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

June 24–26, 2014
Amended report as of September 8,
2014

This report has been amended due to inaccurate information that appeared on
pages 20 and 23 of this report. The detention status of pregnant female detainees
provided medical care was clarified in the Medical Care standard under footnote
three. More information was added under the Medical Care-Women standard to
address the detention status for a pregnant detainee being held in ICE custody
under footnote seven. No other changes were made to this report.

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COMPLIANCE INSPECTION
NORTHWEST DETENTION CENTER
SEATTLE FIELD OFFICE
TABLE OF CONTENTS
INSPECTION PROCESS
Report Organization .............................................................................................................1
Inspection Team Members ...................................................................................................2
EXECUTIVE SUMMARY ...........................................................................................................3
OPERATIONAL ENVIRONMENT
Detainee Relations ...............................................................................................................9
ICE 2011 PERFORMANCE-BASED NATIONAL DETENTION STANDARDS
Detention Standards Reviewed ..........................................................................................10
Admission and Release .....................................................................................................11
Disciplinary System ...........................................................................................................13
Food Service ......................................................................................................................15
Grievance System ..............................................................................................................17
Medical Care ......................................................................................................................19
Medical Care (Women)......................................................................................................23
Sexual Abuse and Assault Prevention and Intervention ....................................................24
Special Management Unit-Administrative Segregation/ Disciplinary Segregation ..........26
Telephone Access ..............................................................................................................29

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INSPECTION PROCESS
The U.S. Immigration and Customs Enforcement (ICE), Office of Professional
Responsibility (OPR), Office of Detention Oversight (ODO) conducts broad-based compliance
inspections to determine a detention facility’s overall compliance with the applicable ICE
National Detention Standards (NDS) or Performance-Based National Detention
Standards (PBNDS), and ICE policies. ODO bases its compliance inspections around specific
detention standards, also referred to as core standards, which directly affect detainee health,
safety, and well-being. Inspections may also be based on allegations or issues of high priority or
interest to ICE executive management.
Prior to an inspection, ODO reviews information from various sources, including the Joint Intake
Center (JIC), Enforcement and Removal Operations (ERO), detention facility management, and
other program offices within the U.S. Department of Homeland Security (DHS). Immediately
following an inspection, ODO hosts a closeout briefing at which all identified deficiencies are
discussed in person with both facility and ERO field office management. Within days, ODO
provides ERO a preliminary findings report, and later, a final report, to assist in developing
corrective actions to resolve identified deficiencies.

REPORT ORGANIZATION
ODO’s compliance inspection reports provide executive ICE and ERO leadership with an
independent assessment of the overall state of ICE detention facilities. They assist leadership in
ensuring and enhancing the safety, health, and well-being of detainees and allow ICE to make
decisions on the most appropriate actions for individual detention facilities nationwide.
ODO defines a deficiency as a violation of written policy that can be specifically linked to ICE
detention standards, ICE policies, or operational procedures. Deficiencies in this report are
highlighted in bold and coded using unique identifiers. Recommendations for corrective actions
are made where appropriate. The report also highlights ICE’s priority components, when
applicable. Priority components have been identified for the 2008 and 2011 PBNDS; priority
components have not yet been identified for the NDS. Priority components, which replaced the
system of mandatory components, are designed to better reflect detention standards that ICE
considers of critical importance. These components have been selected from across a range of
detention standards based on their importance to factors such as health and safety, facility
security, detainee rights, and quality of life in detention. Deficient priority components will be
footnoted, when applicable. Comments and questions regarding this report should be forwarded
to the Deputy Division Director, OPR ODO.

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INSPECTION TEAM MEMBERS

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

Detention Deportation Officer (Team Lead)
Special Agent
Management and Program Analyst
Contractor
Contractor
Contractor
Contractor

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ODO
ODO
ODO
Creative Corrections
Creative Corrections
Creative Corrections
Creative Corrections

Northwest Detention Center
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EXECUTIVE SUMMARY
ODO conducted a compliance inspection of the Northwest Detention Center (NWDC) in
Tacoma, Washington, from June 24 to 26, 2014. NWDC, which opened in 2004, is owned and
operated by GEO Group, Inc. ERO began housing detainees at NWDC in April 2004 under an
intergovernmental service agreement (IGSA) between ICE and GEO. Male and female detainees
of all security classification levels (Levels I through III) are detained at the facility for periods in
excess of 72 hours. The inspection evaluated NWDC’s compliance with the 2011 PBNDS.
The ERO Field Office
Director (FOD), in Seattle,
Washington, is responsible for
ensuring facility compliance with
the 2011 PBNDS and ICE policies.
(b)(7)e Assistant Field Office Director
(AFOD) (b)(7)eSupervisory Detention
and Deportation Officers,(b)(7)e
Deportation Officers, (b)(7)e
Immigration Enforcement Agents,
and (b)(7)eDetention Service Manager
support ERO operations.

Capacity and Population Statistics

Quantity

Total Bed Capacity

1575

ICE Detainee Bed Capacity

1575

Average Daily Population

1362

Average ICE Detainee Population

1362

Average Length of Stay (Days)

71

Male Detainee Population (as of 06/23/2014)

1276

Female Detainee Population (as of 06/23/2014)

168

The Warden is the highest-ranking official at NWDC and is responsible for oversight of daily
operations.
contract staff members supported NWDC management
(b)(7)e
at the time of inspection. GEO Group Inc. provides food services, and ICE Health Service Corps
(IHSC) provides medical services. NWDC holds accreditation from the National Commission
on Correctional Healthcare (NCCHC).
In January 2012, ODO conducted an inspection of NWDC under the 2008 PBNDS. Of the 15
standards reviewed by ODO, 13 were in full compliance. ODO cited three deficiencies in the
remaining two standards.
During this inspection, ODO reviewed 20 standards and found NWDC compliant with 11
standards. ODO found a total of 20 deficiencies, seven of which relate to priority components, 1
in the remaining nine standards: Admission and Release (3 deficiencies), Disciplinary System (1)
Food Service (3), Grievance System (2), Medical Care (5), Medical Care Women (1), Sexual
Abuse and Assault Prevention and Intervention (1), Special Management Units (3), and
Telephone Access (1). ODO made one recommendation in this report.
This report details all deficiencies and refers to specific, relevant sections of the 2011 PBNDS.
ERO will be provided a copy of this report to assist in developing corrective actions to resolve
all identified deficiencies. ODO discussed preliminary deficiencies with ERO and NWDC staff
during the on-site inspection and at a subsequent closeout briefing conducted on June 26, 2014.

1

Deficient priority components were found in the following five standards: Food Service, Grievance System,
Medical Care, Medical Care (Women), and Special Management Units.

