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

Office of Detention Oversight
Compliance Inspection

Enforcement and Removal Operations
Atlanta Field Office
North Georgia Detention Center
Gainesville, Georgia

May 8 - 10, 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
NORTH GEORGIA DETENTION CENTER
ATLANTA 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 PERFORMANCE BASED NATIONAL DETENTION STANDARDS
Detention Standards Reviewed ................................................................................8
Detainee Handbook ..................................................................................................9
Food Service ..........................................................................................................10
Staff-Detainee Communication .............................................................................11

EXECUTIVE SUMMARY
The Office of Professional Responsibility (OPR), Office of Detention Oversight (ODO)
conducted a Compliance Inspection (CI) of the North Georgia Detention Center (NGDC) in
Gainesville, Georgia, from May 8-10, 2012. NGDC, which opened in October 1, 2009, is
owned by Hall County, Georgia, and operated by the Corrections Corporation of America
(CCA). U.S. Immigration and Customs Enforcement (ICE), Office of Enforcement and Removal
Operations (ERO) began housing detainees at NGDC on October 1, 2009, under an
Intergovernmental Service Agreement (IGSA) between ICE and Hall County. Only ICE
detainees are housed at NGDC. Male and female detainees of security classification Level II and
Level III (Level I – lowest threat; Level II – medium threat; Level III – highest threat) are
detained at the facility for periods in excess of 72 hours. NGDC has a maximum capacity of 502
detainees. At the time of the CI, NGDC housed 259 ICE detainees (219 male; 40 female). The
average daily detainee population is 349. The average length of stay is 16 days. Trinity
Correctional Services provides food service, and CCA provides medical care. The facility holds
accreditation from the American Corrections Association (ACA).
The ICE ERO Field Office Director in Atlanta, Georgia (FOD/Atlanta), is responsible for
ensuring facility compliance with ICE policies and the 2008 Performance Based National
Detention Standards (PBNDS). ODO confirmed with the Contracting Officer’s Technical
Representative (COTR) that in January 2010 the NGDC transitioned from the National Detention
Standards (NDS) to the PBNDS. An Assistant Field Office Director (AFOD) located at the
FOD/Atlanta has oversight responsibility for NGDC. ICE personnel are assigned to NGDC on a
permanent basis. ICE staff is comprised of(b)(7)e
Supervisory Detention and Deportation Officer
(SDDO),(b)(7)e Immigration Enforcement Agents (IEA),(b)(7)e Deportation Officers (DO), and (b)(7)e
Detention and Removal Assistant (DRA). There is no DSM assigned to the facility.
The Warden is the highest ranking official at NGDC and is responsible for oversight of daily
operations. In addition to the Warden, supervisory staff at NGDC consists of an Assistant
Warden, a Chief of Security, a Chief Unit Manager, a Quality Assurance Manager, a Safety
Manager, a Training Manager, (b)(7)eShift Supervisors,(b)(7)eUnit Managers (b)(7)e Assistant Unit
Managers, a Human Resources Manager, and a Business Manager. The total number of non-ICE
staff employed at NGDC is (b)(7)e The medical staff consists of a Health Services Administrator
(HSA), a Medical Director, a Dentist, a Nurse Practitioner, a Mental Health Coordinator, (b)(7)e
Registered Nurses (RN) (b)(7)e Licensed Practical Nurses (LPN), a Dental Assistant, a Medical
Assistant, and a Medical Records Technician. There is currently a vacancy for a contract
Psychiatrist.
In January 2011, ODO conducted a Quality Assurance Review (QAR) at NGDC of 24 NDS. Of
the standards reviewed, 18 were in full compliance. The remaining six standards accounted for
nine deficiencies. Use of the NDS during the January 2011 QAR was in error.
In July 2011, ERO Detention Standards Compliance Unit contractor, MGT of America, Inc.,
conducted an annual review of the PBNDS at NGDC. The facility received an overall rating of
“Meets Standards” and was found compliant with all 39 standards reviewed.

