Skip navigation

ICE Detention Standards Compliance Audit - West Texas Detention Facility, Sierra Blanca, TX, ICE, 2009

Download original document:
Brief thumbnail
This text is machine-read, and may contain errors. Check the original document to verify accuracy.
•

MGT
OF

AMERICA,

INC

1333 New Hampshire Avenue NW
Washington, DC 20036
Contract # 04-00-80-3818

ICE National Detention Standards
Compliance Review

•

•

Facility:

West Texas Detention Facility

Inspection Dates:

October 13-15, 2009

Report Date:

October 16, 2009

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)

•

1III1III1III1III1III_~~~~~~-~~5--5-5-5-5-55·-5555~

1I

1III1III1III1III1III1III..1III1III................1III..

-_.. _.•...

1333 New Hampshire Ave. NW
Suite 300
Washington, DC 20036

MGT
OF

AMERICA,

202/419-3930 (T)
202/419-3931 (F)
W\VW.MGTofAmerica.com

INC.

October 16, 2009

MEMORANDUM FOR:

David Venturella
Office of Detention and Rem

FROM:

b6,b7c

ons
b6,b7c

Lead Compliance Ins
b6,b7c

SUBJECT:

•

West Texas Detention Facility
Annual Detention Review

MGT of America performed an annual inspection for compliance with the ICE National Detention
Standards (NDS) at the West Texas Detention Facility located in Sierra Blanca, Texas during the period
of October 13-15,2009. This facility is an IGSA.
The annual inspection was performed under the guidance of Stephen J. Huffman, Lead Compliance
Inspector. Team members were:

SlIJ,Ije¢fM#ttefFi!!I!l . .
Security
Health Services
Food Services
Safety

T~ ~~lIllber

b6,b7c

TyPe ofReview
This review is a scheduled annual inspection which is performed to determine overall compliance with
the ICE NOS. The facility received a previous rating of "Acceptable" during the October 2008
inspection.

Review Summary

•

The West Texas Detention Facility is accredited by the American Correctional Association (ACA). The
facility is not accredited by the National Commission on Correctional Health Care (NCCHC) or the Joint
Commission on Accreditation of Health Organizations (JCAHO).

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)

Page II

•

MGT

==================================--"0' AMERICA, iNC
Standards Compliance
The following information is a summary of the standards that were reviewed and overall compliance that
was determined as a result of the 2009 and 2008 National Detention Standards compliance annual
inspection.
.

20081itSoeCtion
Compliant
Deficient
Repeat Deficiency
Not Applicable

1009 Im,pection
35
0
0
3

Compliant
Deficient
Repeat Deficiency
Not Applicable

37
0

a
1

Best Practices
The West Texas Detention Facility has well written and comprehensive policies, and their staff is
knowledgeable ofICE National Detention Standards.
The West Texas Detention Facility Law Library is well managed and offers a wide range oflegal material
which is accessible to the detainee population.

•

Recommended Rating and Justification:
The Lead Compliance Inspector recommends that the facility receive a rating of "Good."

LCI Assurance Statement
The findings of compliance and noncompliance are accurately and completely documented on the
G-324A Inspection form and are supported by documentation in the inspection file. An out brief was
b6,b7c
b6,b7c
conducted at the facility and the following were present:
, Warden;
,
b6,b7c
Assistant Warden; b6,b7c , Health Service Administrator;
, Administrative Assistant; and
b6,b7c
, ICE lEA.

b6,b7c

Signature:

LCI

October 16, 2009
Date

•
FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)

Page 12

Department Of Homeland Security
Immigration and Customs Enforcement

Reviewed
ICE Service Processing Center
ICE Contract Detention Facility
ICE
Service
B. Current Insnection
Type of Inspection

D

Field Office

~ HQ Inspection

Date[s] of Facility Review

October 13-15, 2009

C. PreviouslMost Recent Facili

Review

Date[s] of Last Facility Review

October 14-16, 2008

Detention Facility Inspection Form
Facilities Used Over 72 hours

I Estimated Man-days Per Year:
176,136

G. Accreditation Certificates
List all State or National Accreditation[s1received:
American Correctional Association
Check box if facility has no accreditation[ s1
H. Problems 1 Comnlaints (Conies must be attached)
The Facility is under Court Order or Class Action Finding
D Court Order
D Class Action Order
The Facility has Significant Litigation Pending
D Major Litigation
D Life/Safety Issues
IL!:J Check if None.

Previous Rating
aCl

IS or

Date Built
August 2004
Date Last Remodeled or Upgraded
June 2009
Date New Construction 1 Bed space Added
February 20001516 beds
Future Construction Planned
D Yes ~ No Date: N/A
Current Bed space
Future Bed space (# New Beds only)
1054
Number: NIA Date: N/ A

Officer
b6,b7c

b6,b7c

~ul)-U'ITI{:e

(List Office with oversight responsibilities)
Texas

J. Total Facility Population
Total Facility Intake for previous 12 months
4,217
Total ICE Man-days for Previous 12 months
15, 074
K. Classification Level (ICE SP C sandCD Fs 0 uly)

E ICE Information
Name ofLCI (Last Name, Title and Duty Station)
1 LCI 1 MGT of America, Inc.
b6,b7c
Name of Team Member 1 Title 1 Duty Location
b6,b7c 1 CI-Food Service 1 MGT of America, Inc.
Name of Team Member 1Title 1 Dnty Location
b6,b7c 1 CI-Security & Safety 1 MGT of America, Inc.
Name of Team Member 1Title 1 Dnty Location
b6,b7c
1 CI-Health Services 1 MGT of America Inc.
Name of Team Member 1 Title 1 Duty Location
1
1

LOI"tract or IOSA

L-l

N/A
N/A

Adult Male
Adult F ennale

L-2

N/A
N/A

L-3

N/A
N/A

L. Facility Capacity
Rated
Operational
Emergency
Adult Male
1006
960
1032
Adult Female
48
48
48
D Facility holds Juveniles Offenders 16 and older as Adults
M. Average Daily Ponulation
ICE
I AdultMale
41
I Adult Fennale
0

USMS
454
53

Other
0
0

per
Charges: (If None, Indicate N/A)

N. Facility Staffing Level
b2High

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Form 0-324A SIS (Rev. 7/9/07)

Detention Facility Inspection Form
Facilities Used Over 72 hours

Department Of Homeland Secnrity
Immigration and Cnstoms Enforcement

•

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

" Phoi,ol,

Types'

Assault:
Offenders on
Offenders]

etc.)

With
Without

A"HHit:

Types (Sexual

Detainee on
Staff

With

, etc.)

Without
. or rorc~~~~~~s,
inc!. Forced Cell
_4
Dis
Number of Times Chemical
Agents Used
E f T i m e S Special

usea

~

_~I
'

# Times Four/Five Point
Restraints applied/used

a

':

T rpe~(C~?t:':ir'rB~Bed,

Offender / Detainee Medical

Referrals as a result of
injuries

~

~
~

~

L

_

Escapes

Actual
I

Deaths

#D
# Resolved in favor of
Offender/Detainee

Reason.\:

':. '-:~""

",

Jan-Mar

Apr- Jun

Jul- Sept

Physical

Physical

Physical

Physical

0

0

0

0

12

10

12

6

N/A

N/A

N/A

Physical

0

0

0

0

0

0

0

1

0

1

2

0

0

0

1

0

0

0

0

0

9

3

5

0

0

0

0

0

0

0

0

0

0

3

7

0

0

0

0

0

0

0

0

0

12

48

46

43

3

0

0

0

0

0

0

0

0

0

0

0

0

0

2

0

0

0

0

0

Oct-Dec

Suicide,
"uuw ..

"

~utsid~ ~a;:ses referred for

IVleal"al

Referrals
I

#•

• Outside Care
I

~

Cases referred for

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

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

Department Of Homeland Security
Immigration and Customs Enforcement

Detention Facility Inspection Form
Facilities Used Over 72 hours

DBS/ICE Detention Standards Review Summary Report
2. Deficient

1.

3. At Risk

4.

1.
2.
3.
4.
5.
6.
7.
8.
9.

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 Presentation On Legal Rights

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

Marriage Requests
Non-Medical Emergency Escorted Trips
Recreation
Religious Practices
Access to Telephones
Visitation
Work

20.
21.

Hunger Strikes
Access to Medical Care
Suicide Prevention and Intervention
Directives and Death
Terminal

22.
23.
24.
25.
26.
27.
28.
29.
30.
31.
32.
33.
34.
35.
36.
37.
38.

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

5.Not

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

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

Department Of Homeland Security
Immigration and Customs Enforcement

•

Detention Facility Inspection Form
Facilities Used Over 72 hours

LeI Review Assurance Statement

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

SPECTOR

LEAD COMPT.T
.
Lead Compliance Inspector: (Print Name)

b6,b7c

b6,b7c

!

b6,b7c

Title & Duty Location

LCI, MGT of America, Inc.

,/

"'-

October 15,2009

TEAM MEMBERS
Print Name, Title, & Duty Location

Print Name, Title, & Duty Location
b6,b7c

CI-Food Service, MGT of America,Inc.

Print Name, Title, & Duty Location
b6,b7c

•

b6,b7c

, CI-Security & Safety, MGT of America, Inc.

Print Name, Title, & Duty Location

, CI-Medical Services, MGT of America, Inc .

commended Rating:

o Superior
IZl Good
o Acceptable
o Deficient
OAt-Risk

Comments:

•

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

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

•

•

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

ICE Detention Standards Review Worksheet

I:gj

D
D

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

Name
West Texas Detention l'
Address (Street and Name)
401 S. VIIIIIIPrll Ave., P.O. Box 430
City, State and Zip Code
, 1>1.
Texas 79851
County
.L

n

Name and Title of Chief Executive Officer (Warden/OIC/Superintendent)
"'- ...
b6,b7c
Name and Title of Reviewer-In-Charge
b6,b7c
,LCI
Date[s] of Review
October 13-15. 2009
Type of Review
I:gj Headquarters D Operational
D Special Assessment
DOther

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

TABLE OF CONTENTS

•

DETAINEE SERVICES STANDARDS (SECTION I) .................................................................................. 3
ACCESS TO LEGAL MATERIALS ...................................................................................................................... .
ADMISSION AND RELEASE .............................................................................................................................. .
CLASSIFICATION SYSTEM ............................................................................................................................... .
CORRESPONDENCE AND OTHER MAIL. .......................................................................................................... .
DETAINEE HANDBOOK ................................................................................................................................... .
FOOD SERVICE ................................................................................................................................................ .
FUNDS AND PERSONAL PROPERTY ................................................................................................................ .
DETAINEE GRIEVANCE PROCEDURES ............................................................................................................ .
GROUP PRESENTATIONS ON LEGAL RIGHTS .................................................................................................. .
ISSUANCE AND EXCHANGE OF CLOTHING, BEDDING, AND TOWELS ............................................................ .
MARRIAGE REQUESTS .................................................................................................................................... .
NON-MEDICAL ESCORTED TRIPS ................................................................................................................... .
RECREATION ................................................................................................................................................... .
ACCESS To TELEPHONES ............................................................................................................................... .
VISITATION ...................................................................................................................................................... .
VOLUNTARY WORK PROGRAM ...................................................................................................................... .

•

HEALTH SERVICES STANDARDS (SECTION II) ................................................................................. 30
HUNGER STRIKES ............................................................................................................................................ .
ACCESS To MEDICAL CARE ........................................................................................................................... .
SUICIDE PREVENTION AND INTERVENTION ................................................................................................... .
TERMINAL ILLNESS, ADVANCED DIRECTIVES AND DEATH .......................................................................... .
SECURITY AND CONTROL STANDARDS (SECTION III) .................................................................... 45
CONTRABAND ................................................................................................................................................. .
DETENTION FILES ........................................................................................................................................... .
DISCIPLINARY POLICY .................................................................................................................................... .
EMERGENCY PLANS ........................................................................................................................................ .
ENVIRONMENTAL HEALTH AND SAFETY ....................................................................................................... .
HOLD ROOMS IN DETENTION F ACILITIES ...................................................................................................... .
KEy AND LOCK CONTROL .............................................................................................................................. .
POPULATION COUNTS .............................................................................................................
POST ORDERS ................................................................................................................................................. .
SECURITY INSPECTIONS ................................................................................................................................. .
SPECIAL MANAGEMENT UNIT (ADMINISTRATIVE SEGREGATION) ............................................................... .
SPECIAL MANAGEMENT UNIT (DISCIPLINARY SEGREGATION) .................................................................... .
TOOL CONTROL .............................................................................................................................................. .
TRANSPORTATION (LAND) ............................................................................................................................ .
USE OF FORCE ................................................................................................................................................. .
STAFFIDETAINEE COMMUNICATIONS ............................................................................................................ .
DETAINEE TRANSFER STANDARD .................................................................................................................. .
>0 • • • • • • • • • • • • • • • • • • • • • • •

NOTE: FOR EACH STANDARD RATED BELOW ACCEPTABLE, FACILITIES MUST ATTACH A PLAN OF ACTION FOR BRINGING
OPERATIONS INTO COMPLIANCE.
EACH FACILITY SHOULD EXAMINE THE ENTIRE WORKSHEET TO IDENTIFY AREAS OF
INCLUDING THOSE STANDARDS WHERE AN OVERALL FINDING OF ACCEPTABLE WAS ACHIEVED.

FOR OFFICIAL USE ONL Y (LAW ENFORCEMENT SENSITIVE)
Page 2 of75

•
SECTION I

DETAINEE SERVICES STANDARDS

•

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 3 of75

ACCESS TO LEGAL MATERIALS
POLICY: FACILITIES HOLDING ICE DETAINEES SHALL PERMIT DETAINEES ACCESS TO A LAW LillRARY, AND PROVIDE LEGAL MATERIALS,
f PRIVILEGES, AND TIfP
; LEGAL
DOCUMENTL
NITYTOl
'''II.ITIE'_
1>~M'DL'.
YES
No
NA
The fucility provides a designated law library for detainee use.
Facilitypolic~and the detainee
handbook outline all library
~

I

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.
. a
.
number of chairs, is well lit, and is
The library
I from noisy areas.
andlor computers,
~nh: ~:: '>U~_"'J .
;for,
In addition to the physical law library, detainees have access to the Lexis
Nexis electronic law library.

I~:;;;

D

D

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

Detainees are
. I to assist other detainees,
'''J and free of
charge, in researching and preparing legal documents, consistent with

~

D

D

.
without legal representation
just English-language law books after

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

the T eyi, Neyi,

Where

lih~rv

i<

per week in the
library.
Detainees are offured a
5
Detainees are not required to forego recreation time in lieu oflihraryusage.
of the law library.
: facing a court deadline are given.
may request
.
not currently in the law library. Each
request is reviewed and, where appropriate, an acquisition request is timely
initiated. Requests for copies ofeaurt decisions areaccorrunodated within 3
- 5
: days.

receive access to more

: their need for help.
Detainees Uta! l,",~(lJU
amount ofpersonal legal material in the
general population and in the special management unit. Stored legal
: are ,
within 24 hours of a written reo"e,t
Detainees housed in
. ,r
and
"J
units have the same law library access as the general population, barring

security concerns.

Detainees denied access to legal materials are

.A
, for lifting 01
documented and.
All denials of access to the law library fully documented.

'"

•

staff
ICE
when a
or group of
: is rlenierl .cce" to the law library or law
who seek iudicial relief on any matter are not subjected to
, or:

~ ACCEPTABLE

There are 3 computers with
access to the Lexis Nexis

I .nrl i, e""ent

,,,h i'herllegal
Outside persons and organizations are pennitted to
material for inclusion in the legal library. Outside published material is
I and
I by ICE prior to inel",inn.
There is a
: I;:~E or fuc!li~nd u~ v J 'Wh~n a routine basis. and

Illiterate or

,.;,

D DEFICIENT

D

AT-RISK

-0-:

staff. The ~ v&'.
was updated
4 days prior to the review.

D REPEAT FINDING

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 4 of75

REMARKS:

b6,b7c

b6,b7c

b6,b7c

•

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 5 of75

ADMISSION AND RELEASE
POLlCY: ALL DETAINEES WILL BE ADMIITED AND RELEASED IN A MANNER THAT ENSURES THEIR HEALTH, SAFETY, AND WELFARE. THE
~~~~.~~~':~ PROCEDURE WILL, AMONG OTHER THINGS INCLUDE: MEDICAL SCREENING; A FILE-BASED ASSESSMENT AND CLASSIFICATION
A BODY SEARCH; AND A SEARCH OF PERSONALBEWNGINGS, WHICH WILL BE INVENTORIED, DOCUMENTED, AND SAFEGUARDED AS
'F

"RY.
('

YES

h, ~
an
of the facility. The orientation
includes: Unacceptable activities and behavior, and corresponding
sanctions; How to contact ICE; The availability ofpro bono legal services,
and how to pursue such services; schedule of programs, services, daily

NO

NA

lSI

D

D

Per facility policy, all detainees receive
an orientation presentation, view an
orientation video, and receive the
detainee handbook.

lSI

D

D

Medical staff does all the intake medical
screenings.

activities, including visitation, telephone usage, mail service, religious
programs, count procedures, access to and use ofthe law library and the
-I library; sick-call
and the detainee handbook.

Medical screenings are performed by medical staff or persons who have
received specialized training for the purpose of conducting an initial health

; have bee~and are

,.-,

office.

All new arrivals are searched in accordance with the "Detainee Search"
standard. An officer ofthe same sex as the detainee conducts the search
and the search is conducted in an area that affords as much privacy as

•

..

L.J

Detainees are stripped searched only when cause has been established and
not as routine policy. Non-criminal detainees are not strip-searched but
are patted do":n, unless
I is .
~!~ "e
standard governs all personal property searches.
,~JAo,~""rs use or have a similar contraband standard. Staffprepares a
cOlnpl.ete inventory of each detainee s possessions. The detainee receives
a copy.
...r form,",
,oncl Tn~A<
"y
Form 1-387 v'
1,
.
I allI-387 claims to ICE.
; are issued appropriate and sufficient clothing and bedding for
the
, items as needed.
The facility provides and
Gender-specific items are available. ICE Detainees are not charged for
these items.
I with ICE using a Form 1-203.
All
; are I
: fur release as
~llll
1

LJ

'"

J

. I0;

classified again by the mc"""
as
.~vu.uy

D

D

D

D

lSI

D

D

lSI

D

D

lSI

D

D

lSI

D

D

lSI

[J

[J

I:i<J

LJ

LJ
LJ

REMARKS:
b6,b7c
b6,b7c

II O-I5-~E

AUDlTOR'SSIGNATURE

..----b6,b7c

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 6 of75

CLASSIFICATION SYSTEM
POLICY:

ALL FACILITIES WILL DEVELOP AND IMPLEMENT A SYSTEM ACCORDING TO WHICH ICE DETAINEES ARE CLASSIFIED. THE
SYSTEM WILL ENSURE THAT EACH DETAINEE IS PLACED IN THE APPROPRIATE CATEGORY, PHYSICALLY SEPARATED FROM

rA·

e

YES

The fucility has a system for classifYing detainees. In CDFs
and IGSAs, an Objective Classification System or similar is
used.
system inclu"e,:
The fucility
• ClassifYing detainees upon arrival;
• Separating from the general population those
individuals who cannot be classified upon arrival;
and
• The first-line supervisor or designated
classification
specialist
reviewing
every
The

I

A_file.,

nfficer

etc., to
I new arrival.
Staff uses only
that is factual, and
to
determine classification assignments.
Opinions and
unsubstantiated! unconfirmed reports may be filed but are
not used to score
cI
Hn",in~
; are based on
-leVel.
A detainee's classification-level does not affect hislher
recreation opportunities. Detainees recreate with persons of
similar classification
work assignments are based upon classification
rhe
classification
process
includes
reassessment/reclassification. At IGSA's, detainees may
160 days after~ival.
Procedures exist for a detainee to appeal their classification
assigrunent. Only a designated supervisor or classification
specialist has the authority to reduce a classification-level on
appeal.
Classification appeals are resolved within five business days
and detainees are notified of the outcome within 10 business
days.
may be
to a higher
,or, .:. ~;,
,such as the
The Detainee Handbook or equivalent for !GSAs explains
the classification levels, with the conditions and restrictions
: to each.

o

I2J ACCEPTABLE

DEFICIENT

No

NA

I2J

0

0

Facility policy describes the,
process.
ICE detainees have been classified by ICE prior to
arrival, but are classified by fucility staff upon arrival
as
. and

I2J

0

0

ICE detainees are housed separate from the general
population.

,-,

,-,

"'"

LJ

LJ

I2J

0

0

~

LJ

LJ

I2J

0

0

I2J

0

0

0

I2J

0

The !GSA facility reassesses the detainee
classification every 90 days.

I2J

0

0

Detainees can appeal their classification through the
grievance process.

I2J

0

0

I2J

0

0

I2J

0

0

.~

OAT-RISK

o

REPEAT FINDING

REMARKS:

b6,b7c

n"~ ,,~,

b6,b7c

AUDITOR'S SIGNATURE

•

~

b6,b7c

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 7 of75

,

,

I

,

E'

CORRESPONDENCE AND OTHER MAIL

ALL FACILITIES WILL ENSURE THAT DETAINEES SEND AND RECEIVE CORRESPONDENCE IN A TIMELY MANNER, SUBJECT TO
FOR THE SAFETY, SECURITY, AND ORDERLY OPERATION OFTHE FACILITY. OTHER MAlL WILL BE PERMITTED, SUBJECT
; SAME
EACH r,
'WILL WIDELY DISTRIBIITE ITS GUIDELINES CONCERNING CORRESPONDENCE AND ornER MAIL.
YES
No
NA
The rules for correspondence and other mail are posted in each
Correspondence rules and regulations are
housing or common area, or provided to each detainee via a
addressed in the detainee handbook and every
detainee handbook.
detainee receives a handbook. These rules and
~

0

0

regulations are also posted in the housing units.
The facility provides key information in languages other than
English; In the language(s) spoken by significant numbers of
detainees. List
. within 24 hours or I
: mail is distributed to
;-day after it is received and .
Outgoing mail is delivered to the postal service within one

~

0

0

~

0

0

~

0

0

and other mail (including packages and publications) without the
detainee present unless documented and authorized in writing by
the Warden
for
reasons.

0

~

0

detainee and is not a requirement ofIGSA
facilities.

Staff does not read incoming general correspondence without the
Warden's prior written
_1

0

~

0

Mail is generally read for security reasollS.

~

0

0

~

0

0

~

0

0

~

0

0

~

0

0

~

0

0

~

0

0

~

0

0

~

0

0

~

0

0

~

0

0

business day of its entering the internal mail system (excluding
, ";'d L

Staff does not open and inspect incoming general correspondence

Staff does not inspect incoming special Correspondence for
physical contraband or to verifY the Hspecial" status of enclosures
without the detainee n,.,.,en'
CiS
.
from reading or copying incoming special
Staff is 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 "C';";'''.
: to a politician or to the media is processed as
special
and is not read or copied.
The official authorizing the rejection of incoming mail sends
written notice to the sender and the addressee.
The official authorizing
. or rejection of outgoing mail
. , the detainee with signed written notice.
Staff
a written record of every item removed from
, 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 fimds 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.
Original identity documents (e.g., passports, birth certificates) are
immediately removed and forwarded to ICE staff for placement in

E

'the

, a copy or rusiller ,uvm;,y

Mail is not opened in the presence of the

Facility policy describes the mail rules and
regulations. Funds received are placed in the
detainee's account in the Business Office and
detainee is given" rpcp;n'

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 8 of75

CORRESPONDENCE AND OTIlER MAIL

~

POLICY:

,
I

ALL FACILITIES WILL ENSURE THAT DETAINEES SEND AND RECEIVE CORRESPONDENCE IN A TIMELY MANNER, SUBJECT TO
I IIIn;n FOR THE SAFETY, SECURITY, AND ORDERLY OPERATION OFTHEFACILITY. OTHER MAIL WILL BE PERMfITED, SUBJECT
; SAME I
E A C H ' WILL
' r.Inn", INR< ,
AND OTHER MAIL.

Staff disposes of prohibited items found in detainee mail in
accordance with the "Control and Disposition of Contraband"
Standard or the similar
' : policy in [GSAs.
Every indigent detainee has the opportunity to mail, at
government expense, reasonable correspondence about a legal
matter, in three one ounce letters per week and packages
deemed
I by ICE.
The facility has a system for detainees to purchase stamps and for
mailing all special correspondence and a minimum of5 pieces of
general
, per week.
The facility provides writing paper, envelopes, and pencils at no
cost to ICE detainees.

0

I2<:l ACCEPTABLE

DEFICIENT

I2<:l

0

0

I2<:l

0

0

I2<:l

0

0

I2<:l

0

0

OAT-RISK

A commissary is provided for the detainees to
purchase stamps.

o

REPEAT FINDING

REMARKS:
b6,b7c
b6,b7c

110-15-0

SIG

~
b6,b7c

•

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 9 of75

DETAINEE HANDBOOK

POLICY: EVERY OIC WILL DEVELOP A SITE-SPECIFIC DETAINEE HANDBOOK TO SERVE AS AN OVERVIEW OF, AND GUIDE TO, THE DETENTION
r .r.~o RULES, AND PROCEDURES IN EFFECT AT THE FACILITY. THE HANDBOOK WILL ALSO DESCRIBE THE SERVICES, PROGRAMS, AND
t"UKI UNlll~' AVAILABLE THROUGH VARIOUS SOURCES, INCLUDING THE FACILITY, ICE, PRIVATE ORGANIZATIONS, ETC. EVERY DETAINEE
WILL KCChl v A COPY OF THIS HANDBOOK UPON ADMISSION TO THE FACILITY.
NO
YES
NA
"Ii'UA """"

J,

handbook is written in Fnali,h and translated into
IT
,or into the
The handbook is
by the facility orientation video,
where one is
"'""".
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 en onnm I review ofthe handbook by a designated committee
The

I:2l

0

0

I:2l

0

0

I:2l

0

0

I:2l

0

0

I:2l

0

0

I:2l

0

0

I:2l

0

0

I:2l

0

0

will be

I:2l

0

0

units, dayrooms, in, and spe~i~~e facilit~'units,'
dorm
The handbook describes official count times and count procedures;
meal times and feeding procedures; procedures for medical or
religious diets; smoking poJicy; clothing exchange schedules; and, if
authorized, clothes washing and drying procedures, and expected

I:2l

0

0

I:2l

0

0

I:2l

0

0

I:2l

0

0

I:2l

0

0

I:2l
I:2l
I:2l

[J

[J

0

0

[J

[J

[2l

0

0

[2l

0

0

nr

•

Personal Items permitted to be retained by the detainee;
and
• Initial issue of clothes, bedding and personal hygiene
items.
handbook states in clear language the basic detainee
The
_'L Illies.
'.,.
The handbook clearly outlines the methods for classification of
detainees, explains each level, and explains the classification

~

states when a medical

The handbook describe times and procedures for obtaining
disposable razors, and allows that detainees attending court will be
I the nnnnrhmi""n shave first.
The handbook describes barber hours and hair cutting restrictions.

The handbook describes the telephone policy; debit card procedures;
direct and free calls; locations oftelephones; policy when telephone
demand is high; and policy and procedures for emergency phone
calls.
The
The
The

~aw

states times and procedures for commissary or
, usage, where available.
; the,
the library location and hours ofoperation,
.~.
and schedules.
library·
attorney and regular visitation hours,
and
HU"

A handbook is issued to staff during employee
orientation.
Employees are issued a new handbook when
changes are made. In-service training is
on a regular basis.

Barber hours are not listed in handbook as
they vary. Hours are announced in housing
areas prior to hair cuts being given.
Telephone policy is explained in handbook;
however, debit card procedures are not
addressed. Information regarding use of debit
cards is posted in housing area next to phones.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 10 of75

I

DETAINEE HANDBOOK
POLICY: EVERY OlC WILL DEVELOP A SITE-SPECIFIC DETAINEE HANDBOOK TO SERVE AS AN OVERVIEW OF, AND GruDE TO, THE DETENTION
".~.ro RULES, AND PROCEDURES IN EFFECT AT THE FACILITY. THE HANDBOOK WILL ALSO DESCRIBE THE SERVICES, PROGRAMS, AND
rrv", um, ,,:~ AVAILABLE THROUGH VARIOUS SOURCES, INCLUDING THE FACILITY, ICE, PRIVATE ORGANIZATIONS, ETC. EVERY DETAINEE
",n.
,ACOPYOFTHIS
[UPON.
ITOTHIlFACILITY.
No
NA
YES
, the facility ,
The.
I policy.
IZI
LJ [J
'~O'v"Vv; the facility visiting hours and schedule, and
D D
: rules and rem.bt;nn,
; the
,policy and:
[J
[J
The handbook describes the detainee disciplinary policy and
procedures, including:
0
Prohibited acts and severity scale sanctions;
D D
0
Time limits in the Disciplinary Process; and
0
'ope

~;~~h'

IZI
IZI
IZI

The grievance section of the handbook explains all steps in the
grievance process - Including:
l l V V " . . . . , . . ~VV) . . . . . . . ."

....

5'

The appeals process;
0
In CDF facilities: procedures for filing an appeal of a
grievance with ICE.
0
Staftldetainee availability to help during the grievance
process.
0
Guarantee against staff retaliation for filing/pursuing a
grievance.
0
How to file a complaint about officer misconduct with the
tot
~
. ; the medical sick call procedures
. general:
' ami
.
The handbook descnbes the facllity recreation policy including:
0
Outdoor recreation hours.
0
Indoor recreation hours.
The
describes the detainee dress code for daily living; and
work
The handbook specifies the rights and responsibilities of all
detainees.
0

D DEFICIENT

IZI ACCEPTABLE
I

IZI

D

D

IZI

D

D

IZI

D

D

IZI

D

D

IZI

D

D

D

AT-RISK

Grievance procedures are clearly explained in
the handbook.

Recreation policy is addressed in the
handbook; however, hours for indoor/outdoor
recreation are not listed.

D REPEAT FINDING

REMARKS:
Telephone policy is described in handbook, with the exception of debit card procedures. Infunnation regarding the use of a debit card and
making collect calls is posted in housing areas next to the phone. Barber hours are not listed in the handbooks as they vary according to
facility activities. Advance notice is given to detainees so that they are aware when haircuts will be given. Recreation hours are not listed
in handbook; during the inspection, a written schedule of recreation hours was prepared and posted in housing areas.

b6,b7c

/10-15-09

AUDITOR'SSIG

b6,b7c

~

b6,b7c

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 11 of75

--

FOOD SERVICE
POLICY: EVERY FACILITY WILL PROVIDE DETAINEES IN ITS CARE WITH NUTRITIOUS AND APPETIZINGMEALS,PREPAREDIN ACCORDANCEWITH

'0.
YES

NO

NA

Responsibilities of cooks and cook foremen are in writing. The
Food Service Administrator (FSA) determines the responsibilities
of the Food Service Staff.

[2]

D

D

The Cook Supervisor is on duty on days when the FSA is off duty
and vice versa.
The FSA provides food service employees with training that
specifically addresses detainee-related issues.

[2]

D

D

[2]

D

D

[2]

D

D

[2]

D

D

All knires being used are physically secured to
work stations as required by the standard.
Yeast is used at this facility and it is secured
inside the FSA's office and locked using an
:device.

C

VIC ..." " .

The food service program is under the direct supervision of a

professionally trained and certified food service administrator.

i

•

In ICE Facilities this includes a review of the ICE ''Food
Service" standard

Knife,

close with an ~pp'"U
: device,. and the
, contm 1 t the J

The FSA determines the responsibilities of the
food service staff and is ServSafe certified.

device.

All knives not in a secure cutting room are physically secured to
the workstation and staff directly supervises detainees using
knives at these workstations. Staff monitors the condition of
knives and dining
When necessary, special procedures govern the handling offood
items that pose a secwity threat.

[2]

D

D

[2]

D

D

[2]

D

D

[2]

D

D

The FSA annually reviews detainee-volunteer job descriptions to
ensure they are accurate and
The Cook Foreman or equivalent instructs newly assigned

[2]

D

D

detainee workers in the rules and procedures of the food service

[2]

D

D

[2]

D

D

[2]

D

D

procedures include daily searches (shakedowns) of
: work areas.
FSA monitors staff implementation of the facility's
counts procedures.
Staff is trained in count
The detainees assigned to the food service department look neat
and clean. Their clothing and grooming comply with the "Food
Service" standard.

During orientation and training session(s), the CS explains and

demonstrates:

•
•

Sare work practices and methods;
Safety features of individual products/pieces of
equipment; and
• Training covers the safe handling of hazardous
rnaterial[ s1the detainees are likely to encounter in their
work.
The Cook Supervisor documents all training in individual
detainee detention files.

Detainee files located in the Food Service

Department were reviewed and contained
proper

Detainees at CDFs are paid in accordance with the "Voluntary
Work Program" standard. Detainee workers at !GSAs are
subject to local and state rules and regulations regarding detainee

[2]

D

. .

D

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 12 of75

FOOD SERVICE

,

i
I

-==

POLICY: EVERY FACILITY WILL PROVIDE DETAINEES IN ITS CARE WITH NlITRlTIOUS AND APPETIZING MEALS, PREPARED IN ACCORDANCE WITH
'<,

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 tollowmg 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, !GSAs use a 35
day or similar system for
: meals,
The FSA or fucility considers the ethnic diversity of the
facility's detainee population when developing menu cycles

YES

No

NA

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

/VI

n

n

~

~

~

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

No more than 14 hours elapse between the last
meal served and the first meal the following
day

This facility operates on a 5 week rotating menu
cycle,

\

A registered
~L:menu
every
The FSA has established

-1 reci~~~~'u =-

, a,

nutritional analysis of

,to ensure that items

the

uuu

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
know and adhere to written "food

,

~

whose religious beliefs require the adherence to
religious dietary laws are refined to the Chaplain or

A nutritional

on the

was available for review
: menus.

A common-fare menu available to detainees whose dietary

requirements cannot be met on the main line.
• Changes to the planned common-fure menu can be
made at the fucility level;
• Hot entrees are offered three times a week;
• The common-fare menus satisfY nutritional
recommended daily allowances (RDAs);
• Staff routinely provide hot water for instant beverages
and foods;
0
Common-tare meals are served with:
• Disposable plates and utensils .
• Reusable plates and utensils .
Staff
use
separate cutting boards, koives, spoons,
•
the
'" : diet items,
scoops, etc" to
A, ....}'. . . at the command level must approve a detainee's
I from the Common-Fare
The Warden, in conjunction with the chaplain and/or local
religious leaders, provides the FSA a schedule ofthe ceremonial
calendar year.
meals for the

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 13 of75

--

FOOD SERVICE

POLICY: EVERY FACILITY WILL PROVIDE DETAINEES IN ITS CARE WITH NUTRITIOUS AND APPETIZING MEALS, PREPARED IN ACCORDANCE WITH
L

YES

NO

NA

[21

0

0

[21

[J
0

[J
0

[21

0
0
0

0
0
0

[21

0

0

[21

0

0

[21

0

0

The COnunOll- fare program acconnnodates 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-forPassover meals as those who do participate.

•

Main-line offerings include one meatless meal (lunch or

dinner) on Ash
The food service pw5' a,a

'and Fridays during Lent.
I diets.

Satellite-feeding programs follow guidelines for proper

sanitation.
BV'

='u

W'U

'vvuo a,o

a,

"'0

p",oouvou,

0=0

temperature( s) while being served.
All meals are

[21
[21
[21

lin

Food is not used to punish or reward detainees based upon

I~vei~.

we,e

WUHU

'v ue

WWHH

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

.,.

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
Equipment is inspected for compliance with health and safety

codes and regulations.
• When was the most recent inspection?

• Which agency conducted the
Reports of discrepancies are forwarded to the Warden or
designated department head, and corrective action is scheduled
and
Standard procedure includes checking and documenting
temperatures of all dishwashing machines after each meal.
Staff documents the results of every refiigerator/freezer
check.

[21

0

0

[21

0

0

[21

0

0

[21

0

0

[21

0

0

The Texas Health Services Retail Food
Establishment report dated 7-7-09 was
available and indicated compliance with health
and ,c_
< and

The cleaning schedule for each food service area is conspicuously
posted.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 14 of7S

FOOD SERVICE

-==

POLICY: EVERY FACILITY WILL PROVIDE DETAINEES IN ITS CARE WITH NUfRITIOUS AND APPETIZING MEALS, PREPARED IN ACCORDANCEWITH
'0.

Procedures include inspecting all incoming food shipments for
damage, contamination, and pest infestation.
~ <V'

.0" areas are locked when not in use.

No

NA

[8J

0
[J

0
[J

[8J

o

[8J ACCEPTABLE

YES

DEFICIENT

OAT-RISK

o

REPEAT FINDING

REMARKS:

This fucility Food Service Depart

utritionally prepared meals in a safe and clean environment.
b6,b7c

b6,b7c

AUDITOR'S SIGNATU
b6,b7c

•

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 15 of75

FUNDS AND PERSONAL PROPERTY
POLICY: ALL FACILITIES WILL IMPLEMENT PROCEDURES TO CONTROL AND SAFEGUARD DETAINEES' PERSONALPROPERTY. PROCEDURES WILL
FOR THE SECURE STORAGE OF FUNDS, VALUABLES, BAGGAGE AND OTHER PERSONAL PROPERTY; THE DOCUMENTATION AND
,~~ ,,' nNe. OF SURRENDERED PROPERTY; AND THE INITIAL AND REGULARLY SCHEDULED INVENTORYING OF ALL FUNDS, VALUABLES, AND
OTHER PROPERTY.
D STANDARD NA: (lGSA ONLY) CHECK THIS BOX IF ALL ICE DETAINEE FUNDS, VALUABLESAND PROPERTY ARE HANDLEDONLYBY
THE Tt"1l'. v,
, >:1l ....0"mrR
.OFTHE
L
YES
NA
No
Detainee funds and valuables are properly separated, stored, and are
Detainee funds and valuables are
[2J
accessible only by designated supervisor(s).
D D separated and stored in a secured area.

'\~;r~:

are OWD' cu HO a location accessible to desigoated
~ ,"'ff only.
Staff itemizes the baggage and personal property of arriving detainees
(including funds and valuables). For IGSAs and CDFs, using a personal
fonn that meets the ICE standard?
Staff forwards an arriving detainee's medication to the medical staff

[2J

D

D

[2J

D

D

[2J

D

D

~~~~~~~~ and

[2J

D

D

[2J

D

D

[2J

D

D

follow written policy for returning forgotten property to

[2J

D

D

are immediately reported to the CD EO or Chief of

[2J

D

D

; when
rollows written
for handling detainee property claims are
CDFIIGSA facility_
similar with the ICE_
The facility attempts to notifY an out-processed detainee that helshe lett
property in the fucility:
• By sending written notice to the detainee's last known address;
• Via certified mail; and
• The notice state that the detainee has 30 days in which to claim the
after which it will be considered abandoned.
The fucility disposes of abandoned property in
with written
procedures.
If a CDF/IGSA facility, written procedure requires the prompt
to ICE.

