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
Dallas Field Office
Rolling Plains Detention Center
Haskell, Texas

December 4 - 7, 2012

COMPLIANCE INSPECTION
ROLLING PLAINS DETENTION CENTER
DALLAS FIELD OFFICE
TABLE OF CONTENTS
EXECUTIVE SUMMARY ...............................................................................................1
INSPECTION PROCESS
Report Organization .................................................................................................7
Inspection Team Members .......................................................................................7
OPERATIONAL ENVIRONMENT
Internal Relations .....................................................................................................8
Detainee Relations ...................................................................................................8
ICE NATIONAL DETENTION STANDARDS
Detention Standards Reviewed ................................................................................9
Food Service ..........................................................................................................10
Medical Care ..........................................................................................................12
Staff-Detainee Communication .............................................................................14
Use of Force ...........................................................................................................15

identified deficiencies. These deficiencies were discussed with RPDC and ICE personnel during
the inspection, as well as during the closeout briefing conducted on December 6, 2012. The
majority of deficiencies identified were related to practices and procedures having minimal
impact to life-safety issues and the overall operational readiness of the facility. ODO learned
through interviews with staff that RPDC personnel have not received any formal training on the
ICE NDS. ODO attributes the high level of compliance to the effective presence of the DSM at
RPDC. The minimal amount of detainee issues is a direct reflection of the DSM’s oversight of
the facility’s daily operations, and regularly keeping ERO Headquarters management abreast of
issues that may affect the safety and well-being of detainees.
Overall, ODO found RPDC to be orderly and well managed. The overall sanitation of the
facility was very good; however, ODO observed peeling paint in all of the detainee housing unit
shower areas. The Chief of Security was present during ODO’s inspection of the shower areas
and reported the peeling paint issue to the Warden, the Emerald Corporate Director of
Operations, and the Director of Contract Compliance. The Warden later confirmed the facility is
working to find a solution to address the problem as quickly as possible.
During the admissions process, detainees undergo medical screenings, attend a facility
orientation, and receive an RPDC facility detainee handbook and the ICE National Detainee
Handbook, which are both available in the English and Spanish languages. Detainees are
provided with appropriate clothing and hygiene supplies. Valuables are placed in property bags
and stored in a secure storage area. Detainee property is inventoried and logged during the
intake process, and documented on a personal property form attached to the detainees’ property
bags. ODO reviewed 20 detainee detention files and found all files had classification forms
signed by a reviewing supervisor, proof of hygiene items issued, and detainee signatures of
receipt for both facility and ICE national detainee handbooks. Furthermore, new arrivals at
RPDC are shown the “Know Your Rights” and RPDC orientation videos.
The RPDC law library has adequate furnishings in a well-lit, quiet room. RPDC has seven
computers in the law library and one mobile computer for the Special Management Units,
installed with the most recent version of Lexis-Nexis. Additional hard copy legal reference
material is available. Library hours are posted and placed in all detainees’ housing units, as well
in the facility’s detainee handbook. A law librarian oversees the law library and is available to
assist detainees.
Detainees are classified by ICE prior to arrival at RPDC, and facility staff adheres to the
classification assignment made by ICE. Review of 20 detention files confirmed ICE provides
the facility with forms and information to support the ICE-provided classification level. RPDC
staff reviews the information provided by ICE, and verifies the classification level before
assigning the detainee to a housing unit. Review of housing unit rosters confirmed Level I
detainees are not mixed with Level III detainees. ODO confirmed procedures are in place for
reclassifying detainees when necessary. A supervisor reviews and approves all classification and
reclassification actions. The detainee handbook includes information on the classification
system, and addresses procedures for appealing classification decisions.
Grievance forms are freely available in all housing units. RPDC attempts to resolve oral and
written detainee grievances informally and at the lowest level possible. Detainees are free to
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bypass or terminate the informal grievance process and proceed directly to filing a formal
grievance. RPDC has procedures for identifying and handling an emergency grievance, and the
grievance process is recorded in the facility-specific detainee handbook. Additionally,
procedures for filing and appealing a grievance are provided in the detainee handbook. Upon
resolution of informal and formal grievances, copies of grievances are filed in a Detainee
Grievance Log, and the original grievance form is placed in the detainee’s detention file. RPDC
received 242 grievances from January to November 2012. No specific trends or patterns were
observed relating to review of grievances. A review of each showed informal and formal
grievances were addressed in a timely manner, and resolutions for each were documented. ODO
reviewed ten randomly-selected detention files of detainees who had filed a grievance. Each file
contained the original grievance.
Both the English and Spanish versions of the RPDC handbook are posted in all detainee housing
units and in the law library. RPDC’s handbook advises detainees of their responsibilities,
