ICE Detention Standards Compliance Audit - Otero County Processing Center, Chaparral, NM, ICE, 2008

• June 2, 2016 • Locations: United States of America -> New Mexico • Topics: Corrections Audits, Immigration

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0 "Detention and Removal Operations
U.S. Department of Homeland Security
500 12tb Street, SW
Washington, DC 20536

u.s. Immigration

and Customs
Enforcement

MAR 30 2009
MEMORANDUM FOR:

Robert E. Jolicoeur
Field Office Director

FROM:

-SUBJECT:

Otero County Prison Facility Annual Review

The annual review of the Otero County Prison Facility conducted on December 10-12, 2008 in
Chaparral~ New Mexico, has been received. A final rating of Acceptable has been assigned.
The G-324A worksheets provided by the Reviewer-in-Charge (RIC) indicated the facility did
not have any deficient· standards. However, a Plan of Action is required to address the
deficiencies identified in the Key & Lock Control, Contraband, and Detainee Handbook
standards.
The rating was based on the RIC Summary Memorandum and supporting documentation. The
Field Office Director must remedy the deficient standards, and initiate the following actions in
accordance with the Detention Management Control Program (DMCP):
1) The Field Office Director, Detention and Removal OperatioJ!S, shall notify the facility
within five business days of receipt of this memorandum. Notification shall include
copi~s of the Form G-324A Detention Facility Review Form, the G-324A Worksheet,
RIC Summary Memorandum,and a copy of this memorandum.
2) The Field Office Director is responsible for ensuring that the facility responds to all
fmdings and a Plan of Action is submitted to the Review Authority (RA) within 30
days.
3) The RA will advise the Field Office Director once the Plan of Action is approved.
4) Once a Plan of Action is approved, the Field Office Director shall schedule a follow-up
on the above noted deficiencies within 90 days.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)

Otero County Prison Facillllnnual Review
Page 2 of2

•

The Field Office is responsible for assisting the Intergovernmental Service Agreement (lGSA)
facility to respond to the Immigration and Customs Enforcement findings when assistance is
requested. Notification to the facility shall include information that this assistance is available.
Should you or your staff have any questions regarding this matter, please contac J
III, Detention and Deportation Officer at (202) 73• •
cc: Official File
ICE:HQDR

:2-4526:01/0512009
b2hligll

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)

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•

ICE Detention Standards
Compliance Review
Otero County Prison Facility

December 10-12,·2008
REPORT DATE -December 15,2008

rea t iv e

corrections

Contract Nwnber: ODT~6~D~0001
Order Number: HSCEOP~07~F~1016
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Executive Vice President
Creative Corrections
6415 Calder, Suite B
Beaumont, TX 77706

COTR
U.S. Immigration and Customs Enforcement
Detention Standards Compliance Unit
..
500 12th Street, SW
.
Washington, DC 20536

ons

6415 Calder, Suite B • Beaumont, Texas 77706
409.866.9920 • www.correctionalexperts.com
Making a Difference!

December 15, 2008
MEMORANDUM FOR:

Jaines T. Hayes, Jr.,
Director
Office of Detention and Removal Operations

FROM:

SUBJECT:

Otero County Prison F
Annual Detention Review

Creative Corrections conducted an Annual Detention Review (ADR) of the Otero County Prison
Facility (OCPF) in Chaparral, New Mexico, on December 10-12, 2008. As noted on the attached
documents, the team of Subject Matter Experts (SMB) included
SME for Security;
SME for Health Services;
SME for Environmental Health & Safety;
SME for Food Services.
A closeout meeting that included a discussion of all deficiencies, concerns, and
06,b70
•n
recommendations noted during our review was conducted with Warde
Friday, December 12,2008.
Deputy Assistant Director, and
Assistant Field Office Director, ofImmigration and Customs Enforcement attended the closeout.
Type of Review

This review is an Annual Detention Standard Review to determine general compliance with
established ICE National Detention Standards (NDS) for facilities used for over 72 hours.
Review Summary

Both the American Correctional Association and the Correctional Education Association have
accredited the Otero County Prison Facility. Neither the National Com1i1ission on Correctional
Health Care nor the Joint Commission on Accreditation of Healthcare Organizations has
accredited the OCPF.
.
Standards Compliance

The following statistical information provides a swnmary of the results of this review and a
comparison with the results of the previous review.
.

December 18-20. 2007 Review
Compliant
35
1
Deficient
o
At-Risk
Not-Applicable
2

December 10-12. 2008 Review
Compliant
35
Deficient
o
o
At-Ris.k
Not-Applicable .
3

RIC Comments
In July of2008, with the opening of the Otero County Processing Center (OCPC), ICE detainees
were r~moved from.the Otero County Prison Facility. However, at the outset of the tour, it-was
clear that the Otero County Prison Facility did not drop off in its efforts regarding the NOS
compliance. The facility is an exceptionally clean and well-managed facility. During the
review, the staff and detainees were polite and respectful.
The single area of note was the practice used for issuance of razors to detainees. The review
2008, regarding the
team provided a copy ofth~memo, dated J
proper "Issuance and Control of Razors." The Deputy W
agreed to review the
procedures for implementation.
This facility has developed and implemented an exceptional ~ystem for storing, issuing, and
maintaining constant inventories of hazardous and flammable materials. This system includes a
code system to clearly identify each individual material. Each code then correlates to the
Material Safety Data Sheet (MSDS) and the inventory so data for that chemical can be accessed
immediately.
In addition, the Risk Manager,
,has developed and implemented an exceptionally
comprehensive checklist format for weekly and monthly fIre safety inspections.. This system is
most likely responsible for the continuing high-level of safety conditions maintained within all
areas of the facility, but specifically the critical areas of concern, housing units and food services.
The Risk Manager also schedules and monitors fIre drills for the facility that include three drills
per shift monthly, with at least one of those drills including detainees. Staffwas remarkably and
impressively familiar with these emergency procedures.
Recommended Rating and Justification

It is the Reviewer-in-Charge's (RIC) reC()mmendation that the facility receive a rating of
"Acceptable." No Plan of Action is required.
RIC Assurance Statement

All findings of this review have been documented on the Detention Review Worksheet and are
supported by the written doc~entationcontained in the review fIle.

Department Of Homeland Secur-ity
Immigration and Customs Enforcement

Detention Facility Inspection Form
Facilities Used Over 72 hours

A.· Tvpe of Facility Reviewed
·0
ICE Service Processing Center
ICE Contract Detention Facility
181
ICE Intergovernmental Service Agreement

B. Current Inspection
Type of Inspection
Ffeld Office ~ HQ Inspection
Date[s] of Facility Review
December 10-12, 2008

C. PreviouSlMost Recent Facility Review
Date[s] of Last Facility Review
December 18-20,2007
Previous Rating
Superior 0 Good 181 Acceptable 0 Deficient 0 At-Risk

D. Name and Location of

IEstimated
Man-days Per Year:
182,000

]

G. Accreditation Certificates
List all State or National Accreditation[s] received:
American Correctional & Correctional Education Ass.
J J Check box if faci1!ty_ has no accreditation[s]
H. Problems 1 Complaints (Copies must be attached)
The Facility is under Court Order or Class Action Finding
Court Order
'0 Class Action Order
The Facility has Significant Litigation Pending
Maior Litigation
0 Life/Safety Issues
181 Check if None.

o
o

I. Facility_ His~ry
Date Built
,10/9/2003
Date Last Remodeled or Upgraded
10/2005
Date New Construction 1 Bed space Added
10/2005 1 785 beds '
Future Construction Planned
DYes 181 No Date:
Current Bed space
Future Bed space (# New Beds only)
1,335
Number: N/A Date:

r1f£~i!~!:ooiCe (List Office with oversight responsibilities)

J. TotaIFacii!tyPo]!ulation
Total Facility Intake for previous 12 months
10,439
Total ICE Man-days for Previous 12 months
40,392
K. Classification Levet(l~E SPCs and CDFs Only)
L-l
1.-2
L-3
Adult Male
NIA
Adult Female
N/A

L FaCI·Iity Capacit~
Operational
Emel1!ency
:Ilated
1,165 .
Adult Male
1,165
Adult Female
188
188
Facility holds Juveniles Offenders 16 and older as Adults

ltion
M.Average D·IP
al Y ~ua
F. CDFIIGSA Information Only
Contract Number
Date of Contract or IGSA
10-01-2004
51-04-0064
Basic Rates per Man-Day
$60.31
Other Charges: (If None, Indicate N/A)
$15.29 per hour GSA

FO~ OFFICIAL USE

I AduitMale
I Adult Female

ICE
0
0

USMS
619
134

Other

ONLY (LAW ENFORCEMENT SENSITIVE)
Form G-324A SIS (Rev. 7/9107)

Department Of Homeland Security
Immigration and Customs Enforcement

Detention FacilitY Inspection Form
Facilities Used Over 72 hours

Significant Incident Summary Worksheet
For ICE to complete its review of your facility, the following information must be completed prior to the scheduled review dates. The
information on this form should contain data for the past twelve months in the boxes provided. The information on this form is used
in conjunction with the iCE Detention Standards in assessing your Detention Operations against the ne~ds of the ICE and its detained
population: This form should be filled out by the facility prior to the start of any inspection. Failure to complete this section will
result in a delay in processing this report and the possible reduction or removal onCE'detainees at your facility.

Assault:
Offenders on
Offenders!

Physical

'Physical·

Physical

Assault:
Detainee on
. Staff

# Times FourlFive Point
Restraints applied/used

Offender I Detainee Medical
Referrals as a result of

Escapes

Deaths

Medical
Referrals
# Psychiatric Cases referred for
Outside Care

3IBehavior

Bed

o
o.

Any attempted physical contacl ar physical contact that involves two or more offenders
Oral, anal or vaginal penetration or attempted penetration involving at least 2 parties, whether it is consenting or non-consenting
Routine transportation of detainees/offenders is not considered "forced" .
Any incident that involves four or more detainees/offenders, includes gang fights, organized multiple hunger strikes, work stoppages, hostage situations,
major fires, or other large scale incidents.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
.

Form G-324A SIS (Rev. 7/9/07)

Department Of Homeland Security
Immigration alld Customs Enforcement

n .. t-.. ntinn

Detention Facility Inspection Fonn
-Facilities Used Over 72 hours

Standards Kevie'w
5.Not

1.
2.
3. -

4.
S.
6.
7.
8.

Access to Legal Materials
Group Presentations on Legal Rights
Visitation
Access -

9.
10.
11.
12.
13.
14.
15.
16.
17.

' Admission and Release
Classification System
<::orrespondence and Other Mail
Detainee Handbook
Food Service
Funds and Personal Property
Detainee GrievanCe Procedures
Issuance and Exchange of Clothing, Bedding, and Towels
Marriage Requests
Non-Medical Emergency Escorted Trip
Recreation
Religious Practices
Work

18.
19.
20.
21.

Hunger Strikes
Medical Care
Suicide Prevention and Intervention
Advanced Directives and Death

22.
23.

24.
25.
26.
27.
28.
29.
30.
31.
32.
33.
34.
35.
36.
37.
38.

Contraband
Detention Files
Discip,linary Policy
Emergency Plans
Environmental Health and Safety
Hoid Rooms in Detention Facilities
Key and Lock Control
Population Counts
Post Orders
Security Inspections '
Special Management Units (Administrative Segregation)
Special Management Units (DiscipHnary Segregation)
Tool Control
'
Transportation (Land management)
Use of Force
, Staff 1 Detahiee Communi~ation (Added ~ugust 2003)
Detalnee Tr~nsfer (Added September 2004)

All findings (Deficient and At-Risk) require written comment describing the finding and what is necessary to meet compliance.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSInVE) ,
Fonn G~324A SIS (Rev. 7/9/07)

Department Of Homeland Security
Immigration and Customs Enforcement

Detention Facility Inspection Form
Facilities Used Over 72 hours
RIC Review Assurance Statement

By signing below; the Reviewer-In-Charge (RIC) certifies that all fmdings of noncompliance with policy or inadequate controls
contained in the Inspection Report are supported by evidence that is sufficient and reliable. Furthermore, findings of noteworthy
accomplishments are supported by sufficient and reliable evidence. Within the scope of the review, the facility is operating in
. accordance with applicable law and policy, and property and resources are efficiently used and adequately safeguarded, except for the
deficiencies noted in the report.
Reviewer-In-Charge: (print Name)

Name, Title, & Duty Location
SME-Food Sp.rvi/""~Q Creative Corrections
5MB-Health Services, Creative Corrections

Recommended Rating:

_
8ME-Environmental Health and Safety~ Creative
CorrectIons

o Superior
o Good·

IZI Acceptable
D Deficient
OAt-Risk
Comments: ICE detainees were removed from the facility earlier this year. The facility's management team is aware of the various
ICE specific postings which would need to be in place should detainees return to the facility. It was evident that the facility had.
improved in Food Service operations since last year's review.

FOR OFFICIAL .USE ONLY (LAW ENFORCEMENT SENSITIVE)
Form G-324A SIS.(Rev. 7/9/07)

Department Of Homeland Security
Immigration and Customs Enforcement

Detention Facility Inspection Form
Facilities Used Over 72 hours

A. Type of Facility Reviewed
ICE Service Processing Center
ICE Contract Detention Facility
ICE Intergovernmental Service Agreement

Estimated Man-days Per Year:
310,250
G. Accreditation Certificates
List all State or National Accreditation[s] received:
Will file for ACA in November 2008
Check box if facility has no accreditation[s]

B. Current Inspection
Type of Inspection

Field Office

HQ Inspection

Date[s] of Facility Review

H. Problems / Complaints (Copies must be attached)
The Facility is under Court Order or Class Action Finding
Court Order
Class Action Order
The Facility has Significant Litigation Pending
Major Litigation
Life/Safety Issues
Check if None.

September 16-18, 2008 (Initial Review)
C. Previous/Most Recent Facility Review
Date[s] of Last Facility Review

N/A
Previous Rating

Superior

Good

Acceptable

Deficient

At-Risk

D. Name and Location of Facility
Name

Otero County Processing Center
Address (Street and Name)

26 McGregor Range Road
City, State and Zip Code

Chaparral, New Mexico, 88081
County

Otero
Name and Title of Chief Executive Officer (Warden/OIC/Supt.)
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Warden

Telephone # (Include Area Code)

575

I. Facility History
Date Built
Spring 2008
Date Last Remodeled or Upgraded
N/A
Date New Construction / Bed space Added
N/A
Future Construction Planned
Yes
No Date:
Current Bed space
Future Bed space (# New Beds only)
Number:
Date:
1086

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Field Office / Sub-Office (List Office with oversight responsibilities)

El Paso, Texas
Distance from Field Office

J. Total Facility Population
Total Facility Intake for previous 12 months
N/A facility activated this year.
Total ICE Man-days for Previous 12 months
N/A facility activated this year.

23 miles
E. ICE Information
Name of Inspector (Last Name, Title and Duty Station)
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/ Reviewer -in-Charge
Name of Team Member / Title / Duty Location
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/ SME for Security
mber / Title / Duty Location
b6
/ SME for Food Service
ember / Title / Duty Location
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/ SME for Medical
Member / Title / Duty Location
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/ SME for Safety
F. CDF/IGSA Information Only
Contract Number
Date of Contract or IGSA
DROIGSA-08-0019
June 12, 2008
Basic Rates per Man-Day
96.99
Other Charges: (If None, Indicate N/A)
Stationary Guard Service $11.36-$17.04 per hour
Transportation @ .505 per mile

FOR OFFICIAL USE

K. Classification Level (ICE SPCs and CDFs Only)
L-1
L-2
L-3
Adult Male
506
227
173
Adult Female
0
0
0

L. Facility Capacity
Rated
Adult Male
1086
Adult Female
0

Operational
1086
0

Emergency
1086
0

Facility holds Juveniles Offenders 16 and older as Adults

M. Average Daily Population
ICE
Adult Male
826
Adult Female
0

USMS
0
0

Other
0
0

N. Facility Staffing Level

xxxxxxxxxxxxxxxxxxxxxxxxxxxxxx

ort:
b2High

ENT SENSITIVE)
Form G-324A SIS (Rev. 7/9/07)

Department Of Homeland Security
Immigration and Customs Enforcement

Detention Facility Inspection Form
Facilities Used Over 72 hours

Significant Incident Summary Worksheet
For ICE to complete its review of your facility, the following information must be completed prior to the scheduled review dates. The
information on this form should contain data for the past twelve months in the boxes provided. The information on this form is used
in conjunction with the ICE Detention Standards in assessing your Detention Operations against the needs of the ICE and its detained
population. This form should be filled out by the facility prior to the start of any inspection. Failure to complete this section will
result in a delay in processing this report and the possible reduction or removal of ICE’ detainees at your facility.
Incidents

Jan – Mar

Description
Types (Sexual 2 , Physical, etc.)

Assault:
Offenders on
Offenders 1

With Weapon
Without Weapon
Types (Sexual Physical, etc.)

Assault:
Detainee on
Staff

With Weapon
Without Weapon

Number of Forced Moves,
incl. Forced Cell moves 3
Disturbances 4
Number of Times Chemical
Agents Used
Number of Times Special
Reaction Team
Deployed/Used
Number/Reason (M=Medical,
V=Violent Behavior, O=Other)
Type (C=Chair, B=Bed,
BB=Board, O=Other)

# Times Four/Five Point
Restraints applied/used
Offender / Detainee Medical
Referrals as a result of
injuries sustained.

Attempted

Escapes

Actual
Grievances:
# Received
# Resolved in favor of
Offender/Detainee
Reason (V=Violent, I=Illness,
S=Suicide, A=Attempted
Suicide, O=Other)
Number

Deaths

Psychiatric / Medical
Referrals

1
2
3
4

# Medical Cases referred for
Outside Care
# Psychiatric Cases referred for
Outside Care

Apr – Jun

Jul – Sept

Oct – Dec

Physical

227

Any attempted physical contact or physical contact that involves two or more offenders
Oral, anal or vaginal penetration or attempted penetration involving at least 2 parties, whether it is consenting or non-consenting
Routine transportation of detainees/offenders is not considered “forced”
Any incident that involves four or more detainees/offenders, includes gang fights, organized multiple hunger strikes, work stoppages, hostage situations,
major fires, or other large scale incidents.

FOR OFFICIAL USE

xxxxxxxxxxxxxxxxxxxxxxxxxxxxxx

MENT SENSITIVE)
Form G-324A SIS (Rev. 7/9/07)

Department Of Homeland Security
Immigration and Customs Enforcement

Detention Facility Inspection Form
Facilities Used Over 72 hours

DHS/ICE Detention Standards Review Summary Report
1. Acceptable 2. Deficient 3. At Risk
4. Repeat Finding
Legal Access Standards
1.
Access to Legal Materials
2.
Group Presentations on Legal Rights
3.
Visitation
4.
Telephone Access
Detainee Services
5.
Admission and Release
6.
Classification System
7.
Correspondence and Other Mail
8.
Detainee Handbook
9.
Food Service
10.
Funds and Personal Property
11.
Detainee Grievance Procedures
12.
Issuance and Exchange of Clothing, Bedding, and Towels
13.
Marriage Requests
14.
Non-Medical Emergency Escorted Trip
15.
Recreation
16.
Religious Practices
17.
Voluntary Work Program
Health Services
18.
Hunger Strikes
19.
Medical Care
20.
Suicide Prevention and Intervention
21.
Terminal Illness, Advanced Directives and Death
Security and Control
22.
Contraband
23.
Detention Files
24.
Disciplinary Policy
25.
Emergency Plans
26.
Environmental Health and Safety
27.
Hold Rooms in Detention Facilities
28.
Key and Lock Control
29.
Population Counts
30.
Post Orders
31.
Security Inspections
32.
Special Management Units (Administrative Segregation)
33.
Special Management Units (Disciplinary Segregation)
34.
Tool Control
35.
Transportation (Land management)
36.
Use of Force
37.
Staff / Detainee Communication (Added August 2003)
38.
Detainee Transfer (Added September 2004)

5.Not Applicable
1.

All findings (Deficient and At-Risk) require written comment describing the finding and what is necessary to meet compliance.

FOR OFFICIAL USE

xxxxxxxxxxxxxxxxxxxxxxxxxxxxxx

CEMENT SENSITIVE)
Form G-324A SIS (Rev. 7/9/07)

Department Of Homeland Security
Immigration and Customs Enforcement

Detention Facility Inspection Form
Facilities Used Over 72 hours

RIC Review Assurance Statement

By signing below, the Reviewer-In-Charge (RIC) certifies that all findings of noncompliance with policy or inadequate controls
contained in the Inspection Report are supported by evidence that is sufficient and reliable. Furthermore, findings of noteworthy
accomplishments are supported by sufficient and reliable evidence. Within the scope of the review, the facility is operating in
accordance with applicable law and policy, and property and resources are efficiently used and adequately safeguarded, except for the
deficiencies noted in the report.
Reviewer-In-Charge: (Print Name)

Signature

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Title & Duty Location

Date

Reviewer -in-Charge, Creative Corrections

September 18, 2008

Team Members
Print Name, Title, & Duty Location

Print Name, Title, & Duty Location

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SME for Security
Print Name, Title, & Duty Location

b6
SME for Food Service
Print Name, Title, & Duty Location

SME for Medical

Recommended Rating:

SME for Safety

Superior
Good
Acceptable
Deficient
At-Risk

Comments: This is the initial review for Otero County. Data only exists for one quarter.

FOR OFFICIAL USE

xxxxxxxxxxxxxxxxxxxxxxxxxxxxxx

SENSITIVE)
Form G-324A SIS (Rev. 7/9/07)

Department of Homeland Security
Immigration and Customs Enforcement
Office of Detention and Removal

Condition of Confinement Review Worksheet
(This document must be attached to each G-324A Inspection Form)

This Form to be used for Inspections of all Facilities Used Over 72 Hours

ICE Detention Review Worksheet
~

o
o

Local Jail- IGSA
State Facility - IGSA
ICE Contract Detention Facility

Name
Otero
Center
Address (Street and Name)
26·
Road
and Zip Code
New
88081

Date[s] of Review
16-1 2008

. Type of Review
Headquarters

IZI

.
Operational·

DSpecial Assessment

o Other

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
.