I2Q

LJ

LJ

[2J

D

D

[2J

D

D

[2J

D

D

property occur each quarter and audits

Two officers are present during the processing of detainee funds and
valuables during in-processing to the facility. Both officers veruyfunds and
valuables.
Staff searches arriving detainees and their personal property for contraband.
"tarr
~p

.'J

"UUI

•

[2J

[J

DH

[

AT-KJ>K

All medication found during intake is
Eiven to the medical staff

;>tall

_,

arriving detainees and
for contraband.

LJ RVP"AT
I

REMARKS:

!

b6,b7c
b6,b7c

110-15-09

AUDITOR'S SIGNATURE
b6,b7c

•

~ ,lY

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 16 of75

DETAINEE GRIEVANCE PROCEDURES
POLICY: EVERY FACILITY WILL DEVELOP AND IMPLEMENT STANDARD OPERATING PROCEDURES (SOPS) FOR ADDRESSING DETAINEE
IN TIMELY FASHION. EACH STEP IN TIlE PROCESS WILL OCCUR WITHIN THE PRESCRIBED TIME FRAME. AMONG OTHER THINGS, A
::;ruEV,o,N<:E WILL BE PROCESSED, INVESTIGATED, AND DECIDED (SUBJECT TO APPEAL) IN ACCORDANCE WTIH THE SOPS; A GRIEVANCE
COMMITTEE WILL CONVENE AS PROVIDED IN THE SOPS. STANDARD PROCEDURE WILL INCLUDE PROVIDING TIlE DETAINEE WITH AWRITTEN
RESPONSE TO ANY FORMAL GRIEVANCE, WHICH WILL INCLUDE THE BASIS FOR TIlE DECISION. THE FACILITY WILL ALSO ESTABLISH STANDARD
PROCEDURES FOR HANDLING EMERGENCY GRIEVANCES. ALL GRJEV ANCES WILL RECEIVE SUPERVISORY REVIEW. REPRISALAGAlNSTTHEFILER
OF A GRIEVANCE WILL NOT BE TOLERATED.
RICMARKS
YES
NA
No
Written procedures provide for the informal resolution of oral grievances
Facility policy and the detainee
(Not mandatory).
[g]
handbook explain the grievance
D
D
• If yes, the detainee has up to five days within which to make
procedures.
his/her 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 [g]
D
D
when preparing a grievance.
, or
receive
•
special
,when
Every member of the staff knows how to identifir emergency grievances,
Staff receive grievance training
[g]
including the procedures for expediting them.
D during the 40-hour annual training.
D
There are documented or substantiated cases of staff harassing,
disciplining, penalizing, or otherwise retaliating against a detainee who
lodged a complaint:
• If yes, oynl.in
Procedures include maintaining a Detainee Grievance Log.
a If not, an alternative acceptable record keeping system is
maintained.
a "Nuisance complaints!! are identified in the records.
a For quality control purposes, staff document nuisance complaints
received but not filed.
Staffis required to
, ,,""illM' tbat includes officer misconduct
to a higher official or, in a
, facility, to ICE.

D

[g] ACCEPTABLE

DEFICIENT

D

[g]

D

AT-RISK

[g]

D

There are no documented cases of
staff harassment toward ICE
detainees.

D

D

The Administrative Captain
maintains the grievance log.

D

D
D

REPEAT FINDING

REMARKS:

b6,b7c

•

O
"

b6,b7c

II

b6,b7c

p~

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 17 of75

-

GROUP LEGAL RIGHTS PRESENTATIONS

I

POLICY: FACILITIES HOUSING ICE DETAINEES SHALL PERMIT AUTHORIZE PERSONS TO MAKE PRESENTATIONS TOGROUPS OFDETAINEESFOR
I~
• TION I ,AWAND PROCEDURES, CONSISTENT WITH THE SECURITY ANDORDERLYOPERATION
EACH FACILITY. ICE ENCOURAGES SUCH PRESENTATIONS, WHICH INSTRUCT DETAINEES ABOUT THE IMMIGRATION SYSTEM AND THEIR
RIGHTS AND OPTIONS WITHIN IT,
~ CHECK HERE IF No GROUP PRESENTATIONS WERE CONDUCTED WITHIN THE PAST 12 MONTHS. MARK STANDARD AS ACCEPTABLE
OVERALL AND CONTINUE ON WITH NEXT PORTION OF WORKSHEET.
YES
NA
No
The Field Office is responsive to requests by attorneys and accredited
0
0
0
' : for group
Upon receipt of concurrence by the Field Office Director, the facility or
authorized ICE Field Office ensures timely and proper notification to
0
0
0
i or
The fucility follows policy and procedure when rejecting or requesting
modifications to objectionable material provided or presented by the
0
0
0

r Ie",' 4~ hours
and accessible.
is submitted and maintained when
detainee is denied
I to attend a
'and the
l) for the deniaL
When the number of detainees allowed to attend a presentation is limited,
the facility provides a sufficient number of presentations so that all detainees
signed up may attend,
Detainees in segregation, unable to attend for
may request
;are
Such
with
are admitted when necessary to assist attorneys and other legal
Pn,'e,'

in advance and ,,:r

to,

are
:a

UHV.

sheets are

vvJ a

I of one hour to

make the presentation and

' 0.00;'

: ICE

ito

"L.J

"L.J

"L.J

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

LJ

LJ

LJ

0

0

0

0

0

0

0

0

0

0

0

0

Presenters are pennitted to meet with small groups of detainees to discuss

their cases after the group presentation, ICE or authorized detention stalfis
present but do not monitor conversations with legal

Group presenters who have had their privileges suspended are notified in
writing by the Field Office Director or designee; and the reasons for
suspension are documented, The Headquarters Office for Detention and
Removal, Field Operations and Detention management Division, is notified
whena group or'
, I is
I from making
The facility plays ICE-approved videotaped
on legal rights at
at the request of outside
regular '
A copy of the Group Legal Rights Presentation policy, including
is available to detainees nnnn

o DEFICIENT

~ ACCEPTABLE

OAT-RISK

o REPEAT FINDING
i

REMARKS:

b6,b7c

/ 10-15-09
AUDITOR'S SIGNATURE
b6,b7c

•

V

b6,b7c

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 18 of75

,

,

ISSUANCE AND EXCHANGE OF CLOTHING, BEDDING, AND TOWELS

C

POLICY: ICE REQUIRES THAT ALL FACILITIES HOUSING ICE DETAINEES PROVIDE CLEAN CLOTHING, BEDDING, LINENS AND TOWELS TO EVERY
UPON ARRlV AL. FURTHER, FACILITIES SHALL PROVIDE ICE DETAINEES WITH REGULAR EXCHANGES OF CLOTHING,LINENS,AND
1.8 FOR AS LONG AS THEY REMAIN IN DETENTION.

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, temperature-appropriate, presentable
clothing during in-processing. Detainees receive:
• One uniform shirt and one pair of uniform pants, or one jumpsuit;
• One pair of socks;
• One pair of underwear (Daily change); and
footwear.
• One pair or
Additional clothing is available for changing weather conditions, or as
IY
, "re ;«"e~ rie"n

I;nen<

"n~ tn~ei<

YES

No

NA

IZI

0

0

IZI

0

0

IZI

0

0

IZI

0

0

IZI

0

0

""".D".

Facility staff issue two sets of required
clothing items.

'of

a minimum:
• One mattress;
• One blanket;
• Two sheets;
• One pillowcase;
• One towel; and
• Additional blankets are issued based on local weather conditions.
I to ~pecial work areas are clothed in accordance with the
; oftheiob.
are provided clean clothing, linen and towels.
• Socks and undergarments - exchanged daily.
• Outer gannents - twice weekly.
• Sheets - weekly.
• Towels - weekly.
• Pillowcases Food service detainee volunteer workers are permitted to exchange outer
; daily.
Volunteer detainee workers are permitted to exchange outer garments more

IZI

0

0

IZI

0

0

IZI

0

0

Pillowcases are not required as
pillows are not issued.

Outer garments are exchanged three
times a week. Sheets are exchanged
twice weekly.

e""

o

IZI ACCEPTABLE

DEFICIENT

OAT-RISK

o

REPEAT FINDING

REMARKS:

b6,b7c

b6,b7c

110

AUDITOR'SSIGN

b6,b7c

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 19 of75

MARRIAGE REQUESTS

POLICY: ALL

, WILl.

IA!

CONSIDERATION FROM ICE MANAGEMENT.
YES
No
NA

c
Field Office considers detainee marriage requests on a case-by-case

basis.
The Field Office Director reviews every marriage request rejected by a
Warden/OIC or lGSA. Rejections are documented.

t0marry.
It is
, to require a written request fur
The written request includes a signed
or comparable
documentation from the intended spouse,
~ marital intent.
The walOon/OlC provides" wo .,,'" copy ofhislher decision to the detainee
. .
and hislher legal
When permission is denied, the Warden/OlC states the basis for his/her

decision.
The Warden/OlC provides the detainee with a place and time to make

o

[Sj ACCEPTABLE

DEFICIENT

[Sj

0

0

0

0

[Sj

lSI

LJ

LJ

[Sj

0

0

[Sj

0

0

[Sj

0

0

[Xl

n

n

OAT-RISK

o

Marriages are approved at this
fucility. but no requests have
been forwarded to be completed
or

REPEAT FINDING

REMARKS:

No marriage requests have been submitted for approval at this facility.

.,.

b6,b7c

"."-M

b6,b7c

UDITOR'SSIGNAT

b6,b7c

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 20 of75

I

!

i

I

,

,

i

,

NON-MEDICAL EMERGENCY ESCORTED TRIPS
POLICY: THE IMMIGRATION AND CUSTOMS ENFORCEMENT (ICE) MAY PROVIDE DETAINEES WITH STAFF-ESCORTED TRIPS INTO THE
'" rv" THE PURPOSE OF Y1SITING CRITICALLY ILL MEMBERS OF THE DETAINEE'S IMMEDIATE FAMILY, ORFOR ATTENDING FUNERALS.
rgJSTANDARDN/A: CHECK THIS BOX IF ALL ICE NON-MEDlCAL EMERGENCY ESCORTED TRIPS ARE HANDLED ONLY BYTHEICEFIELD
OFFICE OR SUB-OFFICE IN CONTROL OF THE DETAINEE CASE.
YES
NO
NA
The Field Office Director considers and approves, on a case-by-case basis,
trips to an immediate family member's:

•
•

Funeral; or
n

The facility
, mnthpr, father, hmther, sister, spouse, child, stepparent, and foster parent as '
fomih,.,
The !GSA facility notifies ICE of all detainee requests for
escorts.
"~p

The

detainee's request,

0

0

0

0

0

0

0

0

0

0

0

LJ

LJ

LJ

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

Officer reviews the file before forwarding a
recommendation, to the approving official Each
f~

".

,1.
'0'

kind
Each escort ,
, at least two
Escorting officers report unexpected situations to the originating fitcilityas a
matter ofprocedure, and the ranking supervisor on duty has the authority to
issue instructions for
of the trip.
Escorting officers have the discretion to increase or decrease minimum
restraints in accordance with written procedures and classification level of
the detainee.
iii-om
gifts/gratuities from a detainee,
Escort officers
detainee's relati~e or friend
,rt

0

ensure that detainees:

•

Conduct themselves in a manner that does not bring discredit to the
ICE;
• Do not violate federal, state, or local laws;
• Do not purchase, possess, use, consume, or administer narcotics, other
drugs, or intoxicants;
• Make no unauthorized phone calls; and
• Know they are subject to search, urinalysis, breathalyzer, or
, test upon return.
Standard
the
return to the facility of any
detainee who "'~,, i trip rules.

o ACCEPTABLE
REMARKS:

,

b6,b7c

".,

'"

AUDITOR'S SIGNATURE / nATE

OnEFICIENT

OAT-RISK

o REPEAT FINDING

b6,b7c

b6,b7c

~

,

,

,

,

,

I

,

,

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 21 of75

---

RECREATION
POLICY:
,~

IT IS ICE POLICY TO PROVIDE ACCESS TO RECREATIONAL PROGRAMS AND ACTIVITIES TO ALL ICE DETAlNEES, TO THE EXTENT
UNDER CONDITIONS OF SECURITY AND SUPERVISION THAT PROTECT THEIR SAFETY AND WELFARE.
.. u

1 and filci! itv.
The facility has a .
A recreational specialist (for facilities with more than 350 detainees) tailors
the program activities and offerings to the detainee population.

YES

No

NA

I2<:J

L

L
This facility does not have a

recreation specialist Recreation

0

0

~

is supervised by recreation

correctional officers, This
requirement is only mandated at
SPC/CDF.

Regular maintenance keeps recreational facilities and equipment in good

condition.
The recreational specialist or trained equivalent supervises detainee
recreation workers.
for special
, offer

:

unit~:;~ and

.,. ,;,'

.A,

. e.Q .. board Qames. cards.
tn .
t sports.
;are:
Each detainee has the opportunity to participate in daily recreation.

Detainees have:

I U)

•

activities outside the housing units for at

least one hour daily, 5 days a week.
,and
; aU items for·
, VI

~talJ

1 areas

AU

under I

1 areas

t is I

before and:

. SU111

[ with mdios.
: staff is
facility provides detainees in the SHU at least one hour of outdoor
time daily, five times per week.

Detainees in disciplinary/administrative
when a panel revokes hiSlher
. ,are

Snec;"l

receive a written
,to,

are required to sign a waiver ofJiability before entering a secure
portion of the facility where detainees
[ to serve as .
; or friends are not,
,
is
......
r
....
check
this box. No
I2<:J
Ifthe facility has no outside recreation, are detainees considered for transfer

after six months?

~

0

0

0

0

~

~

0

0

IX!

I I

I I

I2<:J

L

J

~

0

0

~

0

0

~

0

0

~

0

0

[X]

]

]

~

0

0

~

]

tis

0

0

LJ

J

0

0

0

0

0

0

, is
the ICE Districts routinely review transfer
: after 60 days.
'ror aU
The A-file of every detainee who is held more than 60 days without access

0

0

0

do
written determination of the detainee's ineligibility fur transfer.

0

0

0

, or no.

The detainee's written decision for or against an offered transfer
documented in his/her A-file.
Staff notifies the detainee's legal representative of his/her decision to

a transfer.
If no

f;;: """"" ci"".-""""'-",.., -

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 22 of75

1 hour
days a week.

]

0

detainee to the OlC.
,aU
TheOlC

17

SHU detainees are provided at
least 1 hour of outdoor recreation
daily 7 days a week.

[when

0

Case officers make written transfer recommendations about every six-month

: is

~
~
~

0

If yes, written procedures ensure timely review of all eligible

For.h
,'A,a.

Il5:

0

•

There are no detainee recreation
workers.

tis

I

RECREATION
POLICY: IT IS ICE POLICY TO PROVIDE ACCESS TO RECREATIONAL PROGRAMS AND ACTIVITIES TO ALL ICE DETAINEES, TO THE EXTENT
POSSmLE, UNDER CONDITIONS OF SECURITY AND SUPERVISION THAT PROTECT THEIR SAFETY AND WELFARE.
• 0

legal representative is notified of the detainee'slOIC's

o

r:gj ACCEPTABLE

DEFICIENT

0

OAT-RISK

0

0

o

REPEAT FINDING

REMARKS:
This facility provides recreational programs and activities to all detainees and supervision is provided by the security staff.

b6,b7c

b6,b7c

AUDITOR'S SIGNATU
b6,b7c

•

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 23 of75

RELIGIOUS PRACTICES
POLICY: FACILITIES WILL PROVIDE ICE DETAINEES OF ALL FAITHS WITH REASONABLE AND EQUIT ABLE OPPORTUNITIES TO PARTICIPATEINTHE
OF THEIR FAITH, LIMITED ONLY BY THE CONSTRAINTS OF SAFETY, SECURITY, THE ORDERLY OPERAnONS OF THE FACILITY AND
>AnON'

YES

: are:
I to engage in •
Space is ." ,ilohle for·
; to
The facility allows detainees to observe the major "holy days" of their
religious faith.
• List
The facility accommodates recognized holy-day observances by:

•
•
•
•

Providing special meals, consistent with dietary restrictions;
Honoring fasting requirements;
Facilitating religious services; and

No

NA

LJ
LJ

LJ
LJ

o

o

o

o

LJ

LJ

n

n

o

o

o

o
o

,

, is

Each

.,I,

's

: items in his/her .
are checked and verified before allowing

~

!XI

IHI

Members UllCllUl.:'i not represented by clergy may conduct their own services

within
Detainees in the Special Management Unit are allowed to participate in
religious practices unless otherwise documented for the safety and security

of the facility.

o

lSI ACCEPTABLE

DEFICIENT

OAT-RISK

REPEAT FINDING

REMARKS:

•
b6,b7c

11O-l~

b6,b7c

AUDITOR'SSIGNATURE
b6,b7c

•

'

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 24 of75

I

•

I

:

I
I

I

,

I

!

i

DETAINEE TELEPHONE ACCESS
POLICY: ALL FACILITIES HOUSING ICE DETAINEES WILL PERMIT DETAINEES' REASONABLE AND

are allowed access to telephones during established fucility
waking hours.

YES

No

NA

IS5l

0

0

detainees are made aware ofthe fucilit)ls telephone
Upon
access policy.
Access rules are posted in •
: units.
The facility makes a reasonable effort to provide key information to
detainees in languages spoken by any significant portion of the

IS5l

0

0

DSI

LJ

LJ

IS5l

0

0

Telephones are provided at a minimum ratio of one telephone per 25
detainees in the facility population.

IS5l

0

0

Telephones are inspected regularly by facility staff to ensure that they
are in good working order.

IS5l

0

0

The fucility:
to tne i.cuuy ,

IV1

n

n

IS5l

0

0

IS5l

0

0

IS5l

0

0

IS5l

0

0

DSI

LJ

LJ

,- -"',

cop",

• VUC-u.-v,ue,

, servIce

The facility administration monitors repair progress and takes
appropriate measures to ensure that 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 fucility provides the detainees with the ability to make non~special access) calls.
. . Access calls are at no charge to the
.
The OIG phone number for reporting abuse is programmed into the
detainee phone system and the phone number was checked by the
inspector during the review.

0

IS5l

0

IS5l

0

0

IS5l

0

0

IS5l

0

0

DSI

LJ

LJ

IS5l

0
[J

IS5l

0
[J
0

IS5l

0

0

IS5l

0

0

LE ACCESS TO TELEPHONES.

Facility policy explains the telephone
procedures. Detainees can make calls
between 6:00am and ll:OOpm.

There are 4 telephones for 48 detainees for a
ratio of! :12.

