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

Office of Detention Oversight
Compliance Inspection

Enforcement and Removal Operations
Washington Field Office
Rappahannock Regional Jail
Stafford, Virginia

November 13 - 15, 2012

COMPLIANCE INSPECTION
RAPPAHANNOCK REGIONAL JAIL
WASHINGTON FIELD OFFICE
TABLE OF CONTENTS
EXECUTIVE SUMMARY ...............................................................................................1
INSPECTION PROCESS
Report Organization .................................................................................................6
Inspection Team Members .......................................................................................6
OPERATIONAL ENVIRONMENT
Internal Relations .....................................................................................................7
Detainee Relations ...................................................................................................7
ICE NATIONAL DETENTION STANDARDS
Detention Standards Reviewed ................................................................................8
Access to Legal Material .........................................................................................9
Admission and Release ..........................................................................................10
Detainee Grievance Procedures .............................................................................12
Disciplinary Policy.................................................................................................14
Environmental Health and Safety ..........................................................................16
Food Service ..........................................................................................................18
Funds and Personal Property .................................................................................20
Medical Care ..........................................................................................................21
Staff-Detainee Communication .............................................................................24
Use of Force ...........................................................................................................26
Visitation ................................................................................................................28

EXECUTIVE SUMMARY
The Office of Professional Responsibility (OPR), Office of Detention Oversight (ODO)
conducted a Compliance Inspection (CI) of the Rappahannock Regional Jail (RRJ) in
Stafford, Virginia, from November 13 through 15, 2012. RRJ, which opened in June 2000, is
owned and operated by Rappahannock Regional Jail Authority. RRJ houses Federal prisoners
under an intergovernmental service agreement (IGSA) with the U.S. Marshals Service. In 2008,
U.S. Immigration and Customs Enforcement (ICE), Office of Enforcement and Removal
Operations (ERO), began using the U.S. Marshals Service contract to house male detainees of all
security classification levels (Level I – lowest threat, Level II – medium threat, Level III –
highest threat) at the facility for periods in excess of 72 hours. RRJ has a total capacity of
2,000 beds. Bed space for ICE detainees is available as needed; the remaining bed space is used
by the U.S. Marshals Service, and state and local law enforcement agencies in the surrounding
area. At the time of the CI, RRJ housed 240 ICE male detainees. There were no female
detainees at RRJ at the time of the CI. The average daily detainee population is 195. The
average length of stay is 76 days. Correctional Health Resources provides medical care and
Aramark provides food service under contract. The facility holds no accreditations.
The ICE ERO Field Office Director, Washington, DC (ERO Washington), is responsible for
ensuring facility compliance with ICE policies and the ICE National Detention Standards (NDS).
ICE has (b)(7)eImmigration Enforcement Agent (IEA) stationed full-time at the facility. An Acting
Assistant Field Office Director (AFOD), located at the ERO office in Richmond, Virginia, has
oversight responsibility at RRJ. The Acting AFOD and a Supervisory Detention and Deportation
Officer visit the facility monthly. Weekly scheduled and unscheduled visits are conducted by the
IEA and Deportation Officers. There is no Detention Service Manager assigned to this facility.
The Superintendent is the highest-ranking official at RRJ and is responsible for oversight of daily
operations. In addition to the Superintendent, RRJ employs a total of(b)(7)eemployees, including a
Deputy Superintendent,(b)(7)e Captains, and (b)(7)e Lieutenants.
In December 2010, ODO conducted a Quality Assurance Review (QAR) at RRJ and cited
33 deficiencies in 17 of the 25 standards inspected. In July 2012, ERO Detention Standards
Compliance Unit contractor, The Nakamoto Group, Inc., conducted an annual review of the NDS
at RRJ. The facility received an overall rating of “Acceptable,” and was found to be in
compliance with all 38 standards reviewed.
During this CI, ODO reviewed 21 NDS. Ten standards were determined to be in full
compliance, while 22 deficiencies were found in the following 11 standards: Access to Legal
Material (1 deficiency), Admission and Release (1), Detainee Grievance Procedures (2),
Disciplinary Policy (3), Environmental Health and Safety (4), Food Service (2), Funds and
Personal Property (1), Medical Care (2), Staff-Detainee Communication (3), Use of Force (2)
and Visitation (1). Four repeat deficiencies from the December 2010 QAR were noted in the
following standards: Access to Legal Material (1 deficiency), Environmental Health and
Safety (1), and Medical Care (2).
This report includes descriptions of all the deficiencies and refers to the specific, relevant
sections of the NDS. ERO will be provided a copy of this report to assist in developing
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corrective actions to resolve the 22 identified deficiencies. These deficiencies were discussed
with RRJ and ICE personnel on-site during the inspection and during the closeout briefing on
November 15, 2012.
All detainees have access to indoor and outdoor recreation, which is available to them for six
hours each day. Detainees have visitation privileges and access to religious services. Detainees
are classified and medically screened upon admission to the facility with classifications
reassessed at appropriate intervals. During the admission process, detainees are provided with
either the English or Spanish version of the ICE National Detainee Handbook and a facilityspecific handbook. Detainees confirm receipt of the handbook by signing an acknowledgement
form that is placed in each detention file. ODO inspected 20 detention files and verified all
detainees received handbooks at the time of admission. ODO confirmed all detainees go through
an orientation process that includes viewing an ICE video, and being informed about facility
operations, programs, and services. RRJ officials show the orientation video in the housing units
every Saturday and maintain a log to document the presentation in each individual detention file.
RRJ does not maintain a designated room for a law library. Instead, each housing unit in B-pod,
where all ICE detainees are housed, has a computer station designated for legal research
purposes. ODO notes the computer stations are located near the housing unit officers’ posts,
away from the televisions and primary dayroom activity areas.
The detainee grievance program at RRJ is managed by the inmate services coordinator/
ombudsman. The detainee grievance system allows detainees to file informal, formal, and
emergency grievances, and to appeal those grievance decisions. ODO interviewed ten detainees
and specifically inquired if they are familiar with grievance procedures; all detainees confirmed
awareness of the grievance process, but none had ever filed a grievance. Grievance forms are
available at the officer’s station in each housing area.
The grievance process begins as an informal grievance where facility staff attempts to resolve the
issue at the lowest possible level, in an orderly and timely manner. The informal grievance may
be given either verbally or in writing by the detainee. If the grievance is not resolved at the
