U.S. Department of Homeland Security

Immigration and Customs Enforcement
Office of Professional Responsibility
Inspections and Detention Oversight Division
Washington, DC 20536-5501

Office of Detention Oversight
Compliance Inspection

Enforcement and Removal Operations
ERO Boston Field Office
Plymouth County Correctional Facility
Plymouth, Massachusetts

July 28–30, 2015

COMPLIANCE INSPECTION
for the
PLYMOUTH COUNTY CORRECTIONAL FACILITY
PLYMOUTH, MASSACHUSETTS
TABLE OF CONTENTS
EXECUTIVE SUMMARY
Overall Findings...................................................................................................................2
Findings by National Detention Standard (NDS) 2000 Major Categories ..........................3
INSPECTION PROCESS .............................................................................................................4
DETAINEE RELATIONS ............................................................................................................5
INSPECTION FINDINGS
DETAINEE SERVICES
Access to Legal Material .....................................................................................................7
Detainee Grievance Procedures ...........................................................................................7
Detainee Handbook ..............................................................................................................7
Food Service ........................................................................................................................8
Staff-Detainee Communication ...........................................................................................8
SECURITY AND CONTROL
Environmental Health and Safety ........................................................................................8
HEALTH SERVICES
Medical Care ........................................................................................................................9

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INSPECTION TEAM MEMBERS

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

Office of Detention Oversight
July 2015
OPR 201507556

Lead Inspections and Compliance Specialist
ODO
Inspections and Compliance Specialist
ODO
Inspections and Compliance Specialist
ODO
Inspections and Compliance Specialist
ODO
Inspections and Compliance Specialist
ODO
Contractor
Creative Corrections
Contractor
Creative Corrections
Contractor
Creative Corrections
Contractor
Creative Corrections
1

Plymouth County Correctional Facility
ERO Boston

EXECUTIVE SUMMARY
The Office of Detention Oversight (ODO) conducted a compliance inspection of the Plymouth
County Correctional Facility (PCCF) in Plymouth, Massachusetts, from July 28 to 30, 2015. 1
PCCF opened in 1994 and is owned by the Commonwealth of Massachusetts and operated by the
Plymouth County Sheriff’s office. Enforcement and Removal Operations (ERO) began housing
detainees at PCCF in 1998 pursuant to an Intergovernmental Service Agreement (IGSA), under
the oversight of ERO’s Field Office Director (FOD) in Boston, Massachusetts.
ERO staff members and a Detention
Capacity and Population Statistics
Quantity
Services Manager are assigned to the
1140
facility. A PCCF Superintendent is Total Bed Capacity
340
responsible for oversight of daily facility ICE Detainee Bed Capacity
1073
operations and is supported by (b)(7)e Average Daily Population
80
personnel.
Trinity Services Group Average ICE Detainee Population
provides food services and Correctional Average Length of Stay (Days)
88
Psychiatric Services (CPS) of Sherborn, Male Detainee Population (as of 07/28/2015)
51
Massachusetts and Plymouth County Female Detainee Population (as of 07/28/15)
N/A
employees provide medical services.
The facility is not contractually obligated to comply with the ICE Performance-Based National
Detention Standards (PBNDS) 2011, Sexual Abuse and Assault Prevention and Intervention
(SAAPI) standard but made efforts to comply. 2 The facility is accredited by the American
Correctional Association (ACA).

OVERALL FINDINGS
In November 2012, ODO conducted
an inspection of PCCF under the
National Detention Standards (NDS)
2000, reviewing the facility’s
compliance with 21 standards and
finding the facility compliant with 16
standards. There were a total of 18
deficiencies in the remaining five
standards.

