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ICE Detention Standards Compliance Audit - St. Clair County Intervention Center, Port Huron Township, MI, ICE, 2006

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Department of Homeland 'urity
Immigration and Customs Enforcement
Office of Detention and Removal

Condition of Confinement Review Worksheet
(This document must be attached to each G-324a Inspection Form)
This Form to be used for Inspections of alllGSA Facilities Used over 72 Hours

Field Office Detention Review Worksheet
IZl

Local Jail- IGSA
State Facility - IGSA
ICE Contract Detention
Name
THE ST. CLAIR CLAIR COUNTY INTERVENTION CENTER
Address (Street and Name)
1170 MICHIGAN
City, State and Zip Code
PORT HURON TOWNSHIP MI48060
County
ST. CLAIR
Name and Title of Chief Executive Officer (Warden/OIC/Superintendent)
(b)(6), (b)(7)c

Name and title of Reviewer-In-Charge
IMMIGRA TJON ENFORCEMENT AGENT

Assessment

Other

Table of Contents
DETAINEE SERVICES STANDARDS

(SECTION J)

............................................................. 3

ACCESS TO LEGAL MATERIALS ............................................................................................................... .
ADMISSION AND RELEASE ....................................................................................................................... .
CLASSIFICATION SySTEM ........................................................................................................................ .
CORRESPONDENCE AND OTHER MAIL .................................................................................................... .
DETAINEE HANDBOOK ............................................................................................................................ .
FOOD SERVICE ........................................................................................................................................ .
FUNDS AND PERSONAL PROPERTy ........................................................................................................ '"
DETAINEE GRIEVANCE PROCEDURES ..................................................................................................... .
GROUP PRESENTATJ:ONS ON LEGAL RiGHTS ........................................................................................... .
ISSUANCE AND EXCHANGE OF CLOTHING, BEDDING, AND TOWELS ...................................................... .
MARRIAGE REQUESTS ............................................................................................................................. .
NON-MEDICAL ESCORTED 'fRIPS ............................................................................................................ .
RECREATION ............................................................................................................................................ .
RELIGIOUS PRACTICES ............................................................................................................................ .
ACCESS TO TELEPHONES ......................................................................................................................... .
VISITATION .............................................................................................................................................. .
VOLUNTARY WORK PROGRAM ............................................................................................................... .

HEALTH SERVICES STANDARDS (SECTION II) ................................................................. 33
HUNGER STRIKES .................................................................................................................................... .
MEDICAL CARE ....................................................................................................................................... .
SUICIDE PREVENTION AND INTERVENTION ............................................................................................. .
TERMINAL ILLNESS, ADVANCED DIRECTIVES AND DEATH .................................................................... .

SECURITY AND CONTROL STANDARDS (SECTION III) .................................................. 40
CONTRABAND .......................................................................................................................................... .
DETENTION FILES .................................................................................................................................... .
DISCIPLINARY POLICY ............................................................................................................................ .
EMERGENCY PLANS ................................................................................................................................ .
ENVIRONMENTAL HEALTH AND SAFETY ................................................................................................ .
HOLD ROOMS IN DETENTION FACILITIES ................................................................................................ .
KEy AND LOCK CONTROL ....................................................................................................................... .
POPULATION COUNTS ............................................................................................................................. ..
POST ORDERS .......................................................................................................................................... .
SECURITY INSPECTIONS .......................................................................................................................... .
SPECIAL MANAGEMENT UNIT (ADMINISTRATIVE SEGREGATION) ......................................................... .
SPECIAL MANAGEMENT UNIT (DISCIPLINARY SEGREGATION) ............................................................... .
TOOL CONTROL ....................................................................................................................................... .
'fRANSPORTATION (LAND) ..................................................................................................................... .
USE OF FORCE ......................................................................................................................................... .
STAFF/DETAINEE COMMUNICATIONS ..................................................................................................... .
DETAINEE 'fRANSFER STANDARD ........................................................................................................... .

For each standard rated below Acceptable, mciiities must attach a Plan of Action f'O.[ bringing
operations into -compliance. Each facility S'flould examine the entire worksheet to identify-areas of
improvement including those :standaras where an overall finding of acceptable wasa:chieved.

2
G-324A Detention Inspection Ponn Worksheet for IGSAs - Rev: 01104/05

Section I
Detainee Services Standards

3
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01/04/05

ACCESS TO 'LEGAL ,MATERIALS

•

Policy: Facilities holding ,ICE detainees sha1fperrnlt detainees access to-a ,law library, and provide legal '
materials, facilities, equipmentanq documentcopy!ing priv!iileges,and tl'te opport-unjty to prepeu;e legal'
docl!IJiJ'I:ents.
iN
COJ]lponents
NA
Y
Remaroks
The facility provides a designated law library for
detainee use.
The law library contains all materials listed in the
"Access to Legal Materials" Standard, Attachment A.
The listing of materials is posted in the law library.
The library contains a sufficient number of chairs, is well
lit and is reasonably isolated from noisy areas.
The law library is adequately equipped with typewriter,
computers or both and has sufficient supplies for daily
use by the detainees.
In addition to the physical law library, ICE detainees
have access to the Lexus Nexus electronic law library.
Where provided, the Lexus Nexus library is updated and
is current.
Outside persons and organizations are permitted to
submit published legal material for inclusion in the legal
library. Outside published material is forwarded and
reviewed by the ICE prior to inclusion.
There is a designated ICE or facility employee who
inspects, updates, and maintain/replace legal material
and equipment on a routine basis.
Detainees are offered a minimum 5 hours per week in
the law library. Detainees are not reguired to forego
recreation time in lieu of libra!y usage. Detainees faCing
a court deadline are given priority use of the law library.
Detainees may request material not currently in the law
library. Each request is reviewed and where appropriate
an acquisition request is initiate and timely pursued.
Request for copies of court decisions are
accommodated within 3 - 5 business days.
The facility permits detainees to assist other detainees,
voluntarily and free of charge, in researching and
preparing leQal documents, consistent with security.
Staff ensures that illiterate or non-English-speaking
detainees without legal representation receive more
than access to English-language law books after
indicating their need for help.
Detainees may retain a reasonable amount of personal
legal material in the general population and in the
special management unit. Stored legal materials are
accessible within 24 hours of a written request.
Detainees housed in Administrative Segregation and
Disciplinary Segregation units have the same law library
access as the general population, barring security
concerns. Detainees denied access to legal materials
are documented and reviewed routinely for lifting of
sanctions.
All denials of access to the law library fully documented.
Facility staff informs ICE Management when a detainee
or group of detainees is denied access to the law library
or law materials.

~

0

0

~

0

0

~

0

0

~

0

0

0

~

0

0

0

~

0

~

0

0

~

0

~

0

0

~

0

0

~

0

0

0

~

0

~

0

0

~

0

0

~

0

0

~

0

0

4
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01/04/05

ICE has not provided this.

ICE has not designated
an employee
Must submit rquest. 15
come, 1st serve basis.
Pre-trial gets preference
over sentenced inmates.

Currently only English
language books are
provided.

Unless written orders for
behavior or destruction of
property

ACCESS TO LEGAL :MATERIALS

PaJ:icy: Facilities hdlding)CEdetai~esshall permit detainees access toalaw library,-and pr()vide legal
materials, faciHties,equtprnentanddocument copying prM!eges, and the oppoftunityto prepare legal
documents.
. .
..

y

Com:p0IileAIs
Detainees who seek judicial relief on any matter are not
subjected to reprisals, retaliation, or penalties.
~ Acceptable

.~.
t"
(b)(6), (b)(7)c

Remarks: (Record .

D

Deficient

t

o I:)

NA

D

D

Remarks

D

At-Risk

D Repeat Finding

rvations, alternate source used for verification, etc.}

8/17/2006

Auditor's Signature / Date

5
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01/04/05

ADMISSION ANDRE'LEASE

·Poticy:AII detainees will be admi!ttedancireieasedin a manner that ensures their health, safety, and welfare.
The acimli$s1ons procedure wlll, am.ong :OUhedti'ings include: medical scre.ening; a file-based assessment and
classification process; a body searoh; and a search of personal belongings, whioh wl1l be inventoried,
documented, and safeguarded as necessary.
Y
,'N . ;NA
,Remarks
CODII"onents.
.
In processing includes an orientation of the facility.
List of Free Legal
The orientation includes; Unacceptable activities and
Services provided by ICE
behavior, and corresponding sanctions; How to contact
ICE; The availability of pro bono legal services, and
how to pursue such services. Schedule of programs,
IZI
D
D
services, daily activities, including visitation, telephone
usage, mail service, religious programs, count
procedures, access to and use of the law library and
the general library; sick-call procedures, etc., and the
detainee handbook.
Mediccal staff present
Medical screenings are performed by medical staff Q!
persons who have received specialized training for the
IZI
D
D 24/7 and provide for all
medical related duties
purpose of conducting an initial health screening.
Each new arrival is classified according to criminal
history and threat levels. Criminal history is provided
D
0
IZI
for each detainee by the ICE field office.
Male and female officers
All new arrivals are searched in accordance with the
are on duty 24/7
"Detainee Search" standard. An officer of the same
sex as the detainee conducts the search and the
IZI
D
D
search is conducted in an area that affords as much
privacy as possible.
Detainees are stripped searched only when cause has
been established and not as routine policy. NonIZI
D
D
criminal detainees are not strip-searched but are patted
down unless reasonable suspicion is established.
The "Contraband" standard governs all personal property
searches. IGSAs/CDFs use or have a similar contraband
IZI
D
D
standard. Staff prepares a complete inventory of each
detainee's possessions. The detainee receives a copy.
Staff completes Form 1-387 or similar form for CDFs and
IGSAs for every lost or missing property claim. Facilities
D
IZI
D
forward all 1-387 claims to ICE.
Underwear, socks, t-shirt,
Detainees are issued appropriate and sufficient clothing
D
IZI
0
and uniform
and bedding for the climatic conditions.
The facility provides and replenishes personal hygiene
items as needed. Gender-specific items are available.
IZI
0
D
ICE Detainees are not charged for these items.
DHS provides all
All releases are properly coordinated with ICE using a
D
IZI
D transportation
Form 1-203.
Staff completes paperwork/forms for release as required.
IZI
D
D
~ Acceptable

o Deficient

OAt-Risk

Remarks: (Record significant facts, observations, other sources used, etc.)

8/17/2006

Auditor's Signature 1 Date

6
G-324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 01/04/05

o Repeat Finding

CLAssrFICATIONSYSTEM

Policy: AU facmties 'wi:lil devaOpCindiffi'plement.a systemaccordiflg'iowhich JCEdetainees areclassitied. Tne
Classlficatlon.s},stem wiU ensure that each detainee;jsp1aced :In ittreappropriatecs:tegory; physically separated
from detaineesinmher categories.
,
y
iNA
Rema,rks
N
C6.~c:meBts
The facility has a system for classifying detainees. In
Classifies 1-8. 1 high, 8
[Z]
CDFs and IGSAs, an Objective Classification System
D
D low
or similar is used.
The facility classification system includes:
• Classifying detainees upon arrival.
• Separating individuals who cannot be classified [Z]
upon arrival from the general population.
D
D
The
first-line
supervisor
or
designated
•
classification specialist reviewing every
classification decision.
The intake/processing officer reviews work-folders, A[Z]
D
D
files, etc., to identify and classify each new arrival.
Staff use only information that is factual, and reliable to
determine classification assignments. Opinions and
[Z]
D
D
unsubstantiatedl unconfirmed reports may be filed but
are not used to score detainees classifications.
low, min, max, 1 or 2
Housing assignments are based on classification[Z]
D man
D
cells
level.
A detainee's classification-level does not affect his/her
[Z]
recreation opportunities. Detainees recreate with
D
D
persons of similar classification designations.
detainees not
Detainee work assignments are based upon
[Z]
D
D DHS
permitted to work
classification designations.
The classification process includes
[Z]
reassessment/reclassification. At IGSA's, detainees
D
D
may request reassessment 60 days after arrival.
Procedures exist for a detainee to appeal their
classification assignment. Only a designated
~
D
D
supervisor or classification specialist has the authority
to reduce a classification-level on appeal.
Classification appeals are resolved within five business
[Z]
days and detainees are notified of the outcome within
D
D
10 business days.
Classification designations may be appealed to a
D
D
~
higher authority such as the Warden or equivalent.
See copy
The Detainee Handbook or equivalent for IGSAs
explains the classification levels, with the conditions
~
D
D
and restrictions applicable to each.

IZI Acceptable

o Deficient

OAt-Risk

Remarks: (Record significant facts, obsf!rvations, other sources used, etc.)
,~

_

8/17/2006

Auditor's Signature 1 I

{.

(b )(6). (b )(7)c

~

7
0-324A Detention Inspection Form Worksheet for IOSAs - Rev: 01/04/05

o Repeat Finding

CORRESPONDENCE AND OTHER MAIL

POUcy: Allfacilitieswm ensure:f1at'detaineessend:and rece~ve 'correspondence in a timelY manner, subjecHo '.'
li~aions re,quired 'for the sa,fety, security, and orderly operation ,oUne,facility. Other J:nailwillbe permitted,
stlbjecttGlhle samelimitatiGns. Each facifitywlll widety distribute :its,gtlI!idelines concerning correspondence and .
. ,
other .mail.
Com;ponents

Yes"

The rules for correspondence and other mail are posted
in each housing or common area or provided to each
detainee via a detainee handbook.
The facility provides key information in languages other
than English; In the language(s) spoken by significant
numbers of detainees. List any exceptions.
Incoming mail distributed to detainees within 24 hours or
1 bUsiness day after it is received and inspected.
Outgoing mail is delivered to the postal service within
one business day of its entering the internal mail system
(excluding weekends and holidays).
Staff do not open and inspect incoming general
correspondence and other mail (including packages and
publications) without the detainee present unless
documented and authorized in writing by the Warden or
equivalent for prevailin,g security reasons.
Staff does not read incoming general correspondence
without the Warden's prior written approval.
Staff does not inspect incoming special Correspondence
for physical contraband or to verify the "special" status
of enclosures without the detainee present.
Staff are prohibited from reading or copying incoming
special correspondence.
Staff are only authorized to inspect outgoing
correspondence or other mail without the detainee
present when there is reason to believe the item might
present a threat to the facility's secure or orderly
operation, endanger the recipient or the public, or might
facilitate criminal activity.
Correspondence to a politician or to the media is
processed as special correspondence and is not read or
coj)ied.
The official authorizing the rejection of incoming mail
sends written notice to the sender and the addressee.
The official authorizing censorship or rejection of
outgoing mail provides the detainee with signed written
notice.
Staff maintains a written record of every item removed
from detainee mail.
The Warden or equivalent monitors staff handling of
discovered contraband and its disposition. Records are
accurate and up to date.
The procedure for safeguarding cash removed from a
detainee protects the detainee from loss of funds and
theft. The amount of cash credited to detainee accounts
is accurate. Discrepancies are documented and
investigated. Standard procedure includes issuing a
receipt to the detainee.

No , NA ;

IZI

0

o

o

IZI

o

IZI

0

o

IZI

0

o

o

Remarks'

The jail is open to
translating info. They
have bilingual staff.

All mail is opened and
inspected for contraband
and money

o
o

o
o

o

o

0

0

IZI

0

0

0

IZI

0

0

0

o

o

o

o
o

8
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01104/05

Sender is not notified

,CORRESPONDENCE AN:D OTHER NIAll

Polley: All faclllies wlU ensure that detainees send and rece~ve correspondenoe in a timely manner, subjeot to
limItations required for the safety, seourity, and orderJyoperation of tile faoility. Other maD 'will be permitted, '
subjeot to the same Ilimitations. Eachfaciliiy will wide~y distribute its 'guidelinesooncerning correspondence and ;
other mail.
Original identity documents (e.g., passports, birth
certifioates) are immediately removed and forwarded to
ICE staff for placement in A-files.
Staff provides the detainee a oopy of his/her identity
dooument(s) upon request.
Staff disposes of prohibited items found in detainee mail
in aooordance with the "Control and Disposition of
Contraband" Standard or the similar prevailing polioy in
IGSAs.
Every indigent detainee has the opportunity to mail, at
government expense: Reasonable correspondenoe
about a legal matter: Three one ounoe letters per week:
Packaqes deemed neoessary by ICE.
The faoility has a system for detainees to purohase
stamps and for mailing all special oorrespondenoe and a
minimum of 5 pieoes of general oorrespondence per
week.
The faoility provides writing paper, envelopes, and
penoils at no oost to ICE detainees.

o Deficient

!2J Acceptable

[gJ

D

D

[gJ

D

D

[gJ

D

D

[gJ

D

D

[gJ

D

D

[gJ

D

D

OAt-Risk

Remarks: (Record significant facts, observations, other sources used, etc.)
_

8/17/2006 (b)(6), (b)(7)c

Auditor's Signature

9
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01/04/05

o Repeat Finding

;DE1AINEE HANDBOOK
Policy: Every ole will develop ,a site~speoif:icdetainee handbook to serve as an overview of, and guide to, 1h:e
detention polioies, rules, aFld :}'lfoceduresjn effect at the :facility: Thehandlbook wlUaJso de,scr}be ihe services,
programs" andoppUltU1i'i'tbies available through various:$O:urces, including thefacillty, :ICE, priv.ateorganliZ:ations,
etc. Ev-erydetainee will receive a copy of ~is handbook upon admission to the faoility.

