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
Seattle Field Office
Northwest Detention Center
Tacoma, Washington

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
NORTHWEST DETENTION CENTER
SEATTLE 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 .......................................................................... 10
Disciplinary System........................................................................................... 11
Use of Force and Restraints ............................................................................... 12

EXECUTIVE SUMMARY
The Office of Professional Responsibility (OPR), Office of Detention Oversight (ODO)
conducted a Compliance Inspection (CI) of the Northwest Detention Center (NWDC) in
Tacoma, Washington, from January 10 – 12, 2012. NWDC, which opened on April 23, 1994, is
a Contract Detention Facility (CDF). In November 2005, the GEO Group, Inc. (GEO) acquired
NWDC. The facility is currently under contract with U.S. Immigration and Customs
Enforcement (ICE), Office of Enforcement and Removal Operations (ERO) to house all security
classification levels of adult male and female detainees for periods in excess of 72 hours.
Immigration Health Services Corps (IHSC) provides medical care at NWDC, and the facility
maintains current accreditations with the American Correctional Association (ACA), the Joint
Commission on Accreditation of Healthcare Organizations (JCAHO), and the National
Commission on Correctional Health Care (NCCHC).
NWDC has a total bed capacity of 1,579. At the time of the inspection, NWDC housed a total of
1,358 ICE detainees: 665 Level 1 males, 396 Level 2 males, 118 Level 3 males, 145 Level 1
females, 33 Level 2 females, and 1 Level 3 female. GEO currently has two housing units that
exclusively accommodate female detainees. When necessary, facility managers adjust housing
assignments according to the gender ratio of the detainee population. Under the current contract,
ICE must maintain a minimum population of 1,181 detainees at a rate of $100.65 per day. ICE
pays $62.52 per day for each detainee exceeding 1,181.
ERO Detention Standards Compliance Unit contractor MGT of America, Inc., conducted annual
reviews of the ICE Performance Based National Detention Standards (PBNDS) at NWDC during
2010 and 2011. MGT rated the facility overall as “Meets Standards,” and found NWDC to be in
compliance with all detention standards reviewed. In March 2010, ODO conducted a Quality
Assurance Review (QAR) at NWDC. ODO cited 49 deficiencies in 28 of the 41 PBNDS
inspected. In January 2011, ODO performed a Follow-up Inspection and identified five
recurring deficiencies in four PBNDS.
During this CI, ODO reviewed 15 PBNDS. ODO verified that NWDC was in full compliance
with 13 of the 15 PBNDS reviewed. ODO recorded only three deficiencies in the following two
standards: Disciplinary System (1 deficiency), and Use of Force and Restraints (2). This report
details all deficiencies and refers to specific, relevant sections of the PBNDS. ERO will be
provided a copy of the report to assist in developing corrective actions to resolve the three
identified deficiencies.
The ERO Field Office Director in Seattle, Washington (FOD/Seattle) is responsible for NWDC
compliance with ICE policies and the ICE PBNDS. ERO has a staff of(b)(7)efull-time employees
physically located on-site at the facility. Staff is comprised of an Assistant Field Office Director
(AFOD), (b)(7)e Supervisory Detention and Deportation Officers (SDDO), a Contracting Officer’s
Technical Representative (COTR),(b)(7)e
Detention Services Manager (DSM), (b)(7)e Deportation
Officers (DO), (b)(7)e Enforcement and Removal Assistants (ERA),(b)(7)e student aids, (b)(7)e