informal level, the detainee may proceed with submitting a formal grievance in writing. ODO
was informed detainees are not allowed to bypass or terminate the informal grievance process
and proceed directly to the formal grievance stage. ODO informed facility staff members that
the ICE NDS Detainee Grievance Procedures standard provides that detainees should be allowed
to bypass or terminate the informal grievance process and proceed directly to the formal
grievance stage. ODO recommends the facility revise its current practices to comply with the
NDS requirements.
RRJ employs both informal and formal procedures for key ICE and facility staff to interact with
detainees on a regular basis. ICE staff conducts unscheduled/unannounced contacts through the
Acting AFOD and through Supervisory Detention and Deportation Officers. During these
unannounced visits, ERO department heads visit the facility’s housing units, Food service,
Medical, and the SMUs. A review of the logbooks in each of those areas confirmed ICE
management and non-supervisory staff conduct frequent unscheduled visits to the facility. (b)(7)e
IEA is assigned full-time to RRJ. Detainees’ requests pertaining to facility services are handled
in accordance with the facility’s established guidelines. ODO confirmed, from interviewing six
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detainees and RRJ staff, the IEA assigned to the facility is very active in addressing detainees’
personal concerns and monitoring living conditions. Six detainees interviewed stated they do not
know who is their assigned Deportation Officer. ODO observed a Deportation Officer visiting
the facility during the ODO inspection. ODO confirmed ERO officers were scheduled for
contact visits on Tuesdays and Thursday of each week. However, the written visit schedule was
not posted in each of the housing units or in other areas with detainee access.
RRJ has a designated Prison Rape Elimination Act (PREA) Coordinator. RRJ informs detainees
of the PREA program in the detainee handbook, during orientation, and through postings in the
admission process area and housing units. The information is in both English and Spanish and
includes toll-free telephone numbers. RRJ uses a standard policy and procedure manual, titled
“Prison Rape Elimination Programs,” that was revised on July 1, 2011. The manual covers the
program’s purpose, policy, and procedures. Under the procedures section of the policy, it
addresses prevention, staff training, offender/detainee education, and prompt and effective
response by facility and staff. ODO verified completion of the required training upon review of
(b)(7)etraining records. In interviews, staff knew of the PREA program and how to handle any
information received concerning possible sexual abuse or assault. Detainees are screened during
the admission process for sexual abuse victimization history, as well as predatory history to
determine potential sexual aggressors. RRJ separates detainees with a history of predatory or
abusive sexual behavior from detainees with a history of victimization.
At the time of the inspection there were nine detainees in segregation; seven of whom were in
administrative segregation, and two were in disciplinary segregation. A review of all the
detainees’ disciplinary packets confirmed their statuses were imposed through the disciplinary
process, and in accordance with the standard and facility policy. ODO verified all nine detainees
were issued the disciplinary order placing them on segregation. The Administrative Special
Management Unit (SMU) and the Disciplinary SMU at RRJ are well ventilated, adequately lit,
appropriately heated, and maintained in sanitary conditions. ODO reviewed Facility Liaison
Visit Checklists, and confirmed visits by supervisors and medical personnel are conducted as
required by the standard.
RRJ’s food service program consists of a Food Service Director, an assistant director (b)(7)e
kitchen supervisors, and a crew of b)(7)ecounty inmates. No ICE detainees work in food service.
The facility has a satellite system of meal service involving preparation of meals in the kitchen
and delivery to housing units on thermal trays. ODO observed the preparation and delivery of a
meal, and noted the carts used to transport food trays are not secure. The carts are metal with
open shelves, on which the trays are placed for transport by inmate workers. Though the trays
have lids, they are not secure and may be easily opened. ODO noted that trays should be
transported in secured carts in order to prevent food tampering. ODO verified all menus were
certified by a registered dietician. Religious- and medically-prescribed meals were provided and
properly documented.
Facility sanitation is maintained at an acceptable level. RRJ maintains a master index of all
hazardous substances, including diagrams of their locations and a master file of Material Safety
Data Sheets. ODO confirmed all chemicals, flammables, and combustible materials are stored
and issued as required by the standard. Hazardous substances are strictly controlled, and fire
drills are conducted on a monthly basis. Regular fire drills are critical to ensuring staff
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these crisis cells, ODO recommends adoption of policies and procedures requiring removal of
detainees to use toilet facilities, when needed.
ODO verified detainees are screened for suicide potential during the admission process. All staff
receives initial and ongoing suicide prevention training as required by the standard. There have
been no ICE detainee suicides or deaths at RRJ. ODO noted in the December QAR, RRJ had
documented nine suicide watches and one possible attempt. Documentation of the attempted
suicide found in the detainee’s medical record indicated the detainee was brought to the clinic
and placed on suicide watch for trying to hang himself. Review of this record confirmed
appropriate intervention and monitoring, including documented 15-minute checks. The day after
placement on suicide watch, the detainee was transferred to a local hospital for further
evaluation.
Detainees undergo medical and mental health screenings upon arrival by specially-trained
correctional officers. ODO reviewed 25 records and verified intake screenings were completed
and detainees signed consent for treatment. Before new detainees leave the booking area, they
are seen by a nurse, who reviews the screening information documented by officers to determine
if there are medical or mental health issues requiring attention. In addition, tuberculosis
screenings by way of Purified Protein Derivative (PPD) skin tests are conducted as part of the
intake process. Chest X-rays are completed for detainees whose PPD tests are positive, and
detainees with a history of testing positive.
ODO verified physical examinations were completed by RNs within 14 days of arrival in all
records reviewed; however, of the 25 physical examinations reviewed, only one had been
reviewed and counter-signed by a physician. In addition, ODO was informed RNs’ training for
conducting physical examinations consisted of viewing an assessment video. RNs are not
required to undergo any training by an approved physician, and as a result, they have not
completed training conducted or approved by a physician. This is a repeat deficiency from the
December 2010 QAR. Proper training and physician review of physical examinations is critical
to ensuring the examinations are correctly conducted, and proper follow-up takes place.
Detainees request healthcare services by completing forms printed in both English and Spanish,
and in triplicate. The detainee dates and signs the request form and keeps one copy. Unit
officers stated assistance is available for illiterate detainees and others who may need assistance.
The forms are placed into a separate and secure box in the housing unit. The time the form is
received and triaged by medical staff is recorded on the form, as is the date the detainee is seen,
along with the provider’s note summarizing the encounter. ODO cites the triplicate sick call
request form as a best practice because it supports accountability for request processing, and
documentation of timeliness.