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Upon admission at NWDC, detainees are searched, fingerprinted, photographed, screened and
issued bedding, clothing and hygiene items. Strip searches are only conducted when there is
reasonable suspicion. ODO identified a transgender detainee who was strip searched on April 9,
2014, without the presence of medical staff. Detainees receive medical, mental health and sexual
abuse and assault screenings and are issued the appropriate clothing, linens, hygiene items and
handbooks. Women receive four bras and feminine hygiene items. Four showers are available
in the intake area; however, detainees are not offered showers prior to being transferred to their
assigned housing unit. Upon admission, all detainees receive a detainee and facility handbook
and an orientation that covers facility rules, visitation procedures, telephone access and the
Prison Rape Elimination Act (PREA).
According to ERO staff, detainees are transferred for operational purposes, such as addressing
overcrowding, change of court venue, and legal representation. ODO reviewed 15 A-files and
corresponding detention files for detainees processed out of the facility during the inspection.
All files contained transfer notification, checklist, transfer medical summary (USM 553), and
signed forms acknowledging receipt of personal property and funds. Medical files and
medication were transferred with the detainees. Both ERO and NWDC staff stated information
about transfers is not disclosed to detainees until immediately prior to leaving the sending facility
for security reasons.
NWDC has a satellite meal service system. GEO food service staff is supported by(b)(7)edetainees,
who are paid $1 daily. Menus are certified by a registered dietician and average 3,000 calories
per day. Medical and religious diets are available and approved by the dietician. NWDC uses a
42-day menu cycle to provide a variety of food items, exceeding the 2011 PBNDS requirement
for a 37-day menu cycle. During the inspection, preparations were being made for Ramadan.
ODO found boxes in the dry storage area were stacked beyond the 18-inch clearance beneath the
sprinkler deflectors and the three-compartment sink used for washing, rinsing, and sanitizing was
unlabeled.
During inspection of the detainee restrooms, ODO observed trash on the floor, and there was no
trash receptacle, no hand soap in the dispenser, and no paper towels available. In addition, the
paper towel holder was missing the cover and there were no signs reminding detainees to wash
their hands prior to returning to work in the kitchen.
NWDC’s grievance policy addresses all requirements of the 2011 PBNDS, with the exception of
two items: 1) a written policy to ensure all medical grievances are received by the administrative
health authority within 24 hours or the next business day, with a response from medical staff
within five working days; and 2) a special procedure for time sensitive, emergency grievances,
including having a mechanism by which emergency medical grievances are screened as soon as
practicable by appropriate staff.
NWDC has a policy and procedure in place allowing detainees access to courts, counsel, and
comprehensive legal materials. The law library is located in a designated room near the housing
units and provides sufficient space to facilitate legal research and writing. Detainees, including
those in Special Management Units (SMU), are afforded a minimum of five hours per week
during designated library hours, and can request additional time if needed. The library contains a
sufficient number of tables and chairs in a well-lit room, reasonably isolated from noisy areas.
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Ten desktop computers equipped with LexisNexis, a typewriter, and supplies are available to
support legal research and case preparation. Three additional computers are located in a separate
room near the housing units. All computers contained a current version of LexisNexis and wordprocessing software. Detainees have access to paper, writing utensils, and envelopes. Legal
documents are printed through request and the assistance of a staff member.
The medical clinic is staffed 24-hours a day, seven days a week by IHSC. Sanitation of the
NWDC medical clinic was at a high level at the time of the inspection. Detainees in general
population have access to health care via the sick call process. Nurses conduct face-to-face
triage, entering their notes directly in the electronic medical record. Referrals are forwarded to
providers electronically based on urgency of need, and IHSC physician-approved nursing
protocols are followed for non-urgent healthcare needs. Detainees in the Special Management
Units access health care by completing hand-written sick call request forms, available in English
and Spanish, and turning them in to an officer. Sick call requests are collected from the officer
by nurses during daily rounds. Officer involvement in this process violates patient
confidentiality, because medical information is recorded on the forms. Some health appraisals
were not cosigned by the clinical medical authority. One detainee’s mental health referral was
not evaluated within 72 hours; rather, the evaluation was completed in seven days. Further,
review of medical records for female detainees showed none was offered an evaluation and
assessment of the reproductive system at any point during their detention at NWDC, to include a
pelvic and/or breast examination, pap test, baseline mammography or screening for sexually
transmitted diseases.
NWDC has a comprehensive written policy addressing the prevention, reporting, and
investigation of sexual assaults. The policy includes a zero-tolerance statement that any sexual
conduct between detainees, and detainees and staff, volunteers and contract staff, regardless of
consent, is strictly prohibited. Detainees are notified of the SAAPI program via the facility
handbook, a brochure, and an orientation video. Facility staff, volunteers, and contractors
receive training in sexual assault and abuse prevention and intervention, including procedures for
reporting incidents and allegations. NWDC does not have a designated multi-disciplinary team
to respond to sexual assault and abuse incidents. PREA and Department of Homeland Security
Office of Inspector General Hotline posters were not posted in all areas accessible to detainees.
According to NWDC’s SAAPI coordinator, 26 incidents of reported sexual abuse/assault were
reported since June 2013. None involved staff-on-detainee assault. ERO staff produced
Significant Incident Reports (SIR) for all 26 incidents; however, only six cases appeared in the
OPR Joint Integrity Case Management System (JICMS). ERO staff was of the understanding
that submission of a SIR automatically creates an entry of reportable SAAPI allegations into the
JIC.
According to IHSC staff at NWDC, 15 detainees were on suicide watch in the 12 months
preceding the inspection. A detainee attempted to hang himself on March 24, 2014, and was
hospitalized as a result. Review of suicide watch documentation for five randomly- selected
detainees confirmed 15-minute checks were documented by officers, clinical staff recorded
monitoring checks at least every eight hours, and mental health professionals conducted daily
evaluations. Change of status from constant to 15-minute monitoring, and authorization of
discontinuation of suicide watch status was made by mental health professionals only, following
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suicide risk assessment. Review of the training records of all medical staff and(b)(7)erandomlyselected correctional staff confirmed training in suicide prevention and intervention is completed
upon hire and annually thereafter. The training curriculum covers all topics required by the 2011
PBNDS.
ERO has permanently-assigned ERO staff on site at NWDC; and detainees have frequent
informal contact with ERO staff. ERO staff conducts regularly scheduled and unannounced
visits to the housing units weekly. Written schedules are posted within detainee living areas and
in other areas accessible to detainees. Detainees may submit ICE-related written questions,
requests, and concerns to ERO staff, and there is written procedure regarding the routing of
detainee requests to appropriate ICE officials.
NWDC maintains a tracking log for documenting disciplinary incidents and outcomes. Review
of the log found 202 disciplinary actions since January 1, 2014. ODO’s review of
documentation in 25 randomly-selected disciplinary cases confirmed investigations were
completed within the required 24 hours. In 25 of the total 202 disciplinary cases, detainees were
released from the facility prior to hearings. Of the remaining cases, the Unit Disciplinary
Committee (UDC) adjudicated 51, and 126 cases were adjudicated by the Institution Disciplinary
Panel (IDP). One hundred and eleven of the 126 cases adjudicated by the IDP were not
processed through the UDC.
NWDC’s H-2 unit is the designated SMU for male detainees assigned to administrative and
disciplinary segregation, with separation afforded by cell assignment. Documentation reflects
there were 776 assignments to segregation in the past year: 515 to administrative segregation
and 261 to disciplinary segregation.
Eleven male detainees were on administrative segregation during the inspection: three for
protective custody, six for security reasons, and two pending disciplinary hearings. One of the
detainees on protective custody was assigned to this status upon request on June 27, 2013; the
other two were placed on protective custody within the 30 days preceding the inspection. Of the
six detainees assigned to administrative segregation for security reasons, five were placed on this
status within the 30 days preceding the inspection, and the sixth on June 19, 2013.
Five detainees were serving disciplinary segregation sanctions during the inspection: three were
sanctioned with 30 days for fighting, one was serving 30 days for threatening staff, and one was
serving 20 days, also for threatening staff. One of the two detainees segregated pending a
disciplinary hearing was found not guilty of assault and was returned to general population
during the inspection. The second detainee pending a disciplinary hearing was charged with
damaging his walker. No documentation existed to support that the alleged action posed a threat
to the safety of staff, detainees, or other property, or to support that segregation of the detainee
was necessary to prevent further violation of rules or to protect the security and orderly operation
of the facility. Documentation showed all 11 detainees in segregation received required status
reviews and services mandated by the standard and facility policy.
ODO reviewed documentation for 50 randomly-selected detainees assigned to administrative
segregation in the 12 preceding months. All documentation confirmed segregation orders were
completed and provided to the detainees; however, review of the orders found 12 did not detail
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the justification for segregation. Further, NWDC’s policy mandates placement of transgender
detainees in segregation, with no requirement for exploration of other housing options.
ODO verified detainees have reasonable and equitable access to telephones at NWDC. ODO
confirmed the listings for pro bono services, DHS Office of Inspector General, consulates, and
embassies were located in each housing unit. The facility also provides a TTY if needed.
NWDC staff conducts daily telephone inspections, and ERO staff inspects telephones weekly.
ODO verified serviceability checks by reviewing facility and ERO logbooks, and serviceability
worksheets.
Notifications that calls are subject to monitoring were posted near the telephones, and a recorded
message on each telephone indicates the same. The detainee handbook informs how to request
an unmonitored call to legal services, however, there is no notice placed at each monitored
telephone noting the procedure for obtaining an unmonitored call to a court, a legal
representative or for purposes of obtaining legal representation.
NWDC has a comprehensive written policy governing the use of force. Twenty-six use-of-force
incidents occurred at NWDC in the 12 months preceding the inspection, including 11 calculated
and 15 immediate. Confrontation avoidance is emphasized in policy and in the training
curriculum. Any calculated use of force or restraints or use of chemical agents requires advance
approval by NWDC administration, medical staff, and ERO staff assigned to the facility.
Officers are trained in the use-of-force team technique during pre-service and annual training, as
verified by a review of(b)(7)erandomly-selected training files. The facility’s Correctional
Emergency Response Team is comprised of(b)(7)especially trained officers. Two hand-held video
cameras are available for recording calculated use-of-force incidents. Any video recorded by
stationary security cameras positioned throughout the facility is secured and reviewed following
a use-of-force incident. Written and video documentation confirmed detainees were medically
examined after the incidents, ERO was notified, and NWDC’s After-Action Review Board
conducted analyses of the incidents.