Y

Components
The detainee handbook is written in English and
translated into Spanish or into the next most-prevalent
Language( s).
The handbook supplements the facility orientation
video where one is provided.
All staff members receive a handbook and training
regarding the handbook contents.
The handbook is revised as necessary and there are
procedures in place for immediately communicating
any revisions to staff and detainees.
There an annual review of the handbook by a
designated committee or staff member.
The detainee handbook address the following issues:
Personal Items permitted to be retained by the
detainee.
• Initial issue of clothes, bedding and personal
hygiene items.
The detainee handbook states in clear language basic
detainee responsibilities.
The handbook clearly outlines the methods for
classification of detainees, explains each level, and
explains the classification appeals process.
The handbook states when a medical examination will
be conducted.
The handbook describes the facility, housing units,
dayrooms, In-dorm activities and special management
units.
The handbook describes; Official count times and
count procedures Meal times, feeding procedures,
procedures for medical or religious diets, smoking
policy, Clothing exchange schedules and if authorized,
clothes washing and drying procedures and expected
personal hygiene practices.
The handbook describe times and procedures for
obtaining disposable razors and allows that detainees
attending court will be afforded the opportunity to shave
first.
The handbook describes barber hours and hair cutting
restrictions.
The handbook describes; the telephone policy, debit
card procedures, direct and frees calls; locations of
telephones; policy when telephone demand is high; and
policy and procedures for emergency phone calls.
The handbook addresses religious programming.
The handbook states times and procedures for
commissary or vending machine usage. (where
available)
The handbook describes the detainee voluntary work
program.

•

N

NA

'Rema,rks
English only. Staff
includes bi-lingual
employees. Will translate.

~

D

D

D

D

~

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

IZI

D

D

IZI

D

D

IZI

D

D

IZI

D

D

IZI

D

D

IZI

D

D

~

D

D

IZI

D

D

IZI

D

D

Updated yearly

10
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01/04/05

1

.. '

DETAlNiEE HANDBOOK
Policy: Every ole wiJl develop asite~sp~eilie 'detaineehandib<>ok to serve as an overview of,and guide to, the
·detention policies, futes, and proceduresiiFi effect at the fac!IJty; . The handbook
also describe the serVices,
progral1m.s,and o,pportunitiesavailat:ile fhrough various.5(juices; including the faoillty, :~aE, ;p!'ivateorganizations, .
etc. Every detainee will receive a ·copy of tihishaAdb:ook upon admission to ~he facility.
:N
;Remarks
Compoftents
Y
NA
The handbook describes the library location and hours
IZl
D D
of operation and law library procedures and schedules.
The handbook describes; attorney and regular visitation
D D
IZl
hours, policies, and procedures.
The handbook describes the facility contraband policy.
D D
IZl
The handbook describes the facility visiting hours and
D D
IZl
schedule and visiting rules and regulations.
The handbook describes the correspondence policy
D D
IZl
and procedures.
The handbook describes the detainee diSCiplinary policy
and procedures:
Including:
D D
IZl
• Prohibited acts and severity scale sanctions.
• Time limits in the Disciplinary Process.
• Summary of Disciplinary Process.
The grievance section of the handbook explains all
steps in the grievance process -Including:
• Informal (if used) and formal grievance
procedures;
The
appeals process;
•
In
CDF
facilities: procedures for filing an
•
appeal of a grievance with ICE.
IZl
D D
• Staff/detainee availability to help during the
grievance process.
• Guarantee against staff retaliation for
filing/pursuing a grievance.
• How to file a complaint about officer
misconduct with the Department of Homeland
Security.
The detainee handbook describes the medical sick call
IZl
D D
procedures for general population and segregation.
The handbook describes the facility recreation policy
including:
D D
IZl
• Outdoor recreation hours .
• Indoor recreation hours .
The handbook describes the detainee dress code for
IZl
D D
daily living; and work assignments.
The handbook specifies the rights and responsibilities
IZl
D D
of all detainees.

will

[8J Acceptable

D Deficient

D

At-Risk

Remarks: (Record significant facts, observations, other sources used, etc.)
_

8/17/2006

Auditor's Signature

11
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01/04/05

D Repeat Finding

;FOOD SERVICE
Policy: 'EveryfacUitywiU provide detainees ,in Jtscafe Vl4thnutritiOlls and appetizingmeals,prepared in
aooarrdance with the highest sarilitary· standards.
.
Co.mponents
The food service program is under the direct
supervision of a professionally trained and certified
service administrator. Responsibilities of cooks and
cook foremen are in writing. The Food Service
Administrator (FSA) determines the responsibilities of
the Food Service Staff.

The Cook Foreman is on duty on days when the FSA is
off duty and vice versa.
The FSA provides food service employees with training
that specifically addresses detainee-related issues.
• In ICE Facilities this includes a review of the
ICE "Food Service" standard
Knife cabinets close with an approved locking device
and the on-duty cook foreman maintains control of the
key that locks the device.
All knives not in a secure cutting room are physically
secured to the workstation and staff directly supervise
detainees using knives at these workstations. Staff
monitor the condition of knives and dining utensils
Special procedures (when necessary) govern the
handling of food items that pose a security threat.
Operating procedures include daily searches
(shakedowns) of detainee work areas.
The FSA monitor staffs implementation of the facility's
population counts procedures. Staff are trained in
counts procedures.
The detainees assigned to the food service department
look neat and clean. Their clothing and grooming
comply with the "Food Service" standard.
The FSA annually reviews detainee-volunteer job
descriptions to ensure they are accurate and up-todate.
The Cook Foreman or equivalent instructs newly
assigned detainee workers in the rules and procedures
of the food service department.
During orientation and training session(s), the CS
explains and demonstrates:
• Safe work practices and methods.
• Safety features of individual products/ pieces of
equipment.
• Training covers the safe handling of hazardous
material[s] the detainee are likely to encounter
in their work.
The Cook Foreman documents all training in individual
detainee detention files.
Detainees at CDFs are paid in accordance with the
"Voluntary Work Program" standard. Detainee workers
at IGSAs are subject to local and State rules and
regulations regarding detainee pay.

Y

N

'NA

~

D

D

~

D

D

D

~

D

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

D

~

D

D

D

~

12
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01/04/05

Remalrks
2 full time FSA's

Locking cabinet in
kitchen office. No
inmates allowed in office

They receive orientation
and job training.

I

:FOOD SERVICE

!

Po1icy: Everyfaclttr 'will 'provide detainees in its care wifh nutritious and appetizing meals" prepared in :
,,'accordance'w1trn, the,highestsanitary, stanqards.
'",

Components

,

Detainees are served at least two hot meals every day.
No more than 14 hours elapse between the last meal
served and the first meal of the following day.
For cafeteria style operations, a transparent "sneeze
guard" protects both the serving line and salad bar line.
The facility has a standard 35-day menu cycle. IGSAs
use a 35 day or similar system for rotating meals.
The FSA or facility considers the ethnic diversity of the
facility's detainee population when developing menu
cycles. (Provide examples)
A registered dietitian conducts a complete nutritional
analysis of every master-cycle menu planned.
The FSA has established procedures to ensure that
items on the master-cycle menu are prepared and
presented according to approved recipes.
The Cook Foreman has the authority to change menu
items if necessary.
• If yes, documenting each substitUtion, along
with its justification
• With copy to FSA
All staff and volunteers know and adhere to written
"food preparation" procedures.

Y

N

"NA

[gI

D

D

D

D

[gI

[gI

D

0

[gI

D

D

[gI

D

D

[gI

D

D

[gI

D

D

[gI

D

D

!Remarks
6am, 11 :30am, 5pm

Detainees whose religious beliefs require the
adherence to particular religious dietary laws are
referred to the Chaplain or FSA.
A common-fare menu available to detainees whose
dietary requirements cannot be met on the main.
• Changes to the planned common-fare menu
can be made at the facility level.
• Hot entrees are offered three times a week.
• The common-fare menus satisfy nutritional
recommended daily allowances (RDAs).
Staff
routinely provides hot water for instant
•
beverages and foods.
Common-fare meals are served with:
0
Disposable plates and utensils.
0
Reusable plates and utensils.
0
• Staff use separate cutting boards, knives,
spoons, scoops, etc., to prepare the commonfare diet items.
A supervisor at the command level must approve a
detainee's removal from the Common-Fare Program.

[gI

D

D

[gI

D

D

[gI

D

D

The Warden, in conjunction with the chaplain andlor
local religious leaders, provide the FSA a schedule of
the ceremonial meals for the following calendar year.

[gI

D

D

13
G-324A Detention Inspection Form Worksheet for rGSAs - Rev: 01/04/05

All meals served in
PODS
28 day cycle

POOD SERVICE
Policy: Every facility will pn)Vldedetalneestn its care with
acc()r{jancew~lhl ,the highest
sanitary,..,standards.
.
.
"."

:nutfi~fo:us

,and appetizing meats, pl'epared in

''

"

'

Compon_ts ,:

Y

'N

NA

The common-fare program accommodates detainees
abstaining from particular foods or fasting for religious
purposes at prescribed times of the year.
• Muslims fasting during Ramadan receive their
meals after sundown.
Jews
who observe Passover but do not
•
participate in the Common-Fare Program
receive the same Kosher-for- Passover meals
as those who do participate.
• Main-line offerings include one meatless meal
(lunch or dinner) on Ash Wednesday and
Fridays during Lent.
The food service program addresses medical diets.

IZI

D

D

IZI

D

D

satellite-feeding programs follow guidelines for proper
sanitation.

D

D

IZI

Hot and cold foods are maintained at the prescribed,
"safe" temperature(s) as served.

IZI

D

D

All meals provided in nutritionally adequate portions.

IZI

D

D

Food is not used to punish or reward detainees based
upon behavior.

IZI

D

D

IZI

D

D

IZI

D

D

The food service staff instructs detainee volunteers on:
• Personal cleanliness and hygiene;
• Sanitary techniques for preparing, storing, and
serving food, and;
• The sanitary operation, care, and maintenance
of eguipment.
Everyone working in the food service department
complies with food safety and sanitation requirements.
Standard operating procedures include weekly
inspections of all food service areas, including dining
and food-preparation areas and equipment.
• who conducts the inspections?
Equipment is inspected for compliance with health and
safety codes and regulations.
• When was the most recent inspection?
• Which agency conducted the inspection?
Reports of discrepancies are forwarded to the Warden
or designated department head and corrective action is
scheduled and completed.
Standard procedure includes checking and
documenting temperatures of all dishwashing
machines after each meal.
Staff documents the results of every refrigerator/
freezer temperature check.
The cleaning schedule for each food service area is
conspicuously posted.
Procedures include inspecting all incoming food
shipments for damage, contamination, and pest
infestation.
Storage areas are locked when not in use.

IZI

D

D

IZI

D

D

IZI

D

D

IZI

D

D

IZI

D

D

IZI

D

D

IZI

D

D

IZI

D

D

14
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01/04/05

':

Remarks

FSA does all food service
inspections daily

St. Clair COunty Health
Dept.

FOOD SERVICE
Policy: Every facility will provide detaiAees !inits ,cs:rewith nutritious and appetizing meats, prepared
accordance with ~he hig:hest sanitary standards.

..

.....:

Components '.'

:.

[g] Acceptable

J

o Deficient

0

y

r

N

J :MAI

At-Risk

o Repeat Deficiency

Remarks: (Record significant facts, observations, other sources used, etc.)

_

Remarks

8/21/2006
Auditor's Signature / Date

15
0-324A Detention Inspection Form Worksheet for rOSAs - Rev: 01104/05

'in
)

,FUNDS AND PERSONAL,PROPEiRTY
Policy: All faciilii~ies will Implement procedures toconltrm and safeguard detainees' persolil'al property.
Procedures will provide for the secure storage of funds, MaJuables, baggage and other persol'laJ property; the
documentation and :receipting of surrendered property; and theinitiaJ and regularlyscheduted ,inventorying -of af! '
funds, vall.lli8bles. and other pro;perty.

,(~GSA ONLY)Ciheck this box -iif aU -ICE detainee'Fitllnds" Valuables and P,operiy are
:bandledonly by tbe fCE Field Ofticeor 'Su'b·Office,in cOfltrol of tbe detainee case.
,
Rema!rks
Components
Yes
No
'NA
Detainee funds and valuables are properly separated
and stored away. Detainee funds and valuables are
D
D
D
accessible to designated supervisor(s) only.
Detainees' large valuables are secured in a location
accessible to designated supervisor(s) or processing
D
D
D
staff only.
Staff itemizes the baggage and personal property of
arriving detainees, including funds and valuables). For
D
D
D
IGSAs and CDFs, using a personal property inventory
form that meets the ICE standard?
Staff forwards an arriving detainee's medicine to the
D
D
D
medical staff.
Staff searches arriving detainees and their personal
D
D
D
property for contraband.
There is a written policy for returning forgotten property
D
D
D
to detainees and staff follows procedures?
Property discrepancies are immediately reported to the
D
D
D
CDEO or Chief of Security.
Staff follows written procedures when returning property
D
D
D
to detainees.
CDFIIGSA facility procedures for handling detainee
0
0
D
property claims are similar with the ICE standard.
The facility attempts to notify an out-processed detainee
that helshe left property in the facility.
• By sending written notice to the detainee's last
known address;
D
D
D
Via
certified mail;
•
• The notice state that the detainee has 30 days
in which to claim the property, after which it will
be considered abandoned.
The facility disposes of abandoned property in
accordance with written procedures.
D
D
D
• If a CDFIIGSA facility, written procedure
requires the prompt forwarding of abandoned
property to ICE.

181 StandardNA:

o Deficient

1:8] Acceptable
Remarks: (Record

_

C>'rY",T'f"'<>nT

OAt-Risk

facts, observations, other sources used, etc.)

8/17/2006

Auditor's Signature 1 Date

16
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01104/05

o Repeat Finding

i

GROUP :LEGALRltGHTS.PRESENTATIONS

Poliey: FaciIFties housing IGEdetainees shaJtpermit authorized persons to make presentations to gro,ups o.f
detainees for the purposeC>fiTilformingthem ·'Of U.S, immigratio,n law and pro,cedures, co,nsistent wltih the
secudty and o,rderlyo,peratiGn ofeadh faoitilty. ~CE encourages such presentations, which instruct detainees
about ~eimmigJationsy$temand ~eir rights ando,ptio,ns wi1hinit
.~ ·Check:liler&·U·No ·Group :Presemations were conducted within'tlile past 12moJiltlils.• Mark Standard as

Acceptable o~e.ralJ andcominue on with Bext porticn cf worksl1eet.
Com:ponents
The Field Office is respo,nsive to, requests by atto,rneys
and accredited representatives fo,r group presentatio,ns.
Upo,n receipt o,f co,ncurrence by the Field Office Directo,r,
the facility o,r autho,rized ICE Field Office ensures pro,per
no,tificatio,n to, atto,rneys o,r accredited representatives in
a timely manner.
The facility fo,llo,ws po,licy and pro,cedure when rejecting
o,r requesting mo,dificatio,ns to, o,bjectio,nable material
provided o,r presented by the atto,rney o,r accredited
representative.
Po,sters anno,uncing presentatio,ns appear in co,mmo,n
areas at least 48 ho,urs in advance and sign-up sheets
are available and accessible.
Do,cumentatio,n is submitted and maintained when any
detainee is denied permissio,n to, attend a presentatio,n
and the reaso,n(s) fo,r the denial.
When the number o,f detainees allo,wed to, attend a
presentatio,n is limited, the facility allo,ws a sufficient
number o,f presentatio,ns so, that all detainees signed up
may attend.
Detainees in segregatio,n, unable to, attend fo,r security
reaso,ns may request separate sessio,ns with presenters.
Such requests are do,cumented.
Interpreters are admitted when necessary to, assist
atto,rneys and o,ther legal representatives.
Presenters are affarded a minimum af ane haur to, make
the presentatian and to. canduct a questian-and-answer
sessian.
Staff permits presenters to. distribute ICE-appraved
materials.
The facility permits presenters to. meet with small graups
o,f detainees to. discuss their cases after the graup
presentatian. ICE ar autharized detentian staff are
present but do. nat manito,r co,nversatio,ns with legal
praviders.
Graup presenters who. have had their privileges
suspended are natified in writing by the Field Office
Directar ar disignee; and the reasans far suspensian are
do,cumented. The Headquarters Office far Detentian
and Remaval, Field Operatians and Detentian
management Divisian is natified when a group ar
individual is suspended fram making presentatians.
The facility plays ICE-appraved videataped
presentatians an legal rights, at regular appartunities at
the request af autside o,rganizatians.

