment following the three
step process. This deficiency was identified during the May 2010 QAR. Inspection ofthe
chemical storage room revealed spray bottles containing hazardous substances were not properly
labeled to identify the contents and potential hazard (Deficiency FS-9).
There are no written procedures addressing weekly inspections ofthe food service area
(Deficiency FS-10). ODO was informed weekly inspections ceased in 2010. Regular, consistent
inspections are essential for ensuring that efficient, safe, and sanitary food service operations are
maintained.
The ODO inspection ofthe storage area determined that food products are stored six inches
above the ground, but are not uniformly stored two inches from the walls (Deficiency FS-11).
The standard requires a minimum of two inches clearance from walls to promote proper air
circulation and to prevent possible contamination by vermin.
ODO found during the review that a large percentage ofbulk food (dry, frozen, and refrigerated)
stored at MLDC had not been properly dated for stock rotation, and there was no established
schedule or procedure for rotating stock (Deficiency FS-12). ODO observed receipt dates
displayed on consumable food items that had yet to occur. In one circumstance, the date goods
had been received was labeled "4-1-12" vs. "1-4-12" (month/day/year). LASD staff stated
detainees had written the incorrect dates on the boxes. ODO recommended that staff, not
detainees, take responsibility for ensuring proper labeling for stock rotation on all consumable
food items. Lack of identifiable stock rotation dates prevents food from being served at its
freshest and allows the opportunity for spoilage due to expired or expiring dates.
Inspection of weekly perpetual audit records confirmed that inventory documentation is
incomplete (Deficiency FS-13). Inventory report forms do not include the quantity received, the
quantity issued, or the unit cost. In addition, the inventory report reveals weekly audits had not
been conducted for the weeks of December 19, 2011, and January 2, 2012. Perpetual audits are
essential to provide pertinent information on product usage and support accurate cost analysis.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY FS-1
In accordance with the ICE NDS, Food Service, section (III)(H)(12)(b), the FOD must ensure all
steam lines within seven feet ofthe floor or working surface, and with which a worker may come
in contact, shall be insulated or covered with a heat- resistant material, or be otherwise guarded
from contact. Inaccessible steam lines (guarded by location) need not be protected from contact.

Office of Detention Oversight
January 2012 ·
OPR 201200444

20

Mira Lorna Detention Center
ERO Los Angeles

DEFICIENCY FS-2
In accordance with the ICE NDS, Food Service, section (III)(H)(l2)(c)(4), the FOD must ensure
meat saws, slicers, and grinders are equipped with anti-restart devices.
DEFICIENCY FS-3
In accordance with the ICE NDS, Food Service, section (III)(H)(l2)(t), the FOD must ensure an
approved, fixed, fire-suppression system shall be installed in ventilation hoods over all grills,
deep fryers and open flame devices. A qualified contractor shall inspect the system every six
months. The fire-suppression system shall be equipped with a locally audible alarm and
connected to the control room's annunciator panel.
DEFICIENCY FS-4
In accordance with the ICE NDS, Food Service, section (III)(B)(4), the FOD must ensure all
facilities shall have procedures for the handling of food items that pose a security threat. Mace,
nutmeg, cloves, and alcohol-based flavorings also require special handling and storage. Staff
shall store and inventory these items in a secure area in the food service department. The
purchase order for any ofthese items will specify the special-handling requirements for delivery.
Staff shall directly supervise use of these items.
DEFICIENCY FS-5
In accordance with the ICE NDS, Food Service, section (III)(D)(8), the FOD must ensure
prepared food items which have not been placed on the serving line may be retained for no more
than 24 hours. Leftovers offered for service a second time shall not be retained for later use, but
shall be discarded immediately after offering. All leftovers shall be labeled to identify the
product, preparation date, and time.
DEFICIENCY FS-6
In accordance with the ICE NDS, Food Service, section (III)(H)(3), the FOD must ensure all
food service personnel (both staff and detainee) receive a pre-employment medical examination.
The purpose ofthis examination is to exclude those who have a communicable disease in any
transmissible stage or condition. Detainees who have been absent from work for any length of
time for reasons of communicable illness (including diarrhea) shall be referred to Health
Services for a determination as to fitness for duty prior to resuming work.
DEFICIENCY FS-7
In accordance with the ICE NDS, Food Service, section (III)(H)(5)(c), the FOD must ensure all
facilities shall meet the following environmental standards: Routinely cleaned walls, floors, and
ceilings in all areas.
DEFICIENCY FS-8
In accordance with the ICE NDS, Food Service, section (III)(H)(7)(t)(l ), the FOD must ensure a
sink with at least three labeled compartments is required for manually washing, rinsing, and
sanitizing utensils and equipment. Each compartment shall have the capacity to accommodate
the items to be cleaned. Each shall be supplied with hot and cold water.