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During this CI, ODO reviewed 16 PBNDS. Thirteen standards were determined to be fully
compliant. Three deficiencies were identified in the following three standards: Detainee
Handbook (1 deficiency), Food Service (1), and Staff-Detainee Communication (1). None of the
deficiencies identified during this CI were repeated deficiencies from the 2011 QAR.
This report details all deficiencies and refers to the specific, relevant sections of the PBNDS.
ERO will be provided a copy of this report to assist in developing corrective actions to resolve
the three identified deficiencies. These deficiencies were discussed with NGDC personnel onsite during the inspection, as well as during the closeout briefing conducted on May 10, 2012.
Overall, ODO found NGDC to be well-managed and in compliance with the standards inspected.
ODO attributes the low number of deficiencies encountered during this inspection to the two
inspections conducted during the18 months preceding this CI, and consistent monitoring of
detention conditions by the ICE employees located at the facility. The three identified
deficiencies included an omission from the detainee handbook regarding procedures for
requesting interpretive services, a lack of special menu items for each of the ten recognized
federal holidays, and failure to use a Telephone Serviceability Worksheet to document weekly
testing on telephones designated for detainee use.
During this CI, ODO observed the admission and release processing area at NGDC. All
detainees are booked and properly searched for contraband and other prohibited items. Personal
belongings are searched, inventoried, and documented as required. All detainees undergo
medical screenings. Detainees are provided appropriate clothing and bedding based on current
climatic conditions. Personal hygiene supplies are gender-specific and are replenished as needed
without charge to detainees.
NGDC classification policy is comprehensive and adequately addresses the PBNDS requirement
for an objective and uniformly applied classification process. All detainees received at NGDC
are classified by ICE at the FOD/Atlanta prior to arrival at NGDC. NGDC staff reviews and
abides by the classification determination made by ICE. Facility case managers complete an
internal classification form, orientation checklist, and sexual abuse screening tool for each
arriving detainee. ODO verified ten of ten detention files reviewed contained required
classification documentation. A review of the detainee handbook confirmed it included
information on the classification process and appeal procedures.
The NGDC disciplinary system includes progressive levels of review and appeal procedures.
Prohibited acts are divided into four severity categories: Greatest, High, High-Moderate, and
Low-Moderate. ODO reviewed three randomly-selected disciplinary packets, dated between
July 19, 2011, and April 6, 2012, and verified all incidents were investigated by a supervisor
within 24 hours. The Unit Manager chairs the Unit Disciplinary Committee (UDC), and the
Chief of Security chairs the Institution Disciplinary Panel (IDP). All IDP hearings are conducted
on the first business day after receipt of the UDC referral. ODO verified sanctions are imposed
in accordance with established guidelines.
NGDC has processes and procedures in place to ensure detainees have the opportunity to file
informal, formal, and emergency grievances, and to appeal the decisions. Grievance forms are
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readily available in the housing units. The Chief of Operations is the designated Grievance
Coordinator and is responsible for ensuring grievance activity is reported to NGDC executive
staff. Grievance mailboxes are available in each housing unit, and detainees are instructed to
contact their case managers if they require assistance completing grievance forms. ODO
confirmed staff receives annual training on handling of grievances and procedures for forwarding
allegations of staff misconduct through the chain of command. A review of the NGDC
grievance log listed ten grievances filed since June 1, 2011, in the following categories: NGDC
staff behavior (60%), sanitation (10%), mail (10%), and other (10%). Each grievance was
responded to by the NGDC Grievance Officer within 15 calendar days, in accordance with the
standards. Emergency grievances were resolved within 24 hours of receipt, also in accordance
with the standards.
ODO found the food service area well-organized and clean. The food service operation at
NGDC was confirmed to be in compliance with State regulations during the most recent annual
inspection conducted by the Georgia Department of Community Health on February 24, 2012.
NGDC management provided documentation confirming internal sanitation inspections are
conducted daily, weekly, and monthly by NGDC food service and safety staff. Cleaning
schedules are posted in all areas of the food service department. ODO verified pest control
inspections and treatment are conducted monthly by an outside contractor. Walk-in freezers and
coolers are maintained at proper temperatures. NGDC rotates stock using the first-in, first-out
method. NGDC has a satellite system of meal service; meals are prepared in the central kitchen
and delivered on thermal trays to housing areas. ODO verified food temperatures are in
compliance with the PBNDS. The food quality was determined to be acceptable, and portions
were adequate. A five-week cycle is followed for rotation of meals. A registered dietician
completes a nutritional analysis and a statement of nutritional adequacy for each five-week meal
cycle. NGDC has policies and procedures to ensure special diets are provided to detainees, as
necessary.
ODO confirmed the medical care at NGDC is well-managed. The Medical Director is available
24 hours a day for medical and psychiatric consultations. Staffing is sufficient to meet detainee
health needs. Tuberculosis screening, medications, treatment for special and chronic care needs,
and follow-up care are provided in accordance with the Medical Care PBNDS. Consent is