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INSPECTION PROCESS
ODO inspections evaluate the welfare, safety, and living conditions of detainees. ODO primarily
focuses on areas of noncompliance with the ICE NDS or the ICE Performance Based National
Detention Standards, as applicable. The NDS apply to RRJ. In addition, ODO may focus its
inspection based on detention management information provided by ERO Headquarters, ERO
field offices, and on issues of high priority or interest to ICE executive management.
ODO reviewed the processes employed at RRJ to determine compliance with current policies
and detention standards. Prior to the inspection, ODO collected and analyzed relevant
allegations and detainee information from multiple ICE databases, including the Joint Integrity
Case Management System, the ENFORCE Alien Booking Module, and the ENFORCE Alien
Removal Module. ODO also gathered facility facts and inspection-related information from
ERO Headquarters staff to prepare for the site visit at RRJ.

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

INSPECTION TEAM MEMBERS

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

Management and Program Analyst (Team Leader)
Management and Program Analyst
Detention and Deportation Officer
Contract Inspector
Contract Inspector
Contract Inspector

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ODO, Headquarters
ODO, Headquarters
ODO, Headquarters
Creative Correction
Creative Correction
Creative Correction

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OPERATIONAL ENVIRONMENT
INTERNAL RELATIONS
ODO interviewed the RRJ Deputy Superintendent, Assistant Superintendent of Operations
(major), and the ICE Acting AFOD who oversees the facility. During the interviews, all
personnel stated the working relationship between RRJ and ICE personnel is good, morale is
high, and the working conditions are adequate to accomplish all required duties. The Deputy
Superintendent stated the IEA assigned to the facility is frequently seen visiting detainees in the
housing units at least five times a week, communicating with detainees, and addressing detainee
issues and concerns. A review of RRJ visitation logs for 2012 revealed the Acting AFOD visited
RRJ on a monthly basis, and the Deputy Field Office Director visited the facility twice in the
past year.

DETAINEE RELATIONS
ODO interviewed 20 randomly-selected ICE male detainees to assess the overall living and
detention conditions at RRJ. All detainees stated they were treated with dignity and respect by
RRJ staff. Overall, detainees expressed satisfaction with the treatment and services provided at
RRJ. ODO received no complaints concerning issuance and replenishment of hygiene supplies,
sending and receiving mail, visitation, access to religious services, recreation, or the grievance
process. All detainees stated the health care staff is attentive and responsive. Six out of 20
detainees interviewed stated they did not know their Deportation Officer, or how to contact him
or her. ODO confirmed there was no visitation schedule posted in the housing units and other
areas with detainee access to indicate which ICE officer is scheduled to visit.
One detainee out of the 20 who were interviewed complained about bologna being served
frequently at the facility. ODO reviewed the current menu, and noted bologna was being served
for breakfast or lunch on three of the six days prior to the inspection. The issue was discussed
with Aramark management and a menu review was initiated. During the inspection, ODO was
informed a new menu would be implemented to address the issue.

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ICE NATIONAL DETENTION STANDARDS
ODO reviewed a total of 21 NDS and found RRJ fully compliant with the following
10 standards:
Detainee Handbook1
Hold Rooms in Detention Facilities
Hunger Strikes
Recreation
Religious Practices
Special Management Unit – Administrative Segregation
Special Management Unit – Disciplinary Segregation
Suicide Prevention and Intervention
Telephone Access
Terminal Illness, Advance Directives, and Death
As these standards were compliant at the time of the review, a synopsis for these standards was
not prepared for this report.
ODO found deficiencies in the following 11 standards:
Access to Legal Material
Admission and Release
Detainee Grievance Procedures
Disciplinary System
Environmental Health and Safety
Food Service
Funds and Personal Property
Medical Care
Staff-Detainee Communication
Use of Force
Visitation
ODO findings for these standards are presented in the remainder of this report.

1

Deficiencies relating to omissions from the detainee handbook are noted under the relevant NDS that requires the
information. See Funds and Personal Property (Deficiency F&PP-1).
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ACCESS TO LEGAL MATERIAL (ALM)
ODO reviewed the Access to Legal Material standard at RRJ to determine if detainees have
access to a law library, legal materials, courts, counsel and document copying equipment to
facilitate the preparation of legal documents, in accordance with ICE NDS. ODO reviewed
policies, procedures, and the detainee handbook; inspected the areas designated for law library
use; and interviewed staff and detainees.
RRJ does not have a law library located in a designated room for ICE detainees
(Deficiency ALM-1). This is a repeat deficiency from the December 2010 QAR. Instead, each
housing unit in B-pod, where all ICE detainees are housed, has a computer station designated for
legal research purposes. ODO notes the computer stations are located near the housing unit
officers’ posts, away from the televisions and primary dayroom activity areas. ODO also notes
information regarding policies, procedures, and available legal materials are posted. The station
has a desktop computer with the current version of Lexis-Nexis, word processing software, a
printer, and legal information in English and Spanish. Detainees submit a request form for use of
the law library computer, and are able to access the system after establishing a user name and
password. Their work may be saved under their user name, and is accessible only by use of their
unique password. Access to the desktop is permitted from 8:00 a.m. until 11:00 p.m., except
when detainees are confined to their cells during population counts. Detailed information and
instructions on accessing the law library computers is included in both the English and Spanish
versions of the detainee handbook. Notary services, translations, copying, and indigent needs
for legal materials are handled by the ICE case worker, in an office within the pod entrance
hallway.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY ALM-1
In accordance with the ICE NDS, Access to Legal Material, section (III)(A), the FOD must
ensure the facility provide a law library in a designated room with sufficient space to facilitate
detainees’ legal research and writing. The law library shall be large enough to provide
reasonable access to all detainees who request its use. It shall contain a sufficient number of
tables and chairs in a well-lit room, reasonably isolated from noisy areas.