Office of Detention Oversight
January 2012
OPR 201200444

21

Mira Lorna Detention Center
ERO Los Angeles

DEFICIENCY FS-9
In accordance with the ICE NDS, Food Service, section (III)(H)(ll)(c), the FOD must ensure all
containers oftoxic, flammable, or caustic materials shall be prominently and distinctively labeled
for easy content identification.
DEFICIENCY FS-10
In accordance with the ICE NDS, Food Service, section (III)(H)(13)(a), the FOD must ensure the
facility shall implement written procedures for the administrative, medical, and/or dietary
personnel conducting the weekly inspections of all food service areas, including dining, storage,
equipment, and food-preparation areas. All components ofthe food service department, (ranges,
ovens, refrigerators, mixers, dishwashers, garbage disposal, etc.) require frequent inspection to
ensure their sanitary and operable condition. Staff shall check refrigerator and water
temperatures daily, recording the results. The FSA orCS of food service shall inspect food
service areas weekly.
DEFICIENCY FS-11
In accordance with the ICE NDS, Food Service, section (III)(J)(3)(e), the FOD must ensure that
personnel store food items at least two inches from the walls and at least six inches above the
floor. Wooden pallets may be used to store canned goods and other non-absorbent containers,
but not to store dairy products or fresh produce.
DEFICIENCY FS-12
In accordance with the ICE NDS, Food Service, section (III)(J)(5), the FOD must ensure each
facility shall establish a written stock-rotation schedule.
DEFICIENCY FS-13
In accordance with the ICE NDS, Food Service, section (III)(J)(6), the FOD must ensure,
although details may vary, the information recorded [for the perpetual inventory] always
includes the quantity on hand, quantity received, quantity issued, and unit cost for each food and
supply item. Perpetual inventory records are important because they provide the FSA with upto-date information on product usage and give direction for further purchases. For accurate
accounting of all food and supplies, a perpetual inventory record is insufficient. An official
inventory of stores on hand must be taken annually with a food service staff member and a
member of the financial management staff. All food service departments shall complete a
physical inventory ofthe warehouse quarterly.