G-324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 07109/07

Table of Contents
DETAINEE SERVICES STANDARDS (SECTION I) .....•..................•.............•••••......•..••..............·...........3
ACCESS TO LEGAL MATERIALS .. : ... ; ................................. '" .......................................................... ..
ADMISSION AND RELEASE......................................................................................................... ..
CLASSIFICATION SySTEM ............................................................................................................ ..
CORRESPONDENCE AND OTHER MAIL .. ~ ................. , ......................................................................... ..
DETAINEE HANDBOOK ............................................................................................................... .
FOOD SERVICE ............................................................... " .......................................:............... .
FUNDs AND PERSONAL PROPERTY ........................................................... ~ .................. :....................... ..
DETAINEE GRIEVANCE PROCEDURES ..•. : ........................................................................................ .
GROUP PRESENTATIONS ON LEGAL RIGHTS .......................................................................................... .
ISSUANCE AND EXCHANGE OF CLOTHING, BEDDING, AND TOWELS ...... : .................................................. ,
MARRIAGE REQUESTS .............................................................................................................. ..
NON-MEDICAL ESCORTED TRIPS ........................... , ..................................................................... ..
RECREATION ................................... , ...................................................... , ................................ .
RELIGIOUS PRACTICES .................... :: ...........................................................................................
ACCESS TO TELEPHONES ........................................................................................................... ..
.VISITATION ................................... : .......................................................................................... ..
.VOLUNTARY WORK PROGRAM ..... : ............... : ............................................................ : .................. .
IJEALTH.SERVICES STANDARDS ($ECTION 11). . ~ ...•......•...•••.••..•........................ .......•......•....•........... 34
HUNGER STRiKES .. , .... ; ..................................................... , ................................ , ........................ ..
ACCESS TO MEDICAL CARE .............................................................................................................. .
SUICIDE PREVENTION AND INTERVENTION......................................................................................... ..
TERMINAL ILLNESS, AnvANCED DIRECTIVES AND DEATH............................... ; ............................................ ..
SECURITY AND CONTROL (SECTION Ill) ,'............................... .•....................................... ............ 4S
CONIRABAND ............................................................................................................................... ..
DETENTION FILES ................................................................................................................... .
DISCIPLINARY POLICy ......................................................................................................... ;, ...... ..
E~GENCY PLANS ................................... , ............................................................ : ............... ..
ENVIRONMENTALlIEALTHAND SAFETY ............. : ............................................................................ .
HOLD ROOMS IN DETENTION FACILITIES ........................................................................................... ..
KEy AND LOCK CONTROL............................................................... ; .............................................. .
POPULATION COUNTS: ................................................. ~ ..............................................................
POST ORDERS
..................................... ; ....................
'" .................................................................... .
.
.
SECURITY INSl'ECTIONS ... ~ ............... , ............................................................................................ .
SPECIAL MANAGEMENT UNIT (ADMINISTRATIVE SEGREGATION) ........................................................... .
SPECIAL MANAGEMENT UNIl; (DISCIPLINARY SEGREGATION) ............................................................. ..
TOOL CONTROL .......................................................................... : ........................................... ..
'T.R..ANSPORTATION (LAND) ..................................................................................................... .
USE OF FORCE ........... ; ................................................................. : ........................................... .
STAFFIDETAINEE CO~ICATIONS ........................................................ : .................................... .
DETAINEE TRANSFER STANDARD .................. : ................... ~ ......................... ; .................................. ..

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09107

SECTION I

DETAINEE SERVICES STANDARDS

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324ADetention Inspection Fonn Worksheet for IGSAs - Rev: 07/09/07

AccESS TOLEGAL MAm.;riAts

- , / " , . '.

., ..

f~~~~=~;_~J.~~~~MA~
.
"::'.,'y .: ;'. N. ' . NA,
..' . REMARKs· ."

I</~:";;';"!;~'>;!,;':: ::::·">··,~COMPONENTS<

";;"'.

The facility provides ~ designated law library for detainee 1,lSe.
The law library contains all materials listed in the "Access to Legal
Materials'" Standard, Attachment A The listing ofmaterials is posted in
the law library.
The library contains· a sufficient number of chairs, is well lit, and is
reasonably isolated from noisy areas.
The law library is adequately equipped with typewriters and/or
computers, and has sufficient supplies for daily use by the detainees.
In addition to the physical law hbrary, detainees have access to the Lexus
Nexus electronic law library.
Where provided, the Lexus Nexus library is updated and is current

Outside persons and organizations are permitted to submit published legal
material for inclusion in the legal library. Outside published material is
forwarded and reviewed by ICE prior to inclusion.
There is a designated ICE or facilitY employee who inspects, updates, and
. maintains/replaces legal materials and equipment on a routine basis.
Detainees are offered a minimum 5 hours per week in the law library.
Detainees are not required to forego recreation time in lieu of library
usage. Detainees facing a court deadline are given priority use ofthe law
library.
.
.
Detainees may request materials not currently in the law library. Each
request is reviewed and, where appropriate,. an acquisition request is
'. timely initiated.
Requests for copies of court decisions are
accommodated within 3 - 5 business days.
Detainees are permitted to assist other detainees, voluntarily and free of
charge, in researching and preparing legal documents, consistent with
security.
. Illiterate or non-English-speaking detainees without legal representation
receive access to more than just English-language law books after
indicating their need for help.
Detainees may retain a reasonable amount of personal legal material in
the general population and in the special management unit Stored legal
materials are accessible within 24 hours of a written request.
Detainees housed in Administrative Detention and Disciplinary
Segregation units have the same law library access as the general
population, bariing security concerns. Detainees denied access to legal
materials are documented and reviewed routinely for lifting; of sanctions.
All deniaIs of access to the law h"brary full.y documented.
Facility staff informs ICE Management when a detainee or group of
detainees is denied access to the law library or law materials.

IZI

D
D

Legal materials are maintained
on the computer based
LexisNexis systems.

The law library is well supplied
and equipped with four
computers and a printer.

The LexisNexis system is
updated by ICE officials
quarterly when updates are
available.

The facilitY has assigned Officer
_ t o maintain and inspect
the law library.
.
Detainees submitrequests for
time in the law library.
Detainees are allowed the time
neCessary to complete their legal
work.

Detainees are permitted to assist
other detainees with their legal
work.
Illiterate or non-Englishspeaking detainees.may request
assistance from the staff.

Administrative Detention and
Disciplinary Segregation units
have the same law library access
as general population units,

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A J)etention InspectiOn Form Worksheet for IGSAs - Rev: 07/09/07

:~::/;,>....i

. . . "'AcCJ;SSTO LEGAL MATERIALs:;'?'::,

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COMPONENTS

Y . ··.:·N· NAREMARKS.:,·

Detainees who seek judicial relief on any matter are not subjected to
reprisals, retaliation, or penalties.

IZ/ACCEPTABLE

DEFICIENT

[81

AT-RIsK

There is no evidence of
reprisals, retaliation, or penalties
toward detainees who seek
. judicial relief.

D REPEAT FINDING

REMARKS:

Policy MTC 5.3.2 entitled "Library Ser:vices (Law Library)" dated June 1, 2008, comprehensively addresses acCess to legal materials.
Legal materials are maintained on the computer based LexisNexis systems. The law library is well supplied and equipped with four
computers and a printer. Detainees submit requests for time in the law library. Detainees are allowed the time necessary to complete
their legal work. There is no evidence ofreprjsaIs, retaliation, or penalties towards detainees who seek judicial relief.

{September 18, 2008

AUDITOR'S SIGNATURE {DATE

b6.b7G

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITNE)
G-324A Detention Inspection Form Worksheet for IOSAs - Rev: 07/09107

-:,

,• •~t~&?~T~~~'=E=~=··
'':;:3':'';;''/:",';',' •

COMPONENTS

'Y".-:; ,

In-processing includes an orientation of the faCility. The orientation
includes: Unacceptable activities and behavior, and corresponding
sanctions; How to contact ICE; The availability of pro bono legal
services, and how to pursue such services; schedule of programs,
services, daily activities, including visitation, telephone usage, mail
service, religious programs, count procedures, access to and use of the
law library and the general library; sick-call procedures, and the
detainee handbook.

181

Medical screenings are performed by medical staffQ!persons who have
received specialized training for the purpose of conducting an initial
health screening.
_"
Each new arrival is classified according to ciiminaI history and threat
levels. Criminal history is provided for each detainee by the ICE field
office.
All new arrivals are searched in accordance with the ''Detainee Search"
standard. An officer ofthe same sex as the detainee conducts the search
and the search is conducted in an area that affords as much privacy as
possible.
Detainees are stripped searched only when cause has been established
and not as routine policy. Non-criminal de~ees are not strip-searched
but are patted down, unless reasonable suspicion is established.
The "Contraband" standard governs all personal property searches.
IGSAs/CDFs use or have a similar contraband standard. Staffprepares
a complete inventory of each detainee's possessions. The detainee
receives a copy.
Staff completes Form 1-387/ or similar form for CDFs and IGSAs for
every lost or missing property claim.. Facilities forward allI-387 clajms
to ICE.
Detainees are issued appropriate and sufficient clothing and bedding for
the climatic conditions.
'
The facility proyides and replenishes personal hygiene items as needed.
Gender-specific items are available, ICE Detainees are not charged for
these items. '
All releases are properly coordinated with ICE using a Form I~203.
Staff completes paperwork/forms for release as required.
~ ACCEPTABLE
D DEFICIENT
[

,,'. ,

REMAiu<s;', '

Detainees view a video upon inprocessing which provides
critical information regarding
the facility operations and
prQgrams. The detainee
handbook is also issued at this
orientation. The Detainee
Handbook is in both English and
Spanish.

Medical screerungs are
conducted by medical staff.

o
Detainees are not strip-searched.
Strip-searches are considered
only when cause has been
established.
Property is inventoried and
secured. Receipts for personal
items and valuables are issued
and signed for by the detainees

181

181,

Detainees are issued appropriate
clothing and bedding.

Detainees are issued personal
hygiene items.

IZI
~

AT-RIsK

REPEAT FINDING

REMARKS:

Policy MTC 2.1.10, entitled "Detainee Admission and Reception, "dated June 1, 2008, 'provides guidance with admission and release
procedures. Detainees view a video upon in-processing which provides critical information regarding the facility operations and
programs. The detainee handbook is also issued at this orientation. Detainees are strip-searched only when cause has been
established. Property is inventoried and secured and receipts are issued and signed for by the detainees.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
~32.4A Detention

i'nspection Form Worksheet for lGSAs - Rev: 07/09/07

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CLASSIFICATION SYSTEM WILL ENSURE TIlAT EACH PETAlNEE IS PLACED IN THE APPROPRIATECATEGQRY~PHYSlCAILYSEPARATED FROM

'DET~lNOTIkRCATEdoRmS'::'

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. .REMAR:Ks'
The facility has a system for classifying detainees. In CDFs and IGSAs,
IZI
0
D Detainees are classified using
an Objective Classification System or similar is used.
the ICE classification system.
The mcility classification system includes:
• Classnymg detainees upon arrival;
The classification system
• Separating from the general population those individuals who
includes appropriate
cannot be classified upon arrival; and
information.
• The first-line supervisor or designated classification specialist
reviewing every classification decision.
The intake/processing officer reviews work-folders, A-files, etc., to
Intake officers review
appropriate
informatiQn to
identify and classifY each new arrival.
D
D
identUY and classify detainees.
Staff uses only information that is factual, and reliable to determine
Only factual and reliable
classification assignments. OpinionS and unsubstantiated! unconfirmed
information is used to determine
reports may be filed but are not used to score detainees classifications.
classification assignments.
Housing assignments are based on classification-level.
A detainee's classification-level does not affect hislher recreation
opportunities. Detainees recreate with persons of similar classification
D
.. desifmations.
Detainee work assignments are based upon classification designations.
The classification process includes reassessmentlreclassification. At
is considered
D Reclassification
after 60 days.
IGSA's detainees mayreql!est reassessment 60 days after arrival.
Procedures exist for a detainee to appeal their classification assignment
Procedures exist to appeal
Only a designated supervisor or classification specialist has the authority
classification designations.
to reduce a classification-level on appeal.
Classification appeals are resolved within 'five business days and
detainees are notified of the outcome within 10 business days.
Classification dci;ignations may be appealed to a higher authority, such
as the Warden()r equivalent.
.
The Detainee Handbook or equivalent for IGSAs explains the
The current detainee handbook
classification levels, with the conditions and restrictions applicable to
does not explain the
classification process.
each.
However, a new detainee
:0 handbook has been created
which addresses this issue. It
will be issued once it has been
approved.
'.:~<;'<':'·:;:'::iCOMPONENrs

o
o

o
o
o
o
o
o

o
o

IZI ACCEPTABLE

DDEFICIENT

D·AT-RIsK

D REPEATF'INDING

REMARKS:

Policy # MTC 2.1.13,entitled "Detainee Classification and Separation," dated June 1,2008, provides guidance regarding classification
and separation of detainees. The facility class'ifies the population and separates them according to a. classification and housing
management plan. Detainees are classified using the IC~ classification system. Reclassification is considered after 60 days. The
current detainee handbook does not explain the classification process; however, a new detainee handbook has been created and will be
issued once it has .been approved.

b6,b7e

FOR OFFICIAl, USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

AUDITOR'S SIGNATURE I DATE

< ,'-S"

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CORRltSPONDENCE AND OTHER MAIL

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The rules for correspondence and other mail are posted in each housing
or common area, or provided to each detainee via a detainee handbook

IZI

D·

IZI

The facility provides key infonnation in languages other than English; In
the language(s) spoken by significant numbers of detainees. List any
excep.,tions.
Incoming mail is distributed to detainees within 24 hours or 1 business
day after it is reCeived and inspected.
Outgoing mail is delivered to the postal service within one business day
of its entering the internal mail system (excluding weekends and
holidays).
Staff does not open and inspect incoming general correspondence and
other mail (including packages and publications) without the detainee
present unless documented and authorized in writing by the Warden or
eguivalent for prevailing security reasons.
Staff does not read incoming general correspondence without the
Warden's prior written approval.
Staff does not inspect incoming special Correspondence for physical
contraband or to verifY the "special" status of enclosures witho1,lt the
detainee present
Staff is prohIbited from reading or copying incoming special
correspondence.
Staffis only authorized to inspect outgoing correspondence or other mail
without the detainee present when there is reason to believe the item
might present a threat to the facility's secure or orderly operation,
endanger the recipient or the public, or might facilitate crimiilal activi!y.
Correspondence to a politician or to the media is processed as special
correspondence and is not read or copied.
The official authorizing the rejection of incoming mail sends written
notice to the sender and the addressee.
The official authorizing censorship or rejection ofoutgoing mail provides
the detainee with signed written notice.
Staff maintains a written record of every item removed from detainee
mail.
The Warden or equivalent monitors staff handling of discovered
contraband and its disposition. Records are acCUl"llW and up to date.
The procedure for safeguarding cash. removed from a detainee protects
the detainee from loss offunds and theft. The amount ofcash 'credited to
detainee accounts is accurate. Discrepancies are documented and
investigated. Standard procedure includes· issuing a receipt to the
detainee.

IZI

; REMARKs

The rules for correspondence
are contained in the detainee
handbook
Key information is provided to
detainees in Spanish or other
significant languages.
Incoming mail is distributed to
detainees usually within 24
hours.
Outgoing mail is delivered to
the postal service within, one
business day.
Incommg correspondence is
opened by staff and examined
for cash, checks, money orders
or contraband per facility policy.
Facility policy allows 'staff to
randomly read in~oming general
correspondence under certain
criteria.

Outgoing correspondence is
opened by staff and examined
for contraband per facilitY
j)olicy.

Notifications are sent to the
detainee and the sender when
mail is re1ected.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
().324A Detention Inspection Fonn Worksheet for IOSAs· Rev: 07/09/07

·.,

CORRESPoNDENcE. AND 01'llERMAIL'
--

....

. .

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Original identity documents (e.g., passports, birth certificates) are
immediately removed and forwarded to ICE staff for placement in Afiles.
Staff provides the detainee a copy of bis/her identity' document(s) upon
request.

Staff disposes of prohibited items foqnd in detainee mail in accordance
with the "Control and Disposition of Contraband" Standard orthe similar
prevailing policy iD. IOSAs.
Every indigent detainee has the opportunity to mail, at government
expense, reas~nable correspondence about a legal matter, in three one
ounce letters per week and packages deemednecesS!IY by ICE.
The facility has a system for detainees to purchase stamps and formailing
all special correspondence and a minimum of 5 pieces of general
correspondence per week.
The facility provides writing paper, envelopes, and pencils at no cost to
ICE detainees.

IZI ACCEPT~BLE

o DEFICIENT

Indigent detainees are provided
the opportunity and materials to
mail 3 one ounce letters a week

Detainees can purchase 25
stamps per week.

Writing paper, envelopes, and
pencils are provided at no cost
to detainees weekly upon
request.

~
AT-RISK

Upon request, staff provides
detainees with a copy ofhis/her
identity documents.

REPEAT FINDING

REMARKS:

Policy # MTC 5.2.2, entitled "Correspondence and Other Mail" dated June 1,2008, provides procedures for mail delivery, postage,
legal correspondence, and non-privileged correspondence at the facility. The rules for correspondence are contained in the detainee
handbook and on an orientation video. Key information is provided to detainees in Spanish or other significant languages. Detainees
send and receive mail in a timely manner. Notifications are sent to the detainee and the sender when mail is rejected.

56.bIe

FOR'OFFICIAL USE ONLY ~AW ENFO.RCEMENT SENSITIVE)
G-324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 07/09/07

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::".:....COMPONENTs'\:: .• ; ,'; ... ".
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.:;'(.:.Y.",'

N~}: :.l~'A..REMARKs.

..;>

The detainee handbook is written in English and translated into Spanish,
or mto the next most-prevalent Language(s)..
The handbook is supplemented by the facilitY' orientation video, where
one is provided.
All staff members' receive a handbook· and training regarding the
handbook contents.

181

The handbook is revised as necessary and there are procedures in place
for immediately communicating any revisions to staff and detainees.
There aD. annual review of the handbook by a.designated committee or
staff member.

The detainee handbook addresses the following issues:
• Personal Items permitted to be retained by the detainee; and
• Initial issue of clothes, bedding and personal hygiene items.
The detainee handbook states in clear laIiguage the basic detainee
respons~bilities.

The ha1idbook clearly outlines the methods for classification of
detainees, explains each level, and explains the claSsification appeals
process.

The handbook states when a medical examination will be condu.cted.
The handbook describes the facility, housing units, dayrooms, in-dorm
activities, and special hOusing units.
The handbook describes official count times and ct>untprocedures; meal
times and feeding procedures; procedures for medical or religious diets;
smoking policy; clothing exchange schedules; and, ifauthorized, clothes
washing and drying procedures, and expected personal hygiene
practices.
The handbook describe times and procedures for ohtaining disposable
razors, and allows that detainees attending court will be afforded the
opportunity to shave first.
.
The han~ook describes barber hours and hair-cutting restrictions.

The detainee handbook is written
in both English and Spanish.
The facility does have an
orientation video available.
The training officer confirmed
that all staff does receive training
regarding the contents of the
detainee handbook.
The handbook is revised as
necessary.
There will be an annual review of
all policies and procedures;
however, at this time the facility
has only been operating for three
months.
Personal items permitted to be
retained and initial issue of
clothing are descnbed on pages 5
& 6 of the handbook.
Detainee -responsibilities are
outlined on page five ~fthe
handbook.
Classification and the
classification appeals process is
addressed on page seven of the
new handbook. The new version
of the handbook has not been
published and issued to the
detainee population.
Medical examination procedures
are found on pages 9 - 11 of the
handbook.
All areas are addressed in various
parts of the detainee handbook.
All areas -of the component are

adequately addressed in various
locations within the .handbook.
Disposable razor <listribution
policy is outlined on page seven
of the handbook.
Barbering services are'described
on page 12 of the handbook.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Fonn Worksheet for JGSAs - Rev: 07/09107

::::i,;);(::,;,:::",,'j"";'" .' .;;.: > ' .•.•... :........ ,P~!~~J£~~();~~:;"i<.: '. /:.. ' . ' :

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; POllCY: EVERY·Ole W1ILDEVELOPA srm"SPECIFICD~TAlNEE HA,Nl)BOOK TO SERVE AS AN OVERVIEW OF; AND GUIDE TO; THE DETENTION

'I>6~!a;@./~~,;AtID.PR~J?~~,~##~~ AT TIIi:F~q~tfY::,;tHE~B.~~ Wn.t:.#-s0 D~¢RIBE~ 'S~RVICES. PROO~.~.

;oPPORfuNrl1Es AVAnABLE'i'HROVGH VARIOUS s6lJI{cES~INCLUp~Grtm}lAo¢ttY;JCE, PRIvA.TEORGANlzATIONS, EtC. EvERy DEtAiNEE":

1\-~i,~P~~~~~P)r()F~~~~~~NjMiSS;~NTortffiFAciITY~.:·
The handbook describes the telephone policy; debit card procedures;
direct and free calls; locations of telephones; policy when telephone
demand is hi~ andpelicy and procedures for emergency phone calls.
The handbook addresses religious programming.

The handbook states times and procedures for commissary 'or vending
machine usage, where available.

·;:·:~'~A.··'

181

IZI

Detainee disciplinary policies and
procedures are descn'bed on
pages 18 - 24 of the handbook.

All areas of the component are
adequately addressed on page 25
of the detainee handbOok.

The handbook describes the detainee voluntary work program.

The handbook descn'bes the libraty location and hours ofoperation, and
law library procedures and schedules.

The handbook describes attorney and regular visitation hours, policies,
and procedures.
The handbook describes the facility contraband policy.

The handbook describes the facility visiting pours and schedule. and
visiting rules and regulations.
The handbook describes the correspondence policy and procedures.

The handbook describes the detainee disciplinary policy and procedures,
including:
• Prohibited acts and severity scale sanctions;
• Time limits in the Disciplinary Process; and
• Summary of the Disciplinary Process.
The grievance section of the handbook explains all steps in the
grievance process - Including:
• Infonna! (if used) and formal grievance procedures;
• The appeals process;
• In CDF facilities: procedures for filing an appeal of a
grievance with ICE.
• StaffYdetainee availability to help during the grievance process.
• Guarantee against staff retaliation for filing/pursuing a
grieva,nce.
• How to file a complaint about offiCer misconduct with the
Department of Homeland Security.