!

~A

Yes

No

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

17
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01104/05

Remarks

GROUP LEGAL :RIGHTSPRiESENTATIONS

'PoI.!>y: .1Faclllies housifitg ICEdelalnees snan permlitau1horized pe:rsGns to make presentations to groups of
detainees for the purpose of informing Ilemof U.S. ,ifl\lmigration 1awand p:rocedures., consistent wfth the
security afitdo:rder~y operation of each faoillty. ,ICE encourages such presentations, which instruct detainees
about tihe irnmigrationsystem and their ,rigllts andaptJonswithin it.

[8j. Che6kherelf No G!roup Presentations weFeconducted within the past 12 moliffhs~Mark staildard'asi
Acceptable overall and 'contimueon with next 'ponionofworksheet. .
'.'
,
COInpenents
A copy of the Group Legal Rights Presentation policy,
including attachments, is available to detainees upon
request

[8j Acceptable

o Deficient

0

Yes

No

NA

D

D

D

At-Risk

Remarks: (Record significant facts, observations, other sources used, etc.)

Auditor's Signature I Date

18
0-324A Detention Inspection Form Worksheet for IOSAs - Rev: 01104/05

'Remarks

o Repeat Finding

DETAINEE ,GRIEVANCE PROCEDURES

;Policy: Every facility wll,1 develop andimplementstandardopera~ing :procedures (SOPs) for addressing'
detainee grievances in timely fashion. Ea'chstep;in the process will ,occur within the prescribed t4meframe.
Amor::rg othertbings. agrievancewm be processed, investigated, and decided {subject to appeal) inaccordarnce
wi~h the SOPs; a grievance ,committee wm ,convene as provided in~e SOPs. Standard prooedure will inolude
proviiding the detainee with a wnlten res,ponse to any format grievance" whidhwHl inolude ~Me 'basis for the
decision. The facil.ltywiU also establish stalndard procedures for :han:dling emergency grievances. All;
, grievances will receive supervisory review. :Reprisal against the ilerof aglrievance will not be tolerated.
Written procedures provide for the informal resolution
of oral grievances (Not mandatory).
•
If yes, the detainee has up to five days within
which to make hisfher concern known to a
member of the staff.
Detainees have access to the grievance committee (or
equivalent in IGSA), using formal procedures.
• Detainees may seek help from other detainees
or facility staff when preparing a grievance.
• Illiterate, disabled, or non-English-speaking
detainees receive special assistance when
necessary.
Every member of the staff knows how to identify
emergency grievances, including the procedures for
expediting them.
There are documented or substantiated cases of staff
harassing, disciplining, penalizing, or otherwise
retaliating against a detainee who lodges a complaint.
• If yes, explain.
Procedures include maintaining a Detainee Grievance
Log.
• If not, an alternative acceptable record keeping
system is maintained.
"Nuisance
complains" are identified in the
•
records.
• For quality control purposes, staff documents
nuisance complaints received but not filed.
Staff is required to forward any grievance that includes
officer misconduct to a higher official or, in a CDFflGSA
facility, to ICE.

[8J Acceptable

;N

iNA

D

D

IZI

D

D

IZI

D

D

D

IZI

D

IZI

D

D

IZI

D

D

y'

Components

D Deficient

D

At-Risk

Remarks: (Record significant facts, observations, other sources used, etc.)

19
G-324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 01/04/05

Remarks

D Repeat Finding

lSSUANCE AND EXCHAN:GE OFCLOTHliNG,:SEODtNG, AND TOWELS
.,':

':Policy:ICE requires tmta'il facil~ies housing ICE detamees provide ·oleanclotrring, bedding. linens and towe.ls
to every lGE detainee uponarrivat Further, facutties 's'hatJ provide 1CE detaineeswi'f!h regu1arexchamges .of
clothjng, linens,and towels for .as. Jongas they remain in detention.
Compo1!tel'lts

Yes

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

•

o Deficient

[8J Acceptable

0

No

NA

I8l

D

D

1ZI

0

D

I8l

D

D

I8l

0

D

1ZI

0

D

I8l

0

D

I8l

0

D

I8l

D

0

At-Risk

Remarks: (Record significant facts, observations, other sources used, etc.)
(b)(6), (b)(7)c

8/17/2006
Auditor's Signature 1 Date

20
G-324A Detention inspection Form Worksheet for IGSAs - Rev: Ol/04/05

Remarks
Clean linens and
uniforms are readily
available in each POD

o Repeat Finding

,MARRIAGE.;REQUESTS

,

, ;PoUey: All detainee marriage req'uests Will receive case~by-case coosideration from leE management.
Componen,ts
The Field Office considers detainee marriage requests
on a case-by-case basis.
The Field Office Director reviews every marriage
request rejected by a Warden/Ole or IGSA. Rejections
are documented.
It is standard practice to require a written request for
permission to marry.
The written request includes a signed statement or
comparable documentation from the intended spouse,
confirming marital intent.
The Warden/Ole provides a written copy of his/her
decision to the detainee and his/her legal representative.
When permission is denied, the Warden/Ole states the
basis for his/her decision.
The Warden/Ole provides the detainee with a place and
time to make wedding arrangements.

IZI Acceptable

D

D Deficient

,Y

N

NA

~

0

0

IZI

0

0

IZI

0

0

IZI

0

0

~

0

D

~

0

D

~

D

D

At-Risk

facts, observations, other sources used, etc.)

21
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01/04/05

Relilltairks

D Repeat Finding

NON·M'EDJCAL·.E!Me;RGENCY ES'CORTED TRI;PS
'Policy: The tmmigr~ion and OustomsEnforoement \~fOEt m~provide detainees with staff-esoortedtrips into
lhecommunity for the purpose of visiting oriticaUy ill membsrso.f the deta'inee's immediate famIly, 'Or for
aittendingfunerals.

:[gJ Standard NA:

C!hecktllis 'box if all ICE Non-Medica'i ErneJlg.encyEscorted Trips are bandied only by
the ICE Field Office or Sub-Office in control of the ,detaiaee case.
Components

The Field Offioe Direotor oonsiders and approves, on a
oase-by-oase basis, trips to immediate family member's:
• Funeral
• Deathbed
The faoility reoognizes mother, father, brother, sister,
spouse, ohild, stepparent, and foster parent as
"immediate family".
The IGSA faoility notifies ICE of all detainee requests for
non-medioal esoorts.
The detainee's Deportation Offioer reviews the file
before forwarding a detainee's request, with
reoommendation, to the approving offioial. Eaoh
reoommendation addresses the individual's suitability for
travel, e.g., the kind of supervision required.
Eaoh esoort inoludes at least two offioers.
Esoorting offioers report unexpeoted situations to the
originating faoility as a matter of procedure and the
ranking supervisor on duty has the authority to issue
instruotions for oompletion of the trip.
Esoorting offioers have the disoretion to; Inorease or
deorease minimum restraints in aooordanoe with written
prooedures and olassifioation level of the detainee.
Escort officers do not aooept gifts/gratuities from a
detainee, detainee's relative or friend for any reason.
Escort officers ensure that detainees:
• Conduct themselves in a manner that does not bring
discredit to the ICE.
• Do not violate federal, state, or looallaws.
• Do not purchase, possess, use, consume, or
administer narootios, other drugs, or intoxicants.
Make no un~uthorized phone oalls.
• Know they are subjeot to searoh, urinalysis,
breathalyzer, or comparable test upon return.
Standard prooedure requires the immediate return to the
facility of any detainee who violates trip rules.

Yes

No

riA

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

Remark6

•

[gJ Acceptable

D Deficient

D

At-Risk

Remarks: (Record significant facts, observations, other sources used, etc.)

_

8/17/2006

Auditor's Signature

22
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01/04/05

D Repeat Finding

RECREATJO;N
PoJicy: It is ICE policy to provide access to reoreational pFograms and activities to all ICE detainees,
extoot possible, under -condi~ions of secunty and supervision that prote;ct their safety and welfare.

to~l!le

Components
Y
N
NA
Remarks
The facility has a recreation program and facility.
0
~
0
A recreational specialist (for facilities with more than 350
2 rec specialists. 1 for
detainees) tailors the program activities and offerings to
~
0
0 physical, and 1 for
religious /adult services
the detainee population.
Regular maintenance keeps recreational facilities and
0
~
0
ejluipment in good condition.
The recreational specialist or trained equivalent
~
0
0
supervises detainee recreation workers.
The recreational specialist or trainee equivalent
oversees recreation programs for Special Management
~
0
0
Unit and special-needs detainees.
Dayrooms offer sedentary activities, e.g., board games,
~
0
0
cards, television.
Outside activities are restricted to limited-contact sports.
~
0
0
Each detainee has the opportunity to participate in daily
~
0
0
recreation.
7 days, access to outdoor
Detainees have access to recreation activities outside
the housing units for at least one hour daily, 5 days a
~
0
0 rec during daylight hours
week.
Staff checks aI/ items for damage and condition when
~
0
0
equipment is returned.
Staff conducts searches of recreation areas before and
0
0
~
after use.
AI/ recreation areas under constant staff supervision.
~
0
0
Supervising staff is equipped with radios.
~
0
0
The facility provides detainees in the SMU at least one
hour of outdoor recreation time daily, five times per
0
0
~
week.
Detainees in disCiplinary/administrative segregation
receive a written explanation when a panel revokes
~
0
0
his/her recreation privileges.
Special programs or religious activities are available to
'0
~
0
detainees.
Volunteers are required to sign a waiver of liability
before entering a secure portion of the facility where
0
~
0
detainees are present.
Visitors, relatives or friends are not aI/owed to serve as
0
~
0
volunteers.
~lfoutdoor recreation is ofieredcbeck this box. No further information ,isrequiredwtten -outdoor
recreation is offered.
If the facility has no outside recreation, are detainees
considered for transfer after six months?
0
0
0
• If yes, written procedures ensure timely review
of aI/ eligible detainees.
Case officers make written transfer recommendations
0
0
0
about every six-month detainee to the OIC.
The OIC documents aI/ detainee-transfer decisions,
0
0
0
whether yes or no.
The detainee's written decision for or against an offered
0
0
0
transfer documented in his/her A-file.

23
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01104/05

,RECREATION
, POlicy: :!it is ICE poUcy to provide access to recreational ,progralllsand activities to atJlCE detainees, to the
extent possible, under 'conditions of security and 'supervision tllat protect tReir safety and we'lfare.
Staff notifies the detainee's legal representative of
his/her decision to accej:>Udecline a transfer.
If no recreation is available, the ICE District routinely
review transfer eligibility for all detainees after 60 days.
Does the A-file of every detainee is held more than 60
days without access to recreation contains either a
transfer-waiver signed by the detainee or the OIC's
written determination of the detainee's ineligibility for
transfer.
The detainee's legal representative is notified of the
detainee's/OIC's decision.

r8J Acceptable

o Deficient

0

0

0

0

0

0

0

0

0

0

0

0

OAt-Risk

Remarks: (Record significant facts, observations, other sources used, etc.)
_8/17/;2006
Auditor's Signature

24
G-324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 01104/05

o Repeat Finding

'REUGIOUSPiRACTICES

:Pollcy: Facilities will provide 'teE detainees of all fafthsw,ih reasonabteandequitabJeopportuAlties io !
participate intllla practic:esoftheir faith,limited 001y by:the constrainitsof safety, security, theorder'ly opeIations
6fthe faclltty,and budgetary coosideraliions. .'
.
COJli1,pOAents
Detainees are allowed to engage in religious services.
Space is available for detainees to conduct religious
services.
The facility allows detainees to observe the major "holy
days" of their religious faith.
• List any exceptions.
The facility accommodates recognized holy-day
observances by:
• Providing special meals, consistent with dietary
restrictions.
Honoring
fasting requirements.
•
Facilitating
religious services.
•
Allowing
activi~
restrictions.
•
Each detainee is allowed religious items in his/her
immediate possession.
Volunteer's credentials are checked and verified before
allowing participation in detainee programs.
Members of faiths not represented by clergy conduct
may request to present their own services within security
allowances.
Detainees in the Special Management Unit to participate
in religious practices unless otherwise documented for
the safety and security of the facility.

I:8l Acceptable

D Deficient

D

y

N

NA

~
~

0
0

0
0

~

0

0

~

0

0

~

0

0

~

0

0

~

0

0

~

0

0

At-Risk

Remarks

D Repeat Finding

Remarks: (Record significant facts, observations, other sources used, etc.)

25
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01/04/05

·.'

'DETAINEE TELEPHONE ACCESS

P'C>'ticy: All factlilties:tiousing ICE detainees· wJlf :permit detainees' reasonable and ,equitable access to
telephones.

Ce>mponents
. Detainees are allowed access to telephones during
established facility waking hours.
Upon admittance, detainees are made aware of the
facility's telephone access policy.
Access rules are posted in housinQ units.
The facility makes a reasonable effort to provide key
information to detainees in languages spoken by any
significant portion of the facilitY's population.
Telephones are provided at a minimum ratio of one
telephone per 25 detainees in the facility population.
Telephones are inspected regularly by facility staff to
ensure that they are in good working order.
The facility administration promptly reports out-of-order
telephones to the facility's telephone service provider.
The facility administration monitors repair progress and
take appropriate measures to ensure that the required
repairs are begun and completed timely.
Detainees are afforded a reasonable degree of privacy
for legal phone calls.
A procedure exists to assist a detainee who is having
trouble placing a confidential call.
The facility provides the detainees with the ability to
make non-collect (special access) calls.
Special Access calls are at no charge to the detainees.
In facilities unable to fully meet this requirement initially
because of limitations of its telephone service, the ICE
makes alternate arrangements to provide required
access within 24 hours of a request by a detainee.
No restrictions are placed on detainees attempting to
contact attorneys and legal service providers who are
on the approved "Free Legal Services List".
Special arrangements are made to allow detainees to
speak by telephone with an immediate family member
detained in another Facility.
Any telephone restrictions are documented.
The facility has a system for taking and delivering
emergency detainee telephone messages.
Emergency phone call messages are immediately
given to detainees.
Detainees are allowed to return emergency phone calls
as soon as possible.
Detainees in disciplinary segregation are allowed
phone calls relating to the detainee's immigration case
or other legal matters, including consultation calls.
Detainees in disciplinary segregation are allowed
phone calls to consular/embassy officials.
Detainees in disciplinary segregation are allowed
phone calls for family emergencies.

,

Y

'N

NA

[g]

D

D

[g]
[g]

D
D

D
D

[g]

D

D

[g]

D

D

[g]

D

D

[g]

D

D

[g]

D

D

[g]

D

D

[g]

D

D

[g]
[g]

D
D

D
D

[g]

D

D

[g]

D

D

[g]

D

D

[g]
[g]

D
D

D
D

[g]

D

D

[g]

D

D

[g]

D

D

[g]

D

D

[g]

D

D

26
G-324A Detention Inspection Form Worksheet for rGSAs - Rev: 01104/05

,Remarks

Available inside PODS
Verbally and in writing

DETA1N,EE TELEPHONE ACCESS
'Policy: All facttities housing. ICE detainees ,wiDpermJt detaiAees'reasonable andequftable access to
te/:epnonf:)s.
,
'Components
Detainees in administrative segregation and protective
custody afforded the same telephoning privileges as
those in general population.
When detainee phone calls are monitored, notification
is posted by detainee telephones that phone calls
made by the detainees may be monitored. Special
Access calls are not monitored.

o Deficient

I:8l Acceptable
""'rtnlTlf'~/'Ir

0

Y

N

:N:A ,

~

D

D

~

D

D

At-Risk

facts, observations, other sources used, etc.)

27
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01/04/05

Remarks

D Repeat Finding

VISITATJON·
Policy: lCE shaU;permttdetainees to visit wilhfam,ily,f,riends, legal f~presel1litat~\;1es., specia1 inteFest groups and
the news media.
Components

y

oN

NA

There is a written visitation schedule and hours for
-.general visitation.
The visitation hours tailored to the detainee population
and the demand for visitation.

~

D

D

~

D

D

The visitation schedule and rules are available to the
public.

~

D

D

The hours for all categories of visitation are posted in
the visitation waiting area.

~

D

D

A written copy of the rules regulating visitation and the
hours of visitation is available to visitors.

