San Diego Correctional Facility Annual Detention Review, ICE, 2006

• May 26, 2016 • Locations: United States of America -> California • Topics: Corrections Audits, Immigration

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------------------~----------~-----~---~--

Office of ~Ie"rion and Remo.ai OpemriMS
t;.s. Department ofHo .... land Security
425 I Street, NW
Washington, DC 20536

u.s. Immigration
and Customs
Enforcement

JUN 28 2006
MEMORANDUM FOR:

FROM:

SUBJECT:

Ronald Smith
Field Office Director

;:~~;;~t:\

San Diego Correctional Facility Annual Detention Review

Headquarters Detention and Removal Operations conducted a detention review of the San Diego
Correctional Facility October 18-20. 2005, in San Diego. California. A final rating of Good has
been assigned.
The rating was based on the Reviewer-In-Charge (RIC) Summary Memorandum and supporting
documentation. The Field Office Director must remedy the deficiencies in the RIC Memorandum,
and initiate the following actions in accordance with the Detention Management Control Program
(DMCP):
1) The Field Office Director. Detention and Removal Operations, shall notify the facility within
five business days of receipt of this memorandum. Notification shall include copies of the
Form G-324A. Detention Facility Review Form. the G-324A Worksheet. RIC Summary
Memorandum. and a copy of this memorandum.
2) The Field Office Director is responsible for ensuring that the facility responds to all findings
and a Plan of Action is submitted to the Review Authority (RA) within 30 days.
3) The RA will advise the Field Office Director once the Plan of Action is approved.
4) Once a Plan of Action is approved. the Field Office Director shall schedule and follow-up on
the above noted deficiencies within 90 days.
Should you or your staff have any questions regarding this matter, please
Deputy Assistant Director. Detention Management Division at (202) 732

cc: Official File
b6, b7c, , b2 high

b6, b7c
b2 high

"" of~1f!mJon alld R~moval Opem/lcms

".s. Dtpartmml of Homeland Serorlly
425 I Street. NW
Washington. DC 20536

~ U.S. Immigration

and Customs
... . Enforcement

MEMORANDUM FOR:

John P. Torres
Acting Director

FROM:

b6, b7c

Reviewer-In-Charge
D&D Officer, HQDRO, DSCU
SUBJECT:

San Diego Correctional Facility Detention Review Summary Report

The Detention Management Division, Detention Standards Compliance Unit, performed a
Headquarters Detention Review of the San Diego Correctional Facility in San Diego, CaIiforrua
October 18-20,2005. TIlls is a Contract Detention Facility (CDF) operated by the Corrections
Corporation of America (CCA). The review was performed under the guidance of b6, b7c .
, Phoenix Field Office,
b6, b7c , Reviewer-In-Charge. Team members included
b6, b7c
, Los Angeles Field Office and
, Division ofImmigration Health
b6, b7c
b6, b7c
Services, Washington, DC.
Type of Review
TIlls review is a scheduled Headquarters Review, which is performed to determine overall
compliance with the Immigration Customs Enforcement (ICE) National Detention Standards (NOS).
The facility received a previous rating of "Acceptable" during the August 2004 review.
Review Summary
The American Correctional Association (ACA), the National Commission on Correctional Health
Care (NCCHC) and the Joint Commission on Accreditation of Health Organizations (JCAHO)
accredit the San Diego Correctional Facility.
Standards Compliance
The following information is a summary of the standards that were reviewed and overall compliance
determined during the 2004 and 2005 detention reviews:
2004 Review
Compliant
Deficient
Repeat Deficiency

32
2
3

2005 Review
Compliant
Deficient
Repeat Deficiency

o
2

- - - - - - - - - - - - - - - - -- - - - - - - -- - - - ---- - - - -------- ---

Memorandum for John P. Torres
San Diego Correctional Facility Review Summary Report
Page 2
Detainee Classification SYstem - Repeat Deficiency
• . The facility inconsistently conducts classification of detainees upon arrival
• Reclassification between 45 and 60 days after arrival is inconsistently conducted
• NCIC printouts are not used to classify detainees
• Fonn 1-213 is inconsistently used to classify detainees
The team reviewed approximately seventy-five detainee detention files in determining that a
systemic problem existed with classification at this facility. Files reviewed contained classification
forms that were not completed, and others that were prepared incorrectly. The computer system
used within processing inappropriately dates the classification form. Dates on the classification
forms are not consistent with the actual date in which classification was conducted upon detainee
arrival.
Staff-Detainee Communications Standard-Repeat Deficiency
•
•
•
•

Staff conduct scheduled visits to the housing units to view living conditions
Schedules of officer visits are posted within the housing units
Detainee request form receipt and response activity is effectively logged
Copies of detainee requests are not maintained

ICE does not maintain copies of responses to detainee request forms consistent with the file and
maintenance component of the Standard. The team tracked twenty detainee request forms that had
been logged in and responded to in order to verify if copies were placed within the detainee
detention files. This review resulted in a systemic problem being identified. ICE does not maintain
copies ofrequest forms within the detainee detention files.
Significant Observations
Access to Telepbones
The facility recently re located the housing unit television sets approximately twenty-five feet away
from the telephone carousel area_ This Standard was found deficient during the 2004 review, due to
the location of the television set and the volume impeding, and not allowing a reasonable degree of
privacy during telephone use. Interview of approximately twenty-five detainees in two randomly
selected units during this review revealed that detainees were satisfied with corrective action taken
by the facility and advised that telephone privacy has improved with the television volume not
interfering. Unit managers advised that detainees are further allowed a degree of privacy and are
allowed to use the office telephone with supervision if requested.

•
Memorandum for John P. Torres
San Diego Correctional Facility Review Summary Report
Page 3

Significant Observations
Staff Appearance - Significant Observation
ICE and contract security staff presented a neat appearance. Officers were well groomed; uniforms
and equipment were maintained neatly. Escorting officers remained cognizant and directed
detainees professionally during escorts. Searches ofpersonneI entering and exiting the facility at the
front entrance were conducted thoroughly. Identification documents were also verified.
Food Service - Best Practice
Food Service was observed during food preparation and mea) delivery. During food preparation,
workers continuously maintained safety by mopping up food and water spills to prevent injury.
Workers wore bairnets and gloves while handling food items. Hidden areas behind ovens and the
dishwasher were well painted and clean. Hidden areas within dry and freezer storage, six inches
above ground were very clean and well painted. Food temperatures were taken within the kitchen
and after delivery to the housing units and were in compliance. This kitchen is under the supervision
of a well-experienced Food Service Administrator. The hard work and dedication of the entire Food
Service crew has demonstrated their ability to have this area recognized as a "Best Practice" during
this review.
Tool Control-Best Practice
Tool control was clean and well organized with shadow boards to identify tool locations. Tool
issuance includes the use ofa plastic chit with the photograph ofthe employee using the tool for
visual reference and tracking. Weekly departmental inventories are conducted for accountability
purposes and logs are effectively maintained for tracking tools in the event of an emergent situation.
The tool room is under the guidance of a very knowledgeable supervisor and well-experienced crew
whose hard work and dedication allowed this area to be recognized as a "Best Practice" during this
review.
Detainee Request Tracking Log-Best Practice
The facility has created a local program for tracking detainee request forms. This log was created
with the parameters set forth in the Staff-Detainee Communications Standards and is capable of
tracking incoming and outgoing detainee request activity. The program can be used to produce
reports by date and nationality. This program was recognized as a "Best Practice" during this
review.

Memorandum for John P. Torres
San Diego Correctional Facility Review Summary Report
Page 4

RIC Observations
The Officer In Charge, Warden and staff were very supportive during the review. Staff encountered
during the review, clearly displayed professionalism illustrated by their leadership. This facility is
under very good management and bas excelled from the previous review in 2004.

Recommended Rating and JustificatiOg:
The Reviewer-In-Charge recommends a rating of "Good." The facility has made major
improvements since the 2004 review by correcting and minimizing the total number of deficiencies
and creating an effective tracking mechanism for detainee request activity. The facility complies
with 36-of-38 applicable ICE Detention Standards. The facility should respond to all findings and
initiate a Plan of Action in response to the deficiencies.

RIC Assurance Statement:
The findings of compliance and noncompliance are documented on the G-324a Inspection form and
are supported by documentation in the review file.

•

Depsrtment Of Homeland Stturity
Immigration and Customs Enforcement

A. T

Reviewed
ICE Service Processing Center
ICE Contract Detention Facility
ICE Intergovernmental Service Agreement

Detention Facility Inspection Form
Facilities Used Over 72 hours

G. Accreditation CertifICates
List all State or National Accreditation[s) received :
ACA, NCCHC. JCAHO
Check box if facilitv has no accreditation s

B. Current Inspection
Type of Inspection
Field Office t8J HQ Inspection
Date[s) of Facility Review
October 18-20. 2005

C. Previous/Most Recent Facili

Review

Date[s] of Last Facility Review
. August 3 I-September 2. 2004
Previous Rating
! 0 Superior 0 Good [8J Acceptable

Deficient

At-Risk

Name and Location of FaciJilv

~.mt

Sa. J)i<lio Correctional Facility
Addr~u

(Street and f'riamrJ

446 AlIa Road. Suit. 5400
City. Stat< •• d Zip Cod.
Sa. Oi<t!o. Calirornia 92158
Counl),
San oi<!llo
"'"m. and Tilk or Cbief [It<ulive Ollker (W.rdtn/OIClSuptriDlendenl)
. Ol1ker In Charg.
b6, b7c
Telephone # (lndud. Ar•• Cod.)
619-661 b6, b7c
, Field Offict I Sub-Office (Ust om •• wilh o.. night responsibilities)
I

I. facility History
Date Built
March 1999
11 Date Last Remodeled or Upgraded
. March 2002
Date New Construction 1 Bedspace Added
-None
Future Construction Planned
OYes!8l No Date:
Current Bedspace
Future Bedspace (# New Beds onl y)
1300
Number:
Date:

J. Total Facili
Jation
Total Facility Intake for previous 12 months
11.021
TOlallCE Mandays for Previous 12 months
424,816

San D~o

I DI5taDcc from Fitld onlce
I 2~ Mllrs

K. Classification Le,v-,-e,-I-":-,'-"'--=-=---r=-=,,,,-::-=:-~r'=:'--::E

ICE Information

Name of Inspector (Last Name. Title and Duty Station)
,l D&D Officer ,l Washington, DC
b6, b7c
Name of Team Member 1 Title I Duty Location
! SIEA i Phoenix Field Office
b6, b7c
Name of Team Member j Title ,I Duty Location
! DO I Los Angeles Field Office
b6, b7c
Name of Team Member ! Title; Duty Location
,I CPT J Washington. DC DlHS
b6, b7c
F CDF/IGSA Information Onlv
Contract Number
Date of Contract or IGSA
ODT-5-C-0003
July 7, 2005
Basic Rates per Man-Day
900/2,586.937
Other Charges: (If None. Indicate NlA )
None:
I Estimated Man-days Per Year
I 328,500

Adult Male
Adult Female

Facility Ca acily

F'-':R'!-a-:t-ed-;-'Ir:::Oc--pe-,ra-t-=-io-n-a-=-1' I--=E-m-e-rgle-n-cy-'' I
Adult Male
1000
1
1250
1 Adult Female
200
1
200
I
I [J Facilitv holds Juveniles Offenders 16 and older

1700
300
Adults

J
.1

M. A\'crage Daily P0;-r::..:plu:.,:la;o.l:,:io"'n:.:---._-:-:_.,---,-_.,-,---_-,
ICE
J USMS J Other I

I Adult Male

I Adult Female

751
204

239
30

0
0

N. Facility Staffing Level
b2 high

b2 high

Form G-324A (Rev. 8/\3 104) No Prior Version May Be Used After 1011 104

•

•
SigniflSllnt Incident Spmmary 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.

GriC\aJ1ccs:

l>c:atbs

S=I JA=2

A=2

."1=5

Any Illtcmpled ph}'Sical contact or physical contact that involves t\\'O or morc oITcnders
Oral . anal or vaginal penetration or attempted penetration involv ing at least 2 parries. whether it IS consenting or non-conscOIing

Routine ttansportatjon of detai nees/offenders is not COllsidcred "forced"
Any incidenl that involves. four uf more detainees/offenders. includes g.ang fig.hts. organized multiple hunger strikes. work sioppago!s. hostage situations,
major fires. or orner large scale incid~nts .

Fonn G-324A (Rev. 8i I 3!04) No Prior Version May Be Used After 10! 1;04

HEADQUARTERS EXECUTIVE REVIEW

The signature below constitutes review of this report and acceptance by the Review Authority. Ole/CEO will have 30 dayJ from
receipt of this report to respond to all flndinp and recommend.tIona.
lQDRO EXECUTIVE REVIEW: (Please Print Name)

Signatu,

(

John P. Torres
Title

i"
~!
/V,,

'J
\.

'., , '

j ''.

I.-,, '

Dcl. .

Acting Director

FlnaJ Rating:

Superior

~Good

o Acceptable

o Deficient
OAt-Risk

Comments:
The Review Authority (RA) concurs with the recommended rating of "Good" made by the Reviewer-lnCharge (RIC) as justified in the RIC Memorandwn and the G-324A Worksheets.

Form G-324A (Rev. 8/1/01 ) No Prior Version May Be Used After 12/31101

Department of HommlDd 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 alllGSA Facilities Used over 72 Hours

Headquarters Detention Review Worksheet

Local Jail- IGSA
State Facility - IGSA
~
ICE Contract Detention Facility
ICE Service Processin2 Center
0
Name
San Diego Correctional Facility
Address (Street and Name)
446 Alta Road Suite 5400
City, State and Zip Code
San Diego, California 92158
County
San Diego
Name and Title of Chief Executive Officer (Warden/OIC/Superintendent)
Officer In Chaf1le
b6, b7c
Name and title of Reviewer-In-Charge
, Detention and Deportation Officer
b6, b7c
Date[sJ of Review
October 18-20 2005
~pe of Review
OSpecial Assessment
Other
Headquarters 0 Operational

Table of Contents
DETA1NEE SERVICES STANDARDS
CClSSl'O

(SECTION I)

... _ ..........._._ ......................_ .. _ ....... 3

................ ............ ......................... .......... ......... .. ...................... ........... .... .

ADMISSION AND RELEASE ....... ...... .. .... .. .... .... ..... ......... .... .... .. .... ..... ..... ..... .... .. ......... ...... ...... ..... .. .... ..... . ; .. .
CLAsSIFICATION SYSlEM ......... ................ .... ...... ..... ........... .. .. . .. ..... ..... .. ............. ....... ..... .... ................ ..... .
CORRESPONDENCE AND OTHER MAIL ....... .... ..... ...... ..... ..... .... ....... ...................... ... .. ....... ........... .. ..... .. .. . ..
DETAINEE HANDBOOK .... ... .... .... ......... ....... .. ....... .. ........................ ........ ............................ .. ........... ..... .... .
FOOD SERVJCE ....................... ..... ......... .. ... .. ........... ................................................................................. ..
FuNDS AND PERSONAL PROPERTY ....... ........ ...... ...... ........................ ..... ............ ..... ......... .. .. ........ ..... ....... .
DETAINEE GRlEV ANCE PROCEDURES ... ........ ... .......... .... ..... .. ... ............ ......... . ..... ...... ..... . ........... ............. ..
G
Al1QN ,ON
HTS ........ ... ........................................ ... ......... .. ... ... ....... .. ... ........ ..
IsSUANCE AND ExCHANGE OF CLOTHING, BEDDING, AND TOWELS ............................... .. ............... .. .... ..
MARRIAGE REQUESTS ...... .... .. .. ........ .. ......... ... ..................... ........... .. .... . .. ..... . .. .. .. ...... ...... .. ... .. ....... .. ....... ..
NON-MEDICAL EsCORTED TR1Ps ............................................................ .. .......... .. ............ ... ................... .
RECREATION ....... .... ... .... ......... ...... ......... .... ... ......... .... ..................... ....... .......... ....... ...... ... .. .. .......... ........ .. .
RELIGIOUS PRACTICES .... ... ... ... ............. . ....... .. ...... ... ........ ........ .. ..... .. ... ....... ... .. ... . ..... ..... .. ...................... .. .