classifications levels, claims for lost/damaged property, sexual abuse and assault prevention and
intervention information, and medical care, among others. Additionally, RPDC’s handbook
describes programs such as voluntary work, religious services, recreation activities, access to the
library, barbering and hair cutting services, and commissary. The handbook provides
information on the opportunity to file a complaint about officer misconduct directly with the
Department of Homeland Security’s Office of the Inspector General (OIG). Informational
posters, which advise detainees on how to contact DHS-OIG to make a complaint, were visible
throughout all detainee housing units.
Disciplinary procedures, prohibited acts, sanctions, and the appeal process are detailed in the
facility’s detainee handbook. No disciplinary hearings were scheduled during the inspection.
ODO reviewed reports from 25 disciplinary hearings conducted in the past year, and confirmed
they were handled in compliance with the standard.
Review of(b)(7)erandomly-selected training files confirmed staff receives monthly safety training.
The master index of hazardous substances and Material Safety Data Sheets were up-to-date, and
included documentation of semi-annual reviews. ODO verified Material Safety Data Sheets are
located at each location where chemicals are used. No hazardous substances are stored inside the
secure perimeter of the facility. The inspection team confirmed inventories of cleaning
chemicals used within the facility were accurate and current. Required weekly and monthly fire
and safety inspections are conducted throughout the facility. Fire drills are conducted monthly
and are well documented. The emergency generator is tested weekly for one hour, and is
serviced by an external company on a quarterly basis.
The food service operation is managed by RPDC employees, including the food service
supervisor and (b)(7)e cook specialists. The staff is supported by a crew of(b)(7)eICE detainees.
ODO verified all staff and detainees working in food service received pre-employment medical
clearances. The food service staff is responsible for security in the food service area, including
tool and key control, detainee accountability, and searches. Review of training records and the
curriculum confirmed proper training in these functions by the Texas Jail Commission. Review
of documentation confirmed the master-cycle menu is reviewed annually by the Food Service
Supervisor and certified by a registered dietician based on a complete nutritional analysis. The
master menu is a 35-day cycle, and includes at least two hot meals per day, with a variety of
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meals. Religious diets are approved by the Chaplain, and medical diets are provided when
ordered by the medical unit. Review of religious and medical diet menus confirmed approval by
the registered dietician. ODO’s inspection of the food substitution log confirmed selection of
substitutions from the master menu and approval by the Food Service Supervisor.
Staff and detainee workers were observed wearing hair restraints and beard guards; however,
detainee workers wore their personal or facility-issued tennis shoes, and were not issued
approved rubber-soled safety shoes. ODO observed food preparation equipment was clean,
properly installed, and equipped with emergency gas shut-off valves; however, the meat slicer
was not equipped with an anti-restart device. Equipment powered by electricity stops working
when the electrical power is interrupted. Once power is restored, the equipment restarts
automatically, presenting a significant safety hazard to staff and detainee workers.
RPDC has written policies and procedures that provide for the control and safeguarding of
detainees’ funds and personal property while housed at the facility, during release and transfer
proceedings, and for funds and property that is lost, damaged, or abandoned. ODO verified
property is properly inventoried and recorded on an inventory form. The detainee signs and
receives a copy of the inventory form. Property bags are sealed and secured in the facility’s
property room, which is under the direct supervision of the property supervisor. ODO observed
the property room was neat and well-organized, and is located in a secure location adjacent to the
intake area. Detainees are provided with bins for storage of personal property, allowed for
retention in the housing units. Detainees are not authorized to keep money in their possession.
Detainee money is deposited in an automated detainee funds account. Detainees receive receipts
for any money deposited. Review of seven detention files confirmed the presence of property
inventory forms and funds receipts.
Healthcare is provided by Emerald Health Care. The clinic is open 24 hours a day, seven days a
week. It is administered by a Health Services Administrator (HSA), who also serves as the
mental health crisis manager; however, a registered nurse (RN) is currently transitioning into the
HSA position. An RN Director of Nursing is scheduled to begin on January 7, 2013. Medical
oversight is provided by the Clinical Director, who is on-site one day a week, and on-call
24 hours a day seven days a week. In addition, there is a part-time nurse practitioner who works
five days a week. Mental health services are provided by a psychologist available one day a
week as needed, and the HSA/full-time mental health crisis manager. A part-time dentist, on-site
one day a week, delivers dental care. These positions are augmented by(b)(7)eicensed practical
nurses, (b)(7)e medical assistants, an administrative assistant, and a medical records clerk. ODO
finds staffing adequate to provide basic medical services for detainees.
Nursing staff screen newly-arrived detainees to identify chronic care, mental health, medication
needs, and symptoms of tuberculosis (TB). TB testing is accomplished by administration of a
purified protein derivative (PPD) skin test. Detainees with a positive PPD reading receive a
chest x-ray (CXR) within 72 hours. Review of 30 detainee medical records confirmed
compliance with all screening and TB testing requirements. Review of 30 medical records
confirmed RNs completed physical examinations (PEs) within 14 days of the detainees’ arrival.
ODO verified the PEs were hands-on and reviewed by a physician, and the RNs completed
training in performance of the function.