~

A general visitation log is maintained.

~

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

~

A visitor dress code is available to the public.

~

D
D
D
D

Visitors are searched and identified according to
standard requirements.

D

~

D
D
D
D
D

The requirement on visitation by minors is complied
with.

~

D

D

At facilities where there is no provision for visits by
minors, the ICE arranges for visits by children and
stepchildren, on request, within the first 30 days.

D

D

~

After that time, on request, ICE considers a transfer,
when possible, to a facility that will allow minor
visitation. At a minimum, monthly visits are allowed.
Detainees in special housing afforded visitation.

D

D

~

~

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

~

D
D

D
D

On regular business days legal visitation hours provide
for a minimum of eight (8) hours per day and a
minimum of four hours per day on weekends and
holidays.

~

D

D

On regular business days, detainees are given the
option of continuing a meeting with a legal
representative through a scheduled meal.

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

Private consultation rooms are available for attorney
meetings. There is a mechanism for the detainee and
his/her representative to exchange documents.
There are written procedures governing detainee
searches.
When strip searches are required after every contact
visit with a legal representative, the facility provides an
option for non-contact visits with legal representatives.
Prior to each visit, legal service providers and
assistants are identified per the standard.
The current list of pro bono legal organizations is
posted in the detainee housing areas and other
appropriate areas.

Remarks

Posted in lobby

All searches are under
glass

9a-9p

Given by DHS personell

28
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01104/05

ViSITATION
Policy: ICE shall permit detainees ~o '\1Iisi:twithfamily, fri,enas, legal representatives, special interest groups and
news media.
The decision to permit or deny a tour is not delegated
D
IZI
D
below the level of Field Office Director.
Provisions for NGO visitation as stated in the Detention
IZI
D
D
Standards are complied with.
Law enforcement officials, requesting to visit with a
detainee, are referred to the ICE Field Office for
IZI
D
D
approval.
Former detainees or aliens in proceedings, requesting
to visit with a detainee, are referred to the OIC or ICE
IZI
D
D
Field Office.
Procedures are in place, consistent with the detention
standard, for examinations by independent medical
D
IZI
D
service providers and experts.

'~he

[gJ Acceptable

D

D Deficient

At-Risk

Remarks: (Record significant facts, observations, other sources used, etc.)

_8/17/2006
Auditor's Signature 1 Date

29
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01/04/05

D Repeat Finding

VOLUifiHARYWO'RKPROGRAM
Policy: f.nevery facility offering a votu;r1tary work program, ICE detainees wUl have the opportunity to work and
cearri money byparticipa~lng. While not legar~y req!tflred,ICEaffords detainee
workers basic Occupational
.
Sa~ety and HealtbAdl:ninistra~ion (OSHA) prote~tiOriS~
. '

'[8] Checkh:ere if IOE detainees are not alilthori:zedto work at tile :IGSA faoility. Mark !NAon Form G324A, page 3 and move to next section..
Com,ponents
Does the facility have a voluntary work program?
• Do ICE detainees participate?
Detainee housekeeping meets neatness and cleanliness
standards.
Detainees have the opportunity to participate in special
details, however, are never allowed to work outside the
secure perimeter.
Written procedures govern selection of detainees for the
Voluntary Work Program.
Where possible, physically and mentally challenged
detainees participate in the program.
The facility complies with work-hour requirements for
detainees, not exceeding:
• Eight hours a day and Forty hours a week.
Detainee volunteers generally work according to fixed
schedule.
If a detainee is removed from a work detail, staff places
the written justification for the action in the detainee's
detention file.
Staff, in accordance with written procedure, ensures that
detainee volunteers understand their responsibilities as
workers before they join the work program.
The voluntary work program meets:
• OSHA, NFPA, ACA standards
Medical staff screens and formally certifies detainee food
service volunteers.
• Before the assignment begins
• As a matter of writtenprocedure
Detainees receive safety equipment! training sufficient for
the assignment
Proper procedure is followed when an ICE detainee is
injured on the job.

D Deficient

[8] Acceptable

.

Remarks: (Record .

.~.

t fi t

b

.

D

Y

N

iNA

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

At-RisK

tions, other sources used, etc.)

(b)(6). (b)(7)c

8/17/2006

30
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01/04/05

"

Remarks

D Repeat Finding

Section II
Health Services
Standards

31
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01/04/05

HUINGER..STRIKES
Policy: AlItcicfUties will foJlow standard guidelines for the :medlcaf and adminlstrative management of :ICE
detainees engag!11I9' illl hunger strikes. By monlltoring of the hea!Rhand weLfare ofth,eindi¥iduaJ detainees, :
,facIlities will strive to ,sustain their lives.

ComponeAts

Y

iN

NA

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

IZI

0

0

CDFs and IGSAs immediately report a hunger strike to
the ICE.

IZI

0

0

The facility has established procedures to ensure staff
respond immediately to a hunger strike.

IZI

0

0

IZI

0

0

IZI

0

0

Medical staff records the weight and vital signs of a
hunger-striking detainee at least once every 24 hours.

IZI

0

0

The OIC of the facility obtains a hunger striker's consent
before medical treatment.

IZI

0

0

A signed Refusal of Treatment form is required of every
detainee who rejects medical evaluation or treatment.

IZI

0

0

During a hunger strike, staff documents and provides
the hunger-striking detainee three meals a day.

IZI

0

0

Staff maintains the hunger striker's supply of drinking
water/other beverages.

IZI

0

0

During a hunger strike, staff removes all food items from
the hunger striker's living area.

IZI

0

0

Staff is directed to record the hunger striker's fluid intake
and food consumption, does staff always use Hunger
Strike Monitoring Form 1-839 or similar IGSA form.

IZI

0

0

The medical staff has written procedures for treating
hunger strikers.

IZI

0

0

Staff documents all treatment attempts, including
attempts to persuade hunger striker of medical risks.

IZI

0

0

Staff has received training in identification of hunger
strikes. Medical staff receives early training in hungerstrike evaluation and treatment. Staff remain current in
evaluation and treatment techniques.

IZI

0

0

Policy and procedure require that staff isolate a hungerstriking detainee from other detainees.
• If yes, in an observation room?
Medical personnel are authorized to place a detainee in
the Special Management Unit or a locked hospital room.

o Deficient

IZI Acceptable
Remarks: (Record si • ·ft

t {; t

OAt-Risk

b ervations, other sources used, etc.)

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

Auditor's Signature / Date

32
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: OIl04/0S

Remarks

o Repeat Finding

ACCESS TO :MiSOICAL CARE
faom~ wiJ estabrish andmaintainaflaccredi:ted~acoreditat101'l..,w.orthy heaRb prog~am for ,tne :
'
,
,
general well-'being of .ICE detainees.

;Policy: 'Every

Co.mponemts

Y

N

,NA

Facilities operate a health care facility in compliance
with State and Local laws and guidelines.
The facility's in-processing procedures of arriving
detainees include medical screening.
All detainees have access to and receive medical care.
The facility has access to a PHSIDIHS Managed Health
Care Coordinator.
The medical staff is large enough to provide, examine,
and treat the facility's detainee population.
The facility has sufficient space and equipment to afford
each detainee privacy when receiving health care.
The medical facility has its own restricted-access area.
The restricted access area is located within the confines
of the secure perimeter.
The medical facility entrance includes a holding/waiting
room.
The medical facility's holding/waiting room under the
direct supervision of custodial staff.
Detainees in the holding/waiting room
have access to a toilet and a drinking fountain.
Medical records are kept apart from other files. They
are:
• Secured in a locked area within the medical
unit.
• With physical access restricted to authorized
medical staff.
• Procedurally, no copies made and placed in
detainee files.
Pharmaceuticals are stored in a secure area.

~

D

D

~

~

D
D
D

D
D
D

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

Medical screening includes a Tuberculosis (TB) test.
• Every arriving detainee receives a TB test.
During the admission process.
• Detainee's TB-screening does not occur more
than one business day after his/her arrival at the
facility.
• Detainees not screened are housed separate
from the general population.
All detainees receive a mental-health screening upon
arrival. It is conducted:
• By a health care provider or specially trained
officer;
Before a detainee's assignment to a housing
unit.
The facility health care provider promptly reviews all 1794s (or equivalent) to identify detainees needing
medical attention.
The health care provider physically examines/assesses
arriving detainees within 14 days of admission/arrival at
the facility.

~

Remarks

24/7 access

no drinking fountain, cups
offered

locked cabinet in nurse's
office
Within 14 days unless
medically recommended

•

screenings done upon
arrival at facility

~

D

D

~

D

D

~

D

D

•

33
G-324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 01104/05

ACCESS TOMEDtCALCARE

Policy: EVery facility willestabll.sh and maintain an accre:diteG/acoreditation-wortny 'health program for the
general well..bei'l1Q ·of ICE detainees.
Detainees in the Special Management Unit have access
to health care services.
Staff provides detainees with health- services (sick call)
request slips daily, upon request.
• Request slips are available in the languages
other than English, including every language
spoken by a sizeable number of the facility's
detainee population.
• Service-request slips are delivered in a timely
fashion to the health care provider.
The facility has a written plan for the delivery of 24-hour
emergency health care when no medical personnel are
on duty at the facility, or when immediate outside
medical attention is required.
The plan includes an on-call provider.
The plan includes a list of telephone numbers for local
ambulances and hospital services.
The plan includes procedures for facility staff to utilize
this emergency health care consistent with security and
safety.
Detention staff is trained to respond to health-related
emergencies within a 4-minute response time.
Where staff is used to distribute medication, a health
care provider properly trains these officers.
The medical unit keeps written records of medication
that is distributed.
The 1-819 (or IGSA equivalent) is used to notify the
Warden/Facility of a detainee that has special medical
needs.
A signed and dated consent form is obtained from a
detainee before medical treatment is administered.
Detainees use the 1-813 (or IGSA equivalent) to
authorize the release of confidential medical records to
outside sources.
The facility health care provider is given advance notice
prior to the release, transfer, or removal of a detainee.
Detainee's medical records or a copy thereof, are
available and transferred with the detainee.
Medical records are placed in a sealed envelope or
other container labeled with the detainee's name and Anumber and marked "MEDICAL CONFIDENTIAL".

k8l Acceptable

o Deficient

rg]

D

D

rg]

D

D

rg]

D

D

rg]
rg]

D
D

D
D

rg]

D

D

rg]

D

D

rg]

D

D

rg]

D

D

rg]

D

D

rg]

D

D

rg]

D

D

rg]

D

D

rg]

D

D

rg]

D

D

OAt-Risk

facts, obseNations, other sources used, etc.)

34
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01/04/05

Medical staff available
24/7

Only medical staff
distributes meds

Available w/ release form

o Repeat Finding

SUICIDE iPREVE;NTION ANiD ,INTERVENTION
:Policy: Afl detention staff working withJCE detainees will be traineciio recognize suicide-risk indicatoTS. Sfaff ;
win handle potentially suioidal irndividt.lalsWithsensifiVlty, super~isioA, :and referrals. A olinically suicidal detainee
will reoeiveprelfentive 'superviSion 3A:O ,treatment
'
Components
Y
NA
N
Remarks
Every new staff member receives suicide-prevention
Part of academy training
[8]
training. Suicide-prevention training occurs during the
D
D
employee orientation program.
Training prepares staff to:
• Recognize potentially suicidal behavior;
• Refer potentially suicidal detainees, following
[8]
D
D
facility procedures;
• Understand and apply suicide-prevention
techniques.
A health-care provider or specially trained officer
screens all detainees for suicide potential as part of the
[8]
admission process.
D
D
Screening
does
not
occur
later
than
one
working
•
day after the detainee's arrival.
Written procedures cover when and how to refer at-risk
[8]
0
D
detainees to medical staff and procedures are followed.
The facility has a designated isolation room for
[8]
D
D
evaluation and treatment.
The deSignated isolation room does not contain any
[8]
structures or smaller items that could be used in a
D
D
suicide attempt.
[8]
Medical staff has approved the room for this purpose.
D
D
Staff observes and documents the status of a suicide[8]
D
D
watch detainee at least once every 15 minutes.

!8J Acceptable

D

D Deficient

At-Risk

Remarks: (Record significant facts, observations, other sources used, etc.)
(0)(6), (01(7)c

_

8/17/2006

Auditor's Signature / Date

35
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01/04/05

D Repeat Finding

TERMiN·AL 'ILLNESS, ADVANCEDDIRECTIYES, ~ND 'DEATH
Poley AU facilities housin.g;ICE detainees shall have poUciesand procedures addressing the issues of termina't
illness or'injtltlf)', medlcal advanced directives., and detainee death, to ,include the procek€s to el1lsure proper
notification 'fS provided to ICE of.licials, famllyrnembers and oth.er interested partres intl1teevent of a d:e:tainee
becoming terminatly ill orinaured ·.or death of a detainee occurs. ,(nadditton, the policy will cover procedures to
be taken if the death of a detainee occurs while 'in transit.

.1:8J Ch~ck.thls

box lfthe facHitydoes.t:lotaccept tCE detainees who are sa.erelyor terminally:UI.
Indicate ,NA,in the appropriate box fOT this 'portion of the worksheet. ADNAYS .complete all "efeTences
to detaInee death' aDd :re:lated notifications.
y r N i rNA
.Remarks
Components
Detainees, who are chronically or terminally ill, are
transferred to an ap~ropriate offsite medical facility ..
The facility or appropriate ICE office promptly notifies
the next of kin of the detainee's: medical condition.
• The detainee's location.
• The limitations placed on visiting.
There are guidelines addressing State Advanced
Directive Form for Implementing Living Wills and
Advanced Directives.
The guidelines include instructions for detainees
who wish to have a living will other than the
generic form the 01 HS provides or who wish to
appoint another to make advance decisions for
him or her.
The guidelines provide the detainee the opportunity to
have a private attorney prepare the documents.
There is a policy addressing "Do Not Resuscitate
Orders"

•

Detainees with a "Do Not Resuscitate" order in the
medical record receive maximal therapeutic efforts short
of resuscitation?
The facility notifies the DIHS Medical Director and
Headquarters' Legal Counsel of the name and basic
circumstances of any detainee with a "Do Not
Resuscitate" order in the medical record. In the case of
IGSAs, this notification is made through the local ICE
representative.
The facility has written procedures to address the issues
of organ donation by detainees.
The facility has written procedures to notify ICE officials,
deceased family members and consulates, when a
detainee dies while in Service.
The facility has a policy and procedure to address the
death of a detainee while in transport.
At all ICE locations the detainee's remains disposed of
in accordance with the provisions detailed in this
standard.
In the event that neither family nor consulate claims the
remains, the Field Office schedules an indigent's burial,
consistent with local procedures.
• If the detainee's is a U.S. military veteran is the
Department of Veterans Affairs notified.
An original or certified copy of a detainee's death
certificate is placed in the subject's a-file.

D

D

D

D

D

0

D

D

D

D

D

0

D

D

0

D

D

D

D

D

0

D

D

0

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

36
G-324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 01/04/05

TERMINAL ILLNESS, A,[)VAN'CEDDU~ECTIVES, AND DEATH
,Policy All facil'ttiesbo:usinglCE detainees shall have policies and :procedures,addressinglhe issues of terminal
,fUrless orinjur'y, medical advanceddire:ollves, and detainee death, to include the procedures to ensure pFoper
notification 'is ,provided to ICEoffioiais,"familymembersand"other interested parties in the eventofa deta'inee
becomingtermifilallym or injured ordeath ofa detainee occurs. ~111 addluon, the 'pOlicy will cover procedures to
be taken if tile deaihof a detainee occurs white LI"I;transit.

'~"Cbeck this box if the facUity does ,not accept ICE detainees who are severely or termina:lly :ifl.
indicate 'NA.,in the apf)r~priate box forfbis 'portion of the worksheet. ALWAYS complete aU references "
to detaineedecdb and reJatednotifications,. '
,
,Remarks
Components
NA
Y
'N
The facility follows established policy and procedures
describing when to contact the local coroner regarding
such issues as
• Performance of an autopsy.
0
0
0
• Who will perform the autopsy.
• Obtaining State approved death certificates.
• Local transportation of the body.
ICE staff follow established procedures to properly close
0
0
0
the case of a deceased detainee.

o Deficient

~ Acceptable

Remarks: (Record s'

'fi

t f; t

b

-

D

At-Risk

ations, other sources used, etc.)

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

_

8/17/2006

Auditor's Signature 1 Date

37
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01104/05

D Repeat Finding

Section III

Security and Control

38
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01/04/05

CONTRABAND

Poliey: All detention facilities will eilslltre,1JMe:propefhandlingaAd disposal of all contraband. Documentation of
contraband destruction ·'·s required.

..'

'.