FY 2013
(NDS 2000)

FY2015
(NDS 2000)

Standards Reviewed

21

15

Deficient Standards

5

7

Overall Number of Deficiencies

18

10

Corrective Actions Initiated

0

4

0
N/A

1
N/A

Inspection Results Compared

Best Practice
Deficient Priority Components

In FY2015, ODO conducted an
inspection of PCCF under the NDS 2000 reviewing the facility’s compliance with 15 standards
and finding the facility compliant with eight standards. ODO found ten deficiencies in the
remaining seven standards. Finally, ODO identified four opportunities where the facility
initiated corrective action and one best practice during the course of the inspection. 3

1

Male and detainees with low, medium and high security classification levels are detained at the facility for longer
than 72 hours.
2
The facility has a zero tolerance policy articulated in PCCF Policy 268, Sexual Abuse and Harassment of Inmates.
All facility staff, including volunteers and contractors receives training in sexual assault and abuse prevention and
intervention. The training curriculum specifically addresses the Prison Rape Elimination Act (PREA).
3
Corrective actions, where immediately implemented, best practices and ODO recommendations, as applicable,
have been identified in the Inspection Findings section and annotated with a “C”, “BP” or “R”, respectively.

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Plymouth County Correctional Facility
ERO Boston

FINDINGS BY NDS 2000 MAJOR CATEGORIES
NDS 2000 STANDARDS INSPECTED 4

DEFICIENCIES

Part 1 – Detainee Services
Access to Legal Material
Admission and Release
Detainee Classification System
Detainee Grievance Procedures
Detainee Handbook
Food Service
Funds and Personal Property
Staff-Detainee Communication
Telephone Access
Sub-Total

1
0
0
3
1
1
0
1
0
7

Part 2 – Security and Control
Environmental Health and Safety
Special Management Unit (Administrative)
Special Management Unit (Disciplinary)
Use of Force
Sub-Total

2
0
0
0
2

Part 3 – Health Services
Medical Care
Suicide Prevention and Intervention
Sub-Total

1
0
1

Total Deficiencies

4

10

For greater detail on ODO’s findings, see the Inspection Findings section of this report.

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Plymouth County Correctional Facility
ERO Boston

INSPECTION PROCESS
Every fiscal year, the Office of Detention Oversight (ODO), a unit within U.S. Immigration and
Customs Enforcement’s (ICE) Office of Professional Responsibility (OPR), conducts
compliance inspections at detention facilities in which detainees are accommodated for periods
in excess of 72 hours and with an average daily population greater than ten detainees, to
determine compliance with the applicable ICE National Detention Standards (NDS) 2000, or the
Performance-Based National Detention Standards (PBNDS) 2008 or 2011.
During the compliance inspection, ODO reviews each facility’s compliance with those detention
standards that directly affect detainee health, safety, and/or well-being. 5 ODO then identifies as
a “deficiency,” any violation of written policy specifically linked to ICE detention standards,
policies, or operational procedures. ODO will also highlight any deficiencies found involving
those standards that ICE has designated with either the PBNDS 2008 or 2011 to be “priority
components.” 6 ICE considers those components to be of critical importance, given their impact
on facility security and/or the health and safety, legal rights, and quality of life of detainees in
ICE custody.
Immediately following an inspection, ODO hosts a closeout briefing in person with both facility
and ERO field office management to discuss their preliminary findings, which are summarized
and provided to ERO in a preliminary findings report. Thereafter, ODO provides ERO with a
final compliance inspection report to: (i) assist ERO in working with the facility to develop a
corrective action plan to resolve identified deficiencies; and (ii) provide senior ICE and ERO
leadership with an independent assessment of the overall state of ICE detention facilities. The
reports enable senior agency leadership to make decisions on the most appropriate actions for
individual detention facilities nationwide.

5
6

ODO reviews the facility’s compliance with selected standards in their entirety.
Priority components have not been identified for the NDS.

Office of Detention Oversight
July 2015
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Plymouth County Correctional Facility
ERO Boston

DETAINEE RELATIONS
ODO interviewed 21 detainees, who volunteered to participate. None of the detainees made
allegations of mistreatment, abuse, or discrimination. The majority of detainees reported being
satisfied with facility services, with the exception of the complaints below:
•

Access to Legal Material: Two detainees alleged they were unable to print documents
using the Lexis-Nexis computer system.
o

•

Food Service: Three detainees alleged chicken is never served, and the same food was
served for breakfast; additionally, the portions are too small.
o

•

Action Taken: ODO reviewed the dietician certified 35-day cycle menu and found
it had an average daily calorie count of 2,900 calories. Chicken was on the menu
four times during the 35 day cycle. The menu also reflects that breakfast items
are rotated daily.