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Detainees access health care services by completing sick call requests, available in English and
Spanish, and depositing them directly in secured boxes. Nursing staff retrieve the requests on a
daily basis and triage them for clinical priority. Detainees in the Special Management Units
hand them directly to nursing staff during daily rounds. Nursing staff conduct sick call seven
days a week using physician-approved protocols. ODO verified follow-up appointments and
referrals were completed as indicated. RPDC does not charge detainees co-pays or other fees.
ODO cites as a best practice the availability of pamphlets in the clinic on such conditions as
hypertension, diabetes, and communicable diseases. ODO cites as another best practice anger
and stress management classes conducted by the mental health crisis manager to assist detainees
in developing coping skills.
ODO reviewed facility logbooks, and verified scheduled and unscheduled visits are conducted
by ICE management and staff on a weekly basis. (b)(7)e IEAs are permanently assigned to RPDC,
and conduct scheduled visits once a week to address detainee concerns, monitor conditions of
confinement, and complete the ICE Facility Liaison Visit Checklist. In addition to scheduled
visits, ICE staff conducts multiple unscheduled visits throughout the week. Additionally, a
Supervisory Detention and Deportation Officer visits RPDC at least once a week; the Deputy
Field Office Director and the AFOD have visited the facility at least once during the year prior to
the ODO CI. ODO confirmed each of the visits was logged in the main entrance visitation
logbook. ODO observed written ICE visitation schedules and listings of Deportation Officers
are posted in the detainee housing units. Detainees are able to submit written questions, requests,
and concerns to ERO staff and receive timely responses. ODO reviewed 20 detention files and
confirmed detainees receive timely responses to requests; requests are filed appropriately.
Detainees have reasonable and equitable access to telephones at RPDC. The telephone
availability ratio is approximately one telephone per 12 detainees. Detainees are given
emergency messages and allowed to return emergency telephone calls without delay. Review of
the RPDC Detainee Telephone Log confirmed facility personnel conduct daily inspections of
telephones and respond to maintenance issues within 24 hours. Additionally, ODO reviewed
ICE Telephone Serviceability Worksheets, confirming weekly telephone inspections by ICE
staff. ODO checked the operability of each telephone in all detainee housing areas and found the
telephones to be in good working order. Notifications that telephone calls are subject to
monitoring are posted on each telephone and in the facility-specific handbook. Procedures for
telephone use and obtaining an unmonitored call are addressed in the handbook and posted in
each housing unit.
All staff receives initial and ongoing suicide prevention training, which includes the
identification of suicide risk factors, recognizing the signs of suicidal thinking and behavior,
referral procedures, suicide prevention techniques, and responding to an in-progress suicide
attempt. RPDC uses a curriculum developed locally, which is based on the NDS and presented
by mental health and training staff. Review of(b)(7)etraining files confirmed staff completed initial
and ongoing suicide prevention training. ODO verified detainees are screened for suicide risk
during the intake process. Detainees on suicide watch are housed in one of four observation cells
located in the medical clinic. The cells are suicide resistant, and free from any protrusions or
objects that could assist in a suicide attempt. The medical record review confirmed practice
consistent with policy and in accordance with the NDS. There have been no suicides, no suicide
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attempts, and six documented suicide watches since the last ODO inspection. ODO was
informed there was one detainee death at RPDC, which occurred in March 2008. The autopsy
identified the cause death as hypertensive and atherosclerotic cardiovascular disease with severe
three-vessel coronary artery stenosis, with contributing factors of smoking and
hypercholesterolemia.
ODO reviewed RPDC’s Sexual Abuse and Assault Prevention and Intervention (SAAPI) policy.
Information concerning SAAPI is posted in English and Spanish in all housing units and
common areas, and is also included in the facility handbook. According to the RPDC SAAPI
policy, RPDC management has a zero tolerance towards all forms of sexual abuse and sexual
harassment.
The Special Management Unit consists of 13 single cells, each with its own shower. The Special
Management Unit has a dayroom with a television and telephone, and a secure outdoor
recreation area. There were four ICE detainees in administrative segregation during the
inspection. Review of administrative segregation orders found three of the detainees were in
protective custody at their own request, and the fourth detainee was pending a disciplinary
hearing. Three detainees were housed in disciplinary segregation during the review. Review of
documentation confirmed the detainees were placed on this status through the disciplinary
process, and segregation orders were issued imposing segregation terms of 20 days in all four
cases. Log entries documented compliance with the standard, including recreation and visitation
privileges, access to telephones and legal materials, and daily rounds by medical and supervisory
personnel.
Confrontation avoidance training is addressed in the facility’s use of force policy, and covered in
the use of force training program. Review of ten randomly-selected staff training files confirmed
completion of initial and annual use of force training. During the past year there have been four
immediate and three calculated use of force incidents involving ICE detainees. Written
documentation in one of the three calculated use of force incidents indicated a use of force team
entered a detainee’s cell and performed a cell extraction; however, the incident was not video
recorded. Upon interview, staff could not explain why the use of force team action was not
recorded. Review of video recordings of the other two calculated use of force incidents found
the team members did not wear protective gear. The video recordings included a brief synopsis
of the situation by the shift supervisor; however, all other components required by facility policy
and the standard were missing.