obtained prior to medical treatment. A physical examination (PE) of each detainee is completed
within the required 14-day timeframe. The facility uses AT&T Language Line interpretation
services for detainees who do not speak English or Spanish. Detainees access healthcare by
placing written medical request forms available in English and Spanish in a secure “Sick Call”
box located in each housing unit. Medical request forms are collected seven days a week and
triaged on a timely basis to determine priority for care. Detainees in the Special Management
Unit are seen daily by medical staff. Pharmacy services are provided by Diamond Pharmacy on
a contractual basis. ODO inspected (b)(7)e ustody, and b)(7)emedical staff records, and confirmed
that all receive cardiopulmonary resuscitation (CPR) and first aid training during orientation and
on an annual basis.
ODO reviewed transfer summaries for 21 detainees transferred from NGDC to other facilities.
Each summary contained relevant medical information regarding tuberculosis screening,
medications, and any required special instructions.
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ODO reviewed NGDC records concerning Suicide Prevention and Intervention, and determined
there were nine suicide watches and no suicides since the previous ODO inspection. Screening
for suicide potential occurs as part of intake screening, and detainees at risk for suicide are
referred to medical staff, housed, and monitored in accordance with the standard. The NGDC
Suicide Prevention training curriculum covers required elements: recognizing signs of suicidal
thinking, facility referral procedures, suicide-prevention techniques, responding to an in-progress
suicide attempt, and identification of suicide risk factors. Inspection of records fo (b)(7)ecustody
and(b)(7)emedical staff confirmed all received training during orientation and on an annual basis.
A random record review of four detainees on suicide watch confirmed all records contained
documentation required by the PBNDS, and suicide management was consistent with NGDC
policy. ODO conducted a review of the logbook used for suicide watch and confirmed entries
were made documenting 15-minute checks as required by the PBNDS.
ODO verified written procedures are in place to temporarily segregate detainees for
administrative and disciplinary reasons. Inspection of the SMU verified the two units used for
ICE detainees are well ventilated, adequately lit, appropriately heated, and maintained in a
sanitary condition. All cells are equipped with beds securely fastened to the floor, toilets, wash
basins, writing tables and chairs, and intercoms for direct communication with the officer in the
SMU control station. There are showers and recreation cages. At the time of the review, there
was a detainee in disciplinary segregation and a detainee in administrative segregation. The
detainee in administrative segregation was pending an investigation for allegedly creating
disturbances in multiple housing units. The detainee in disciplinary segregation was serving a
sanction for threatening staff. Both detainees stated they received regular recreation, showers,
meals, and telephone access, and that NGDC staff were responsive to their needs.
NGDC has a comprehensive use of force policy addressing all requirements of the Use of Force
PBNDS. Confrontation avoidance and use of force as a last resort are features of the NGDC
policy. NGDC conducts an annual policy review to ensure compliance with the PBNDS and to
verify current practices. Review of training records for(b)(7)eofficers confirmed completion of use
of force training prior to assuming duty and annual training thereafter. All NGDC officers are
authorized to carry Oleoresin Capsicum (OC) spray. Current training in OC was documented in
all(b)(7)erecords reviewed. The Special Operation and Response Team (SORT) at NGDC is
comprised of(b)(7)emembers assigned to rotating shifts to ensure availability.
The use of force and medical restraint policies include specific requirements and adequate
controls for use of four point restraints. All NGDC correctional officers attend an initial twohour class covering progressive and medical restraints, and annual refresher training thereafter.
NGDC had not used four point restraints on detainees. There were two calculated use of force
incidents, and one immediate use of force incident at NGDC involving detainees since the
previous ODO inspection. An immediate use of force situation is created when a detainee's
behavior constitutes a serious and immediate threat to self, staff, another detainee, property, or
the security and orderly operation of the facility. In that situation, staff may respond without a
supervisor's direction or presence. A calculated use of force occurs when a detainee is in a
location where there is no immediate threat to the detainee or others. Prior to a calculated use of
force, staff shall take the time to assess the possibility of resolving the situation without resorting
to force. A calculated use of force needs to be authorized in advance by the facility
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administrator. Review of written documentation and video recordings by ODO confirmed full
compliance with the standard in all cases.
NGDC is in compliance with all requirements of the Telephone Access PBNDS. The total
number of telephones for detainee use at NGDC is 38. That is a ratio of one telephone for every
seven detainees. The PBNDS requires one telephone for every 25 detainees. All telephones
were confirmed to be in working order. Separate rooms are available to provide privacy for
detainees placing telephone calls to legal representatives.
All detainees have access to indoor and outdoor recreation areas. NGDC has a law library with
two computers equipped with the most recent version of LexisNexis. Detainees have visitation
privileges and access to religious services. NGDC provides elective classes in English as a
Second Language (ESL), life skills, and anger management. These classes are well-received by
the detainee population, and promote positive interaction between staff and detainees. ODO
cites the availability of these classes as a best practice.