Staff-Detainee Communication: Two detainees alleged they are not visited by their
deportation officer, and their ICE requests are not answered.
o

•

Action Taken: Staff informed ODO, the detainees can request to have documents
printed by submitting a request for legal assistance.

Action Taken: ODO reviewed the ICE Request Log, which revealed the
aforementioned detainees requests were responded to within the required time. A
review of the housing unit logbooks reveal ERO staff signed into the housing unit
in accordance with the posted ICE visit schedule.

Medical Care: One detainee alleged he submitted a sick call request regarding a wound
on his arm and never received medical care. One detainee alleged medical services
stopped giving him medication for hypertension.
o

Action Taken:
Medical services notified ODO, the detainee who alleged not to have received
medical care for a wound to his arm did not have a sick call request submitted for
medical care. The detainee was referred to medical for further review. Medical
services notified ODO, the detainee who alleged not to have received medication
for hypertension was refusing to take his prescribed medication. Prior to the end
of the inspection, the detainee resumed taking his medication as prescribed.

Office of Detention Oversight
July 2015
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Plymouth County Correctional Facility
ERO Boston

•

Telephone Access: One detainee alleged their calls to the consulate or pro bono services
are not answered.
o

•

Action Taken: ODO could not verify the detainee’s allegations. At the time of the
inspection, all telephones were in operating order.

Detainee Grievance Procedures: One detainee alleged he submitted several grievances
over the last several weeks and never received a decision/answer to the grievances
submitted.
o

Action Taken: ODO reviewed all recorded grievances submitted dating back to
January 2014 and did not observe any grievances submitted by the detainee.

Office of Detention Oversight
July 2015
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Plymouth County Correctional Facility
ERO Boston

INSPECTION FINDINGS
DETAINEE SERVICES
ACCESS TO LEGAL MATERIALS
ODO observed there were no operational policies and procedures posted in the law library
(Deficiency ALM-1 7).
Corrective Action:
The facility initiated corrective action during this inspection by
posting the policies and procedures in the law library (C-1).
DETAINEE GRIEVANCE PROCEDURES (DGP)
An interview with staff and review of policy and procedure revealed, the facility does not have
procedures in place to allow detainees who are dissatisfied with the facility’s response to
grievances a method to communicate directly with ERO (Deficiency DGP-1 8).
ODO reviewed four grievances that involved officer misconduct and, through interviews,
determined the facility does not inform ERO of the grievances. In the absence of such notice,
ERO could not conduct an investigation of the alleged misconduct (Deficiency DGP-2 9). ERO
was notified of this issue and worked with facility staff to initiate corrective action.
Corrective Action:
The facility initiated corrective action during this inspection by
developing and implementing policy that requires ERO to be notified on all detainee
grievances involving allegations of staff misconduct (C-2).
The facility handbook does not inform detainees of the procedure for contacting ICE to appeal
the decision of the facility Officer-In-Charge (OIC) (Deficiency DGP-3 10).
DETAINEE HANDBOOK
During an interview with staff, ODO determined staff members who have contact with detainees
are not provided a copy of the facility handbook (Deficiency DH-1 11).
7

“These policies and procedures shall also be posted in the law library along with a list of the law library’s
holdings.” See ICE NDS 2000, Standard, Access to Legal Material, Section (III)(Q).
8
“CDFs and IGSA facilities must allow any INS detainee dissatisfied with the facility’s response to his/her
grievance to communicate directly with INS.” See ICE NDS 2000, Standard, Detainee Grievance Procedures,
Section (III)(C).
9
“Staff must forward all detainee grievances containing allegations of officer misconduct to a supervisor or higherlevel official in the chain of command. CDFs and IGSA facilities must forward detainee grievances alleging officer
misconduct to INS. INS will investigate every allegation of officer misconduct.” See ICE NDS 2000, Standard,
Detainee Grievance Procedures, Section (III)(F).
10
“The facility shall provide each detainee, upon admittance, a copy of the detainee handbook or equivalent. The
grievance section of the detainee handbook will provide notice of the following: 4. The procedures for contacting
the INS to appeal the decision of the OIC of a CDF or an IGSA facility.” See ICE NDS 2000, Standard, Detainee
Grievance Procedures, Section (III)(G)(4).
11
“The OIC will provide a copy of the handbook to every staff member who has contact with detainees.” See ICE
NDS 2000, Standard, Detainee Handbook, Section (III)(G)