CCIlS$TO

.................................................... ................................. ... ........... ........... ........... .

1S1t;
.................. ........... .... ............... ........... ... ............ ... ....... ........ ..... ......... ......... .. .. ...... ......... ... ..... .
VOLUNTARY WORK PROGRAM ...... ...... ..... ......... .. .... .. .. .......... ..... .. .. .. ..................... ....................... ........... .

HEALTH SERVICES STA.."IDARDS (SECTIONll) ..................... _ ......................................... 33
HUNGER STIUKES ... ......... ..... ...... ...... .... ... ........... .... ......... ....... .......... .... .... ............. ..... .. ......... .. ..... ... ... .. .. . .
MEDICAL CARE ........ ............................... ... ........ ..... ... ....... ..... ............ ... .... ........ ... .. ........................ .......... .
SUICIDE PREVENTION AND INTERVENTION ......... ........................... .. .. ........................................... ... ... .... .
TERMINAL ILLNESS, ADVANCED DIRECTIVES AND DEATIl ....... .. ............ ........ ...... ..... ............... .... ..... ... ..

SECURITY AND CONTROL STANDARDS (SECTION Ill) .................................................. 40
CONTRABAND .... .. ....... ......... .... .. .. ... .... .... .... ................ .... ................... .. ... ................... ............ ..... .......... .. . .
DETENTION FILES .... ... ............ ... .... .. ....... ... ................................................................................... ........... .
DISCIPLINARY POLICY ...... ... .............. .. .... .. .. .. ...... .... .. .. ..... .... .......... .. ... ... ...... ...... ..... ... .......... .... ... ....... .... . .
EMERGENCY PLANS ....... ........................... ... ..... ........ .. ... ..... .... ... .. ...... .. ... ...... ........... .......... .......... ...... ..... . .
ENVIRONMENTAL HEALTIl AND SAFETY ...... ..... .. ... ............................ ... .................................................. .
HOLD ROOMS IN DETENTION F ACILmES ... ..... .. ..... .............................. .. ........ .. ...... .. ... ....... ..................... .
KEy Al'<1) LOCK CONTROL ... .. .. ..... ........... ... ..... ... .. .... .... ...... ..... ..... .. .. .. ... ................. .. ... ...... ... ............. ..... . .
POPULATION COUNTS ..... ...... ... .... .. .... ....... ......... .... ... ............ ................ ............. . .... ....... ..... .......... .......... ..
POST ORDERS .... ...... ... ....... ... .. .... ....... .. ................................................................... ..... ........ ........... ... ..... ..
SEC URITY INSPECTIONS ... ......... .. ....... .............. ......... ........ .. ...... .. ... ..... .... .. .... ..... .... .. .. ... ... .... ...... ......... ..... .
SPECIAL MANAGEMENT UNIT (ADMINISTRATIVE S EGREGATION) ....... ......... ....... ....... ........... .. .. ... .. .... .. .. .
SPECIAL MANAGEMENT UNIT (DISCIPLINARY SEGREGATION) ......... ... .... ..... ....... ........ .. ..... .. .... .... ...... .. . ..
TOOL CONTROL ... .. .................. .... ... .............. ... ...... ...... .. ........ .. ........ ... .. ........... .. ........ ..... ....... ... .. ........ .. ... .
TRANSPORTATION (LAND) .... ... ............. .. .. ........... ...... ...... .. ..... ...... ... ... .......... .. ............................... ... ...... .
USE OF FORCE ....................................... ...... .... ........... ......... ....... ... ... ..... ........ ....... .... ...... ... .. .... .. ... ... ... ... .. .
STAFFIDETAINEE COMMUNlCATIONS .......... .... .... .. .... .. ......... .... ..... ...... ... .. ...... ..... ... .. .. .......... ........ .. ... ... ... .
DETAINEE TRANSFER STANDARD .... ...... ........ ...... ... .... .... ...... .... .... ......... ........ .. .. ............. .... ..... ...... .. ... ..... .

Page 2
G-324A Detention Inspection Form Worksheet for IGSAs • Rev: 10118104

•
Section I
Detainee Services Standards

Page 3
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

¥ ~ "'-- '--- "

ACCESS TO LEGAL MATERJALS ·· ,

•

. . :<.

Policy: Fec:l1IlIea holding ICE. deIIIII ..... IhIII penni detainees ecceaa to. law library, and provide IagaI
materiafa. faciIiIIn, ~ and documanl copying privIIgM• ..net the oppcwtUrity to prepant JagaI
doa,Imenta.

CoIIIP""
The facUlty provides a designated law library for
detainee use.
The law library contains all materials listed in the
"Access to Legal Matarials· Standard, Attachment A.
The listina of materials is POSted in the law library.
The library contains a sufficient number of chairs , is well
lit and is reasonably isolated from noisy areas.
The law library is adequately equipped with typewriter,
computers or both and has sufficient supplies for daily
use by the detainees.
In lieu of/or in addition to the physical law library, ICE
detainees have access to the Lexus Nexus electronic
law library.
The Lexus Nexus libraJY is updated and is current.
Outside persons and organizations are permitted to
submit published legal material for inclusion in the legal
library. Outside published material is forwarded and
revieWed b~the ICE prior to inclusion.
There is a deSignated ICE or facility employee who
inspects, updates, and maintalnireplace legal material
and equipment on a routine basis. The designee
properly disposes outdated supplements and replaces
damaged or missing material promptly.
Detainees are offered a minimum 5 hours per week in
the law library. Detainees are not required to forego
recreation time in lieu of library usage. Detainees facing
a court deadline are given priority use of the law library.
Detainees may request material not currantly in the law
library. Each request is reviewed and where appropriate
an acquisition request is initiate and timely pursued.
Request for copies of court decisions are
accommodated with in 3 - 5 business days.
The facility permits detainees to assist other detainees,
voluntarily and free of charge, in researching and
preparina leaal documents consistent with security.
Staff ensures that Illiterate or non-English-speaking
detainees without legal representation receive more
than access to English-language law books after
indicatina their need for help.
Detainees may retain a reasonable amount of personal
legal material in the general population and in the
special management unit. Stored legal materials are
accessible within 24 hours of a written request.
Detainees housed in Administrative Segregation and
Disciplinary Segregation units have the same law library
access as the general population, barring security
concerns . Detainees denied access to legal materials
are documented and reviewed routinely for lifting of
sanctions.
All denials of access to the law library fully documented.

ItA-

f2l

J8J

f2l

[8]

RIImmb
Naw material has been
ordered.

Staff advise sometimes it
can take up to two
weeks .

Very limited selection in a
language other then
english.

Staff go to segregation
twice a week. Staff will
deliver legal material
upon detainee's request.

Page 4
G-324A Detention Inspection Form Worksheet for (GSAs - Rev: 10/18/04

•

ACCESS TO LEGALMATERIALS

PoIIcr: Fac:iIties holding ICE dataInees ahal permit deIINes acceI8 110 • law library. and pro¥ide legal
1TIIII8r111s. t.ciIIIIes, equipment and document CIDIJ'iIr1g priviIegeI. end 1M ~ to prepare legal
dOcurnenta.
Y

CoIIIponenm
Facility staff infOlTTlS ICE Management when a detainee
or group of detainees is denied access to the law library
or law materials.
Detainees who seek judicial relief on any matter are not
subjected to reprisals retaliation or penalties.

R8maJb

NA
I

181

r-----...,.. ~·-·----"~--':AC-=C""E""SS="T=-:O::-:-LE~~
-=-=-"""""
MA
=T=ER'-'u.a.
""'
IL
""S"'--~--""""-~~ Acceptable

o Deficient

o At-Risk

o Repeat Finding

Remarks: (Record significant facts, observations, altemate source used for verification, etc.)
b6, b7c

Auditor's Signature I Date

\~ lJo lQ)

Page 5
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10118/04

•
Y

Component.

RemarIca

-Iii processing includes an orientation of the facHity.
The orientation includes; Unacceptable activities and
behavior, and correspond ing sanctions, How to contact
ICE. The availability of pro bono legal services, and
how to pursue such services, Schedule of programs,
services, daily activities, including visitation, telephone
usage, mail service, religious programs, count
procedures, access to and use of the law library and
the general library; sick-call procedures, etc., and the
detainee handbook.
Medical screenings are performed by a medical staff 2[
persons who have received specialized training for the
purpose of conducting an initial health screening,
When available, accompanying documentation is used
to identify and classify each new arrival .
All new arrivals are searched In accordance with the
"Detainee Search" standard. An offlC8r of the same
sex as the detainee conducts the search and the
search is conducted in an area that affords as much
priv~ as possible.
Detainees are stripped searched only when cause has
been established and not as routine policy. Non-criminal
detainees are never strip-searched but are patted down
unless cause or reasonable susp icion has been
establiShed.
The "Contraband" standard governs all personal property
searches. IGSAslCDFs use Of have a similar contraband
standard. Staff prepares a complete inventory of each
detainee's possessions. The detainee receives a copy.
Staff completes Form 1-387 or similar fonn for CDFs and
IGSAs for every lost or missing property claim . Fac~ities
forward all 1-387 claims to ICE.
Detainees are issued appropriate and sufficient clothing
and bedding for the climatic conditions .
The facility provides and replenishes personal hygiene
items as needed, Gender-specific items are available,
ICE Detainees are not charged for these items.
All releases are coordinated with ICE.
Staff completes paperworklforms for release as reQuired.

181 Acceptable

o Def1clent

o
o

I:8l

o
o
o

I:8l

[8l

I:8l
I:8l

0
0
0

At-Risk

o Repelt Finding

Remarks: (Record significant facts. obs9Nations. other sources used, etc.)
b6, b7c

Page 6
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

., .'

•
ClASSIFICATION SYSTEM
! Poley. All fecIItlea wiDdeVelop and Implement •

system according to which ICE detainees . . cIasIIfted. The

QasIIfIc;ation system will ensure-that each detainee Is placed In the IIJPrOPriaI8 category, physic8IIy eeparated

from deb*lees In other categories
Components

Housing assignments are based on classtficationlevel.
A detainee's classifIcation-level does not affect hislher
recreation opportunities. Detainees recreate with
persons of similar classification designations.
Detainee work assignments are based upon
classification designations.
The classification process includes
reassessment/reclassification . For IGSA's detainees
may request reassessment !)etween 45 and 60 days
after arrival. For CDF's detainees are re-assessed
approximately every 60 days.
The classification system includes standard procedures
for processing new arrivals' appeals. 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 with in
10 business days.
ClassifICation designations may be appealed to a
higher authority such as the Warden or equivalent.
The Detainee Handbook or equivalent for IGSAs
explains the classification levels, with the conditions
and restrictions applicable to each.

I2Sl DefiCient

The facilitY has a system for classifying detainees. In
CDFs and IGSAs, an Objective Classification System
or similar Is used.
The facility classification systam includes:
• Classifying detainees upon arrival.
Separating individuals who cannot be classified
upon arrival from the general population.
• The first-line supervisor or deSignated
classification specialist reviewing every
classification decision.
The intake/processing officer reviews work-folders, Afdes etc. to Identify and classify each new arrival.
Staff use only infonnation that is factual , and reliable to
detennine classification assignments. Opinions and
unsubstantiated! unconfinned reports may !)e filed but
are not used to score detainees classifications .

181

Remarb

0
Please see remarks
below

181

r8I

181

II appears that insufficient
infonnalion is being used
to detennine the subject's
classification. Very
seldom is CLETS or
NCIC printouts used.

Please see remarks
stated balow.

181

Al-Risk

The subject can file a
grievance.

o Repeat Finding

Remarks: (Record significant facts, observations, other sources used, etc.)
Approximately 100 hundred files were reviewed. The Review Team found several discrepencies.

Page 7
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10118104

•

Several lies showed that subject's had been In custody severa/days before being cIasslfied.
Staff stated that this was an Issue with !heir classification computer program.
Other files that the Review Team found.

I had received intial classification on 09I08I05. his admittance date was
b6, b7c
The file shows the subject was In custody for eight days without being classified.

MexIcO I Subject's 1-213 showed a gang affiliation. the classification form did

b6, b7c

not acurateIy reflect that informatiOn.

Guatemala I Subject's fie contained an initial c1assiflcallon sOd a 90 day review.

b6, b7c

but there was no 30 to 45 day review.

Colombia I Subject has been In custody 637 days with an initial classification
b6, b7c
and a 90 day review. The file shows no other reviews.
Nigeria I Subject has been in custody 380 days with only a blank

b6, b7c

classification form in his file.