Supervisory Immigration Enforcement Agent (SIEA), (b)(7)e Immigration Enforcement Agents
(IEA), and(b)(7)eield Medical Coordinator (FMC).
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GEO employs a total of (b)(7)epersonnel. All GEO positions are currently filled. The Warden is
the highest ranking GEO employee at NWDC and is responsible for oversight of daily
operations. The Warden is assisted by an Administrative Assistant, a Compliance Administrator,
a Human Resources Specialist, and a Business Manager. The Business Manager oversees
accounting, food service, payroll, the physical plant, and the warehouse. An Associate Warden
provides direct oversight of supervisory operations personnel, which includes a full-time
Chaplain, a Chief of Security,(b)(7)e Classification Officers, a Fire and Safety Manager(b)(7)e
Ground
Transportation Manager,(b)(7)e Recreation Officers, and a Training Administrator. The remaining
staff of first and second level supervisory personnel and associated subordinates is comprised of
(b)(7)e Lieutenants,(b)(7)e Detention Officers(b)(7)eGround Transportation Officers, janitors, cooks,
and physical plant workers. GEO personnel are responsible for facility security, maintenance,
and food service. The Keefe Group provides commissary services through a contract with GEO.
Healthcare is provided by IHSC, and augmented by medical personnel contracted by IHSC
through STG, Inc. The clinic is open 24 hours a day, seven days a week, and is administered by
an Acting Health Services Administrator (AHSA). The Clinical Director position is vacant.
Currently, clinical oversight is provided by the Regional Clinical Director, who is based at
NWDC. The clinic has seven examination rooms, a nine-bed Short Stay Unit, four negative
pressure rooms for tuberculosis (TB) isolation, and a two-chair dental suite.
The medical staff includes a contract physician, a part-time contract psychiatrist, an IHSC dentist
and dental hygienist, a contract dental technician, (b)(7)e HSC and (b)(7)econtract physician’s
assistants,(b)(7)eIHSC and(b)(7)econtract nurse practitioner, (b)(7)e IHSC and (b)(7)e contract
registered nurses (RN), (b)(7)e contract licensed practical nurses(b)(7)eontract psychologis (b)(7)e HSC
social worker(b)(7)eIHSC pharmacist,(b)(7)e contract pharmacy technicians,(b)(7)e contract medical
records technicians, and a contract administrative assistant.
Overall, ODO determined NWDC to be a well-managed detention facility. The inspection team
noted no life-safety concerns within the complex, and inspectors observed a better than
satisfactory quality of life among detainees. The three deficiencies discovered during the
inspection related to documentation discrepancies rather than shortcomings with respect to
practices and procedures. ODO found the detainee handbook does not state the facility will not
discriminate against detainees based on sexual preference. ODO also found, following uses of
force on detainees, the After-Action Reviews did not contain close-ups of the detainee’s body
during the medical examination to visually record the presence or absence of injuries to the
detainee.
ODO identified one area of concern. While reviewing the use of force incident packets, ODO
found all five packets reviewed did not contain the required corresponding medical reports.
NWDC informed ODO the corresponding medical reports for each use of force incident are
secured and maintained by IHSC in the medical clinic; IHSC does not distribute copies of the
medical reports. Therefore the NWDC Warden, who is a GEO employee, was not able to review
the corresponding medical reports when reviewing the use of force reports. ODO recommends
the medical reports be included in the incident packet to facilitate easy accessibility of the