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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 RPDC. In addition, ODO may focus its
inspection based on detention management information provided by ERO Headquarters and
ERO field offices, and on issues of high priority or interest to ICE executive management.
ODO reviewed the processes employed at RPDC 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 RPDC.

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

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

7

ODO, Houston
ODO, Atlanta
ODO, Chicago
Creative Corrections
Creative Corrections
Creative Corrections

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OPERATIONAL ENVIRONMENT
INTERNAL RELATIONS
ODO interviewed supervisory ICE and RPDC staff, including the Warden and the ERO AFOD.
Both reported the working relationship between RPDC and ICE personnel is excellent. RPDC
and ICE staff stated morale is high, and the working conditions are adequate to accomplish all
required duties. The Warden stated he regularly observes ICE staff visiting detainees in the
housing units throughout the week, communicating with detainees and addressing detainee
concerns. ODO reviewed facility logbooks, and verified scheduled and unscheduled visits are
conducted by ICE management and staff on a weekly basis.
ICE staff stated the facility is short-staffed. ODO confirmed during interviews with the Warden
and Assistant Warden that RPDC is understaffed, with(b)(7)evacancies available at the time of
inspection. RPDC staff advised these vacancies did not negatively affect or impact operations.
RPDC staff stated that due to the remote geographic location of the facility, there is difficulty in
recruiting and retaining personnel.

DETAINEE RELATIONS
ODO interviewed 30 randomly-selected ICE detainees (20 male and ten female) at RPDC to
assess the overall living and detention conditions at the facility. Detainees stated they are treated
well, and the facility is clean and sanitary. No complaints were received regarding the detainee
handbook, recreation, telephones, religious services, visitation, or the law library.
Ten detainees stated they did not know who their Deportation Officer was, but stated ICE staff
visits the housing units daily to speak with any detainees who have questions about their cases.
Names of Deportation Officers were posted in the housing units. Five detainees indicated they
did not receive a facility handbook; however, upon review of their detention files, ODO verified
handbooks were issued and signed for by each of the five detainees.
Six detainees complained about the poor quality of undergarments, uniforms, and blankets being
issued. Facility staff advised ODO that clothing and blankets are in back order due to a shortage
in the vendor’s stock. RPDC staff stated certain sizes are difficult to obtain, and they are trying
purchase clothing items through new vendors.
One out the 30 detainees who was interviewed complained about not receiving timely medical
care. ODO reviewed the detainee’s medical file and determined she was treated in a timely
manner, and was currently awaiting a doctor’s scheduled appointment.