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ADMISSION AND RELEASE (AR)
ODO reviewed the Admission and Release standard at RRJ to determine if procedures are in
place to protect the health, safety, security, and welfare of each person during the admission and
release process, in accordance with the ICE NDS. ODO interviewed staff and detainees;
reviewed policies, procedures, and detention files; and observed admission and intake
procedures.
The admission process at RRJ consists of recording personal information, conducting basic
criminal history checks, taking photographs and fingerprints, conducting medical and mental
health screenings, and inventorying personal property. ODO observed the intake processing of
two detainees, and found the intake officer followed admission processing procedures. RRJ
intake officers conduct thorough pat searches on all detainees entering the intake processing area.
Medical staff performs medical screenings for newly-arriving detainees. There are no routine
strip searches of detainees during intake processing. According to RRJ intake processing staff,
guidelines requiring execution of the Record of Search (Form G-1025) are followed whenever
strip-searches are conducted.
ODO interviewed 20 detainees and reviewed 15 randomly-selected detention files. All detainees
interviewed stated they were issued both the national and facility detainee handbooks. ODO also
confirmed the detainees were issued detainee handbooks by reviewing the acknowledgements
and property receipts maintained in the detention files. All detainees interviewed stated they
were allowed to shower in the intake processing. ODO observed the shower stalls in intake
processing were clean and in sanitary condition. Delousing formula is available for detainees to
wash their hair and body.
A review of 15 detention files showed not all of the required forms and documents associated
with the admission process were maintained in the detainee detention files. Six of the
15 detention files were missing Form I-203, Order to Detain or Release Alien
(Deficiency AR-1). RRJ informed ODO that Form I-216, Record of Persons and Property
Transfer, accompanying detainees to the facility, is used as the replacement for Form I-203.
ODO reiterated, as per the NDS, Form I-216 is not a replacement for Form I-203
(Deficiency AR-2). During the CI and at the closeout briefing, ODO reminded ERO
Washington, staff must complete Form I-203 for each detainee and engage in collaborative
efforts with RRJ staff to ensure the forms generated during intake processing are maintained in
each detainee’s detention file. A correctly executed Form I-203 is required for accounting
purposes, since Form I-203 is the document which authorizes detention or release at a designated
facility.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY AR-1
In accordance with the ICE NDS, Admission and Release, section (III)(A), the FOD must ensure
staff will open a detainee detention file as part of the admissions process. This file will contain
all paperwork generated by the detainee’s stay at the facility.

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DEFICIENCY AR-2
In accordance with the ICE NDS, Admission and Release, section (III)(H), the FOD must ensure
an order to detain or release (Form I-203 or I-203a) bearing the appropriate official signature
shall accompany the newly arriving detainee.

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DETAINEE GRIEVANCE PROCEDURES (DGP)
ODO reviewed the Detainee Grievance Procedures standard at RRJ to determine if a process to
submit formal or emergency grievances exists and responses are provided in a timely manner,
without fear of reprisal. In addition, the review was conducted to determine if detainees have an
opportunity to appeal responses and, if accurate records are maintained in accordance with the
ICE NDS. ODO interviewed staff and reviewed logbooks, forms, detainee grievance policies
and procedures, and the detainee handbook.
RRJ has a grievance system that allows detainees to submit formal or emergency grievances, and
provides detainees with at least one level of appeal. The inmate services coordinator/
ombudsman manages the grievance program at RRJ.
The grievance process begins as an informal grievance where facility staff attempts to resolve the
issue at the lowest possible level, in an orderly and timely manner. The informal grievance may
be given either verbally or in writing by the detainee. If the grievance is not resolved at this level
the detainee may proceed with submitting a formal grievance in writing. The ombudsman stated
detainees are not allowed to bypass or terminate the informal grievance process and proceed
directly to the formal grievance stage (Deficiency DGP-1). ODO informed facility staff
members, per the ICE NDS Detainee Grievance Procedures standard, detainees are to be allowed
the freedom to bypass or terminate the informal grievance process and proceed directly to the
formal grievance stage. Grievance forms are available at the officer’s station in each housing
area.
Detainees who claim an issue is sensitive, or believe their safety or well-being could be
jeopardized if others in the facility were apprised of the nature of the grievance, may seal the
grievance in an envelope and submit it directly to the ombudsman, Facility Administrator, or
ICE. Grievances are picked up on a daily basis by designated RRJ staff members and delivered
to the ombudsman’s office. Each written grievance is logged, and referred to the appropriate
department personnel for resolution. The Superintendent may also review the grievance for
resolution at any time. The ombudsman may meet with the detainee and attempt to resolve the
issue. If a detainee agrees with a proposed resolution the form is signed, logged, filed in the
ombudsman’s office, and a copy is placed in the detainee’s detention file and another copy is
given to the detainee. This initial process is resolved within nine days per RRJ policy and
procedures. The detainee may submit a grievance at any time to ICE. If the detainee is not
satisfied with the decision, an appeal may be filed to the Superintendent or to ICE.
ODO interviewed(b)(7) randomly-selected RRJ staff members who have daily contact with
detainees, to determine their awareness of the grievance system. All staff members were able to
describe the grievance process, including the informal, formal, and emergency grievance
processes, as well as the appeal process. RRJ officers stated they make a concerted effort to
resolve all grievances informally but do not discourage detainees from filing formal grievances.
All staff has been trained during an initial orientation and during on-the-job training to handle
emergency grievances expeditiously, ensuring detainees’ safety and welfare.

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A review of the Grievance Log revealed grievances are logged with all pertinent information,
including the nature of the grievance and date of resolution. Log numbers are assigned in
chronological order for each grievance. The log is maintained in the ombudsman’s office.
ODO reviewed the grievance log from January 2012 to October 2012 and noted 39 formal
logged grievances. All grievances were resolved within nine days. Ten grievances related to
medical. All of the medical grievances were referred to and resolved by the facility medical unit
prior to ODO’s arrival. There were no grievances filed alleging staff misconduct. No grievances
were appealed during this period. RRJ management informed ODO, there has been no pattern of
misuse of the grievance system by any detainee. A review of RRJ documentation revealed the
facility does not document informal grievances in detainee detention files, logs, or data systems
to track such actions (Deficiency DGP-2). ODO recommends the facility devise a method for
documenting informal grievances.
Detainees are informed of the grievance system through the RRJ orientation video and detainee
handbook. ODO randomly interviewed 10 detainees who had never filed a grievance at RRJ to
determine their respective overall understanding of the grievance system. All stated they are
aware of the grievance process and currently have no reasons to complain about the facility.
ODO determined all detainees interviewed were issued an ICE National Detainee Handbook and
a local RRJ handbook. Both books address grievance procedures, including instructions for
contacting ICE to appeal decisions made by the facility.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY DGP-1
In accordance with the ICE NDS, Detainee Grievance Procedures, section (III)(A)(1), the FOD
must ensure the detainees is free to bypass or terminate the informal grievance process, and
proceed directly to the formal grievance stage.
DEFICIENCY DGP-2
In accordance with the ICE NDS, Detainee Grievance Procedures, section (III)(A)(1), the FOD
must ensure, if an oral grievance is resolved to the detainee's satisfaction at any level of review,
the staff member need not provide the detainee written confirmation of the outcome, however the
staff member will document the results for the record and place his/her report in the detainee’s
detention file.