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information, and to enable timely and efficient reporting regarding the absence and/or presence
of detainee injuries resulting from a use of force incident.
ICE personnel at NWDC are assigned docket control and detention management responsibilities.
ICE staff visit the detainee housing units weekly, as does the COTR and the DSM. The DSM
keeps track of staff visits to the housing units via spreadsheets, which he uses for accountability
and for statistical reporting to ICE Headquarters. In addition to tracking staff-detainee
communication, the DSM also maintains thorough documentation regarding responses to
detainee requests, food service daily menus and portion sizes, and housing pod visitation logs.
The level of personal involvement displayed by the DSM and the COTR in the daily operations
of the facility, as well as their proactive participation in weekly dialogue with ICE detainees, ICE
staff, and GEO managers, directly correlates to the favorable outcome of this inspection. The
DSM and COTR are exemplary; their work ethic and efficiency could be applied by ERO
nationally as a model for staff-detainee communication and inter-agency cooperation with regard
to detainee custody, care, and the conduct of daily operations.
ODO observed a high level of personal involvement by the ICE and GEO management teams.
Staff interviews and facility visitation logs verified that, at a minimum, the FOD and Deputy
FOD (DFOD) visit the facility once each week, and enter the housing pods once each month.
The FOD/Seattle main office is located off-site from NWDC, but the FOD established a
secondary office at the facility as a base of operations to ensure proper oversight of NWDC.
There is a meeting each Tuesday between ICE and GEO command staff. The meeting minutes
confirm the attendance of the FOD, DFOD, and the Warden. The Warden visits the detainee
living areas bi-weekly and visits the Special Management Units (SMU) more often. The Warden
requires the same level of detainee attention from the Associate Warden, the Training
Coordinator, and the Chief of Security. The Warden requires these key personnel to visit the
SMU daily to ensure segregated detainees are being cared for appropriately. Throughout the
inspection, ODO noted the close cooperation between GEO and ICE officials on detention
issues.
During the intake process, nursing staff perform medical screenings to identify chronic care
issues and medication needs for detainees. Medical personnel conduct chest X-rays to screen for
the presence of TB. ODO reviewed medical records and confirmed that all detainees undergo
intake screenings within the required 12 hours after arrival at the facility. Policy at the NWDC
provides that an RN is authorized to perform a physical exam (PE) on a “Healthy Adult with No
Chronic/Mental Health Issues” within 14 days of arrival. ODO verified that applicable staff
members are trained in this function. All of the 16 chronic care cases reviewed had received a
PE by a provider either the same day or the following day. ODO cites this as a best practice.
Detainees are afforded access to health care services via a medical triage system (sick call)
conducted daily beginning at 6:00 a.m. This face-to-face triage takes place in the clinic. RNs
prioritize complaints using a “Sick Call Triage Form,” which is reviewed by a mid-level
practitioner such as a Nurse Practitioner or a Physician’s Assistant. Detainees housed in the
SMU complete a “Request for Medical” slip printed in English and Spanish. The slips are
picked up each day by nursing staff making daily medical rounds. ODO reviewed logs and
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confirmed the required daily rounds to the SMU by nursing staff. Dental staff performs face-toface triage using the “Dental Triage Assessment Form.” Examination of the Sick Call Log and
medical records verified that detainees are seen at sick call in a timely manner. Follow-up
appointments and referrals were completed as indicated, and documented in a computer
database.
NWDC medical staff uses a Medical/Psychiatric Alert to identify detainees who have special
medical or psychiatric needs at the time of transfer. NWDC exceeds the detention standard by
using a “Medical Hold” to notify ICE staff if a detainee cannot be released or transferred until
medically cleared by medical staff. In addition, medical staff created a red laminated “24 hour
access card,” which is provided to detainees who have a medical condition requiring expedited
access to the clinic. Detainees present their card to the pod officer in the event of a non-routine
medical issue or in the case of a detainee who may require an interpreter. The cards are
numbered and logged to prevent abuse. ODO cites this as a best practice.
During the March 2010 QAR, ODO noted NWDC personnel had performed detainee strip
searches without completing a Record of Search (Form G-1025), as required by the standard. In
the absence of documentation, ODO could not conclude that facility officials clearly established
reasonable suspicion prior to the searches. In the subsequent Follow-up Inspection in January
2011, ODO found that facility officials were not properly completing the Record of Search.
Although the forms were being placed in the detention files, officers were not adequately
articulating reasonable suspicion for conducting strip searches. Additionally, some forms had
not been signed by supervisors indicating concurrence. During this CI, ODO found GEO
officials had revised the Record of Search to include check boxes with language taken directly
from the standard. All forms now clearly articulate the reason for conducting a strip search, and
all forms are signed by a supervisor. Supervisory concurrence is a safeguard that ensures the
preservation of civil rights.
The Grievance System at NWDC provides for both formal and informal grievances. Facility
officials encourage detainees to resolve their grievances at the lowest level possible; however,
detainees are free to bypass the informal grievance process and proceed directly to filing a
formal grievance. The Warden reviews every grievance. The Warden also assigns the
grievances to staff members and personally assesses the resolution of each grievance to ensure
uniformity and fairness.
ODO reviewed grievance logs and documentation of informal, formal, and medical grievances,
and confirmed that from January 1, 2011, to the date of this inspection, NWDC officials had
adjudicated 85 grievances and medical officials had adjudicated 141 grievances. ODO verified
NWDC officials processed all of the grievances in compliance with the PBNDS. ODO inspected
detention files and confirmed they contained copies of grievances and corresponding responses.
The Grievance Officer maintains copies of informal and formal grievances and associated
responses, while medical grievances are maintained by the AHSA. Logs were confirmed to be
current and complete. The facility utilizes a Grievance Committee to address appeals. Detainees
can appeal committee decisions to either the Warden or the AFOD.