Y

N

NA,

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

Staff follows written procedures when destroying hard
contraband that is illegal.

~

D

D

Hard contraband that is illegal (under criminal statutes)
may be retained and used for official use, e.g. training
purposes.
If yes, under specific circumstances and using
specified written procedures. Hard contraband is
secured when not in use.

~

D

D

Components .'
The facility follows a written procedure for handling
illegal contraband. Staff inventories, holds, and reports
it when necessary to the proper authority for
action/possible seizure.
Contraband that is government property is retained as
evidence for potential disciplinary action or criminal
~osecution.

Staff returns property not needed as evidence to the
proper authority. Written procedures cover the return of
such property.
Altered property is destroyed following documentation
and using established procedures.
Before confiscating religious items, the OIC or
designated investigator contacts a religious authority.

IZI Acceptable

o Deficient

OAt-Risk

Remarks: (Record significant facts, obseNations, other sources used, etc.)

39
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01104/05

Remarks

o Repeat Finding

DETENTION PILES
Policy: Every facility wUlcreate a detention file for ,every lCE detainee booked 'into the facility, excluding Gmy
dstaineessOheduil:ed to depart·wlthiA ·24 hours. The detention fite will contain copies and, in some cases,; tine
ongil1lslof ·s,peoified documents concerning fhedetainee's stay in the faoility: classiiflcatronsneet,rnedical
questionllaire, property inventory sheet, disciplinary dOGuments,etc.

Comptmell1ts

Y

N

NA

A detention file is created for every new arrival whose
stay will exceed 24 hours.
The detainee detention file contains either originals or
copies of documentation and forms generated during
the admissions process.
The detainee's detention file also contains documents
generated during the detainee's custody.
• Special requests
Any G-589s and/or 1-77s closed-out during the
detainee's stay
• Disciplinary forms/Segregation forms
• Grievances, complaints, and the disposition(s)
of same
The detention files are located and maintained in a
secured area. If not the cabinets are lockable and
distribution of the keys is limited to supervisors.
The detention file remains active during the detainee's
stay. When the detainee is released from the facility,
staff adds copies of completed release documents, the
original closed-out receipts for property and valuables,
the original 1-385 or equivalent and other
documentation.
The officer closing the detention file makes a notation
that the file is complete and ready to be archived.
Staff makes copies and sends documents from the file
when appropriately requested by supervisory personnel
at the receiving facility or office.

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

•

Appropriate staff has access to the detention files and
other departmental requests are accommodated by
making a request for the file. Each file is properly
logged out and in by a representative of the responsible
department.
~ Acceptable

o Deficient

D

At-Risk

Remarks: (Record significant facts, obseNations, other sources used, etc.)

40
G-324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 01/04/05

Remarks

o Repeat Finding

.

!

i

DISCIPUNARY;POUCY

Pol~y: Alltacitines housing fCE d:etainees are authorized to ,impose disciplineol'l detainees whose behavior is '

not in co~ljance With facUity fuiles and regulations.

NA

, Components

Y

The facility has a written disciplinary system using
progressive levels of reviews and appeals.
The facility rules state that disciplinary action shall not
be capricious or retaliatory.
Written rules prohibit staff from imposing or permitting
the following sanctions:
• corporal punishment
deviations from normal food service
clothing deprivation
bedding deprivation
denial
of personal hygiene items
•
loss
of
correspondence privileges
•
deprivation
of physical exercise
•
The rules of conduct, sanctions, and procedures for
violations are defined in writing and communicated to all
detainees verbally and in writing.
The following items are conspicuously posted in
Spanish and English or other dominate languages used
in the facility:
• Rights and Responsibilities
• Prohibited Acts
• Disciplinary Severity Scale
• Sanctions
When minor rule violations or prohibited acts occur,
informal resolutions are encouraged.
Incident reports and Notice of Charges are promptly
forwarded to the designated supervisor.
Incident reports are investigated within 24 hours of the
incident. The Unit Disciplinary Committee (UDC) or
equivalent does not convene before investigations end.
An intermediate disciplinary process is used to
adjudicate minor infractions.
A disciplinary panel (or equivalent in IGSAs) adjudicates
infractions. The panel:
• Conducts hearings on all charges and
allegations referred by the UDC
• Considers written reports, statements, physical
evidence, and oral testimony
• Hears pleadings by detainee and staff
representative
Bases
its findings on the preponderance of
•
evidence
• Imposes only authorized sanctions
A staff representative is available if requested for a
detainee facing a disciplinary hearing
The facility permits hearing postponements or
continuances when conditions warrant such a
continuance. Reasons for are documented.

[8]

0

0

[8]

0

0

[8]

0

0

[8]

0

0

[8]

0

0

[8]

0

0

[8]

0

0

[8]

0

0

[8]

0

0

[8]

0

0

[8]

0

0

[8]

0

0

•
•
•

;

N

I

41
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01/04/05

Remarks

During orientation, written
in handbook, and posted
in PODS
Not Spanish

:

,DlSClPUNARY POLICY

,

Policy: Alf'facilftiies bousinglCE detainees are autherizedto ,impose discipline on detaihees whose behavior is
not 1n compliance wi~l'lfacmty rules and Jegulations."'"
,N
'Compol'llents
V
The duration of punishment set by the OIC, as
recommended by the disciplinary panel does not exceed
established sanctions. The maximum time in disciplinary
segregation does not exceed 60 days for a single
offense.
Written procedures govern the handling of confidentialinformant information. Standards include criteria for
recognizing "substantial evidence"
All forms relevant to the incident, investigation,
committee/panel reports, etc., are completed and
distributed as required.

IZI Acceptable

o Deficient

,

0

NA

~

D

D

~

D

D

~

D

D

At-Risk

Remarks: (Record significant facts, observations, other sources used, etc.)

Audito

42
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01104/05

,
Remarks

o Repeat Finding

EMIERGENCY(CONTJ'NG'ENCY) PLANS

Poliey AU facillties'hotding K~E detainees will respond ,to emergencies with a predetermined standardized plan to
,minimize lJIe harmtAg of human ·/ifeand the destrl!lOtlon of property. It is recommel'lded that SPCsamd CDFs enter
into agreement, via 'Memorandum o,f Und'erstandlng (MOU/, withfederaJ. Iloca] and state agencies to ass1st in
times of emergency.
:N
Y
'NA
Remarks
'. Components
No Detainee or detainee groups exercise control or authority
0
0
IZI
over other detainees.
Detainees are protected from:
• Personal abuse
• Corporal punishment
0
IZI
0
• Personal injury
• Disease
• Property damage
• Harassment from other detainees
Staff are trained to identify signs of detainee unrest.
During academy and
,0 yearly
IZI
0
refresher courses
• WhatJype of training and how often?
Staff effectively disseminates information on facility climate,
0
IZI
0
detainee attitudes, and moods to the Officer In Charge (OIC)
There is a designated person or persons responsible for
emergency plans and their implementation. Sufficient
0
IZI
0
time is allotted to the person or group for development and
implementation of the plans.
The plans address the following issues:
• Confidentiality
0
IZI
0
• Accountability (copies and storage locations)
• Annual review procedures and schedule
• Revisions
Contingency plans include a comprehensive general section
0
IZI
0
with PIocedures apQlicable to most emergency situations.
The facility has cooperative contingency plans with
applicable:
0
IZI
0
• Local law enforcement agencies
• State agencies
• Federal agencies
All staff receive copies of Hostage Situation Management
0
IZI
0
polic~ and procedures.
Staff is trained to disregard instructions from hostages,
regardless of rank. Within 24 hours after release
0
IZI
0
hostages are screened for medical and psychological
effects.
Emergency plans include emergency medical treatment for
0
IZI
0
staff and detainees during and after an incident.
The food service maintain at least 3-days' worth of
0
IZI
0
emergency meals for staff and detainees.
Written plans locate shut-off valves and switches for all
0
IZI
0
utilities (water, gas, electric).

43
0-324A Detention Inspection Fonn Worksheet for IOSAs - Rev: 01104/05

i

EMERGENCY (CONTINGENCY) PLANS
Policy A~lfaciliies'Anlding JCE detainees will respond to emergencies with a predetermined standardized plan to
mrnimizethe harrmngof human life ,aAdtAe destruction of property. 1t is recommended that spes and CDFs enter
into ,agr-eement. via Memorandum of Un'derstantflng {MOO). wl~htederal. :Ioca'i and state agencies to assist iin"
times of emel'1gency.
,NA
Components
Remarks
Y
N
Written procedures cover:
• Work/Food Strike
• Disturbances
• Escapes
• Bomb Threats
• Adverse Weather
~
0
0
• Internal Searches
• Facility Evacuation
• Detainee Transportation System Plan
• Internal Hostages
• Civil Disturbances

IZI Acceptable

o Deficient

0

At-Risk

Remarks: (Record Significant facts, observations, other sources used, etc.)

44
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01/04/05

o Repeat Finding

.EiNVIRONMENTAL· HEAiLTHAND SAFETY
,~erialsthrough a hazardous materials .
program. The program will inctude, a,mongo~her:trnngs. the identificatton and ,tabetingofhazBrdous materials in
accordance with'appJiGaible standards (e.. g., National Fire Protect-ion Assooiation INPPA)); identif,ication ,of
inc-om,patible materials" and safe-.h:andlirng procedures

Polie,: Every· facility wi" control· flammable, toxic, and caustic

Com,ponents
The facility has a system for storing, issuing, and
maintaining inventories of hazardous materials.
Constant inventories are maintained for all flammable,
toxic, and caustic substances used/stored in each
section of the facility.
The manufacturer's Material Safety Data Sheet (MSDS)
file is up-to-date for every hazardous substance used.
• The files list all storage areas, and include a
plant diagram and legend.
The
MSDSs and other information in the files
•
are available to personnel managing the
facility's safety program.
All personnel using flammable, toxic, and/or caustic
substances follow the prescribed procedures. They:
• Wear personal protective
• Equipment.
• Report hazards and spills to the
• designated official.
The MSDSs are readily accessible to staff and
detainees in the work areas.
Hazardous materials are always issued under proper
supervision.
• quantities are limited.
• Staff always supervises detainees using these
substances.
All "flammable" and "combustible" materials (liquid and
aerosol) are stored and used according to label
recommendations.
Lighting fixtures and electrical equipment are installed in
storage rooms and other hazardous areas meet
National Electrical Code requirements.
All toxic and caustic materials stored in their original
containers in a secure area.
Excess flammables, combustibles, and toxic liquids are
disposed of J?roperly and in accordance with MSDSs.
Staff directly supervises and accounts for products with
methyl alcohol. Staff receive a list of products
containing diluted methyl alcohol, e.g., shoe dye. All
such products clearly labeled as such. "Accountability"
includes issuing such products to detainees in the
smallest workable quantities.
Every employee and detainee using flammable, toxic, or
caustic materials receives advance training in their use,
storage, and disposal.
The facility complies with the most current edition of
applicable codes, standards, and regulations of the
National Fire Protection Association and the
Occupational Safety and Health Administration (OSHA).

Y

N

NA

1ZI

D

D

1ZI

D

D

1ZI

D

D

1ZI

D

D

1ZI

D

D

1ZI

D

D

1ZI

D

D

1ZI

D

D

1ZI

D

D

1ZI

D

D

D

D

1ZI

1ZI

D

D

1ZI

D

D

45
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01104/05

:Remal'ks

Inmates do not handle
products containing
methyl alcohol

ENViRONMENTAL HEALTH AND SAFETY
'Policy: Every facility wM'1 'comro:1 fttammable.• toxic, and causiic materials through a hazardous materiails
. program. The program wfll include,amon;g other things, the Identification and labeling of hazardous materiatsin
accordance with applicable standards (e.. g., National Fire Protection Association fNFPA]);ideflittmcal10n of
j:ncompatible materiais, ,andsafe...handlirn,gprocedures
:.

Coinponen!ts.

A technically qualified officer conducts the fire and
safety inspections.
The Safety Office (or officer) maintains files of
inspection reports; Including corrective actions taken,
The facility has an approved fire prevention, control, and
evacuation plan.
The plan requires:
Monthly fire inspections.
• Fire protection equipment strategically located
throughout the facility.
Public posting of emergency plan with
accessible building/room floor plans.
• Exit signs and directional arrows.
• An area-specific exit diagram conspicuously
posted in the diagrammed area.
Fire drills are conducted and documented monthly.
A sanitation program covers barberinQ operations.
The barbershop has the facilities and equipment
necessary to meet sanitation requirements.
The sanitation standards are conspicuously posted in
the barbershop.
Written procedures regulate the handling and disposal
of used needles and other sharp objects.
All items representing potential safety or security risks
are inventoried and a designated individual checks this
inventory weekly.
Standard cleaning practices include:
• Using specified equipment; cleansers;
disinfectants and detergents.
An
established schedule of cleaning and follow•
up inspections.
The facility follows standard cleaninQ procedures.
Spill kits are readily available.
A licensed medical waste contractor disposes of
infectious/bio-hazardous waste.
Staff are trained to prevent contact with blood and other
body fluids and written procedures are followed.
Do the methods for handling/disposing of refuse meet
all reQulatory requirements.
A Iicensed/CertifiedlTrained pest-control professional
inspects for rodents, insects, and vermin.
• At least monthly.
• The pest-control program includes preventive
spraying for indiQenous insects.
Drinking water and wastewater is routinely tested
accordinQ to a fixed schedule.

NA

Y

iN

~

D

D

~

D

D

~

D

D

~

D

D

~
~

~

D
D
D

D
D
D

~

D

D

~

0

D

~

D

D

~

D

D

~
~

~

D
D
D

D
D
D

~

0

D

~

0

D

~

D

D

~

0

D

i

'Remarks

•
•

46
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01/04/05

Sharps container located
in nurse's office

ENVIRONMENTAL HEAL'TH ANDSAPETY

!

Policy: Every facility will contrOl Clammable.,. to}Cic. and caustic materials 1hFougha haz8rdoosmater'ials
p.rogram. TlleprogramwIU 'i:Mclude, ,amongother1!Rings, the 'rdellfificatiorl.andlabeling of nazardous materials in
aocordance with 8iPplieable standards (e.,g.. , 'N~olla'1 .Are Protection Association VNFPA]);tdentr1iication O'f:
incompa~ible mateliats,andsafe-ltmndiiAg procedures
'.
.
Co_poRents
Emergency power generators is tested at least every
two weeks.
Other emergency systems and equipment
receive testing at least quarterly.
Testing
is followed-up with timely corrective
•
actions (repairs and replacements).

•

IZI Acceptable

D Deficient

D

Y

N

!N!A

0

0

0

At-Risk

Remarks: (Record significant facts, observations, other sources used, etc.)
8/

(bl(6). (b)(7)c

Auditor's Sig

47
G-324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 01104/05

Rema,rks

o Repeat Finding

HOLD :ROONIS 'IN DETENTIONFACIUT1ES
poncy: Hold roomswlJlbe used only for temporary detention brdetainees awaiting removaJ,transfer, EOtR ,'
hearings, medical~reatl1Tlefl!t,. intra~faci*tty movement, or other processing ;into or out ,of the facibly.
Componellts

,

The hold room is situated within the secure perimeter.
The hold rooms are well ventilated, well lighted and all
activating switches located outside the room.
The hold rooms contain sufficient seating for the
number of detainees held.
No bunks/cots/beds or other related make shift
sleeping apparatuses are permitted inside holdrooms.
The walls and ceilings of the hold rooms are tamper and
escape proof.
Detention in hold rooms is limited to 12 hours.
Male and females are segregated from each other.
Every effort is made to ensure that detained detainees
under the age of 18 are not held with adult detainees.
Detainees are provided with basic personal hygiene
items such as water, soap, toilet paper, cups for water,
feminine hygiene items, diapers and wipes.
In older facilities officers are within visual or audible
range to allow detainees access to toilet facilities on a
regular basis.
All detainees are given a patdown search for weapons or
contraband before being placed in the room.
Officers closely supervise the detention hold rooms
using direct supervision (Irregular visual monitoring.).
• Hold rooms are irregularly monitored every 15
minutes.
• Unusual behavior or complaints are noted .
When the last detainee has been removed from the
hold room, it is given a thorouQh inspection.
There is a written evacuation plan that includes a
designated officer to remove detainees from hold rooms
in case of fire and/or building evacuation.
An appropriate emergency service is called
immediately upon a determination that a medical
emergency may exist.

[8J Acceptable

D Deficient

Y

N

NA

[gI
[gI

0
0

0
0

[gI

0

0

[gI

0

0

[gI

0

[gI
[gI

0
0

0

[gI

0
0
0
0

[gI

0

0

0

0

[gI

[gI

0

0

,Remarks

6-8 hrs max
17 is adult in Michigan

Direct/constant
supervision

D

[gI

0

0

[gI

0

0

[gI

0

0

[gI

0

0

At-Risk

Remarks: (Record significant facts, observations, other sources used, etc.)