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OPERATIONAL ENVIRONMENT
DETAINEE RELATIONS
ODO interviewed 40 randomly-selected ICE detainees (eight Level I males; six Level II males;
16 Level III males; and five Level I and five Level II females) to assess the conditions of
confinement at NWDC. All detainees stated they never received any verbal, physical, or sexual
abuse at the facility.
Admission: Detainees stated they received the ICE National Detainee Handbook and a facilityspecific handbook in either English or Spanish upon arrival. They confirmed the initial provision
and replenishment of personal hygiene items at no cost. Thirteen detainees stated they were strip
searched during intake. ODO reviewed their detention files and found forms validating the need
for strip searches.
Facility services: All detainees confirmed unimpeded access to the law library, the grievance
system, mail services, recreation, telephones, and visitation. Three detainees expressed
dissatisfaction with the quality of food service.
Staff-Detainee Communication: Most detainees knew how to communicate with ICE and were
aware ICE visits the housing units weekly. However, three detainees stated ICE officials do not
announce their presence upon entering the housing units.

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ICE 2011 PERFORMANCE-BASED
NATIONAL DETENTION STANDARDS
ODO reviewed a total of 20 PBNDS and found NWDC fully compliant with the following 11
standards:
1. Custody Classification System
2. Detainee Handbook
3. Detainee Transfer
4. Emergency Plans
5. Funds and Personal Property
6. Law Library and Legal Materials
7. Significant Self Harm and Suicide Prevention and Intervention
8. Staff-Detainee Communication
9. Staff Training
10. Use of Force and Restraints
11. Voluntary Work Program
As these standards were compliant at the time of the review, a synopsis for these standards is not
included in this report.
ODO found deficiencies in the following nine standards.
1.
2.
3.
4.
5.
6.
7.
8.
9.

Admission and Release
Disciplinary System
Food Service
Grievance System
Medical Care
Medical Care (Women)
Sexual Abuse and Assault Prevention and Intervention (SAAPI)
Special Management Units-Administrative Segregation/Disciplinary Segregation
Telephone Access

Findings for these standards are presented in the remainder of this report.