When the staff was asked to provide corrected documentatlon concerning the cases listed above they were
unable to do so.
b6, b7c

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G-324A Detention lDspeet10n Form Worbheet for IGSAs - Rev: 10/18104

•

CORRESPONDENCE AND OTHER MAIL

:,;;'"

\. Policy:' All fac:iIitieI will ensure that
send and raceive COfl'Mpondence in a .meIy manner. aubjecr to
Iimitationa reqUIted for the ufety. IeCUr1Iy.-and orderty operation of the facility. Other mail wiU be ~
I SUbject to the aame IimltaIlons. Each r.cI1lly will widely dIs1riIuIII ita ~ cancemlng CIOIT8IPDIIdence _

, OIarMIL

Componenta

The rules for correspondence and other mail are posted
in each housing or common area or provided to each
detainee via a detainee handbook.
The facility provides key infonnation in languages other
than English; In the language{s) spoken by Significant
numbers of detainees. List any exceptions.
Incoming mail distributed to detainees within 24 hours or
1 business day after it is received and inspected.
Outgoing mail is delivered to the postal service within
one business day of its entering the internal ma~ system
(exciudinQ weekends and holidavs).
IN CDFs: Staff maintain a logbook-recording
acceptance of priority, priority overnight. and certified
mail delivered to the facility for a detainee.
Staff do not open and inspect incoming general
correspondence and other mail (including packages and
publications) without the detainee present unless
documented and authorized in writing by the Warden or
equivalent for prevailing securityreasons.
Staff does not ever read incoming general
correspondence without the Warden's prior approval .
Staff does not inspect Incoming special Correspondence
for physical contraband or to verify the "special" status
of enclosures without the detainee present.
Staff are prohibited from reading or copying incoming
special correspondence.
Staff are only authorized to inspect outgoing
correspondence or other mail without the detainee
present when there is reason to believe the item might
present a threat to the facility's secure or orderly
operation, endanger the recipient or the public, or might
facilitate criminal ectivlty.
Correspondence to a politician or to the media is
processed as special correspondence 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 censorship or rejection of
outgoing mail provides the detainee With signed written
notica.
Staff maintains a written record of every item removed
from detainee mail.
The Warden or equivalent monitors staff handling of
discovered contraband and its disposition. Records are
accurate and up to date.

r8l

t8l

[8J

r8l

[8J

t8l

[8J

R8marIca

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G-324A Detention Inspectlon Form Worksheet Cor IGSAs - Rev: 10/18104

CORRESPONDENCE AND OTHER MAIL

Poncy: AI fadItieI Win ensure that detainees Mod and rec:eM corJeIPOrl(Ience In • timelymanner. IUbjec:t"
HrnItdons required for the safety.l8CUtIty. and ~ operation of the fJIcIIly. Other mal will be penniII8d,
aubjectto ~ ..me 1imIIIItIona. Ead1 facIIy wII WIdely ~ b guicMIIMa calC8fT\k)g ODmIIPOIldeta and

other mal.
The procedure for safeguarding cash removed from a
detainee protects the detainee from loss of funds and
theft. The amount of cash credited to detainee accounts
is accurate. Discrepancies are documented and
investigated . Standard procedure includes issuing a
receipt to the detainee.
Original identity documents (e.g., passports, birth
certificates) are immediately removed and forwarded 10
ICE staff for placement in A-files.
Staff provides the detainee a copy of his/her identity
document(s) upon request
Staff disposes of prohibited items found in detainee mail
in accordance with the ·Control and Disposition of
Contraband" Standard or the similar prevailing policy in
IGSAs and CDFs.
Every indigent detainee has \he opportunity 10 mail. at
government expense: Reasonable correspondence
about a legal matter: Three one ounce letters per week:
Packages deemed necessary by ICE.
The facility has a system for detainees to purchase
slamps and for mailing all special correspondence and a
minimum of 5 pieces of general correspondence per
week.
The facility provides writing paper, envelopes, and
pencils at no cost to ICE detainees.

I2l

ICE's responsibilty.

The facility allows up to 5
a week.

Up to 5 a week.

CORRESPONDENCE AND OTHER MAl. - R.tInll

I2l AccepUilble

o Deficient

At·R1.k

o Repeat Find ing

Remarks: (Record significant facts, observations, other sources used, etc.)
b6, b7c

Page )()
G-324A Detention Inspection Form Worksheet for IGSAs • Rev: 10/18/04

r --.:- - .

Policy:

DETAINEE HANDBOOK ': :,

•

. .,

:: ..

· ·.··,·:"','1

~veryOlC Wil develope ~deIaInee hIindbooIt~S8fv." an ~;. ~~~:~
varfous.aun:ee:

, detention pofJCies 1\1181 and proc:edurM In eItIIct. the facility The handbook will also deKribe the..w:..
proglM\a, and ~~ttvough
IncludIng ttlefd'ily. ICE. prtvaIe~:
aIc. Every detainee will rec:etve. ~ of thla t.dxlok upon edmisaioflliO the facility.
The detainee handbook is written in English and
translated into Spanish or into the next most-prevalent
Language{s).
The handbook supplements the facility orientation
video where one is provided.
All staff members receive a handbook and training
regarding the handbook contents.
The handbook Is revised as necessary and there are
procedures in place for immediately communicating
any revisions to staff and detainees.
There an annual review of the handbook by a
designated committee or staff member.
The detainee handbook address the following issues:
•
Personal Items permitted to be retained by the
detainee.
•
Initial issue of clothes. bedding and personal
l1ygiene items.
The detainee handbook states in clear language basic
detainee responsibilities .
The handbook clearly outlines the methods for
classification of detainees, explains each level, and
explains the classifICation appeals process.
The handbook states when a medical examination will
be conducted .
The handbook describes the facility, housing units,
dayrooms, In-dorm activities and special management
units.
The handbook describes; Official count times and
count procedures Meal times, feeding procedures,
procedures for medical or religiOUS diets, smOking
policy, Clothing exchange schedules and if authorized,
clothes washing and drying procedures and expected
personal hYQiene practices.
The handbook describe times and procedures for
obtaining disposable razors and allows that detainees
attending court will be afforded the opportunity to shave
first.
The handbook describes barber hours and hair cutting
restrictions .
The handbook describes; the telephone policy, debit
card procedures, direct and frees calls; locations of
telephones; policy when telephone demand is high; and
poliey and procedures for emeraency phone calls.
The handbook addresses rel igious programming.
The handbook states times and procedures for
commissary or vending machine usage. (where
availablei
The handbook describes the detainee voluntary work
program .

o o
o o
o o
o

o
o

121

IZI

121

IZI

Reviewed quarterly.

Clothing exchange is not
specifically stated, but the
info is posted in each unit

The issue is not
specifically stated but staff
states that detainee's are
allowed to shave before
court.
Hours of operation are
posted in each unit.

Hours of operation are
posted in each unit.

Page 11
G-324A Detention Inspedlon Form Worksheet for IGSAs - Rev: 10/18104

II
'

'I'

IPoHc,:

DETAINEE HANDBOOK

wII,...,.

ptOgrMIS. and opportunItiea ....... through wrIouI eoun..lncUIng the facIly. ICE. privaIe
a c:op'f of
handbook upon edmIuIon 110 the '-dilly.

etc. Every detainee

Componerda

The handbook describes the library location and hours
of operatlon and law librarv procedures and schedules.
The handbook describes; attorney and regular visitation
hours, policies and procedures.
The handbook describes the facility contraband policy.
The handbook describes the facility visiting hours and
schedule and visiting rules and regulations ,
The handbook describes the correspondence policy
and procedures,
The handbook describes the detainee disciplinary policy
and procedures:
Including:
Prohibited acts and severity scale sanctions.
Time limits In the Disciplinary Process.
Summary of Disciplinary Process.
The grievance section of the handbook explains all
steps in the grievance process - Including:
Informal (If used) and formal grievance
procedures;
The appeals process;
In CDF facilities: procedures for filing an
appeal of a grievance with ICE.
• Staff/detainee ava~ability to help during the
grievance process .
• Guarantee against staff retaliation for
filing/pursuing a grievance.
How to file a complaint about officer
misconduct with the Department of Homeland
Security.
The detainee handbook describes the medical sick call
procedures for general population and segregation.
The handbook describes the facility recreation policy
including:
• Outdoor recreation hours.
• Indoor recreation hours.
The handbook describes the detainee dress code for
daily livinQ; and work assiQnments.
The handbook specifies the rights and responsibilities
of all detainees.

[8J

1:81

[8J

181

[8J

181

[8J

181

•
•
•

Hours are posted in each
unii,

1:81 Acceptable

o Deficient

OAt-Risk

orv-lizIlIa.,

•
•
•

o Repeat Finding

Remarks: (Record significant facts, observations, other sources used, etc.)
b6, b7c

Auditor's Signature / Date

Pagc12
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18104

the;

ev.y OIC will develop a ~ datIIlnee fIandbook to eerYe as an oveMew of, and guide 110.
d••ntlon poUcJe. t\Iies. 8nCJ procedtnlln etr.ct lithe fIIciIty. The handbook wIIallo delJcrI)e the 88rYicas,

FOOD SERVICE

---

Policy: Every fecIIty will provide ......... in ita '*B with nutritious and appetizing meaIa, prepared In
IICCOIdance WIIh till! ~ unlta!y standards.
V
~
ComponetllS
N
NA

r.n;e-foOd service program is under the direct

supervision of a professionally trained and certified
service administrator. Responsibilities of cooks and
cook foremen are in writing. The Food Service
Administrator (FSA) determines the responsibilities of
the Food Service Staff.
The Cook Foreman is on duty on days when the FSA is
off duly and vice versa.
The FSA provides food service employees with training
that specifically addresses detainee-related issues.

•

In ICE Fac~ities this includes a review of the
ICE "Food Service" standard

Knife cabinets dose with an approved locking device
and the on-duty cook foreman maintains control of the
key that locks the device.
All knives not in a secure cutting room are physically
secured to the workstation and staff directly supervise
detainees using knives at these wornstations . Staff
monitor the condition of knives and dinina utensils
Special procedures (when necessary) govem the
handlinQ of food items that pose a security threat.
Operating procedures Include daHy searches
(shakedowns) of detainee worn areas.
The FSA monitor staffs implementation of the facility's
population counts procedures. Staff are trained in
counts procedures.
The detainees assigned to the food service departmenl
look neat and clean. Their clothing and grooming
comply with the "Food Service" standard.
The FSA annually reviews detainee-volunteer job
descriptions to ensure they are accurate and up-todate.
The Cook Foreman or equivalent instructs newly
assigned detainee warners in the rules and procedures
of the food service department.
During orientation and training session(s), the CS
explains and demonstrates:
• Safe worn practices and methods.
• Safety features of individual products! pieces of
equipment.
Training covers the safe handling of hazardous
material[sj the detainee are likely to encounter
in their wor1<:.
The Cook Foreman documents ali training in individual
detainee detention files .
Detainees at CDFs are paid in accordance with the
"Voluntary Work Program" standard. Detainee warners
at IGSAs are subject to local and State rules and
r6Quiations r6Qarding detainee"'pay.

rgj

181

rgj

The faCility does not use
knifes, they use dough
cutters.
Same as above.

•

Page 13
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10118104

•

FOOD SERVICE

PolICy: Every fac:iJIty
provide detaltleee in Its care with nutritious .-.d appetizing meals. prepanId
; aocordance with !he highest sanitary standards.
y
N
NA
Renwb
Components
Detainees are served at least two hot meals every day.
No more than 14 hours elapse between the last meal
served and the first meal of the following day.
For cafeteria style operations, a transparent ·sneeze
guard" protects both the serving line and salad bar line.
The facility has a standard 35-day menu cycle. IGSAs
use a 35 day or similar system for rotating meals.
The FSA or facility considers the ethnic diversity of the
facil ity's detainee population when developing menu
cvcles. (Provide examples}
A registered dietitian conducts a complete nutritional
analysis of every master-cycle menu planned.
The FSA has established procedures to ensure that
items on the master-cycle menu are prepared and
presented according to approved recipes.
The Cook Foreman has the authority to change menu
Items if necessary.
If yes, documenting each substitution, along
with its justification
• With copy to FSA
All staff and volunteers know and adhere to written
"food preparation" procedures.

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

r8l

r81

r8l

r81

r8l

0
The common-fare menu
consists of pre-prepared
frozen meals.

r8l

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

Page

In"

G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

[

.•.....

•

acc:onIanc:e with tt. ~ senit8ry It8IId8rds.
~

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

R8maIb
i

[8J

0
0

0
0
0
0
0

satellite-feeding programs follow guidelines for proper
sanitation.

[8J

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

[8J

All meals provided in nutritionally adequate portions.

[8J

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

[8J

0
0
0

t8.1

[8J

The food service staff instructs detainee volunteers on:
Personal cleanliness and hygiene;
• Sanitary techniques for preparing, storing, and
serving food, and;
• The sanitary operation, cere, and maintenance
of equipment.
Everyone working in the food service department
complies with food safety and sanitation requirements.

•

Standard operating procedures include weekly
inspections of all food service areas, including dining
and food-preparation areas and equipment.
who conducts the inspections?
Equipment is inspected for compliance with health and
safety codes and regulations.
• When was the most recent inspection?
Which agency conducted the inspection?

•

Reports of discrepancies are forwarded to the Warden
or designated department head and corrective action is
scheduled and completed.
Standard procedure includes checking and
documenting temperatures of all dishwashing
machines after each meal.
Staff documents the results of every refrigeratorl
freezer temperature check.
The cleaning schedule for each food service area is
conspicuously posted .
Procedures include inspecting all incoming food
shipments for damage, contam ination, and pest
infestation.
Storage areas are locked when not in use.

[8J

t8.1

[8J

Food service manager
and each unit supervisor
conduct the inspections.
The County of San Diego
Dept. of Environmental
Health inspects the facUity
every three months, last
inspection 08/08/05 .

Page 15
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

FOOD SERVICE

181 Acceptable

o Deficient

At-RIsk

o Repeat Deficiency

Remar1c:s: (Record significant facts, OOs&IVations, other sources used, etc.)
The food temperature was inspected at the kithchen and then again at the lime of it's serving. The temp's
ranged from 151 degrees up to 177 degrees.
The kitchen staff was found to be extremely professional and well versed in the proper running of a food
service program. The kitchen was very clean and was well organized. The food carts were clean and well
maintained. This standard is a best practice for this review.
b6, b7c

Page 16
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

FUNDS AND PERSONAL PROPERTY
, PolIcy:

All facilIIiM . . Implement procedures to conlrol and Ufeguerd cteIalnees' personal ~.
the MCUre storage of fundi , valuables, bIIggage and other petIOn8I PfOPe!rlY; the
document.lioli and receipting of ....'., idenId property; and the lnltilll8rld reg~ ICheduIed lrwemoryIhg of ..
tur.t.. VIIIUabIe8. 8fId aa. property.
1CI8nI 1M: (IGM
~ Check ..... box • ell leE ......... ' - - . V8IuUIee lind 'rap.", ...
hInCIIICI onIr ,,"'.ICE FIIId 0III0e or.....ano.ln oonIIOI 0I1he ....... __
V_ No NA
Detainee funds and valuables are propet1y separated
and stored fNISY. Detainee funds and valuables are
181
0
0
~ wiI pIO!IIde for

o ....

........

accessible to designated supervisor(s} only.
Detainees' large valuables are secured in a location
accessible to designated supervisor(s) or processing
staff only.
Staff itemizes the baggage and personal property of
arriving detainees, Induding funds and valuables). E2r
IGSAs and CDFs, using a personal property inventory
form that meets the ICE standard?
Staff forwards an arriving detainee's medicine to the
medical staff.
Staff searches arrMng detainees and their personal
property for contraband.
There is a written policy for retuming forgotten property
to detainees and staff follows procedures?
Property discrepancies are immediately reported to the
CDEO or Chief of Security.
Staff follows written procedures when returning property
to detainees.
CDF/IGSA facility procedures for handling detainee
property claims are similar with the ICE standard.
The facility attempts to notify an out· processed detainee
that he/she left property in the facility.
• By sending written notice to the detainee's last
known address;
• Via certified mail;
• The notice state that the detainee has 30 days
in which to claim the property, after which it will
be considered abandoned.
The facility disposes of abandoned property in
accordance with written procedures.
• If a CDFIIGSA facility, written procedure
requires the prompt forwarding of abandoned
property to iCE.

181

!8l

181

I8J

;\ "....•. FUNDS AND PERSONAL PROPERTY

!8l Acceptable

o Deficient

At-Risk

o Repeat Finding

Remarks: (Record significant facts, observations, other sources used, etc.)
b6, b7c

1~):l.UJo~("
I Date

Page 17
G-324A Detention Inspection Form Worksheet for IGSAs • Rev: 10/18104

GROUP LEGAL RIGHTS PRESENTATIONS

PolICy: FaclIities ho!JaInQ ICE detalneu ahal pefmit.rthorized persons to make presenlatlonsto groupe of
d....... for the purpose of Infanning them of U.s. Immigration law and procedures, conaisIIInt with the
security and ordiJrIy operation of uch fdy. ICE encou,-.ge..uc:h peMntationa, which Inatruct det8lneee
about the Immigration system and thtiIr rfgl'rta and options within It.
181 Check ...... ., No Group P~.. ..,. conduc:e.ctwlhlntlle _12 montIIL MMl_lCIanIa
AccepIabIe ovwaIl and conlin_on with ned portion of worlcilhMt.
r.::- ' -

Compon...