.... , .... '

RE~

Telephone policy and debit
procedures are outlined on pages
13 & 14 of the handbook.
Religious programming
infonnatiorr is described on page
14 of the handbook.
Commissary procedures are
'outlined on page 14 of the
handbook.
Voluntary work program
information is found on page 15
of the handbook.
Library and law h'braty
procedures are described on page
15 of the handbook. Law library
schedules are posted in the
housing units.
Regular visitation policy and
procedures are found on page 16
ofthe detainee handbook.
Contraband policy is described
on pages 27 & 28 of the
handbook.
Visitation hours and schedules
are published on page 16 of the
handbook.
Correspondence information is
included onpage 18 of the
handbook.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G·324A Detention Inspection Form Worksheet for IGSAs • Rev: 07/09107
Pasre 11 of RO

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.~~!~5~'~r:~n:=:~

The detainee handbook describes the medical sick call procedures for
general population and segregation.

IZI

The handbook describes the facility recreation policy including:
• Outdoor recreation hours.
• Indoor recreation hours.
The handbook descnoes the detainee dress code for daily living; and
work assignments.

The handbook specifies the ri~ts and responsibilities of all detainees.

~ ACCEPTABLE

o DEFICIENT

OAT-RISK

Sick call procedures for general
population and segregation
detainees are outlined on page
nine of the handbook.
Indoor and. outdoor recreation'
regulations are described on
pages 25 & 26 of the handbook.
Dress code issues are adequately
addressed on page 26 of the
handbook.
Detainee rights and
responsibilities are outlined on
page two of the handbook.

REPEAT FINDING

REMARKS:

All areas of the detainee handbook were thoroughly reviewed for compliance with published rCE standards. A new version of the
detainee handbook was recently developed to include .additional information pertinent to detainee programs. The new updated version
has not been disseminated to the detainee population.
' .

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITNE)
G-324A Detention Inspection Form Worksheet for lGSAs - Rev: 07109/07
P~ap.l?

nfRO

FOOD SERVICE ..

:~~~i7:~~tt:t~fk~E.T~~·INITSC~~NUT~#~>uSANDAPP~ri~'PRE~A#,INAGOORDANCEWllli·
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.. '.
The food service program is under. the direct supervision of a
professionally trained and certified food service administrator.
Responsibilities of cooks and cook foremen are in writing. The Food
Service Administrator (FSA) determines the responsibilities ofthe Food
Service Staff.

.' Y

IZJ

The Cook Supervisor is on duty on days when the FSA is off duty and
vice versa.
The FSA provides food service employees with training that specifically
addresses detainee-related issues.
• In ICE Facilities this includes a review of the ICE "Food
Service" standard
Knife cabinets close with an approved locking device, and the on-duty
cook foreman maintains control of the 'keythat locks the device.
All knives not in a secure -cutting room are physically secured to the
workstation and staffdirectly supervises detainees us'ing knives at these
workstations.' Staffmonitors the condition of Knives and dining utensils.
When necessary, special procedures govern the handling offood items
that pose a security threat.

IZJ

·0

IZJ

Operating procedures include daily searches (shakedowns) ofdetainee
work areas.

. . N .. ' NAREMARKs .
The food service dire,ct9r has 11
years offood service experience
with the Army. He is also servsafe trained and has a food
handler card with the state of
New Mexico.

Only the food service supervisor
has the key to the knife cabinet.

The facility has dry yeast which
is maintained inside the housing
control room.
Detention officers conduct
shakedowns of detainees. Food
service staff and detention
officers shakedown all work

areas.
The FSA monitors staff implementation of the facility's population
counts procedures. Staff is traiIied in count procedures.

The detainees assigned to the food service department look neat and
clean. Their clothing and grooming comply ·with the "Food Service"
Standard.'
The FSA annually reviews detainee-volunteerjob descriptions to ensure
they are accurate and up-to-date.
The Cook Foreman or equivalent instructs newly assigned detainee
workers in the rules and procedures of the food service department.
During orientation and training session(s), the CS explains and
demonstrates:
• . Sate work practices and methods;
•
Safety featw:es ofindividual productS/pieces ofequipment; and.
• Training covers the sate handling of hazardous material[s] the
detainees are likely to encounter in their work.

Detention officers and food
. service staff conduct the
population count in food
service. However, the food
service staff was not trained in
count procedures, according to
the food service director.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for 10SAs - Rev: 07/09/07

.'.

The Cook Supervisor documents all training in individual detainee
detention' files.
Detainees at CDFs are paid in accordance with the "Voluntary Work
Program" standard. Detainee workers at IGSAs are subject to local and
state rules and regulations regarding detainee pay.

Detainees are served at least two hot meals every 'day. No more than 14
,hours elapse between the last meal served and the first meal of the
following day.

For cafeteria style operations, a transparent "srieeze guard" protects both
the serving line andsaIad bar line.

o
The facility has a standard 35-day menu cycle. IGSAs use a 35 day
or similar system for rotating meals.
The FSA or facility considers the ethnic div~sity of the facility's
detainee population when developing menu cycles (Provide
examples).
A registered dietitian conducts a complete nutritional analysis of every
master-cycle menu planned.
The FSA has established procedures to ensure that items on the mastercycle menu are prepared and presented, according to approved reCipes.
The Cook Foreman has the authority to change menu items ifnecessary.
• If yes, documenting each substitution, along with its
justification
.
• With copy to FSA
All staff and volunteers mow and adhere to written "food preparation"
procedures.
. Detainees whose religious beliefs require the adherence to particular
religious dietary laws are referredto the Chaplain or FSA.

o
o

Food service has approximately
1~-15 detainees assigned to
work food service and they
receive $1.00 per day. The food
service, quota of detainee
workers needs to be increased to
enhance the overall sanitation.
B-5:00 a.m. L-ll:45 a.m. and
D-4:00 p.m. Therefore, no more
than 14 hours elapses between
the last meal served and first
meal of the following day.
Food service has cafeteria style
operations. However, ithas a
blind window feeding program '
(just a small window where food
trays are passed to the
detainees).
Food service has a 42 day
master cycle menu.
Food service has a diverse
menu, i.e. hot dogs, chili mac,
tuna salad, cold cuts, chicken,
taco meat, and turkey slices etc.
No complete nutritional analysis
was available for.review on the
42 day master cycle menus or
common fare menu.

. FOR OFFICIAL USE ONLY {LAW ENFORCEMENT SENSITIVE)
G·324A Detention InspeCtion Fo~ Worksheet for IGSAs - ReV: 07109/07

.. FOOD
.: .... SERVICE:
.~

'.~:

'.··~~~Ws~':~~~0E.I':ETA1NEr.IN~S.S~~·~1?ySA.ND~P~ING~~P~~ARED~ACroRDANCEWlm .
>/:\::~:';:;{;;::i:;·"·.'·<COMPONENT8 ........ :£:.'
':y.
A common-fare menu available to detainees whose dietary requirements
cannot be met on the main iine.
.
• Changes to the planned common-fare menu can be made at the
facility level;
• Hot entrees are offered three times a week;
• The common-fare menus satisfy nutritional recommended daily
allowances (RDAs);
D
• Staff routinely provide hot water fer instant beverages and
foods;
o Common-fare meals are served with:
• Disposable plates and utensils.
• Reusable plates and utensils.
• Staffuse sepw:ate cutting boards, knives, spoons, scoops, etc.,
toJ)repare the common-fare diet items.
A supervisor at the command level must approve a detainee's removal'
from the Common-Fare Program.

The Warden, in conjunction with the chaplain and/or local religious
leaders, provides the FSA a schedule of the ceremonial meals for the
following calendar year.
The common-fare program accommodates detainees abstaining from
particular foods or fasting for religious PurPoses at prescribed times of
the year.
• Muslims fasting during Ramadan ~eceive their meals after
sundown.
• Jews who observe Passover but do not participate in the
Common~Fare Program receive the same Kosher-for- Passover
meals as those who do participate.
• Main-line offerings include one meatless meal (lunch or
dinner) on Ash Wednesday and Fridays during Lent.

N};:

'., REMARKs
The facility does have a
Common Fare menu. However,
approximately 30-50% of the
food items were not kosher.
Therefore, the current program
is not meeting the detainees'
religious dietary requirements as
required. The food service
director needs to develop policy
and procedures to address
religious diets.
The facility does have a
Common Fare menu. However,
approx~ly 30-50% of the
food items were not kosher.
Therefore, the current program
is not meeting the detainees'
religious dietary requirements as
required. The food service
director needs to develop policy
and procedures to address
religious diets.
A schedule of religious
ceremonial meals is not
provided to the food service
director prior to the beginning of
the calendar year.
The facility does have a
Common Fare menu. However,
approximately 30-50% of the
food items were not kosher.
Therefore, the current program
is not meeting the detainees'
religious dietary requirements as
required. Thefood service
'
director n.eeds to develop policy
arid procedures to address
religious diets.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Fonn Worksheet for lGSAs - Rev: 07109/07

.The food service program addresses medical diets.

Satellite-feeding programs follow guidelines for proper sanitation.

Hot and cold foods are· maintained at the prescribed, "safe"
temperature(s) while being served.
All meals are provided in nutritionally adequate portions.
Food is not used to pmllsh or reward detainees based upon behavior.

CUrrently, food service is not
providing any medical diets to
anyone within the facility. Food
service is required to provide all
medical diets as ordered by the
medical department according to .
MTC Policy Number 4.1.6,
Special Diets. Food service
does not have a proper medical
diet menu to address any special
medical diets.
The satellite-feeding program is
not following proper sanitation
guidelines. Several sanitation
issues were identified during !he
review. The following items
need additional attention:
storage carts, food tray racks,
cooler and :freezer floors; dish
machines need to be de-limed;
food steamer, hot serving line
food wells need to be de-limed;
and dining room floor and tables
need cleaning. The food service
director did take some
corrective action to correct some
of the sanitation issues identified
during the review. It was noted
that instead of detainees wearing
proper safety shoes or ·rubber
boots, most of the food service
workers were observed wearing
tennis shoes while working in
the kitchen. This is a high risk
area for potential injuries and
slip hazards. The pot and pan
manual three-compartment sinks
were not properly labeled.
None of the food service staff;
except for the food service
director, has a New MeXico
Food Handlers Card as required
by MTe Policy Number 4.1.1,
Food Service Management.

. []

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G·324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 07/09/07

: . FOQD~:EllVlC]t '

The food service staff instructs detainee volunteers on:
• Personal cleanliness and hygiene;
• Sanitary techniques for preparing,· storing, and serving food;
and .
,

•

The sanitary operation. care ' and maintenance of equipment.
Everyone working in the food service dep8rtment complies with food
safety and sanitation requirements.
Standard operating procedures include weekly inspections of all food
service areas, including dining and food-preparation areas ,and
equipment.
• Who conducts the inspections?

Equipment is inspected for compliance with health and safety codes and
regulations.
• When was the most recent inspection?
• Which agency conducted the inspection?

- Reports of discrepancies are forwarded to the Warden or designated
department head, ,and corrective action is scheduled and completed.
Standard procedure includes checking and doc.umenting temperatures of
all dishwashing machines after each meal.
Staff documents the results of every refrigerator/freezer temperature
check.
The cleaning schedule for each food service area is conspicuously
posted.
Procedures include inspecting all incoming food ~hipments for damage,
' con~ation. and pest infestation.
Storage areas are locked when not in use.

ACCEPTABLE

lZI DEFICIENT

r8I

IZI

0
0

OAT-RIsK

The food service director or his
assistant is not conducting a
weekly sanitation inspection.
Therefore, he is not able to
provide suffiCient information
on deficiencies to enable the
development of a corrective
action plan to eliminate problem
areas.
New Mexico Environmental
Health Department Division has
not come out to iIispect food
service as of yet The facility
started receiving ICE detainees
in June of2008. The facility is
brand new and has been open
for,a]Jproximately 6 months.

D REPEAT FINDING

REMARKS:
A registered dietitian has not conducted a complete nutritional analysis of every master-cycle menu planned or common fare
menu.
,A proper Common Fare Program is not available to detainees whose religious dietary requirements cannot be met onthe mainline'
as well as to accommodate deiainees abs~g from particular foods or ~ting forreligious purposes at prescribed times of the
year. Food Service does not have policy and procedures in place for religious dietary requirements.
A schedule ofreligious ceremonial meals is not provided to the food service director prior to the beginning of the calendar year.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITNE)
G-324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 07/09/07

The food service program is not addressing or providing any medical diets as required.
The satellite-feeding program is not following proper sanitation guidelines.
The weekly sanitation inspections of all food service areas and equipment are not being conducted as required.

156,070

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention. Inspection Form Worksheet for JOSAs -Rev: 07/09/07

Page 18 of 80

···.<:;;.::i . ;.

,<;'

.;':;:.i:';' ,,>.,: . . .

;:~S~'~¥RSO~~P~QP:E~'rY"<

•....

i_A~••~~~~~~~~=3··
-, LJ STAND~~~! (i~SAON.L~ CHECK THISBOX~"AL):.~CE DETAINEE ~S, VAt~ABLESAND PROPERTY ARE HANDLED ONLY'

::;<",;nt:';""'t~;h.,;:;:·.·

BY,rHiitE1J'tELD'OFFlCE ORSUiJ'::OFFtCE iN·COr.iTl{OLOF tB,iDE1'AINEitCASE. ',: .......

Detainee funds and valuables are properly separated, stored, and are
accessible only by designated supervisor(s).

Detainees' large valuables are secured in' a location accessible to
designated supervisor(s) or processing staff only;

Staff itemizes the baggage and personal property of arriving detainees
(including funds and valuables) .. For IGSAs and CDFs, using a personal
property inventory form that meets the ICE standard?

Staffforwards an arriving detainee's medication to the~edical staff.

Audits of baggage and non-valuable property occur each quarter and
audits are logged and verified.

Two officers are present during the processing of detainee funds and
valuables during in-processing to the facility. Both officers verify funds
and valuables.
Staff searches arriving detainees and their personal, property for
contraband.
Staffprocedures follow written policy for returning forgotten property to
4etainees.

Property discrepancies are immediately reported to the CDEO or Chiefof
Security.

2008.

Detainee funds and valuables
are separated, verified, and
processed by intake staff at the
time of admission. Funds are
counted and all relevant
information (offender name,
number, and the amount of
funds collected) is recorded.
The facility limits large
valuables which are secured in
the property room.
Staff was not itemizing all
baggage, backpacks, and other
bags as required. 11ris~
corrected during the review.
Medications confiscated Or
$UlTendered during the intake
process are reviewed by medical
staff. Prescriptions deemed
necessary are forwarded to the
detainees or filled and dispensed
~ the facility's medical staff .
The facility just started to
receive detainees on June 23,

Staff searches arriving detainees
and their personal property for
contraband.
MTC Policy Number 2.1.11,
Detainee Funds and Personal
Property, does not address
proper procedures in returning
forgotten property to detainees.
The procedure is addressed in
MTC Policy Number 2.1.11,
Detainee Funds and Personal
Property.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE) ,
0-324A Detention Inspection Fonn Worksheet for IOSAs - Rev: 07/09/07

"':.,.;.,:

,,'~

,:'::.'"

......

'~~ANJ)PE~ONAf:,~O~ERTY

;.,D'\'o;o'::. ':":';(:;),:;':;;<.,';;."'I. ;;',.,.' ..

...........

:,:':).::';0:":'." ","<:;>L ..... , . ....

..• .•

,POLIcY; AI..LFAClLITmSWILLlMPLEMENT PROCEDURES TOCONTItOLAND SAFEGUARD DETA1NEES~PERsbNALPROPER'tY~ PROCEDURES wiLi::.,:

:Bililli~~~~£::-:::~
Staff follows written procedures when returning property to detainees.

o
CDFIIGSA facility procedures for handling detainee property claims are
similar with the ICE standard.

The facility attempts to notiiY an out-processed detainee that he/she left
property in the facility:
• By sending written notice to the detainee's last mown address;
• Via certified mail; and
• The notice state that the detainee has 30 days in which to claim
the property, after which it will be considered abandoned.
The facility disposes of abandoned property in accordance with written
procedures.
.
• If a CDFIIGSA facility, written procedure requires the prompt
forwarding of abandoned property to ICE.

IZI ACCEYfABLE

DEFICIENT

o
o
AT-RISK

MTC Policy Number 2.1.11,
Detainee Funds and Personal
Property, does not address or
.provide proper procedures for
returning property to detainees.
MTC Policy Number 2.1.11,
Detainee Funds and Personal
Property, does address proper
procedures for handling
property claims.
MTC Policy Number 2.1.11,
Detainee Funds and Personal
Property, does not address or
provide proper procedures for
returning property to detainees.

Policy Number 2.1.11 required
that any detainee's abandoned
property shall be reported to and
turned over to ICE.

D REPEAT FINDING

REMARKS

The facility provides for the control and safeguarding of detainees' personal property through the secure storage of funds, valuables,
baggage, and other personal property. Procedures for the documentation and receipt of surrendered property and the initial and
regularly scheduled inventory of all funds, valuables, and other property are in place. However, Policy Number, 2.1.11, Detainee
Funds and Personal Property, does not address or provide proper procedures for returning forgotten property or returning property to
detainee's last known address.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
0-324ADetention Inspection Form Worksheet for IOSAs - Rev: 07/09/07

. ,DETAINEEGiUEVANCEpaO~DURES ..... '. .. : .:<.: .'..

. .:~:

.., ..

Written procedures provide for the informal resolution of oral
grievances (Not mandatory).
• If yes, the detainee has up to five days within which to make
his/her concern known to a member of the staff.

Detainees have access to the grievance committee (or equivalent in
IOSA), using formal procedures.
.
• Detainees may seek help from other detainees or facility staff
when preparing a grievance.
• Illiterate, disabled. or non-English-speaking detainees receive
special assistance when necessary.
Every member ofthe staffknows how to identifY emergency grievances,
including the procedures for exp~difu.g them~
There are documented or substantiated cases of staff harassing,
disciplining, penalizing, or otherwise retaliating against a detainee who
lodged a Complaint:
• Ifyes, explain.
Procedures include maintaining a Detainee Grievance Log.
• '. If not, an alternative acceptable record keeping system· is
maintained.
• "Nuisance complaints" are identified in the records.
• For quality control purposes, staff document nuisance
complaints received but not filed.
.
Staff is required to forward any grievance that includes officer
misconduct to a higher official or, in a CDFIIGSA facility, to ICE.

[8J ACCEPTABLE

DDEFIClENT

o
o
o

D AT-RIsK

Local policy 6.2.1 "Grievance
Procedures" provides a five day
time frame for a detainee to make
his/her concern known to a staff
member.

Detainees may seek the assistance
of another detainee or staff
member in the preparation of
their gtievances.

Emergency grievance procedures
are incl\:!ded as part of the overall
lesson plan for grievance
procedures.

The designated grievance
lieutenant maintains an
acceptable recordkeeping system.
'The recordkeeping systeIIi is
documented using paper and
electronic means.
Local policy 6.2.1, paragraph 7,
includes infonnation that .
grievances pertaining to officer
misconduct be forwarded to ICE.
REPEAT FINDING

REMARKS:

All areas pertaining to grievance procedures were thoroughly reviewed for content and compliance with published ICE standards.
There were no areas of concern noted.
.

b6,b7G

. I I

••

Se tember 18 2008

lJ6.b7c

NATURE/DATE

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Fonn WDrksheet for IGSAs - Rev: 07109/07

GROUP
LEGAL RIGHTS
PRESENTATIONS
..
.
.
..........

...• :

:.':.

:.""

The Field Office is responsive to requests by attorneys. and accredited
representatives for 2l'oUP presentations.
Upon receipt of concurrence by the Field Office Director, the facility or
authorized ICE Field Office ensures timely and proper notification to
attorneys or accredited representatives.
The facility follows policy and procedure when rejecting or requesting
modifications to objectionable material provided or presented by the
attorney or accredited representative. .
.
Posters announcing presentations appear in common areas at least 48
hours in advance and sign-up sheets are available and accessible.
Documentation is submitted and maintained when any detainee is denied
~ion attend a presentation and the reason(s) for the denial.

When the number of detainees allowed to attend a presentation is limited,
the facility provides a sufficient number of presentations so that all
detainees signed up may attend.
Detainees in segregation, unable to attend for security reasons, may
request separate sessions with presenters. Such requests are documented.
Interpreters are admitted when necessary to assist attorneys and other
legal representatives.
Presenters are afforded a minimum of one hour to make the presentation
and to conduct a question-and-answer ses~ion.
Staff pertn,lts presenters to distribute ICE-approved materials.
Presenters are permitted to meet with small grQUPS of detainees to discuss
their cases after the group presentation. rCE or authorized detention staff
is present 'but do not monitor conversations with legal providers.
Group presenters who have had their privileges suspended are notified in
writing by the Field Office Director or designee; and the reasons for
suspension are documented. The Headquarters Office for Detention and
Removal, Field Operations and Detention management Division, is
notified when a group or individual· is suspended from making
presentations.
The facility plays ICE-approved videotaped presentations on legal rights
at regular opportunities, at the request of outside organizations.
A copy of the Group Legal Rights Presentation policy, including
attachments, is available to detainees upon request

JZI ACCEPTABLE

o DEFICIENT

o
o

IZI

181

181
~

0
D

0
0

181.

181

jgI

D·

181·

D AT-RIsK

..: '

Detainees are required to
particip~te in the "To Know
Your Legal Rights"
oresentation.

o REPEAT FINDING

REMARKS:

The Diocesan Migrant and Refugee Services Inc. provide a "To Know Your Legal Rights" presentation. Every detainee is required to
attend thiS presentation.