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DISCIPLINARY POLICY (DP)
ODO reviewed the Disciplinary Policy standard at RRJ to determine if sanctions imposed on
detainees who violate facility rules are appropriate, and if the discipline process includes due
process requirements, in accordance with the ICE NDS. ODO interviewed staff, and reviewed
policy, disciplinary records, and the detainee handbook.
Detainees are notified of prohibited acts and the disciplinary process during orientation and by
way of the detainee handbook. In addition, the handbook advises detainees of their rights and
protections, and procedures for appealing guilty findings. The facility uses a progressive
severity scale for prohibited acts and disciplinary consequences.
The RRJ disciplinary process does not include procedures for investigation of incidents prior to a
disciplinary hearing. Based on staff interviews and review of policy, ODO determined incident
reports are forwarded directly for disciplinary hearings without investigations
(Deficiency DP-1). Independent impartial investigations ensure the alleged rule violations
warrant potential actions through the formal disciplinary process. ODO’s review of five
completed disciplinary packets confirmed the incidents were not investigated prior to the
disciplinary hearing. RRJ does not have a Unit Disciplinary Committee (UDC) or other
intermediate level of adjudication for low or moderate infractions (Deficiency DP-2). The
facility’s hearing officer is responsible for conducting hearings for all levels of prohibited acts.
ODO notes, in the five cases reviewed, documentation was present confirming there was
sufficient evidence to support findings that detainees committed prohibited acts, and the Hearing
Officer informed the detainees of their rights.
RRJ policy authorizes a one- to 23-hour lockdown, which may be imposed as a sanction for
violation of pod rules and other minor violations. During the period of lockdown, all privileges
except visitation are restricted. Though supervisory approval is required, lockdown and
restriction of privileges occurs outside the disciplinary process. ODO finds this practice does not
safeguard against capricious or retaliatory disciplinary actions (Deficiency DP-3). During the
review, ODO learned of six detainees placed on lockdown status for a violation of pod rules.
While on lockdown, they allegedly acted to incite a riot, resulting in issuance of infractions and
placement on administrative segregation in the SMU pending a hearing.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY DP-1
In accordance with the ICE NDS, Disciplinary Policy, section (III)(C), the FOD must ensure
IGSAs shall have procedures in place to ensure that all incident reports are investigated within
24 hours of the incident.
The investigating officer shall have supervisory rank, or higher (unless prevented by personnel
shortages) and shall have had no prior involvement in the incident, either as witness or officer at
the scene. If an officer below supervisory rank conducts the investigation, the shift supervisor
shall review his/her report(s) for accuracy, completeness and sign them.

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DEFICIENCY DP-2
In accordance with the ICE NDS, Disciplinary Policy, section (III)(C) Unit Disciplinary
Committee, the FOD must ensure all facilities shall establish an intermediate level of
investigation/adjudication is present to adjudicate low or moderate infractions. They shall also
ensure that the detainee is afforded all the rights listed under “Detainee Rights in UDC
Proceedings,” below.
DEFICIENCY DP-3
In accordance with the ICE NDS, Disciplinary Policy, section (III)(A)(2), the FOD must ensure
disciplinary action may not be capricious or retaliatory.

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ENVIRONMENTAL HEALTH AND SAFETY (EH&S)
ODO reviewed the Environmental Health and Safety standard at RRJ to determine if the facility
maintains high standards of cleanliness and sanitation, safe work practices, and control of
hazardous materials and substances, in accordance with the ICE NDS. ODO toured the facility;
interviewed staff; and reviewed procedures and documentation of inspections, hazardous
chemical management, and fire drills.
The overall sanitation of the facility was good, although concerns were noted. Inspection of
shower areas in three of four detainee housing units found they were maintained in sanitary
condition and in good repair. However, in Unit B-1, ODO observed paint peeling off the shower
floor. RRJ’s Safety Officer was present and submitted a work order to address the peeling paint.
In addition, the two shower areas in the intake section were found to be in very unsanitary
condition. Mold was observed on the wall in one shower area and trash was observed on the
floor near the drain. A buildup of soap scum was identified in the second shower, and the metal
benches in both showers were rust-covered as a result of paint peeling off. The ODO inspector
observed rust residue on his hand after coming in contact with the bench. Intake staff was
present and indicated they would submit work orders to have the benches repaired and showers
sanitized.
A master index of hazardous substances and Material Safety Data Sheets were available,
including documentation of semi-annual reviews. ODO verified Material Safety Data Sheets
were present at each location where chemicals are used. No hazardous substances are stored
inside the secure perimeter of the facility. Required weekly and monthly inspections are
conducted throughout the facility. Fire drills are conducted on a monthly basis and are welldocumented. Emergency keys are not checked out and tested during fire drills
(Deficiency EH&S-1). Accessing and testing emergency keys ensures staff is familiar with the
keys, locks, and exit routes, supporting expeditious egress in the event of an emergency.
RRJ’s emergency power generator is tested and serviced by an external company on a quarterly
basis. Staff tests the generator on a weekly basis for only 18 minutes, rather than testing biweekly for at least one hour (Deficiency EH&S-2). ODO was informed by RRJ maintenance
personnel that weekly testing for 18 minutes is recommended by the generator manufacturer.
Barbering is conducted in a dedicated room along the hallway of B-Pod where ICE detainees are
housed. The room is not equipped with a sink that has hot and cold running water
(Deficiency EH&S-3), and sanitation regulations for barber operations are not posted
(Deficiency EH&S-4). This is a repeat deficiency from the December 2010 QAR. A secure
plastic bag with clippers, combs, disinfectant, and other barbering equipment is maintained in the
shift supervisor’s office, and issued to the housing unit at the time designated for haircuts.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY EH&S-1
In accordance with the ICE NDS, Environmental Health and Safety, section (III)(L)(4)(c), the
FOD must ensure 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
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not in daily use. NFPA recommends a limit of four and one-half minutes for drawing keys and
unlocking emergency doors.
DEFICIENCY EH&S-2
In accordance with the ICE NDS, Environmental Health and Safety, section (III)(O), the FOD
must ensure power generators will be tested at least every two weeks. Other emergency
equipment and systems will undergo quarterly testing, with follow-up repairs or replacement as
necessary.
The biweekly test of the emergency electrical generator will last one hour. During that time, the
oil, water, hoses and belts will be inspected for mechanical readiness to perform in an emergency
situation. The emergency generator will also receive quarterly testing and servicing from an
external generator-service company. Among other things, the technicians will check starting
battery voltage, generator voltage and amperage output.
DEFICIENCY EH&S-3
In accordance with ICE NDS, Environmental Health and Safety, section (III)(P), the FOD must
ensure sanitation of barber operations is of the utmost concern because of the possible transfer of
diseases through direct contact or by towels, combs and clippers. Towels must not be reused
after use on one person. Instruments such as combs and clippers will not be used successively on
detainees without proper cleaning and disinfecting. The following standards will be adhered to:
1. The operation will be located in a separate room not used for any other purpose. The floor
will be smooth, nonabsorbent and easily cleaned. Walls and ceiling will be in good repair
and painted a light color. Artificial lighting of at least 50-foot candles will be provided.
Mechanical ventilation of 5 air changes per hour will be provided if there are no operable
windows to provide fresh air. At least one lavatory will be provided. Both hot and cold
water will be available, and the hot water will be capable of maintaining a constant flow of
water between 105 degrees and 120 degrees.
DEFICIENCY EH&S-4
In accordance with the ICE NDS, Environmental Health and Safety, section (III)(P)(4), the FOD
must ensure each barbershop will have detailed hair care sanitation regulations posted in a
conspicuous location for the use of all hair care personnel and detainees.