...- - - - -..

.'.

.~--

The Field Office Is responsive to requests by attorneys
and accredited representatives for group presentations.
Upon receipt of concurrence by the Field Office Director,
the facility or authorized ICE Field Office ensures proper
notifICation to attorneys or accredited representatives in
a timely manner.
The facility follows policy and procedure when rejecting
or requesting modifications to objectionable material
provided or presented by the attomey or accredited
representative .
Posters announcing presentations appear in common
areas at least 48 hours in advance and sign-up sheets
are available and accessible.

Documentation is submitted and maintained when any
detainee is denied permission to attend a presentation
and the reason(s) for the denial.
When the number of detainees allowed to attend a
presentation is limited, the facility allows a sufficient
number of presentations so that all detainees signed up
may attend.
Detainees in segregation, unable to attend for security
reasons may request separate sessions with presenters.
Such requests are documented.
Interpreters are admitted when necessary to assist
attomeys and other legal representatives.
Presenters are afforded a minimum of one hour to make
the presentation and to conduct a question-and-answer
session.
Staff permits presenters to distribute ICE-approved
materials.
The facility permits presenters to meet with small groups
of detainees to discuss their cases after the group
presentation. ICE or authorized detention steff are
present but do not monitor conversations with legal
providers.
Group presenters who have had their privileges
suspended are notified in writing by the Field Office
Director or disignee; and the reasons for suspension are
documented. The Headquarters Office for Detention
and Removal , Field Operations and Detention
management Division is notified when a group or
individual is suspended from making presentations.
The facility plays ICE-approved videotaped
presentations on legal rights, at regular opportunities at
the request of outside organizations.
A copy of the Group Legal RIghts Presentation policy,
including attachments, is available to detainees upon
request

Y..

I•

Page 18
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18104

caROW LEGAL RIGHT8 PRESENTATIONS - Rat!

o Deflc:lent

At-RIlk

o ReP"t Finding

Remarks: (Record significant facts, observ81Jons. oth6r sources used. etc.)
b6, b7c

Auditor's S

sture I Date

Page 19
G-324A Detention IDspectJoD Form Worksheet for IGSAs - Rev: 10/18104

•

.,-.--.-~

-.~. - --

;,1

DETAalEE GREVANCE PROCEDURES

l'oIIcJ:

Ev8(y facility will dIMIIop and ImpIament atandI!rd operatkIg procedures (SOPs) for 8ddf8S8ilg ;
.detaNe ~ In timely f8shlon. &ch __ In the proc:eM will occur wtIh1n the prescribed lime bme. .
~ otheftlWlgl, agriedncewllbe pnaaed, investigaKt, and dIIc:ided (eubjactto appal) In IICCOidll..ce
will the SOPs; 11 ~ oomrnIIIH wi! c:aMfI8 as providecIln the SOPs. St8ndan:I procedure will include
~ the daI8Inee wIh • wrIIIIn ,..,... \0 any formal griadllCII, which wi) Inc:bte the t.Ia for the
decialcn. The IacIIIy wi! aIIo 8ItIbIIIh standard procedutaa for handling ernargeney gsfavan!:8II. All
grII!!YIncas \VB receMt aupervfIory 18V1ew. RepriIaI against the flat 01 a ~ wII net be ~
ComponentII
Y
N
NA
RaIMrb
f._ _.. •
Written procedures provide for !he informal resolution
The policy states seven
of oral grievances (Not mandatory).
If yes, the detainee has up to five days within
which to make 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 when preparing a grievance.
• Illiterate, disabled, or non-English·speaking
detainees receive special assistance when
necessary.
Every member of the staff knows how to identify
emergency grievances, Including the procedures for
expeditina them .
There are documented or substantiated cases of staff
harassing, disciplining, penalizing, or otherwise
retaliating against a detainee who lodges a complaint.
If yes, explain .
Procedures include maintaining a Detainee Grievance
Log.
If not, an alternative acceptable record keeping
system is maintained.
• ·Nuisance complains· are identified in the
records.
• For quality control purposes, staff documents
nuisance complaints received but not filed.
Staff is required to forward any grievance that indudes
officer misconduct to a higher official or, in a CDFIIGSA
facility, to ICE.

•

r8I

0
I

r8I

[81

r8I

days but the staff and the
handlJool( state 5. Staff
slate the policy wiD be
changed soon.
Detainee's have access to
a grievance cordinator.

•

"'.. - .---"'- DETAINEE GRIEVANCE PROCEDURES

r-"',.,.,..,,,...,.,--:-:----:--c--~......,--·-·---·~-T-r-~·--·--·-··--

o Deflclent

t8I Acceptable

o At~l.k

,< ''.

.' 0' ''' ,

o R.epeat Finding

Remarks: (Record significant facts, observations, other sources used, etc.)
b6, b7c

- ""-.- ...- .. - -

}Opu ) oS

Auditor's Signature f Date

Page 20
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18104

•

E"-'--'

ISSUANCE AND EXCHANGE OF a.O~ING., BEDD:lNG., AND TOWELS

:POlICY: ICE requnslt1at all fIIciIties houUlg Ice ~ pn:Mde~ clothing, bedding, linens and wei.

f 10 .-y ICE detainee iJpOr) amvaJ, Fur1herJ fIIcIties shaH provIda Ice detaIr)ees with r8Qular exchanges of
. cblhing, ....ens. and towels foJ _long .. they rem8in In~ .
CompoI ......
No
NA
A.....yThe 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 reauired for the number of detainees,
All new detainees are issued clean, temperatureappropriate, presentable clothing during In-processing.
Detainees receive
One uniform shirt and one pair of uniform pants
or one jumpsuit
One pair of socks,
One pair of underwear (Dally change),
• One pair of facility-issued footwear.
Additional clothing is available for changing weather
conditions or is seasonally appropriate,

•

•
•
•

New detainees are isSued clean bedding, linens and
towel. They receive at a minimum:
• One mattress
• One blanket
• Two sheets
• One pillowcase
• One towel
• Additional blankets are issued based on local
weather conditions.
Detainees assigned to special work areas are clothed in
accordance with the requirements of the job,
Detainees are provided clean clothing , linen and towels,
• Socks and undergarments - exchanged daily.
Outer garments - twice weekly,
• Sheets - weekly.
• Towels - weekly.
Pillowcases - weekly,
Food service detainee volunteer workers permitted to
exchange outer garments daity,
Volunteer detainee workers are permitted to exchanges
of outer garments more frequenUy,

l8I

rzI

l8I

Staff stata that detainee's
can purchase sweatshirts
at the commissary.

•

!8l Acceptable

o Deficient

o At-Riek

o Repeat Finding

Remarks: (Record significant facts, observations, other sources used, etc.)
b6, b7c

Auditor's Signature { Date

Page 21
~314A

Detention lDspectIon Form Worksheet for IGSAs - Rev: 10118104

•

MARRIAGE REQUESTS

f. ..

" i:-

"Policy: AI d!tWnee mantllge requests wiIIl'8C8Ive c:ase-by-case <:OOIIideration from ICE management
y
Components
N
NA
rt.marb
._.~'-.-.-.--..
The Field OffIce considers detainee marriage requests
~
0
0
on a case-by-case basis.

The Field Office Director reviews every marriage
request rejected by a Warden/OIC or IGSA. Rejections
are documented .
It is standard practice to require a written request for
permission to marry.
The written request includes a signed statement or
comparable documentation from the intended spouse,
confirming marital intent.
The Warden/OIC provides a written copy of hlslher
decision to the detainee and hislher legal representative.
When permission is denied, the Warden/OIC states the
basis for hislher decision .
The WardenfOIC provides the detainee with a place and
time to make wedding arrangements.

t ·•.. ····

::i

t8] Acceptable

t8]

MARRIAGE REQUESTS

o Deficient

o At-Risk

o Repeat Finding

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

b6, b7c

Page 22
G-324A Detention Inspedion Form Worksheet for IGSAs - Rev: 10/18104

.
': \:.

NON-IIElllCAL EMERGENCY ESCORTED TRIPi
Policy: The Imm~1'8IIon and CuatDnw Enforcement (ICE) may provide . . . . . WIth ataff-escorted ~ inID .
\tie community for the purpoee of visiting CI1tic:8Iy ill mem_ of the detainee's immediate family, or for
attending funeralS.

ltinclard NA: Check ..11 box IfIillIC£Non ... dIaI EnIergMcJ EecortedTrlpa ... MndleclOIIIf..,
the ICE field 0III0e or 8uboOf11Oe In c:a*ol or the ........ C8N.
NA
yNo
RInIaIb .•
CoftIFIIrii
The Warden/OIC considers and approves, on a caseby-case basis, trips to immediate family member's:
• Funeral
• Deathbed
The facility recognizes mother, father, brother, sister,
spouse, child, stepparent, and foster parent as
"immediate fam~i':
The CDFflGSA facility notifies ICE of all detainee
requests for non-medical escorts.
The Field OffICe Director is the approving official for
non-medical escorted trips.
The detainee's Deportation Officer reviews the fde
before forwarding a detainee's request, with
recommendation, to the approving official. Each
recommendation addresses the individual's suitability for
travel e.g., the kind of supervision required .
Detainees who require overnight housing are placed in
approved IGSA facilities.
Each escort includes at least two officers.
• The detainee remains under constant, direct
visual supervision of escorting staff.
Escorting officers report unexpected situations to the
originating facility as a matter of procedure and the
ranking supervisor on duty has the authority to issue
instructions for completion of the trip.
Escorting officers have the discretion to : a. Increase or
decrease minimum restraints in accordance with written
instruction, procedures and classification level of the
detainee.
Escort officers do not accept gifts/gratuities from a
detainee, detainee's relative or friend for any reason.
Escort officers ensure that detainees:
• Conduct themselves in a manner that does not
bring discredit to the ICE.
• Do not violate federal, state, or local laws.
Do not purchase, possess, use, consume, or
administer narcotics, other drugs, or intoxicants.
• Do not arrange to visit family or friends unless
approved before the trip.
• Make no unauthorized phone calls .
• Know they are subject to search, urinalysis,
breathalyzer, or comparable test upon return to
the faCility.
Standard procedure requires the immediate return to the
facility of any detainee who violates trip rules.

[8J

[8l

[8J

[8l

I2l

Page 23
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: IO/18f04

123 Acceptable

o Deficient

Al-Risk

o Repeat Finding

Remarks: (Record significant facts, observations, other sources used, etc.)
b6, b7c

Auditor's Signature I Date

Page 24
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10118104

•

RECREATION
Policy: It Is ICE poIicy1O proYide IICC8U to recreational program' and activities to .. ICE detainees, IQ !be

exI8nt ponibIe. under condlllon& of 8ec:urity and supervision that protect !heIr safety and welfare.

CompoI .....

RwNtb

Does the facHity provide:
An indoor recreation program?
0
0
181
• An outdoor recreation program?
A recreational specialist (for facilities with more than 350
detainees) tailors the program activities and offerings to
0
181
0
the detainee population.
Regular maintenance keeps recreational facilities and
0
0
181
equipment in good condition.
The recreational specialist or trained equivalent
181
0
0
supervises detainee recreation workers .
The recreational specialist or trainee equivalent
oversees recreation programs for Special Management
181
0
0
Unit and special-needs detainees.
Dayrooms offer sedentary activities, e.g., board games,
181
0
0
cards, television .
[2$]
Outside activities are restricted to limited-contact sports.
LJ
LJ
Each detainee has the opportunity to participate in daily
0
0
181
recreation.
Detainees have access to recreation activities outside
the housing units for at least one hour daily, 5 days a
0
0
181
week.
Staff checks all Items for damage and condition when
181
0
0
equipment is returned .
Staff conducts searches of recreation areas before and
181
0
0
after use.
[2$]
All recreation areas under constant staff supervision.
LJ
LJ
[l
Supervising staff is equipped with radios .
181
Unless inclimate weather.
The facility provides detainees in the SMU at least one
hour of outdoor recreation time daily, five times per
181
0
0
week.
Detainees in disciplinary/administrative segregation
receive a written explanation when a panel revokes
181
0
0
hislher recreation privil6(les.
Special programs or religious activities are available to
0
0
181
detainees.
Volunteers are required to sign a waiver of liability
before entering a secure portion of the facility where
181
0
0
detainees are present.
Visitors, relatives or friends are not allowed to serve as
0
0
181
volunteers.
~ If outdoor recreation 18 offered cheek this box. No further InfOl'mlltion IS required when outdoor
recreatIon Is offend.
If the facility has no outside recreation, are detainees
considered for transfer after six months?
0
0
0
If yes, written procedures ensure timely review
of all eliQible detainees.
Case officers make written transfer recommendations
0
0
0
about every six-month detainee to the OIG.
The OIG documents all detainee-transfer decisions,
0
0
0
whether yes or no.
The detainee's written decision for or against an offered
0
0
0
transfer documented in hislher A-file.