156 ble

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE) .
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

':,.. >~:.~{>;:,~.;"""'" :. :'. ~6g;rrlt~~~~~,;?}:~~r~~,)J~~]),~~,A~3:~~E~: .,"

',. '.,' . '. .. . .;.• .
~~~~~E~~tElCEDEr:~ur~~::llNENS.~

p<>:r:.~CY:]C;E REQUn.uiS THAT AP4FAClI;J.TIES HOUS~G ICEP¥i'AINEES PROVIDE CLEAN·CLQnnNG, :SE.l?])~G, LINENS ANDTOWBts TOEVERY:'

The facility has a policy and procedure for the regular issuance and
exchange of clothing, bedding, linens, and towels.
• The supply ofthese items exceeds the minimum required for the
number of detainees.
All new detainees are issued clean, temperature-appropriate, presentable
clothing during in-processing. Detainees receive:
• One uniform shirt and one pair of uniform pants, or one
jumpsuit;
• One pair of socks;
• One pair of underwear (Daily change); and
• One pair of facility-issued footwear.
Additional clothing is available for changing weather conditions, or as
seasonally_ appropriate.
.
New detainees are issued clean bedding, linens, and towels. They receive
at a minimum:
• One mattress;
• One blanket;
• Two sheets;
• One pillowcase;
• One towel; and
• Additional blankets are issued based on local weather
conditions.
Detainees assigned to special work areas are clothed in accordance with
the requirements of the job.
Detainees are provided clean clothing, linen and towels.
• Socks and undergarments - exchanged daily.
• Outer garments - twice weekly.
• Sheets - weekly.
• Towels - weekly.
.• Pillowcases - weekly.
Food service detainee volunteer workers are permitted to exchange outer
garments daily.
Volunteer detainee workers are permitted to exchange outer garments
more frequently.

IZI ACCEPTABLE

DEFICIENT

fg\

Policy 4.2.1 "Laundry Services"
provides procedures for the
regular issuance and exchange
of clothing, bedding, and linens.

·All detainees are issued the .
appropriate amount of clean,
presentable clothing during inprocessing.

· Additional clothing is available
· for changing weather conditions.

Detainees are issued the
appropriate amount of bedding,
linens, and towels.

Detainees are provided
additional clothing as dictated
by job assignnient

IZI

Clothing exchanges are
provided to meet or exceed the
minimum standards.

fg\

Food service workers ate
permitted to exchange outer .
· garments daily.
Outer garments are exchanged at
least twice weekly.

. fg\

181
AT-RISK

REPEAT FINDING·

REMARKS:

All areas pertaining to the issuance of clothing, bedding, and towels was thoroughly reviewed for compliance with ICE standards. It
was noted that chemical control and inventory procedures in the laundry were excellent during the review process. There were no
areas of concern noted.

FOR OFFICIAL USE 'ONLY (LAW ENFORCEMENT SENSITNE)
G-324ADetention Inspection Form Worksheet for IGSAs - Rev: 07109107

i"\i,::'i:Y,',::-:'t··:',ir'. "'~'::;'~,:~~::::;)~Sl:;'f"/.::~":·,'"~0ft0C1~~TS:::;":::,:::, . . . . . ,•. '.;;:,';".' ;"';. .',
.POLICV:.,AtL DEI:AlNEEMARruAQEREQUESJ1; W1LLREcElVEiCA$$:-~Y-{'!ASE CONSIDERATION FRoMICE.MANA,GEMENT.

The Field Office considers detamee marriage requests on a case-by:-case
basis.

IZI

The Field Office Director reviews every marriage request rejected by a
Warden/OlC or IGSA. R~iections are documented.
It is standard practice to require a written request for permission to many.

The written request includes a signed statement or comparable
documentation from the intended ~ouse, co
. marital intent
The Warden/OIC provides a written copy of hislher decision to the
detainee and hislher legal representative.
When penmssion is denied, the Warden/OIC states the basis for bis/her
decision.
The Warden/Ole provides the detainee with a place and time to make
wedding arrangements.

, 181 ACCEPTABLE,

D DEFICIENT

o
o
o

Denials of requests for marriage
are handled by the ICE field
office.

IZI

D AT-RISK

Any marriage request will be
forward to ICE local field office
on a case-by-case basis.

The facility has only had a
couple of requests in the past
three months since opening up
in June 2008. Any ICE detainee
request will be forward to ICE
field office.

o
.

'.. ".~•.'•..', ':>;

o REPEAT FINDING

REMARKS:

Marriage requests from ICE detainees are submitted directly to ICE to reCeive case-by-case consideration from the ICE field office.
The facility has only had a couple of requests since receiving ICE detainees on June 23, 2008.

Doble

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 07/09/07

The Field Office Director considers and approves, on a case-by-case
basis, trips to an immediate family member's:
-. Funeral; or
• Deathbed
The facility recognizes mother, father, brother, sister, spouse, child, stepparent, and foster parent as "immediate family".
The !GSA facility notifies ICE of all detainee requests for non-medical
escorts.
The detainee's Deportation Officer reviews the file before forwarding a
detainee's request, with recommendation, to the approving official. Each
recommendation addresses the individual's suitability for travel; e.g., the
kind of supervision required.
Each escort includes at least two officers.

Escorting officers report unexpected situations to the originating facility
as a matter of procedure, and the ranking supervisor on duty has· the
authority to issue instructions for completion of the-trip.
Escorting officers have the discretion to increase or decrease minimum
restraints in accordance with written procedures and classification level of
the detainee.
Escort officers are precluded from accepting gifts/gratuities from a
detainee, or detainee's relative or friend for any reason.

Escort officers ensure that detainees:
• Conduct themselves in a manner that does not bring- discredit to the
ICE;
• Do. not violate federal, state, or local laws;
• . -Do not purchase, possess, use, consume, or administer narcotics,
other drugs, or intoxicants;
Make
no unauthorized phone calls; and
•
Know
they' are subject to search, u$a1ysis, breathalyzer, or
•
comparable test upon return.
·Standard procedure requires the immediate return to the facility of any
detainee who violates trip rules.

jgI ACCEPTABLE

o DEFICIENT

IZI

181

IZI

-0

The FOD is the approving
official for any detainee request
for non-medical emergency
escorted trips.
Management & Training
Corporation, Operational
Policies and ProcedUres No.
1.2.2, Title-Detainee
Transportation, addresses
escorting staff.

MTC Employee Handbook,
page 27, precludes staff from
accepting gifts/gratuities from
detainees or their relatives or
friends for anyreaSon.
MTC, Operational Policies and
Procedures No. 1.22, SubjectDetainee Transportation,
requires staff to instruct the
detainee about the rules of
conduct during. the escorted trip.

I8l

181

OAT-RIsK

All detainee requests for nonmedical escorts are considered
on a case-by-case basis by ICE.

o REPEAT FINDING

REMARKS:

Discussions with the warden and ICE personnel provided verification that facility staffperforms escorts of this type.
Se.ptember 18, 2008

06,b7e

AUDITOR'S SIGNATURE I DATE

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITNE)
G-324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 07/09107

Paie25 of 80

A recreational specialist (for facilities with more than 350 detainees) tailors
the program activities and offerings to the detainee population.
Regular maintenance keeps recreational facilities and equipment in good
condition.
The recreational specialist or trained equivalent supervises detainee
recreation workers.
.
The recreational specialist or trainee equivalent oversees recreation
programs' for special hoUsing units (SHUl and special-needs detainees.
Dayrooms offer sedentary activities, e;g., board games, cards, television.

IZI

181

IZI

Outside activities are restricted to limited-contact sports.

Each detainee has the opportunity to participate in daily recreation.
Detainees have access to recreation activities outside the housing units for
at least one hour daily, 5 days a week.

181
181 .'

[ ]

Staff checks all items for damage and condition when equipment is
returned.
Staff conducts searches of recreation areas before and after use.

181

IZI

[]

IZI

D
D

181
181

o
o

All recreation areas under constant staff supervision.
Supervising staff is equipped with radios.
The facility provides detainees in the SHU at least one hour of outdoor
recreation time daily. five times per week.

The facility has a recreation
supervisor and a specialist.
The facility has limited
recreation equipment, i.e. pullup bars, volleyball, handball and
basketball courts.
Currently, no detainees are
assigned to the recreation
department.

The facility offers board games,
cards, and TV on a daily basis.
Outside recreation activities are
restricted to limited contact·
sports such as basketball and
volleyball.
Detainees have aCGess to outside
recreation activities for one. hour
daily, seven days per week.

All recreation areas are searched
prior to opening and closing.

Detainees have access to outside
recreation activities for one hour
daily, seven days per week.

Detainees in discipIiruuy/administrative segregation receive, a written
0
D
explanation when a panel revokes his/her recreation privileges.
181
[]
0
Special programs or religious activities are available to detainees.
Volunteers are required to sign a waiver of liability before entering a secure
0
0
[8J
Volunteers are not utilized in the
portion of the facility where detainees are present.
recreation program.
Visitors, relatives or friends are not allowed to serve as volunteers.
IZI
[]
0
J8l.Hou.tdoorreereatibn is offered, eheckthisboL Nofiirtlieriid'ormation is required wbenoutdoor recreation is offered.
If the facility has no outside recreation, are detainees considered fot
transfer after six months?
• If yes, written procedures ensure timely review of all eligible
detainees.
ease officers make written transfer recommendations about every sixmonth detainee to the Ole.
[]
[J
The Ole documents all detainee-transfer decisions, whether yes or no.
D
The detainee's written decision for or against an offered tranSfer
D
documented in his/her A-flie.
Staff notifies the detainee's legal representative of his/her decision to
D
D
accept/decline a transfer.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 07/09/07

~~~~~\_~ra:1~~~~;io,~·~.··
lfno recreation is available, the ICE Districts routinely review transfer
eligibility for all detainees after 60 days.
The A-file of every detainee who is held more than 60 days without
access to recreation contains either a transfer-waiver signed by the
detainee, or the OlC's written determination ofthe detainee's ineligibility
. .
for transfer.
The detainee's legal representative is notified of the detainee'stOlC's
decision.
.

IZI ACCEPTABLE

DDEFICIENT

OAT-RISK

REPEAT FINDING

REMARKS:

The facility provides access to limited recreational programs and activities to the entire population, to the extent possible, under
conditions of security and supervision that protect their s~fety and welfare. Currently, the facility is housing approximately 920 ICE
detainees. This facility has been open since June 23, 2008.

be bYe

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITNE)
G-324A Detention Inspection Fonn Worksheet for IOSAs - Rev: 07/09/07

i~E~~1~fgs~~~~~~1~~.
,>:"",/,,<>···~:;,y;,··,'COMP.oNtNTs·:::;iL'.'·'

D~~inees areaIlowed toenga~e

fu religi~; s~rvices.

"','," . •.

....,

',C"

,'·;,Y·, .·······N <?:I~'A'«
D'

Space is available for detainees to conduct religious services.

I8J

The facility allows detainees to observe the major "holy days" of their
. religious faith.
• List any exceptions.
The facility accommodates recognized holy~day observances by:
• Providing special meals. consistent with dietary restrictions;
• Honoring fasting requirements;
.
• Facilitating religious services; and
• Allowing activity restrictions.
Each detainee is allowed religious items in his/her immediate possession.
Volunteer's credentials are checked and verified before allowing
participation in detainee programs.

Members of faiths not represented by clergy may conduct their own
I8J
services within security allowances.
Detainees in the Special Management Unit are allowed to participate in
religious practices unless otherwise documented for the safety and
security of the facility.~

IZI ACcEPTABLE

DEFICIENT

'IZI"

OAT-RIsK

,." REMAR:Ks; ../ ....

. ".

Religious services are conducted
O D i n the multi~purpose room and in
the housing. unit.
Ramadan, Passover. Lent etc.
'are observed by detainees upon
request.

All volunteer clergy' credentials
are checked and verified prior to
admittance into the secure area
of the facility. NCIC
background investigations are
also performed.

Religious services are provided
by clergy making rounds
through the Special
Management Unit or through the
use of non-contact pastoral visits
upon request.
REPEAT FINDING

REMARKS:
All detainees are provided with reasonable and equitable opportunities to participate in the practice of their faith within the constraints
of safety, security. and orderly operations of the facility.

. • I

b6,bIe
••

Se tember 18 2008

b6 bIc

, ATURE/DATE

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSIUVE)
G-324A Detention Inspection Fonn Worksheet for !GSAs - Rev: 07/09/07

:, :,>"'.:' ". ',(: ,,:"(' :.

,DETAINEETELEPHONEAcCESS'

~O~~:'~:F~di~~1I6U~1Nglqi~~1'~s~::i.~'~~;~ESx~.g~~~~~~PrrJ\B~A.~SS TO TELEPHONES.· .:' "

......::"::;},;.. ':.;.,:.•. . ".';:COMPO:N:ENTs>',

, "." . . !, .':,.., . y ':, <:N <'(N'A

Detainees are allowed access to telephones during established facility
waking hours.

Upon admittance, detainees are made aware of the mcility's telephone
access policy.

181

Access rules are posted in housing units.
The facility makes a reasonable effort to provide key infonnation to
detainees in languages spoken by any significant portion ofthe facility's
population.
Telephones are provided at a minimum ratio' of one telephone per 25
detainees in the facilfty population.
Telephones are inspected regularly by mcility staff to ensure that they
are in good working order.
The facility administration promptly reports out-of-order telephones to
the facility's telephone service provider.
The facility administration monitors repair progress and takes
appropriate' measures to ensure that requiTed repairs are begun and
completed timely.
.
Detainees are afforded a reasonable degree ofprivacy for legal phone
calls.
A procedure exists to assist a detainee who is having trouble placing a
confidential call.
The facility provides the detainees with the ability to make non-collect
(special access) calls.
Special Access calls are at no charge to the detainees.
The OIG phone number for reporting abuse' is programmed into the
detainee phone system and the phone number was checked by the
inspector during the review.
In mcilities unable to fully meet this requirement initially because of
limitations ofits telephone service, ICE makes alternate arrangements to
provide required access within 24 hours of a request by a detainee.
No restrictions are placed on detainees attempting to contact attorneys
and legal service providers who are on the approved ''Free Legal
Services List".
Special arrangements are ~ade to allow detailiees to speak by telephone
with an immediate filmily member detained in another Facility.
Any telephone restrictions are documented.
The filcility has a system for taking and delivering emergency detainee
telephone DlessageS.
Emergency phone call messages are immediately given to detainees.
Detainees are allowed to return emergency phone calls' as soon as
possible.

121

181

121

181

IZI

D·

181

IZI
IZI

D
D

o
o
[ ]

IZI

181

D
0
0
D
D

D
D

. ,;.: ... REMARKS .'

Telephones are turned on at
8:00 AM and shut off at 10:00
PM. Phones are shut off prior to
institution counts and are turned
back on after the count clears.
Telephone procedures are
addressed in the detainee
handbook and posted in the
ho~ing unit.

IZI
IZI

Key information is provided to
detainees in, Spanish or other
si~ficant languages.
Each unit has three phones for a
maximum of 50 detainees.
P1!ones are inspected regularly
and a log is maintamed.

The OIG and Pro Bono numbers
are programmed intO the phone
_system.

o
o
D

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Fonn Worksheet for IGSAs • Rev: 07/09/07.

" i " ':;" ":":/):

"':"

' , '" ...•... DET~ETI£LEf~~~ACCESS

.•. " ; ; . .

7 ' ."./,

':~~~~/,~~ii~9~~H~~SWG,tC$i>~~~\vniI'~ri¥~ES~REAS9*~~~EQpfi.~PE,;\CCESST6~~}I~~S. . ,"" .'

L/:;;""");';·;:'\V};i:<'i:'rr>:i;.. ~:.·co.ONENTs;,',: ". . . ; i ; : ; i : ; y : ' "N: .:'N.A:>'T\ . '. REMARKS'.':- ' :
Detainees in disciplinary segregation are allowed phone calls relating to
the detainee's immigration case or other legal matters, including
consultation calls.
Detainees. in disciplinary segregation are allowed phone calls to
consular/embassy officials.
Detainees in disciplinary segregation are allowed phone calls for family
emergencies.
Detainees in administrative
Detainees in administrative detention and protective custody are
segregation and protective
custody are afforded telephone
afforded the same telephone privileges as those in general popula~on.
privileges.
Phones clearly identify thatthe
When detainee phone calIs are monitored, notification is posted by
calls are being monitored at the .
detainee telephones that phone calls made by the detainees may be
~
facility.
monitored. Special Access calls are not monitored.

o
o
o

[81 ACCEPTABLE

D.DEFICIENT

AT-RISK

o
o
o

o
o REPEAT FINDING

REMARKS:

Policy # MTC S.2.3, entitled "Telephone Access" dated June 1, 2008. provides guidance to staff regarding detainee telephone usage.
Telephones are turned on at 8:00 AM and shut off at 10:00 PM. Phones are shut ofi'prior to institution counts and are turned back on
after the count clears. Telephone procedmes are addressed in the detainee handbook and posted in the housing units. The DIG and
Pro Bono numbers are programmed into the phone system.
S tember 18 2008

b6,b7c

AUDITOR S iGNATURE/DATE

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Fonn Worksheet for IG8As - Rev: 07/09107

:' Y ' , : ' " ... ; <.. ' ......: ,.' . ··<>''':ViSJTATION,:';. . . i , : " .

. . . . '.:;."

.,: .. ;

.~l?J,~~~~~~fii:~~~~~1~~~~·~~.~~1HB~
.'.?c';i"~:

//\',.::.,.,·:·,.:":COMPONENTS':::'·:';, ;';:.. ~. :........ " ..; : :~>y" ,'?:;N(: "NA<·

There is a written visitation schedule and hours for general visitation.

The visitation hours tailored to the detainee population and the demand
for visitation.

"':.'~

Non-contact visiting is allowed
weekly from 5:30 PM through
8:00 PM Monday through
Friday and 12:00 PM through
3:00 PM Saturday and Sunday.

A visitation schedule and rules

are available in the visiting .
lobby. Visitation rules are also
available in the detainee .
handbook.

18I

A general visitation log is maintained.

A visiting log is maintained by
the facility.

The detainees are permitted to retain personal property items specified
in the standard.

18I

A visitor dress code is available to the public.

181

Visitors are searched and identified according to standard requirements.

The :tequirement on visitation by minors is complied with.

181

o
o
o
o

Visitor dress code is available in
the front entrance.
Searches are not conducted on
visitors because the facility
utilizes non-contact visiting.
Visitation by minors is allowed.
with adult supervision.

Detainees in special hoUsing are afforded visitation.

Legal visitation is available seven (7) days a week, including holidays.

l8I

The visitation schedule and rules are available to the public.

The hours for all categories of visitation are posted in the visitation
waiting area.
A written copy of the rules regulating visitation and the hours of
visitation is available to visitors.

At facilities where there is no provision for visits by minors; ICE .
arranges for visits by children and stepchildren, on request, within the
first 30 days.
After that time, on request, ICE considers a transfer, when possible, to a
facility that will allow minor visitation. At a minimUm, monthly visits
are allowed.
.

On regular business days legal visitation hours are provide for a
minimum of eight (8) hours. per day, and a minimum of four hours per
day on weekends and holidays.
On regular business days, 'detainees are given the option of continuing a
meeting with a legal representative through a scheduled meal.
Private consultation rooms are available for attorney meetings. There is
a mechanism for the detainee and his/her representative to exchange
documents.
There are written procedures goveI;lling detainee searches.

181

IZI

o
o

Detainees in special housing are
afforded visitation. .
Legal visitation is available
seven days a week including
holidays.
Legal visits occur as needed.

Private consultation rooms are
available for attorneys'
meetings.

FOR OFFICIAL. USE ONLY (LAW ENFORCEMENT SENSITIVE)
G·324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 07109107

' ; / - ; ' .' .<~

.....: . "

VISITA'UON(

. : ;.

· ' Cr .

:~tiF('~~;~AINEE8;'~~;f~}.~~~~.~~~ors.~~~·.
When strip searches are required after every contact visit with a legal
representative, the facility provides an option for non-contact visits with
legal representatives.
.
Prior to each visit, legal service providers and assistants are identified
per the standard.

181

!'VI

IC:>I

The current list ofpro bono legal organizations is posted in the detainee
housing areas and other appropriate areas.
The decision to permit or deny a tour is not delegated below the level of
Field Office Director.
Provisions for NGO visitation, as stated in the'Detention Standards, are
complied with.
Law enforcement officials who request to visit with a detainee are.
referred to the ICE Field Office for approval.
Former detainees or aliens in proceedings, requesting to visit with a
detainee, are ·referred to the OlC or ICE Field Office.
'
Procedures ate in place, consisten,t with the detention standard, for
examinations by independent medical service providers and experts.

181 ACCEPTABLE

DEFICIENTD AT-RISK

The list of pro bono legal
organizations is posted in the
housing units.

o REPEAT FINDING

REMARKS:

Policy # MTC 5.2.1, entitled "Visitation" dated September 16,2008, provides guidance regarding detainee visitation. Non-contact
visiting is allowed weekly from 5:30 PM through 8:00 PM Monday through Friday and 12:00 PM through 3:00 PM Saturday and
Sunday. Visitation schedule and rules are available in the visiting lobby; Visitation rules are also available in the detainee handbook.
The visitor dress code is available in the front entrance. Detainees in special housing are afforded visitation.

56,b7c

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITNE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07
h

___

""'"

_.c n.n

:~.,:;;,::: ;'.. ' _ _ . ' . : . ,

"'" VOLUNTARYWOlU{PROGRAM,'

. ,

",..

o
o

Detainees have the opportunity to participate in special details, however,
are never allowed to work outside the secure perimeter.
Written procedures govern selection ofdetainees for the Voltmtary Work
Program.
Where possible, physically and mentally challenged detainees participate
in the program.
The facility complies with work-hour requirements for detainees, not
exceedirig:
" . Eight hours a day and Forty hours a week.
Detainee volunteers generally work according to fixed schedule.
If a detainee is removed from a work detail, staff places the written
justification for the action in the detainee's detention file.
Staff. in 'accordance 'with written procedure, ensures that detainee
volunteers understand their responsibilities as workers before they join
die work program.
'

The voltmtary work program meets:
• OSHA, NFPA, ACA standards
Medical staff screen and fOlmally certifY detainee food service
volunteers.
• 'Before the assignment begins; and
•
As a matter of written procedure
Detainees receive safety equipment! training s1Jfficient fur the' assignment.
Proper procedure is followed when an ICE detainee is injured on the job. '

IZI ACCEPTABLE

DEFICIENT

,t8l

.0 AT-RIsK

. ; ..