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ICE NATIONAL DETENTION STANDARDS
ODO reviewed a total of 17 NDS and found RPDC fully compliant with the following
13 standards:
Access to Legal Material
Admission and Release
Contraband
Detainee Classification System
Detainee Grievance Procedures
Detainee Handbook
Disciplinary Policy
Environmental Health and Safety
Funds and Personal Property
Special Management Unit (Administrative Segregation)
Special Management Unit (Disciplinary Segregation)
Suicide Prevention and Intervention
Telephone Access
As these 13 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 four standards:
Food Service
Medical Care
Staff-Detainee Communication
Use of Force
Findings for each of these standards are presented in the remainder of this report.

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FOOD SERVICE (FS)
ODO reviewed the Food Service standard at RPDC to determine if detainees are provided with a
nutritious and balanced diet, in a sanitary manner, in accordance with the ICE NDS. ODO
reviewed policy and documentation, interviewed staff, observed meal service and tray delivery,
and inspected food storage and preparation areas.
The food service operation is managed by RPDC employees, including the Food Service
Supervisor and (b)(7)e cook specialists. The staff is supported by a crew of 30 ICE detainees.
ODO verified all staff and detainees working in food service received pre-employment medical
clearances. The food service staff is responsible for security in the food service area, including
tool and key control, detainee accountability, and searches. Review of training records and the
curriculum confirmed proper training in these functions by the Texas Jail Commission.
Review of documentation confirmed the master-cycle menu is reviewed annually by the food
service supervisor, and certified by a registered dietician based on a complete nutritional
analysis. The master menu is a 35-day cycle, and includes at least two hot meals per day, with a
variety of meals. Religious diets are approved by the Chaplain, and medical diets are provided
when ordered by the medical unit. Review of religious and medical diet menus confirmed
approval by the registered dietician. ODO’s inspection of the food substitution log confirmed
selection of substitutions from the master menu, and approval by the Food Service Supervisor.
ODO observed the food service staff actively involved overseeing the preparation and service of
meals. All meals are consumed in the dining hall, with the exception of meals for the Special
Management Unit and intake area, which are delivered on thermal trays. Observation of meal
service in the dining hall confirmed food was served at appropriate temperatures, and properly
presented. Portions were controlled and consistent with the menu.
The food service storage areas consist of one spacious dry storage room, two walk-in freezers,
and two walk-in coolers. ODO confirmed temperatures in the walk-in freezer and cooler were
maintained at required levels. The facility stocks a 15-day minimum supply of food, and uses
the first-in/first-out stock rotation system. ODO verified “hot” items, such as yeast and nutmeg,
were properly secured in a cabinet in the Food Service Supervisor’s office and accounted for as
required by policy. However, purchase orders for these items do not specify special handling
requirements for delivery (Deficiency FS-1). Both yeast and nutmeg are highly pilfered items in
correctional facilities, yeast because it may be used for fermentation purposes in making alcohol,
and nutmeg because ingestion in large quantities may result in altered consciousness and
hallucinations, posing potentially serious health consequences. Tight control of these items
protects against their introduction into the general population.
All areas of the food service operation were clean and organized. Cleaning schedules were
posted strategically throughout the food service area, and detainee workers were observed
following “clean-as-you-go” procedures. Review of documentation confirmed comprehensive
daily inspections are conducted by the Food Service Supervisor, and weekly inspections are
conducted by the Risk Management Supervisor. Inspection reports are submitted to the Warden
for review. An inspection conducted by the Texas Department of State Health Services on
July 16, 2012, found RPDC in compliance with state food service regulations. Chemicals were
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observed properly stored and secured, and Material Safety Data Sheets were available. Review
of logs confirmed chemical inventories are maintained, and containers are properly labeled for
hazards.
Staff and detainee workers were observed wearing hair restraints and beard guards; however,
detainee workers wore their personal or facility-issued tennis shoes, and were not issued
approved rubber-soled safety shoes (Deficiency FS-2). Floors in food service areas are often
wet, and items dropped during food preparation may be present. Providing safety shoes with
rubber soles to all workers prevents slips, trips, and falls.
Knives are not used in the food service operation. Dough cutters are used in place of knives, and
were observed tethered to the tables in the food preparation areas. Inspection confirmed utensils
and tools were properly secured and accounted for. ODO observed food preparation equipment
was clean, properly installed, and equipped with emergency gas shut-off valves; however, the
meat slicer was not equipped with an anti-restart device (Deficiency FS-3). Equipment powered
by electricity stops working when the electrical power is interrupted. Once power is restored, the
equipment restarts automatically, presenting a significant safety hazard to staff and detainee
workers.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY FS-1
In accordance with the ICE NDS, Food Service, section (III)(B)(4), the FOD must ensure all
facilities shall have procedures for the handling of food items that pose a security threat.
Mace, nutmeg, cloves, and alcohol-based flavorings also require special handling and storage.
The purchase order for any of these items will specify the special-handling requirements for
delivery.
DEFICIENCY FS-2
In accordance with the ICE NDS, Food Service, section (III)(H)(2)(e), the FOD must ensure
approved rubber soled safety shoes shall be provided and used by all food service personnel
working in food service.
DEFICIENCY FS-3
In accordance with the ICE NDS, Food Service, section (III)(H)(12)(c)(4), the FOD must ensure
machines shall be guarded in compliance with OSHA standards: meat saws, slicers, and grinders
shall be equipped with anti-restart devices.