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FOOD SERVICE (FS)
ODO reviewed the Food Service standard at RRJ to determine if detainees are provided with a
nutritious and balanced diet, in a sanitary manner, in accordance with the ICE NDS. ODO
interviewed staff, inspected storage areas, observed meal preparation and service, and reviewed
policies and relevant documentation.
Aramark Correctional Service manages the Food service operation at RRJ. Food service staff
consists of the Food Service Director, Assistant Food Service Director, and (b)(7)e kitchen
supervisors, supported by a crew of(b)(7)ecounty inmates. No ICE detainees work in food service.
Inspection of the food service operation confirmed knives and utensils were properly controlled,
food temperature requirements were met, and the menu was certified by a registered dietitian
based on a complete nutritional analysis. At the time of the review, 13 ICE detainees were on
medical diets and one detainee was on a religious diet. Documentation supports that special diets
were approved and provided in accordance with the standard.
The RRJ food service operation was inspected by the Stafford County Environmental Health
Department in March 2012, during which two compliance issues were noted. Both issues were
corrected during that inspection, and no follow-up inspection was required. Inmate workers
wear green uniforms, which are changed daily, along with hairnets, beard nets, and gloves.
Employees wear Aramark-provided uniforms, hats, gloves, and beard nets when necessary. All
visitors to the kitchen are required to wear hair and beard nets.
ODO sampled the noon meal on Wednesday during the inspection. All items were in accordance
with the menu for that particular meal. The items were at the appropriate temperatures and
properly seasoned; proportions were as listed on the menu. RRJ has a satellite system of meal
service involving preparation of meals in the kitchen and delivery to housing units on thermal
trays. During observation of preparation and delivery of a meal, ODO noted the carts used to
transport food trays are not secure. The carts are metal with open shelves, on which the trays are
placed for transport by inmate workers (Deficiency FS-1). Although the food trays have lids, the
lids are not secure and may be easily opened. Transporting trays on secured carts prevents food
tampering.
Documentation was available verifying all inmate workers received medical screenings and
clearances prior to working in the kitchen. No Aramark employees had undergone preemployment medical examinations at the time of the review (Deficiency FS-2). Medical
examinations serve the critical purpose of ensuring prospective food service workers do not have
a communicable disease in any transmissible stage or condition. Aramark management informed
ODO that medical exams for their employees would be scheduled within the next week.
During random interviews conducted by ODO, one detainee complained of being served
bologna, “…all the time. That’s all we get.” While reviewing the current menu, ODO noted
bologna was served for breakfast or lunch on three of the six days prior to the inspection. The
issue was discussed with Aramark management and a menu review was initiated. During the
inspection, ODO was informed a new menu would be implemented to address the issue.

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STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY FS-1
In accordance with the ICE NDS, Food Service, section (III)(C)(2)(g), the FOD must ensure
food will be delivered from one place to another in covered containers. These may be individual
containers, such as pots with lids, or larger conveyances that can move objects in bulk, such as
enclosed, satellite-feeding carts. Food carts must have locking devices.
DEFICIENCY FS-2
In accordance with the ICE NDS, Food Service, section (III)(H)(3)(a), the FOD must ensure all
food service personnel (both staff and detainee) shall receive a pre-employment medical
examination. The purpose of this examination is to exclude those who have a communicable
disease in any transmissible stage or condition. Detainees who have been absent from work for
any length of time for reasons of communicable illness (including diarrhea) shall be referred to
Health Services for a determination as to fitness for duty prior to resuming work.

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FUNDS AND PERSONAL PROPERTY (F&PP)
ODO reviewed the Funds and Personal Property standard at RRJ to determine if controls are in
place to inventory, receipt, store, and safeguard detainees’ personal property, in accordance with
the ICE NDS. ODO reviewed policies, procedures, and the detainee handbook; interviewed
staff; observed processing of detainees; and inspected areas where property is maintained.
The property storage area is behind locked doors, located in a separate area from intake
processing, and is only accessible to property room staff. ODO found all detainees’ property
bags are clearly marked with a large tag documenting the detainees’ name and detainee
identification number. Property is stored using a numerical system.
The detainee handbook does not provide information concerning the facility’s policies and
procedures for obtaining certified copies of any identity document (Deficiency F&PP-1).
Having these procedures included in the detainee handbook ensures detainees are aware of the
facility’s procedures, and provides for better accountability.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY F&PP-1
In accordance with the ICE NDS, Funds and Personal Property, section (III)(J)(2), the FOD must
ensure the detainee handbook or equivalent shall notify the detainees of facility policies and
procedures concerning personal property, including:
2. That, upon request, they will be provided an INS-certified copy of any identity document
(passport, birth certificate, etc.) placed in their A-files.