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INSPECTION PROCESS
ODO inspections evaluate the welfare, safety, and living conditions of detainees. ODO primarily
focuses on areas of noncompliance with the ICE NDS or the ICE PBNDS, as applicable. The
PBNDS apply to NGDC. In addition, ODO 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 NGDC 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 NGDC.

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

INSPECTION TEAM MEMBERS

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

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

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

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OPERATIONAL ENVIRONMENT
INTERNAL RELATIONS
ODO interviewed supervisory ICE and NGDC staff, including the NGDC Warden, Assistant
Warden, Chief of Security, the ERO AFOD, and an SDDO. NGDC and ICE staff stated that the
working relationship between the two entities is excellent, and morale is high.
During the CI, ODO confirmed through a review of housing unit visitation logbooks and
interviews with ICE and NGDC staff and detainees, that ICE staff and the Warden conduct
regular and unscheduled visits to the housing units on a daily basis to address detainee concerns
and inquiries. A review of NGDC visitation logs for 2012 indicated the AFOD visited NGDC on
a monthly basis, and the Deputy Field Office Director has visited the facility twice this year.
The Warden stated he would welcome more detainees at NGDC, because the current detainee
population is approximately half of the total housing capacity of 502.
In 2009, NGDC built a courtroom within the facility for the purpose of holding immigration
hearings. The courtroom has Video Teleconferencing (VTC) and all the necessary equipment to
make the courtroom fully functional; however, no immigration hearings have taken place at
NGDC since the courtroom was built. ICE management stated that the FOD/Atlanta and the
Office of Chief Counsel (OCC) remain in the planning phase for VTC operations with the
Executive Office for Immigration Review (EOIR) in Atlanta, Georgia. EOIR is responsible for
conducting immigration court proceedings. Conducting immigration court proceedings at
NGDC would eliminate the need to transport detainees from NGDC to the Immigration Court in
Atlanta, Georgia, and would likely reduce the average length of stay for detainees at NGDC.