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ICE detainees have access to televisions, outdoor recreation, local newspapers, mail, and
commissary purchases. NWDC offers religious services and a voluntary work program.
Detainees may receive public visitation weekly, Thursday through Monday, including holidays,
from 8:00 a.m. to 11:00 a.m. and from 1:00 p.m. to 3:30 p.m.

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INSPECTION PROCESS
ODO inspections evaluate the welfare, safety, and living conditions of detainees. ODO primarily
focuses on areas of noncompliance with the ICE National Detention Standards (NDS) or the ICE
PBNDS, as applicable. The PBNDS applies to NWDC. 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 NWDC 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 Alien
Removal Module (EARM). ODO also gathered facility facts and inspection-related information
from ERO HQ staff to prepare for the site visit at NWDC.

REPORT ORGANIZATION
This report documents inspection results, serves as an official record, and is intended to provide
ICE and detention facility management with a comprehensive evaluation of compliance with
policies and detention standards. It summarizes the 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.
Specific deficiencies and areas of concern are identified 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 PBNDS, ICE policy, or established operational procedure. OPR defines an area of
concern as something that may lead to or risk a violation of the PBNDS, ICE policy, or
established 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

b6, b7c

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

6

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

Northwest Detention Center
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OPERATIONAL ENVIRONMENT
INTERNAL RELATIONS
ODO interviewed ICE and GEO supervisory staff at NWDC, including the ICE AFOD and the
Warden. ODO also interviewed the ICE DSM and COTR. During the interviews, ICE and GEO
employees stated the working relationship between the two agencies is excellent, and morale is
high among ICE and GEO personnel.
The Warden stated NWDC has sufficient personnel to administer services to a detainee
population of 1,181. The AFOD confirmed ICE is budgeted for 1,181 ICE detainees pursuant to
the current contract; however, the facility maintains a population of approximately 1,350
detainees consistently for the past two months. The Warden stated the additional detainee
population has been accommodated by scheduling overtime hours for assigned personnel. The
AFOD has not experienced any staffing issues during this period of increased detainee
population, and staff members are not receiving any complaints from detainees regarding the
responsiveness of ICE employees. The unusually large detainee population has not affected
morale among NWDC staff or ICE employees.
The average length of stay for a detainee at NWDC is 37 days. Both the AFOD and the Warden
agreed the average could be reduced if the Executive Office for Immigration Review (EOIR)
hired a third Immigration Judge to fill a current vacancy. In addition, both managers stated
independently that reinstituting stipulated removals would significantly reduce the length of time
detainees remain in custody. Stipulated removals are a form of administrative removal,
permitted by the Immigration and Nationality Act, which eliminates the need for a hearing
before an Immigration Judge. Aliens amenable to removal from the U.S. who request stipulated
orders of removal waive their rights to a hearing and agree to have a removal order entered
against them. Some Immigration Judges have criticized the procedure as a denial of due process
and have therefore refused to accept Stipulated Removal requests.

DETAINEE RELATIONS
ODO interviewed 66 randomly-selected ICE detainees to assess the overall living and detention
conditions at NWDC. The detainees interviewed represented all three classification levels and
both genders within the general population and the SMU. There were no complaints about
recreation, access to telephones, sending and receiving correspondence, or access to the law
library. All detainees stated they were issued adequate hygiene supplies upon arrival. Most
detainees knew the identity of their DO and how to establish contact. Those who did not were
recent arrivals at the facility and had yet to meet with an officer. Detainees who had met with a
DO stated there are regular visits to the housing pods. Schedules for these visits are posted
conspicuously in the housing areas.
All detainees interviewed stated they had received a detainee handbook and were familiar with
its content. Detainee handbooks are available in English and Spanish. The Warden estimated