~:~

Does the facility have a voluntary work program?
• Do ICE detainees participate?
Detainee housekeeping meets neatness and cleanliness standards.

o
o

:: ..

Sanitation in the housing units
was found to be acceptable.

D
D

All detainees are given an
opportunity to participate in the
voltmtary workprogram.

All work schedules are fixed.

D
Pre-employment orientation
training includes educating the
detainees on their
.
responsibilities as workers'
within the voluntary work
p.1"0gram.

All detainees assigned to food
service were medically cleared.

Safety training is provided
during the initial orientation
class.

[]

REPEAT FINDING

REMARKS

'The Otero County Processing Center, Volun4ler Work Program provides detainees with the opportunity to work and earn money.
Whilenot legally required to do so, ICE affords working detainees basic Occupational Safety and Health Administration (OSHA)
protections.

bB,We

I Se tember 18 2008

AUDITOR'S' SIGNATURE I DATE

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 07/09/07

SECTION II

HEALTH SERVICES STANDARDS

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE) .
G-324A Detention Inspection Form Worksheet for IG8As - Rev: 07/09/07

When a detainee has refused food for 72 hours, it is standard practice for
staff to refer him/her to the medical department.
~

CDFs and IGSAs immediately report a hunger strike to the ICE.
The facility has established procedures to ensure staff respond
immediately to a hunger strike.
Policy and procedure require that staff isolate a hunger-striking detainee
from other detainees.
• If yes, in an observation room?
Medical personnel are authorized to place a detainee in the Special
Management Unit or a locked hospital room.
Medical staff records the weight and vital signs of a hunger-striking
. detainee at least once every 24 hours.
The OIC of the facility obtains a hunger striker's consent before medical
treatment.
A signed Refusal of Trea1ment form is required of every detainee who
rejects medical (Waluation or treatment.

During a hunger strike, staff document and provide the hunger-striking
. detainee three meals a day.
Staff maintains the hunger striker's. supply' of drinking water/other
beverages.
During a hunger strike, staff removes all food items from the hunger
striker's living area.
Staff is dffected to record the hunger striker's fluid intake and food
consumption; .Does staff always use HlUlger Strike Monitoring Form 1839 or similar IGSA form.
The me.dical staffhas written procedures for treating hunger strikers.
Staff documents. all treatment attempts, including attempts to persuade
.
hunger striker of medical risks.
Staffbas received training in identification of hunger strikes. Medical
staff receives early training in hunger-strike evaluation and treatment.
Staff remains current in evaluation and treatment techniques.

~ ACCEPTABLE.

DDEFICIENT

D AT-RIsK

o
o

o
o
o

This element is fully addressed
in both policies

o
o

. Management & Training
Corporation, Otero County
Emergency Action Plan, Section
Twelve, Hunger Strike
Emergency Plan, and Physician
Network Association Policy A4012, Hunger Strikes, fully
address this standard

This is addressed in the
Physicians Network Association
Policy A-4012, Hunger Strikes,
dated 10/24/2006.

A review of the training plan
and interview with the training
officer found all staff receive
hunger strike training, to include
identification and reporting
. during orientation and during
.the oiigoing training program.

D REPEAT FINDING

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

REMARKS:

The facility has policies addressing hunger strikes. The mental health staff of the contract medical provider, Physicians Network
Association, provides mental health treatment and evaluation for detainees on a hunger strike. All detention staff receives training in
the identification and reporting of hunger strikes. Medica). staff receives training for hunger strike intervention, evaluation, and
treatment.

b6,b70

I September 18.2008

bB bAG

AUDITOR'S SIGNATURE / DATE

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITNE)
G·324A Detention Inspection Form Worksheet fur IGSAs - Rev: 07/09/07

';,:~<;;;;,:::;;.

·:{:t.<·

;,. .:.'.<;:, ACCESSTO.MltDiCALCA1UL •••.

,~',.,<',

,m~~~~~~~~;'tA~",,~~l@~A~-ViOR~~~~~l1m~'
';::':~';\:;::::::'lli£i;;'.·~··:,,·:,coMPoNENTsi·>"::,~ •.

',:.'

Facilities operate a health care facility in compliance with state and local
laws and guidelines.

The facility's in-processing procedures for arriving detainees include
medical screening.
All detainees have access to and receive medical care.
The facility has access to a PHSlDllIS Managed Health Care
Coordinator.
The medical staff is large enough to provide, examine, and treat the
facility's detainee population.

The facility has sufficient space and equipment to afford detainee privacy
when receiving health care.
The medical facility has its own restricted-access area. The restricted
access area is located within the conf'mes of the secure perimeter.
The medical facility entrance includes a holding/waiting room.
The medical facility's holding/waiting room is under the direct,
superviSion of custodial staff.
Detainees in the holding/waiting room have access to a drinking fquntain.
. Medical records are kept apart from other files. They are:
• SecUred in a locked area within the medical unit;
• With physical access restricted to authorized n;tedical staff; and
• Procedurally, no copies made and placed in detainee files.
Pharmaceuticals are stored in a secure area. .

IZI

~'.N·

, NA, : . ':

o
o
o

The policies of the facility and
current medical operating
procedures are in compliance
with state and local laws and
guidelines.

o
o

The Physician Network
Association contractual services
has a :full complement of
medical and mental health
providers which is large enough
to meet the clinical needs of the
detainee population.

[]

"', ."

o
o
o

All pharmaceuticals are stored
in the pharmacy and inventoried
quarterly for expiration dates.
Medications carts are secured in
the pharmacy except when ,
conducting pill lines by clinical
staff. Needles, syringes, and
medical instruments are
inventoried. A daily working
stock of needles and syringes is
maintained on a perpetual
inventory.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for I08As.- Rev; 07109/07

,:.;.,<>:;""

<;' " , . '

'i,t·:· ACCESS TOl\'iEDiCAL CARE'

:.,,';::' ...·····:·:i>:>

f.~~~~~~~~~~~~~~~~~~~y;~~~~··'
Medical screening mcludes a Tuberculosis (TB) test
• Every arriving detainee receives a TB test during the admission
process;
• Detainee's TB-screening does not occur more than one business
day after hislher arrival at the facility; and '.
• Detainees not screened are housed separate from the general
population.
All detainees receive a mental-health screening upon arrival. It is
conducted:
. ,
• By a health care provider or specially trained officer; and
• Before a detainee's assignmentto a housing unit.
The facility health care provider promptly reviews all 1-794s (or
equivalent) to. identify detainees needing medical attention.
The health care provider physically examines/assesses arriving detainees
within 14 days of admission/arrival at the facility.

Detainees in the Special Management Unit have access to health care
services.

Staff provides detainees with health services (sick call) request slips
daily, upon request
• Request slips are available in languages other than English,
including every language spoken by a sizeable number of the
facilitY's detainee population.
• Service-request slips are delivered in a timely fashion to the
health care provider.

The facility has a written plan for the delivery of 24~hour emergency
health care when no medical personnel are o~ duty at the facility, or when
imtnediate outside medical attention is required

All newly arrived detainees
receive a chest x-ray upon
arrival at the facility with an
immediatereadingprovided. If
a questionable finding is
identified the detainee is housed
in the negative pressure rooms
and evaluated by the physician.
All detainees receive a mental
health screening by medical
staff. If a mental health concern
is identified the detainee is
referred to the contract
psychiatrist

A review of30 detainee files
found that ~8 of 30 had a health
appraisal conducted by the
physician assistant within 14 .
days of arrival. One medical
file identified the health
appraisal was completed 17 days
after arrival and one 21 days
after arrival.
Physician Network Association
Policy, Access to Clinical
Services A~3; dated 6/1108,
section 4, addresses medical
staff making daily rounds in the
Special Management Unit
(SMU). A review of the SMU
log identified that medical staff
making rounds for sick call and,
pill lines are documented.
Sick Call request slips are
available fu the units from the
correctional officer and are in
English and Spanish. Once the
detainee completes the request
these are placed in the sick call
box for medical to pick up and
triage. The average time for a
completed sick call request is 24
to 48 hours.
. Physician Network Association
Policy, Emergency Plan A-08,
dated 6/1/08 fully addresses this
element on how to contact
emergency m~caI care and
transport when indi~ted.

FOR-OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09107

The plan includes an on-call provider.
The plan includes a list of telephone numbers for local ambulance and
hospital services.
The plan includes prQcedures for facility staff to utilize this emergency
health care consistent with security and safety.
Detention staff is trained to respond to health-related emergencies within
a 4-minute response time.

I8l

o
Where staff is used to distribute medication, a health care provider
properly trains these officers.
The medical unit keeps written records of medication that .is distributed.

The Form 1-819 (or !GSA equivalent) is used to notity the
WardenlFacility of a detainee that has special medical needs.
A signed and dated consent form is obtained from a detainee before
medical treatment is administered.
Detainees use the 1-813 (or !GSA equivalent) to authorize the release of
confidential medical records to outside sources.
The facility health care provider is given advance notice prior to the
release, transfer, or removal of a detain~e.
Detainee's medical records or a copy thereof, are available and
transferred with the detainee.

Medical records are placed ina sealed envelope or other container
labeled with the detainee's name and A-number and marked "MEDICAL
CONFIDENTIAL".

IZI ACCEPTABLE

DEFICIENT

I8l

OAT-RIsK

o .

All detention staff is trained to
respond to health related
emergencies. The American
Heart Association Life Saver
course to include CPR and First
Aid is provided to all staff.
Only medical staff distributes
medications.
Medication Administration
Records (MAR) are maintained
on all prescribed medications
distributed to the detainees.
Numerous Keep-an-Person
medicatioris are provided to the
deta.iI).ees an~ these medications
are maintained on the MARs. fur
review of compliance.

.The medical summary, to
include medications, infectious
disease status; and a copy of all
pertinent information, is
transferred with the detainee.
The medical record is placed in
a sealed envelope and marked
with the detainee's name and Anumber and sealed with a tape
labeled Medical Confidential.
REPEAT FINDING

REMARKS:

Physician Network Association provides contractual medical staff on site 24 hours a day. Medical staff includes a physician, a
physician assistant, one dentist, a dental assistant, a director of nursing, seven RNs, five LVNs, two medical records administrators,
three general clerks, a mental health social worker, a psychiatrist, aD. x-ray technician, a pharmacy and supply manager, an assistant
health services administrator, and the health services administrator. The physician provides oversight and supervision of the physician
assistant The physician is on site two days a week and the phYsician assistant provides oD$ite cove~e five days a week. Thomason
General Hospital in El Paso Texas provides in-patient and out-patient services.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Fonn Worksheet for !GSAs • Rev: 07/09107

A review of 30 detainee medical fIles found that 28 have a history and physical examination completed by the physician assistant
within 14 days of arrival. Two detainees' history and physical examinations were completed late.' One ~fthe exams was conducted at
17 days and one at 21 days after the .detainee's arrival.
All detainees receive a chest x-ray to rule out tuberculosis. The radiographic equipment provides a preliminary report of negative or
abnormal findings and then a final report is reviewed by the physician.
All staff is trairied to respond to' health-related emergencies within a 4-minute response time and have received the American Red
Cross Heart Savers course in basic CPR and first aid.
Only medical staff conducts medical and mental health intake screening.

•••illi,MIIII

/ September 18.2008

AUDITOR'S SIGNATURE I DATE

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITNE)
G-324A Detention Inspection Forni Worksheet for IGSAs - Rev: 07/09/07·

'IY-_~~:~~=~

.Every new staff member receives suicide-prevention training. Suicideprevention training occurs during the employee orientation program.

Training prepares staff to:
• Recognize potentially suicidal behavior;
• Refer potentially suicidal detainees, following facility
procedures; and
• Understand an,dapply suicide-prevention techniques.
A health-care provider or specially trained officer screens all detainees for
suicide potential as part of the admission process.
• Screening does not occur later than ·one working. day after the
·detainee's arrival.

·IZI

D
D

Written procedures cover when a'nd how to refer at-risk detainees to
medical staff and procedures are followed. .

The facility has a designated isolation room for evaluation and treatment.

The designated isolation room does not contain any structures or smaller
items that could be used in a suicide attem~.
Medical staffhas approved the room for this purpose ..

Physician Network Association
Suicide Prevention and
Intervention Policy A-32, dated
10/2412006, requires all staff to
receive suicide prevention
training. A review of the
training records and lesson plan
for suicide prevention identified
staff as receiving 2 hours of
training during orientation and
ongoing monthly training
sessions during the "muster"
sessions for correctional staff.
The suicide prevention and
intervention training fully
addresses this element.
Additionally, all staff completes
a post test of understanding of
the policy and intervention
techniques.
Medical staff completes a
mental health intake screening
as part of the adinission process.
If a mental health history is
identified, the detainee is .
referred to the psychiatrist and
placed on the mental health
clinic roster.
.
Management & Training
Corporation Policy 2.1.16,
Suicide Prevention and
Awareness, dated September 8,
2008, and Physician Network
Association Policy Suicide
Prevention A-32, dated
10/24/06, fully address this
standard.
The facility has two cells
identified for special watch
under constantsupervision by a
trained correctional officer.

FOR OFFICIAL USE ONLY ~AW ENFORCEMENT SENSITNE)
G-324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 07/09107
p~~p.

<11 nf SIn

·:~\ )':~:t;:'~~~i~·.·· ..... ,. ,~;:\:r::~··

. ;.

'. -.. -'. -:;.:,.~.: .;~;.. ",.' . ':;., :::::SUlCIDE·pREVENTIO,N··AND mTERVENTlON;<>-':·. .

. , .:"

(1~~~~.7~~tlt~~;=w:=.·.
Staff observes and documents the status of a suicide-watch detainee at
least once every 15 minutes.

. [gI

IZI ACCEPTABLE

D'DEFICIENT

AT-RISK

An officer sits outside the
special watch room and constant
observation is maintained for all
special watches and documented
in the log book.

D REPEAT FINDING

REMARKS:

The MTC Suicide Prevention and Awareness Policy #2.1.16 and the Physician Network Association Suicide Prevention Policy A-32,
fully address how to handle a potentially suicidal detainee to include supervision, referrals, and housing of the detainee.
All detention staff working with ICE detainees has received suicide prevention and intervention training during orientation and
ongoing training. The lesson pIan fully addr~sses how to recognize potential suiCidal behavior, understand and apply suicide
prevention techniques, and the referral to medical and mental health providers.

b6,b7c

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Fonn WOIksheet for IGSAs - Rev: 07109/07

/:;:'I}r;~!i~~:!!'?t·"J"""':;~:::'n;'.:T~~~,;"Ij~S~,:~~~~D DI~~~r:~~ ~ PE.A~.'·". ' :

. '

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,:Poucv)\LLfACJtITIES HOUSINGICEDETAlNEESS'HALtIiAVEl>OUC1ES ANDPROCEPQREsADDRESsiON'GTHEISSUESOFTERMINAL ILLNESS OR

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,.. ,::::: . . . . ".;:'"
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C,'

Detainees who are chronically or terminally ill are transferred to an
appropriate offsite medical facility.

The,facility or appropriate ICE office promptly notifies the next of kin of
the detainee's medical condition, to include: .
• The detainee's location; and
• The limitations placed on visiting.
There are guidelines addressing the State AdvancedDirective Form for
Implementing Living Wills and Advanced Directives.
• The guidelines include instructions for detainees who wish to
have a living will other than the generic form the DIHS provides
or who wishes to appoint another to make advance decisions for
him or her.
The guidelines provide the detainee the opportunity to have a private
attorney prepare the documents.

There is a policy addressing "Do Not Resuscitate Orders"
Detainees with a "Do Not ResusCitate" order in the medical record
receive maximal therapeutic efforts short of resuscitation?
The facility notifies the DmS Medical Director and Headquarters' Legal
Counsel ofthe name and basic circumstances of any detainee with' a "Do
Not Resuscitate" order in the medical record. In the case oflGSAs, this
notification is made through the local ICE representative.
The facility has written procedures to address the issues of organ
. donation by detainees.
The fac~ty has written procedures to notifY ICE officials, deceased
fiunily members and consulates, when a detainee dies while in Service.

o
o

Management & Training
Corporation (MTC) Policy
6.5.1, TenninalllIness, Advance
Directives, and Death, dated
August 27,2008 Section A 1
and Physician Network
Association Policy B-23, dated
10124/06, fully' address this
element.

Physician Network Association
Policy Section B Living Wills
and Advance Directive does not
ad,dress having a private
attorney prepare the document.'
During the review process a
revised policy waS provided to
the health service administrator
to include guidelines to provide
an' opportunity to have a private
attorney prepare the documents.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITNE)
G-324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 07/09/07

: ,y;< ,;:) "'i::;,,':';;':"
, rEJll\fINALILLNESS, ADVANCED D~CTIVES, AND DEAm
.
',.<:~(.:.:::::

""'.':

.y:

The facility has a policy and procedure to address the death of a detainee
while in transport.
At all ICE locations the detainee's remains disposed of in accordance
With the provisions detailed in this standard.
In the event that neither family nor consulate claims theremains, the Field
Office schedules an indigent's burial, consistent with local procedures. '
• Ifthe detainee's is a U.S. military veteran, is the Department of
Veterans Affairs notified?

An original or certified copy ofa detainee's death certificate is placed in
the subfect's a-file.
The facility follows established policy and procedures describing when to
contact the local coroner regarding such issues as:
• Perfonnance of an autopsy;
• Who will perform the autopsy;
• Obtaining state approved death certificates; and
• Local transportation of the body.
ICE staff follows established procedures to properly close the case of a
deceased detainee.

IZI ACCEPTABLE

DEFICIENT

".:.

o
AT-RIsK

",REMARKs

',N/ 'NA:>

ThiS element is not addressed in
. either policy. During the review
process a revised policy was
provided to the health service
administrator to address this
element.

The local ICE agent indicates
appropriate procedures are
followed to close the case of a
deceased detainee.

D REPEAT FINDING

REMARKS:

The facility has policy and procedures addressing terminal illness, advanced directives, and death. The local ICE agent indicates
appropriate procedures are followed to close the case of a deceased detainee.
DUring the review process, policies were revised to fully address advanced directives, specifically the opportunity to have a private
attorney prepare the documents. The Death of a Detainee policy was revised to identifY whether a detainee is a U. S. military veteran.
in which case, the Department of Veterans Affairs is notified.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)'
G-324A Detention Inspection Form Worksheet for 108As - Rev: 07109/07

SECTION III

SECURITY AND CONTROL STANDARDS

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Fonn Worksheet for IGSAs • Rev: 07109io7

ti._.~~;~~~~~~i·~~~;&AT~{~<..

I~;;';;:~ir?',;"(/;;:,;g; ,...,:"'/\;C()MPONENTsi.'·:··>i'i.•. :"::,:;>[.::;,';:-2:'

The facility follows a written procedure for handling illegal contraband.
Staff inventory, hold, and report it when necessary to the proper authority
for action/possible seizure.

·;Y';·,' N·. ···NA '.".,"

181

o
o

Contraband that is government property is ~ retained as evidence for
potential disciplinary action or criminal prosecution.

Staff returns property not needed as evidence to the proper authority.
Written procedures cov~ the return of such property.
Altered property is destroyed following documentation and using
established procedures.
Before .confiscating religious items, the Ole or designated investigator
contacts a religious authority.
Staff follows written procedures when destroying hard contraband that is
illegal.
Hard contraband that is illegal (under criminal statutes) may be retained
and used for official use, e.g. training purposes.
If yes, under specific circumstances and using specified written
procedures. Hard contraband is secured when not in use.

181 ACCEPTABLE

DEFICIENT

OAT-RISK·

."";:.

REMARKS .............

Management & Training
Corporation, Operational
Policies and Procedures No.
2.3.1, Subject-Contraband.
addresses· properly handling
contraband.
Confiscated government
property is forwarded to the
shift supervisor who initiates a
process assigning a control
number to all contraband and
placing it in the evidence box
located in central control. All
evidence in the evidence box is
only removed by the chief of
security or higher authority.
MTC policy 2.3.1 addresses
proceduresforDehu!Ung
property not needed as evidence
to the proper authori.ty.

The facility armory officer is
designated to destroy hard
contraband with at least one
witness to the destiuction.

REPEAT FINDING

REMARKS:

A review oflocal policy, confiscation documentation, and interviews with staff indicate contraband is confiscated, stored, and
destroyed in a manner which is consistent with accepted correctional practice. There is an effective system of control to ensure all
contraband is accounted for andlor forwarded to the appropriate. authority.

56 bYG

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

....

::.

';" .

:'~>;

·D~TENTION!iLES<·

...•.... :

A detention file is created for every new arrival whose stay will exceed
24 hours.
The detainee detention file contains either originals or copies of
documentation and forms generated during the admissions process.

.: ......:

'.. .. ..... . >.}/}>: .'

IZI

The detainee's detention file also contains ddcuments generated during
the detainee's custody.
• Sp~ial requests
• . Any G-589s andlor I~ 77s closedo..{)ut during the detainee's stay
• Disciplinary forms/Segregation forms
• Grievances, complaints, and the dispqsition(s) of same _
The detention files are located and maintained in a secure area !fnot, the
cabinets are lockable and distribution ofthe keys is limited to supervisors.
The detention file remains active during the getainee's stay. When the
detainee is released from the facility, staff adds copies of completed
release dOcuments, the original closed-out receipts for property and
valuables, the original 1-385 or equivalent, and other documentation.

The officer closing the detention file makes a notation that the file is
complete and ready to be archived.

Staff makes copies and sends documents from the file when properly
or office.
Appropriate staffhas access to the detention files, and other departmental
requests are accommodated by making a request for the file. Each file is
properly logged out and in by a representative of the responsible
department.
requ~ted by supervisory personnel at the receiving facility

~ ACCEPTABLE

DDEFICIENT

AT-RISK

Detention files are created for
all detainees.
A review of25 active files and
10 inactive files reveals the files
contain documentation and
forms generated during theadmissions process.
A review of the detainee
detention files indicates they
contamall documents generated
duiing the detainee's custody.
Detention files are in a secured
area.
Release paperwork (1-203's) was
not maintained in the detainee
files. The facility corrected this
issue and started filing the
releasepaperwotk in the
detainee files.
Staff makes notations that the
file is complete and ready to be
archived.