•

Page 25
G-324A Detention Inspectton Form Worksheet ror IGSAs - Rev: 10/18104

•

~~~

Policy: It !lICE policy ID provide 8CCiIU lD rec:reetionaI propma end actMtIes to WI ICE detainees, to the
! extent poaible undet conditionl Of aecOOty and lupervja\Or! 1hat proIa<:t theIr I8fety and welfare.

Staff notifies the detainee's legal representative of
hisJher decision to accepUdecline a transfer.
If no recreation is avaHable, the ICE District routinely
review transfer eligibility for all detainees after 60 days.
Does the A-file of every detainee is held more than 60
days without access to recreation contains either a
transfer-waiver signed by the detainee or the OIC's
written detenmination of the detainee's ineligibility for
transfer.
The detainee's legal representative is notified of the
detalnee'slOIC's decision.

0
-

0
" - - ----:l
1

o Deficient

o At-RJlk

o R.epeat Finding

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

b6, b7c

Auditor's

Ignature I Date

Page 26
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10118/04

OJ.

RELIGIOUS PRACTICES

cletllineee of ... faiths with re8IOnIIbIe 8fId equllllble QPP!OI1unltias to !
participa,1n the practicea ofthelrfallh, limilad only by the COI'tIIIlliliti of ufity, secunty.lt1eordef1y opII8liona
ofb facility and budgIC8ry c:onatdenIIIarI

Policy: F. . . wiI provide ICE

.....

~
Detainees are allowed to engage in religious aervlces.
Space is available for detainees to conduct religious
services.
The taclily allows detainees to observe the major "holy
days· of their religious faith .
List any exceptions.
'The facility accommodates recognized ho/y-day
observances by:
Providing special meals, consistent with dietery
restrictions .
Honoring fasting requirements.
Facilitating religious services.
Allowing activity restrictions.
Each detainee is allowed religious items in hisJher
immediate POSS8Ssion.
Volunteer's credentials are checked and verified before
allowing participation in detainee programs.
Members of faiths not represented by clergy conduct
may request to present their own services within security
allowances.
Detainees in the Special Management Unit to partiCipate
in religious practices unless otherwise documented for
the safet}! and security of the facility.

•
•

1'81

[]

181

RwDatb

•

f8I Acceptable

o DeficIent

o At-Rlak

o Repeat Finding

Remarks: (Record Significant facts, observations. othar sources used, etc.)
b6, b7c
/4):20 )0.5
Auditor'signature I Date

Page 27
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18104

DETAINEE TELEPHONE AC?CE88

pennit deWinees' reasonable and equilable access to

Polley: All facilities housing ICE. aetai1ees
telephones.

181

I:SI

181

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

181

The facility administration promptly reports out-of-order
telephones to the facility's telephone service provider.

181

The facility administration monitors repair progress and
take appropriate measures to ensure that the required
repairs are begun and completed timely.

181

Detainees are afforded a reasonable degree of privacy
for legal phone calls .
A procedure exists to assist a detainee who is having
trouble placing a confidential call.
The facility provides the detainees with the ability to
make non-collect (special access) calls .

181

Special Access calls are at no charge to the detainees.
In facilities unable to fully meet this requirement initially
because of limitations of Its telephone service, the ICE
makes alternate arrangements to provide required
access within 24 hours of a reQuest by a detainee.
No restrictions are placed on detainees attempting to
contact attorneys and legal service providers who are
on the approved "Free Legal Services List".
Special arrangements are made to allow detainees to
speak by telephone with an immediate fam ily member
detained In another Facility.
Any telephone restrictions are documented.
The facility has a system for taking and delivering
emergency detainee telephone messages .

181

I:1SJ

181

Components
Detainees are allowed access to telephones during
established facility waking hours.
Upon admittance, detainees are made aware of the
faCility's telephone access policy.
Access rules are posted in housing units .
The facility makes a reasonable effort to provide key
information to detainees in languages spoken by any
sig nifleant portion of the facilitY'_s OODulation.
Telephones are provided at a minimum ratio of one
telephone per 25 detainees in the facility population.

Emergency phone call messages are immediately
given to detainees.
Detainees are allowed to return emergency phone calls
as soon as possible.
Detainees in disciplinary segregation are allowed
phone calls relating to the detainee's immigration case
or other legal matters inciuding consultation calls .
Detainees in disciplinary segregation are allowed
phone calls to consular/embassy officials.
Detainees in disciplinary segregation are allowed
phone calls for family emergencies.

Retnarb

Please see remarks
below

Page 28
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10118/04

DEnlNEE TELEPHONE ACCESS

' Policy: AI facilities housing ICE det8lnees wit permit detainees' fUI(In8bIe and equitable aoceu to
talep/'ionel.

Components
Detainees in administrative segregation and protective
custody afforded the same telephoning privileges as
those in general population.
When detainee phone calls are monitored. notification
is posted by detainee telephones that phone calis
made by the detainees may be monitored. Special
Access calls are not monitored.

181

RMnarb

DETAINEE TELEPHONE ACCE88

181 Aec:eptable

o Deficient

o At-RJt,k

o Repeat Finding

Remarks: (Record significant facts, observations, other sources used, etc.)
The facility recently moved the television sets approximately 25 feet f2W8y from the existing telephone
location. Verification with detainees in two units revealed that the movement of the television sets has helped
in allowing more privacy during use of the telephones.
b6, b7c

Page 29
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18104

Policy: ICE n

7;-

-/-'.

VlSlTAnON

il pei'm/tdetalnees to'villltwith family, fr'Iendl,legal ~. special fmereetgroupa and

the IMIW8 media.
ComponenJII
There is a written visitation schedule and hours for
aeneral visitation.
The visitation hours tailored to the detainee population
and the demand for visitation.
The visitation schedule and rules are available to the
public.
The hours for all categories of visitation are posted in
the visitation waiting area.
A written copy of the rules regulating visitation and the
hours of visitation is available to visitors.
A general visitation log is maintained.
The detainees are permitted to retain personal property
item specified in the standard.
A visitor dress code is available to the public.
Visitors are searched and identified according to
standard requirements.
The requirement on visitation by minors is complied
with.
At facilities whare there is no provision for viSits by
minors, the ICE arranges for visits by children and
stepchildren, on request, within the first 30 days.
After that time, on request, ICE considers a transfer,
when poSSible, to a fecility that will allow minor
visitation. At a minimum, monthly visits are allowed.
Detainees in special housing afforded visitation.
Legal visitation is available seven (7) days a week,
including holidays.
On regular business days legal visitation hours provide
for a minimum of eight (8) hours per day and a
minimum of four hours per day on weekends and
holidays.
On regular business days, detainees are given the
option of continuing a meeting with a legal
representative through a scheduled meal.
Private consultation rooms are available for attomey
meetings. There is a mechanism for the detainee and
hislher representative to exchanae documents.
There are written procedures governing detainee
searches.
When strip searches are required after every contact
visit with a legal representative, the facility provides an
option for non-contact visits with legal representatives.
Prior to each visit, legal servica providers and
assistants are identified per the standard.
The current list of pro bono legal organizations is
posted in the detainee housing areas and other
appropriate areas.

r8I

[8J

r8I
r8I

0
0
0

r8I

[8J

0
0
0
0
0

[8J

r8I

[8J

r8I

[8J

r8I

[8J

r8I

[8J

Pat down searches only
unless probable cause
dictates a ~_ search.

Page 30
G-314A Detention Impection Form Worksheet for IGSAs - Rev: 10/18/04

•

Vlln'ATION

PoJlcy: ICE shaIIl penM detail MMIS to VIsit with t.mlly, friends, legal repmentatives. spec:.ial1nI8test WOUPi n
the news mecIla.
The decision to permit or deny a tour Is not delegated
~
0
0
below the level of Field OffIce Director.
Provisions for NGO visitation as stated in the Detention
Standards are complied with.

Law enforcement officials, requesting to visit with a
detainee, are referred to the ICE Field OffICe for
approval.

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

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

VISITATION

o Deficient

18! Acceptable

Al-Risk

o Repeat Flndln

Remarks: (Record significant facts, obseNations, other sources used, etc.)
b6, b7c

~ /:>0 )65

Auditor's Signature 1Date

Page 31
G-324A Detention lnspec:tion Form Wor ksheet for IGSAs - Rev: 10/18104

)

VOWNTARYWORK PROGRAM

Policy: In every'fac:iiJy offering a vduntary work program, ICe detainees wII h.ve the opportunity·to wotk and
...um money by p8(ticIpeling. WhIle not legally r8qUlred. ICE affords detainee workeB basic Occupational
Safety and Health Administration (OSHA) protections.

o ChIck here If ICI! ~ .... not authorized to wortt -* the IG8A t.cllily. IIMl NA on Form G32AA, PI"- 3 Md move to next HCtIon.

ComPGMnta
Does the facility have a voluntary work program?

• Do ICE detainees partidpate?
Detainee housekeeping meets neatness and deanliness
standards.
Detainees have the opportunity to participate in special
details. however, are never allowed to work outside the
secure perimeter.
Written procedures govern selection of detainees for the
Voluntary Work Program.
The same procedures apply for replacement
workers as for "new" workers.
• Staff follows written procedures.
Where possible, physically and mentany challenged
detainees participate in the proQram.
The facility complies with work-hour requirements for
detainees, not exceeding:
• Eight hours a day.
• Forty hours a week .
Detainee volunteers generally work according to fIXed
schedule.
If a detainee is removed from a work detail. staff places
the written justification for the action in the detainee's
detention file.
Staff. in accordance with written procedure, ensures that
detainee volunteers understand their responsibilities as
workers before they join the work proQram .
The voluntary work program meets:
• OSHA standards
NFPA standards
• ACA standards
Medical staff screens and formally certifies detainee food
service volunteers.
Before the aSSignment begins
• As a matter of written procedure
Detainees receive safety equipment! training sufficient for
the assiQnment
Proper procedure is followed when an ICE detainee is
injured on the job.

·
·

181

[8l

181

[8l

181

Page 32
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18(04

fhmarb

1181 Acceptable

, ' .0

-,r..

Oef1cIent

VOLUNTARY WORK PROGRAM

At-RJaK

••

Repeet Finding

Remarks: (Record significant feets, observations, other SOUfC6S used, etc.)
b6, b7c

Auditor's Signature I Date

Page 33
G-314A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18104

Section II
Health Services
Standards

•
Page 34
G-3l4A Deteatioa lDapec:doa FOnD Worbheet for IGSAI - Rev: 10ll81D4

,""

.:'

•

. ... . .

c·...

Poley: All facilities will foIIOW;~ . ~Uldelinesfor:the~I .and admin ~. management of IC,E
detainees engaging in hunpel' ~; ! .By monitorlngpf~i~' and ..w.tfare of the lndlviduaJ detainees,
, racIIItIes will strfve to sustain,their lives. ';'':'"
. .' .
. . '., '
~_c ,,__
Componer6__ ":i,;i;::;; ,.".....
..: ..... ' . < :v','
N i, NA
When a detainee has refused food for 72 hours, it is
standard practice for staff to refer himlher to the medical
department

I8J

o o

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

o o
o o
o o

The facility has established procedures to ensure staff
respond immediately to a hunger strike.
Policy and procedure require that staff isolate a hungerstriking detainee from other detainees.
•
If yes, in an observation room?
Medical personnel are authorized to place a detainee in
the Special Management Unit or a locked hospital room .

o
o
o
o
o
o
o o

o
o
o
o
o
o

Medical staff records the weight and vital signs of a
hunger-striking detainee at least once every 24 hours.
The OIC of the facility obtains a hunger striker's consent
before medical treatment.
A signed Refusal of Treatment form is required of every
detainee who rejects medical evaluation or treatment.
During a hunger strike, staff documents and provides
the hunger-striking detainee three meals a day.
Staff maintains the hunger striker's supply of drinking
water/other beverages.
During a hunger strike, staff removes all food items from
the hunger striker's living area.
Staff is directed to record the hunger striker's fluid intake
and food consumption, does staff always use Hunger
Strike Monitoring Form 1-839. IGSA's use a similar
form.
The medical staff has written procedures for treating
hunger strikers.

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

DIHS Policy and
Procedure 8.14
DIHS Policy and
Procedure 8.14
DIHS Policy and
Procedure 8.14
For medical isolation per
DIHS Policy and
Procedure 8.14
Patient Records
Patient Records
Patient Records
Patient Records

DIHS form 1-839

o o
o o

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

Staff Interviews

o o

DIHS Policy and
Procedure 8 .14

Initial and Refresher
Training

. HUNGER 8TRJKE8 .'

o D.tk:1ent

o At-RJ8k

o ~peat Finding

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

Page 35
G-3UA Detention IupeetioD Fora Worbbeet for IGSAI • Rev: 10118104

m 1-839, Staff interviews
b6, b7c

b6, b7c

Page 36
G-314A Detention InspeetIoa Form Worblleet for IGSAs • Rev: 10118104

{l
y~;:

.........

ACCI!S8 TO IIIEDICAL CARE ' .. !:

"',,"

,','

PolIcy: EYeIY t.ciIily wi establish and maintain 8n accredJt8dlaccrad~~worthyhealth programfo(!"8
general well-being of ICE detai)ees
. ,.. /'
' . . ...
.
:. ",.,," ""

I.":'

>." CompoI..m.
operate a health care facility in compliance
with State and Local laws and guidelines.
The facility's in-processing procedures of arriving
detainees include medical screeninQ,
All detainees have access to and receive medical care,
~

The facility has access to a Managed Health Care
Coordinator.
The medical staff is large enough to provide, examine,
and treat the facility's detainee population.
The facility has sufficient space and equipment to afford
each detainee privacy when receiving health care.
The medical facility has its own restricted-accass area,
The restricted access area Is located within the confines
of the secureJ:>erimeter.
The medical facility entrance includes a holdinglwaiting
room.
The medical facility's holdinglwaiting room under the
direct supervision of custodial staff.
Detainees in the holdlnglwaiting room
have access to a toilet and a drinking fountain.
Medical records are kept apart from other files. They
are:
• Secured in a locked area within the medical
unit.
• With physical access restricted to authorized
medical staff.
• Procedurally, no copies made and placed in
detainee files,
Pharmaceuticals are stored in a secure area.
Medical screening includes a Tuberculosis (TBl test.
• Every arriving detainee receives a TB test.
• During the admission process,
• Detainee's TB-screening does not occur more
than one business day after hisJher arrival at the
facility.