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80% of his personnel are bilingual in multiple languages; staff assists in many situations
requiring translations in languages other than Spanish.
Although sick call is explained in detail in the handbook, 13 detainees (19%) complained the
medical process was cumbersome and inefficient. Those detainees stated they perceived the
purpose of sick call was to make an appointment to return for treatment at a later time.
Detainees expected instant treatment for their symptoms upon presenting themselves at sick
call, regardless of whether their health conditions were emergent. None of those who
complained about medical services stated they had not received emergency medical services
when necessary, nor did they know of any instances where immediate or emergency medical
care had been denied to a detainee. All detainees stated medical personnel provided them with
over-the-counter medication during sick call when warranted. The medical SME assigned to
the ODO inspection team was aware of these complaints and reviewed the medical services at
the NWDC noting no deficiencies. The SME examined 30 randomly-selected detainee medical
records and recorded no inconsistencies relative to the quality or continuity of health care at
NWDC.
Nine detainees (13%) complained about food service. Complaints included portions that were
too small; too frequent servings of rice, beans, and pasta; lumpy oatmeal; cold pancakes; and
coffee that tasted as though it had been sitting for an extended period of time. ODO asked
these detainees if they had ever submitted complaints. The detainees confirmed they had not
notified NWDC staff of their concerns with food service. ODO counseled detainees that issues
cannot be addressed if they are not communicated.
The DSM and COTR stated they were aware of detainee complaints regarding a small portion
of a particular breakfast food item. They addressed the issue with the facility’s registered
dietician, who verified the nutritional content of the food portion was within acceptable dietary
requirements. A new menu is being planned to provide detainees with a greater variety of
popular food items such as cheeseburgers and pizza. Food service officials claimed they were
unaware of detainee complaints. Officials agreed to monitor service of oatmeal, pancakes, and
coffee to ensure better quality. With the institution of a new menu, the frequency of beans,
rice, and pasta will diminish. Detainees reacted favorably to this information and were urged to
notify facility officials when they have a complaint. ODO recorded no deficiencies with regard
to food service at NWDC.
Eight detainees (12%) stated they were not satisfied with the availability of Catholic services.
These detainees stated the facility offered two Catholic masses, with attendance restricted to
eight or nine detainees. ODO spoke with the Chaplain and the DSM about this issue. The
Chaplain stated the facility does not have a dedicated Chapel. Religious services are provided
in housing areas that are vacant or unused. In the event there are more participants for a
religious service than can be accommodated at one time, the Chaplain arranges for additional
services to address the overflow. The Chaplain provided ODO with a copy of the religious
services schedule. Currently, Catholic Masses are offered within the facility in three locations
at 6:00 p.m. on Monday evenings. Each location can accommodate 20 to 25 detainees. At the
time of the inspection, one location had been dedicated exclusively for female detainees, one
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was dedicated for male Level 3 and high Level 2 detainees, and the third location was reserved
for low Level 2 and Level 1 male detainees. Separating detainees by gender and classification
level is necessary to ensure safety and security. The Chaplain and the DSM stated they meet
weekly to discuss religious service issues and ensure religious service needs are being met.
Both officials make regular visits to the housing units and speak directly to detainees to get
feedback about the availability of religious services to all faiths represented within the
population.
Two detainees stated they were not receiving special diets in accordance with their religious
beliefs. These detainees stated they are Muslim and had requested a Halal diet. ODO directed
these detainees to page 11 of the detainee handbook, which clearly states the standard fare
meals at NWDC contain no pork products and are therefore Halal. One of the detainees
insisted the meals did not conform to Halal requirements and requested a kosher diet instead.
ODO again directed the detainee to page 11 of the Detainee Handbook, which requires the
requesting detainee to submit a request to the Chaplain stating the reason(s) for a religious diet.
ODO confirmed that food service provides special meals to detainees whose requests are
approved and authorized.
Two detainees requested the facility add exercise equipment. The DSM stated the facility was
in the process of procuring exercise equipment appropriate for a detention setting (i.e. isometric
structures, no free weights, etc.). Delivery and installation of the equipment is to be
determined.

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ICE PERFORMANCE BASED
NATIONAL DETENTION STANDARDS
ODO reviewed a total of 15 PBNDS and found NWDC fully compliant with the following 13
standards:
Correspondence and Other Mail
Detainee Handbook
Food Service
Funds and Personal Property
Grievance System
Law Libraries and Legal Materials
Medical Care
Personal Hygiene
Searches of Detainees
Special Management Units
Staff-Detainee Communication
Telephone Access
Transfer of Detainees
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 two areas:
Disciplinary System
Use of Force and Restraints
ODO findings for these standards are presented in the remainder of this report.