D REPEAT FINDING

REMARKS:

The facility creates a detention file for every ICE detainee booked into the facility. A review of the detainee detention files indicates
they contain all (tocUttlents generated during the detainee's custody. Detention files are in a secured area and only appropriate staffhaS
access to the files.

b6,b7e

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Fonn Worksheet for IOSAs - Rev: 07/09/07

. POLICY:/ALt·PACILlUES"HOtlSlNG,'ICB DETAINEES' AlffiAumc>RIZED'rO IMPOSE DISCIPI.;lNEONDETAlNEES WHOSE BEHAVIOR IS NOTlN

:·,;:":j:.:'f:':_:~~~~~E~:~~~!%t~~~?~~~Sl.::.\· .';: •. ;

~ .•• ~' ••.•...... NA:~;::·.· . ·:.•·.··RE~·

The facility has a written disciplinary system using progressive levels of
reviews and appeals.

The facility rules state that disciplinary action shall not be capricious or
retaliatory.

Written rules prohibit staff from imposing or permitting the following
sanctions:
• corporal punishment
• deviations from nonnal food service
• clothing deprivation
• bedding deprivation
• denial of personal hygiene items
• loss of correspondence privileges
• deprivation of physical exercise
The rules ofconduct, sanctions, and procedures for violations are defined
in writing and communicated to all detainees verbally and in writing.

Detainees are informed verbally
ofthenliesofconductduring
the intake process. The
information is also contained in
the detainee handbook.

An inspection ofsix detainee
living areas revealed the
discipline criteria is posted.

IZI

The following items are conspicuously posted in Spanish and English,
and other dominate languages used in the facility:
• Rights and Responsibilities
• Prohibited Acts
• Disciplinary Severity Scale .
• Sanctions
When minor rule violations or prohibited acts occur, infolllllil resolutions
are encouraged.
Incident reports and Notice of Charges are promptly forwarded to the
designated supervisor.
'

Incident reports are investigated within 24 hours of the incident The
. Unit Disciplinary Committee (UDC) or equivalent does not convene
before an investigation ends.
An intermediate disciplinary process is used to adjudicate minor
infractions.

Management & Training
. Corporation, Operational
Policies and Procedures No.
6.3.1, Subject-Disciplinary
Procedures, addressees a
progressive system of discipline
and appeals.
A review of the facility policy
6.3.1, Subject-Disciplinary
Procedures, includes the
statement that discipline shall
not be capricious or retaliatory.

The facility shift lieutenant is
responsible for adjudication of
minor infractions.
The facility discipline
procedures require staff to
forward disciplinary reports to
the shift supervisor prior to
completing their shift.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G·324A Detention Inspection Forni Worksheet for IGSAs • Rev: 07/09107

~m~
A disciplinary panel (or equivalent in IG8As) adjudicates infractions.
The panel:
• Conducts hearings on all charges and allegations referred by the
UDC;

Considers written reports, statements, physical evidence, and
,
oral testimony;
• Hears pleadings by detainees and staff representatives;
• Bases its findings on the preponderance of evidence; and
• hnposes orily authorized sanctions
A staff representative is available if requested for a detainee facing a
discipIinary hearing.

The facility permits hearing postponements or continuances when
conditions warrant such a continuance. Reasons are docwnented.
The duration of punishinent set by the 'OIC~ as recommended by the
discipIinary panel, does not exceed established sanctions. The maximwn
time in disciplinatY segregation is limited to 60 days for a single offense.
Written procedures govern. .the handling of confidential-informant
information. Standards include criteria for recognizing "substantial
evidence"
All forms relevant'to the incident, investigation, committee/panel reports,
etc., are completed and distributed as required.

0' DEFICIENT

IX! ACCEPTABLE

The chief of security
(disciplinary hearing officer)
adjudicates infractions.

MTC Operational Policies and
Procedures, No. 6.3.1, SubjectDisciplinary Procedures,
reference a staff representative
during disciplinary hearing.

o
o

•

D
I:8l
AT-RISK

o
o
o
D REPEAT FINDING

REMARKS:

A review of the discipline policy and practical application of th~ process revealed staff are well-trained, proficient, and knowledgeable
of the discipline process. Interviews of detainees in living areas and SMU indicate detainees are treated fairly and understand the
discipline process.

.. .

b6,b7c

8e tember 18 2008
TURE/DATE

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324ADetention Inspection Form Worksheet for IGSAs - Rev: 07109/07

,!R~.1Ic.~~!s~
Policy precludes detainees or detainee groups from exercising control or
authority over other detainees.

Management & Training
Corporation, Operational
Policies and Procedures, No.
2.1.8, Subject-Detainees
Control and Movement, section
(e) states, liN0 detainee or
groups of detainees shall be
given authority over other
detainees.
MTC Operational Policies and
Procedures, No. 6.1.2, SUbjectDetainee Rights, section (c)
states, "Detainees will not be
subject to personal abuse,
corporal punishment, personal
injury, disease, property
damage, or harassment The
personal property of detainees
will be protected."
The facility staff received
training in communication
skills, detainee supervision,
manipulation, and fraternization
during in-service and preservice training.
The facility supervisory staff
di"S'shift~rnM~Dateste O~ationtaffduring
. us r prIor to s
going on duty.
The warden is the designated
person responsible for
emergency plans and their
implementation.
II

Detainees are protected from:
• Personal abuse
• Corporal punishment
• Personal injury
• Disease .
• Property damage
• Harassment from other detainees

Staff is trained to identify signs of detainee unrest.
• What type of training and how Clften?

Staff effectively disseminates information on facility climate, detainee
attitudes, and moods to the Officer In Charge·(OlC)
There is a designated person or persons responsible for emergency plans
and their implementation. Sufficient time is allotted to the person or group
for development and implementation of the plans.
The plans address the following issues:
• Confidentiality
• Accountability (copies and storage locations)
• Annual review procedures and schedule
• Revisions
Contingency plans·. include a comprehensive general section with
.J>1'ocedures applicable to most emergency situations.
The facility has cooperative contingency plans with applicable:
• Local law eilforcement agencies
.
• State agencies
• Federal agencies

inti"

The facility does not have
cooperative contingency plans .
with local, state, and federal
law enforcement agencies.

FOR OFFICIAL USE ONLY(LAW ENFORCEMENT SENSITNE)
G-324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 07/09107

.~': :~i~>.:. :::;";.

:.': :; .... .<;;:::.. ~:J, .~:" ;":',: '. :~~.:..;:: :'(;~. ' .":--:>.:

":..~ ;i).: .~\ :::.<:..,'

:·;:';.EME:RGENCY·{coNTiNGEN¢¥lPLAN~j"\...·.·

c~§j• •~e~·.
/;'::,j:6:i~clL','~/:'·::S:,::/:~;:Y:\COMPoNEilfiS"\:::,;;/<":;'~ .>,,);«:,< y:,,":.;';'N'

All staff receives copies of Hostage Situation Management policy and
procedures.

Staffis trained to disregard instructions from hostages, regardless of rank.
Within 24 hours after release, hostages are screened for medical and
psychological effects.
Emergency plans include emergency medical· treatment for staff and
detainees during and after an incident.
Food service maintains at least 3 days' worth of emergency meals for staff
and detainees.
Written plan,s identify locations of shut-off valves and switches for all
utilities (water, gas, electric)~
Written procedures cover:
• WorkIFood Strike
• Disturbances
• Escapes
• Bomb Threats
• Adverse Weather
• Internal Searches
• Facility Evacuation
• Detainee Transportation System Plan
• Internal Hostages
• Civil Disturbances

IZ1 ACCEPTABLE

DDEFIClENT

OAT-RISK

'NAt:,.'" '·:REMARKs;'::',

The facility staffhas access to
hostage management policy on'
D. the computer share directory
that is located in the
administration area.

o
o

During the review it was noted
the facility emergency plans do,
not cover written procedures for·
WorkIFood Strike. However,
on 9-18-08, management staff
developed written procedures
for WorkIFood Strike.

o REPEAT FINDING

REMARKS:

The facility does not have cooperative contingency plans with loca~ state, and federal law enforcement agencies.

.• I

DB, bYe
••

/.s tember 18 2008
•

TURE/DATE

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITNE)
G-324A Detention Inspection Form Worksheet for IG&As - Rev: 07/09/07

The facility has a system for storing, issuing, and maintaining inventories
of hazardous materials.

o
Constant·inventories are maintained for all flammable, toxic, and caustic
substances used/stored in each section of the facility.
The manufacturer's Material Safety Data Sheet (MSDS) file is up-to--date
for every hazardous substance used.
• The files list all storage areas, and include a plant diagram and
legend.
.
• The MSDSs and other infonnation in the files are available to
personnel managing the facility's safety program.
All personnel usmg flammable, toxic, and/or caustic substances follow
the prescnbed procedures. They:
• Wear personal protective equipment; and
• Report hazards and spills tQ the designated official.
The MSDSs are readily accessible to staff and detainees in work areas.
Hazardous materials are always issued under proper supervision.
• Quantities are limited; and
• Staff always supervises d(!tainees using these substances.
All "flammable" and "combustible" materials (liquid and aerosol) are
Stored and used according to label recolnmendations.
Lighting fixtures and electrical equipment installed in storage rooms and
other hazardous areas meet National Electrical'Code requirements.

o .

o . D.
o

The facility does have a system
for the storage, issuance and
inventories of hazardous
materials. Local policy 1.3.6
"Control of Flammable, Toxic,
and Caustic Materials" mdicates
program particulars.
Constant inventories are being
maintained.

Material Safety Data Sheets
were not available for items
stored in the food service dining
room chemical closet.
All staff members receive
training pertaining to the OSHA
1910.1200 "Hazard
Communication" standard.
MSDSs are readily available to
staffand detainees.
.
Observations and interviews
concluded that hazardous
materials are under proper
supervision.
Flammable and combustible
materials are stored properly.
There was no evidence of
electrical fixtures not meeting
National Electric Code
requirem~nts.

The facility has sufficient ventilation, and provides and ensures clean air
exchanges throughout all buildings.

Vents return vents,and air conditioning ducts are not blocked or
. obstructed in cells or ·anywherein the facility.

Living units are maintained at appropriate temperatures in accordance
with industry standards. (68 to 74 degrees in the winter and 72 to 78
degrees in the summer.)
Shower. and sink water temperatures do not, exceed the industry standard
of 120 degrees.
All toxic and caustic materials are stored in their original containers in a
secure area.

The facility appears to have
adequate ventilation and air
exchanges in all areas;
There was no evidence of vents.
or ducts being blocked or
obstructed.
Living unit temperatures were
observed to be within prescribed
temperature parameters.
Shower and sink water
temperatures did not exceed 105
degrees.
All toxic and caustic materials
are stored in their original
container and properly secured.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07109/07

Pruze 52 of 80

~~j'··:;~~.~~:::;:::=~~~~A~~-=~TIffi
nm

:P;R(j(f"

: JN9LUD~;,AMONG OTHER THINGS,

IDENTIFICATION AND LABE~G OF.HAZARDOUS' MATERIALS IN ACCORDANCE WITH

:;~_{~~~ti:_~~:(»)~:,~,~o/EciI?N.~SO~rAtIO~.~~~)~.~tm~ICATI~~.~~;~~~~A~r~~~;·~.'· •
.;;;.'l?/'(;Y:X;;':\!~..

«:'·COMPO:NENTs'··<;:':Y:·>,;d.~\:NA>:

Excess flammables, combustibles, and toxic liquids are disposed of
properly.and in accordance with MSDSs. '
Staff directly supervise and account for products with methyl alcohoLStaff receives a list of products containing diluted methyl alcohol, e.g.,
shoe dye. All such products are clearly labeled. "Accountability"
includes issuing such products to detainees,in the smallest workable
. quantities. .
.
Every employee and detainee using flammable, toxic, or caustic. materials
receives advance training in their use, storage, and disposal.
The facility complies with the most current edition of applicable codes,
standards, and regulations of the National Fire Protection Association and
the Occupational Safety and Health Administration (OSHA).

. (gI

o
o

The Safety Office (or officer) maintains files of inspection reports.

. The plan requires:
• Monthly fire inspections;
• Fire protection equipment strategically located throughout the
facility;
• Public posting of emergency plans with accessible
building/room floor plans;
• Exit signs and directional arrows; ~d
• An area-specific exit diagram conspicuously posted in the
diagrammed area.

A technically qualified officer conducts the fire and safety inspections.

The facility has an approved fire prevention, control, and evacuation plan.

Fire drills are conducted and documented monthly.

>, ,"

G-324A Detention Inspection Fom Worksheet for IGSAs -- Rev: 07/09/07

" .

Staff directly supervises methyl
alcohol products.
Employees and detainees do
receive training in chemical
usage.
All areas, with the exception of
a secondary means of egress
from the Food Service
'
Department appear to be
compliaitt with published NFPA.
and OSHA regulations and/or
guidelines.
The facility employs a full time
safety man.ager.
The safety officer (risk
manager) maintains files of all
inspection reports.
The facility is currently
developing a fire· prevention,
control and evacuation plan.
Certain elements of the fire plan
are in place. However, the .
facility does not currently have a
comprehensive approved fire .
plan; Additionally, most areas
of the facility do not have exit
signs with directional arrows
installed. The contractor has
been made aware of this
deficiency. Furthermore, the
contractor acknowledged the
deficiency in a letter dated
Septeinber 17, 2008. Exitlights
are to be ordered and delivery
expected on September 23. '
.2008.
. Fire drills II1'e conducted on a
monthly basis. Emergency keys
are not drawn to unlock
emergency exit doors not in
daily use;

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
.

REMARKS

:;~.,,; .··.,r'.,,::·::y::";:',.:ei;.c::::'\:~:';':, >:;,;~?~~fL.~~T~;~,~,~E;&r-,':":
','PO~~:~VERY,FAmItYvhLLcoNiROL~LE, TO~,ANDCAUSTIC~TE~ ~Ot1GHAHAZAiIDOUSMATERJALSPROGRAM. TIffi·• ·•

[_.it~~G~~TIt!~~~~~s~~~~~~,.
:'/"\;f:{,(

::.<ii"·,',: COMPoNENT8:,;·''''':b: ','il'
A sanitation program covers barbering operations.

.The barber shop has the facilities
sanitation requirementS.

··::Y/~

I8l

>·;N<:

equipment necessary to meet

The sanitation standards are conspicuously pQsted in the barbershop.
Written procedures regulate the handling and disposal of used needles
and other s~ objects. .
All items representing potentia! safety .or security risks are inventoried
and a designated individual checks this inventory weekly.
Standard cleaning practices include:
• Using specified equipment; cleansers; disinfectants and
detergents.
• An established schedule of cleaning and follow-up inspections.

o
o

A licensed medical waste contractor disposes ofinfectiouslbio-hazardous
waste.

Staff is trained to prevent contact with blood and other body fluids and
written procedures are followed.

Do the methods for handling/disposing of refuse meet ail regulatory
requirements?

•

The fucility follows standard cleaning procedures.
Spill kits are readily available.
.

A licensedlCertifiedlTrained pest-control professional inspects for
rodents, insects, and vermin. .
• At least monthly.
• The pest-control program includes preventative spraying for
indigenous insects.
Drinking water and wastewater is routinely tested according to a fixed
schedule.

. 'REMARKs
Local policy 1.1:1, Facility
Sanitation & Maintenance,'
covers all areas of the facility.
The barbershop does have the
facilities and equipment
necessary to meet sanitation
requirements.
Sanitation standards are posted
in the barbershop.
Local policy 2.4.4 "Access to
Keys, Tools and Utensils"
stipulates the handling of used
needles and other sharps.
Items representing a potential
safety or security risk are being
inventoried on a daily basis.

Local policy 1.1.1 "Facility
Sanitation and Maintenance"
specifies sanitation and
inspection standards.
Standard cleaning procedures
are located hllocall'olicy 1.1.1.
Spill kitS were not readily
available in any area of the
facility.
Stericycle is the contractor
handling medical waste for the
faci1i!y.
All staff is trained in the OSHA
'blood borne pathogen standard
29 CPR 1910.1030.
The facility maintains a contract
with EI Paso Disposal for refuse
removal.
The facility maintains a contract
for pest control services with
Continental Termite & Pest
Control. Monthly services are
provided under the contract.
Water testing and analysis is
provided by the University of
New MeXico.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection FO.nn Worksheet for IGSAs - Rev: 07/09/07

11.~M~.ii~~~~
>:;\tL/"'}:·:,::·.;:~;i·:~"COMPONENT8"

' , . ) ;",:',
·'y':,'N\".NA
Emergency power generators
tested at least every two weeks.
• Other'emergency systems and equipment receive testing at least
quarterly.
• Testing is followed-up with timely corrective actions (repairs
and replacements).

are

·0 ACCEPTABLE

~ DEFICIENT.

D AT-RISK

. . ' REMARKs :'., <,;

Documentation of emergency
generator testing was not
available.

D REPEAT FINDING

REMARKS:

All areas of the' Environmental Health and Safety components were thoroughly reviewed for compliance'with published ICE standards
andguidelfues.
The Material Safety Data Sheets (MSDS) fu the Food Service Department are not up-to-date for every hazardous substance.
The facility- does not comply with the most current edition of applicable codes,.standards, "and regulations of the National Fire
Protection Association and the Occupational Safety and Health A~fuistration (OSHA). The two doors in each of the detainee dinfug
areas, which seat approximately ISO, do ~ot have two exits (per area) that are remotely located from each other, as specified by the
following NFPA 101 Life Codes.
NFPA 101,4.5.3, Means of Egress
4.5.3.1, Nwilber of Means of Egress. Two means of egress, as a minimum, shall be provided in every building or structure, section,
and area where size, occupancy, and arrangement endanger occupants attempting to use a single means of egress that is blocked by fire
or smoke. The two means of egress shall be arranged to mfuimize the possibility that both might be rendered impassable by the same
emergency condition.
NFPA 101,7.5, Arrangement of Means of Egress.
7.5.1.3. I. Where more than one exit is required from a building or portion thereot: such exits shall be remotely located from each
other and shall be arranged and constructed to minimize the possibility that more than one has the potential to be blocked by anyone
fire or other emergencY condition.
7.5.1.3.2, Where two exits or exit access doors are required, they shall be located at a distance from one another not less than one-half
the length of the maximum overall diagonal dimension of the buildfug or area to be served, measured in a straight line between the
nearest edge of the exit doors or exit access doors, unless otherwise pro~ded in 7.5.1.3.3 through 7.5.1.3.5.
7.5.1.3.3 In buildings protected throughout by an approved supervised automatic sprfukler system fu accordance with Section 9.7, the
minimUIil separation distance between two exits or exit access doors measured maccordance with 7.5.1.3.2 shall be not less than onethird the length of the maximum overall diagonal dimension of the buil~g or area to be served
7.5.1.3.6 Where more than two exits or exit access doors are required, at least two of the required exits or exit access doors shall be
. .
.arranged to comply with the minimum separation distance requirements.
7.5.1.3.7 The balance of the exits or exit access doors specified in 7.5.1.3.6 shall be located so that, ifone becomes locked, the others
shall be available.

NFPA 101,7.5.2, Jmpediments to Egress.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITNE)
G-324A Detention InSpection Form Worksheet for IGSAs - Rev: 07/09/07.

7.5.2.1 Access to an exit shall not be through'kitchens, storerooms other than as provided in Chapter 36 and Chapter 37, restrooms,
workrooms, closets, bedrooms, or similar spaces or other rooms or spaces subject to locking, unless passage through such rooms or
spaces is pennitted for the occupancy by Chapter 18, 19, 22 or 23. Chapters 22 or 23 do riot allow passage through kitchens.
The facility does not have an approved fire prevention, control, and evacuation plan. The plan requirements should include monthly
fire inspections; fire protection equipment strategically located throughout the facility; public posting of emergency plans with
accessible building/room floor plans; exit signs and directional arrows; and area-specific exit diagram conspicuously posted in the
diagrammed area. Additionally, NFPA Life Safety Code 101, Chapter 7 requires the installation of illuminated exit signs with
directional arrows throughout the facility.
Fire drills are conducted and documented monthly. However, emergency keys are not drawn and used to unlock one set of emergency
exit doors.
.
Spill kits are not readily available.
There was no documentation available to indicate that emergency power generators are tested at least every two weeks. Additionally,
there was no evidence or documentation to indicate that the generator is receiving quarterly testing and servicing from and external
generator servicing company.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheetfor IGSAs - Rev: 07/09/07

.",t-

..... ";'.:

rooms are well ventilated well lighted, and. all activating
located outside the room.
detainees

The facility has 3
within
secure nerimf!ter
The hold rooms conform to ICE

!XI

IZI

contraband

Officers closely supervise the detention hold rooms using direct
supervision (Irregular visual monitoring.).
Hold rooms are irregularly monitored every 15 minutes.
• Unusual behavior or complaints are noted.

181

D·
D REPEAT FINDING

Male

other.

females are segregated from

Detainees under the age of 18 are not held with adult detainees.
Detainees are provided with basic personal hygiene items such as water,
soap, toilet paper, cups for water, feminine hygiene items, diapers and

•

the last ctetiam~~e has been removed from the

room, it is given

There is a written evacuation plan that includes a designated officer to
remove detainees from hold rooms in case of fire and/or building
evacuation.
An appropriate emergency service is called immediately upon a
determination that a medical
exist.
.

IZI ACCEPTABLE

DEFICIENT

AT-RISK

Benches are utilized for the
detainees.
During the review detainees
were observed sleepirtg on the
with blankets.
Interview with supervisory
indicated detainees are removed
. from hold room within 6 hours.
The facility does not house
females.
The facility does not house
detainees under the
of 18.

REMARKS:

Hold rooms are used only for temporary detention of detainees awaiting removal, transfer, treatment, intra~facility movement, or other
processing into or out of the facility. An inspection of the hold rooms, whi~h are located in the intake area, revealed the rooms are
constructed and managed in accordance with policy and accepted practices. Hold rooms are constructed well and searched before
. other detainees are placed in the area.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet fur IGSAs - Rev: 07/09107

.';,',

,;st~;,,;'-::t;!I :,~"::,...;,,, . . ,.',},; ':.::(~~~;'~~B~~if~~R~~~CEr

~~#JtJl~~;~,~l~;~'~~~AN~~~nli~~~~~MAnmlNANcEOFi:.·
{COMP.,O$Ni'S<;;~<;·:·J,

The security officer[s], or equivalent in IGSAs,has attended an approved
locksmith training program.