48
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01104/05

D Repeat Finding

•

l

KEYAttD iLOCKOONTROL
fSECURUY, ACCOUNTABIUTY AND :MAINTENANCE,)
·.

.

PO:lleyt:t isih:e po1icy of the JOE Service to maintain an . efficient system for1lle. use, accoumabitity. and
maintenance of all keys and locks.

Components

Y

N

NA

The security officer[s], or equivalent in IGSAs, has
attended an approved locksmith training_program.
The security officer, or equivalent in IGSAs, has
responsibly for all administrative duties and responsibilities
relating to keys, locks etc.
The security officer, or equivalent in IGSAs, provides
training to employees in key control.
The security officer, or equivalent in IGSAs, maintains
inventories of all keys, locks and locking devices.

IZl

D

D

IZl

D

D

IZl

D

D

IZl

D

D

IZl

D

D

IZl

D

D

IZl

D

D

IZl

D

D

IZl
IZl
IZl
~

D
D
D
D

D
D
D
D

IZl

D

D

IZl

D

D

IZl

D

D

IZl
IZl
IZl

D
D
D

D
D
D

The security officer follows a preventive maintenance
program and maintains all preventive maintenance
documentation.
Facility policies and procedures address the issue of
compromised keys and locks.
The security officer, or equivalent in I GSAs, develops
policy and procedures to ensure safe combinations
integrity.
Only dead bolt or dead lock functions are used in detainee
accessible areas.
Non-authorized locks (as specified in the Detention
Standardl are not used in detainee accessible areas.
The facility does not use grand master keying systems.
All worn or discarded keys and locks cut up and properly
disposed of .
Padlocks and/or chains are not used on cell doors.
The entrance/exit door locks to detainee living quarters, or
areas with an occupant load of 50 or more people,
conform to
• Occupational Safety and Environmental Health
Manual, Chapter 3
• National Fire Protection Association Life Safety
Code 101.
The operational keyboard sufficient to accommodate all
the facility key rings including keys in use is located in a
secure area.
Procedures in place to ensure that key rings are:
• Identifiable
• Numbers of keys on the ring are cited?
• Keys cannot be removed from issued key rings
Emergency keys are available for all areas of the facility.
The facilities use a key accountability system.
Authorization is necessary to issue any restricted key.
Individual gun lockers are provided.
They are located in an area that permits constant
officer observation.
• In an area that does not allow detainee or public
access.

•

IZl

D

D

49
G-324A Detention Inspection Form Worksheet for IOSAs - Rev: 01/04/05

Remarks

Padlocks, chain, etc are
not used

In sally port area (outside
processing). In lobby,
and before entering
secure areas of the
facility

,

KEY AND lOCK CONTROL
.
.
. (SECURJTY, .AOCO'UNTA8~l1TVAND MAINTENANCE)
P.olicy It :isthe :pdficy of the tCE Service to maintain an efficient system for the use,accountabitity and
maintenance of all keys and locks.
Compone;nts
NA
Remalrks
N
Y
The facility has a key accountability policy and procedures
to ensure key accountability. The keys are physically
counted daily.
All staff members are trained and held responsible for
adhering to proper procedures for the handling of keys.
• Issued keys are returned immediately in the
event an employee inadvertently carries a key
ring home.
When
a key or key ring is lost, misplaced, or not
•
accounted for, the shift supervisor is
immediately notified.
Detainees
are not permitted to handle keys
•
assigned to staff.

l8J Acceptable

D Deficient

D

[gl

D

D

~

D

D

At-Risk

Remarks: (Record significant facts, observations, other sources used, etc.)

-

Auditor's

50
G·324A Detention Inspection Fonn Worksheet for IGSAs • Rev: 01104/05

D Repeat Finding

POPULATION COUNTS

:1

Polcy: AU detentrol'l,faciltlies shalleAS\jJr€around-1he~doCk accountability foral! detainees. This requtres that '
theyoondiuot at least one formal count ~f1he detainee population per shit, 'with additional formal and In:formal
counts conducted as necessary.

Components

:

Staff oonducts a formal count at least once each shift.
Activities cease or are strictly controlled while a formal
count is being conducted.
Do certain operations continue during formal counts.
Is a certain amount of movement tolerated during a
formal count.
Formal counts in all units take place simultaneously.
Officers do not allow detainee participation in the count.
A face-ta-photo count follows each unsuccessful
recount.
Officers positively identify each detainee before
counting him/her as present.
Written procedures cover informal and emergency
counts.
• They followed during informal counts .
• Durill9 emergencies .
The control officer (or other designated position)
maintains an out -count record of all detainees
temporarily leaving the facility.
This training is documented in each officer's training
folder.

[8J Acceptable

N

NA

~
~

D
D

~

[]

~

D

~
~

[]

LJ

~

D

D
D
D
D
D
D
D

~

D

D

~

D

D

~

D

D

~

D

D

At-Risk

Remarks: (Record significant facts, observations, other sources used, etc.)
(b)(6), (b)(7)c

I

~

.

..~...

Remarks

officers do the count

writband w/ picture

Each POD keeps count

D

D Deficient

Y

.. ..

51
G·324A Detention Inspection Form Worksheet for IGSAs • Rev: 01/04/05

D Repeat Finding

POSTOROERS
Policy: ICE pro\fidesoifficers alt Jlecessary guidance for carrying out their duties. This guidance includes Ile •
post orders established for every post,.wbicnare reviewed atieast annuaHy, and g~ven to 'each o1ifiicerupolil I
assignment to that post.
.
.'
,

COID.potlelirts

Y

N

NA

Every Fixed post has a set of post orders.
Each set contains the latest inserts (emergency
memoranda, etc.) and revisions.
One individual or department is responsible for keeping
all post-orders current with revisions that take place
between reviews.
The IGSA maintains a complete set (central file) of post
orders.
The central file accessible to all staff.
The OIC or Contract /IGSA equivalent
initiate/authorizes all post-order changes.
The ole or Contract /IGSA equivalent has signed and
dated the last p_age of every section.
A review/updating/reissuing of post orders occurs
regularly and at a minimum, annually.
Procedures keep post orders and logbooks secure from
detainees at all times.
Every armed-post officer qualifies with the post
weapon(s) before assuming post duty.
Armed-post post orders provide instructions for escape
attempts.
The post orders for housing units track the event
schedule.
Housing-unit post officers record all detainee activity in a
log. The post order include instructions on maintaining
the logbook.

~

~

D
D

D
D

~

D

D

~
~

D
D
D

D
D
D

~

D

D

~

D

D

~

D

D

D

D

~

D

D

~

~

D

D

~

D

D

[8] Acceptable

D

D

Deficient

~

At-Risk

Remarks: (Record significant facts, observations, other sources used, etc.)

52
G-324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 01/04/05

,Remarks

There are no armed
posts at facility

D

Repeat Finding

.SECURtTY fNS~ECTIO:NS

Pone,:: ,Pos,tasstgnmen'tsfn thefacili\t'$.h1gtHisk areas, where special seourityproceduresmustbe fallowed,
will be restricted to expenenced personnel 'with .a tnofOughgrounding in facitityo, ~ra11ions.
.
Comp~nents

Yes

The facility has a comprehensive security inspection
policy. The policy specifies:
• Posts to be inspected
• Required inspection forms
Frequency of inspections
Guidelines for checking security features
• Procedures for reporting weak spots,
inconSistencies, and other areas needing
improvement
Every officer is required to conduct a security check of
his/her assigned area. The results are documented.
Documentation of security insp_ections is kept on file.
Procedures ensure that recurring problems and a failure to
take corrective action are reported to the appropriate
manager.
The front-entrance officer checks the ID of everyone
entering or exiting the facility.

•
•

All visits officially recorded in a visitor logbook or
electronically recorded.
The facility has a secure visitor pass system.
Every Control Center officer receives specialized training.
The Control Center is staffed around the clock.
Policy restricts staff access to the Control Center.
Detainees do not have access to the Control Center.
Communications are centralized in the Control Center.
Officers monitor all vehicular traffic entering and leaving
the facility.
The facility maintains a log of all incoming and departing
vehicles to sensitive areas of the facility. Each entry
contains:
• The driver's name
• Company represented
• Vehicle contents
• Delivery date and time
Date and time out
• Vehicle license number
• Name of employee responsible for the vehicle
during the facility visit
Officers thoroughly search each vehicle entering and
leaving the facility.
The facility has a written policy and procedures to prevent
the introduction of contraband into the facility or any of its
components.
Tools being taken into the secure area of the facility are
inventoried before enterinQ and prior to departure.
The SMU entrance has a sallyport.
Written procedures govern searches of detainee housing
units and personal areas.
Housing area searches occur at irreQular times.

No iNA

[gI

D

D

[gI
[gI

D
D

D
D

[gI

D

D

[gI

D

D

[gI

[gI

D
D
D
D
D
D
D
D

D
D
D
D
D
D
D
D

[gI

D

D

D

[gI

D

[gI

D

D

[gI

D

D

[gI

[gI

D
D

D
D
D
D

[gI
[gI
[gI
[gI
[gI
[gI

•

[gI

53
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01104/05

Remarks

Kept in logbook

Logged in computer

SECURITY 'U4S,PECTrONS
Policy: Past assi.gmments in ,the facility's high:-risk.areas, where special security ;pr-ocedures must be ,followed, '
will be ,restricted to -eJCperienced personnel with a ;tihorough grounding In facility operations.
,No
Components
NA
Yes
Remarks
Every search of the SMU and other housing units
0
~
0
documented.
Storage and supply rooms; walls, light and plumbing
fixtures, accesses, and drains, etc. undergo frequent,
~
0
0
irregular searches. These searches are documented.
Walls, fences, and exits, including exterior windows, are
0
~
0
inspected for defects once each shift.
Daily procedures include:
• Perimeter alarm system tests.
0
~
0
• Physical checks of the perimeter fence.
• Documenting the results.
Visitation areas receive frequent, irregular inspections.
0
~
0

[8J Acceptable

D

D

Deficient

At-Risk

Remarks: (Record significant facts, observations, other sources used, etc.)

54
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01/04/05

D Repeat Finding

SPEctAl MANAGEMENT UN'JT(SM'U~

Administrative SegregatioJi1
Policy: The Speciall Management Unit requires in" every facntty 'isolates certain detaiflees ffQl1l'l.;~he general
population. vhe Special' Management Unit wiU consist of two 'sections. On.e, Administrative Segregation,
,houses detaineesiso1ated for their own protec~iOll; the other for detainees being disciplined for wrongdoing (see
the "Special Management UnilfOisciplinary Seftriegationr standard).

NA
The Administrative Segregation unit provides
non-punitive protection from the general population and
individuals undergoing disciplinary segregation.
•
Detainees are placed in the SMU
(administrative) in accordance with written
criteria.
In exigent circumstances, staff may place a detainee in
the SMU (administrative) before a written order has
been approved.
•
A copy of the order given to the detainee within
24 hours.
The OIC (or equivalent) regularly reviews the status of
detainees in administrative detention.
•
A supervisory officer conducts a review within
72 hours of the detainee's placement in the
SMU (administrative).
A supervisory officer conducts another review after the
detainee has spent seven days in administrative
segregation.
•
Every week thereafter for the first month.
•
Every 30 days after the first month.
•
Does each review include an interview with the
detainee.
•
Is a written record made of the decision and
the justification.
The detainee is given a copy of the decision and
justification for each review.
•
The detainee is given an opportunity to appeal
the reviewer's decision to someone else in the
facility.
The OIC (or equivalent) routinely notifies the Field
Office Director (or staff officer in charge of IGSAs) any
time a detainee's stay in administrative detention
exceeds 30 days.
•
Upon notification that the detainee's
administrative segregation has exceeded 60
days, the FD forwards written notice to HQ
Field Operations Branch Chief for ORO.
The OIC or equivalent) reviews the case of every
detainee who objects to administrative segregation
after 30 days in the SMU.
•
A written record is made of the decision and
the justification.
•
The detainee receives a copy of this record.
The detainee is given the right to appeal to the OIC (or
equivalent) the conclusions and recommendations of
any review conducted after the detainee has remained
in administrative segregation for seven consecutive
days.

o

o

o

o

o

o

o

o

o

o

o

o

o

o

o

o

55
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01104/05

Remarks

!

SPSC.Al MANAGEMENT UN'IT (smU)
Administrative Segregation

Policy: The $peoia1 Mamrgement Unit requir.ed lin every facflityisoIates certain detainees from ,the general
'populatiol1. The Special ,ManagememUnlt wiUcol'lsist of two. sections. One, Aoministratlve Segregation.,
houses detainees :iso\ated ror:their·aw,n protection; the .other for detainees 'being disciplined for wr<lI'lgdoing (see
the "Speciat Management Unit if,Disciplinary Segregationr' standard).
Components
Administratively segregated detainees enjoy the same
general privileges as detainees in the general
j)oj)ulation.
The SMU well ventilated.
• Adequately lighted.
• Appropriately heated.
• Maintained in a sanitary condition.
All cells are equipped with beds.
• Every bed securely fastened to the floor or
wall.
The number of detainees in any cell does not exceed
the occupancy limit.
• When occupancy exceeds recommended
capacity, do basic living standards decline?
• Do criteria for objectively assessing living
standards exist?
• If yes, are the criteria included in the written
procedures?
The segregated detainees do not have fewer
opportunities to exchange/launder clothing, bedding,
and linen than detainees in the general population.
Detainees receive three nutritious meals per day.
• From the general population's menu of the day.
• Do detainees eat only with disposable utensils.
• Is food ever used as _~unishment.
Each detainee maintains a normal level of personal
hygiene in the SMU.
• The detainees have the opportunity to shower
and shave at least three times a week.
• If not, explain.
The detainees are provided:
• Barbering services.
Recreation privileges in accordance with the
"Detainee Recreation" standard.
• Non-legal reading material.
• Religious material.
• The same correspondence privileges as
detainees in the general population.
• Telephone access similar to that of the general
population.
Personal
legal material.
•
A health care professional visits every detainee at least
three times a week.
• The shift supervisor visits each detainee daily.
• Weekends and holidays.
Procedures comply with the "Visitation" standard.
• The detainee retains visiting privileges.
• The visiting room available during normal
visiting hours.

iNA

Y

N

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

i

•

56
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01104/05

,
i

Remarks

I
I

SPECIAL 'MANAGEMENT UNIT lSMU)
AElmin:istratiiw Segregation

Policy: The Special Management Vnit ,required kl everyfacjlity isolates certain detainees from ,the,gerneral .,
popullation. The Special Management UnftwID consist ·oftwo section.s. One, Administrative Segregation, .
hOllses detainees isolated for thefr OWA protection; the ,other for detainees being disolplined ,for wrongdoing (see
the "Speoia:J. Marnag:ement Unit [Disciplinary Segre,gation]" standard).

.....

Com.ponents

Visits from clerQY are allowed.
Detainees do not have less law-library access than the
general population.
• Are they required to use the law library
separately, as a group? If so:
• Legal materials brought to them.
The SMU maintains a permanent log.
• Detainee-related activity, e.g., meals served,
recreation, visitors etc.
SPC procedures include completing the SMU Housing
Record (1-888) immediately upon a detainee's
placement in the SMU.
• Staff completes the form at the end of each
shift.
• CDFs and IGSA facilities use Form 1-888 (or
local equivalent).
Staff record whether the detainee ate, showered,
exercised and took any medication during every shift.
Logs record all pertinent information, e.g., a
medical condition, suicidal/assaultive behavior,
etc..
• The medical officer/health care professional
signs each individual's record during each visit
The housing officer initials the record when all
detainee services are completed or at the end
of the shift.
A new record is created for each week the detainee is
in Administrative Segregation.
• These weekly records are retained in the SMU
until the detainee's return to the general
population.

Y
[8J

N

NA

D

D

[8J

D

D

[8J

D

D

[8J

D

D

[8J

D

D

[8J

D

D

Remarks

•

•

~ Acceptable

D Deficient

D

At-Risk

. ·. 'U"III'L.n'lI facts, obseNations, other sources used, etc.)