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ADMISSION AND RELEASE (AR)
ODO reviewed the Admission and Release standard at NWDC to determine if procedures are in
place to protect the health, safety, security, and welfare of each person during the admission and
release process, in accordance with the ICE 2011 PBNDS. ODO reviewed policies, procedures,
and detention files, observed the admission process, and interviewed staff and detainees.
Upon admission at NWDC, detainees are searched, fingerprinted, photographed, screened and
issued bedding, clothing and hygiene items. Detainees are pat-searched upon entry; strip
searches are only conducted when there is a reasonable suspicion. They receive medical, mental
health and sexual abuse and assault screenings and are issued the appropriate clothing, linens,
hygiene items and handbooks.
ODO observed the processing of 16 incoming detainees during the inspection. The detainees
were pat-searched only; none were searched with a metal detector (Deficiency AR-1).
According to booking staff, a metal detector is available in the control center and may be
checked out for use during booking, when necessary.
Per facility policy, strip searches are conducted only when there is a reasonable suspicion and
only with the approval of the supervising lieutenant. Strip searches are documented on the Hold
Room/Book-In Log and Record of Strip Search form. ODO identified a transgender detainee
who was strip searched on April 9, 2014, without the presence of medical staff
(Deficiency AR-2). The documented reason for the strip search was a history of violence and
weapons.
Detainees are issued two pairs of pants, two shirts, four pairs of underwear, four pairs of socks,
four t-shirts, one pair of shower sandals, a sweat shirt and sweat pants; a mesh laundry bag; one
towel, two sheets, one pillowcase, and two blankets; a toothbrush, toothpaste, and deodorant; a
drinking cup; and a box with a combination lock for personal property. Women receive four
bras and feminine hygiene items. Four showers are available in the intake area; however,
detainees were not offered showers prior to being transferred to their assigned housing unit
(Deficiency AR-3).
Property accompanying detainees is searched and inventoried. Unauthorized property is stored
in a secure property storage room in the booking area. Cash and personal funds are counted by
two staff members and documented on the GEOtrack Property Receipt form in the detainee’s
presence. After all required information is entered in the GEOtrack system, (b)(7)eofficers and the
detainee sign the form, and the date and time is reflected on the printed document. The officer
deposits envelopes containing the funds and receipt in a secure drop vault.
NWDC’s orientation video is shown continuously in the holding area. The video is also shown
daily in each housing unit during breakfast, as verified by review of documentation in the
lieutenant’s log. NWDC staff conducts a question-and-answer session after the video is played.
The video is available in English and Spanish. ODO found the video and audio were not in sync,
interfering with effective communication of the information being conveyed. Additionally, there
were points where images were distorted, and where the video prematurely advanced to the next
subject. ODO recommends that steps be taken to improve the quality of the video (R-1).
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ODO reviewed 40 randomly-selected detention files over the past six months preceding the
inspection. Required intake documentation was present in all files, including Form I-203A. All
contained signed receipts for funds and property, and Form I-203B. NWDC is within walking
distance of a bus station located less than a mile away. ODO was informed that during inclement
weather, or if there is a public safety concern, ERO staff transport detainees to the bus station.
ERO staff also provides detainees with a listing of local cab companies, if they choose to call a
cab.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY AR-1
In accordance with the ICE 2011 PBNDS, Admission and Release, section (V)(B)(2)(a)(b)&(c),
the FOD must ensure, “All detainees shall be screened upon admission; screening shall
ordinarily include:
a. screening with a metal detector;
b. a thorough pat search; and
c. a search of each detainee’s clothing (and issuance of institutional clothing).”
DEFICIENCY AR-2
In accordance with the ICE 2011 PBNDS, Admission and Release, section (V)(B)(4)(c), the
FOD must ensure, “Staff of the same gender as the detainee shall perform the search, except
when circumstances are such that a delay would mean the likely loss of contraband. Except in
the case of an emergency or exigent circumstance, a staff member may not perform strip
searches of detainees of the opposite gender. When a member of the opposite gender from the
detainee must perform a strip search, a staff member of the same sex as the detainee must be
present. When staff members of the opposite gender conduct a strip search, staff shall document
the reason for the opposite- gender search in any logs used to record searches and in the
detainee’s detention file. Special care should be taken to ensure that transgender detainees are
searched in private. **Whenever possible, medical personnel shall be present to observe the
strip search of a transgender detainee.”
DEFICIENCY AR-3
In accordance with the ICE 2011 PBNDS, Admission and Release, section (V)(B)(2)(d), the
FOD must ensure, “To maintain standards of personal hygiene and to prevent the spread of
communicable diseases and other unhealthy conditions within the housing units, where possible,
the FOD must ensure every detainee shall shower before entering his/her assigned unit. During
the detainee’s shower, an officer of the same gender shall remain in the immediate area as
described above.”

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DISCIPLINARY SYSTEM (DS)
ODO reviewed the Disciplinary System standard at NWDC to determine if sanctions imposed on
detainees who violate facility rules are appropriate, and if the discipline process includes due
process requirements, in accordance with the ICE 2011 PBNDS. ODO toured the facility,
conducted interviews, and reviewed policy, disciplinary records, and the detainee handbook.
NWDC maintains a tracking log for disciplinary incidents and outcomes. According to the log,
202 disciplinary actions occurred since January 1, 2014. Review of documentation in 25
randomly-selected disciplinary cases confirmed investigations were completed within the
required 24 hours. In 25 of the 202 disciplinary cases, the detainees were released from the
facility prior to hearings. Among the remaining cases, 51 were adjudicated by the UDC and 126
cases were adjudicated by the IDP. One hundred and eleven of the 126 cases adjudicated by the
IDP were not processed through the UDC (Deficiency DS-1). According to staff, detainees
charged with offenses classified as “greatest” and “high” bypass the UDC, because the policy
and the standard mandate a hearing by the IDP. NWDC staff informed ODO the detainee is
notified of rights related to the IDP hearing by an officer assigned to the SMU, or by the SMU
lieutenant, who serves as chairperson of the IDP. Though the standard authorizes the UDC to
adjudicate low- and moderate-level infractions only, it also mandates that it perform specified
functions in referring greatest and high level infractions to the IDP. SMU officers are not
designated members of the UDC, who are authorized to perform these functions; furthermore,
performance of the functions by the SMU lieutenant, who will adjudicate the charges as IDP
chair, does not support the distinction between the respective roles of the UDC and IDP.
ODO’s review found disciplinary segregation sanctions were imposed by the IDP in 59 of 126
cases. In 23 of the 59 cases, the detainees were given credit for time served and released to the
general population. None of the disciplinary segregation sanctions were for periods greater than
30 days.
The detainee handbook notifies detainees of the rules of conduct, prohibited acts and sanctions,
disciplinary and appeal procedures, and detainee rights. In addition, ODO observed the rules and
prohibited acts were posted in each housing unit. ODO’s review of the facility’s disciplinary
policy confirmed it covers all elements required by the standard.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY DS-1
In accordance with the ICE 2011 PBNDS, Disciplinary System, section (V)(F), the FOD must
ensure, “The UDC shall:
1. advise the detainee of his/her rights at the hearing;
2. refer to the IDP any incident involving a serious violation associated with an A throughD-range sanction. This includes code violations in the “greatest” and “high” categories
(100s and 200s);
3. serve the detainee with:
a. a copy of the UDC decision which must contain the reason for the disposition and
sanctions imposed; or
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b. written notification of charges and hearing before the IDP; and
4. if the detainee’s case is being referred to the IDP, advise the detainee, in writing, of:
a. The right to call witnesses and present evidence before the IDP, and
b. The right to a staff representative before the IDP.”