• Detainees not screened are housed separate
from the general population.
All detainees receive a mental-health screening upon
arrival. It is conducted:
By a health care provider or specially trained
officer;
• Before a detainee's assignment to a housing
unit.
The facility health care provider promptly revieNIS all 1794s (or equivalent) to identify detainees needing
medical attention .
The health care provider physically examines/assesses
arriving detainees within 14 days of admission/arrival at
the facility.

N/"

R8marb

[81

Staff Records

[81

Direct Observation

[81

General Population and
Segregation
Captain Sorenson, MCC

[81

Vem Vacancies

[81

Direct Observation

[81

3 separate areas.

[81

2 Post Officers and 1
Roving Officer
Direct Observation

Direct Observation

Secure, Limited Access,
Confidential

181

I:8J

[]

181

Secure Space
Chest X-rayon arrival;
separated from other
detainees until cleared

Screened by healthcare
personnel

181

Medical Records Review

181

30 Charts Reviewed. 6
without completed
Physicals after 14 to 60
days.

Page 37
G-314A DetntIoa lnJpeetIou Form Wombed for IGSAI - Rev: 19118104

" "',

"i,

•

, .;. ",,'

,! 'ACCE8& TO

IiIEDICAL CARE

::,:,':,:

,.~~ Every facility wiI estabbh ~nd mai1ta n ilnaccreditlldlac:craditation- health

'geoQ ~ of ICE delajnees. ,, :

;.<" " ' ::j, ,:,:,"

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

' ,, ' " " ' ,

181

,',

Segregation log books

ACcESS TO MEDICAL,CARE

o o.nc:lent

program for the

At-RJak

Remarks: (Record signifICant facts, observations, other SOlirceS used, etc.)

Page 38
G-324A Detention Impectlon Form Worbbeet for IGSAB - Rev: 10/18104

•

30 Charts Reviewed; 6 wi1hout completed Physicals after 14 to 60 days; Problem is due to 3 provider
vacancies; Plan to remedy is to train RNs to do Well Patient Physical Exams per DIHS policy; DIHS Policy
and Procedure 8.14, DIHS Form 1-819, 1-813, USM 553, Staff and detainee Interviews, Log books
b6, b7c
b6, b7c

re I Date

Page 39
G-314A DeteatioD IBapectioD Fora Worbbeet tor IGSAs - Rev: 10118104

e
~--~--

1'-.

, : ;"t'

\}?"! :

IUICI)I!

------

.".
. . ".

PREVENTION AND INT!RVl!N11ON

-1
i

PolIcY:

AJ det8ntion IIfaf'f wor1dng With ICE detainees wi be tnIined to recognize suiclde-fjsk ind'lCStors. Staff {
~ handle polItntially suicidallrJdiVidUaIs with sensitivity. SUperVision. am l8femlIs. A cinically $UicldaI deIainee '
;Wi11 receive pnN'entive supeIVIiion ~ treatment
'.
y
.....•
.:,:.,
CompoI.....
N
NA
" . :-C." .
.
,,*,-rb _~
Every new staff member receives sUicide-prevention
Employee Training
training. Suicide-prevention training occurs during the
~
0
0 Records
employee orientation program.
Training prepares staff to:
Per lesson plans
• Recognize potentially suicidal behavior;
• Refer potentially suicidal detainees, following
~
0
0
facility proced ures;

•

Understand and apply SUicide-prevention
techniQues.
A heaith-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.
Written procedures cover when and how to refer at-risk
detainees to medical staff and procedures are followed .
The facility has a designated isolation room for
evaluation and treatment.
The designated isolation room does not contain any
structures or smaller items that could be used in a
suicide attempt
Medical staff has approved the room for this purpose.
Staff observes and documents the status of a suicidewatch detainee at least once every 15 minutes.

Screened within 12 hours
of arrival

181

DIHS Policy and
Procedure manual 15.15
Room is in intake area
Meets criteria

o AI-Rlak

Approved by Medical
Director
Continuous observation
as reQuired

o RaPMt Finding

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

procedu~5. 15, DIHS Form 1-835. Staff interviews. Medical Records
b6, b7c

b6, b7c

Page 40
G-3l4A Deteatioo IDJpeeUoD Form Worlulbeet for IGSAJ - Rev: 10118104

~ UHI88, ADVANCED DIRECTM!s~ ANlfDeATH .

1:-\ ..~';: . .....
:}~.; .. ,
'

:...·;:·-:·:i:·;·,':·

kPoley AI facilities housing ICE dafaineet IhIII have poIIcIIes 8nd proc:edu.8ddreIaing !he lIauea oftefmiJ'llll
! . 1Ineta « Injury, med1c818dVanced dnctIves, and ctet.inee dNth, to Il1CIude !he procedures to enlUre ~~;:
!.'notification Is provIdecIlio ICE offlcIaIa. famiy membel$ and other inter8lted parties in the event of a detainee!;,
i b,8comlng terminally iI « injured or deeth of a detainee oc:an. In addition, the ~lcy Will cover proced~ to '
be,~ if the death of a detainee occurs while in transit.
. .',
""';':"

.... _ _ doee not 8CCepC ICE d ......... , ~ ... ~ or tIIrInInaIly II,
.11*- NA In .... IIPP'........ boll for ... pcMtk!II of .... ~ ~WAY8 ccnpIeeiId"""'~ .,.
\ to ......... deIIIh end reIIIId nodtIclil:clt.. .. . . •.. . :;.:.:.':. "':u ' . . '., ' .•,:, ' : ,.:
'.:
";
'\-"'
y
N
, , ... . .' CoInponenIiI
NA
'
. RMmIIII,:/
'-;::-, .' ... .. '

d,j,etWcJC'''1a ball I
'. '

Detainees, who are chronically or terminally ill, are
transferred to an appropriate offsite medical facility,
The facility or appropriate ICE office prompUy notifies
the next of kin of the detainee's: medical condition .
• The detainee's location.
The limitations placed on visitinQ.
There are guidelines addressing State Advanced
Directive Form for Impl8menting Living Wills and
Advanced Directives.
The guidelines include instructions for detainees
who wish to have a living will other than the
generic form the DIHS provides or who wish to
appoint another to make advance decisions for
him or her.
The guidelines provide the detainee the opportunity to
have a private attomey prepare the documents,
There is a policy addressing "00 Not Resuscitate
Orders'

t8I
t8I

0
0

•

Detainees with a ''00 Not Resuscitate" order in the
medical record receive maximal therapeutic efforts short
of resuscitation?
The facility notifies the DIHS Medical Director and
Headquarters' Legal Counsel of the name and basic
circumstances of any detainee with a "Do Not
Resuscitate" order In the medical record, In the case of
IGSAs, this notification is made through the local ICE
reQresentative.
The facility has written procedures to address the issues
of organ donation by detainees.
The facility has written procedures to notify ICE officials,
deceased family members and consulates, when a
detainee dies while in Service,
The facility has a policy and procedure to address the
death of a detainee while in transport.
At all ICE locations the detainee's remains disposed of
in accordance with the provisiOns detailed in this
standard,
In the event that neither family nor conSUlate claims the
remains, the Field OffICe schedules an indigenfs burial,
consistent with local procedures,
• If the detainee's is a U.S. military veteran is the
Department of Veterans Affairs notified.
An original or certified copy of a detainee's death
certificate is placed in the subject's a-file.

Medical 'Records
Per DIHS and ICE
policies

Detainee Handbook

t8I

DIHS Policy and
Procedure 2 .6,1
DIHS Policy and
Procedure 2,6.2

t8I

Staff Interviews and
Professional Training
Per DIHS Policy

t8I

I2l

t8I

I2l

DIHS Policy and
Procedure 2.6.4
Per National Detention
Standards Policy
Per National Detention
Standards Policy
Per ICE National Policy

Page 41
G-314A DeteDtioD IDJpeetioD Form Worbbeet for IGSAJ • Rev: 10118104

~:,=--~:';:=':;::~~=~
f noIItk:aIIon Is proYIded 10 ICE officials, family members and other lnterested parties In the event of a detainee
r becoming terminally II or Injured or deeth of a detainee occurs. In addi60n, the policy will cover procedul'8$ ~
,be taken ;If the death of a detainee occurs While in transit.
,,,,:
->;,'

'o : ~ tltll

bolt" ....

fadIIII1 ... not .ccept ICE d ......... who . . eewNIy or ",""Indy II. '.
Ind.... MA In ............. box for ..... portion of·........hMt. ALWAYS ~,a11

to cIMIInee ct.Ih end reIIIIiId "alllle.llon.:":'::·

...---

'. ComponentIa

The facility follows established policy and procedures
describing when to contact the local coroner regarding
such issues as
•
Performance of an autopsy.
• Who will perform the autopsy.
• Obtaining State approved death certificates.
•
Local transportation of the body.
ICE staff follow established procedures to properly close
the case of a deceased detainee.

181 Acceptable

o DefIcient

rwrw.tete

..J"

.;.

,:"";" .

y:.:' N

MA '

I8l

At-Rllk

, .. '.:;... ,"

o Repelt Finding

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

b6, b7c

Page 42
~z.cA Deteadon

.:",.",•

RemarIaa .,.f

IupeetioB Form Worksheet for IGSAa - Rev: 10118104

,,'

-- -~ - - .--

....

Section III

Security and Control

Page 41
G-324A Detention Inspedion Form Worksheet for IGSAs - Rev: 10118104

CONTRABAND
PolIcy; All deIiIi ItIon fa:iIIIIeIa will ensure the proper I'IandO!1g end dispose! d ... oantrIIband. Doc:uIr.-I!IIIIaI i of
cantu_lid dIWuction II requRd.

Componenta
The facility follows a written procedure for handling
illegal contraband. Staff Inventories, holds, and reports
it when necessary to the proper authority for
actionfpoasible seizure. _
Contraband that is government property II retained 8$
evidence for potential disciplinary action or criminal
prosecution.
Staff returns property not needed as evidence to the
proper authority. Written procedures cover the return of
such property.
Altered property is destroyed following dOQJmentation
and usina established Drocedures.
Before confiscating religious items, the OIC or
designated investigator contacts a religious authority.

Staff follows written procedures when destroying hard
contraband thai Is Illegal.
Hard contraband that is Illegal (under criminal statutes)
may be retained and used for official use, e.g. training
purposes.
If yes, under specific circumstances and using
speclfied written procedures. Hard contraband is
secured when not in use.

181

·0

Rematb

COn,

gj Acceptable

o Deficient

At-Risk

o Repeat Finding

Remarks: (Record significant fads, obseNetions, other sources used, etc.)
b6, b7c

\01w ;D;;;

ture I Date

Page 42
G-324A DeteatiDn Inspection Form Worksheet for IGSAs - Rev: 10118/04

•
-

DETEl(nON FLE8

I Poley: Every t.c:iity WIll aeat. dltellIIcn file for w«y ICE deIIIlNe booked Into the faciIly, exdudlng only

detllln... scheduled \0 depart within 24 ho&A The dNnIion file wiD ca1tain copiaand, In some cases.. the
. Offglnel of speciIIed do(:umenIa conc:emIng the deI8in. . . . . . nile fac:J1Ily: cIIiuification sheet, medical
.questionnaire, property ~ sheet, disclplinary docIJmenta, etc.
Y
N
NA
Componen.,

.....,..

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

i8i Acceptable

i ..,

I8l

\\J~
I8l

I8l

181

!81

DETENTtON FILES,

o DeficIent

G 589 and/or I 775 (or
equivalent) are
being
maintained in detention
flies.

At·Risk

o Repeat Finding

Remarks : (Record significant facts, observations, other sources used, etc.)
b6, b7c

Auditor's Signature / Date

Page 43
G-324A Detention In.pectlon Form Worklibeet for IGSAs - Rev: 10/18/04

-.-~ -.- -- - .- - .

DI8CIPlINARY PoUCY

_---_....,...

IPolIcy AInotf8ci11tJes
bcluU'9ICE detafneee ate authorized Impoee~. on . . . . . wtlOIe behavior Is
in
with
rules and regulationl.
to

. ft

faIcIIty

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

IZl

r8l

IZl

r8l

IZl

•

Renwb

·•
•

As per I.C.E. detention
policy.

Page 44
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18104

•

[r'

•
,:'"

DI8CIPLJNARY POUCY

I,:o,!; ~~::"~==-:nd~~ImJlOlS8~ondetaineeawholebehrJlorls
' ~>;i,:,'h '

Compo.,• •

The duration of punishment set by the ole. as
recommended by the disciplinary panel does not exceed
established sanctions. The maximum time in disciplinary
segregation does not exceed 60 days for a single
offense.
Written procedures govem the handling of confidentialinformant Information. Standards include criteria for
recognizing "substantial evidence"
All forms relevant to the Incident, invastigation,
committee/panel reports, etc., are completed and
distributed as required .

!8l

181

Remarb

DISCIPUNARY POLICY

181 Acee

tab I.

o Deficient

At· R1lk

o Re~.t Finding

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

b6, b7c

ure I Date

Page 45
G-324A Detention Inspectlon Form Worksheet for IGSAs - Rev: 10/18/04

EMERGENCY (CONTINGENCY) PLANS

t- ~

It.

,,t Policy AI fIICiIIIiea holding ICE deIaneeI wi! ruponci110 emetv.nc••
, 'MIIh

·PI .....rmlined _ICtal cized plan to
f' minimize !he henning of hlMnan . . and the dellruction 01 property. recamrnendIId that SPes and CDFa
I into ....".nt. vie Memorandum of Undetst8nd1ng (MOU). will federal. leal ."d Itate agencies to aaist In

en_

timesot

Componenta

No Detainee or detainee groups exercise control or authority
over ottler detainees.

181

Disturbance training,

Disseminated during staff
musters.

181

Detainees are protected from :
• Personal abuse
Corporal punishment
Personal injury
• Disease
• Property damage
Harassment from other detainees
Staff are trained to identify signs of detainee unrest.
• What type of training and how often ?
Staff effectively disseminates Information on faci lity climate,
detainee attitudes and moods to ttle 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 development and
Implementation of the plans.
The plans address the following Issues:
• Confidentiality
• Accountability (copies and storage locations)
• Annual review procedures and schedule
Revisions
Contingency plans include a comprehensive general section
with procedures applicable to most emergency situations.
The facility has cooperative contingency plans with
applicable:
• Locellaw enforcement agencies
• State agencies
Federal agencies
All staff receive copies of Hostage Situation Management
policy and procedures.
Staff is tralnad to disregard instructions from hostages,
regardless of rank. Within 24 hours after release
hostages are screened for medical and psychological
effects.
Emergency plans include emergency medical treatment for
staff and detainees during and after an incident.
The food service maintain at leasl 3-days' worth of
emeraencv meals for staff and detainees.
Written plans locate shut-off valves and switches for all
utilities (water gas electric).

•
•

Remarks

-- ---.

•

~rly .

•

Contained in emergency
plans manual.

Page 46
G-324A Detention ImpectioD Form Worksheet for IGSAs - Rev: 10/18/04

1 < ,~i·. .

•

EMERGI!NCY '(CONTINGENCY) PLANS- --

' ..........••••• , .'

! p~1Icy ~1tIes

'i
~

AI
hoIc*lg ICE det1iineeaWill respbnd 10 emergendea with.
pal fD
t1m!"mIze !he harming of hulJ18I'I Ire and the dMtrUction of~. It II recomrnend8Cl1h8t SPCa 8nd CDFs enlIIr :
lnlo agreement. viii MemOl'8nClum ot Und8mandlng (MOU). wfttt federal, 1oc8I and state ~enc:Ies to assist inj

...

, times of

Compon.",.

t:'

RemaJb
Individual plans are In
place for each listed
emergency.

Written procedures cover:
Work/Food Strike
Disturbances
Escapes
Bomb Threats
Adverse Weather
• Internal Searches
Facility Evacuation
Detainee Transportation System Plan
• Internal Hostages
• Civil Disturbances

•
•
•
•
•

•
•

· ·- c - ~ .....- ~

. '."

181 Ace.

tabl.

~ _·-· ·

.....,.- _ _'_----,..,..-_
EMERGENCy (CONTINGENCy) PLANS '

o Oeflt;lent

At·Rllk

o Repelt Finding

Remarks: (Record significant facts, observations, other sources used, etc.)
b6, b7c

nature / Date

Page 47
G-324A Detention lnspe«Ion Form Worksheet Cor IGSAs - Rev: 10/18104

!NVIRONII!NTAL HEALTH AND 8ARTY
PolIcy: Every f8cIIly wII control ftammable, 1DXk:, and C80IIIc rnaIef1aIs through a hazardous materials
program. The program will include, amcng ather things, the ide"tificatioll ancIlabeIing of hazwdoua maI8riIIls In
ec:cordanoe with ~1c8b1e standards (e.g., NaIiona1 Fire Protection AsIocIetion INFPAD; identification of
1ncon)patibIe rnaterII*. aod safe..handIing procedures
Y
N
NA
C.... a.......
The faciity has a system for storing, issuing, and
0
0
~
maintaining inventories of hazardous materials.
Conslant inventorIeS are maintained for aD flammable,