57
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01/04/05

D Repeat Finding

SPECIALMANAGEM:ENT UNIT
(Disciplinary Segregati(),R~

:

Policy: Each faotn~wil.esta'blish aSpecial Management t.lnitin which toisdlate certain detainees from the'
general populatfort The Special Management Unit will have two section5,onefor detainees in Administrait4ve '
Segregation; the ,other for detainees ,being segregated for disciplinary reasons.
:
CompoReats

Y

N

NA i

Officers placing detainees in disciplinary segregation
follow written procedures.
The sanctions for violations committed during one
incident do not exceed 60 days.
Segregation
Order
completed
Disciplinary
A
accompanies the detainee into the SMU.
• The detainee receives a copy of the order
within 24 hours of placement in disciplinary
segregation.
Standard procedures include reviewing the cases of
individual detainees housed in disciplinary detention at
set intervals.
• After each formal review, the detainee receives
a written copy of the decision and reasons for it.
The conditions of confinement in the SMU are
proportional to the amount of control necessary to
protect detainees and staff.
Detainees in disciplinary segregation have fewer
privileges than those housed in administrative
segregation.
Living conditions in disciplinary SMUs modified to
reinforce acceptable behavior.
• If yes, does staff prepare written
documentation for this action.
• Does the OIC sign to indicate approval.
Every detainee in disciplinary segregation receive the
same humane treatment, regardless of offense.
The quarters used for segregation are:
• Well-ventilated.
• Adequately lighted.
• Appropriately heated.
• Maintained in a sanitary condition.

~

D

0

~

D

0

~

D

0

~

D

0

~

D

0

~

D

0

~

0

D

~

0

0

~

0

0

~

0

D

~

D

D

~

0

D

~

0

D

All cells are equipped with beds.
• The beds securely fastened to the floor or wall of
the cell.
The number of detainees confined to each cell or room
do not exceed the number for which the space was
designate.
• Does the OIC approve excess occupancy on a
temporary basis.
When a detainee is segregated without clothing,
mattress, blanket, or pillOW, (in a dry cell setting) a
justification is made and the decision is reviewed each
shift. Items are returned as soon as it is safe.
Detainees in the SMU have the same opportunities to
exchange clothing, bedding, etc., as other detainees.

58
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01104/05

Rema,rks

:
I

SPECtAL ,MANAGEMENT UNfIT
fDisoipUnary Segregation:)

:I

. Polie-y: Each facUitywilf' establtsh a Special Managemen¢ Unl'tin which to isdlate certain detainees from the
general population. The Special Management Unit will haveilWosections, one for detainees in Adminis'raWe
·~·otherfor
d:etatnees beingseg!regated forqiscipiinary reasons.
.
Segregation:;
·
.
. .
~.

Components
Detainees in the SMU receive three nutritious
meals/days.
• Selected from the Food Service's menu of the
day.
• Food is not used as punishment.
Detainees are allowed to maintain a normal level of
personal hygiene, including the opportunity to shower
and shave at least three times/week.
The detainees receive, unless documented as a threat
to security:
• Barbering services.
• Recreation privileges.
• Other-than-Iegal reading material.
• Religious material.
• The same correspondence privileges as other
detainees.
• Personal legal material.
When phone access is limited by number or type of calls,
limits do not apply to the following:
• Calls about the detainee's immigration case or
other legal matters.
• Calls to consular/embassy officials.
• Calls during family emergencies (as determined
by the OIClWarden).
A health care professional visits every detainee in
disciplinary segregation every day, Monday through
Friday.
• The shift supervisor visit each segregated
detainee daily
• Weekends and holidays.
SMU detainees are allowed visitors, in accordance with
the "Visitation" standard.
SMU detainees receive legal visits, as provided in the
"Visitation" standard.
• Legal service providers notified of security
concerns arising before a visit
Visits from clergy are allowed.
The clergy member given the option of
visiting/not visiting the segregated detainee.
ViolenVuncooperative
detainees denied access
•
to religious services when safety and security
would otherwise be affected.
SMU detainees have law library access.
• ViolenVuncooperative detainees retain access
to the law library unless adjudicated a security
threat in writing.
• Legal material brought to individuals in the
SMU on a case-by-case basis.
• Staff document every incident of denied
access to the law library.

Y

N

'NA

[gl

0

0

[gl

0

0

[gl

0

0

IZI

0

0

[gl

0

0

IZI

0

0

[gl

0

0

[gl

0

0

[gl

0

0

Remarks

Daily

•

59
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01104/05

SPEC.AL MANAGIEMENT UNIT
(Disciplinary "Segregation:)
Potic,.: Each facmty will establish a Special :f\:6aFtagement Unit in which te isoiatecertaln detainees firem the
general 'populatien. The Special Management Unit win have twe sections, .one fer detainees in Administrative
Segregation; ~he otherfor detainee.s b.eing s-egfegatedfor disciplinary reasens.
Components
All detainee-related activities are decumented, e.g.,
meals served, recreatien activities, visiters, etc.
Is the SPC's, the Special Management Heusing Unit
Recerd (1-888er equivalent) is prepared as seen as the
detainee is placed in the SMU.
• All 1-888s filled .out by the end .of each shift
• The CDF/IGSA facility use Ferm
• 1-888 (.or equivalent lecal ferm).
SMU staff recerds whether the detainee ate, shewered,
exercised, teek medicatien, etc.
• Details abeut the detainee legged, e.g., a
medical cenditien, suicidallvielent behavier,
etc.
• The health care .official sign individual recerds
after each visit.
The
heusing .officer initials the recerd when all
•
detainee services are cempleted .or at the end
.of the shift.
A
• new recerd is created weekly fer each
detainee in the SMU.
• The SMU retains these recerds until the
detainee leaves the SMU.
~ Acceptable

D Deficient

:N

'NA

~

0

0

~

0

0

~

0

0

Y

D

"

At-Risk

Remarks: (Record significant facts, observatiens, other sources used, etc.)
(b)(6). (b)(7)c

60
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01/04/05

,Remarks

D Repeat Finding

,

I

TOOL CONTROL

Poney: n 'is 'the policy of aU facnlties thatallemplo~ees shall be responsibtefor complying with the tool control '
policy. The Mamteoonce Supervisor shall maintain a computet generated ,or typewritten Master Inventory !/istof .
tooisandequipment and the location 1n which tools are stoyed. Theseinvenlor1es shall be current, f.ifedand
readily available for toolinventoryandaccountabiJity during an audit.
,
,NA
Components
Y
N
'Remar.ks
There is an individual who is responsible for developing
a tool control procedure and an inspection system to
insure accountability.
Department heads are responsible for implementing this
standard in their departments.
Tool inventories are required for:
• Maintenance Department
• Medial Department
• Food Service Department
• Electronics Shop
• Recreation Department
• Armory
The facility has a facility policy for the regular inventory
of all tools.
• The policy sets minimum time lines for physical
inventory and all necessary documentation.
• ICE facilities use AMIS bar code labels when
required.
The facility has a tool classification system. Tools are
classified according to:
• Restricted (dangerous/hazardous)

•

1ZI

0

0

1ZI

0

0

1ZI

0

0

1ZI

0

0

1ZI

0

0

1ZI

0'

0

1ZI

0

0

1ZI

0

0

IZI

0

0

1ZI

0

0

1ZI

0

0

1ZI

0

0

Non Restricted (non-hazardous).

Department heads are responsible for implementing
tool-control procedures.
The facility has policies and procedures in place to
ensure that all tools are marked and readily identifiable.
The facility has an approved tool storage system.
• The system ensures that all stored tools are
accountable.
• Commonly used tools (tools that can be
mounted) are stored in such a way that
missing tool are readily notice.
Each facility has procedures for the issuance of tools to
staff and detainees.
The facility has policies and procedures to address the
issue of lost tools. The policy and procedures include:
• Verbal and written notification.
• Procedures for detainee access.
• Necessary documentation/review for all
incidents of lost tools.
Broken or worn out tools are surveyed and disposed of
in an appropriate and secure manner.
All private or contract repairs and maintenance workers
under contract to the ICE, or other visitors, submit an
inventory of all tools prior to admittance into or departure
from the faCility.

61
G-324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 01104/05

TOOL CONTROL
Policy: :It is the po1icyofal1 faclUtres ttlat aU employ.ees shall be r,esponsible for complying ,wi~ the tool control
policy. The Mamremanoe Supervisof'shal1maintainacornputergenerate,d or 'typewritten Master ,I nventory ;\ist of
tools and equipment and the locatlOnin wnich tools are stored. These inventories shall be curpent, filedan:d
readny available f{)r too:l ;invenltory and accountabtJity during an audit.
y
,1'4
Remarks
Components
NA

I

IZI Acceptable

o Deficient

0

I

~

At-Risk

Remarks: (Record significant facts, observations, other sources used, etc.)
(b)(6), (b)(7)c

62
G-324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 01/04/05

I

o Repeat Finding

TRANSPORTATION
·.iLand.Transportat-ion)
Thetlil'm1ll~ration and Maturalizati()fl Service wJ!l ta'keall necessary precautiems to protect the fives, .
safety, and welfare ofour of,f,icers, 1he'generalpublic. and thoseifl lCEcusiody during the transportation of •
detainees,Standards have ibeen ·established for 'professional transp'Ortatiion 'Under the superviSion of :
experienced and tralAsd Detention ElJI;fo(;Qement Officers ,or authorized oon1r:act personnel.
,

Policy

1ZI Sia.dard NA:

CR:ecik ,tltls .box if aU ICE Transportation are bandledonty by thetCEReld 'Offloeor !
,
Sub-Office in oo:ntroloftbe ·deta·jnee case.
Com:poRents

Transporting officers comply with applicable local, state,
and federal motor vehicle laws and regulations. Records
support this finding of compliance.
Every transporting officer required to drive a commercial
size bus has a valid Commercial Driver's License (CDL)
issued by the state of employment.
Supervisors maintain records for each vehicle operator.
Officers use a checklist during every vehicle inspection.
• Officers report deficiencies affecting operability.
• Deficiencies are corrected before the vehicle
goes back into service.
Transporting officers:
• Limit driving time to 10 hours in any 15 hour
period.
• Drive only after eight consecutive off-duty hours.
• Do not receive transportation assignments after
having been on duty, in any capacity, for 15
hours.
• Drive a 50-hour maximum in a given work week;
a 70-hour maximum during eight consecutive
days.
• During emergency conditions (including bad
weather), officers may drive as long as
necessary and safe to reach a safe
area-exceeding the 1O-hour limit.
Two officers with valid CDLs required in any bus
transporting detainees.
• When buses travel in tandem with detainees,
there two qualified officers per vehicle.
• An unaccompanied driver transport an empty
vehicle.
Before the start of each detail, the vehicle is thoroughly
searched.
Positive identification of all detainees being transported is
confirmed.
All detainees are searched immediately prior to boarding
the vehicle by staff controlling the bus or vehicle.
The facility ensures that the number of detainees
transported does not exceed the vehicles manufacturers
occupancy level.
Protective vests are provided to all transporting officers.

,

No

NA

0

0

0

D

0

0

0

0

0

0

0

0

D

0

0

0

0

0

0

0

0

0

0

0

D

0

0

0

0

0

0

0

0

Yes

63
G-324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 01104/05

Rerna'rks

TRANSPORTATION
··,Land Transpolta,tion)
Policy Thetmtnigration and NatOra,l;ization Service wiIf ta:K~ aU necessary pfecau~ions to protect the lives,
safety, andwelifareof our oUicerS,thegerneral pub'lic,and1hose in ICEcbls:tody during 1iIetransportation at
detainees. Standards na'Vebeenestablished for professional transportation under 'tihesupervision of .
experienced and trained 'l)etiention Enforcement Offiicersorauthorizedcontraot personna:!.
~ Standard :NA-: Check tllisbox if aU 1lCE Transportalion are haadled on!ly 'by the :ICE Field Office or !
Sub-Office :in 'contFGlofthe detainee case.
. . '

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

Yes

:No

:NARemarks

D

o

D

0
0

o
o

o
o

0

D

o

0

o

D

0

o

D

0

o

o

o

o

o

64
G-324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 01/04/05

TRANSPORTA11QN
" (Land Transportation)
Policy Thelmmig~ation andNaturalizamonServicewil take a'l ;neoessary precautions to protect the Itves, !
safety, and welfare of ow officers, the generalpubl1c, and thoseim ~CEcustody :during ,the ,transpartatlonof '
professiona'ltransportation under the supervision of.
d'etGtinees.Standards have been established
experienced and traIned Detention Enfopcement Officers or authorizedcO'ntraot ,personnel.

ror

~ Standard NA: Check,tbis bOI( if all ICE Transportath.arebandledoniJy 'bytlile :ICE Field Office or '
Sub~:mceln controlGf !the detai!nee case.
'

Components

'Yes'

The following contingencies are included in the written
procedures for vehicle crews:
• Attack
•
Escape
•
Hostage-taking
•
Detainee sickness
•
Detainee death
• Vehicle fire
•
Riot
•
Traffic accident
•
Mechanical problems
•
Natural disasters
•
Severe weather
•
Passenger list is not exclusively men or women
or minors

o

[8J Acceptable

D

D

DefiCient

Re,marks

o

o

At-Risk

Remarks: (Record Significant facts, observations, other sources used, etc.)
(b)(6), (b)(7)e

~

•

•

65
G-324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 01104/05

D

Repeat Finding

USE OF iFORCE

'.

..

'Policy! T:ne'U .S. Department'of Homeland Seouriiyauthorizes th.e use,of force only as a last alternativeaier all
otiher reasonab.lee~orts to resolve a situation have failed. 'Only that amountoHorce r:lecessary to gainoontrOi .
of the detainee, to protect and ensure the safety of detainees, slaV ando1hers, to prevent serious property
damage and to ensure msmution security and good ,order 'maybe used. Physical restraints necessary to gam
contFol ota detainee Who appears to be dangerous may be employed ,when the detainee:
,

Components

Written policy authorizes staff to respond in an
immediate-use-of-force situation without a supervisor's
presenoe or direction.
When the detainee is in an area that is or can be
isolated (e.g., a locked cell, a range), posing no direct
threat to the detainee or others, officers must try to
resolve the situation without resorting to force.
Written polioy asserts that calculated rather than
immediate use of force is feasible in most cases.
The facility subscribes to the prescribed Confrontation
Avoidance Procedures.
• Ranking detention official, health
professional, and others confer before every
calculated use of force.
When a detainee must be forcibly moved and/or
restrained and there is time for a calculated use of force,
staff use the Use-of-Force Team Technique.
• Under staff supervision.
Staff members are trained in the performance of the
Use-of-Force Team Technique.
All use-of-force incidents are documented and reviewed.
Staff:
• Does not use force as punishment.
• Attempts to gain the detainee's voluntary
cooperation before resorting to force
• Uses only as much force as necessary to
control the detainee.
• Uses restraints only when other nonconfrontational means, including verbal
persuasion, have failed or are impractical.
Mecication may only be used for restraint purposes
when authorized by the Medical Authority as medically
necessary.
Use-of-Force Team follow written procedures that
attempt to prevent injury and exposure to communicable
disease(s).

Yes

,No

NA

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

~
~

D
D

D
D

~

D

D

~

D

D

~

D

D

66
G-324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 01/04/05

Remarks

USE OF FORCE

;P-olicy: The U.s; Department pf Homeland Security authorizes ,tile use of forceornty as a last alternative af:terall i

wee

mher reasoAable efforts ,to reSolve a situation have faiied. Only that amount of
necessary to gain control
of~he detainee,'to proteot and ensure th.esafetyOfdetainees.,staff and others, to preventserious;~roperty ,
damage ,and to ensure institution security a.nd ,good order maybe 'used. Physical.restraints necessary to gain
'
,
comrol of a detaineew,no appear.g to be dangerous may be employed wnen the detainee: '
,

,

'

Yes i ,No

Cornp,onents
Standard procedures associated with using four-point
restraints include:
Soft restraints (e.g., vinyl)
• Dressing the detainee appropriately for the
temperature.
• A bed, mattress, and blanket/sheet.
Checking the detainee at least every 15
minutes.
• Logging each check.
Turning the bed-restrained detainee often
enough to prevent soreness or stiffness.
Medical
evaluation of the restrained
•
detainee twice per eight-hour shift.
• When qualified medical staff is not
immediately available, staff position the
detainee "face-up".
The shift supervisor monitors the detainee's
position/condition every two hours.
• He/she allow the detainee to use the rest
room at these times under safeguards.
All detainee checks are logged.
In immediate-use-of-force situations, staff contacts
medical staff once the detainee is under control.
When the OIC authorizes use of non-lethal weapons:
• Medical staff is consulted before staff use
pepper spray/non-lethal weapons.
Medical
staff review the detainee's medical
•
file before use of a non-lethal weapon is
authorized.
Special precautions are taken when restraining pregnant
detainees.
• Medical personnel are consulted
Protective gear is worn when restraining detainees with
open cuts or wounds.
Staff documents every use of force and/or non-routine
a~ication of restraints.
It standard practice to review any use of force and the
non-routine application of restraints.
All officers receive training in self-defense,
confrontation-avoidance techniques and the use of force
to control detainees.
• Specialized training is given Officers are
certified in all devices they use.
The officers are thoroughly trained in the use of soft and
hard restraints.
In SPCs is the Use of Force form is used. In other
facilities (IGSAs / CDFs) this form or its equivalent is
used.