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FOOD SERVICE (FS)
ODO reviewed the Food Service standard at NWDC to determine if detainees are provided with
a nutritious and balanced diet, in a sanitary manner, in accordance with the ICE 2011 PBNDS.
ODO reviewed policy and procedures, inspected all areas of the food service operation, observed
meals being prepared and served, and interviewed staff and detainees.
NWDC’s food service operation is operated by GEO staff, including a food service
administrator, a production supervisor, and(b)(7)e cook supervisors. A correctional officer is
assigned to the food service department on each shift to monitor security in the area. (b)(7)e
(b)(7)e detainees support kitchen staff. Detainee workers are paid $1 daily. Documentation shows
all employees and(b)(7)erandomly-selected detainee workers were medically cleared to work in
food service. The detainees’ files also contained documentation of job orientation and training.
Detainee workers are visually inspected prior to the beginning of the shift for hygiene concerns
and signs of health issues. Following inspection, detainee workers change into white kitchen
uniforms. Detainee workers, staff, and visitors wear hairnets and beard guards for facial hair,
and all persons involved in food preparation wear gloves.
NWDC has a satellite system of meal service. Menus are certified by a registered dietician and
average 3,000 calories daily. The facility utilizes a 42-day menu cycle to provide a variety of
food items, exceeding the 2011 PBNDS requirement for a 37-day menu cycle. The dietician also
approves medical and religious diet menus. During the inspection, 168 detainees were receiving
medical diets, and 23 detainees were receiving religious diets. During the inspection,
preparations were being made for the upcoming observance of Ramadan. Detainees receiving
medical and religious diets are issued an identification card indicating the period for which the
special diet is approved. Diet trays are labeled with the detainee’s name and housing unit. The
housing officer checks the identification card and documents issuance of the special diet tray.
Also, facility staff document issuance of regular meal trays, and meal refusal is reported to the
medical unit for tracking and follow up.
ODO observed preparation and service of the noon meal on June 25, 2014. Food service staff
took food temperatures on the serving line in the kitchen and as the meal was served in the
housing units. The temperatures of hot items (burritos, beans, and rice) were 161 to 178 degrees
Fahrenheit on the serving line and the temperature of the coleslaw was 39 degrees Fahrenheit
ODO confirmed the items served were in the portions listed on the menu.
The overall sanitation of the kitchen and storage areas during the inspection was good. ODO
observed “clean as you go” procedures were being followed, with detainees wiping down surface
areas and tables with a sanitizing solution. Documentation reflects the food service administrator
conducts weekly inspections of the food service area. A team of staff members, headed by the
Health Services Administrator, conducts monthly inspections. The Tacoma-Pierce County
Health Department Food and Community Safety Program inspect the NWDC food service
operation annually. The most-recent inspection was on March 28, 2014, with no violations of
health code or other deficiencies cited. Pest control services are provided by a local contractor
on a monthly basis and as needed. The most recent pest control service was on June 9, 2014.
ODO observed no signs of insect or rodent infestation in the food service area.
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Inspection of the dry storage area found boxes were stacked nearly to the ceiling, not allowing an
18-inch clearance beneath the sprinkler deflectors (Deficiency FS-1). Documentation reflects
temperatures for the freezer, cooler, and dishwasher are taken and recorded on each shift. The
three-compartment sink used for manually washing, rinsing, and sanitizing utensils and
equipment was not labeled (Deficiency FS-2).
During inspection of the detainee restrooms, ODO observed trash on the floor, and there was no
trash receptacle, no hand soap in the dispenser, and no paper towels. In addition, the paper towel
holder was missing the cover, and there were no signs reminding detainees to wash their hands
prior to returning to work in the kitchen (Deficiency FS-3). Inspection of the staff restroom
found it clean and properly equipped. Hand-washing reminder signs were posted in the staff
restroom and at hand-washing stations throughout the kitchen. Both the detainee and staff
restrooms had a ready supply of hot and cold water.
During a final tour of the food service area and prior to completion of the inspection, all
identified deficiencies were corrected.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY FS-1
In accordance with ICE 2011 PBNDS, Food Service, section (V)(J)(5)(e), the FOD must ensure,
“The area underneath sprinkler deflectors must have at least an 18 inch clearance.”
DEFICIENCY FS-2
In accordance with ICE 2011 PBNDS, Food Service, section (V)(J)(7)(f)(1), the FOD must
ensure, “A sink with at least three labeled compartments is required for manually washing,
rinsing, and sanitizing utilities and equipment. Each compartment shall have the capacity to
accommodate the items to be cleaned. Each shall be supplied with hot and cold water.”
DEFICIENCY FS-3
In accordance with ICE 2011 PBNDS, Food Service, section (V)(J)(9)(b, c, e, f), the FOD must
ensure, “Adequate and conveniently located toilet facilities shall be provided for all food service
staff and detainee workers.
b. Toilet rooms shall be kept clean and in good repair.
c. Signs shall be prominently displayed.
e. Soap or detergent and paper towels or a hand-drying device providing heated air, shall be
available at all times in each lavatory.
f. Waste receptacles shall be conveniently placed near hand-washing facilities.

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GRIEVANCE SYSTEM (GS)
ODO reviewed the Grievance System standard at NWDC 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, in accordance with the
ICE 2011 PBNDS. ODO interviewed staff and detainees, and reviewed NWDC policies, the
grievance log and detainee files.
NWDC permits detainees to file informal, formal, and emergency grievances, and appeal
grievance decisions. Grievance forms are available by request from a staff member, and are
printed in both English and Spanish. NWDC provides detainees with an opportunity to obtain
assistance from another detainee or facility staff in preparing a grievance.
The NWDC grievance system policy is comprehensive and addresses all requirements of the
2011 PBNDS, with the exception of having a written policy in place to ensure a procedure in
which all medical grievances are received by the administrative health authority within 24 hours
or the next business day, with a response from medical staff within five working days
(Deficiency GS-1). Further, written policy lacks a special procedure for time sensitive,
emergency grievances, including having a mechanism by which emergency medical grievances
are screened as soon as practicable by appropriate staff (Deficiency GS-2). 2
During admission, NWDC management provides each detainee a handbook. The detainee
handbook notes the opportunity to file formal and informal grievances, the procedures for filing
grievances and appeals, and the procedures for resolving grievances and appeals, including the
right to appeal to a higher level if unsatisfied with the resolution of the grievance. The detainee
handbook also provides instructions for filing complaints regarding officer misconduct.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY GS-1
In accordance with the ICE 2011 PBNDS, Grievance System, section (V)(A)(4)&(5), the FOD
must ensure, each facility shall have written policy and procedures for a detainee grievance
system that:
4. “ensure a procedure in which all medical grievances are received by the administrative
health authority within 24 hours or the next business day, with a response from medical
staff within five working days, where practicable;
5. establish a special procedure for time- sensitive, emergency grievances, including having
a mechanism by which emergency medical grievances are screened as soon as
practicable by appropriate personnel.”