Office of Detention Oversight
July 2015
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Plymouth County Correctional Facility
ERO Boston

FOOD SERVICE
ODO observed food items were placed in compartments of insulated trays which were then
stacked and strapped onto unsecured flat carts (Deficiency FS-1 12).
Corrective Action:
The facility initiated corrective action during this inspection by
ensuring the carts are secured. The change was implemented through a new policy (C-3).
STAFF-DETAINEE COMMUNICATION (SDC)
ICE detainee request forms are not placed in the detainee detention file after review (Deficiency
SDC-1 13).
Corrective Action:
The facility initiated corrective action during this inspection by
creating a policy that requires ICE detainee request forms to be placed in the detainee
detention file after they are reviewed (C-4).

SECURITY AND CONTROL
ENVIRONMENTAL HEALTH AND SAFETY
A review of the documented monthly fire drills conducted in the facility revealed detainees were
not evacuated from housing units during the drills (Deficiency EH&S-1 14).
A review of the documented monthly fire drills conducted in the facility revealed emergency
keys were not drawn and tested during the fire drills (Deficiency EH&S-2 15).
Best Practice: PCCF has the Aquawing Ozone Laundry System©, which is used in
conjunction with a solid detergent dispensing system. Ozone systems potentially provide
superior disinfection of clothing and linens and are environmentally friendly, saving hot
water, and extending the life of equipment and items laundered. In addition, the system
eliminates the need to store bulk quantities of hazardous detergents and bleaching agents
required for traditional laundry operations. ODO cites this as a best practice (BP-1).

12

“A member of the food service staff will oversee the loading of satellite-feeding carts. Staff shall inspect and
secure all food carts before allowing their removal from the food service area.” See ICE NDS 2000, Standard, Food
Service, Section (III)(C)(2)(i).
13
“All completed Detainee Request will be filed in the detainee’s detention file and will remain in the detainee’s
detention file for at least three years.” See ICE NDS 2000, Standard, Staff-Detainee Communication, Section
(III)(B)(2).
14
“Detainees will be evacuated during fire drills, except in areas where security would be jeopardized or in medical
areas where patient health could be jeopardized or, in individual cases when evacuation of patients is logistically not
feasible. Staff- simulated drills will take place instead in the areas where detainees are not evacuated.” See ICE
NDS 2000, Standard, Environmental Health and Safety, Section (III)(L)(4)(b).
15
Emergency-key drills will be included in each fire drill, and timed. Emergency keys will be drawn and used by
the appropriate staff to unlock one set of emergency exit doors not in daily use. NFPA recommends a limit of four
and one-half minutes for drawing keys and unlocking emergency doors.” See ICE NDS 2000, Standard,
Environmental Health and Safety, Section (III)(L)(4)(c).

Office of Detention Oversight
July 2015
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Plymouth County Correctional Facility
ERO Boston

HEALTH SERVICES
MEDICAL CARE
The facility has a full time on-site dentist, but a review of 20 health appraisals reveal initial
dental screenings are performed by the physician or nurse practitioner; with referral to the dentist
if issues are identified (Deficiency MC-1 16).

16

“An initial dental screening exam should be performed within 14 days of the detainee’s arrival. If no on-site
dentist is available, the initial dental screening may be performed by a physician, physician’s assistant or nurse
practitioner.” See ICE NDS 2000, Standard, Medical Care, Section (III)(E).

Office of Detention Oversight
July 2015
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Plymouth County Correctional Facility
ERO Boston