The orG telephone number is posted in the
housing units but not programmed into the
phone system. The number was tested and
found to be

In fucilities unable to fully meet this requirement initially because of
limitations of its telephone service, ICE makes alternate
arrangements to provide required access within 24 hours ofarequest
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
r. _''',
I are I
The fucility has a system for taking and
detainee telephone messages.
v

j

~uuue

call •

-0

''''-

emergency

} to,

IS5l

are allowed to return emergency phone calls as soon as
Detainees in disciplinary segregation are allowed phone calls relating
to the detainee's irrnnigration case or other legal matters, including
consultation calls.
in
segregation are allowed phone calls to

0
There are portable telephones available in
the disciplinary unit.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 25 of75

DETAINEE TELEPHONE ACCESS
POLICY: ALL FACILITIES HOUSING ICE DEIAINEES WILL PERMIT DEIAINEES' REASONABLE AND
YES

No

NA

Is:J

D

D

afforded the same telephone privileges as those in general

Is:J

D

D

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.

Is:J

D

D

in

ry segregation are allowed phone calls fur

fumilv,

LE

).

Detainees in administrative detention and protective custody are

D DEFICIENT

Is:J ACCEPTABLE

D

AT-RISK

Notifications of telephone monitoring are
posted in the housing units.

D REPEAT FINDING

REMARKS:

b6,b7c

b6,b7c

I 10-15-09

AUDITOR'S SIGNATURE I DATE
b6,b7c

•

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 26 of75

--

---

----

----

- ----

--

-

-- - -

-

-- - -

VISITATION

-===

POLICY:!CESHALLPERMITDEfAINEESTOVISITWITHFAMILY,FRIENDS,LEGALREPRESENTATIVES,SPECIALINTEREST GROUPS,AND THE NEWS

YES

NA

VilMA"".

.

and

v;;f~~~~~chedule.

, refler.<
All visits are non-

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

rgJ

D

D

The visitation hours tailored to the detainee population and the

rgJ

D

D

rgJ

[J

[J

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

rgJ

D

D

A written copy of the rules

rgJ

D

D

I'V'I

n

n

~

~

~

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

rgJ

A visitor dress code is

rgJ

D
[J

D
[J

rgJ

D

D

The visitors are cleared through a walk-thru
metal detector.

rgJ

D

D

are
under the age ofl5 .

D

D

rgJ

Minors are allowed to visit.

to a facility that will allow minor visitation. At a minimwn, monthly
visits are allowed.

D

D

rgJ

Minors are allowed to visit.

Detainees in spec~al_

rgJ

D
D

demand for visitation.
: and rules are ,

The

: to the public.

and the hours of

visitation is available to visitors.
A

01

.

,1,

.;,

: to the public.

Visitors are searched and identified according to standard

requirements.
The requirement on visitation by minors is complied with.
•

No

::acilities where there is no provision for visits by minors, ICE
for visits by children and stepchildren, on request, within
first 30 days.

the
contact visits.
The visitation hours are as follows: 8:00am5:00pm on Friday and Saturday for male
detainees, and the same hours on Sunday and
,,detainees.

The
officer.

dog is

I by the entry

to visit with an adult if

After that time, on request, ICE considers a transfer, when possible,

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

rgJ

D
D

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

rgJ

D

D

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

rgJ

D

D

Private consultation rooms are available for attorney meetings.
There is a mechanism for the detainee and hislher representative to

rgJ

D

D

There are mr;tten

~

LJ

LJ

rgJ

D

D

When strip
legal
visits with legal

: are

«uv'uw

.

are required after every contact visit with a
the fucility provides an option for non-contact

Prior to each visit, legal service providers and assistants are
identified per the standard_

~

rgJ

D

D

Legal visitation rooms are available with a
pass-thru window.

Legal representatives must be cleared prior to
their visit by submitting proper identification
before and during their visit to the Library
0_

current list of pro bono legal organizations is posted in the
detainee housing areas and other appropriate areas.

rgJ

D

D

..,_

The current Pro Bono listing is posted in all
housing units.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 27 of75

VISITATION
POLICY: ICE SHALL PERMIT DETAINEES TO VISIT WITH FAMILY, FRIENDS, LEGALREPRESENTATIVES,SPECIALINTERESTGROUPS,ANDTHENEWS

decision to peJIDit or deny a tour is not delegated below the
level ofField Office Director.

IZI

0

0

Provisions for NOO visitation, as stated in the Detention Standards,
are complied with.

IZI

0

0

referred to the ICE Field Office for approval.

IZI

0

0

Fonner detainees or aliens in proceedings, requesting to visit with a
detainee, are referred to the OlC or ICE Field Office.

IZI

0

0

Procedures are in place,
with the detention standard, for
examinations by independent medical service providers and experts.

IZI

0

0

Law enforcement officials who request to visit with a detainee are

o

IZI ACCEPTABLE

DEFICIENT

OAT-RISK

o

REPEAT FINDING

REMARKS:
b6,b7c
b6,b7c

/10-15-09

b6,b7c

AUDITOR'S SIGNATURE !D
b6,b7c

•

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 28 of75

VOLUNTARY WORK PROGRAM
POLICY: IN EVERY FACILITY OFFERING AVOLUNTARY WORK PROGRAM, ICE DETAINEES WILL HAVE THE OPPORTUNITY TO WORKAND EARN
BY PARTICIPATING. WHILE NOT LEGALLY REQUIRED, ICE AFFORDS DETAINEE WORKERS BASIC OCCUPATIONAL SAFETY ANDIiEALTH
(OSHA) PROTECTIONS.

o CHECK HERE IF ICE DETAINEES ARE NOT AUTHORIZED TO WORK AT THE IGSA FACILITY. MARKNAONFORM G-324A,PAGE3AND
MOVE TO NEXT SECTION.
YES
Does the facility have a voluntary work program?
• Do ICE detainees participate?

No

R~.M"'RK'

NA

ICE detainees are ""

r::gj

0

0

I2<J
r::gj

LJ

LJ

0

0

r::gj

0

0

the
The facility complies with work-hour requirements for detainees, not

IL'J

LJ

LJ

exceeding:

r::gj

0

0

lSI

[J

[J

r::gj

0

0

r::gj

0

0

r::gj

0

0

r::gj

0

0

lSI

LJ
[J

LJ
[J

,and
Detainees have the opportunity to ~ ' ..~
in special details,
are never
I to work outside the secure I
Written procedures govern selection of detainees for the Voluntary Work

the fucility did not have any ICE
i during this review.

,in

Eight hours a day and Forty hours a week.
n
. generally work
: to fixed
.~"
from a work detail, staft)laces the written
If a.
, for the action in the
1 file.
Staff, in accordance with written procedure, ensures that detainee volunteers
understand their responsibilities as workers before they join the work

•

•

o~~:~:fp;~c~meets:

Medical staff screen and formally certifY detainee food service volunteers.

•
•

Before the assignment begins; and
As a matter of written
i

Proper

..

receive
, is

I when an ICE

,is injured on the job.

o DEFICIENT

lSI ACCEPTABLE

I2<J
OAT-RISK

o REPEAT FINDING

REMARKS:
ICE detainees are authorized to work in this facility. Presently, there are no ICE detainees housed at this fucility.

b6,b7c

/ 10-15-09

b6,b7c

GNATU

b6,b7c

•

b6,b7c

V

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 29 of75

to

work in this facility; however,

•

SECTION II

HEALTH SERVICES STANDARDS

•

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 30 of75

- - --

HUNGER STRIKES
POLICY: ALL FACILITIES WILL FOLLOW STANDARD GUIDELINES FOR THE MEDICAL AND ADMINISTRATIVE MANAGEMENT OF ICE DETAINEES
~.~ • ~~.~ IN HUNGER STRIKES. By MONITORING OFTHE HEALTH AND WELFARE OF THE INDIVIDUAL DETAINEES, FACILITIES WILL STRIVE TO

l LIVES.

c:

",

""WheI1a detainee has refused food for 72 hours, it is

YES

No

NA

practice for

Medical policy H-70, Hunger Strike,

staff to refer himlher to the medical department.

requires notification of medical staff

IZI

0

0

IZI

0

0

IZI

0

0

CDFs and !GSAs immediately report a hunger strike to the ICE.

The facility has established procedures to ensure staff respond immediately

to a hunger strike.

~d

I

when a detainee has refused food for
72 hours. Per the HSA, in practice
notification is provided after the first
refused meal.
Policy requires medical staff to notifY
the Warden who in turn is to notifY
ICE.
Policy establishes the required
procedures.
Po~icy requires

require that staff isolate a hunger-striking detainee

trom other

•

D

isolation of a hunger

"rum rer me n~A,

If yes, in an observation room?

refusing one meal is counseled and

IZI

0

0

placed in the medical observation
multi-bed ward. After 3 refused
meals, the detainee would be moved
into a single-bed medical observation
cell.
When notified of a detainee refusing

IZI

0

0

from the physician to admit the

Medical personnel are authorized to place a detainee in the Special
Management Unit or a locked hospital room.

meals, medical staff requests an order
detainee to a medical observation bed.

Medical staff records the weight and vital signs of a hunger-striking

IZI

detainee at least once every 24 hours,

0

0

Policy requires daily weights and vital
signs. These are documented on a

fann entitled 'Hunger Strike",
The OIC of the facility obtains a hunger striker's consent befure medical
treatment

IZI

0

0

A signed Refusal of Treatment form is required of every detainee who

A detainee hunger striker would be
asked to sign a Medical Consent Form
for Treatment While on Hunger Strike
Status. The form is available in both
l'fl"l;o!, and

Any detainee refusing medical care

rejects medical evaluation or treatment.

must sign a Refusal of Medical

Treatments fonn in accordance with

IZI

0

0

IZI

0

0

During a hunger strike, staff document and provide the hunger-striking
detainee three meals a day.

Policy fur Right to Refuse Treatment.
If refusal of treatment puts the
detainee's life at risk, the fucility
would notifY ICE. The detainee would
be transported to an outside medical
fucility as
indicated.
Per policy, a hunger striker would be
offured 3 meals per day. Medical staff
would document the offer and the

detainee's response in the detainee's
medical record .

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 31 of75

HUNGER STRIKES
POLICY: ALL FACILITIES WILL FOLLOW STANDARD GUIDEUNES FOR ruE MEDICAL AND ADMINISTRATIVE MANAGEMENT OF ICE DETAINEES
ANGf"n,,,, IN HUNGER STRIKES. By MONITORING OF THE HEALTH AND WELFAREOFTHE INDIVIDUALDET AINEES, FACILITIES WILL STRIVE TO
~ I THEIR LIVES.
Staff maintains the hunger striker's supply of drinking water/other
beverages.

D

IS!

D

Per the HSA, a hunger striking
detainee would not be given
independent access to drinking water,
but would be offered fluids every hour
so as to ensure access to fluids at all
times as required by policy. Medical

staff would maintain an accurate

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

to record the hunger
fluid intake and food
Staff is
consumption; Does staff always use Hunger Strike Monitoring Form 1-8 39
or similar IGSA form.
The medical staffhas written procedures for treating hunger strikers.

IS!

D

D

IS!

D

D

IS!

D

D

accounting of all fluids consumed and
eliminated by the detainee.
A hunger striking detainee would not
be permitted to bring any food with
him when he is transferred to a
I cell.
medical
fln;~
I staff"'nnl~
and food consumption on a Hunger
Strike Monitoring Tool EHS H70
form.
Policy
written procedures
for
: hunger strikers.

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

D

D

Per the HSA, all counseling regarding
medical risks and all treatment
attempts would be documented in the
detainee's medical record.

D

Per discussions with the Training
Officer, and a review ofthe training
curriculum and individual staff
training records, staff receive training
in the identification of hunger strikes
during their initial 40- hour
orientation training. The HSA also
participated in hunger strike training
provided by PHSID IHS and in turn
trained other members of the medical
staff. A review of medical training
documentation confirmed the
of this additional

Staffhas received training in identification ofhunger strikes. Medical staff
receives early training in hunger-strike evaluation and treatment. Staff
remains current in evaluation and treatment teclmiques.

D

IS! ACCEPTABLE

D DEFICIENT

D

AT-RISK

D REPEAT FINDING

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 32 of75

-- __________ I

REMARKS:

No documentation was available for review to confirm compliance with policy directives as there have been no detainee hunger strikers at
hiS fucility. Staff interviewed are familiar with the policy requirements and have the ability to implement the policy should a hunger strike
•

ceur.

b6,b7c
b6,b7c

/10-15-09

S[GNA

b6,b7c

~
~
,

•

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 33 of75

ACCESS TO MEDICAL CARE

•

•

•

POLICY: EVERY FACILITY WILL ESTABLISH AND MAINTAIN AN ACCREDITEDiACCREDITAnON-WORTHY HEALTH PROGRAM FOR THE
GENERAL WELL-BEING OF ICE DETAINEES.
COMPONENTS
YES
No
NA
REMARKS
Facilities operate a health care facility in compliance with state and
Policy for Credentialing, requires current
local laws and guidelines.
licensure/certification confirmation
before hire and annually thereafter. The
licenses/certifications of clinical staff
were verified as current. Per the HSA,
[2J
D D the on-site satellite pharmacy is
inspected on a monthly basis by the
pharmacy provider. Procedures are in
place fur maintaining accountability for
rederally-controlled medications.
The facility's in-processing procedures for arriving detainees
An initial medical screening is conducted
include medical screening.
by detention officers using a
computerized screening fOim during the
booking process. A review of
documentation maintained by the HSA
[2J
D D continned the officers are trained to
complete the screenings. Upon
completion of the booking process, the
detainees are seen by medical staff for
additional intake screening as required
by policy for Receiving Screening.
A review of detainee medical records
All detainees have access to and receive medical care.
continned detainee access to, and receipt
of, medical care. Instructions for
accessing medical care are provided
during medical intake and are included in
the DetaineeiOffunder Orientation
Handbook. Detainees submitting nonurgent medical requests are scheduled
for sick call the next business day. Upon
notification to any staff member,
[2J
D D detainees with urgent medical concerns
are promptly referred to and seen by
medical staff. Documentation in
detainee medical records confinned
access to outside medical specialists
when indicated. Community medical
resources, including Culberson Hospital
in Van Hom and Del Sol and University
Medical Centers in El Paso, are used as
needed for emergency and/or inpatient
hospital care.
Per the HSA, and as confirmed per a
The fucility has access to a PHSIDIHS Managed Health Care
Coordinator.
review of detainee medical records, the
facility has access to a PHSIDIHS
[2J
D D Managed Health Care Coordinator
through the TARWeb system and per
phone call for more urgent concerns,

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 34 of75

ACCESS TO MEDICAL CARE

,

•

POLICY: EVERY FACILITY WILL ESTABLISH AND MAINTAIN AN ACCREDITED/ACCREDITATION-WORTHY HEALTH PROGRAM FOR THE

GENERAL WELL-BEING oFlCE DETAINEES.

The medical staff is large enough to provide, examine, and treat

Medical staff is on site 24 hours17 days a
week. Medical staffing includes a HSA,

the fucility's detainee population.

1 registered nurse, 1 licensed vocational
nurse, 5 emergency medical technicians

IS]

D

D

(one of which serves as the assistant
HSA), 1 phannacy tech, 2 medical
assistants and 2 medical records staff.
Per the HSA and as confirmed by a
review of the medical staffing schedule, a
minimum of2 clinical staff are on duty at
all times. The physician provides

services on site 3 times per week and is

The facility has sufficient space and equipment to afford detainee

on call when not on site. Dental services
are provided on site every wo weeks.
Mental health services are provided by
the physician and two clinical staff
specifically trained in mental health.
The medical unit has two

privacy when receiving health care.

examination/treatment rooms, including
one equipped to handle medical

emergencies/trauma. Portable
emergency medical equipment is
available for an on-site response to

•

IS]

D

D

medical emergencies. The medical area
also includes a 9-bed medical
observation ward, 10 single bed medical
isolation cells that are equipped to serve

as negative pressure rooms for isolating
any detainee with active tuberculosis and
2 suicide watch cells. A one-chair dental

office is also included in the medical
area.
The medical facility has its own restricted-access area. The
restricted access area is located within the confines of the secure
perimeter.

The medical area is a locked self-

contained unit within the secure
perimeter ofthe facility. On duty

IS]

D

D

medical staff control access to this secure
area. Control Center has the ability to

access the doors remotely in an
emergency.

A waiting room for detainees is located

The medical facility entrance includes a holding/waiting room.

IS]

D

D

near the back entrance to the medical

area.

•

The medical facility's holding/waiting room is under the direct
supervision of custodial staff.

Detention officers posted in the medical

IS]

D

D

area maintain direct supervision of the
detainees.

Detainees in the holding/waiting room have access to a drinking
fountain.

IS]

D

D

A drinking fountain is located within the

waiting room.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 35 of75

-

ACCESS TO MEDICAL CARE

•

•
:

•

POLICY: EVERY FACIUfY WILL ESTABLISH AND MAINTAIN AN ACCREDITED/ACCREDITATION-WORTHY HEALTH PROGRAM FOR THE
GENERAL WELL-BEING OF ICE DETAINEES.
Medical records are kept apart from other files. They are:
Medical records are secured in the
Medical Records room within the
• Secured in a locked area within the medical unit;
medical area. Records of detainees no
• With physical access restricted to authorized medical
longer in the fucility are stored in a
staff; and
separate
secured Archive room. Policies
Procedurally,
no
copies
made
and
placed
in
detainee
•
D D H-58, Health
~
Record Formats and
files.
Content, and H-59, Confidentiality of
Health Records, establish procedures to
protect the confidentiality of medical
records.
Pharmaceuticals are stored in a secure area.
Policy H-26, Pharmaceuticals,
establishes procedures for the
management, control and administration
of ph annaceuticaIs, Over-the counter
medications are secured within a locked
medication room. Prescription
pharmaceuticals are stored in locked
cabinets and carts within this medication
room. Federally controlled drugs are
D D further secured in a locked compartment
~
within a locked medication cart.
Inventory and accountability procedures
are compliant with applicable
regulations as continued per a review of
shift medication count records and drug
inventory logs. A check of actual
pharmaceutical counts against drug
inventory documentation confirmed its
accuracy.
Medical screening includes a Tuberculosis (TB) test.
Per a review of detainee medical records
and
TB Logs, detainees are given a TB
• Every arriving detainee receives a TB test during the
test
during
the medical intake process
admission process;
unless
documentation
of recent TB
Detainee's
TB-screening
does
not
occur
more
than
one
•
screening is available. Detainees with
business day after hislher arrival at the facility; and
D D pending TB test results, and those for
~
• Detainees not screened are housed separate from the
whom follow-up screening per x-ray is
general popUlation.
needed, are housed separate from the
general population until cleared by
medical staff for a housing assignment.
AU detainees receive a mental-health screening upon arrival. It is
In accordance with policies fur
Receiving Screening and Mental Health
conducted:
Program,
all detainees receive a mentalBya
health
care
provider
or
specially
trained
officer;
and
•
health
screerting
upon arrival. An initial
Before
a
detainee's
assignment
to
a
housing
unit.
•
mental health screening is conducted by
the detention officers, using a
computerized screening fonn, during the
D D booking process. A review of
~
documentation maintained by the HSA
confirmed the officers are trained to
complete the screenings. Upon
completion of the booking process, the
detainees are seen by medical staff for
additional mental health intake
screening.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 36 of75

ACCESS TO MEDICAL CARE

•

POLICY: EVERY FACILITY WILL ESTABLISH AND MAINTAIN AN ACCREDITED/ACCREDITATlON-WORTIIY HEALTH PROGRAM FOR THE
GENERAL WELL-BEING OF ICE DETAINEES.
The facility health care provider promptly reviews all 1-794s (or
Screening forms completed by the
equivalent) to identity detainees needing medical attention.
detention officers are reviewed by
medical staff during the medical intake

~

0

0

process. Screening documentation is
reviewed by the registered nurse when
she completes the detainee physical
assessments.
Per a review of detainee medical records,
the registered nurse usually completes

The health care provider physically examines/assesses arriving
detainees within 14 days of admission/arrival at the facility.

detainee physical exams/assessments
within the first 1-5 days ofa detainee's
placement in the facility. Per a review of

~

0

0

21 records, all detainees were assessed
within 14 days of admission. The facility
physician provided the registered nurse
with documented physical assessment
training and certified her ability to
complete these evaluations. The

physician reviews the docwnentation of
each assessment and co-signs the results.
Detainees in the Special Management Unit have access to health
care services.