2

Priority Component

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DEFICIENCY GS-2
In accordance with the ICE 2011 PBNDS, Grievance System, section (V)(C)(2), the FOD must
ensure, “Each facility shall implement written procedures for identifying and handling a timesensitive emergency grievance that involves an immediate threat to health, safety or welfare.”

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(b)(7)e

For clinical care beyond NWDC’s scope of services, detainees are transported to either Tacoma
General Hospital or St. Joseph’s Hospital. Specialty care for pregnant women 3, as well as for
significant gynecological cases, is provided by Babycatchers and Beyond in Tacoma. The
Tacoma fire department provides emergency transport, with an approximate response time of ten
minutes. ODO determined the written medical emergency plan was complete, calling for the
provision of 24-hour nursing coverage, 24-hour physician and mental health on-call services,
automated external defibrillator (AED) availability, and posting of emergency contacts. First aid
kits were present in each of the housing units, master control, and in the urgent care room of the
clinic, and documentation of monthly inventories by pharmacy technicians was present. AEDs
are located in master control and health services. An RN who serves in the role of health and
safety officer is responsible for monthly AED monitoring, and Northwest Biomedical Services
provides preventive maintenance on an annual basis. An emergency go-bag with a breakaway
lock and inventory is located in the urgent care room. A review of all medical staff and(b)(7)e
custody staff training records confirmed all were current in cardiopulmonary resuscitation/AED,
first aid, and four-minute response training.
ODO reviewed a sampling of 30 detainee medical files and confirmed intake screening is
completed within 12 hours of arrival, with general consent for treatment statements signed and
dated at that time. Specific consent for treatment statements were located in the medical records
of six detainees receiving psychotropic medications. Nurses conduct intake screening in the
clinic, adjacent to the receiving area. Digital radiology is used for tuberculosis screening, with
reports provided by the University of Maryland within four hours. The chest X-rays are
conducted by nurses, all of whom completed an on-site training program in direct digital
radiology by Swissray International, Inc. ODO’s review of the electronic intake screening form
found it inclusive of all components required by the 2011 PBNDS, including a symptom check
for infectious disease, mental health and suicide risk assessment, determination of transgender
status, and medications. Significant medical and mental health concerns were forwarded
electronically to a provider, and according to the acting HSA, she is immediately informed by
email when there is an indication of need or request for mental health services during intake.
Detainees in general population access the health care system by signing up for sick call, which
is held daily in the clinic. Nurses conduct face-to-face triage, entering notes directly in the
electronic medical record. Referrals are forwarded to providers electronically based on urgency
of need, and IHSC physician-approved nursing protocols are followed for non-urgent healthcare
needs. Detainees in the Special Management Units access health care by completing handwritten sick call request forms available in English and Spanish, and turning them in to the
officer. Nurses collect the sick call requests from the officer during daily rounds. Officer
involvement in this process violates patient confidentiality because medical information is
recorded on the forms (Deficiency MC-1). In addition, because the potential exists for officers
to lose or destroy sick call requests, detainees’ access to health care may be impeded. The acting
HSA initiated corrective action during the inspection by agreeing to modify the process by
having nurses retrieve sick call requests directly from detainees during rounds.
ODO reviewed a sampling of 30 medical files to confirm the completion of comprehensive
health appraisals. All 30 medical files confirmed completion of health appraisals, including
3

Corrected from original published report. Detained pregnant female detainees are mandatory detention only.

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hands-on physical examination and dental screenings, within 14 days of arrival. Midlevel
providers conduct health appraisals for detainees with chronic medical conditions and RNs
conduct all others. Review of training and competency records confirmed all RNs received
physical examination training by the physician, and annual refresher training and competency
determination by a midlevel provider. Thirteen of the 30 assessments reviewed by ODO were
conducted by an RN, all of which documented review by the clinical medical authority. Nurse
practitioners and physician assistants performed the remaining 17 health appraisals, five of
which were not cosigned by the clinical medical authority (Deficiency MC-2). Over 90 percent
of the records documented the health appraisals were conducted within four days.
Mental health referrals resulting from intake screening, health appraisals, or subsequent
observations by staff are electronically or telephonically forwarded to the psychologist and
mental health social workers. ODO’s review of five mental health referrals found one detainee
was not evaluated within 72 hours; rather, the evaluation was completed in seven days
(Deficiency MC-3). 4 According to the psychologist, the large number of referrals necessitates
that they be prioritized by risk level, resulting in delays in completion of evaluations.
Review of 17 medical files of detainees with chronic medical and mental health conditions
showed all contained treatment plans. Diagnostic testing and monitoring were documented, with
follow-up appointments electronically scheduled as ordered by the provider. ODO’s review
found nine of the 17 records did not include medical/psychiatric alerts, including the records of
detainees who were immune-compromised (Deficiency MC-4). 5
The pharmacy was found well organized and securely controlled, with access limited to
pharmacy staff. The pharmacist participates in quarterly medical department meetings and
conducts annual pharmacy and therapeutics meetings. Only nursing staff administer
medications. ODO’s review of ten medication administration records confirmed all contained
complete entries.
Medical staff uses Interpretalk, a telephone language service, for detainees with limited English
proficiency. The electronic medical record documents the detainee’s language, and
documentation of encounters includes the method of interpretation used. Posters were observed
in the intake areas informing detainees of available interpretation services, and phone lines were
observed in all areas where interviews and assessments are conducted.
The infectious disease management and the quality improvement programs are collateral duties
of the RNs, with three or more nurses assigned to each area. The IHSC infection control plan
addresses all PBNDS-mandated components. An interview with the infection control nurse,
along with a review of electronic logs and reports, confirmed routine reporting of communicable
disease cases to the county health department and IHSC’s Epidemiology Unit. Review of two
varicella (chicken pox) exposures over the past year confirmed evaluation, isolation, and
reporting. Extensive patient information regarding infection prevention and control is included
the detainee handbook.
The electronic medical record implemented by IHSC has been in operation at NWDC since
4
5

Priority Component
Priority Component

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August 2013. Hard copy medical files are securely maintained in the medical records office.
The procedure medical staff follows in providing detainees copies of medical records meets the
requirements of the standard. On transfer of detainees to another detention facility, an electronic
medical transfer summary is completed and sealed in an envelope stamped “Medical
Confidential” and labeled with the detainee’s name and A-number. According to the assistant
HSA, unless a written request is received from the detainee, the entire medical record does not
accompany a detainee transferring to a non-IHSC facility (Deficiency MC-5).