NA

•

•

I2$l

0

0

I2$l

0

0

I2$l
I2$l

0
0

0
0

I2$l

0

0

I2$l

0

0

I2$l

0

0

I2$l

0

0

I2$l

0

0

I2$l

0

0

I2$l

0

0

I2$l

0

0

•

67
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01/04/05

Remarks

USE OF FORCE

Policy:: The U.S. Department ofHom~and Securityau~horizes the use of fOliceonly as a last alternative after all ,
other reasonable etonslo resolve a situation have failed. OnJythatamdunt of force n.ecessaryto gajo'control .
of the detaimea, to protect .and ensure ,the safety of detainees,staiandothers, to prevemt serious property
damage and to ensure tnstitUitiolil security and good ofld,er may be used. Physica~ restraints necessary to ,gain
contFol·ofa detainee who appears to be dang.erOl.lsmay be employed when the:detainee:
CO'mponents
~ Acceptable

'1

D Deficient

D

Yes

1 :1\11'0'

1

NA

At-Risk

Remarks: (Record significant facts, observations, other sources used, etc.)

68
G-324A Detention Inspection Form Worksheet for rGSAs - Rev: 01104/05

:1

Remarks

D Repeat Finding

STAFF DETAU4EE COMMUNICATIONS
:Poliey:. Procedl;fres. mbrstbe'iR place to allow ior .format andin.formal 'contact between key facility staff .ao"
ICE staff and~CE det~ineeand to· permit detainees to make written requests ·to leE staff and recei'tean
.answerin an acceptab1etime~rame.

Co.panents
The ICE Field Office Director ensures that weekly
announced and unannounced visits occur at the IGSA.
Detention and Deportation Staff conduct scheduled
weekly visits with detainees held in the IGSA.
Scheduled visits are posted in ICE detainee areas.
Visiting staff observe and note current climate and
conditions of confinement at each IGSA.
ICE information request Forms are available at the
IGSA for use by ICE detainees.
The IGSA treats detainee correspondence to ICE staff
as Special Correspondence.
ICE staff respond to a detainee request from an IGSA
within 72 hours.
ICE detainees are notified ion writing upon admission to
the facility of their right to correspond with ICE staff
regarding their case or conditions of confinement.
~ Acceptable

D

D

Deficient

Y

:N

NA

D

D

rgj

D
D
D

D
D
D

rgj

D

D

rgj

D

D

rgj

D

D

rgj

D

D

rgj

Remarks

rgj
rgj

At-Risk

Remarks: (Record significant facts, observations, other sources used, etc.)

69
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 0 I104/05

D

Repeat Finding

DETAJHEE T,RANSFER STANDARD

•

Policy: teE will maike all necessary ,ootiif:ications when a detainee ,is transferred. It a detainee is being
.. transferred via .tbe Justice PrisonerAli~ Transportation System (JlPATS~,ICE wnladhere to JPATS
protocots~l:ndecidtngwf1:ether totransferaaetalnee, JOE wJI take intooonsideration whether the detaine.e
is liepresentedbeforetheimmigrationco.urt. ilnsuch cases.,the :Field OffICe Director wlllcons.ider the
detainee's stage within the remo¥a'i process, whether 'Ihe detainee's .attorney ,is located wi~hin reasonable
driving distance ,of the ;facflity. and where ,the tl11lrnligration ,coudproceedii:tgs alre :tak4ng place.
Comporumts

Y

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

•

N

,NA

IZJ

D

D

IZJ

D

D

IZJ

D

D

IZJ

D

D

IZJ

D

D

IZJ

D

D

IZJ

D

D

IZJ

D

D

IZJ

D

D

IZJ

D

D

IZJ

D

D

IZJ

D

D

•

•

•

•

•

•

Remarks
On file with local DHS
offices

•

70
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01/04/05

.

,

DETAlfJEETRANSFER STAN:DARD

Polley: ,tCEwiU make all necessary notifications when a detainee is transferred. If a detainee is being
transf.er:red via the JusiicePrisoner Alien Transportation System (JPATS), ;ICE win aanere tolPATS
protocols. Iln.decidtng~helrer to traAsfera detainee,.·~CEwfUta-Ke into -oonsideration whether -the detainee
is represented before the limmigration court. '(nsuoh cases,l1eField Office Director will -consider the
detainee's stagewithimthe removal process., whetherlhe detainee's attorney is 'located wi~hin reasonable
driving d1istance of the facility. ,and where the immigration ,court ;prooeedfngs are taltin:g plaoe.
Y
Remarks
CompOReDts
N
NA
Meals are provided when transfers ooour during
IZl
D D
normally sohedule meal times.
An A File or work folder aooompanies the detainee when
IZl
D D
transferred to a different field offioe or sub-offioe.
A Files are forwarded to the reoeiving offioe via
overnight mail no later than one business day following
IZl
D D
the transfer.

IZI Acceptable

o Deficient
ob~servatjons_

0

At-Risk

other sources used, etc.)

71
G-324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 01104/05

o Repeat Finding

•

The following items must be inspected for compliance with those Justice Core Standards not
covered by the ICE Detention Standards:

1

2
3
4
5
6

Written Policy and Procedures are in place to provide staff with the necessary
information to operate and maintain the facility on a daily basis and in accordance
with local, state, and federal law
Written policy and procedure are reviewed annually and updated accordingly

!8l

U

NA

0

0

'The facility provides for a system of monitoring through internal audits and reviews
The internal administrative audit is separate from any external audits or reviews
Audit or inspection reports identify areas of concern, identify necessary corrective
action, and provide for a system follow-up
Audit and Inspection reports are maintained on file until at least the next review is
conducted

0
".:.;. '."

7

8

9

To the extent Possible, physical plant design facilitates continuous personal contact
and interaction between staff and detainees in the housing unit and recreation /
leisure areas.
Written policies and procedures are in place that outline a comprehensive program
that promotes and encourages staff/detainee communications. A daily rotation
schedule should be established to ensure adequate staff coverage is provided
throu hout the meal.
Staff are provided appropriate annual cultural diversity or sensitivity training. Such
training is designed and implemented in a fashion that will further enhance
staff members' abili to communicate with detainees in an effective manner.

~ Acceptable

D Deficient D Repeat Deficiency D

At-Risk

*Remarks: (Record significant facts, observations, other sources used, etc.)
(b)(6), (b)(7)c

72
G-324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 01/04/05

!8l

0

0

!8l

0

0

IZI

0

0

•

..

ADepartment of Homclll!ld Security
Whington, DC 2053( ~

~

U.S. Immigration
and Customs
Enforcement

August 24, 2006

MEMORANDUM FOR:

John P. Torres
Director (Acting)
Office Of Detention and Removal
(b)(6), (b)(7)c

FROM:

I

Reviewer-In-Cn ..T!
SUBJECT:

St. Clair County Intervention Center's Annual Detention Review

The Detroit Field Office, Office of Detention and Removal conducted a detention review of the St.
Clair County Intervention Center on August 12 and 21,2006. This review was conducted by
Reviewer in Charge, and Team Member,
This facility is used for
detainees requiring housing more than 72 hours. Attached to this memorandum is a copy of the
original Form G-324a Detention Inspection Form and a copy of the worksheet.

a_' ,

Type of Review:

This review is a scheduled Operational Review to determine general compliance with established
Immigration and Customs Enforcement (ICE) National Detention Standards.

Review Summary:

The Facility is not accredited by the American Correctional Association (ACA). As with other
facilities within the State of Michigan, the old St. Clair County Jail was been inspected and approved
by the Michigan Department of Corrections and received 100% compliance with their regulations
for the past three years. Their medical department also held NCCHC accreditation and has for the
past 16 years. The st. Clair County Intervention Center is a brand new facility and has not been in
operation for one year yet. Facilities must be in operation for one year before accreditations are
awarded, therefore, no accreditations have been awarded.

Review Findings:

Subject: Detention Revie&mary Report
Page 2

•

The following infonnation summarizes those standards not in compliance. Each standard is
identified and a short summary provided regarding standards or procedures not currently in
compliance.

Compliant
Deficient
At-Risk
Non-Applicable -

32
0
0
6

RIC Observations:
•
•
•
•
•

•

•
•

BEST PRACTICE: Correction Officers were well versed in policies and procedures as well
as being professional and courteous.
Administration answered all questions and had policy manuals at arm's reach.
The Facility was clean and orderly.
Attitudes of both correction officers and inmates was positive and upbeat.
The St. Clair County Intervention Center is used by the Detroit Sector Border Patrol for
lodging detainees on a short-tenn basis, usually 1 to 7 days. They are either Mexican
nationals that have requested a Voluntary Return to Mexico and are awaiting the next
JP ATS flight (it runs every Tuesday) or a detainee that is to be turned over to the Detroit
Field Office on the next business day.
The facility currently holds 60 U.S. marshals prisoners and provides transportation to and
from Federal Court. USMS pays 2 deputies time and a halfper vehicle needed to provide for
these duties.
Video arraignments are available on-site
Jail administration would like to negotiate long term housing and transportation

Issues and Concerns
There were no 'Deficient' or 'At Risk' rated standards.

Recommended Rating and Justification:
It is the Reviewer in Charge recommendation that the facility receive a rating of "GOOD". The
facility continues to make progress for full implementation of the ICE Detention Standards. The
facility now fully complies with 32 of 32 applicable standards. The RIC recommends that the RIC
review standards found to be deficient within 90 days after receipt and concurrence of the Facilities
plans of action.

RIC Assurance ,Statement:
All findings of this review have been documented on Fonn G-324B and are supported by the written
documentation contained in the review file.

•

,.

•

Department Of Homeland Security
Immigration and Customs Enforcement

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

o
o

Detention Facility Inspection Form
Facilities Used Over 72 hours

G. Accreditation Certificates
List all State or National Accreditation[s] received:
~ Check box if facility has no accreditation[s]

B. Current Inspection
Type of Inspection
~ Field Office 0 HQ Inspection
Date[s] of Facility Review
8112/2006,8/21/2006

H. Problems / Complaints (Copies must be attached)
The Facility is under Court Order or Class Action Finding
Court Order
0 Class Action Order
The Facility has Significant Litigation Pending
Maior Litigation
0 Life/Safety Issues
,~ Check ifNoRe.

o
o

C. PreviouslMost Recent Facility Review
Date[s] of Last Facility Review
10119/2005
Previous Rating
Superior 0 Good ~ Acceptable 0 Deficient 0 At-Risk

I. Facility History
Date Built
2005
Date Last Remodeled or Upgraded

o

D. Name and Location of Facility
Date New Construction / Bedspace Added

Name
ST. CLAIR COUNTY INTERVENTION CENTER
Address (Street and Name)
1170 MICHIGAN
City, State and Zip Code
PORT HURON, MI 48060
County
ST. CLAIR
Name and Title of Chief Executive Officer (Warden/OIC/Superintendent)

•

.

Future Construction Planned
~ Yes 0 No Date: UNKNOWN
Current Bedspace
Future Bedspace (# New Beds only)
424
Number:
Date:

I

J. Total Facility Population
Total Facility Intake for previous 12 months
5652
Total ICE Mandays for Previous 12 months
2

•

Telephone # (Include Area Code)

•

•

Field Office / Sub-Office (List Office with oversight responsibilities)
DETROIT
Distance from Field Office
60

ICE Information
lnspec;tor (Last Name, Title and Duty Station)

IPHM

K. Classification Level (ICE SPCs and CDFs Only)
L-l
L-2
L-3
I Adult Male
I Adult Female

Member 1 Title / Duty Location
/DET
Name of Team Member / Title / Duty .LJV,_,. . . .JU
/
/
Name of Team Member / Title / Duty Location

L

F
aCllty
T Capacity
Rated
Adult Male
376
Adult Female
48

I

Basic Rates per Man-Day
Other Charges: (If None, Indicate N/A)
Estimated Man-days Per Year

Operational

Emerj~ency

o Facility holds Juveniles Offenders 16 and older as Adults

1 / '
F. CDFIIGSA Information Only
Contract Number
Date of Contract or IGSA

.

M Average Daily Population

I AdultMale
I Adult Female

.I

ICE
0
0

N. Facility Staffing Level
secu.rity:

USMS
60

Other

.-

I Support:

Form G-324A (Rev. 8/13/04) No Prior Version May Be Used After 1011/04

•

,

Significant Incident Summary Worksheet

•

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

2
Assault:
Offenders on
Offenders!

o

o

o

2

3

2

o
Assault:
Detainee on
Staff

Offender / Detainee Medical
Referrals as a result of
sustained.
Escapes

o

o

o

o

o

o

o

o

o

o

o

o

o

o

o

o

o

o

o

o

# Times FourlFive Point
Restraints applied/used

o

o

o

Number of Forced Moves,
incl. Forced Cell moves3

o

5

6

5

6

C

C

C

C

2

2

2

2

o

o

o

o

10

16

2

4

o

o

o

o

o

o

o

o

o

10

15

5

5

6

7

o
o

Actual
Grievances:

# Received
# Resolved in favor of
OffenderlDetainee
Reason (V=Violent, I=IlIness,
S=Suicide, A=Attempted

Deaths

Psychiatric /
Referrals

# Psychiatric Cases referred for

4

Outside Care

Any attempted physical contact or physical contact that involves two or more offenders

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

Form G-324A (Rev. 8/13/04) No Prior Version May Be Used After 10/1/04

•
1.

7.
8.
9.
10.
11.

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

•

Access to Legal Materials
Group Presentations on Legal Rights
Visitation

Classification System
Correspondence and Other Mail
Detainee Handbook
Food Service
Funds and Personal Property
Detainee Grievance Procedures
Issuance and Exchange of Clothing, Bedding, and Towels
Marriage Requests
Non-Medical Emergency Escorted Trip
Recreation

Detention Files
Disciplinary Policy
Emergency Plans
Environmental Health and Safety
Hold Rooms in Detention Facilities
Key and Lock Control
Population Counts
Post Orders
Security Inspections
Special Management Units (Administrative Segregation)
Special Management Units (Disciplinary Segregation)
Tool Control
Transportation (Land management)
Use of Force
Staff / Detainee Communication (Added August 2003)
Detainee Transfer (Added September 2004)

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

Form G-324A (Rev. 8/13/04) No Prior Version May Be Used After 10/1/04

•

RIC Review Assurance Statement

•

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

8/23/2006

IMMIGRATION ENFORCEMENT AGENT PHM

Recommended Rating:

o Superior
[gJ Good
o Acceptable
o Deficient
OAt-Risk

Comments:

Form G-324A (Rev. 8/13/04) No Prior Version May Be Used After 10/1/04

•

HEADQUARTERS EXECUTIVE REVIEW

I Review Authority
The signature below constitutes review of this report and acceptance by the Review Authority. OIC/CEO will have 30 days from
receipt of this report to respond to all findings and recommendations.
(b}(6). (b}(7)c

Final Rating:

D Superior
IZl Good
D Acceptable
D Deficient
D At-Risk
Comments: The Review Authority concurs with the Reviewer-In-Charge (ruC) recommended rating of
"GOOD" as justified in the ruc Memorandum and G-324A Worksheet.

Form G-324A (Rev. 8/1/01) No Prior Version May Be Used After 12/31/01

Office oj Detention and Removal Operations
U.S. Department of Homeland Security
425 I Street, NW
Washington, DC 20536

:JAN 1 0 2007
MEMORANDUM FOR:

Robin Baker
Field Office Director
Detroit Field Office
(b)(6), (b)(7)c

FROM:

SUBJECT:

(b)(6). (b)(7)c

-Chief
·11~
Detention Standards Comp

•

St. Clair Jail Annual Review

The annual review ofthe St. Clair Jail conducted on August 12 and 21,2006, in Port Huron,
Michigan has been received. A final rating of GOOD has been assigned. No further action is
required and this review is closed.
The rating was based on the Reviewer-In-Charge (RIC) Summary Memorandum and
supporting documentation. The Field Office Director must now initiate the following actions
in accordance with the Detention Management Control Program (DMCP):
1) The Field Office Director, Detention and Removal Operations, shall notify the facility
within five business days of receipt of this memorandum. Notification shall include
copies of the Form G-324A, Detention Facility Review Form, the G-324A Worksheet,
RIC Summary Memorandum, and a copy of this memorandum.
2) The Field Office Director shall schedule the next annual review on or before
August 12,2007.
_ . or your staff have any questions regarding this matter, please contact"
•
Detention and Deportation Officer, Detention Standards Compliance Unit at (202)
732-1II8l!!
cc: Official File
(b)(2)Low, (b)(6), (b)(7)c

www.ice.gov