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MEDICAL CARE (MC)
ODO reviewed the Medical Care standard at RPDC to determine if detainees have access to
healthcare and emergency services to meet health needs in a timely manner, in accordance with
the ICE NDS. ODO toured the clinic; reviewed policies and procedures, and medical staff
licenses; and interviewed regional and local health care and administrative staff. ODO examined
30 medical records of detainees falling into the following categories: chronic care, sick call log
for November 28, 2012, suspect TB, detainee complaints (summarized in another section of this
report), suicide watch, females, and random healthy. All records were spot checked for sick call
timeliness and reviewed for transfer documentation. Any records older than a year were checked
for annual TB testing and PEs. ODO was informed there was one detainee death at RPDC,
which occurred in 2008.
Healthcare is provided by Emerald Health Care. The facility maintains no current accreditations.
The clinic is open 24 hours a day, seven days a week. It is administered by an HSA, who also
serves as the mental health crisis manager; however, an RN is currently transitioning into the
HSA position. An RN Director of Nursing is scheduled to begin on January 7, 2013. Medical
oversight is provided by the Clinical Director, who is on-site one day a week and on-call
24 hours a day, seven days a week. In addition there is a part-time nurse practitioner who works
five days a week. Mental health services are provided by a psychologist available one day a
week as needed, and the HSA/full-time mental health crisis manager. A part time dentist, on-site
one day a week, delivers dental care. These positions are augmented by(b)(7)elicensed practical
nurses, (b)(7)e medical assistants, an administrative assistant, and a medical records clerk. There
were no vacancies at the time of the review. ODO finds staffing adequate to provide basic
medical services for detainees. All professional licenses were present, however, (b)(7)e out of the
(b)(7)e provider licenses had not been primary-source verified with the issuing state boards for
authentication purposes (Deficiency MC-1). The HSA completed primary source verification of
all the licenses at the time of the inspection.
Haskell Hospital, five minutes away, is used for a higher level of medical care and emergency
services. Specialty cases are referred to Parkland Hospital in Dallas. Detainees who require
inpatient mental health treatment are sent to Red River Hospital in Wichita Falls.
The clinic contains two examination/treatment rooms; four medical observation cells, all of
which are negative air-flow rooms for TB isolation; an x-ray room; a dental suite; a medical
records room; a locked medication room; a nurses station; a mental health office; and the HSA’s
office. A detention officer’s desk is located within the clinic for custody and control purposes.
ODO found the clinic to be adequately sized and equipped.
Nursing staff screen newly arrived detainees to identify chronic care, mental health, medication
needs, and symptoms of TB. TB testing is accomplished by administration of a PPD skin test.
Detainees with a positive PPD reading receive a CXR within 72 hours. Review of 30 detainee
medical records confirmed compliance with all screening and TB testing requirements. ODO
notes, however, that in one case an asymptomatic detainee had a positive PPD and subsequent
CXR indicating possible TB. The CXR report was not received by the facility until two days
following its completion. Upon receipt of the report, the detainee was removed from general
population and transferred to a negative pressure isolation room. Diagnostic sputum culture
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testing ultimately determined the detainee was negative for TB; however, pending those results,
detainees and staff who came into contact with him were required to undergo testing to
determine if they had been exposed to TB. Although in this case the detainee was determined
negative for TB, delayed reporting of the positive CXR delayed his isolation, potentially placing
other detainees, staff and community at risk for exposure. Following discussion between ODO
and the Emerald Regional Director of Health Services, the Director completed a Process Quality
Improvement Study. As a result, the radiology group will be required to immediately notify the
HSA by telephone of any positive CXR and RPDC staff will follow up on all delayed CXR
report findings.
Review of 30 medical records confirmed RNs completed PEs within 14 days of the detainees’
arrival. ODO verified the PEs were hands-on and reviewed by a physician, and the RNs
completed training in performance of the function.
Detainees access health care services by completing sick call requests, available in English and
Spanish, and depositing them directly in secured boxes. Nursing staff retrieve the requests on a
daily basis and triage them for clinical priority. Detainees in the Special Management Units
hand them directly to nursing staff during daily rounds. Nursing staff conduct sick call seven
days a week using physician-approved protocols. ODO verified follow-up appointments and
referrals were completed as indicated. RPDC does not charge detainees co-pays or other fees.
ODO cites as a best practice the availability of pamphlets in the clinic on such conditions as
hypertension, diabetes, and communicable diseases. ODO cites as another best practice anger
and stress management classes conducted by the mental health crisis manager to assist detainees
in developing coping skills.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY MC-1
In accordance with the ICE NDS, Medical Care, section (III)(C), the FOD must ensure the health
care staff will have a valid professional licensure and or certification. The USPHS, Division of
Immigration Health Services, will be consulted to determine the appropriate credentials
requirements for health care providers.
In accordance with IHS Policy 4.3.1.1, each licensed independent practitioner portfolio must
contain, at a minimum, written evidence the professional licensure or certification (all current,
past, active, and inactive) have been verified at the primary source.