DETAINEE RELATIONS
ODO randomly selected 25 detainees (17 males; 8 females) at NGDC to provide their assessment
of the detention conditions at NGDC. The detainees stated they were treated with dignity and
respect. Detainees stated they are able to send and receive mail, use the telephones, access
religious services, engage in recreation, and use the law library. The detainees did not express
any complaints about medical care.
All detainees were dissatisfied with the food served at the facility. The detainees stated that they
were tired of eating beans, which are always on the menu. ODO verified that a five-week cycle
is followed for rotation of meals, and a registered dietician completes a nutritional analysis and a
statement of nutritional adequacy for each five-week cycle. The Warden informed ODO he was
aware of dissatisfaction with the food variety among detainees; therefore, beginning May 18,
2012, a new menu will be implemented. The new menu will include popular items such as
hamburgers, hot dogs, pasta, potatoes, vegetables, and fewer beans.

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ICE PERFORMANCE BASED
NATIONAL DETENTION STANDARDS
ODO reviewed a total of 16 PBNDS and found NGDC fully compliant with the following 13
standards:
Admission and Release
Classification System
Disciplinary System
Funds and Personal Property
Grievance System
Law Libraries and Legal Material
Medical Care
Personal Hygiene
Special Management Units
Suicide Prevention and Intervention
Telephone Access
Transfer of Detainees
Use of Force and Restraints
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 three standards:
Detainee Handbook
Food Service
Staff-Detainee Communication
Findings for these standards are presented in the remainder of this report.

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DETAINEE HANDBOOK (DH)
ODO reviewed the Detainee Handbook standard at NGDC to determine if the facility provides
each detainee with a handbook, written in English and any other languages spoken by a
significant number of detainees housed at the facility, describing the facility’s rules and
sanctions, disciplinary system, mail and visiting procedures, grievance system, services,
programs, and medical care, in accordance with the ICE PBNDS. ODO observed the admissions
process, interviewed NGDC staff and detainees, and reviewed policies, procedures, the detainee
handbook, and detention files.
NGDC local detainee handbooks are available in English and Spanish, and are provided to each
detainee upon admission to the facility. Detainee handbooks are also available in each housing
unit. ODO confirmed that if a detainee speaks a language other than English or Spanish,
interpretation services are provided to explain the detainee handbook, but the procedures for
requesting interpretive services are not contained in the detainee handbook (Deficiency DH-1).
NGDC corrected the deficiency by adding an addendum to undistributed detainee handbooks.
The updates to the detainee handbook were posted in each housing unit for detainees who had
received a handbook that did not contain the addendum.
ODO randomly inspected 30 detention files to determine if detainees had received the handbook.
All files contained documentation signed by the detainee acknowledging receipt of the detainee
handbook.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY DH-1
In accordance with the ICE PBNDS, Detainee Handbook, section (V)(2), the FOD must ensure,
while all applicable topics from the ICE National Detainee Handbook must be addressed, it is
particularly important that each local supplement notify each detainee of procedures for
requesting interpretive services for essential communication.