Office of Detention Oversight
January 2012
OPR 201200444

22

Mira Lorna Detention Center
ERO Los Angeles

MEDICAL CARE (MC)
ODO reviewed the Medical Care NDS at MLDC to determine if detainees have access to
healthcare and emergency services to meet health needs in a timely manner. ODO reviewed
policies and procedures, and observed intake screening, sick call, dispensing of medication,
health appraisals and telemedicine practices. In addition, ODO examined 45 detainee medical
records, verified medical staff credentials, and interviewed health care staff.
Health care at MLDC is provided by medical personnel employed by LASD. The facility holds
no accreditations. The medical department has 24-hour nursing coverage. A full-time
Registered Nurse Practitioner (RNP) and a fulltime dentist are on duty five days per week.
Provider service is supplemented by a cadre ofLASD physicians who provide on-call services
during non-business hours, including weekends and holidays. The on-call physicians can be
reached by telephone or telemedicine, a system through which nursing staff present cases and
physicians interview and assess detainees. Additional medical staff consists of a Health Service
Administrator (HSA);(b)(7)eRegistered Nurses (RN), (b)(7)e ofwhom serve as nursing supervisors;
(b)(7)eLicensed Vocational Nurses (LVN); (b)(7)e Medical Records Technicians; and(b)(7)eDental
Assistant. ODO found staffing and services adequate for the size of the detainee population held
atMLDC.
MLDC accepts only healthy detainees who require minimal care. Consequently, intake
screening focuses on assessing the general health of arriving detainees. ODO verified intake
screening is conducted within two to three hours of arrival in all cases. MLDC does not accept
detainees with chronic conditions requiring frequent monitoring such as HIV, hepatitis B,
hypertension, mental illness, cardiac conditions, insulin-dependent diabetes, or detainees with
orthopedic needs requiring crutches and/or splinting. All detainees are screened for TB by way
of a chest X-ray at the Los Angeles Sheriffs Department prior to admission. Detainees without
a negative chest X-ray report are not admitted to MLDC.
Detainees access medical services through use of sick call request forms that are placed in locked
boxes within the housing units. These locked boxes are also used to submit non-medical
requests. Security staff maintains the keys to the boxes and sorts all requests, forwarding any
medical requests to the medical unit. This practice was cited as a deficiency during the
September 2011 ERO annual inspection. As a corrective action, MLDC instituted a procedure
requiring nursing staffto be present when security staff opens the locked boxes; however, ODO
does not agree that this procedure assures the confidentiality of medical requests. ODO
recommends that separate boxes dedicated solely to medical requests be installed, with keys to
those boxes solely managed by the medical staff. Under the current arrangement, confidentiality
cannot be guaranteed. This is a continued deficiency (Deficiency MC-1).
ODO confrrmed health appraisals and physical examinations had been conducted by the RNP
within seven to ten days of arrival in all 45 cases reviewed. This exceeds the NDS requirement
of completing the physical examinations within 14 days of arrival. ODO verified health
appraisals include a hands-on assessment of systems, and a visual examination for dental status.
Referrals for dental services are submitted as needed. Review ofthe dental list indicated

Office of Detention Oversight
January 2012
OPR 201200444

23

Mira Lorna Detention Center
ERO Los Angeles

detainees referred to the dental department are seen by the dentist within 24 hours of referral.
ODO cites this as a best ·practice well exceeding the standard.
At the time of the CI, there were 118 detainees with Keep-on-Person (KOP) medications. A
nurse is assigned the sole duty of reassessing detainees on the KOP program weekly, to include a
pill count of remaining medications to verify compliance. This reduces the risk of misuse of
medications and is identified by ODO as a best practice.
ODO reviewed and verified credentials, licenses, and CPR certifications for all medical staff.
All providers had current Drug Enforcement Administration licenses on file. Medical staff
training records included current documentation oftraining on hunger strikes and medical
protocols.
According to nursing staff and the HSA, detainees requiring emergency care and management
beyond the scope of services at MLDC are sent to Antelope Valley Hospital or Palmdale
Regional Hospital for off-site care. ODO recommends use ofthese facilities be formalized in
memoranda ofunderstanding.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY MC-1
In accordance with the ICE NDS, Medical Care, section (III)(M), the FOD must ensure all
medical providers shall protect the privacy of detainee's medical information to the extent
possible, while permitting the exchange ofhealth information required to fulfill program
responsibilities and to provide for the well being of detainees.