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Detainees undergo medical and mental health screenings upon arrival by specially-trained
correctional officers. ODO verified completion of intake screenings in all 25 medical records
reviewed, and all detainees signed consents for treatment. Before new detainees leave the
booking area, they are seen by a nurse who reviews the screening information documented by
officers to determine if there are medical or mental health issues requiring attention. In addition,
tuberculosis screenings by way of PPD skin test are conducted as part of the intake process.
Chest X-rays are completed for detainees whose PPD tests are positive, as well as for detainees
with a history of testing positive.
ODO verified physical examinations were completed by RNs within 14 days of arrival in all
records reviewed; however, 24 of 25 physical examinations were not reviewed and countersigned by a physician. In addition, ODO determined RN training for conducting physical
examinations consisted of viewing an assessment video. They have not completed training
conducted or approved by a physician (Deficiency MC-1). This is a repeat deficiency from the
December 2010 QAR. Proper training and physician review of physical examinations is critical
to ensuring the examinations are correctly conducted, and proper follow-up takes place. Review
of completed physical examinations confirmed they included a “hands-on” review of all major
systems, and detainees were referred to a provider if a chronic or other medical condition
requiring follow-up was identified.
ODO verified all RRJ and contract medical staff credentials were current and primary-source
verified. Review of training records for all RRJ medical staff an (b)(7)e andomly-selected custody
staff confirmed current certifications in CPR and first aid training; however, none of the contract
medical staff had current certifications in CPR or first aid (Deficiency MC-2). This is a repeat
deficiency from the December 2010 QAR. The physician assistant on duty informed ODO that
Mary Washington Hospital does not require their staff contracted to RRJ to maintain
certifications.
Detainees request healthcare services by completing forms printed in both English and Spanish,
and in triplicate. The detainee dates and signs the request form and keeps one copy. During
ODO’s tour of the housing units, ODO confirmed the availability of request forms. Unit officers
stated assistance is available for illiterate detainees and others who may need assistance. The
forms are placed into a separate and secure box in the housing unit. The time the form is
received and triaged by medical staff is recorded on the form, as is the date the detainee is seen,
along with the provider’s note summarizing the encounter. ODO cites the triplicate sick call
request form as a best practice because it supports accountability for request processing, and
documentation of timeliness. Sick call is provided seven days a week in the detainee housing
cluster; alternatively, detainees may be seen in the clinic when necessary. When a detainee is
seen in the clinic, there is a holding area with access to a bathroom and drinking fountain. A unit
officer is present at all times. Medications are delivered and administered by nurses three times
each day. Detainees are not charged a fee for healthcare services. A telephonic language
interpretation service is available for detainees with limited English language proficiency.
When detainees are transferred, two forms are completed for forwarding to the receiving facility:
a medical screening form and a Medical Summary of Federal Prisoner/Alien in Transit. These
forms are placed into a sealed envelope with the detainee’s name, date of birth, and alien number

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documented on the envelope. When detainees are released to the community, procedures are in
place for medical staff to inform the detainees of any pending appointments in the community.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY MC-1
In accordance with the ICE NDS, Medical Care, section (III)(D), the FOD must ensure health
appraisals will be performed according to NCCHC [National Commission on Correctional
Health Care] and JCAHO [Joint Commission on Accreditation of Healthcare Organizations]
standards.
NCCHC standard J-E-04 states the hands-on portion of the health assessment may be performed
by an RN only when the nurse completes appropriate training that is approved by the responsible
physician. All findings must be reviewed by a physician when the RN completes the physical.
DEFICIENCY MC-2
In accordance with the ICE NDS, Medical Care, section (III)(H), the FOD must ensure detention
staff will be trained to respond to health-related emergencies within a 4-minute response time.
This training will be provided by a responsible medical authority in cooperation with the OIC
and will include the following:
2. The administration of first aid and cardiopulmonary resuscitation (CPR).

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STAFF-DETAINEE COMMUNICATION (SDC)
ODO reviewed the Staff-Detainee Communication standard at RRJ to determine if procedures
are in place to allow formal and informal contact between detainees, and key ICE and facility
staff; and if ICE detainees are able to submit written requests to ICE staff and receive responses
in timely manner, in accordance with the ICE NDS. ODO interviewed ERO employees, as well
as facility staff and detainees; and reviewed logbooks, policies and procedures.
RRJ employs both informal and formal procedures for key ICE and facility staff to interact with
detainees on a regular basis. ICE staff conducts unscheduled and unannounced contacts through
the Acting AFOD, and Supervisory Detention and Deportation Officers. During these
unannounced visits, ERO department heads visit the facility’s living and activities areas,
including housing units, food services, recreation, special management units, and medical care
infirmary rooms. A logbook in each of the housing units records ICE staff’s unannounced visits.
ODO confirmed, from interviewing six detainees and RRJ staff, the IEA assigned to the facility
is very active in addressing detainees’ personal concerns and monitoring living conditions. A
Deportation Officer was also observed visiting detainees during the ODO inspection.
The formal process of interaction begins from the moment written questions, requests, or
personal concerns are submitted. The housing officers provide request forms to detainees upon
request. The completed forms are handed to the RRJ housing officers or directly to ICE officers.
One IEA is assigned full-time to RRJ. Detainees’ requests pertaining to facility services are
handled in accordance with the facility’s established guidelines. ODO confirmed from
interviewing six detainees and RRJ staff, the assigned IEA is proactive in addressing detainees’
personal concerns and monitoring living conditions. ODO was informed by the facility and ICE
staff, the responsibilities seem overwhelming for one IEA. ODO was informed ERO has
scheduled visits with detainees on Tuesdays and Thursdays of each week. However, the written
visit schedules were not posted in each of the housing units, or other areas with detainee access
(Deficiency SDC-1).
On Wednesday, November 14, 2012, one Deportation Officer visited RRJ for the scheduled
contact visit with detainees. ODO noted the Deportation Officer spent approximately two hours
with detainees in the housing units and departed the facility before noontime. The Deportation
Officer did not visit the SMUs or the medical infirmary. On Thursday, November 15, 2012,
none of the Deportation Officers from ERO Washington conducted the scheduled contact visit
with detainees (Deficiency SCD-2).
ICE staff checks the telephones located in detainees’ housing areas for serviceability, and
completes the Model Protocol for ERO Officer Facility Liaison Visit. The Model Protocol is
designed for conducting and documenting liaison visits, observing living conditions and
engaging in staff-detainee communications. ODO reviewed the Model Protocol sheets and
found the required information is captured. ODO observed detainee requests for information
pertaining to immigration cases and the associated responses are not logged. The requests for
information are assigned to Deportation Officers, according to the case docket. The requests for
information are required to be logged whenever request forms are received by ICE, as well as
when responses are provided to detainees. Completed request forms, including ICE’s responses,
are not recorded or maintained in each individual detainee’s detention file for at least three
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years (Deficiency SDC-3). During the close-out briefing, ERO staff stated corrective actions
will be implemented for maintaining copies of completed detainee requests and corresponding
responses.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY SDC-1
In accordance with the ICE NDS, Staff-Detainee Communication, section (III)(A)(2)(b), the
FOD must ensure the ICE Field Office Director shall devise a written schedule and procedure for
weekly detainee visits by District ICE deportation staff. The ICE officer will also visit the
facility’s Special Management Units (SMU) to interview any ICE detainees housed there,
monitor housing conditions, review detainees’ classification and basis for placement in the SMU,
and review all records in this regard. Written schedules shall be developed and posted in the
detainee living areas and other areas with detainee access. The ICE Field Office Director shall
have specific procedures for documenting the visit. IGSAs with larger populations should be
visited more often if necessary.
DEFICIENCY SDC-2
In accordance with the ICE NDS, Staff-Detainee Communication, section (III)(A)(2), the FOD
must ensure the purpose of these scheduled weekly visits is to address detainees’ personal
concerns and to monitor living conditions. Facility or District deportation staff in the jurisdiction
where these facilities are located shall conduct these scheduled visits. The visiting officer should
be familiar with the detention standards and report all violations to the Field Director.
DEFICIENCY SDC-3
In accordance with the ICE NDS, Staff-Detainee Communication, section (III)(B)(2), the FOD
must ensure, in IGSAs, the date the request was forwarded to ICE and the date it was returned
shall also be recorded.
All completed Detainee Requests will be filed in the detainee’s detention file and will remain in
the detainee’s detention file for at least three years.