Welghed and Recorded
toxic, and caustic substances usedlstored in each
t8I
0 .0
section of the facility.
The manufacturer's Material Safety Data Sheet (MSOS)
Up to date and on file
file Is up-to-date for every haZardous substance used.
The files list all storage areas, and include a
plant diagram and legend.
0
0
t8I
• The MSp$s and other infonnation in the files
are available to personnel managing the
facility's saf~ progra~ .
All personnel using flammable, toxic, and/or caustic
substances follow the prescribed procedures. They:
• Wear personal protective
t8I
0
0
• Equipment
Report hazards and spills to the
• designated official.
The MSOSs are readily accessible to staff and
t8I
0
0
detainees in the wor1< areas.
Hazardous materialS are always Issued under proper
Issued under sUpelVision
supervision.
only
181
0
0
• quantities are limited.
• Staff always supervises detainees using these
substances.
All "flammable" and "combustible" materials (rlqUid and
aerosol) are stored and used according to label
0
0
I8l
recommendations.
Lighting fixtures and electrical equipment are installed in
storage rooms and other hazardous areas meet
I8l
D 0
National ElectJical Code reQuirements.
All toxic and caustic materials stored in their original
I8l
0
0
containers in a secure area.
Excess flammables, combustibles, and toxic liquids are
I8J
D 0 Vendors, County, etc
disposed of properly and in accordance with MSDSs.
Not applicable
Staff directly supervises and accounts for products with
methyl alcohol. Staff receive a list of products
containing diluted methyl alcohol, e.g., shoe dye. All
0
0
I8J
such products clearly labeled as such. "Accountability"
includes issuing such products to detainees in the
smallest worI<able quantities.
Every employee and detainee using flammable, toxic, Of
Training Records
caustic materials receives advance training in their use,
181
0
D detainees and officers
storage, and disposal.
The facility complies with the most current edition of
Manuals on file
applicable codes, standards, and regulations of the
181
D 0
National Fire Protection Association and the
Occupational Safety and Health Administration (OSHA).
A technically qualified officer conducts the fire and
I8J
0
D OHSA Trained
safety inspections.

........

•

Page 50
G-3l4A Detntloa lMpecUoB Form Worblleet lor IGSAa - Rev: 10/lBlO4

•

.••. .•.• ENvItoNMENTAL HEAL1M AND SAFETY

Po.cr.' .E~ flldttywill COntro!~. toxic, 8Ilct caustic maI8riaIs through

hazardous materials,'

pqram. The program wi. inclUde, among other things, theldentlllc:ation and 1abeIi)g of hazardous rnaIIIriaIa 1'1 '

,ac:C:oI'd8nc:eWlth applicable standards (e.g., NationaI . Fii'Q Protection Associ8tion lNFPAD; ldentfflcationof ;
Jncompatible materials, and I8fe-h8ndling procedures .•.
·· 't·,
CompoMnta
'"
. : .• ; \
The Safety Office (or officer) maintains files of
inspection rePOrts: Including corrective actions taken .
The facility has an approved fire prevention, control, and
evacuation plan.
The plan requires:
•
Monthly fire inspections.
•
Fire protection equipment strategically located
throughout the facility.
•
Public posting of emergency plan with
accessible building/room floor plans.
•
Exit signs and directional arrows.
•
An area-specific exit diagram conspicuously
POSted in the diagrammed area.
Fire drills are conducted and documented monthly.
A sanitation program covers barbering operations.
The barbershop has the facilities and equipment
necessary to meet sanitation rl!guirements.
The sanitation standards are conspicuously posted in
the barbershop.
Written procedures regulate the handling and disposal
of used needles and other sharp objects.
All items representing potential safety or security risks
are inventoried and a designated individual checks this
Inventorv weekly.
Standard cleaning practices include:
• Using specified equipment; cleansers;
disinfectants and detergents.
• An established schedule of cleaning and foIlowup inspections.
The facility follows standard cleaning procedures.
Spill kits are readily available.
A licensed medical waste contractor disposes of
infectiouslbio-hazardous waste .
Staff are trained to prevent contact with blood and other
body fluids and written procedures are followed .
Do the methods for handling/disposing of refuse meet
all reQulatorv rSQuirements.
A Iicensed/CertifiedlTrained pest-control professional
inspects for rodents , insects, and vermin .
• At least monthly.
• The pest-control program includes preventive
spraying for indigenous insects.
Drinking water and wastewater is routinely tested
accordina to a fixed schedule.
Emergency power generators is tested at least every
two weeks.
• Other emergency systems and equipment
receive testing at least quarterly.
• Testing is followed-up with timely corrective
actions (repairs and replacements).

.'.' --'. \

181

"-"alb.:

L •

·•• ~ i

Inspections on file

Reports on file and up to
date

o o
[J

[]

181

I8J
I8J

[J
[J

181

Barber shops in
compliance

Standards posted

Inventories up to date

181

Contract on file

Contract and findings on
file (recent rodent
problem ; resolved)

County facility George
baily supplies Emergency
Power

Page 51
G-324A Detentioa IBtpectioIl Form Worbheet for IGSAa - Rev: 10118104

o o.tIdent

181 Acceptable

o At-bk

o RepMt Finding

Relnarb: (Record significant facts, obssNations, other sources used, etc.)
DIHS Policy and Procedure Manual Chapter 7, DIHS Standard Operating Procedures 7.3.2.1 , 7.3.2.1.1 ,
; on view
7.3.6.1 .1; Log Books and Reports from CCA Environmental and Safety Officer Mr
b6, b7c
; continuous inventory log books
b6, b7c
b6, b7c

Auditor's Signature 1 Date

Page 52
G-3l4A Deleatioa IDJpection Form Worksbeet for IGSAs - Rev: 10/181114

HOLD ROOMS IN DETENTION FACILIT1E8

PolIcy: Hold rooms WiJI be ~ only for lIImpcnIy detention for detaineea awaiting 1'8f'I1CMI1, transfer EOIR
t-rtngI, medl!:al tre8tment,1ntra-facIlIty mcMment. 0( other praceuing InID 0( out of the fKility.
,
N
NA
Renwrtcs
Components
Y
The hold room is situated in a location within the secure
perimeter.
The hold rooms wen ventilated, well lighted and all
activatimswitches located outside the room .
The hold rooms contain sufficient seating for the
number of detainees held.
No bunks/cotsJbeds or other related make shift
sleeping apparatuses are permitted inside holdroorns.
The walls of the hold roorns escape proof.
• The hold room ceilings are escape and tamper
resistant.
Individuals are not held in hold rooms for more than 12
hours.
Male and femeles are segregated from eacl1 other at
all times.
Every effort Is made to ensure that detained detainees
under the age of 18 are not held with adult detainees.
Detainees are provided with basic personal hygiene
items such as water, soap, toilet paper, cups for water,
feminine hygiene items, diapers and wipes.
In older facilities officers are within visual or audible
range to allow detainees access to toilet facilities on a
@gular basis .
All detainees are given a patdown search for weapons or
contraband before being 'placed in the room.
OffICers closely supervise the detention hold rooms
using direct supervision (Irregular visual monitoring.).
• Hold roorns are irregularly monitored every 15
minutes.
• Unusual behavior or complaints are noted.
When the last detainee has been removed from the
hold room, it is given a thorough inspection.
Cleaning.
Evidence of tampering with doors, locks,
windows , grills, plumbing or electrical fixtures is
reported to the shift supervisor for corrective
action or repair.
There is a written evacuation plan.
• There is a designated officer to remove
detainees from the holdrooms in case of fife
and/or building evacuation.
An appropriate emergency service is called
immediately upon a determination that a medical
emergency may exist.

•
•

181

t8:l

181

[gI

181

t8:l

IZl

t8:l

181

[gI

, .. . . . ": ).(

181 Acceptable

o Deficient

At-RI.s k

o Repeat FIndings

Page 51
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

•

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

•

b6, b7c

Auditor's Signature I Date

Page 52
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

•

, ;;:·.·r···.+..; ·:. ---·-:~--~~-

. ".

KEY AND LOCK coNtRoL.

(SECURITY. ACCoUNTABLITY AND MAINTENANCE)

Policy II • ~ policy of the ICE ServIce 110 maintain

r mainteMnCe of .. keys and IocI(s

Compoownta

an efficient

~m for the use, 8CCOUntabl itY end .

The security offIcer[s], or equivalent in IGSAs, has
attended an approved locksmith training program .
The security officer, Of equivalent in IGSAs, has
responsibly for all administrative duties and responsibilities
relating to keys, locks etc.
The security officer, or equivalent in IGSAs, provides
training to employees in key control.

The security officer, or equivalent in IGSAs, maintains
inventories of all keys, locks and locking devices.

t8l

IZI

C8l

f2J

181

f2J

181

f2J

C8l

C8l
C8l
C8l

0
0
0

C8l

RMnadca
Has not attended fonnal
training.

Provided by training
officer. T ng record
verified.

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

0
0

Page 53
G-324A Detention IlI8pedion Form Worksheet for IGSAs - Rev: 10118104

•

KEY AND LOCK CONTROL
(SECURITY, ACCOUNTABILITY AND MAINTENANCE)

f. Policy It is lfIe porlCy of ",. ICE SetvIc:e to maintain an elflclent ayIIem for IfIe use. accoulltability and...

1·

f maintenance of .. keya end 1octcI.

The facility has a key accountability policy and procedures
to ensure key accountability. The keys are physically
counted daily.
All staff members are trained and held responsible for
adhering to proper procedures for the handling of keys.
• Issued keys are retumed immediately in the
event an employee inadvertently carries a key
ring home.
• When a key or key ring is lost, misplaced, or not
accounted for, the shift supervisor is
immediately notified.
• Detainees are not permitted to handle keys
assigned to staff.
... ~-- •..•...,.~--c-~ ....-

[8]

-... - .. ' ---""""~- -

KEY AND L.OCKCONTROL

o Deficient

At·Rlak

Remarb

~""
, ,",
, ,, , .,,,
,,,,.,,,.
.,,,,.....""""'''''''''''~='''--'Cl

,;",.!;

b6, b7c

: /,:.: ;

o Repelt Finding

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

10 1'"W /0')

{ Date

Page 54
G-324A Detention Inspection Form Worksheet for IGSAs • Rev: 10/18104

•
•
1.-.._. . _. . _. --_. _-_. .
I

POPULATION COUNTS

i
1

" they conduct at IeMt one fonNI 0DUJI1 of the detainee popuIII6on per aIift, will additional formal and lnformaI
COunts conducted .. nee
1IIIry
;:
-------..
y
>
...
,
R
.emub
...
N
NA
.
"
_.' '.'
Components
-.'
':\ :'::;i,i',t'L
--0 - "
S iStTCondUCtSaformal ~-atJe8St once each shift.
r8I
Activities cease or are strictly controlled while a formal
0
0
181
count is being conducted.
Do certain operations continue during formal counts.
[] .- [ l
~
~,

--u-

Is a certain amount of movement tolerated during a
formal count.
Format counts in all units take place simultaneously.
Officers do not allow detainee participation in the count.
A face-te-photo count follows each unsuccessful
recount.
Officers positively identify each detainee before
counting hlmlher as present.
Written procedures cover informal and emergency
counts.
• They follCPNed during informal counts .
During emergencies .
The control officer (or other designated position)
maintains an out -count record of all detainees
temporarily leaving the facility.
This training is documented in each officer's training
folder.

181

r8I
t8l

[J
[J

181

[gI

•

181 AcQptab le

o Deficient

At·Rllk

o Rape" Finding

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

b6, b7c

Aud

ure I Date

Page 55
G-324A Detention Inspection Form Worksbeet for IGSA. - Rev: 10118104

.. :'

_ __

•

p o

POST ORDERS

IfIe l

Policy: ICE provides oIJjcers . . necessary guidance fQr C8trying out their dutIea. This.guidar1c8 includes
post 0 ' " est.bIiahed for".,.ry post. WhIch are reviewed lit Ieaat ennually. ~ given to each officer upon
auJgnment to that post.
I
",
Y
N
NA
RetMrb .. ":'-.
Com
i
.
~.--.- -

Every Fixed post haS a set of post orders.
Each set contains the latest inserts (emergency
memoranda. etc.) and revisions.
One individual or department is responsible for keeping
all post-orders current with revisions that take place
between reviews,
The IGSA maintains a complete set (central file) of post
orders ,
The central file accessible to all staff.
The OIC or Contract IIGSA equivalent
initiate/authorizes all post-order changes.
The OIC or Contract IIGSA equivalent has signed and
dated the last page of every section.
A review/updating/reissuing of post orders occurs
regularly and at a minimum annually.
Procedures keep post onders and logbooks secure from
detainees at all times,
Every armed-post officer qualifies with the post
weaPon(s) before assumina post dutv.
Armed-post post orders provide instructions for escape
attempts.
The post orders for housing units track the event
schedule.
Housing-unit post officers record all detainee activity in a
log. The post order include instructions on maintaining
the 100000k.
,

181

Qualification certificates
kept in training folder.

POSTORDERi

o Acceptable

o Deficient

At·RI.k

. ' .

o Repeat Finding

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

b6, b7c

ture I Date

Page 56
G-324A Detention InspectioD Form Worksheet for IGSAI - Rev: 10/18104

. ".':

,~'

"' "

•

.......

8ECURITY INSPECnONS

I will
Policy: Posl~nmenta In the facility'.. h~-risk .rea. WheIw Ipeci8I security prooedu,.. must be followed.
be reatrIcted to
I personnel wiIh a ......... .:..~
in facility :lItI1ltIons.
0

~. - ,

Componenta

The facility has a comprehensive security inspection
policy. The policy specifies:
• Posts to be inspected
• Required inspection forms
• Frequency of inspections
• Guidelines for checking security features
Procedures for reporting weak spots,
inconsistencies. and other areas needing
improvement
Every officer Is required to conduct a security check of
his/her assigned area. The results are documented .
Documentation of securi~inspectlons is keQt on file .
Procedures ensure that recurring problems and a failure to
take corrective action are reported to the appropriate
manager.
The front-entrance officer checks the 10 of everyone
entering or exiting the facility.

Y..

t8I
t8I

t8I

!81

[

t8I

.-.-.

Remartcs

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

Separate logs for each
type of access.

Page 57
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18/04

•

~---",--------- -SE
==C
=-=U
===-I
RITY ~
N8P==
ECTION
===S ' --~'----'

i ;,

t PoI~ Post assignments In the fac:IIlty'a hlglHislt . . . .. where apecIaI aecurtty proCed.... nut be foIowed,
, wli be restrIc:ted to IIlCPIIrIenced

Componenta

I WIIh • thorougl grounding In fIIc:iIllY
y- No NA

Storage and supply rooms; walls, light and plumbing
fixtures, accesses, and drains, etc. undergo frequent,
Irregular searches. These searches are documented.
Walls, fences, and exits, including exterior windows, are
inspected for defects once each shift,
Daily procedures Include:
• Perimeter alann system tests.
• Physical checks of the perimeter fence.
Documentina the results.
Visitation areas receive frequent irregular inspections.

t8J

I:8:J

[]

•

Remarb

Perimeter is also
checked each shift.

SECURITY INSPECTIONS

181 Acceptable

o Deficient

At-Riak

o Repellt Finding

Remarks: (Record significant facts, obseNations, other sources used, etc.)
b6, b7c

IOlu)los-

re I Date

Page 58
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18104

;

" :.;<

<','

.'<

•

SPECIAL MANAGEMENT UNIT (eMU)
Admlnlatratlve s.g,......uon

•

Policy: The Special M8IIIIgeII'TeOt UnIt requintd in every ~lity isolates cettain detainees from the general
popuIdon The Specal ~ Unit wiI consist oJ two.eetlonS. One, AdmInistrative Segr8gllllor1.