Office of Detention Oversight
January 2012
OPR 201200444

24

Mira Lama Detention Center
ERO Los Angeles

STAFF-DETAINEE COMMUNICATION (SDC)
ODO reviewed the Staff-Detainee Communication NDS at MLDC to determine ifprocedures are
in place to allow formal and informal contact between detainees and key ICE and facility staff,
and ifiCE detainees are able to submit written requests to ICE staff and receive responses in a
timely manner. ODO interviewed staff and detainees, toured and observed housing units, and
reviewed policies, request logs, ERO visitation records, and detention files.
ERO supervisory staff, the AFOD, an SDDO, and an SIEA, conduct unannounced visits
throughout the facility. The unannounced visits are manually recorded in a logbook maintained
by ERO; however, specific housing units visited by ERO supervisory staff are not identified on
most entries in the ERO logbook. An LASD Sergeant stated that visits by ERO officers are not
always recorded by housing unit officers in the electronic logs compiled in the housing units
(Deficiency SDC-1). ODO could not verify or validate the unannounced visits by
cross-checking ERO visitation records with LASD housing unit logs.
ODO reviewed the Facility Liaison Visit Checklists and noted that the checklists are completed
documenting weekly visits by ERO personnel. Each completed checklist displays the name of
the visiting ERO officer and the time of the visit. Detainees and LASD staff stated ERO officers
do not visit the housing units to address issues or to communicate with detainees. An lEA
confirmed that Spectrum Contract Officers visit the housing units and complete the Facility
Liaison Visit Checklists, which are then signed by an ERO officer (Deficiency SDC-2). The
lEA stated Spectrum Contract Officers conduct the weekly liaison visits for ERO, because there
is not a DO or lEA available to complete the task.
An LASD Sergeant stated, and ODO verified, ERO does not provide LASD staff with a logbook
for ERO officers to document the names and alien numbers of detainees interviewed during
liaison visits (Deficiency SDC-3). This logbook should be maintained by LASD staff according
to the ICE ERO Staffi'Detainee Communication Model Protocol, dated June 15, 2007.
Detainees have opportunities to submit written questions, requests, or concerns to facility and
ERO staff. Detainees use an Inmate Complaint I Services Request Form to submit requests and
formal grievances to LASD staff. Detainees use an ICE Detainee Request Form to submit
requests and formal grievances to ERO (Deficiency SDC-4). The NDS requires use of a
dedicated grievance form. Submission of requests and formal grievances on the same form does
not comply with the standard.
LASD staff received and processed ten detainee requests during December 201 1. A review of
the requests showed two (20 percent) of the requests were not answered within 72 hours. Two
other requests (20 percent) had no notation or documentation verifying a response, so ODO
could not confirm a response had been provided (Deficiency SDC-5).
ERO maintains an electronic request log for documenting and tracking detainee requests
submitted directly to ICE. During calendar year 2011, ERO received and processed 4,698
requests submitted by detainees at MLDC. ERO staff stated the on-site AFOD is electronically

Office of Detention Oversight
January 2012
OPR201200444

25

Mira Lorna Detention Center
ERO Los Angeles

notified when requests are not answered within 72 hours. The ERO log does not identify the
officer logging the request. LASD staff does not maintain a log for documenting and recording
detainee requests. Completed ICE request forms are maintained in detention files, but completed
LASD request forms are not (Deficiency SDC-6). This deficiency was also identified during the
May2010 QAR.

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 Change Notice National Detention Standards Staff7Detainee
Communication Model Protocol, dated June 15, 2007, section (C)(2), the FOD must ensure
assigned [ERO] officers shall enter all units in which detainees are housed and document
observations ofthe general living condition: General population housing units, Special Housing
Units (administrative and disciplinary segregation), and Medical units (infirmaries, hospitals,
etc.).
DEFICIENCY SDC-3
In accordance with the Change Notice National Detention Standards Staff/Detainee
Communication Model Protocol, dated June 15, 2007, section (F)(3), the FOD must ensure the
officer shall document each visit, in the following format: The Field Office should provide the
facility with a logbook to maintain in control. The officer shall log in his or her visit, names, and
alien registration of detainees interviewed, along with any concerns or comments.
DEFICIENCY SDC-4
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.
Formal grievances shall be submitted according to the procedures specified in the Detainee
Grievance standard. However, the procedures outlined here may be used to resolve informal
grievances as described in that standard.
DEFICIENCY SDC-5
In accordance with the ICE NDS, Staff-Detainee Communication, section (III)(B)(l)(a), the
FOD must ensure, in SPCs/CDFs and in IGSAs with ICE on-site presence, the officer receiving
the request shall normally respond in person or in writing as soon as possible and practicable, not
later than within 72 hours from receiving the request.