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FOOD SERVICE (FS)
ODO reviewed the Food Service standard at NGDC to determine if detainees are provided with a
nutritious and balanced diet, in a sanitary manner, in accordance with the ICE PBNDS. ODO
interviewed food service staff, reviewed documentation, inspected food storage areas, and
observed food service operations.
The facility contracts Trinity Services Group (TSG) for management of the food service
operation. The department is staffed by (b)(7)e employees, including the Food Service Manager
(FSM), Assistant FSM, and (b)(7)e supervisors. There are 45 ICE detainees working in the food
service area. TSG personnel and detainee workers were medically cleared to work in the food
service area. Training records confirmed staff and detainees received training in food service
operations.
The food service area is well-organized and clean. The food service operation at NGDC was
confirmed to be in compliance with State regulations during the most recent annual inspection
conducted by the Georgia Department of Community Health on February 24, 2012. NGDC
management provided documentation confirming internal sanitation inspections are conducted
daily, weekly, and monthly by NGDC food service and safety staff. Cleaning schedules are
posted in all areas of the food service department. ODO verified pest control inspections and
treatments are conducted monthly by an outside contractor. Material Safety Data Sheets
(MSDS) and chemical accountability logs comply with policy and the PBNDS. Walk-in freezers
and coolers operate at proper temperatures. NGDC rotates stock using the first-in, first-out
method.
NGDC has a satellite system of meal service. Meals are prepared in the food service area, placed
on thermal trays, and delivered to housing units. ODO verified food temperatures are in
compliance with the PBNDS. A five-week cycle is followed for rotation of meals. A registered
dietician provides a nutritional analysis and a statement of nutritional adequacy for each fiveweek meal cycle. Food quality is acceptable, and portions are adequate. Records of menu
substitutions are documented on logs and reviewed by the FSM.
NGDC has policies and procedures to ensure special diets are provided to detainees for religious
or medical reasons. Review of the common fare menu revealed it has special menus for only
four of ten recognized federal holidays. The common fare menu does not include special menus
for all ten recognized federal holidays (Deficiency FS-1).

STANDARD/ POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY FS-1
In accordance with the ICE PBNDS, Food Service, section (V)(G)(2), the FOD must ensure
Common Fare is intended to accommodate detainees whose religious dietary needs cannot be
met on the mainline. The Common Fare menu is based on a 14-day cycle, with special menus
for the 10 Federal holidays. The menus must be certified as exceeding minimum daily
nutritional requirements and meeting daily allowances (RDAs). Beverages shall be selected
from the regular menu.
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STAFF-DETAINEE COMMUNICATION (SDC)
ODO reviewed the Staff-Detainee Communication standard at NGDC to determine if procedures
are in place to allow formal and informal contact between detainees and key ICE and facility
staff; and if ICE detainees are able to submit written requests to ICE staff and receive responses
in a timely manner, in accordance with the ICE PBNDS. ODO interviewed ICE and NGDC staff
and detainees, and reviewed the ICE detainee request electronic log and NGDC housing unit
logbooks. ODO also reviewed telephone serviceability worksheets, facility liaison visit
checklists, housing unit postings, drop box accessibility, and communication logbooks.
ICE staff is assigned to visit the facility on a weekly basis. The FOD/Atlanta has written policies
and procedures to ensure and document that ICE supervisory and non-supervisory personnel
conduct frequent unannounced and unscheduled visits. ODO verified there is one scheduled and
one unscheduled visit conducted each week. The visits are documented. Schedules for weekly
ICE staff visits are conspicuously posted in English and Spanish in each housing unit. These
visits are documented on a Facility Liaison Visit Checklist.
NGDC has written procedures for detainees to submit written questions, requests, or concerns to
ICE. There are secure boxes located in each housing unit for detainees to submit their ICE request
forms. The secure boxes are only accessible by ICE staff. Detainee requests are logged and
responded to within 72 hours of receipt.
ODO checked all telephones in the housing units and found them to be in working order. NGDC
and ICE staff stated the telephones are tested each week by ERO staff, but a Telephone
Serviceability Worksheet is not being used to document those weekly tests (Deficiency SDC-1).
Documenting the serviceability of all telephones in detainee housing units ensures inoperable
telephones are repaired in a timely manner.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY SDC-1
In accordance with the ICE PBNDS, Staff-Detainee Communication, section (V)(C), the FOD must
ensure that staff shall document each serviceability test on a form that has been provided by DRO
[ERO], and each field office shall maintain those forms, organized by month, for three years. The
Detention Standards Compliance Unit shall conduct random audits of field office compliance.

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