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY MC-1
In accordance with ICE 2011 PBNDS, Medical Care, section (V)(Y)(2), the FOD must ensure,
“All medical providers, as well as detention officers and staff shall protect the privacy of
detainees’ medical information in accordance with established guidelines and applicable laws.”
DEFICIENCY MC-2
In accordance with ICE 2011 PBNDS, Medical Care, section (V)(L), the FOD must ensure, “The
[clinical medical authority] shall be responsible for review of all health appraisals to assess the
priority for treatment.”
DEFICIENCY MC-3
In accordance with ICE 2011 PBNDS, Medical Care, section (V)(N)(4), the FOD must ensure,
“Any detainee referred for mental health treatment shall receive an evaluation by a qualified
licensed mental health professional as medically indicated no later than 72 hours after the
referral, or sooner if necessary.”
DEFICIENCY MC-4
In accordance with ICE 2011 PBNDS, Medical Care, section (V)(M), the FOD must ensure,
“Where a detainee has a serious medical or mental health condition or otherwise requires special
or close medical care, medical staff complete a Medical/Psychiatric Alert form (IHSC-834) or
equivalent, and file the form in the detainee’s medical record.”
DEFICIENCY MC-5
In accordance with ICE 2011 PBNDS, Medical Care, section (V)(Y)(4)(c)(2), the FOD must
ensure, “When a detainee is transferred to an IGSA detention facility, the sending facility shall
ensure that the Transfer Summary will accompany the detainee. A copy of the full medical
record must accompany each detainee during transfer unless extenuating circumstances make
this impossible, in which case the full medical record will follow as soon as practicable.”

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

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

SEXUAL ABUSE AND ASSAULT PREVENTION AND INTERVENTION
(SAAPI)
ODO reviewed the Sexual Abuse and Assault Prevention and Intervention standard at NWDC to
determine if facilities act to prevent sexual abuse and assaults on detainees, provide prompt and
effective intervention and treatment for victims of sexual abuse and assault, and control,
discipline, and prosecute the perpetrators, in accordance with ICE 2011 PBNDS. ODO
interviewed staff and detainees, inspected informational postings throughout the facility, and
reviewed policy and procedures, the detainee handbook, documentation of reported sexual abuse
incidents, and the SAAPI training curriculum and staff training records.
NWDC has a comprehensive written policy addressing the prevention, reporting, and
investigation of sexual assaults. The policy includes a zero tolerance statement that any sexual
conduct between detainees, and detainees and staff, volunteers and contract staff, regardless of
consent, is strictly prohibited. The facility’s training lieutenant is the SAAPI Coordinator.
NWDC does not have a designated multi-disciplinary team to respond to sexual assault and
abuse incidents (Deficiency SAAPI-1).
Facility staff fulfills SAAPI training requirements during pre-service and annual training, as
verified by review of(b)(7)erandomly-selected training records. ODO reviewed the training
curriculum and confirmed it is comprehensive and inclusive of all required elements. ODO
observed a SAAPI class in process during the inspection. Staff interviews supported they are
knowledgeable with respect to the SAAPI program and how to handle incidents involving sexual
abuse or assault.
The intake process includes screening by booking officers and by medical staff for sexual abuse
victimization history and risk, and predatory history to identify potential sexual aggressors.
Detainees are referred to mental health staff for follow up when information is obtained
reflecting victimization or predatory risk. A copy of the referral is forwarded to the SAAPI
Coordinator.
Detainees are notified of the SAAPI program by way of the detainee handbook and a separate
brochure available in English and Spanish. The facility orientation video, also available in both
English and Spanish, includes information regarding the SAAPI program. ODO observed
SAAPI posters in the booking area, medical department, and housing units. The postings include
toll-free telephone numbers for reporting incidents, including the Department of Homeland
Security, Office of Inspector General hotline.
The SAAPI coordinator informed ODO there were 26 incidents of reported sexual abuse/assault
since June 2013. None involved staff-on-detainee assault. ODO’s review of documentation
confirmed the incidents were handled in accordance with the facility policy and the standard,
including reporting the incidents to ERO. ERO staff produced documentation confirming
Significant Incident Reports (SIR) were filed for all 26 incidents; however, only six cases were
entered in the OPR Joint Integrity Case Management System (JICMS) as of the inspection. ERO
staff was of the understanding that submission of a SIR automatically creates an entry of
reportable SAAPI allegations into the JICMS and allegations of incidents that occurred in the
past do not require a SIR.
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STANDARD/POLICY REQUIREMENT FOR DEFICIENT FINDINGS
DEFICIENCY SAAPI-1
In accordance with ICE 2011 PBNDS Sexual Abuse Assault Prevention and Intervention, section
(V)(H), the FOD must ensure, “Facilities should use a coordinated, multidisciplinary team
approach to responding to sexual abuse, such as a sexual assault response team (SART), which
in accordance with community practices, includes a medical practitioner, a mental health
practitioner, a security staff member and an investigator from the assigned investigative entity, as
well as representatives from outside entities that provide relevant services and expertise.”