Office of Detention Oversight
January 2012
OPR 201200444

26

Mira Lorna Detention Center
ERO Los Angeles

DEFICIENCY SDC-6
In accordance with the ICE NDS, Staff-Detainee Communication, section {III)(B)(2), 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;£ 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.

Office of Detention Oversight
January 2012
OPR 201200444

27

Mira Lorna Detention Center
ERO Los Angeles

USE OF FORCE (UOF)
ODO reviewed the Use ofForce NDS at MLDC to determine if necessary use of force is
employed 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.
MLDC has a written policy governing the use of force. Digital video cameras maintained in
three separate locations are readily available to document use of force incidents and are checked
daily by designated staff. In the year preceding the CI, MLDC had three documented uses of
force on detainees: one calculated, and two immediate. Review of the video-recording for the
calculated use of force incident verified it covered all required elements; however, a copy was
not forwarded to ICE (Deficiency UOF-1), and the facility did not catalogue and preserve a copy
on-site (Deficiency UOF-2). In accordance with local policy, the video-recording was
forwarded to the LASD Discovery Unit to be maintained for 60 months. Digital recording of
incidents facilitates compliance with local policy and the ICE NDS, and ensures all parties are
able to view the incident exactly as it occurred.
Review of documentation on the two immediate uses of force confirmed that detainees were not
examined by medical personnel following the incidents (Deficiency UOF-3). Immediate,
mandatory medical evaluations serve the critical purpose of identifying injuries, assuring
detainees receive necessary care, and shielding the facility from future legal claims.
MLDC does not use four-point restraints, but does use a restraint chair when necessary. Some
staff members carry M26 or X26 tasers, which are electro-muscular disruption devices. ODO
verified staff assigned to carry and use tasers are trained in their proper use and deployment. The
MLDC arsenal includes Othochlorobenzalmalonitrile (CS Gas), a chemical agent not authorized
by ICE (Deficiency UOF-4). LASD management stated LASD policy and non-negotiable Los
Angeles County Employee Union Agreements require these options be available for use on
detention personnel, though their use is avoided. There have been no uses oftasers or CS Gas on
ICE detainees at MLDC.
Deputies assigned to the facility are trained at the LASD Academy to use carotid (choke) holds.
Though prohibited by ICE, use of this restraint technique is authorized by the MLDC use of
force option chart (Deficiency UOF-5).

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY UOF-1
In accordance with the ICE NDS, Use ofForce, section (III)(A)(2)(b), the FOD must ensure that
all incidents of use of force be documented and forwarded to ICE for review.

Office of Detention Oversight
January 2012
OPR 201200444

28

Mira Lorna Detention Center
ERO Los Angeles

DEFICIENCY UOF -2
In accordance with the ICE NDS, Use of Force, section (III)(A)(4)(h), the FOD must ensure the
videotape shall be catalogued and preserved until no longer needed, but no less than 30 months
after its last documented use. In the event of litigation, the facility will retain the tape a
minimum of six months after its conclusion/resolution.

DEFICIENCY UOF-3
In accordance with the ICE NDS, Use ofForce, section (111)(0)(2), the FOD must ensure, after
any use of force or forcible application of restraints, medical personnel shall examine the
detainee, immediately treating any injuries. The medical services provided shall be documented.

DEFICIENCY UOF-4
In accordance with the ICE NDS, Use ofForce, section (III)(M), the FOD must ensure the
following non-deadly force devices are not authorized for use: 1. Saps, blackjacks, and sap
gloves; 2. Mace; tear gas, or other chemical agents, except OC spray; 3. Homemade devices, or
tools; and 4. Any other device or tool not issued or approved by ICE.

DEFICIENCY UOF-5
In accordance with the ICE NDS, Use ofForce, section (III)(N)(l), the FOD must ensure the
following acts and techniques are prohibited when using non-deadly force: Choke holds, carotid
control holds, and other neck restraints.

Office of Detention Oversight
January 2012
OPR 201200444

29

Mira Lorna Detention Center
ERO Los Angeles