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

I
I,

~

0

0

~

0

0

~

0

0

~

0

0

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.

Policy for Health Evaluation of
Offenders in Segregation requires a
medical evaluation to determine fitness
for placement in Segregation and equal
access to medical services for detainees
housed in this special management unit.
Daily visits by medical staff to all
detainees in the special management unit
are documented in medical reports and
Segregation security logs.
Policy for Daily Handling of NonEmergency Medical Requests,
establishes procedures for the use of
Medical Request forms to access
medical care. The request fonus are
written in English and Spanish.
Completed requests are placed in
specially marked boxes in the housing
units and are collected early each
morning by the medical staff
Two or more clinical medical staff is on
duty at all times. Policy for Emergency
Services, establishes a plan for the
delivery of24-hour emergency health
care when immediate outside medical
attention is required. Policy for
Emergency Plan, establishes additional
procedures for providing medical
services in the event of a disaster.
The facility physician is on call when not
on site. The HSA is also on call to
provide guidance to on-duty medical
staff.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 37 of75

ACCESS TO MEDICAL CARE

•

POLICY: EVERY FACILITY WILL ESTABLISH AND MAINTAIN AN ACCREDITED/ACCREDITATION-WORTHY HEALTH PROGRAM FOR THE

GENERAL WELL-BEING OF ICE DETAINEES.
The plan includes a list oftelephone numbers for local ambulance

A listing of community hospital phone

and hospital services.

~

D

D

numbers is available in the medical
trauma room, the medical records room
and the HSA's office. Emergency

Medical Services are summoned when
needed through a 911 call.

Policy requires security procedures that
ensure immediate transport of detainees

The plan includes procedures for facility staff to utilize this
emergency health care consistent with security and sarety.

~

D

D

when medically necessary. The Post
Order for the Ambulance Security

Officer establishes procedures to ensure
emergency medical transport is
consistent with security and safety.
Detention staffis trained to respond to health-related emergencies

Per Policy fur Training for Emergency
Response a review of emplovee training
records and the facility training plan, all

within a 4-minute resnonse time.

~

D

D

First Aid and in CPR.
In accordance with Policy for

Where stalfis used to distribute medication, a health care provider
properly trains these officers.

Phannaceuticals, all medications are

D

,

i
I
,

•

detention staff are trained in the
recognition of potential emergency
situations, in the administration of basic

D

~

distributed by health care staff.
Detention officers do not distribute

medications.
The medical unit keeps written records of medication that is
distributed.

In accordance with Policy for Medical

Administration Records are used to
document the administration of
medications. Per a review of detainee

~

D

D

medical records and medical department

documentation, and per observations
during Pill Call, all medications are

administered and documented in
accordance with accepted medical
protocol.
Per Policy fur Special Needs Treatment

The Fonn 1-819 (or IGSA equivalent) is used to notilY the
WardenlFacility of a detainee that has special medical needs.

Plans, the HSA is required to maintain a
list of special needs offenders.

~

D

D

Information on specific detainees is
commuuicated to the Warden and facility
staff through use ofa Health Summary
Report & Tuberculosis Screening

Evaluation form.
A signed and dated consent fonn is obtained from a detainee
before medical treatment is administered.

~

D

D

All detainees are asked to sign a general
Medical Consent F onn written in both
English and Spanish during the medical
intake process. In accordance with
Policy for Informed Consent, a separate

signed Consent to Operation, Diagnostic

•

or Special Treatment Procedure form is

used to document authorization for any
special procedures.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 38 of75

ACCESS TO MEDICAL CARE

•

POLICY: EVERY F ACILIIY WILL ESTABLISH AND MAINTAIN AN ACCREDITED/ACCREDITATION-WORTHY HEALTH PROGRAM FOR THE
GENERAL WELL-BEING OF ICE DETAINEES.

Detainees use the 1-813 (or !GSA equivalent) to authorize the
release of confidential medical records to outside sources.

D

D

D

D

D

D

The facility health care provider is given advance notice prior to
the release, transfer, or removal of a detainee.

Detainee1s medical records or a copy thereof are available and
transferred with the detainee.

•

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

[g] ACCEPTABLE

D DEFICIENT

[g]

D

D D
AT-RISK

Policy for Confidentiality of Health
Records establishes procedures for the
release of confidential medical records.
A signed Consent for Exchange of
Information fann is used to document
authorization by the detainee.
The fucility Transport Department
provides notification to medical staff for
all detainee arrivals, transfers and
removals. Per the HSA, if necessary,
detainee departure is delayed pending
completion of applicable medical
transfer summaries and preparation of
any needed transfer medications.
Per policy, discussions with the HSA,
observations in the medical area, and a
review of medical records for detainees
previously transferred from the fucility, a
Health Information Transfer Form
providing medical summary infonnation
is prepared for transfer with the detainee.
Original medical records are retained by
the fucility.
Per policies for Non-Emergency
Transport Protocols and
Phannaceuticals, documents containing
confidential medical infonnation are
placed in appropriately labeled sealed
envelopes for tran~ort.

D REPEAT FINDING

REMARKS:

No ICE detainees were housed in the facility during this inspection. Twenty-one closed medical records for ICE detainees housed in the
facility during the past year were reviewed. This review, together with direct observations, a review of training records and medical
documentation, discussions with medical and other facility staff and detainee interviews, confirmed the delivery of comprehensive health
care services within the scope of services available within the facility and the availability of off-site treatment when more extensive medical
care is necessary.

b6,b7c

•

b6,b7c

/10-15-09

SIGNATURE

b6,b7c

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 39 of75

SUICIDE PREVENTION AND INTERVENTION
POLICY: ALL DETENTION STAFF WORKING WITH ICE DETAINEES WILL BE TRAINED TO RECOGNIZE SUiCIDE-RlSK INDICATORS. STAFF WILL
'Nnl J' POTENTIALLY SUICIDAL INDIVIDUALS WITH SENSITIVITY, SUPERVISION, AND REFERRALS. A CLINICALLY SUICIDAL DETAlNEE WILL
PREVENTIVE SUPERVISION AND TREATMENT.

YES

No

NA

Every new staff member receives suicide-prevention training. Suicide-

prevention training occurs during the employee orientation program.

o o

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

Response, review of employee
training records and the facility's
Orientation training plan, all detention
staff is trained in Suicide Intervention
during orientation. The HSA
provided additional training to health
care staff using information obtained
from PHSIDIHS. A review of
medical training documentation
confirmed the provision of this

o o

Per policy and a review of the Suicide
Detection & Prevention in Jails lesson
plan, all required components are
included in the training

o o

In accordance with policy, all
detainees receive a mental-health
screening upon arrival. An initial
mental health screening is conducted
by detention officers, using a
computerized screening fann, during
the booking process. A review of
documentation maintained by the HSA
confirmed that officers are trained to
complete the screenings. Upon
completion of the booking process,
the detainees are seen by medical staff
for additional screening for suicide

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

RFMARKS

Per Policies for
and Training for Emergency

o o

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

o o

Policy establishes procedures for the
referral of at-risk detainees to medical
staff. None of the 21 detainees whose
medical records were reviewed were
I as being at risk.
The facility uses 3 levels of suicide
watch, with Levell being the most
restrictive for those detennined to be
at highest risk. Cell #315 in the
medical area is designated as the
primary location fur suicide watches
and is used for those placed on Level
1 watch status. Adjacent cell #316 is
also available if a second cell is
needed. Per the HSA, Cell #316 is
used for those placed on the less
restrictive Level 2 or 3.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 40 of75

,-------

smCIDE PREVENTION AND INTERVENTION
POLICY: ALL DETENTION STAFF WORKING WITH ICE DETAINEES WILL BE TRAINED TO RECOGNIZE SUICIDE-RISK INDICATORS. STAFF WILL
'ANn'I' POTENTIALLY SUICIDAL INDIVIDUALS WITH SENSITIVITY, SUPERVISION, AND REFERRALS. A CLINICALLY SUICIDAL DETAINEE WILL
AND TREATMENT.
YES

No

NA

Cell #315 included handicap rails,
metal brackets on the sides ofthe bed,
a metal toilet tissue holder and a small
water fountain on the sink to which a
noose could be attached. Except for
the small sink-mounted fountain, the

The designated isolation room does not contain any structures or smal1er
items that could be used in a suicide attempt.

structures of concern were removed

n

FX1

n

from the cell during the inspection.
Cell #316 is free of structures which
could be used in a suicide attempt
except for brackets attaching a seat
and small table to the wall. Both the
small sink-mounted fountain in Cell
IIJ I )

ana "'v ~V'v

in Cell #316 would be within the
direct line of sight of officers
maintaining suicide watches. Any
detainee placed on suicide watch is
maintained under constant one-on-one
observation and is not permitted to

retain person possessions Of standard

Medical staff has approved the room for this purpose.

D

D

D

D

Staff observes and documents the status ofa suicide-watch detainee at least
once every 15 minutes.

IZI ACCEPTABLE

•

D DEFICIENT

D

AT-RISK

issue clothing until evaluated by
health care staff and detennined to no
longer be actively suicidal. No ICE
detainees at this facility have been
placed on suicide watch status.
The facility physician provided written
approval for the use of Cells #315 and
#316 for suicide watches.
In accordance with Special Post Order
"Suicide Watch Officer, II officers
assigned to this post are required to
maintain constant surveillance, noting
the actions of the detainee and
recording those observations on a
suicide watch sheet at least once every
15 minutes. A review of Security
Watch Log Sheets confirmed 15
minute documentation. Medical staff
also observes detainees on suicide
watch and documents these
observations several times each day
on forms later inserted into the
medical record.

D REPEAT FINDING

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 41 of75

REMARKS:

•

Policies and procedures are in place to support a comprehensive suicide prevention plan. Staff training on suicide prevention and
ntervention is well documented. There have been no ICE detainee suicides or suicide attempts at this facility, and no detainee suicide
atches have been needed. The modifications made to Cell #315 during the inspection reduced the potential for attempted suicide by
hanging by any detainee placed on suicide watch in that cell. The policy of maintaining all detainees under suicide watch on one-an-one
constant surveillance mitigates concerns related to the remaining structural concerns in the designated cells.

b6,b7c
b6,b7c

/ 10-15-09

SSIGNAT

I~
b6,b7c

•

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 42 of75

-_.

TERMINAL ILLNESS, ADVANCED DIRECTIVES, AND DEATII
POLICY ALL FACILITIES HOUSING ICE DETAINEES SHALL HAVEPOUCIES AND PROCEDURES ADDRESSING THE ISSUES OF TERMINALILLNESSOR
",v£o,ANDDETAINEEDEATH, TO INCLUDE THEPROCEDURESTO ENSUREPROPERNOTIFICATION IS PROVIDED
1< FAMl!
AND OTHER INTERESTED PARTIES IN THE EVENT OF ADETAINEE BECOMING TERMINALLY ILLORINflJRE[)
OR DEATH OF ADETAINEE OCCURS. IN ADDITION, THE POLICY WILL COVER PROCEDURES TO BE TAKEN IF THE DEATH OF ADETAINEE OCCURS
WHILE IN TRANSIT.
IS! CHECK THIS BOX IF THE FACILITY DOES NOT ACCEPT ICE DETAINEES WHO ARE SEVERELY OR TERMINALLY ILL. INDICATENA IN
THE APPROPRIATE BOX FOR THIS PORTION OF TIlE WORKSHEET. ALWAYS COMPLETE ALL REFERENCES TO DETAINEE DEATH AND
.m. <Tvn

YES

No

NA

Ilv or terminally ill are transferred to an
appropriate offsite medical facility.

The facility does not have adequate

Detainees who are

resources for, and does not accept,

IS!

D

D

terminally or severely ill detainees. In
accordance with policy for Terminal
Illness, Advance Directives and Do-NotResuscitate (DNR) Orders, any detainee
diagnosed as being in need of more
extensive medical care is transferred to
. taClllty lOf
the near~st
I care.
The facility does not accept severely or
terminally ill detainees. Should a detainee
housed in the fucility become seriously ill,
policy establishes procedures for the
notification ofICE. Per the ICE
Enforcement Agent at the facility during
HU'C

The facility or appropriate ICE office promptly notifies the next of
kin ofthe detainee's medical condition, to include:
• The detainee's location; and

•

The limitations placed on visiting.

IS!

D

D

the inspection, ICE would then assume

are guidelines addressing the 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 D IHS

IS!

D

D

the documents.
There is a policy addressing liDo Not Resuscitate Orders"

Detainees with a liDo Not
' order in the medical record
: efforts short of resuscitation?
receive maximal

I

The fucility notifies the DIHS Medical Director and Headquarters'
Legal Counsel of the name and basic circumstances of any detainee
with a liDo Not Resuscitate" order in the medical record. In the case
of IGSAs, this notification is made through the local ICE

assisting any detainee interested in

implementing an advanced directive.

provides or who wishes to appoint another to make advance
decisions for him or her.

The guidelines provide the detainee the opportunity to have a private

responsibility for next of kin notification
when
Although severely or terminally ill
detainees are not accepted by the facility,
policy does establish procedures for

The fucility does not accept terminally or
ill detainees.
The fucility does not accept terminally or
severely ill detainees. In addressing the

D

D

IS!

D

D

IS!

issue of Do Not Resuscitate orders, policy

I2J

states that DNR orders are beyond the
scope of care delivered at this facility.
The facility does not accept terminally or
ili detainees.

D
D

D
D

I2J

The facility has written procedures to address the issues of organ
donation by detainees.

IS!

D

D

A ,,,

The facility does not accept terminally or
severely ill detainees. Per the Warden, no
detainees with current DNR orders have
been admitted to the fucility.
Policy for Organ Donation by Detainees,
establishes procedures to address the issue
of organ donation by detainees.
Donations are permitted only to members

of the detainee's innnediate family and
only at the detainee's

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 43 of75

----

.

,

TERMINAL ILLNESS, ADVANCED DIRECTIVES, AND DEATH
POLICY ALLFACILITIES HOUSING ICE DETAINEES SHALL HAVE POLICIES AND PROCEDURES ADDRESSING THE ISSUES OF TERMINAL ILLNESS OR
MEDICAL ADVANCED DIRECTIVES, AND DETAINEE DEATH, TOINCLUDETHEPROCEDURESmENSUREPROPERNOTlFlCATIONISPROVlDED
)TrF,

'nn~INTERESTEDPARTIESINTHEEVENTOFADETAlNEEBECOMINGTERMINALLYILLORINJURED

1< FAMTT

OR DEATH OF ADETAINEE OCCURS. IN ADDITION, THE POLICY WILL COVER PROCEDURES TO BE TAKEN IF THE DEATH OF ADETAINEE OCCURS
WHILE IN TRANSIT.
~ CHECK THIS BOX IF THE FACILITY DOES NOT ACCEPT ICE DETAINEES WHO ARE SEVERELY OR TERMINALLY ILL. INDICATENAIN
THE APPROPRIATE BOX FOR THIS PORTION OF THE WORKSHEET. ALWAYS COMPLETE ALL REFERENCES TO DETAINEE DEATH AND
C
The facility has written procedures to notifY ICE officials, deceased
family members and consulates, when a detainee dies while in
Service.

YES

No

Policy for Procedure in the Event of an
Offender's Death requires notification of

ISJ

D

D

ISJ

D

D

The facility has a policy and procedure to address the death of a
detainee while in transport.

ICE in the event of a detainee death. Per
the lEA, ICE would assume responsibility
, as
for other
Policy for Death Occurring in ICE
Custody, establishes procedures to
, the death of
while in

a

,

Per the lEA, ICE would handle

At all ICE locations the detainee's remains disposed ofinaccordance

with the provisions detailed in this standard.

»~~'DVO

NA

ISJ

D

D

disposition of the detainee's remains in
accordance with the requirements ofthe

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
of Veterans Affuirs notified?
original or certified copyofa detainee's death certificate is placed
the subject's a-file.

ISJ

D

D

Per discussion with the lEA, ICE policy
would dictate the handling of any needed
burial arrangements by ICE.

ISJ

D

D

Per the lEA, ICE would place a copy of
the detainee death certificate in the
a-file.

The facility follows established policy and procedures describing
when to contact the local coroner regarding such issues as:
• PerfOlmance of an autopsy;

•
•
•

Who will perform the autopsy;
Obtaining state approved death certificates; and
Local
of the body.
ICE staff follows established procedures to properly close the case of

ISJ

ISJ ACCEPTABLE

DDEFICIENT

D

and would contact the local coroner.

ISJ

a deceased detainee.

D

Policy for Authority to Order Autopsies,
addresses contact with the coroner. The
Sheriff would be notified of any deaths

D

D AT-RISK

D

Per the lEA, ICE would close the case of a
deceased detainee in accordance with
policy.
D REPEAT FINDING

REMARKS:
Per the Warden and HSA, no terminally or severely ill detainees have been admitted to this facility, and there have been no detainee deaths.
Any detainee already housed at the facility identified as needing more extensive medical care would be transported to a community
medical facility.
b6,b7c
b6,b7c
/10-14-0
AUDITOR'S SIGNATURE ID

•

b6,b7c

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 44 of75

•
SECTION III

SECURITY AND CONTROL STANDARDS

•

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 45 of75

CONTRABAND
POLICY: ALL DETENTION FACILITIES WILL ENSURE THE PROPER HANDLING AND DISPOSAL OF ALL CONTRABAND. DOCUMENTATION OF
DESTRUCTION IS
YES
No
NA
The facility follows a written procedure for handling illegal contraband.
Facility policy reflects the
Staff inventory, hold, and report it when necessary to the proper authority
handling of contraband. All
12;;]
fur action/possible seizure.
illegal contraband is processed
0
0
through the Hudspeth Sheriffs
Office.
r
' p up ' l " retained as evidence for potential
12;;]

:~~~:~~~r

Staff returns property not needed as evidence to the proper authority.
Written procedures cover the return of such property.
Altered

p

up

'J

following

is

Before confiscating religious items, the
contacts a religious authority.

and using

0

0

12;;]

0

0

12;;]

0

0

ore or designated investigator
I\i1

n

n

A memo from Warden dated
10/05/09 states that religious
;,

";,,

unless they are considered
, in an
Staff follows written procedures when destroying hard contraband that is
illegal.