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STAFF-DETAINEE COMMUNICATION (SDC)
ODO reviewed the Staff-Detainee Communication standard at RPDC 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 a timely manner, in accordance with the ICE NDS. ODO interviewed staff and detainees, and
reviewed policies, request logs, and detention files.
ODO reviewed facility logbooks, and verified scheduled and unscheduled visits are conducted
by ICE management and staff on a weekly basis. (b)(7)e IEAs are permanently assigned to RPDC,
and conduct scheduled visits once a week to address detainee concerns, monitor conditions of
confinement, and complete the ICE Facility Liaison Visit Checklist. In addition to scheduled
visits, ICE staff conducts multiple unscheduled visits throughout the week. Additionally, a
Supervisory Detention and Deportation Officer visits RPDC at least once a week; the Deputy
Field Office Director and the AFOD have visited the facility at least once during the year prior to
the ODO CI. ODO confirmed each of the visits was logged in the main entrance visitation
logbook by the facility.
ODO reviewed 20 detention files, and confirmed a copy of the detainee’s request had been
placed in the file and each request received a response within 72 hours. Upon receipt by on-site
ICE staff, all requests are date-stamped, scanned, and emailed to ERO Dallas. A copy of the
request is placed in the detainee’s detention file. ERO Dallas staff maintains an electronic log of
the detainee requests received from RPDC. ODO requested to review a six-month history of the
detainee request logbook. ODO was informed request logs for the months of September 2012,
October 2012, and November 2012 were not available. ICE staff updated the logs to include
these months while ODO was on-site; however, it could not be confirmed that all requests during
the three-month timeframe were accounted for (Deficiency SDC-1).
A review of the Detainee Request Log from June to August 2012 showed accurate recording of
detainee requests, and all requests were responded to in a timely manner.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY SDC-1
In accordance with the ICE NDS, Staff-Detainee Communication, section (III)(B)(2), the FOD
must ensure all requests shall be recorded in a logbook specifically designed for that purpose. In
IGSAs, the date the request was forwarded to ICE and the date it was returned shall also be
recorded.