,.'y,

The security officer, dr equivalent in IOSAs, has responsibly for all
administrative duties and res onsibilities relatin tok s, locks etc.
The security officer, or equivalent in IGSAs, provides training to
employees in key control.

The security officer, or equivalent in IOSAs, maintains inventories ofall
keys, locks and locking devices.
The security officer follows a preventive maintenance program and
. maintains all reventive maintenance documentation.
Facility policies and procedures address the issue of compromised keys
and locks.

'. NNA"

I8J

The security officer, or equivalent in IGSAs, develops policy and
procedures to ensure safe combinations integrity.

181 . 0

Oniy dead bolt or dead lock functions are used in detainee accessible
areas.

181

181
181

0
0

Only authorized locks (as specified in the Detention Standard) are used in
detainee accessible areas.

o
o

~------------~----~~~~~~--~~---------+------~--~~~-+

' ....... , REMARKs

The security officer has not
attended an approved locksmith
trainin ro

Review of the facility training
curriculum revealed that staff
received key control training
during in-service and preservice training.

Management Tmining &
Corporation, Opemtional
Policies and Procedures, No.
2.4.1, Subject-Key and Lock
Contro~ addresses the issue of
com romised ke s and locks.

MTC policy Key and Lock
Control procedures provide
direction on the destruction of
worn and discarded ke .

Padlocks and/or. chains are prohibited from u~ on cell doors.

The entrance/exit door locks to detainee living quarters, or areas with an
'
occupant load of 50 or more people, conform to:
Occupational
Safety
and
Environmental
Health
Manual,
Ch. 3;
•
• National Fire Protection Association Life Safety Code 101.
The opemtional keyboard is sufficient to accommodate all the facility key
rin s includ\n keys in use, and is located in a secure area.
Procedures are in place to ensure that key rings are:
• Identifiable;
• The numbers keys are cited; and
• Ke s cannot be removed.

181

b2HIgh

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IOSAs - Rev: 07/09/07

..-:::.;;;.:....~~;

.....

,:";;:,:(~¢®try~ :l1,-_,-,,-,V:L' ... ,~_., ...

o
The facilities use a key accountability system.

D·

AuthOl'IZliUCln is necessary to issue any restricted key.

Individual gun lockers are provided.
• They are located in an area that permits constant officer
observation.
• In area that does not allow detainee or
access.
The facility has a key accountability policy and proced1:U"es to ensure key
accountability. The keys are physically counted daily.

o
All staffmembers are trained and held responsible for adhering to proper
procedures for the handling of keys.
• Issued keys are returned immediately in the event an employee
inadvertently carries a key ring home.
• When a key or key ring is lost, nusplaced, or not accounted for,
the shift supervisor is immediately n~tified.
• Detainees are not permitted to handle keys assigned to staff.
~ ACCEPTAB~E

DEFICIENT .

o
AT-RISK

authorization to issue any
restricted key from the chief of
security, associate warden or the
warden. ,.

Management Training &
Corporation, Operational
Policies and Procedures, No ..
2.4.1, Subject-Key and Lock
Control, address key .
accountability, and keys are
counted on each shift.

o
o REPEAT FINDING

REMARKS:

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G·324A Detention Inspection Form Worksheet for IGSAs· Rev: 07109/07

,~~,;:}t:;f~~}~~;i/:;';F:.:,·" ,'::;\,:)., .' '.' ....... , .p~P~A.~IONC().ti~I~'

..... '..., ....•.. ' ' . . . . , . , : ' . . . . "

. ·POLICV!.AtLDETENTIONFACn:.ITiES SHALLENStJREAROUND:'TIiE;.qocl(ACCOUNTABILIi'YFOJ:tALLDETAlNEES; TmSREQUIRESTHATTHEY

,;;,I~~~r!~~~~~;'~'~~UNTOF THED~~ATh$E~~r~~~~~It~hlri, ~;~Drri~N~,FO~AND OOOlUh\£CbbNTS'
::: i{~ C O M P o N E N i : s · .
Staff conduct a fonnal count at least once each shift.

I.l>:;~;';;~/::;:;:ti):\.":'

Activities cease or are strictly controlled while a formal count is being
conducted.'
CeJ1;a.in <>perations cease dllring formal counts.
All movement ceases for the duration of a formal count.
Fonnal counts in all units take place simultaneously.
Detainee participation in counts is prohIbited.
A face-to-photo count follows each unsuccessful recount
Officers positively identify each detainee before counting himlher as
present.
Written procedures cover itiformal and emergency counts.
• They are followed durfug informal counts and emergencies.

y .'. . ..... N ......

IZI
IZI
IZI
IZI
IZI

0
0
0
II
0

0
1J

IZI

The control officer (or other designated position) maintains an out count record of all detainees temporarily leaving the facility.
This training is documented in each officer's trainin~ folder.

IZ1 ACCEPTABLE

D DEFICIENT

NA.··: :.
REMARKS.; ;
D The facility conducts 8 formal
counts within a 24 hour period.

IZI

IZI
OAT-RIsK

0
D
D

The facility conducts one faceto-photo count per 24 hour
period.

Management Training & .
Corporation, Operational
Policies and Procedures, No.
2.1.9, Subject~Detainees Counts,
addresses written procedures fur
informal and emergency counts.
The count room maintains an
out-count record of all detainees
leaving_ the facility.

o REPEAT FINDING

REMARKS:

Count procedures at the faciliiy are appropriate and are in line with effective accountability practices. The number of counts
performed appears to be adequate to ensure detainees are accounted for. During this review the team members accompanied staffin
the housing units as they performed the 3:45pm count on September 16 and the 11 :OOam count on September 17. One team member
observed the taking of the count in the count room.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G·324A Detention Inspection Fonn Worksheet for IGSAs - ReV: 07/09107

1!~~~;iiI~~~~I~~i~~DWAA~~~~~ffie~ORIlEas•
,'ESt~LIS:aEDF9R:BVERY pOS1}<wmt:::HAREREVJijW~DAi LEASTANNUA'LLY; ANImIVEN TOBACHOFFICERlJPON ASSIGNMENfTOTHATPOST;·

:,;;:\;;rJ~f/c: '/~~;"(':;:\;'\: '·:·'.;'CO~ONENTS:';:i:~:~X:'~:i(::"';'"

,;:;-,\>:;;' .' :y< ',N>"

';:NA:"'> ·REMARKS,~> • :c"'<

Every fixed post has a set of post orders.

. Each set contains the latest inserts (emergency memoranda, etc.) and
revisions.
One individual or department is responsible for keeping all post-orders
current with revisions that take place between reviews.
The IGSA maintains a complete set (central fil~ of~ost orders.
The central file is accessible to all staff.
The OlC or Contract {IGSA equivalent initiates/authorizes all post-order
changes,
TheOlC or Contract {IGSA equivalent has signed and dated the last page
of every section.
A review/updating/reissuing of post orders occurs regularly and at a
minimum. annually.
Procedures keep post orders and logbooks secure from detainees at all
times.
Every armed-post officer qualifies with the post weapon(s) before
assuming post duty.
Anned-post post orders provide :instructions for escape attempts.

The post orders for housing units track the event schedule.
Housing-unit post officers record all detainee activity in a log. The post
order includes instructions on maintaining the logbook.

IZI ACCEPTABLE

DEFICIENT

181

~
~

[]

IZI

181

IZI

During the review the facility
did not have post orders for
outside hospital. However,
management developed post
orders on9-1S-0S.
Transportation post orders were
not maintained on the buses or
vans during escort. They are
maintained in the intake area.

The chief of security is
responsible for keeping all postorders ClUTent with quarterly
reviews.

A review of25 postorders

IZI

IZI
IZI

0
0

OAT-RISK

revealed the warden signed and
dated the fust page.

A review of transportation, and
perimeter post-orders revealed
instructions for escape attempts
are provided.

D REPEAT FINDING

REMARKS:

Transportation post orders were not maintained on the bus or van during escort.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 07/09/07

The facility has a comprehensive security inspection policy. The policy
specifies:
• Posts to be inspected;
• Required inspection forms;
• Frequency of inspections;
• Guidelines for checking security features; and .
• Procedures for reporting weak spots, inconsistencies, and other
areas needing improvement

Every officer is required to conduct a security check ofhislher assigned
area. The results are documented.
Documentation of securi ins ections is ke t on file.
Procedures ensure that recuning problems and a failure to take corrective
action are reported to the ~ppropriate manager. .

The front-entrance officer checks the ID of everyone entering or exiting
the fitCility:
All visits are officially recorded in a visitOr logbook or electronically
recorded.

D. D

181

D
D

The facili has a secure visitor asS s stem.
Every Control Center officer receives specialized training.

o
D

The Control Center is staffed around the clock.

D
D

Policy restricts staff access to the Control Center;

Detainees are restricted from access to the Control Center.
Communications are centralized in the Control Center.
Officers monitor all vehicular traffic entering'and leaving the facilio/.

The facility maintains a log of all incoming and departing vehicles to
sensitive areas of the facility. Each entry contains:
• The driver's name;
• Company represented;
• Vehicle contents;
• Delivery date and time;
• Date and time out;
• Vehicle license number; and
• Name of em 10 ee res onsible' for the vehicle durin the visit
Officers thorou 1
and.1eilvin the facili .

Management & Training
Corporation, Operational
Policies and Procedures, No.
2.1.5, 'Subject-Patrols and
Inspections, includes a listing of
areas to be inspected and
provides direction to staff in all
areas to perform daily security
in ections.
Daily security checks are
documented in the housing unit
10 book.
All discrepancies are reported to
the shift supervisor and a work
order must be submitted by the
end of the shift.

All visitors are required to sign .
into the facility and are issued a
pass or escorted to the area they
are visitin .
Staff received on the job
trainin b senior staff.
The central control room is
staffed around the clock.
The Central Control Post-Orders
address staff access to Central
ControL

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Fonn Worksheet for'IGSAs - Rev: 07/09/07

The facility has a written
introduction of contraband
Tools being taken into the secure area of the facility are
before entering and prior to departure.

The ~MU entrance has a. sally port.

O·

181

Written procedures govern searches of detainee housing units and
areas.
Housing area searches occur at irregular times.

Every search of the SMU and other housmg units is documented.

fixtures, accesses,
Storage and supply rooms, walls, light and
and drains, etc., undergo frequent, irregular searches. These searches are
Walls, fences, and exits, including exterior windows, are inspected for
defects once each shift.

181

Daily procedures include:
• Perimeter aJarm system tests;
• Physical checks of the perimeter fence; and
•
the results.

IZI ACCEPTABLE

DEFICIENT

AT-RISK

D·

A tool inventory form is
completed before tools are taken
into the secure area of the

Post orders require staff to
perform regular and irregular
searches of detainee living
areas.
The SMU staff document cell
searches in Search MatriX Form,
and housing unit staff document
searches in the Daily
Shakedown Form.

A r.eview of the Daily Shift
Activity Report revealed these
. areas are inspected daily by shift

b2HIgh

REPEAT FINDING

REMARKS:

bG.b7c

September 18, 2008

AUDITOR'S SIGNATURE /DATE

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for 108As - Rev: 07/09/07

:,".

';;:.'

'.':<.'.:'.;.,

;.::'~:>-:: .... '

.:..... :

The Administrative Segregation unit provides non-punitive protection
from the general popUlation and individuals undergoing disciplinary
segregation.
• Detainees are placed in the SMU (adininistrative) in
accordance with written criteria.

IZI

A detention order is completed
for .each detainee confined to the
SMU. A review of eight SMU
files indicated detainees are
placed in SMU consistent with
policy..

In exigent circumstances, staff may place a detainee in the SMU

(administrative) before a written order has been approved.
• A copy of the order given to the-detainee within 24 hours.
The OlC (or equivalent) regularly reviews the status of detainees in
administrative detention.
• A supervisory officer conducts a review within 72 hours ofthe
detamee's placement in the SMU (administrative).
.
A supervisory officer conducts ano~er review after the detainee has
spent seven days ill administrative segregation, and:
• Every week thereafter for the first month; and
• Every 30 days after the first month.
• Does each review include an interview with i:he detainee?
• Is a written record made of the decision and the iustification?
The detainee is given a copy of the decision and justification for each
review.
The detainee is given an opportunity to appeal the reviewer's
• decision
to someone else in the facility.
The OlC (or equivalent) routinely notifies the Field Office Director (or
staff officer in charge of IGSAs) any time a detainee's stay in
administrative detention exceeds 30 days.
• Upon notification that the detainee's admfuistrative segregation
has exceeded 60 days, the FD forwards written notice to HQ
Field Operations Branch Chieffor DRO.
The OlC or equivalent) reviews the case ofevery detainee who objects .
to administrative segregation after 30 days in the SMU.
• A written record is made of the decision and the justification.
• The detainee receives a copy ofthis record.
The detainee is given the right to appeal to the OIC (or equivalent) the
conclusions and recommendations of any review conducted after the
detainee have remained in administrative segregation for· seven
consecutive days.
Administratively segregated detainees enjoy the same general privileges
as detainees in the general population.
TheSMUis:
• Well ventilated;
• . Adequately lighted;
• Appropriately heated; and
• Maintained in a sanitary condition.

IZI

The chief of security conducts
regular reviews of detainees in
administrative detention.
The chief of secUrity conducts
reviews of detainees who have
spent 3, 10, 17,24, and 30 days
in administrative segregation. A
written documentation is
maintained with the justification.
. The detainee is given a copy of
administrative segregation
review form. The detainee may
appeal to the assistant director
of inmate services.
The facility policy requires staff
to notify the CORT any time a
detainee's stay in administrative
detention exceeds 30 days.

o
o

Otero County Processing Center
SMU is well ventilated, properly
lighted, heated, and in sanitary
condition.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07
n .. _._ r.t

_.S!OI\

:': ;:".<~<::~:. ;<;"':'.>::.

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J .....

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• &1. .~:.~.~~~.~:
;.;"!\i·::J·<;.:)?:·:::":>::iXr:C()MPONENTS··'~···::;·:·

:: ..'..:y;;.: .•. '-<!'ii!:;:' ·.N-Ai::· ··;··:liE:MARKS. :'...

All cells are equipped with beds.
• Every bed is securely fastened to the floor or wall.
The number of detainees in any cell does not exceed the occupancy

IZI

limit.

•

When occupancy exceeds recommended capacity, do basic :
living standards decline?
• Do criteria for objectively assessing living standards exist?
• If yes, are the criteria included in the written procedures?
The segregated detainees have the same opportunities to
exchangellawider clothing, bedding, and linen !lS detainees in the
general population.
Detainees receiv.e three nutritious meals per day, from the general
population's menu of the day.
• Do detainees eat only with disposable utensils?
• Is food ever used as punishment?
Each detainee maintains a normal level ofpersonal hygiene in the SMU.
• The detainees have the opportunity to shower' and shave at
least three times a w~ek.
• lfnot, explain.
The .detainees are provided: .
• Barbering services;
• Recreation privileges in accordance with the "Detalnee
Recreation" standard;
• Non-legal reading material;
• Religious material;
• The same correspondence privileges as detainees in the general
population;
• Telephone access similar to that ofthe general population; and
• Personal legal material.
A health care professional visits every detainee at least three times a
week
• The shift supervisor visits each detainee daily.
• Weekends and holidays.
Procedures comply with the ''Visitation'' standard.
• The detainee retains visiting privileges; and
• The visiting room is available during normal visiting hours.
Visits from clergy are allowed.
Detainees have the same law-library access as the general population.
• Are they required to use the law library DSe.parately, or
DAsagroup?
• Are legal materials broughtto them?

All ~Ils in the SMU are single
occupancy.

Health Care professionals visit
all detainees in SMU three ~es
daily, and supervisqry staff
visits daily.

Detainees may visit once per
week for 30 minutes.

Detainees in SMU. are provided .
the same opportunity as
detainees in the general
population. Upon written'
request the detainee is escorted
to the law library.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for rG8As - Rev: 07/09/07

;'.i']: .. ,:)·>

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The SMU maintains a permanent log of detainee-related activity, e.g.,
meals served, recreation, visitors etc.
SPC procedures include completing the SMtJ. Housing Record (1-888)
immediately upon a detainee's placement in the SMU.
• Staff completes the form at the end of each shift.
.
• CDFs and IGSA facilities use FormI-8S8 (or local equivalent).
Staffrecord whether the detainee ate, showered, exercised, and took any
applicable medication during every shift.
• Staff 10~ record all pertinent information, e.g., a medical
condition, suicidal/assaultive behavior, etc;
• The medicRI officerlhealth care professional signs each,
individual's record during each visit; and
• , The housing officer initials, the record when all detainee
services are completed or at the end of the shift.
A new record is created for each week the detainee is in Administrative
Segregation.
.
• The weekly records are retained in the SMU until the
detainee's return to tlte general population.

IZI ACCEPTABLE

DEFICIENT

. 0

.. "N,>NA i:" ',':,,:-";;,;" 'REMAiri<s,':",;

IZI

AT-RIsK

SMU maintains a Daily Activity
Log of detainee-related activity,
e.g., meals served, recreation,
and visitors are recorded.

REPEAT FINDING

REMARKS:

The facility ensures supeivision of the detainees in Special Housing Unit. The operations of the unit is supervised by staff that ensures
detainees have all permitted items of personal property and access to medical services. Detainees in administrative segregation,
protective cUstody, and disciplinary detention are housed separately. Logs have daily entries of any unusual detainee behavior. The
sign-in log was reviewed and it revealed that supervisory staff makes daily visits of the Special Housirig Unit.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITNE)
G-324A Detention Inspection FOIDl Worksheet for IGSAs - Rev: 07109/07
n ___ ,.,

_.I:"D/'\

SPECIAL MANAGEMENT UNIT

DISClPllNARYSEGltEGATION
POllCY: EACH FACJLiTy WlU EstABLISH ASPECIAL MANAGEMENT UNIT IN WHl"CH TO ISOLATE CERTAIN DETAINEES FROM 'I1IE GENERAL
PDPULATION.-THESPEc:rAL MANAoEMmr UNIT WIIiaAvE TWO S~cTIONS~ONE FORDETAlNEES IN AoMINIS'ffiATlVE SEGREGATION; THE
OTImRFOR DETAiNEES BEINGSEGREGATIID F6iu~Istwi:JNAR.yREASONS..
. . - .
y
,
.:NA.
N
CoMPoNENTs
REMARKS
Officers
placing
detainees
in
disciplinary
segregation
follow
written
Management
& Training
.
.
procedures;
Corporation. Operational Policy
and Procedures, No. 2.1.15,
Subject..Special Housing Unit,
~
0
0
provides written procedures for
placing detainees in disciplinary
segregation.
The sanctions for violations committed during one incident are limited .~
0
0
to 60 days.
A completed Disciplininy Segiegation Order accompani~ the detainee
The detainee receives a
into the SMU.
disciplinary segregation order
0
0
within 24 hours ofplacem.ent in
• The detainee receives a copy of the order within 24 hours of ~
disciplinary segregation.
placement in disciplinary segregation.
Standardprocedures include reviewing the cases ofindividual detainees
The chief of security conducts
housed in disciplinary detention at set intervals.
reviews of each detainee who
has spent seven days in
After each formal review, tlie detainee receives a written copy of
disciplinary segregation and
the decision and supporting reasons.
every week thereafter for the
~
0
0
first two months. and every 30
days thereafter. The detainee is
provided with a written copy of
the decision.
The conditions of confinement in the SMU are proportional to the
~
0
0
amount of control necessary to protect detainees and staff.
Detainees in disciplinary segregation have rewer privileges than those
181·
0
0
housed in administrative segre~on.
Living conditions in disciplinary SMUs remain the same regardless of
behavior.
181.
0
0
Ifno, does staffprepare written documentationforthis action?
• Does the OIC sign to indicate approval.
Every detainee in disciplinary segregation receives the same humane
0
0
181
treatment, regardless of offense.
The quarters used for segregation are:
Otero County Processing Center
Well-ventilated
SMU is well ventilated, properly
• Adequately lighted. .
181
0
0
lighted, heated, and in sanitary
• Appropriately heated.
condition.
Maintained in a sanitaIy condition.

•

All cells are equipped with beds that are seclD'ely fiJstened to the floor or
wall of the cell.
The number of detainees confined to each cell or room is limited to the
number for which the space was designate.
basis?
Does the Ole approve excess occupancy on ate
When a detainee_ is segregated without clothing, mattress, blanket, or
pillow (in a dry cell setting), a justification is made and the decision is
reviewed each shift. Items are returned as soon as it is safe.

•

181

All cells in the SMU are single
ocaJpaDCy.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITNE)
G-324A Detention Inspection Form Worksheet fur IGSAs - Rev: 07109f(YJ

..;.

.,': .• '.;:"\;::

SPECIALMANAGEMENt'UNIT: ..• ,

' ..

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Detainees in the SMU have the same opportunities to exchange clothing,
bedding, etc., as other detainees.
.
Detainees in the SMU receive three nutritious meals per day, selected
from the Food Service's menu of the day.
• Food is not used as punishment
Detainees are allowed to maintain a normal level of personal hygiene,
including the opportunity to shower and shave at least three times/week.
Detainees receive, unless documented as a threat to security:
• Barbering services;
• Recreation privileges;
• Other-than-legal reading material;
• Religious material;
• The same correspondence privileges a,s other detainee~; and
• Personal legal material.
When phone access is limited by number or type of calls, the following
areas are exempt:
. • Calls about the detainee's immigration case or other legal
matters;
• Calls to consular/embassy officials; and
• Calls during family emergencies (as determined by the
OIC/Warden).
A health care professional visits every detainee in disciplinary
segregation every' week day.
• The shift supervisor visits each segregated <;letainee daily
• Weekends and holidays.
SMU detainees are allowed visitors, in accordance with the "Visitation"
standard.
SMU detainees receive legal visits, as provided in the "Visitation"
standard.
• Legal service providers· are notified of security concerns
arising. before a visit.
Visits from clergy are allowed.
• The clergy member is given the option ofvisitinglnot visiting
the segregated detainee.
.
• Violent/uncooperative detain~es are denied access to religious
services when safety and security would otherwise be affected.
SMU detainees have law library access.
• Violent/uncooperative detainees retain access to the law library
unless adjudicated a security threat in writing.
• Legal material brought to individuals in the SMU on a case-bycase basis.
• Staff documents every incident of denied access to the law
library.
All .detainee-related activities are documented, e.g.. meals served,
recreation activities, visitors, etc.
.