12;;]

0

0

12;;]

0

0

Hard contraband that is illegal (under criminal statutes) may be.
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.

o DEFICIENT

12;;] ACCEPTABLE

OAT-RISK

o REPEAT FINDING

REMARKS:

b6,b7c

IIO-l

b6,b7c

AUDITOR'SSIGNATURE/D

¥

b6,b7c

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 46 of75

,

DETENTION FILES
POLICY: EVERY FACIUTY WILL CREATE A DETENTION FILE FOR EVERY ICE DETAINEE BOOKED INTO THE FACIUTY, EXCLUDING ONLY

"'TAINEES SCHEDULED TO DEPART WITHIN 24 HOURS. THE DETENTION FILE WILL CONTAIN COPIES AND, IN SOME CASES, THE ORIGINAL OF
DOCUMENTS CONCERNING THE DETAINEE'S STAY IN THE FACIUTY: CLASSIFICATION SHEET, MEDICAL QUESTIONNAIRE, PROPERTY
SHEET m<f'TPT TNARV
,ETC.
e
YES
No NA
A detention file is created for every new arrival whose stay will exceed
[21
0
0
24 hours.
either originals or copies of
The detainee detention file

documentation and forms

0

[21

I during the admissions

0

The detainee's detention file also contains documents generated during
the detainee's custody.
• Special requests
• AnyG-589s and/or 1-77s closed-out during the detainee's stay
• Disciplinary forms/Segregation forms
• Grievances, complaints, and the disposition(s) ofsarne

0

[21

0

,files
There were a total of 26
reviewed with the following
documentation noted: Classification
Form, Booking Report, WTDC Release
Report Form, Intake Orientation Check
List, Property List Form, Request Forms,
Law Library Sign-in Log, Health Care
Intake
Record, Disciplinary Hearing
Notification Form, Monetary Restitution
Form, Incident Reports, Detainee
statements, Fingerprint Card, Religious
Meal Request and Detainee's intake
nie.hIre

The detention files are located and maintained in a secure area. If not,
the cabinets are lockable and distribution of the keys is limited to

file remains active during the detainee's stay. When the
is released from the fucility, staff adds copies of completed
documents, the original closed-out receipts for property and
the ongmw 1-385 or
and other documentation.
The officer closing the detention file makes a notation that the file is
, and ready to be archived.
Staff makes copies and sends documents from the file when properly
requested by supervisory personnel at the receiving facility or office.

[21

0

0

[21

0

0

IZI

0

0

[21

0

0

[21

0

0

The detention files are maintained in the
Records Office in the secured
Administrative area of the facility_

.The

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

[21 aLL

[J

"'LE

IJ

]

A

n

[J

REMARKS:

1 0-15-09
AUDITOR'S SIGNATUR
b6,b7c

b6,b7c

b6,b7c

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 47 of75

--

DISCIPLINARY POLICY
POLICY: ALL FACILITIES HOUSING ICE DETAINEES ARE AUTHORIZED TO IMPOSE DISCIPLINE ON DETAINEES WHOSE BEHAVIOR IS NOT IN
COMPLIANCE WITH FACILITY RULES AND REGULATIONS.
No
NA
YES
The fucility has a written disciplinary system nsing progressive levels of
D
D
~

reviews and

The facility rules state that disciplinary action shall not be capricions or

~

D

D

Written rules prohibit staff from imposing or permitting the following

sanctions:

•
•
•
•
•
•
•

corporal punishment

deviations from normal food service

Facility policy for Detainee
Rights specifically addresses this
component.

~

D

D

,verh.llvand in »,,;';no.
writing and
I to all
The following items are conspicuously posted in Spanish and English, and
other dominate languages used in the facility:
• Rights and Responsibilities
• Prohibited Acts
• Disciplinary Severity Scale

k>oJ

U

U

~

D

D

When minor rule violations or prohibited acts occur, informal resolutions

~

D

D

~

D

D

~

D

D

~

[J

[J

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

clothing deprivation
bedding deprivation
denial of personal hygiene items
loss of correspondence privileges
A, ,;. ,';, Lof
exerCIse

'O"J "0'

~

the

Information is stated in the
handbook and is posted in
housing areas.

•

are
reports and Notice of Charges are promptly forwarded to the

supervisor.

I

i
,

Incident reports are investigated within 24 hours of the incident. The Unit
Disciplinary Committee (UDC) or equivalent does not convene before an
ends.
; is used to,
An
A disciplinary panel (or equivalent in raSAs) adjudicates infractions. The
panel:
• Conducts hearings on all charges and allegations referred by the
UDC;
• Considers written reports, statements, physical evidence, and oral

•
•
•

The Major reviews all incident
reports.

testimony;
Hears pleadings by detainees and staff representatives;
Bases its findings on the preponderance of evidence; and
; only authorized sanctions

A staff representative is available if requested for a detainee fucing a
y

The ,. ~i1ity pennits

I~~

postponements or continuances when

: such a Mn';n"O",
Reasons are documented.
The duration of punishment set by the OIC, as recommended by the
disciplinary panel, does not exceed established sanctions. The maximum
is limited to 60 days for a single offense.
time i n '
Written procedures govern the handling of confidential-informant
infonnation. Standards include criteria for recognizing "substantial
e'
,
E o r m s -" ",' to the incident, ~"
I and
I as ren,,;,
are

Is::! ACCEPTABLE

committee/panel reports,
.~

DDEFICIENT

D AT-RISK

D REPEAT FINDING

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 48 of75

REMARKS:

.O

b6,b7c

110-15-09

b6,b7c

AUDITOR'S SIGNATUR
b6,b7c

•

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 49 of75

EMERGENCY (CONTINGENCY) PLANS

C

POLICY ALL FACILlTIES HOWING ICE DETAINEES WILL RESPOND TO EMERGENCIES WllHAPREDEfERMINED STANDARDIZED PLAN TO MINIMIZE
U ,;
IIMANIWC
IfrTlON OF PROPERTY. IT IS RECOMMENDED THAT SPCS ANDCDFS ENTER lNTO AGREEMENT, VlA
..,
IOF
\N1UU), WITH FFnFR AI LOCAL AND STATE AGENCIES TO ASSIST IN TIMES OF EMERGENCY.
YES
No
NA
V ..M.Ut<O
Policy
detainees or detainee groups from exercising control or
D
D
IZI
authority over other detainees.
Detainees are protected from:
• Personal abuse
• Corporal punishment
• Personal injury
• Disease
• Property damage
. n-o", other detainees
•
Staff is trained to identifY signs of detainee unrest.
• What type of training and how often?

IZI

Staff effectively disseminates UUVHuauvu on fucility climate, detainee
and moods to the Officer In Charge (OIC)
There is a designated person or persons responsible for emergency plans and
their implementation. Sufficient time is allotted to the person or group for
".
t and
of the plans.
The plans address the following issues:
• Confidentiality
• Accountability (copies and storage locations)
• Annual review procedures and schedule

•

D

D

IZI

D

D

IZI

D

D

IZI

D

D

IZI

D

D

IZI

D

D

IZI

D

D

IZI

D

D

IZI

D

D

IZI

D

D

IZI

D

D

IZI

D

D

Training is provided during
employee orientation and again
during annual in-service
Briefings are conducted daily.
The Security Chiefis
responsible for emergency plans
per racif

Revisions

general section with procedures
"J p
include a
,to most
The facility has cooperative contingency plans with applicable:
• Local law enfurcement agencies
• State agencies
• Federal
All staff receives copies of Hostage Situation Management policy and

Staff is trained on Hostage
policy during'
.

Staff is trained to disregard instructions from hostages, regardless of rank.
Within 24 hours after release, hostages are screened for medical and

I effects.
"J plans include
.~ 6' "J medical treattnent for staff and
; during and after an
Food service maintains at least 3 days' worth of emergency meals for staff
and detainees.
Written plans'
.•, locations of shut-off valves and switches for all utilities
(water, gas,

•

A 15-day supply offood is
maintained at the facility.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 50 of75

EMERGENCY (CONTlNGENCY) PLANS
POLICY ALLFACILITIES HOLDING ICE DETAINEES WILL RESPOND TO EMERGENCIES WITHAPREDETERMINED STANDARDIZED PLAN TO MINIMIZE
rHIiH,®.!INIG C)HIUlI~AN LIFE AND THE DESTRUCTION OF PROPERTY. IT IS RECOMMENDED THAT SPCS AND CDFs ENTER INTO AGREEMENT, VIA

Written procedures cover:
• WorkIFood Strike
• Disturbances
• Escapes
• Bomb Tbreats
• Adverse Weather
• !otemal Searches
• Facility Evacuation
• Detainee Transportation System Plan
• !otemal Hostages
• Civil Disturbances

D

D

AT-RISK

REMARKS:

b6,b7c

b6,b7c

110-15-09

AUDITOR'S SIGNATURE f
b6,b7c

•

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 51 of75

ENVIRONMENTAL HEALTH AND SAFETY
POLICY: EVERY FACILITY WILL CONTROL FLAMMABLE, TOXIC, AND CAUSTIC MATERIALS THROUGH AHAZARDOUSMATERIALSPROGRAM. THE
WILL INCLUDE, AMONG OTHER THINGS, THE IDENTIFICATION AND LABELING OF HAZARDOUS MATERIALS IN ACCORDANCE WITH
lpPTU
,r STANDARDS (E.G., NATIONAL FIRE PROTECTION ASSOCIATION [NFPA]); IDENTIFICATION OF INCOMPATIBLE MATERIALS, AND
r INn PROCEDURES
R,
YES
NA
NO
The mcuny nas a system for storing, issuing, "nri
hazardous materials.

: are
fur all
toxic, and caustic
''1 in each QPc';on ,f'h, facility.
The manufacturer's Material Safety Data Sheet (MSDS) file is up-to-date
<1o

12;;]

D

D

12;;]

D

D

12;;]

D

D

[2;]

D

U

12;;]

D

D

for every hazardous substance used.

•
•
All

The files list all storage areas, and include a plant diagram and
legend.
The MSDSs and other information in the files are available to
the facility's safety'
using

toxic, and/or caustic substances follow the

~~::ective

¥

•
•

Wear personal
equipment; and
loffic;"l.
Report hazards and spills to the
The MSDSs are readily accessible to staff and detainees in work areas.

MSDS Sheets were reviewed and
fuund to be up-to-date in all

areas.
Hazardous materials are always issued under proper supervision.

•
•

I

• Alit used

Quantities are limited; and
: using these
Staff llIways
' and "combustible" materials (liquid and aerosol) are stored
.

~

to label recommendations.

12;;]

D

D

12;;]

D

D

12;;]

D

D

Ij"hting fixtures and electrical equipment installed in storage rooms and
other hazardous areas meet National Electrical Code requirements.

Issue logs were reviewed and
found to be accurate.

A Fire Chief report dated 6-1909 indicated NEC requirements
are met.

The facility has

and provides and ensures clean air

12;;]

D

D

ducts are not blocked or obstructed

12;;]

D

D

Living units are maintained at appropriate temperatures in accordance with
industry standards. (68 to 74 degrees in the winter and 72 to 78 degrees in
the
.)

12;;]

D

D

with the temperature ranges from
68-78
Water temperature logs reflected

12;;]

D

D

water temperatures ranged from

~,.

oh

: all
Vents return vents, and air
.
in~s or .
,,"
in the facility.

Shower and sink water temperatures do not exceed the industry standard of
120 degrees.

Temperature logs were reviewed

101-105
All toxic and caustic materials are stored in their original containers in a

secure area.
Excess flammables,
and in

,h oo,;hlpQ

and toxic liquids are disposed of

,withM~n~,

Staff directly supervise and account for products with methyl alcohol. Staff
receives a list ofproducts containing diluted methyl alcohol, e.g., shoe dye.
All such products are clearly labeled. "Accountability" includes issuing
; to
in the
workable
such
Every employee and detainee using flammable, toxic, or caustic materials
receives advance training in their use, storage, and disposal.

12;;]

D

D

12;;]

D

D

12;;]

D

D

12;;]

D

D

The cage inventory reflected the
accountability of the methyl
alcohol usage.
Training records reviewed
indicate the staff receives training

during orientation and annual 40
hour

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 52 of75

ENVIRONMENTAL HEALTH AND SAFETY

EVERY FACILITY WILL CONTROL FLAMMABLE, TOXIC, AND CAUSTIC MATERIALS THROUGH AHAZAROOUS MATERIALS PROGRAM. THE
VILL INCLUDE, AMONG OTHER THINGS, THE IDENTIFICATION AND LABELING OF HAZARDOUS MATERIALS IN ACCORDANCE WITH
'PPT T('ART P STANDARDS (E.G., NATIONAL FIRE PROTECTION ASSOCIATION [NFPA]); IDENTIFICATION OF INCOMPATIBLE MATERIALS, AND
UN"

POLICY:

YES

The fucility complies with the most current edition of applicable codes,
standards, and regulations ofthe National Fire Protection Association and
the Occupational Safety and Health Administration (OSHA).

D

; files
The
LlInce'
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 plans with accessible building/room
floor plans;
• Exit signs and directional arrows; and
• An area-specific exit diagram conspicuously posted in the
area.
Fire drills are conducted and documented monthly.

D

[g]

D

D

[g]

[J

[J

[g]

D

D

[g]

D

D

[g]

D

D

[g]

D

D

has the facilities and equipment necessary to meet

[g]

D

D

' are,
I in the
regulate the handling and disposal of used needles and

[g]

[J

[J

[g]

D

D

'risks are inventoried and a
All items representing potential
"J
individual checks this i
Standard cleaning practices include:
• Using specified equipment; cleansers; disinfectants and
detergents.
and ~~TT"
An,
:or
•
The fucility follows standard cleaning procedures,

[g]

D

D

[g]

D

D

[g]

D

D

Spill kits are readily available.

[g]

D

D

[g]

D

D

A sanitation program covers barbering operations.
The barber
sanitation

s~op

The

~;~~;v;~~rp

,h;,

.:!~:.nsed medical waste contractor disposes of infectiouslbio-hazardous

Dv . . muo

NA

A technically qualified officer conducts the fire and safety inspections.

I

!

[g]

No

The Safety Officer maintains
NFPA and OSHA manuals and
the 6-15-09 Fire Chief report
indicates the facility is following
applicable codes and standards.
The fucility safety officer has
completed necessary Fireman
Basic and I-II training, as well as,
Incident Command System
Training and Hazardous Material

The plan was approved by the
local Fire ChiefJune 15, 2009.
Monthly Fire Inspection reports
were reviewed and fuund to be
comprehensive. Emergency plans
are posted appropriately
throughout the facility in English
and Spanish. Exit signs with
appropriate exit arrows are
visible.
Monthly simulated fire drills of
all fucility areas are conducted.
Fire drill reports were reviewed.

The fucility has a contract with
the Stericycle Company dated 924-09, for

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 53 of75

ENVIRONMENTAL HEALTH AND SAFETY
POLICY: EVERY FACILITY WILL CONTROL FLAMMABLE, TOXIC, AND CAUSTIC MATERIALS THROUGH AHAZARDOUS MATERIALS PROGRAM. THE
,,,,,,u,,,,,A';M,,, WILL INCLUDE, AMONG OTHER THINGS, THE IDENTIFICATION AND LABELING OF HAZARDOUS MATERIALS IN ACCORDANCE WITH
'nn, 'Nm v STANDARDS (E.G., NATIONAL FIRE PROTECTION ASSOCIATION [NFPA]); IDENTIFICATION OF INCOMPATIBLE MATERIALS, AND
I IN"

UK""

. contact with blood and other body fluids and
Staff is trained to "
written
,are
Do the
for handling/disposing of refuse meet all regulatory

YES

No

NA

Is:!

D

D

Is:!

D

D

Is:!

D

D

A licensed/Certified/Trained pest-control professional inspects forrodents,
insects, and vermin.

•
•

At least monthly.
The pest-control program includes preventative spraying for
insects.

Management Services, Inc.

The 2008 Hudspeth County

Drinking water and wastewater is routinely tested according to a fixed

D

schedule.

D

I

Emergency power generators are 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

Is:! ACCEPTABLE

DDEFICIENT

D AT-RISK

Monthly inspections are
completed by the Carter Pest

Water Inspection report was

."

The emergency power generator

D

D

is tested weekly with a full load
test monthly.
D REPEAT FINDING

_EMARKS:
b6,b7c

110-15-09
AUDITOR'SSIGNATURE/DA
b6,b7c

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 54 of75

HOLD ROOMS IN DETENTION FACILITIES
PoLICY: HOLD ROOMS WILL BE USED ONLY FOR TEMPORARY DETENTION OF DETAINEES AWAITING REMOVAL, TRANSFER, EOIRHEARINGS,
TREATMENT INTRA-FACILITY MOVEMENT
INTO OR OUT OF THE FACILITY.

switches

D

D

D

D

D

lSI

The
not accept
detainees under the age of18.

or audible range to allow
basis.

lSI

D

D

all

a pat down search for weapons or contraband

lSI

D

D

lSI

D

D

lSI

D

D

lSI

D

D

lSI

D

D

Detainees nnder the age of 18 are not held with adult detainees.

are

basic

water,

are available in

direct

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

lSI ACCEPTABLE

DDEFICIENT

D

AT-RISK

D REPEATFINIHNG

REMARKS:

b6,b7c
b6,b7c

!10-15-09

AUIHTOR'S SIGNATURE! DATE

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 55 of75

,
,

I,

i

i

CL.

KEY AND LOCK CONTROL
(SECURITY, ACCOUNTABILITY AND MAINTENANCE)
IS THE POLICY OFTHEICE SERVICE TO MAINTAIN AN EFFICIENT SYSTEM FOR THE USE, ACCOUNTABILITY ANDMAlNfENANCEOF ALL

ANnrnrK'.

YES

No

NA

D

I2J

D

in IOSAs. has responsibly fur all
The security officer, or ""1.~
.
. ~ to keys, locks etc.
administrative duties and
The security officer, or equivalent in IOSAs, provides training to employees
in key control.
The security officer, or equivalent in IGSAs, maintains inventories of all
keys, locks and locking devices.

I2J

D

D

I2J

D

D

I2J

D

D

The security officer follows a preventive maintenance program and
documentation.
maintains all
; the issue OI ,
I keys
' and
and locks.
The security officer, or equivalent in IOSAs, develops policy and
procedures to ensure safe combinations integrity.

I2J

D

D

IX!

n

n

The security officer[ s1, or equivalent in IOSAs, has attended an approved
locksmith training program.

~ a~HHl

I in
: areas.
I bolt or dead lock
I locks (as specified in the Detention Standard) are used in
: areas.
; are
Grand master keying
I wom or,
I keys and locks are cut up and
lof

Only;

; are
I from use on cell doors.
The entrance/exit door locks to detainee living quarters, or areas with an
occupant load of 50 or more people, conform to:
• Occupational Safety and Environmental Health Manual, Ch. 3;
• National Fire Protection Association Life Safety Code 101.
_,
is sufficient to accommodate all the facility key
~ keys in use, and is located in a secure area.
Procedures are in place to ensure that key rings are:
• Identifiable;
• The numbers of keys are cited; and
• Keys cannot be removed.
: for all areas of the fucility.
I keys are

~~;s,

The

; use a

'system,.
Ito issue any
1 is
Ikey~
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.
•

D

D

I2J
I2J

[

[

D

D

L

[

L

L

I2J

D

D

I2J

D

D

I2J

D

D

[8J

D

Facility policy requires that safe
combinations be changed every
twelve months. Combinations
were last changed in April 2009.

b2High

I2J

hOJ

The fucility has a key accountability policy and procedures to ensure key
accountability. The keys are physically counted daily.