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SPECIAL MANAGEMENT UNIT (SMU)
ODO reviewed the Special Management Unit (SMU) standard at NWDC to determine if the
facility has procedures in place to temporarily segregate detainees for disciplinary and
administrative reasons, in accordance with the ICE 2011 PBNDS. ODO toured the SMU,
interviewed staff, and reviewed policies, log books and available SMU documentation.
NWDC’s H-2 unit is the designated SMU for male detainees assigned to administrative and
disciplinary segregation, with separation afforded by cell assignment. The unit has two levels
with ten double-occupancy cells on each level. The beds are affixed to the floor, and the toilet,
sink, desk, and stool are affixed to the cell walls. There are two showers on each level and an
outdoor recreation area with two enclosures on the first level. The SMU for females consists of
four designated cells on the lower level of housing unit D-1, which is the female general
population unit. Each cell has a bunk, toilet, sink, desk and stool secured to the walls. There is a
secure shower and an outdoor recreation enclosure. There are also four single cells in the
medical unit designated as special housing for detainees requiring medical monitoring. ODO’s
inspection verified the segregation areas were well lit, maintained in good sanitary condition and
properly ventilated.
Per the policy and in accordance with the 2011 PBNDS, disciplinary segregation is a sanction
imposed through the disciplinary process, and administrative segregation is a non-punitive form
of separation from the general population when the presence of the detainee poses a serious
threat to self, other detainees, staff, property, or the security and orderly operation of the facility.
While in SMU, detainees have access to the same privileges as those in the general population.
Two portable telephones are available for use. There is a separate law library with three
computer stations equipped with LexisNexis, provided upon request. NWDC’s policy allows
visiting privileges consistent with the general population. Detainees are offered recreation daily
and showers three times weekly. As confirmed by the AFOD, ERO receives a copy of
segregation orders and participates in seven day status reviews.
Five detainees were serving disciplinary segregation sanctions during the inspection. Three were
sanctioned with 30 days for fighting, one was serving 30 days for threatening staff, and one was
serving 20 days for threatening staff. There were 11 male detainees on administrative
segregation: three for protective custody, six for security reasons, and two pending disciplinary
hearings. One of the detainees on protective custody was assigned to this status on June 27,
2013, upon his request; the other two were placed on protective custody within the past 30 days.
Of the six detainees assigned to administrative segregation for security reasons, five were placed
on this status within the past 30 days, and the sixth on June 19, 2013, having been determined a
security risk due to gang affiliation and inability to cohabitate with other detainees. One of the
two detainees segregated pending a disciplinary hearing was found not guilty of assault and was
returned to general population during the inspection. The second detainee pending a disciplinary
hearing was charged with damaging his walker. No documentation existed to support the
allegation that damaging his walker posed a threat to the safety of staff, detainees, or other
property, or to support that segregation of the detainee was necessary to prevent further violation

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of rules or to protect the security and orderly operation of the facility (Deficiency SMU-1). 8
ODO’s review of documentation confirmed all 11 detainees currently in segregation received
required status reviews and services mandated by the standard and facility policy.
Documentation reflects there were 776 assignments to segregation in the past year: 515 to
administrative segregation and 261 to disciplinary segregation. ODO’s review of 15 randomly
selected disciplinary segregation cases confirmed the sanctions were imposed by the Institution
Disciplinary Panel and the terms did not exceed 30 days per infraction. ODO’s review of
documentation for 50 randomly-selected detainees assigned to administrative segregation in the
past year confirmed segregation orders were completed and provided to the detainees; however,
review of the orders found 12 of them did not detail the justification for segregation
(Deficiency SMU-2). 9 In seven of the 12 cases, the orders documented the detainees were
assigned to administrative segregation for security reasons, with no explanation of what the
reasons were or the specific threat the detainees’ continued presence in general population posed.
The remaining five orders documented the detainees were assigned for protective custody, but
did not specify why segregation was necessary to assure the detainees’ safety. ODO confirmed
72-hour, seven day, and 30-day status reviews were conducted in accordance with the standard in
all cases reviewed.
NWDC’s policy mandates placement of transgender detainees in segregation, with no
requirement for exploration of other housing options. ODO identified a transgender detainee
who, pursuant to the policy, was placed in administrative segregation upon admission in April
2014. The segregation order documents the detainee, “Is a security risk to him/herself or the
security of the facility,” and, “The detainee claims to be transgender” (Deficiency SMU-3). 10
The detainee was transferred from NWDC within five days.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY SMU-1
In accordance with the ICE 2011 PBNDS, Special Management Units, section (V)(A)(1)(a), the
FOD must ensure, “A detainee may be placed in administrative segregation when the detainee’s
continued presence in the general population poses a threat to life, property, self, staff, or other
detainees; for the secure and orderly operation of the facility; for medical reasons; or under other
circumstances as set forth below. Some examples of incidents warranting a detainee’s
assignment to administrative segregation include, but are not limited to, the following.
a. A detainee is awaiting an investigation or a hearing for a violation of facility rules. Predisciplinary hearing detention shall be ordered only as necessary to prevent further
violation of those rules or to protect the security and orderly operation of the facility.”
DEFICIENCY SMU-2
In accordance with the ICE 2011 PBNDS, Special Management Units, section (V)(A)(2)(b), the
FOD must ensure, “Prior to a detainee’s actual placement in administrative segregation, the
8

Priority Component
Priority Component
10
Priority Component
9

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facility administrator or designee shall complete the administrative segregation order (Form I885 or equivalent), detailing the reasons for placing a detainee in administrative segregation.”
DEFICIENCY SMU-3
In accordance with the ICE 2011 PBNDS, Special Management Units, section (V)(A)(1)(c)(9),
the FOD must ensure, “Use of administrative segregation to protect vulnerable populations shall
be restricted to those instances where reasonable efforts have been made to provide appropriate
housing and shall be made for the least amount of time practicable, and when no other viable
housing options exist, and as a last resort. Detainees who have been placed in administrative
segregation for protective custody shall have access to programs, services, visitation, counsel and
other services available to the general population to the maximum extent possible.”

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TELEPHONE ACCESS (TA)
ODO reviewed the Telephone Access standard at NWDC to determine if the facility provides
detainees with reasonable and equitable access to telephones to maintain ties with family and
others in the community, in accordance with the 2011 PBNDS. ODO interviewed facility staff
and detainees; reviewed policy, procedures, and the detainee handbook; and conducted
functionality tests on the telephones located in detainee housing units.
Detainees have reasonable and equitable access to telephones at NWDC. The telephone
availability ratio for each housing unit is approximately ten detainees per telephone. The listings
for pro bono services, DHS Office of Inspector General, consulates, and embassies are located in
each housing unit. All calls are limited to 20 minutes. NWDC provides a TTY if needed.
NWDC staff inspects telephones daily and ERO staff inspects telephones weekly. ERO
performs serviceability checks and documents the results on worksheets. ODO conducted
operation checks of telephones in detainee housing units and found them to be in good working
order.
Notifications of monitored calls are posted near the telephones, and a recorded message on each
telephone indicates the same. The facility handbook informs detainees of the availability of
unmonitored calls to legal service providers; however, there are no notices posted next to the
telephones in each housing unit informing detainees of the procedure for obtaining unmonitored
calls (Deficiency TA-1). Detainees may request to make legal calls in an area that provides
privacy by submitting a request form.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY TA-1
In accordance with the ICE 2011 PBNDS, Telephone Access, section (V)(B)(3)(b), the FOD
must ensure, “at each monitored telephone, place a notice that states the following:
b. the procedure for obtaining an unmonitored call to a court, a legal representative or for

the purposes of obtaining legal representation.”

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