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USE OF FORCE (UOF)
ODO reviewed the Use of Force standard at RPDC 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, inspected video recording equipment, and reviewed policy and
procedures, training records, and use of force incident documentation.
Confrontation avoidance training is addressed in the facility’s use of force policy and covered in
the use of force training program. Review of(b)(7)erandomly-selected staff training files confirmed
completion of initial and annual use of force training. Oleo Capsicum (OC) spray is maintained
in Central Control for use upon authorization by a supervisor. Documentation of current
certifications was included in all ten training files reviewed by ODO. RPDC does not have
electro-muscular disruption devices. ODO verified protective gear for use of force team
members and video-recording equipment was available and adequate.
During the past year there have been four immediate and three calculated use of force incidents
involving ICE detainees. ODO reviewed documentation in the four immediate use of force
incidents and confirmed full compliance with the standard.
Written documentation in one of the three calculated use of force incidents indicated a use of
force team entered a detainee’s cell and performed a cell extraction; however, the incident was
not video recorded (Deficiency UOF-1). Upon interview, staff could not explain why the use of
force team action was not recorded. Review of video recordings of the other two calculated use
of force incidents found the team members did not wear protective gear (Deficiency UOF-2).
Wearing protective gear reduces the risk of injury to use of force team members. The video
recordings included a brief synopsis of the situation by the shift supervisor; however, all other
components required by facility policy and the standard were missing, including: the date, time,
and location of the incident; naming of the video camera operator and other staff present;
showing of the faces and identification of team members; the Team Leader offering the detainee
a last chance to cooperate before team action; close-ups of the detainee’s body during the
medical exam; and an incident debriefing (Deficiency UOF-3). Recording all required
components provides visual documentation of steps taken before, during, and following a use of
force incident, affording better analysis and visual support for the written documentation. ODO
verified written documentation was present confirming the detainees were examined by medical
staff immediately following the incidents, and the ICE Supervisory Detention and Deportation
Officer was notified.
After action reviews were conducted in all immediate and calculated use of force incidents;
however, ODO notes after action reviews conducted in the three calculated use of force incidents
did not address the teams’ failure to wear protective gear and failure to video record
(Deficiency UOF-4). ODO recommends after action reviews include identification of violations
of the policy and the NDS; further, that corrective actions be taken to ensure compliance in
future use of force incidents.

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STANDARD/POLICY REQUIREMENT FOR DEFICIENT FINDINGS
DEFICIENCY UOF-1
In accordance with the ICE NDS, Use of Force, section (III)(A)(2)(b), the FOD must ensure the
videotaping of all calculated used of force is required. The videotape and accompanying
documentation shall be included in the investigation package for the "After-Action Review" (see
Section III.J., below). Additionally, the Officer in Charge (OIC) shall make all videotapes
available to the District Director.
DEFICIENCY UOF-2
In accordance with the ICE NDS, Use of Force, section (III)(A)(4)(a), the FOD must ensure,
when a detainee must be forcibly moved and/or restrained during a calculated use of force, the
use of force team technique shall apply. The team technique usually involves five or more
trained staff members clothed in protective gear, including helmet with face shield, jumpsuit,
flack-vest or knife-resistant vest, gloves, and forearm protectors. Team members enter the
detainee’s area together, with coordinated responsibility for achieving immediate control of the
detainee.
DEFICIENCY UOF-3
In accordance with the ICE NDS, Use of Force, section (III)(A)(4)(g)(1-6), the FOD must ensure
calculated-use-of-force videotape will be edited as follows:
1. Introduction by Team Leader, stating facility name, location, time, date, etc.; describing the
incident that led to the calculated use of force; and naming the video-camera operator and
other staff present.
2. Faces of all team members briefly appear (helmets removed; heads uncovered), one at a time,
identified by name and title.
3. Team Leader offering detainee last chance to cooperate before team action, outlining use-offorce procedures, engaging in confrontation-avoidance, and issuing use-of-force order.
4. Entire tape of Use-of-Force Team operation, unedited, until detainee in restraints.
5. Close-ups of detainee's body during medical exam, focusing on the presence/absence of
injuries; staff injuries, if any, described but not shown.
6. Debriefing, including full discussion/analysis/assessment of incident.
DEFICIENCY UOF-4
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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