•

I2J

The Key Control Officer is
currently taking an on-line
locksmith course.

D

b2High

I2J

D

D

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 56 of75

KEY AND LOCK CONTROL
(SECURITY, ACCOUNTABILITY AND MAINTENANCE)
I' IS THE POLICY OFTHE ICE SERVICE TO MAINTAIN AN EffiCIENT SYSTEM FOR THE USE, ACCOUNTABILITY AND MAINTENANCE OF ALL I
ANIJLQCKS.
RI
YES
No
NA
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.
D
D
1:21
• When a key or key ring is lost, misplaced, or not accounted for,
the shift supervisor is immediately notified .
to staff.
• Detainees are not . " '~to handle keys ,

D DEFICIENT

1:21 ACCEPTABLE

D

AT-RISK

D REPEAT FINDING

REMARKS:
The rncility does not have a locksmith; however, the Key Control Officer is currently emolled in an on-line locksmith training program.
One set of gun lockers is located in a public access area monitored by security cameras. Recommendation is that a cage be built to secure
lockers from access by general public. Other gun lockers are provided in areas with no public access.

b6,b7c

/ 10-15-09

SIGNATU

b6,b7c
b6,b7c

~

•

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 57 of75

crT

POPULATION COUNTS

POLICY: ALL DETENTION FACILITIES SHALL ENSURE AROUND-THE-CLOCK ACCOUNTABILITY FOR ALL DETAINEES. THIS REQUIRES TlIATTHEY
AT LEAST ONE FORMAL COUNT OF THE DETAINEE POPULATION PER SHIFT, WITH ADDITIONAL FORMAL AND INFORMAL COUNTS
"~Y.

YES

Staff,

• a fonnal count at least once each shift.
, cease or are strictly controlled while a formal count is being

Certain
, cease during formal counts.
. I of a formal count.
All
t ceases for the
Formal counts in all units take place
, in counts is
A face-to-photo count follows each unsuccessful recount.
Officers positively identifY each detainee before counting him/her as
nre<ent
W

n:en PThey are

~~~::'rl during' ana,

'~~ur:is :~ms.

The control officer (or other
an out -count
record of all detainees
lly leavi;'g the facility.
[ is
I in each
: folder.
-'Ihis

~ ACCEPTABLE

I

DDEFICIENT

D

D

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

AT-RISK

RRMA"K~

NA

~

[X]
D

No

Formal counts are done 6 times
per day.

Facility policy addresses this

[
D REPEAT FINDING

REMARKS:

•

popUlation count was observed and was found to be conducted in a manner that is in compliance with the NDS and Facility Policy.
Population counts are conducted eight times daily with "Roster Counts ll Decuning at the beginning of each shift.

b6,b7c

/ lO~

b6,b7c

~

AUDITOR'S SIGNATURE /
b6,b7c

•

,

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 58 of75

POST ORDERS

-==R',

POLICY: ICE PROVIDES OFFICERS ALL NECESSARY GUIDANCE FOR CARRYING our THEIR DUTIES. THIS GUIDANCE INCLUDES TIIEPOSTORDERS
rPAOTANNm,,, ,AND GIVEN'
WHICHAREI
YES
NO
NA

,Hr''''"

Every fixed post has a set of po" nrn~~.
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.

~

LJ

LJ

[2J

D

D

[2J

D

D

,set (c~n'rnl file) of post orders.
The rGSA
'a
, to all staff.
The central file is
The OlC or Contract I rGSA equivalent initiates/authorizes all post-order

[2J
[2J
[2J

[J
[J
D

[J
[J
D

The OlC or Contract I rGSA equivalent has signed and dated the last page
of every section.
A ,~,;c'
of post orders occurs regularly and at a

[2J

D

D

IX!

n

n

[2J

D

D

[2J

D
[J
[J
D

D
[J
[J
D

Procedures keep post orders and logbooks secure fi'om detainees at all

times.
Every anned-post officer qualifies with the post weapon(s) before assuming
post duty.
A
, for escape
t post orders •
: units track the event •
The post orders for
Housing-unit post officers record all
. activity in a log. The post
: the ',"h ;"
order includes instructions on

D DEFICIENT

[2J ACCEPTABLE

D

[2J
[2J
[2J
AT-RISK

Per rncility policy, the Chief of
Security (Major) is responsible
for post orders.

D REPEAT FINDING

REMARKS:

b6,b7c

,

b6,b7c

~
(S

AUDITOR'SSIGNATURE/
b6,b7c

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 59 of75

SECUltlTYINSPECTlONS
POLICY: POST ASSIGNMENTS IN THE FACILITY'S HIGH-RISK AREAS, WHERE SPECIAL SECURITY PROCEDURES MUST BE FOLLOWED, WILL BE
EXPERIENCED
The fucility has a

LITY,

WIT" A

YES

No

NA

~

0

0

~

0

0

~

0

0

security inspection policy. The policy

"P

specifies:

•
•
•
•
•

Posts to be inspected;

Required inspection forms;
Frequency of inspections;

Facility policy describes the
security inspection process.

Guidelines fur checking security features; and

Procedures for reporting weak spots, inconsistencies, and other
areas

Every officer is rpnHirp,j to
area. The results are

a security check of his/her assigned

Documentation of security inspections is kept on file.

Security inspection
documentation is maintained by

the Administrative
action are

lto the

The front-entrance officer checks the ill of everyone entering or exiting the
facility.
All visits are officially recorded in a visitor logbook or electronically
recorded.
The mCllity nas a secure visitor pass system.
. .
Everyrnntrnl Center officer.
The Control Center is staffud around the clock.
, sm1 r access to the rnntrol Center.
; are
I from access to the Control Center.
; are
I in the Control Center.
rail'
traffic
~ and leaving the fucility.

i2'J

U

U

~

0

0

~

0

0

~

0

0

~

]

~

0

0

~

0

0

0

~

0

~

0

0

I2>J

I:8J

[
[

~

0

Visits are recorded in a visitor
: by the entry officer.

~

The facility maintains a log of all incoming and departing vehicles to
sensitive areas of the facility. Each entry contains:

•
•
•
•
•
•
•

I
I
i

The driver's name;
Company represented;

Vehicle contents;
Delivery date and time;

Date and time out;

Vehicle license number; and
for the vehicle during the visit
Name of'
I search each vehicle,
vrneers
~ and leaving the fucility.
The fucility has a written policy and 1'''
to prevent the introduction

ofcontrabandintothefa~ilityor

.~,

Tools being taken into the secure area of the fucility are inventoried before
and prior to
The SMU entrance has a sally port.
Written procedures govern searches of detainee housing units and personal
areas.

. times.
,occur at.
: area
Every search of the SMU and other h 0;' : units is
and supply rooms, walls, light and plumbing fixtures, accesses, and
etc.,. undergo frequent, irregular searches. These searches are

C

0

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 60 of75

b2High

SECURITY INSPECTIONS
POLICY: POST ASSIGNMENTS IN THE FACILITY'S HIGH-RISK AREAS, WHERE SPECIAL SECURITY PROCEDURES MUST BE FOLWWED, WILL BE
TO EXPERIENCED PERSONNEL WITH A THOROUGH GROUNDING IN FACILITY OPERATIONS.

Walls, fences, and exits, including exterior windows, are inspected for
defects once each shift.
Daily procedures include:
• Perimeter alatm system tests;
• Physical checks of the perimeter fence; and
the results.
1 areas receive ITP""en'

•

o

~ ACCEPTABLE

DEFICIENT

YES

No

NA

~

0

0

~

0

0

~

LJ

LJ

OAT-RISK

1> "". .",,0

b2High

o

REPEAT FINDING

REMARKS:

Interviews with staff and a review of logbooks verifY that this standard is in compliance. The facility

.

b6,b7c

b2High

b2High

/10-15-09

b6,b7c

AUDITOR'S SIGNATURE I
b6,b7c

•

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 61 of75

however,

SPECIAL MANAGEMENT UNIT (SMU)
(ADMINISTRATIVE SEGREGATION)
UNIT REQUIRED IN EVERY FACILITY ISOLATES CERTAIN DETAJNEES FROM THE GENERAL POPULATION.
,. UNIT WILL CONSIST OFTWO SECTIONS. ONE, ADMINISTRATIVE SEGREGATION,HOUSES DETAINEES ISOLATED FOR
THEIR OWN PROTECTION; THE OTHER FOR DETAINEES BEING DISCIPLINED FOR WRONGDOING (SEE THE "SPECIAL MANAGEMENT UNIT
IALMI

:1

fTNARV

("

YES

No

NA

[gJ

0

0

[gJ

0

0

[gJ

0

0

[gJ

0

0

[gJ

0

0

[gJ

0

0

[gJ

0

0

conclusions and recommendations of any review conducted after the
detainee have remained in administrative segregation for seven
consecutive days.

[gJ

0

0

enjoy the same general privileges as
Administratively
detainees in the general
The SMU is:
• Well ventilated;
• Adequately lighted;
• Appropriately heated; and
lina
•
All cells are
.
with beds.
•
"very oed is
fastened to the floor or wall .

[gJ

0

0

[gJ

0

0

[gJ

0

0

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 accordaace

administrative detention.
A

I

I

,

,

.,.

.

,,;t~'·,

..."

70

~

,f't~

tin the SMU,

A supervisory officer conducts another review after the detainee has spent
seven days in administrative segregation, and:

•

•
•
•

I

,

Facility policy addresses this
component.

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.
regularly reviews the status of detainees in
The OIC (or

I

I
I

Un,

Every week thereafter for the first month; and
Every 30 days after the first month,

Does each review include an interview with the detainee?
Is a written record made ofthe

l

and the'

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

•
•

A written record is made of the decision and the justification.
The,
record.
; a·

has exceeded 60 days, the FD forwards written notice to HQ
Field
; Branch Chieffor DRO,
The OIC or equivalent) reviews the case of every detainee who objects to
administrative segregation after 30 days in the SMU.

The detainee is given the right to appeal to the OIC (or

•

The Administrative Captain
conducts the 7 day reviews.

' the

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 62 of75

,

SPECIAL MANAGEMENT UNIT (SMU)
(ADMINISTRATIVE SEGREGATION)
THE SPECIAL MANAGEMENT UNIT REQlflRED IN EVERY FACILITY ISOLATES CERTAIN DETAINEES FROM THE GENERAL POPULATION.
SPECIAL MANAGEMENT UNIT WILL CONSIST OF TWO SECTIONS. ONE, ADMINISTRATIVE SEGREGATION,HOUSES DETAINEES ISOLATED FOR
THEIR OWN PROTECTION; THE OTHER FOR DETAINEES BEING DISCIPLINED FOR WRONGDOING (SEE THE "SPECIAL MANAGEMENT UNIT
~l"STAND"Dn\

'Th'WV

YES

NO

NA

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

~

D

D

~

[J

[J

~

D

D

~

D

D

~

D

D

The number of detainees in any cell does not exceed the occupancy limit.

•

%en occupancy exceeds recommended capacity, do basic living
standards decline?

•
•

Do criteria for objectively assessing living standards exist?
Ifves. are the criteria included in the written
~,.,

The
. and

li~~~v:, me same ; ;~ the general

Only I detainee is housed in each
cell.

Detainees receive three nutritious meals per day, from~ general
population's menu ofthe day.

•

Do detainees eat only with disposable utensils?
'~C~,J

food as punislunent.

J

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.

•

Facility policy prohibits using

-.~,.

Ifno!.
The detainees are provided:

•
•

Barbering services;

•
•
•

Non-legal reading material;

•
•

Telephone access similar to that of the general popUlation; and

Recreation privileges in accordance with the "Detainee

Recreationl! standard;
Religious material;
The same correspondence privileges as detainees in the general
popUlation;

Personalle!!al material.
A health care professional visits every detainee at least three times a week
• The shift supervisor visits each detainee daily.

•

and

.'

Procedures comply with the "Visitationll standard.
• The detainee retains visiting privileges; and

The visiting room is n"n"n~l; durino normal visiting hours.
Visits from~ are
Detainees have the same law-library access as the general population.
• Are they required to use the law library ~Separately, or
DAs a group?
to them?
• Are legal materials
The SMU
permanent log of detainee-related activity, e.g.,

•

meals served.

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.
• rJ)F, "nrl J(;SA fucilities use Form 1-888 (or local

•

A local form is used for

documentation.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 63 of75

-----------------------------------------------------------------------------SPECIAL MANAGEMENT UNIT (SMU)
(ADMINISTRATIVE SEGREGATION)
THE SPECIAL MANAGEMENT UNIT REQUIRED IN EVERY FACILITY ISOLATES CERTAIN DETAINEES FROM THE GENERAL POPULATION.
SPECIAL MANAGEMENT UNIT WILL CONSIST OFTWO SECTIONS. ONE, ADMINISTRATIVE SEGREGATION, HOUSESDETAINEES ISOLATED FOR
THEIR OWN PROTECTION; THE OTHER FOR DETAINEES BEING DISCIPLINED FOR WRONGDOING (SEE THE "SPECIAL MANAGEMENT UNIT
lUI
'WARV
N]"STPJnART)\'

(
Staff record
the detainee ate, showered, exercised, and took any
applicable medication during every shift.
•
Staff logs record all pertinent information, e.g., a medical
condition, suicidaVassaultive behavior, etc;
• The medical officer/health care professional signs each
individual's record during each visit; and
• The housing officer initials the record when all detainee services
are
or at the end of the shift.
each week the
is in
A new record is created
Segregation.
Tn

pH

"",

;" .h ,

return to the general'

I2<J ACCEPTABLE

o

~MTT

,

YES

,;1 'h

DEFICIENT

OAT-RISK

No

NA

o

o

o

o

o

RI<M A''',.

REPEATFINDlNG

REMARKS:

.UD

b6,b7c

b6,b7c

/ 10-15-09

NAT

b6,b7c

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 64 of75

SPECIAL MANAGEMENT UNIT
(DISCIPLINARY SEGREGATION)
~LICY: EACH FACILITY WILL ESTABLISH A SPECIAL MANAGEMENT UNIT IN WHICH TO ISOLATE CERTAIN DETAINEES FROM THE GENERAL

,",ATION. THE SPECIAL MANAGEMENT UNIT WILL HAVE TWO SECTIONS, ONE FOR DETAINEES IN ADMINISTRATIVE SEGREGATION; THE

OTHER FOR nFT AINPP< BEING SEGREGATED FOR DISCIPLINARY REASONS.
YES

Officers placing detainees in disciplinary segregation follow written
procedures.

~~~ays.

for violations committed during one incident are limited to

A completed Disciplinary Segregation Order accompanies the detainee
into the SMU.
• The detainee receives a copy of the order within 24 hours of
tin, .
y,
hnno.A

;~t'

i

include

DV~'DV.

NA

C2I

0

0

C2I

0

0

C2I

0

0

161

LJ

LJ

C2I

0

0

C2I

0

0

C2I

0

0

C2I

0

0

C2I

0

0

C2I

0

0

C2I

0

0

C2I

0

0

C2I

0

0

C2I

0

0

C2I

0

0

Facility Policy provides staff
direction in the placement of

detainees in discip linary

'_:' the cases of individual detainees
, ot <et

•

After each fannal review, the detainee receives a written copy of
reasons.
the decision and su
The conditions of confinement in the SMU are proportional to the amoUUlt
,to protect detainees and staff.
of control
segregation have fewer privileges than those
housed in in ~;,
Living conditions in disciplinary SMUs remain the same regardless of
behavior.
• Ifno, does staff prepare written documentation for this action?
Does the OlC sign to •
in
".J segregation
the same humane

~

The quarters used for segregation are:
• Well-ventilated.
• Adequately lighted.
• Appropriately heated.
• Maintained in a sanitary condition.
with beds that are securely listened to the floor or
All cells are
wall of the cell.
The number of detainees confined to each cell or room is limited to the
number for which the space was designate.
excess
ona
oasIS,
• Does the OlC
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.
in the SMU have the same opportunities to exchange clothing,
, etc., as other detainees.
Detainees in the SMU receive three nutritious meals per day, selected
from the Food Service's menu of the day.
• Food is not used as
are
I. to shower
: the

t~

•

No

'::;el::~!~~

;::ua.

Detainees are provided with a
paper gown.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 65 of75

SPECIAL MANAGEMENT UNIT
(DISCIPLINARY SEGREGATION)
'OLlCY, EACH FACILITY WILL ESTABLISH A SPECIAL MANAGEMENT UNIT IN WHICH TO ISOLATE CERTAIN DETAINEES FROM THE GENERAL

orr \TIO~. THE SPECIAL MANAGEMENT UNIT WILL HAVE TWO SECTIONS, ONE FOR DETAINEES IN ADMINISTRATIVE SEGREGATION; THE
OTHER FOR DETAINEES BEING SEGREGATED FOR DISCIPLINARY REASONS.

Detainees receive, unless documented as a threat to security;
• Barbering services;
• Recreation privileges;

•
•
•
•

Other-than-legal reading material;
Religious material;

YES_

No

~

lSI

0

0

lSI

0

0

lSI

0

0

lSI

0

0

RF.M"RKS

The same correspondence privileges as other detainees; and
Personal leKal material.

When phone access is limited by number or type of calls, the following

areas are exempt:

•

Calls about the detainee's immigration case or other legal
matters;

,'"

•

,A

Calls during family emergencies (as determined by the
UIL

1visits v'"'y
A health. :'
every week day.
• The shift supervisor visits each segregated detainee daily
• Weekends and 'Ac
are allow~rl visitors, in accordance with the I!Visitation U
SMU
SMU

receive legal visits, as provided in the "Visitation"

•

Legal service providers are notified of security concerns arising

lSI

0

0

before a visit.
Visits from clergy are allowed.
• The clergy member is given the option of visiting/not visiting the
segregated detainee.

lSI

0

0

lSI

0

0

lSI

0

0

lSI

0

0

•

Health care professionals visit
three times per shift.

Violent/uncooperative detainees are denied access to religious
,,;,

SMU detainees

.;, would otherwise be
; when sarety and
, law library access.

•

Violent/uncooperative detainees retain access to the law library

•

unless adjudicated a security threat in writing.
Legal material brought to individuals in the SMU on a case-by-

case basis.

•
All

Staff documents every incident of denied access to the law
hbrary.

are documented, e.g. meals served,

. etc.
The SPC's, the Special Management Housing Unit Record (I-888or
equivalent), is prepared as soon as the detainee is placed in the SMU.
• All 1-888s are filled out by the end of each shift.
• The CDFIIGSA facility use Form.
local form).
• 1-888 (Of<

•

A local form is used for

documentation.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 66 of75

SPECIAL MANAGEMENT UNIT
(DISCIPLINARY SEGREGATION)
~L1CY: EACH FACILITY WILL ESTABLISH A SPECIAL MANAGEMENT UNIT IN WHICH TO ISOLATE CERTAIN DETAINEES FROM THE GENERAL

OTHER FOR n

THE SPECIAL MANAGEMENT UNIT WILL HAVE TWO SECTIONS, ONE FOR DETAINEES IN ADMINISTRATIVE SEGREGATION; THE
BEING SEGREGATED FOR DISCIPLINARY REASONS.