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DISCIPLINARY SYSTEM (DS)
ODO reviewed the Disciplinary System PBNDS at NWDC to determine if sanctions imposed on
detainees who violate facility rules are appropriate, and if the discipline process includes due
process requirements. ODO interviewed detainees and staff, reviewed the disciplinary policy
and detainee handbook, and examined disciplinary files.
The disciplinary system at NWDC includes progressive levels of review and appeal procedures.
Prohibited acts are divided into four categories of offenses: greatest offenses, high offenses, high
moderate offenses, and low moderate offenses. ODO observed an Institutional Disciplinary
Panel (IDP) hearing and confirmed that required investigations of incident reports are part of the
disciplinary process. The detainee’s right to remain silent, right to an interpreter, right to appeal
the IDP determination, and advisement of other relevant detainee rights, including the right to
staff representation, are being observed and respected at NWDC.
The detainee handbook provides notice of a detainee’s right to protection from personal abuse,
corporal punishment, unnecessary or excessive use of force, personal injury, disease, property
damage, harassment; and the right to freedom from discrimination based on race, national origin,
sex, handicap, or political beliefs. The handbook does not provide notice of a detainee’s right to
freedom from discrimination based on sexual orientation (Deficiency DS-1). Making detainees
aware of this fundamental right helps reduce anxiety among the relevant population, and serves
as a deterrent to those who may have the propensity to engage in such discriminatory behavior.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY DS-1
In accordance with the ICE PBNDS, Disciplinary System, section (V)(B), the Detainee
Handbook, or supplement, issued to each detainee upon admittance, shall provide notice of the
facility’s rules of conduct and prohibited acts, the sanctions imposed for violations of the rules,
the disciplinary severity scale, the disciplinary process, and the procedure for appealing
disciplinary findings. Detainees shall have the following rights and shall receive notice of them
in the Handbook: The right of freedom from discrimination based on race, religion, national
origin, sex, sexual orientation, handicap, or political beliefs.

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USE OF FORCE AND RESTRAINTS (UOF&R)
ODO reviewed the Use of Force and Restraints PBNDS at NWDC to determine if necessary use
of force and restraints 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 security equipment, and reviewed local policies, use
of force documentation, and training records.
During the period of January 2011 to January 2012, 16 use of force incidents took place at
NWDC, of which 13 were uncalculated and 3 were calculated. The required after-action reviews
included detailed critiques of the videos and contained required information supporting the
action(s) taken. The audio-visual recordings included an introduction of the medical staff and
each team member, and their respective positions on the team. The audio-visual recordings did
not include close-ups of detainees’ bodies during the medical examinations to visually record the
presence or absence of injuries to the detainee (Deficiency UOF&R-1). Documenting the
presence or absence of injuries to detainees after a use of force incident ensures accuracy and
certainty in each circumstance.
ODO reviewed five of the sixteen facility use of force incident files, and found none of the files
reviewed contained the corresponding medical reports. NWDC informed ODO the
corresponding medical reports for each use of force incident are secured and maintained by
IHSC in the medical clinic. The local IHSC personnel do not distribute copies of the medical
reports associated with use of force incidents, citing privacy issues. Therefore the NWDC
Warden, who is a GEO employee, was not able to review the corresponding medical reports
when reviewing use of force reports (Deficiency UOF&R-2). IHSC Headquarters policy is that
detainee medical records may be included with use of force reports. ODO referred the issue to
IHSC Headquarters and ERO for resolution to ensure the reports are provided in the future.
ODO recommends the medical reports be included in the incident packet to facilitate easy
accessibility of the information, and to enable timely and efficient reporting regarding the
absence and/or presence of detainee injuries resulting from a use of force incident.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY UOF&R-1
In accordance with the ICE PBNDS, Use of Force and Restraints, section (V)(I)(2)(5), the FOD
must ensure calculated use-of-force incidents shall be audiovisually-recorded in the following
order: Take close-ups of the detainee's body during a medical exam, focusing on the
presence/absence of injuries. Staff injuries, if any, are to be described but not shown.
DEFICIENCY UOF&R-2
In accordance with the ICE PBNDS, Use of Force and Restraints, section (V)(O)(1), the FOD
must ensure all facilities shall have an ICE/[ERO]-approved form to document all uses of force.
Within two working days, copies of the report shall be placed in the detainee's A-File and sent to
the Field Office Director. A report is not necessary for the general use of restraints (for example,
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the routine movement or transfer of detainees). In SPCs and CDFs, staff shall prepare a "Use of
Force" form (sample attached) for each incident involving use of force, including chemical
agents, pepper spray, or other intermediate force weapons or application of progressive restraints
(regardless of level of detainee cooperation). The report shall identify the detainee(s), staff, and
others involved and describe the incident. If intermediate force weapons are used (e.g.
collapsible steel baton or 36-inch straight (riot) baton), the location of the strikes must be
reported on the Use of Force form. Each staff member shall complete a memorandum for the
record to be attached to the original Use of Force form. The report, accompanied by the
corresponding medical report(s), must be submitted to the facility administrator by the end of the
shift during which the incident occurred.

Office of Detention Oversight
January 2012
OPR 201200440

13

Northwest Detention Center
ERO Seattle