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USE OF FORCE (UOF)
ODO reviewed the Use of Force standard at RRJ to determine if necessary use of force is used
only after all reasonable efforts have been exhausted to gain control of a subject, while protecting
and ensuring the safety of detainees, staff and others, preventing serious property damage, and
ensuring the security and orderly operation of the facility, in accordance with the ICE NDS.
ODO interviewed staff, and reviewed local policy, training records, and use of force
documentation.
RRJ’s use of force policy distinguishes between immediate and calculated force, and stresses
confrontation avoidance prior to application of force. ODO was informed there was one
immediate use of force incident involving an ICE detainee in the past year and no calculated use
of force incidents.
ODO reviewed documentation in the immediate use of force incident and confirmed the detainee
was medically examined following the incident; however, an after action review was not
conducted. Interviews of the Special Response Team lieutenant and captain confirmed afteraction reviews are not conducted following use of force incidents (Deficiency UOF-1). Afteraction reviews are critical for conducting an assessment of whether applied force was necessary
and reasonable. ODO was informed ICE is notified of use of force incidents by way of incident
reports only. ICE confirmed this notification process, and stated they also receive telephone
calls.
Based on staff interviews and a review of policy requirements for video recording calculated
force incidents, ODO determined responsibility is not designated for maintaining recording
equipment, to include routine inspections and testing (Deficiency UOF-2). Ensuring recording
equipment is maintained and operable ensures calculated use of force incidents may be properly
documented. In addition, ODO notes staff reported video recording occurs only when the
Special Response Team is assembled to complete a cell extraction. When this occurs, only the
cell extraction itself is video recorded. There is no requirement in policy to video record all
other calculated use of force incidents, and for the video recordings to include all steps in a
calculated use of force as required by the NDS. A deficiency is not being cited because there
were no calculated force incidents involving detainees; however, ODO recommends revision of
the use of force policy to support compliance with the standard in the event of future calculated
force incidents.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY UOF-1
In accordance with the ICE NDS, Use of Force, section (III)(K) the FOD must ensure written
procedures shall govern the use-of-force incident review, whether calculated or immediate, and
the application of restraints. The review is to assess the reasonableness of the actions taken
(force proportional to the detainee's actions), etc. IGSA will pattern their incident review process
after INS. INS shall review and approve all After Action Review procedures.

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DEFICIENCY UOF-2
In accordance with the ICE NDS, Use of Force, section (III)(A)(4)(l), the FOD must ensure the
OIC shall designate responsibility for maintaining the video camera(s) and other video
equipment. This shall include regularly scheduled testing to ensure all parts, including batteries,
are in working order; and keeping back-up supplies on hand (batteries, tapes, lens-cleaners, etc.).
This responsibility shall be incorporated into one or more post orders.

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VISITATION (V)
ODO reviewed the Visitation standard at RRJ to determine if authorized persons, including legal
and media representatives, are able to visit detainees within security and operational constraints,
in accordance with the ICE NDS. ODO reviewed the local policy and detainee handbook,
inspected the visiting area, and interviewed staff and detainees.
The facility has written visitation procedures, including a schedule and hours of visitation.
Detainees are notified of visitation rules and hours by way of a video orientation upon entry into
the facility, and through the detainee handbook. Visitation information is available to the public
by way of a telephone recording, postings in the visitor’s entrance, and the facility’s website.
Separate logs for general visitors and legal representatives are maintained.
All detainees, including those in the SMUs, are allowed visitation with family, friends, legal
representatives, and members of the media. Media visits require approval by the Superintendent.
Legal visitation is available seven days a week, including holidays. On regular business days,
legal visitation hours provide for a minimum of eight hours per day between 8:30 a.m. and
4:30 p.m., and a minimum of four hours per day on weekends and on holidays between 8:00 a.m.
and 12:00 p.m.
The facility has procedures regarding incoming property and money. Visitors may mail funds or
property, or deposit money into a detainee’s account at the facility. RRJ staff informed ODO,
under no circumstances are visitors allowed to give property or money directly to a detainee.
Form G-28, Notice of Entry of Appearance as Attorney or Accredited Representative, was not
available in the legal visitors’ reception area (Deficiency V-1). Form G-28 verifies attorneyclient relationships and notifies ICE of detainees’ legal representations. Before departing the
facility, ODO provided a copy of Form G-28 to the staff in the reception area. ODO also
informed facility staff that attorneys representing detainees on legal matters unrelated to
immigration are not required to complete Form G-28.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY V-1
In accordance with the ICE NDS, Visitation, section (III)(I)(8), the FOD must ensure, once an
attorney-client relationship has been established, the legal representative shall complete and
submit a Form G-28, available in the legal visitors’ reception area. Staff shall collect completed
forms and forward them to INS.

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