YES

SMU staff record whether the detainee ate, showered, exercised, took
medication, etc.
• Details about the detainee logged, e.g., a medical condition,
suicidal/violent behavior, etc.
•
The health care official sign individual records after 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 weekly for each detainee in the SMU.
•
The SMU retains these records nntil the detainee leaves the

No

NA

o

o

SMU.

IYI.

il

n»

nREPEAT

REMARKS:

b6,b7c
b6,b7c

b6,b7c

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 67 of75

'"

I

I
I

,

TOOL CONTROL
POLICY: IT IS THE POLICY OF ALLFACILITIES THAT ALL EMPLOYEES SHALL BE RESPONSIBLE FORCOMPLYING WIT1ITHETOOLCONIROL POLICY.
THE MAINTENANCE SUPERVISOR SHALL MAINTAIN A COMPUTER GENERATED OR TYPEWRITTEN MASTER INVENTORY LIST OF TOOLS AND
,=w 'I fWATION IN WHICH TOOLS ARE STORED. THESE INVENTORIES SHALLBECURRENT,FILED AND READILY AVAIlABLE FOR
ANn
'AtllLlI y DURING AN AUDIT.
TOOL
YES
No
NA
'-UMI
• who is
for
a tool control
There an
D
D
I2l
, syStem to insure,
,and an
~~1-'"' ",,,'" heads are responsible for implementing this standard in their

I2l

D

D

I2l

D

D

I2l

D

D

I2l

D

D

I2l

D

D

I2l

D

D

I2l

D

D

Tool inventories are required for the:

•

Maintenance Department;

•
•
•
•
•

Medial Depattment;
Food Service Department;

Electronics Shop;
Recreation Department; and

u,~ m~u"Yhu"" ~FV "Y w'..

~5·.
l'
f< "Y h . l'
d 11
T e po ICY sets mtnlmum time mes or P YSlca mventory an a
necessary documentation.
; use AMIS bar code labels when re, ,;re,-1.
• ICE
The facility has a tool classification system. Tools are classified according
to:
• Restricted (dangerous/hazardous); and

•

•

N,

1(1

heads are responsible for implementing tool-control

-]-'

Facility Policy reflects the
handling of tools.

e~~ ~::dilY:'

and procedures in place to ensure that all tools are

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
: tool is readily notice.
Each facility has procedures for the issuance oftools to staffand detainees.

The fucility has policies and procedures to address the issue oflost tools.
The policy and procedures include:
• Verbal and written notification;
and
• Procedures for detainee access;
.,for all incidents oflost 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
ICE, or other visitors, submit an inventory of all tools prior to admittance
into or
from the fucility.

D DEFICIENT

I2l ACCEPTABLE

D

I2l

D

I2l

D

D

I2l

D

D

I2l

D

D

AT-RISK

D

All fucility tools are etched for
identification

The facility utilizes a sign-in and
sign-out procedure for issuance
.<,

,I.

D REPEAT FINDING

REMARKS:
b6,b7c

/10-15-09
.UDlTOR'S SIGNATURE / DATE
b6,b7c

y
~

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 68 of75

------

TRANSPORTATION
(LAND TRANSPORTATION)
,rv· THE lMMIGRATION AND NATURALIZATION SERVICE WILL TAKE ALL NECESSARY PRECAUfIONS TO PROTECT THE LIVES, SAFETY, AND
OFFICERS, THE GENERAL PUBLIC, AND THOSE IN ICE CUSTODY DURING THE TRANSPORTATION OF DETAINEES. STANDARDS
HAVE BEEN ESTABLISHED FOR PROFESSIONAL TRANSPORTATION UNDER THE SUPERVISION OF EXPERIENCED AND TRAINED DETENTION
ENFORCEMENT OFFICERS OR AUfHORIZED CONTRACT PERSONNEL.
I
I

~. n~ (W OUR

D STANDARD NA: CHECK THIS BOX IF ALL ICE TRANSPORTATION IS HANDLED ONLY BY THE ICE FIELD OFFICE OR SUB-OFFICE IN
'rAO~

L

10c,I .','e, and fiorIernl mo'or
Transporting officers ~u'."v' y
vehicle laws and" ,,10';0",
wt this finding,
.
Every transporting officer required to drive a commercial size bus has a
valid Commercial Driver's License (CDL) issued by the state of
. I records for each vehicle
Su
Officers use a checklist during every vehicle inspection.
,no
. renor' "~,,. 0; •
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
lO-hour limit.
Two officers with valid CDLs required in any bus transporting detainees.
• When buses travel in tandem with detainees, there are two
qualified officers per vehicle.
driver may
: an empty vehicle.
• An
Before the start of each detail, the vehicle is
I of all
i being
lis
to
boarding
the vehicle by staff
are
searched
immediately
prior
All
~ the bus or vehicle.
The facility ensures that the number of detainees transported does not
exceed the vehicles manufacturer's
level.
,ffi,
I to all
'vests are 1
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.
in place addressing the use of restraining
Policies and procedures
_c
en";nm~'on
.,.
Officers ensure that no one contacts the detainees.
One officer remains in the vehicle at all times when detainees are

•

i

Meals are provided during long distance transfers.
• The meals meet the minimum dietary standards, as identified by
dieticians utilized h ,Trl"

YES

No

NA

~

D

D

~

D

D

IS:]

[J

[J

iL'>J

U

U

~

D

D

~

D

D

~
~

U

LJ

LJ
LJ

~

D

D

~

D

D

~

[J

[J

~

D

D

~

D

D

~

D

D

~

D

D

D~'''DV<

StaffCDL licenses were verified.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 69 of75

TRANSPORTATION
(LAND TRANSPORTATION)

. ~~.~ •• THE IMMIGRATION AND NATURALIZATION SERVICE WILL TAKE ALL NECESSARY PRECAUTIONS TO PROTECT THE LIVES, SAFElY, AND
, ~'D~"~ Of JR ,
_, THE GENERAL PUBLIC, AND THOSE IN ICE CUSTODY DURING THE TRANSPORTATION OF DETAINEES. STANDARDS
HAVE BEEN ESTABLISHED FOR PROFESSIONAL TRANSPORTATION UNDER THE SUPERVISION OF EXPERIENCED AND TRAINED DETENTION
ENFORCEMENT OFFICERS OR AUTHORIZED CONTRACT PERSONNEL.

D STANDARD NA:

CHECK r:::.::.OX IF ALL ICE TRANSPORTATION IS HANDLED ONLY BY THE ICE FIELD OFFICE OR SUB-OFFICE IN

r
The vehicle crew inspects all Food Service pickups before accepting
delivery (food wrapping, portions, quality, quantity, thennos-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
I and
. I on a fix~d
Vehicles have:
• Two-way radios;
• Cellular telephones; and
• Equipment boxes stocked in accordance with the Use of Force
Standard.
, are clean and .
The
' at all times.
Personal property of a detainee transferring to another facility is:
• Inventoried;
• Inspected; and
the detainee.
•
fel10wing 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
list includes women or minors
•
~ ACCEPTABLE

DDEFICIENT

D

YES

No

NA

~

D

D

All food is provided by the
facility and checked by officers
before leaving.

~

D

D

Facility vehicles are equipped
with two-way radios and cellular
phones.

~.

[J

LJ

~

D

D

D

D

AT-RISK

RFM . .' . . .

D REPEAT FINDING

REMARKS:

b6,b7c

I 1O-15..:Q2.

AUDITOR'SSIGNATURE/DAr

•

b6,b7c

V

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 70 of75

I
i

i

USE OF FORCE
POLICY: THE U.S. DEPARTMENT OF HOMELAND SECURITY AUTHORIZES THE USE OF FORCE ONLY AS A LAST ALTERNATIVE AFTER ALL OTHER

EFFORTS TO RESOLVE A SITUATION HAVE FAILED. ONLY THAT AMOUNT OF FORCE NECESSARY TO GAIN CONTROL OF THE
AND ENSURE THE SAFETY OF DETAINEES, STAFF AND OTHERS, TO PREVENT SERIOUS PROPERTYDAMAGEANDTO ENSURE
INSTITUTION SECURITY AND GOOD ORDER MAYBE USED. PHYSICAL RESTRAINTS NECESSARY TO GAIN CONTROL OF ADETAINEE WHO APPEARS
TOBEn.
; MAY BE """"WYED WHEN THE.
:

I

Written policy authorizes staff to respond in an innnediate-use-offorce situation without a
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 policy asserts that calculated rather than
use of
force is feasible in most cases.

The facility:
Procedures.

to the ~

aun

I use UI rurce.
When a detainee must be forcibly moved and/or restrained, and
there is time for a calculated use of force, staff uses the U se-of-

NA

IZI

0

0

IZI

0

0

IZI

0

0

IZI

0

0

IZI

0

0

IZI

0

0

IZI

0

0

Under stal
are trained in the perlormance of the Use-of-Force

IZI

0

0

IZI

0

0

IZI

0

0

IZI

0

0

All use-of-force incidents are documented and reviewed.

•
•
•
•

Do not use force as punishment;
Attempt to gain the detainee's voluntary cooperation
before resorting to force;
Use only as much force as necessary to control the

..

The fucility has a use offorce continuum.

The After Action Review Tearn consisting
of the Warden, Asst Warden, Major and
HSA reviews all use .<.

detainee; and
Use restraints only when other non-confrontational
means, including verbal persuasion, have failed or are
used for
I as
Team follows written
to

-J

by the

Facility policy explains the use offorce

ucanu

Force Team Teclmique.

~:::

No

Confrontation Avoidance

others ;onfer before every'

•

YES

"J

p"

that

to

Medication is not used for restraint

Standard procedures associated with using four-point restraints

include:

•
•
•
•

•
•
•
•

Soft restraints (e.g., vinyl);
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 stiflhess;
Medical evaluation of the restrained detainee twice
per eight-hour shift; and
When qualified medical staff is not immediately
, Stal
the detainee ,,~
,
Dressing

Detainee is kept Wlder constant observation
by an officer. Medical personnel check
detainee hourly.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 71 of75

USE OF FORCE
POLICY: 1lIEU.S. DEPARTMENT OF HOMELAND SECURITY AUTHORIZES THE USEOFFORCEONLY AS A LAST ALTERNATIVE AFTERALLOTHER
'" EFFORTS TO RESOLVE A SITUATION HAVE FAILED. ONLY THAT AMOUNT OF FORCE NECESSARY TO GAIN CONTROL OF THE
., TO PROTECT AND ENSURE THE SAFETY OF DETAINEES, STAFF AND OTHERS, TO PREVENT SERIOUS PROPERTYDAMAGEAND TO ENSURE
INSTITUTION SECURITY AND GOOD ORDER MAYBE USED. PHYSICAL RESTRAINTS NECESSARY TO GAIN CONTROL OF ADETAINEE WHO APPEARS
TO BE DANGEROUS MAY BE EMPLOYED WHEN THE DETAINEE:
D~'''DV<
YES
No
NA
The shift supervisor monitors the detainee's position/condition every
two hours.
~
0
0
• Helshe allows the detainee to use the rest room at
these times under:
: checks are logged.
All
I25J
LJ
LJ
staff contacts medical staff
In
0
0
~
: is un~~;control.
once the
When the OlC authorizes use of non-lethal weapons:
• Medical staff is consulted before staff use pepper
spray/non-lethal weapons.
~
0
0
,
,fF
.
.A;, ,I ~I,
before use of a
I is
Special precautions are taken when restraining pregnant detainees.
are cnn,,, Ite"
• Medical
Protective gear is worn when restraining
w iu, open cuts or
wounds.

Staffdocuments every use offorce andlor non-routine application of
restraints.
It is:

practice to review any use of force and the non-routine
101

~

•

~~~ in self-defense, confrontation-avoidance
and the use offorce to control detainees.
.
Specialized training is given and Officers are certified

in all devices
In SPCs. is the Use of Force fonn is used? In other fucilities
: / CDFs) is this fonn or its
t used?

o DEFICIENT

~ ACCEPTABLE

~

0

0

~

0

0

~

0

0

~

0

0

~

0

0

~

0

0

OAT-RISK

A local form is utilized for

o REPEAT FINDING

REMARKS:
There has been no use of restraints in the past 12 months.
b6,b7c

b6,b7c

AUDITOR'S SIGNATURE
b6,b7c

•

~

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 72 of75

STAFF DETAINEE COMMUNICATIONS
POLlCY: PROCEDURES MUST BE IN PLACE TO ALLOW FOR FORMAL AND INFORMAL CONTACT BETWEEN KEY FACILITY STAFF AND ICE STAFF
PERMIT DETAINEES TO MAKE WRITTEN REQUESTS TO ICE STAFF AND RECEIVE AN ANSWER IN AN ACCEPTABLETIME

C

The ICE Field Office Director ensures that weekly announced and
unannounced visits occur at the IGSA,
and Deportation Staff conduct scheduled weekly visits with
; 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 !GSA.
ICE information request Forms are available at the !GSA for use by ICE
detainees.
'e

ICE staff responds to a detainee request fi·om an IGSA within 72 hours.

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

o DEFICIENT

ISJ ACCEPTABLE

YES

No

NA

ISJ

0

0

ISJ

0

0

0

ISJ

0

ISJ

0

0

ISJ

0

0

~

U

U

ISJ

0

0

ISJ

0

0

OAT-RISK

ICE staff visit the facility daily
when ICE detainees are housed at
the facility.

Scheduled visits are not posted in
the housing units by ICE staff
since their visits are daily.

requests are
on
a daily basis.
Detainees have access to the ICE
National Handbook that explains
the
VClj1l1lC>C

o REPEAT FINDING

.REMARKS:

b6,b7c

/10-15-09

NATURE
b6,b7c

b6,b7c

\)Ii - - ' -

I

I
I
I
,

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 73 of75

I

I

,

DETAINEE TRANSFER STANDARD
POLlCY: ICE WILL MAKE ALL NECESSARY NOTIFICATIONS WHEN ADETAINEE IS TRANSFERRED. IF ADETAINEE IS BEING TRANSFERRED VIATHE I
PRISONER ALIEN TRANSPORTATION SYSTEM (JPATS), ICE WILL ADHERE TO JPATS PROTOCOLS. IN DECIDING WHETHER TO I
•"''''Pl>
,~, '~L, ICE WILL TAKE INTO CONSIDERATION WHETHER THE DETAINEE IS REPRESENTED BEFORE THE IMMIGRATION COURT. IN
SUCH CASES, THE FIELD OFFICE DIRECTOR WILL CONSIDER THE DETAINEE'S STAGE WITHIN THE REMOVALPROCESS, WHETHER THEDETAINEE'S
ATTORNEY IS LOCATED WITHIN REASONABLE DRIVING DISTANCE OFTHE FACILITY, AND WHERE THE IMMIGRAnON COURT PROCEEDINGS ARE
TAKING PLACE.
D~~ADUO
YES
No
NA
When a detainee is represented by legal counselor a legal representative,
and a 0-28 has been filed, the representative of record is notified by the
detainee's Deportation Officer.

•
•
facility.
The

The notification is recorded in the detainee's file; and
When the A File is not available, notification is noted within
DACS
includes the reason for the transfer and the location of the new
officer is
,when

discretion
I

[gJ

D

D

[gJ

D

D

rx1

n

n

: the timing of the

ere

The detainee is infonned the day
nfthe

. "nrl

I

the

,fonn.

!

I

The attorney and detainee are notified that it is their responsibility to notifY
farnily members
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; and
• The detainee is not pennitted to make any phone calls or have
~
contact with any detainee in the general
.
detainee is provided with a completed Detainee Transfer Notification

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 IOSA) (DIHS)
Medical Director or designee approves the transfer;
• Medical transfers are coordinated through the local ICE office;
and
• A medical transfer summary is completed and accompanies the
detainee.
Detainees in ICE facilities having DIHS staff and medical care are
transferred with a completed transfer summary sheet in a sealed envelope
with the detainee's name and A-number, and the envelope is marked
Medical Confidential.
For medical transfers, transporting officers receive instructions regarding
medical issues.
Detainee's funds, valuables, and property are returned and transferred with
the detainee to his/her new location.
Transfer and documentary procedures outlined in Section C and D are
followed.
Meals are provided when transfers occur during nonnally schedule meal
times.
An A File or work folder accompanies the detainee when transferred to a
~ ""offioooo _ _
are forwarded to the receiving office via overnight mail no later than
one business day fullowing the transfer.

[gJ

D

D

[gJ

D

D

[gJ

D

D

[gJ

D

D

[gJ

D

D

[gJ

D

D

[gJ

D

D

[gJ

D

D

[gJ

D

D

[gJ

D

D

[gJ

D

D

[gJ

D

D

A sack lunch with sandwich,
drink and fruit are

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 74 of75

r-----------------------------------------

DETAINEE TRANSFER STANDARD
POLICY: ICE WILL MAKE ALL NECESSARY NOTIFICATIONS WHEN ADETA1NEE IS TRANSFERRED.

IF A DETA1NEEIS BEING TRANSFERRED VIA TIlE

;nee PRISONER ALIEN TRANSPORTATION SYSTEM (JPATS), ICE WILL ADHERE TO JPATS PROTOCOLS. IN DECIDING WHETHER TO
A

.

IrF WIT J _TAKE INTO CONSIDERATION WHETHER THE DETAINEE IS REPRESENTED BEFORETIlE IMMIGRATION COURT. IN

SUCH CASES, THE FIELD OFFICE DIRECTOR WILL CONSIDER THE DETAINEE'S STAGE WITHIN THE REMOVALPROCESS, WHETIlER TIlEDETA1NEE'S
ATTORNEY IS WCATED WITHIN REASONABLE DRIVING DISTANCE OF THE FACILITY, AND WHERE THE IMMIGRATION COURT PROCEEDINGS ARE
TAKING PLACE.

I
~ ACCEPTABLE

D DEFICIENT

D

YES

I

AT-RISK

No

I

NA

I

D REPEAT FINDING

REMARKS:

b6,b7c

110-15-09
AUDITOR'S SIGNATURE 1
b6,b7c

b6,b7c

•

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
Page 75 of75

OjJii.;V

b6,b7c
b6,b7c

West

SUBJECT:

,,-,,""''''U'.J.uu.

FadHty

rUllUIM""-

Review

UCltentmn Facility conducted
13-15,2009, in
has been assigned. No

Sierra Blanc~
A fInal rating
action is required and this review is closed.

The rating was based on
Lead Compliance Inspector (LCI) Summary Memorandum and
Field
Director
now initiate the following actions
supporting documentation,
in accordance
Detention Management Control
(DMCP):
1)

the facility
= = five business days
IJ~ of this memorandum. Notit1catit)tl
include
Facility Review Form.
G-324A Worksheet,
copies ofthc Ponn G~324A,
LCIMemorandum. and a
of this memorand:mn.
""",,>,en,,,,

Operations, shall

l. ...."'."..

wiU

2)

SctlcamCtJ on or before UC1tO!Jler 13
matter,

contact

AS:~lstant ilnCCU)f JJ·"'~""U."''''''.! Management·.DivIsion

b6,b7c
b6,b7c

cc:
b6,b7c

:

2-5514: 10/26/2009
b2High

HEADQUARTERS EXECUTIVE REVIEW

will have 30 dnys

The signature below constitutes review of this report
receipt of this
to
to an
and
b6,b7c
b6,b7c

Title

Comments:

The Review AuthQrity concurs with the recommended rating of "Good". No further action is required and this review is
closed,

FortuG-324A

FOR OFFICIAL

ONLY (LAW