··.·N.·.·: .'/NA.' . . / . ,; .•. R1!:MARKS :;.,.,:,,\.:;..

o
o
o

o
o

181

o
o

Health care professionals visit
all detainees in SMU three times
daily, and supervisory staff'
visits daily.
Detainees may visit once per
week for 30 minutes.

Upon written request to staft
the detainee is escorted to the
law library.

SMU maintains a Daily Activity
Log of detainee-related activity,
e.g., meals served, recreation,
and visitors are recorded.

FOR OFFICIAL USE ONLY O--AW ENFORCEMENT SENSITIVE)
G-324A Detention InspectiQD 'Ponn Worksheet for IGSAs - Rev; 07/09/07

SPECIAL MANAGEi\UNTuNi'r·
DISCIPLINARY SE~GATION'
POUCY:EACH .FAClllTY WILl,. ESTABLISH A SPECIAL MANAGEMENT' UNIT IN WIDCH;TOISOLATE CERTAIN DETAINEES FROM THE GENERAL
POPUlAtION. THE SPECIAL MANAGEMENT UNIT WILL HAVE TWOSECnONS, ONE FOR DETAINEES 1N ADMINISTRATIVE SEGREGATION; TIIE···
OTHER FORDETAlNEES BEING SEGREGAIED FOR:DISC1PLINARY REASoNS.
.'. .
.
. NA
'COMPONENTS
Y
N
REMARKS
The SPC's, the Special Management Housing Unit Record (I-888or
equivalent), is prepared as soon as the detainee is placed in the SMU.
A Daily Activity LOg is
prepared when a detainee is
~
0
0
• All 1-8888 are filled out by the end of each shift.
placed in SMU.
• The CDFIIGSA facility use Form.
• 1-888 (or eguivalent local form}.
SMU staff record whether the detainee ate, showered. exercised, took
medication, etc.
• Details about the detainee logged, e.g., a medical cond,iti~
. suicidallvio1ent behavior, etc.
• The health cafe official sign individual records aftef each visit
0
~
0
The housing officer
the record when all detainee
services are completed or at the end of the shift.
• A new record is created weekly for each detainee in the SMU.
• The SMU retains these records until the detainee leaves the
SMU.

•

initials

.l8I ACCEPTABLE

DDEFlClENT

D AT~RIsK

o REPEAT FINDING

Otero County Processing Center has a required Special Management Unit that isolates certain detainees fromthe general population.
. One unit, Administrative Segregation, houses detainees isolated for their own protection, while the other unit is for detainees being

disciplined for an institution violation.

b6 bIe

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention InspeCtion Form Worksheet for IGSAs - Rev: 07i09107

:y;;( ... :/

" .

::;;: "",TOOLCONTROL . . . . , ' . ' ..... /

, '.

,.".t.tI$t~tSi~~~
..:::,'COMPoNENTS'C,:;::., • ,'. ,<<LC::i .•. ~;:.:\ .,;:.'::Y·
There is an individual who is responsible for 'developing a tool control
procedure and an inspection system to insure accountability.
181

1\·!;':';;:;:.ri'j::·,>~l;';;

Department heads are responsible for implem~nting this standard in their
departments.
.
Tool inventories are required for the:
• Maintenance Department;
• Medial Department;
• Food Service Department;
• Electronics Shop;
• Recreation Department; and
• Armory.
The facility has a policy for the regular inventory of all tools.
• The policy sets minim~ time lines for physical inventOry and
all necessary docwnentation.
• ICE facilities use AMIS bar code labels when required.
The .facility has a tool classification system. Tools are classified
according to:
• Restricted (dangerouslhazardous); and
• Non-Restricted (non-hazardous).
Department heads are responsible for ~plementing tool-control
procedures.
The faCility has policies and procedures in place to ensure that all tools
are marked and re(ldily identifiable.

The facility has an approved tool storage system.
• The system ensures that all stored tools are accountable..
• Commonly used tools (tools that can be mounted) are
stored in such a way that missing tool is readily notice.
Each facility has procedUres for the issuance of tools to staff and.
detainees.
.
. The facility has policies and procedures to address the issue oflost tools.
The policy and procedures include:
•. Verbal and written notification;
• Procedures for detainee access; and '
• Necessary documentation/review for all incidents of lost tools.
Broken or worn out tools are ~eyed and disposed of in an appropriate
and secure manner.
All private or contract repairs anq maintenance workers under contract to
ICE~ or other visitors, submit an inventory of all tools prior to admittance
into or departure ftomthe facility.

.'. N,A...;';, I:,;;:·,"',,,·: ':<: .~. ": .:> ..
The chief of security is
0 responsible for developing tool
control procedures and an
inspection sYstem.

The maintenance shop, medical,
food service, and the armory
have the required tool inventory.

The facility has two different
tool classification systems:
sensitive tools/class A, and non-'
sensitive (less dangerous) tools.

Management & Training
Corporation, Operational
Policies and Procedures, No.
2.4.2, Subject-Tool Control,
references procedures for the
marking of tools with a
departmental nwnber,

o
o

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G·324ADetention Inspection Fonn Worksheet for rGSAs· Rev: 07/09/07

:';r;:i~/:~T"";~}::·.·. :;_,:<;,.,·;"'::·,~''';;.::: . ;,,:)~:": _. . . . \.•. . . . !i·:,···}:,0~~~ijG:::OL:_.> . -"

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. PoLlCY: IT ISTHEpoIiCY OF ALL FACiLITIES tHAT AlLE!v.WWYEES ~HALtBE·REsPONSIBLEFOR.cQlyIPLYlNGWI1HTHE TOOLCON1RQLPOUCY.

,~~~~~~~~~~x~~~.
IZI ACCEPTABLE

D DEFICIENT

AT-RISK

REPEAT FINDING

REMARKS:

The tool control program at the Otero Processing Center fuilctions at a bigh level of proficiency. Staff is aware of procedures for
reporting lost or missing tools, inventory verification, and daily tool accountability. Inventory and tool files are accurate and current.
Staff members in all areas of the institution are familiar with tool control requirements.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 07/09/07

,-"-:::,'~ "):-: ',:;5,>:'"

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.v:;:-"'v~r<t;.

': : COMl'ONENTS :.

yEs:····

Transporting officers comply with applicable local, state, and ·federal
motor vehicle laws- and regulations. Records support this finding of
compliance.
Every transporting officer required to drive a commercial size bus has a
valid Commercial Driver's License (CDL) issued by the state of
employment.
Supervisors maintain records for each vehicle operator.

Officers use a checklist during every vehicle inspection.
• Officers report deficiencies affecting operability; and
• Deficiencies are corrected before the vehicle goes back into
service.
Transporting officers:
• Limit driving time to 10 hours in any 15 hour period;
• Drive only after eight consecutive off-duty hours;
• Do not receive transportation assignments after having been on
duty, in any capacity, for 15 hours;
• Drive a 50-hour maximum in a given work week; a 70-hour
maximum during eight consecutive days;
.
• During emergency conditions (including bad weather), officers
may drive as long as necessary ~d Safe to reach a safe
area-exceeding the 100hour limit. .
Two officers with valid CDLs required in any bus transporting detainees.
• When buses travel in tandem with detainees, there are two
qualified officers per vehicle.
• An unaccompanied driver may transport an empty vehicle..
Before the start of each detail, the vehicie is thoroughly se!ll'ched.

Positive identification of all detainees being transported is confirmed.
All de~ees are searched immediately prior to boarding th~ vehicle by
staff controlling the bus or vehicle.
The facility ensures that the number of detainees transported does not
exceed the vehicles manufacturer's occupancy level.
Protective vests are provided to all transporting officers.

lZI

NA· ,

. . REMARKs

A review of training records
revealed transportation staff is
properly licensed.
The transportation lieutenant
maintains the records of each
. vehicle operator.

Observation of trip preparation
revealed transport staff performs
vehicle searches and inspections
prior to departure.

o
o

Transporting staff conduct pat
searches of detainees as they
enter the vehicle. .

o
o
o

Observation: transportation staff
wore protective vests when
transporting detainees.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Ponn Worksheet for IGSAs - Rev: 07109/07

.::;}~:,·,f~~;~i~~f:·:. P;<".,:;~,::~" ":",." '.;'.

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..,: .... : .. :..
.' ", .: ..• ~... :'.

,..

The vehicle crew conducts a visual count once all passengers are on .
board and seated.
.
.' 'Additional visual counts are made whenever the vehicle makes a
scheduled or unscheduled stop.
Policies and procedures are in place addressing the use of restraining
equipment on transportation vehicles.
Officers ensure that no one contacts the detainees.
• One officer remains in the vehicle at all times when detainees
are present.
Meals are provided during long distance transfers.
• The meals meet the minimum dietaty standards, as identified by
dieticians utilized by ICE.
The vehicle crew inspects all Food Service pickups before accepting
delivery (food wrapping, portions, quality, quantity, thermos-transport
containers, etc.).
Before accepting the meals, the vehicle crew raises and resolves
questions, concerns, or discrepancies with the Food Service
representative;
• Basins, latrines, and drinking-water containers/dispensers are
cleaned and sanitized on a fixed schedule.
Vehicles have:
• Two-way radios;
• Cellular telephones; and
• Equipment boxes stocked in accordance with the Use of Force
Standard.
The vehicles are clean and sanitary at all times.

..........,

0
Personal property of a detainee transferring to another mcility is:
• Inventoried;
• Inspected; and
• Accompanies the detainee.

Transportation Post Orders
address the uSe of restraint
equipment on transportation
vehicles.

The latrines on the buses were
not clean and operationiU. There
were no drinking-water'
containers on the buses.

Inspection of Otero County
Processing Center,
transportation buses B-3,
4,5,7,13,17, and Van numbers
V-9, and V-12, revealed these
vehicles were not clean and
sanitary.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

."',

...
;

,."

",:;"

;;:;:;
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...... .

. ... ; ....... ",.;

The followmg contingencies are included in the written procedures for
. vehicle crews:
• Attack
• Escape
• Hostage-taking
• Detainee sickness
• Detainee death
• Vehicle fire
• Riot
• Traffic accident
• Mechanical problems

•
•

•

Interview with transportation
staff and inspection of the buses,
revealed there are no written
contingencies maintained on the
bus.

~aturaldisasters

Severe weather
Passen er list includes women or minors

o ACCEPTABLE

181 DEFICIENT

o REPEAT

OAT-RISK

FINDING

REMARKS:
.

The latrines on the buses were not clean and operational. There were no drinking-water containers on the buses .
.Inspection ofMTC transportation buses B-3, 4,5,7,13,17, and Van numbers V-9, and V-12, showed these vebicles were not clean and .
sanitary.
Interview with transportation staff and inspection of the buses revealed there are no written contingencies maintained on the buses or
vans.

I September 18. 2008

AUDITOR S IGNATURE/DATE

b6,b7c

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection FormWorksheet for IGSAs - Rev: 07109107

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.. . , .. '.
.' POLIcy:1HBUS. DEPARTMENT OF HOMELAND SECURITY AUTHORIZES THEUSEOF FORCE ONLY ASALAST ALTERNATlVEAFIERAILO'l'HER'

.&1:.'i'&• •~S~~j

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·:L ·;:;'·';(};.. ~;'-'·)·1'::'coMP6NENrg;tL·,:.:::';; ... ~;;:~i:··.· ...•.... •.•.

": •. :.; ...:' .... ,
Written policy authorizes staff to respond in an immediate-use-of-force
situation without a supervisor's presence or direction.

YEs:::· :. .•. No.:··.· :.'. :·NA>

'.• :: .'. REMARKs.

Management & Training
Corporation, Operational .
Policies and Procedures, No.
2.2.1, Subject-Use ofForce,
authorizes staff to use force
when there is a threat to the
safety of staff or detainees
without the approval of a

su~ervisor.

When the detainee is in an area that is or can be isolated (e.g., a locked
cell, a range), posing no direct threat to the detainee or others, officers
musHlYto resolve the situation without resorting to force.
Written policy asserts that calculatedra~r than immediate use offorce is
feasible in most cases.
.

The facility subscribes to the prescribed Confrontation Avoidance
Procedures.
• Ranking detention official, health professional, and others
confer before every calculated qse of force. '
When a detainee must be forcibly moved and/or restrained, and there is
time for a calculated use of force, staff uses the Use-of-Force Team
Technique.
.
• Under staff su~ervision.
Staff members are trained in the performance of the Use-of-Force Team
Technique. .
.

All use-of-force incidents are documented and reviewed.
Staff:
• Do not use force as punishment;
• Attempt to gain the detainee's voluntary cooperation before
reserting to force;
• Use only as much force. as necessary to control the
detainee; and
• Use restraints only when othernon-confrontational means,
including verbal persuasion, have failed or are impractical.
Medication may only be used for restraintpuiposes when authorized by
the Medical Authority as medically necessary.

Use-of-Force Team follows written procedures that attempt to prevent
injury and exposure to conttnUnicable disease(s).

[]

IZI

MTC Opera~onal Policies and
Procedures, ~o. 2.2.1, SubjectUse of Force, addresses
calculated rather than immediate .
use offorce is feasible in most
cases.

Initial and annual training
.agendas revealed staff receive
training in the Use of Force
Team Technique.

Interview with the chief of
security revealed only medical
staff authorizes the use of
medication when it is neceSsary.

FOR OFFICIAt USE ONLY (LAW ENFORCEMENT SENSITIVE)
G~324A Detention

Inspection Fonn Worksheet for IGSAs - Rev: 07/09/07

... ;:.::;~: :

·'i'.USEOF.FORCE .•.. .....

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. ,".>

""> ,"i<r:·': :'YES.,;

N6L ,,;NA,:'· ,,:. REMARKs

, Standard procedures associated with using four-point restraintS include:
• Soft restraintS (e.g., vinyl);
,
• Dressing the detainee appropriately for the temperature;
• A bed, mattress, and blanket/sheet;
• . Checking the detainee at least every 15 minutes;
• Logging each check;
• Turning the bed-restrained detainee often enough to prevent
, ,
soreness or sti:ffuess;
• Medical evaluation of the restrained detainee twice per
eight-hour shift; and
• 'When qualified medical staff is not. immediately available,
staff position the detainee "face-up".
The shift supervisor monitors'the detainee's position/condition every two
hours.
• He/she allows the detainee to use the rest room at these
times under safeguards.
All detainee checks are logged.
In immediate-use-of-force situations, staff contacts medical staffonce the
detainee is under controL

When the OIC authorizes use of non-lethal weapons:
• Medical staff is consulted before staff use pepper
spray/non-lethal weapons.
• Medical staffreviews the detainee's medical file before use
of a non-lethal weapon is authorized.
.
Special precautions are taken when restraining pregnant detainees.
• Medical personnel are consulted
,Protective gear is worn when restraining detainees with open cuts or
wounds.
Staff documents every use of force and/or ~on-routine application of
restraints.
It is standard practice to review any use of force and the non-routine
application ofrestraints.
All officers receive training in self~defense, confrontation-avoidance
techniques and the use of force to control detainees. .
• Specialized training is given and Officers are certified in all
devices they use.
In SPCS, is the Use of Force form is used? In other faciliiies (lGSAs /
CDFs) is this form or its equivalent used?

. IZ1 ACCEPTABLE

DEFICIENT

o
.o

,",::

A review of use-of-force files
revealed'staff and detainee(s)
involved in a use-of-force
incident are examined by
medical staff at the conclusion
of an incident.

MTC, Operational Policies and
Procedures, No.2.2.1, SubjectUse of Force.

o
'0
,0

, The facility does not house
female detainees.

o
o

IZI

AT-RISK

...::: .....

All use of force incidents are
reviewed by the chief of
security. assistant warden, and
'warden.

REPEAT FINDING

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
.G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

REMARKS:

Staff appears to have a sound understanding in the use-of-force procedures and the necessity to utilize confrontation avoidance
procedures. Documentation suggests great concern for the safety ofstaff and detainees. Use-of-force files included required
documentation and there is an appropriate level of review to ensure the effectiveness of the program.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
.

G-324A Detention Inspection Fonn Worksheet fur IGSAs - Rev: 07/09/07

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,,:.}:<

, ','

,;"-'.'; ";-:;",STAFFDETAINEECQMMUNICATIONS''':,'--

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-,<
".'COMPONENTS',:,- .' .'. :_'if~:' -.
>
The ICE Field Office Director ensUres that weekly announced and
unannounced visits occur at the IGSA.

,.\::,i::';~,}<,,><

Y ·..N>NA

. . . REMARKs.,

ICE staff ensures weekly visits _
occur.. ICE officials usually
visit daily.

o
o

o
o
o

Detention and Deportation Staff conduct scheduled weekly visits with
detainees held in the !GSA.
Scheduled visits are posted in ICE detainee areas.
Visiting staff observe and note current climate and conditions of
confinement at each IGSA.
ICE infonnation request Forms are available at the IGSA for use by ICE
detainees.
The IGSA treats' detainee correspondence to ICE staff as Special
Correspondence.
ICE staff responds to a detainee request from an IGSA within 72 hours.

ICE detainees are notified in writing upon admission to the facility of
their right to correspond with ICE staffregarding their case or conditions
of confinement.

IZl ACCEPTABLE

DDEFIClENT

AT-RIsK

Schedules are posted in the
housing units.
ICE officials observe the current
climate and conditions of
confinement and use checklists
to docwnent their findings.

ICE officials provided ICE
infonnation request forms
weekly.
Detainees are being notified of
their right to correspond with
ICE official at the initial
orientation.

D REPEAT FmnING

REMARKS:

Staff detainee communications are excellent at the ,facility. ICE staff ensures weekly visits occur and ICE officials usually visit daily.
ICE officials observe the current climate and conditions of confinement and use checklists to document their findings. Housing Units
include the postings of the OIG hotline information, sexual harassment/assault prevention and reporting information, as well as probono legal telephone numbers and consulate office telephone numbers.

58 ble

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 07/09/07

"'·;',.... <:,,~i':~;~'. ,>~\':/,"

>"';' '.. '. DETAINEE

TRANSFElt'~t~~,'

!.'

<;:< " '.'

')"~~~i.t;;~}9¥~£;MAKE4t~G~S~\iU:N9Tni~~PO~$~~PET~E~~~F1i~Jj~Jk~RET~E~~~~~S~~~;'

';JustICE PiUSO'NERA1.JENTMNsP()RTATION SYSTEM (JPATS); ICE.WILLADHERE to',WATS,PROTOCoiS•.·,IN DECIDlNG WiIirrHER'To'; ,

.··:~~f~il~~~~~~~~~;:~W;~~7:.;~'~::~r_~~~~:~
.' ATIORNEYISLOCATED wrrH1N,REASONABLE~GDISTANCE OF THEFAC1I.J"(Y;AND,WHEIm,'IllEIMMIGRATION COURTPROCEEDlNGSARE
:rAK1NH~LA<%;;r~ ">,,:,~,,,,:,.,

: ... ' ; , ' ,.:'

:>'L>;·-'~:';>::;·::.CO~ONENTs'-

, ',' ,"

' . ", . ,,',

When a detainee is represented by legal counselor a legal representative,
and a G-28 has been filed, the representative of record is notified by the
detainee's Deportation Officer.
• The notification is 'recorded in the detainee's file; and
• When the A File is not available, notification is noted within
DACS
Notification includes the reason for the transfer and the location of the
new facility.
The deportation officer is allowed discretion regarding the timing of the
notification when extenuating circumstances are involved.
The attorney and detainee are notified that it is their responsibility to
notify family members regarding a transfer.
Facility policy mandates that:
• Times and transfer plans are never dis'cussed with the detainee
prior to t:ransfer;
.
• The detainee is not notified of the transfer until immediately
.prior to departing the facility; and
• The detainee is not permitted to make any phone calls or have
contact with any detainee in the general.J)Q}>ulation.
The detainee is provided with a completed Detainee Transfer Notification
Form.
Form G-391 or equivalent authorizing the removal of a detainee from a
facility is used.
For medical transfers:
• The Detainee ~gration Health Service (or IGSA) (DIHS)
Medical Director or designee approves the transfer;
• Medical transfers are coordinated through the local ICE office;
and
• A medical transfer summary is completed and accompanies the
detainee.
Detainees in ICE facilities having DIHS staff and medical care are
transferred with a completed transfer summary sheet in a sealed envelope
with the detainee's name and A-number, ana the envelope is marked
MtXlical Confidential.
For medical transfers, transporting officers receive instructions regarding
medical issues.
Detainee's funds, valuables, and property are returned and transferred
with the detainee to his/her new location.
Transfer and documentary procedures outlined in Section C and D ar~
followed.
~eals are provided when transfers occur during normally schedule meal
times.
An A File or work folder accompanies the detainee when transferred to a
different field office or sub-office.

",. "';,;:;',":")< ........

,'.Y '.,' ',.N;;,:'

,NA

o
o

·::ol"·;·,{<

' ,;"REMARKS

o
o

FOR OFFICIAL USE ONLY ~AW ENFORCEMENT SENSITIVE)
G-324A Detention Inspecti~n Fonn Worksheet for IGSAs - Rev: 07/09/07

»-" "

,.~

Files are forwarded to the receiving office via overnight mail no later than
.
.
one business day following the transfer.

L8J ACCEPTABLE

DEFICIENT·

OAT-RIsK

···N-A ..

.::

. .

.. :"~:

.::...... :.; .....

...

REPEAT FINDING

REMARKS:

All ICE detainees are evaluated and approved by ICE prior to transportation by the facility staff. ICE detainees are released only to
the custody ofICE officials.

b6,b70
.

••

•

e tember 18 2008

06,!;)70

NATURE/DATE

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
G-324A Detention Inspection Form Worksheet for 1GSAs - Rev: 07/09107