I houses detainees IscIa1Ied foIlt)eIr own pcotectioll, ttw oIher for dellII..... being disclpIined for wrongdoing (see
! the "SpecIIII ~negement Unit (DIIcIpIlnary S8grtgd)nt staodard).
CoInponenti
Y
N
NA
Ramarb
The Administrative Segregation unit provides
non-punitive protection from the general population and
individuals undergoing disciplinary segregation.
• Detainees are placed In the SMU
(administrative) in accordance with written
criteria.
In exigent circumstances, staff may place a c1&tainee In
the SMU (administrative) before e written order has
been approved.
• A copy of the order given to the detainee within
24 hours.
The OIC (or equivalent) regularly reviews the status of
detainees in administrative detention.
A supervisory officer conducts a review within
72 hours of the c1&talnee's placement in the
SMU (administrative).
A supervisory officer conducts another review after the
detainee has spent seven days In administretive
segregation.
Every week thereafter for the first month.
• Every 30 days after the first month.
Does each review include an interview with the
c1&talnee.
• Is a written record made of the decision and
the justificetion .
The detainee is given a copy of the decision and
justification for each review.
• The detainee Is given an opportunity to appeal
the reviewer's decision to someone else in the
facility.
The OIC (or equivalent) routinely notifies the Field
Office Director (or staff officer in charge of IGSAs) any
time a detainee's stay in administrative detention
exceeds 30 days.
• Upon notification that the detainee's
administrative segregation has exceeded 60
days, the FD forwards written notice to HQ
Field Operations Branch Chief for ORO.
The OIC or equivalent} reviews the case of every
detainee who objects to administrative segregation
after 30 days in the SMU.
• A written record is made of the decision and
the justification .
• The detainee receives a copy of this record.
The detainee is given the right to appeal to the OIC (or
equivalent) the conclusions and recommendations of
any review conducted after the detainee has remained
in administrative segregation for seven consecutive
days.

•

[8]

rsJ

All detainees must have
written authorization prlor
to placement.

Page 59
G-J14A Detention Iospectlon Form Worksbeet for IGSAs - Rev: 10118/04

SPECIAL MANAGEMENT UNrr (BIIU)
Admlnl8tratlve a.g,.uon

',J

PoIk:y:-The Special Management unlt required In every facility IIoIaIiIIa certain dNlnees from the general
population. The Special Menagement Unit will conailt of two eectIona. One, Admlniatrative Segregation,
houses detainees ItoIated for f1H own pratectIon; holtlei' forcletane. bei(v disciplined for wrongdoing (see
the ·SpecIaI Management Unit 10000001in.ry Segregationr standard).
Y
Relnarb
N
NA
Com~
Administratively segregated detainees enjoy tI1e same
general privileges as detainees In the general
population.
The SMU well ventilated.
• Adequately lighted.
Appropriately heated.
• Maintained in a sanitary condition.
All cells are equipped with beds.
• Every bed securely fastened to the floor or
wall.
The number of detainees in any cell does not exceed
tI1e occupancy limit.
• When occupancy exceeds recommended
capacity. do basic living standerds deciine?
• Do criteria for objectively assessing living
standards exist?
• If yes. are tI1e criteria included in the written
procedures?
The segregated detainees do not have fewer
opportunities to exchangellaunder clothing. bedding,
and linen tI1an detainees in the general_population.
Detainees receive three nutritious meals per day.
From the general population's menu of the day.
Do detainees eat only with disposable utensils.
• Is food ever used as punishment.

•
•

0
Policy/Proccedure does
not allow for exceeding
capacity.

181

•

Each detainee maintains a nonmallevel of personal
hygiene in the SMU.
The detainees have the opportunity to shower
and shave at least tI1ree times a week.
• If not, explain.
The detainees are provided:
• Barbering services.
• Recreation privileges in accordance with tI1e
"Detainee Recreation" standard.
Non-legal reading material.
• Religious material.
• The same correspondence privileges as
detainees in the general population.
• Telephone access similar to tI1at of the general
population .
Persona/legal material.
A health care profeSSional visits every detainee at least
tI1ree times a week.
• The shift supervisor visits each detainee daily.
Weekends and holidays.

•

Disposable utensils are
not used, but are
monitored and
inventoried.
Food is not used as
punishment.

Medical visits are
conducted daily.

•

Page 60
G-324A Detention Inspection Form Worksbeet for IGSAs - Rev: 10118104

SPECIAL IINWJ&ENT UNIT (SIIU)
AdmIIIIIINtIn .............

PaIIcy: The SpeciIII"'IIIgII... 1t UnIt required In.-y _ _ ...... CIItaIn tt.I..... from the general
poJIIlIiIIIan. The SpecaI ~ UnIt wi ~ of two eectIona. One. AdmIniItJative Segregation.
~ ..... _
iIoIIdId tDrtheirown ptotec:tian. theolherfardlllf_ being . . . . . forWfOlIgdoll.a (_
the "Spec:iII ~unIt (DIIc:ipIIMIy 8eg,..uonr.-rd).
y
eon,poneala
N
NA
Remarb
Procedures comply with the "VIsltatlon- standard.
• The detainee retains visiting privileges.
~
0
0
• The visiting room avaHabie during normal
visiting hours.
Visits from clergy are alloWed.
[J
[J
181
Detainees do not have less Iaw-Jibrary access than the
general population.
~
0
0
• Are they required to use the law liJrary
separately. as a group? If so:
• LegcIl materials brought to them.
The SMU maintains a permanent log.
0
~
0
• DetaInee-related actJvlty, e.g., meals served,
recreation visitors etc.
spe Procedures inetude completing the SMU Housing
Record (1-888) immediately upon a detainee's
placement In the SMU.
~
0
0
• Staff completes the form at the end of each
shift.
• eOEs and IGSA facilities use Eorm 1-888 (or
local eouivalent).
Staff record whether the detainee ate, showered,
exercised and took any medication during avery shift.
• logs record aU pertinent information, e.g., a
medical condition, suicidal/essaultive behavior,
etc..

•
•

The medical offlC8l'lheaIth care professional
signs each individual's record during each visit
The housing officer initials the record when all
detainee services are completed or et the end
of the shift.
A new record is created for each week the detainee is
in Administrative Segregation.
• These weekly records are retained in the SMU
until the detainee's retum to the general
population.

I:Sl

.
o DefIcIent

At-Riak

o Repest Finding

Remarks: (Record signifiCBnt facts, observations, other sources used, etc.)
b6, b7c

)

\0 fWlo;"

ure I Date

Page 61
G-314A Deteat10D Iupectioa Fonn WorDbeet for IGSAJ - Rev: 10118104

'UNIT
IPECIAL
(DllclpInIIy . . . . . . . .)

•

PoIIcr. E8Ch _ _

IIIIbIIIh • SpecfalMalIageIII8III UnIt n which lID IIOIaIIt c:ert.n deIaIn8eI from Ihe
gananII populldlon. The 8plcilllMlliIgIftIIftIlJnItwil hIMIlwO-=IonI. one farde'aille.. 1n Adlni""",
SegI....,...,; lhedhlrtDr 4ItIIneIe being ~ lor _ _ .Yre.oM.
eo.p .....
Y
N
NA
0fficerI placing detainees In disciplinary sf98g8llon
follow written .iocedures.
The sanctIont for violations committed during one
Incident do not exceed 60 days.
A
completed
Disciplinary Segregation
Order
accompanies the detainee Into the SMU.
• The detainee receives a copy of the order
within 24 hours of ptacemenl ln disciplinary
segregation.
Standard procedures Include reviewing the cases of
Individual detainees housed In disciplinary detention at
sel intervals.
• After each formal review, the detainee receives
a written copy of the decision and reasons for It.
The conditions of confinement in the SMU are
proportJonal to the amount 0 control necessary to
Protect detainees and staff.
Detainees in disc~linary segregation have fewer
privileges than those housed In administrative
~~tlon.

living conditions In disciplinary SMUs modified to
reinforce acceptable behaVIor.
• If yes. does steff prepare written
documentation for this action.
• Does the OIC sign to Indicate approval.
Every detainee In disc;lpllnary segregation receive the
same humane treatment. reGardless d offense.
The quarters used for segregation are:
• Well-ventilated.
• Adequalaly lighted.
• Appropriately heated.
Maintained in a sanitary condition.
All cells are equipped with beds.
• The beds securely fastened to the oor or waI d
the cell.
The number of detainees confined 10 each cell or room
do nol exceed the number for which the space was
designate.
• Does the OIC approve excess occupancy on a
temPOfaIY basis.
When a detainee is segregated without clothing,
mattress, blanket, or pillow, (In a dry cell setting) a
JualJficatlon is made and the decision Is reviewed each
shift. Items are returned as soon as It Is safe.
Detainees in the SMU have the same opportunities to
exd1ange clothing, bedding, elc. as other detainees.

........

181

t8l

QSl

t8l

All rights and priveleges
accorded general
DODUJation are afforded.
Standard !Mog conditions
are In effect.

•

t8l

Policy and procedure do
not allow for exceeding
rated capacity.

Such confinement is
handled through and
coordinated with madical
deP8ltment

Page 62
~24A

Deteadoa lDspectioo Form Wvrblleet for IGSAJ - Rn: ]011Il104

,;,$

SPECIAL MANAGEMENT UNIT
(DIKIp1inary hgreptlon)

.'~

PolIcY! Each faclIitV wit establish • Special ~ unt In which ~ Isolate certain ~ from the
general population. The SpeciII MaMgement Un wlUhave two Iections, one for detainees in Administrative
Segregatiol'l: the other for detIIneee I*ng Agreg8tild for dilclplnary fMIOIlS.

181

0 '

181

·•

181

•
•

181

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

Remub

•

·
•

181

If alien's security status
precludes law library
access, requested legal
material is brought to
aliens housing location.

Page 63
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 10/18104

SPECIAL IIANAGEIIENT UNIT
(l*cipQrwy 8egNgeIIon)

Poley: Each f8ciI\y Will estabIIIh a ~ MaMgelTlent Unit In wh1ch to iIoInt certain detainee. from the
general population. The Spec:iaI Management Unit wi have two 8ICtions, one for detainees i1 Administrative
Segregation; the other fer detainee. being I8gI1Igated for 4iIcipIiIwry reasons.
y
N
NA
:d Compoa.....
ReJnarb
All detainee-related actMtles are documented. e.g.,
meals served recreation activities visitors, etc.
Is the ~, the Special Management Housing Unit
Record (1-8880r equivalent) is prepared as 600n as the
detainee is placed in the SMU.
All 1-888& filled out by the end of each shift
The CDFIIGSA facility use Form
• 1-888 (or equivalent local form).
SMU staff records whether the detainee ate, showered,
exercised, took medication, etc.
• Details about the detainee logged, e.g., a
medical condition, suicidallviolent 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 until the
detainee leaves the SMU.

•
•

I8l

•

SPECIAL MANAGEMENT UNIT
(Dl8clpllnuy.SegNgllUon)

.:~: :'.--.: ':";::"

. .. "

r",'"

181 Acceptlb le

o Oenclent

o At-Rllk

o Repeat Finding

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

b6, b7c

ure 1 Date

Page 64
G-324A Detention Inspection Form Worksbeet for IGSAs - Rev: 10/18104

•

TOOL CONTROL

PolIcy: It Is the policy of .. t.cIIitieIlhat II empIoy8es-INIII be retpOnIIbIe for complying With the tool control
PoliCy. The Maintanance Supervilor ahaII maIr'ItIIIIl. compufergeneraled or typNrttten MaIIar Irwanto/y lIItof
IoCI!a and equIprner!t and the location In which mota ere stored. TheM jIyentorIes Ih8II be currant. filed and
~..,....,.. for tDoIlnventory and~ during.,.udl.
Y
NA
N
ReIMIb
Com~
There Is an IndMdual who is responsible for developing
a tool control procedure and an inspection system to
Insure accountabilitv.
Department heads are responsible for implementing this
standard in their departments.

TooIlnventor1es are required for:
• Maintenance Department
• Medial Department
• Food Service Department
• Electronics Shop
• Recreation Department

The facility has a facility policy for the regular inventory
of all tools.
• The policy sets minimum time lines for physical
inventory and all necessary documentation.
• ICE facilities use AMIS bar code labels when
required.

[8J

•

Armory

The facility has a tool classiflCStion system. Tools are
classified according to:
• Restricted (dangerousihazardous)

Each department submits
a Inventory on a weekly
basis to the tool control
officer.

Non Restricted (non-hazardous).

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

Detainee tool use under
direct supervision only.

Page 65
G-324A Detention Inspection Form Worksheet for IGS.As - Rev: 10/18104

•
181 Acceptable

TOOL CONTROL

o Deficient

o At-Risk

o Repeat Finding

Remarks: (Record significant facts, observations, other sources used, etc.)
I recommend this element as a "Best Practice" for the following reasons:
The implemetation of a photograph 10 for use as a tool chit for a quick visual reference .
Clean, dear, and concise method for tracking and inventory of tools and restricted equipment
Shadow board for each maintenance personel's individual tool box inventory.
Overall cleanliness and orderly appearance of tool and equipment area.

b6, b7c

ure I Date

Page 66
G-324A Detention Inspection Form Worksheet for IGSAs • Rev: 10/18/04

RTATION
(l;MdT~)

Policy The Immigl'llliOn and Natw.az.tion Service
take .. neceaery precautions to pmtect lhe-lves.
eafiIty. and welfare of our oIIIc:era. the ~ pub/Te, and thole i~ ICE cuatcdy during the tranIIpOI1atIon of
defaIneea. StIIndar:da haw been 8IIabIIbecI for prore.ionaI transportation under the supervillon of
:. lIlCperienced and nined o..entIoIl Enforcement 0f'IIc:erI or authorized conInICt pel'lOl'lnel

o atandaJd NA: Check ... baltJr an Ice T....portdon an ondled only ." the ICE FIeld orne:. fW :
i Sub-Ot'llce In c:&droI of tt.dataInM QM.
•
t

Componentll

T r8iiSporting officers comply wHh applicable local. s1ate.
and federal motor vehicle laws and regulations. Records
support this finding of compliance.
Every transporting officer required to drive a commercial
size bus has a valid Commercial Driver's License (COL)
issued by the slate of emplovmeflt
Supervisors maintein records for each vehicle operator.
Officers use a checklist during every vehicle inspection.
•
Officers report deficiencies affecting operability.
•
Deficiencies are corrected before the vehicle
QOes 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 SO-hour maximum in a given work week;
a 70-hour maximum during eight consecutive
days.
•
During emergency conditions (induding bad
weather). officers may drive as long as
necessary and safe to reach a safe
area-exceeding the 10-h0ur limit.
Two officers with valid CDLs required In any bus
transporting detainees.
•
When buses travel in tandem with detainees.
there two qualified officers per vehicle.
•
An unaccompanied driver transport an empty
Vehicle.
Before tI1e start of each detail. tI1e vehicle is thoroughly
searched.
Positive identifICation of all detainees being transported is
confirmed .
All detainees are searched immediately prior to boarding
the vehicle by staff controlling the bus or vehicle.
The facility ensures that the number of detainees
transported does not exceed the vehicles manufacturers
occupancyleve/'
Protective vests are provided to all transporting officers.
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.

181

[]

~ :~

Copies verified kept in
training IndMdual folder.

o o
o
o
o
o

o
o
o
Vest are Manditory.

Page 67
G-324A Detention Inspedion Form Worlabeet for IGSAJ - Rev: 10/18104

•

r---;--.- - -- - .- -.- -:-:--,----::TRAN==8PORT.==;;:-,J/.;-.::TION=:-;-----;--,
~•
(land TNuportatIon)

wi.

Policy The Immigration end NnnIiration SeJvice
take ... neceuary precaullona 10 protect the liVes, ,
safety, and welfare of our ofIIcers, the general publIC, and thole in ICE custody during the transportation of
dMllmeea. Standwdt h8Ye been eatIIbIIIh8CI fat pror.sIoneI transpOrtation under the IUpervIIIon of .
. ~ and b'ltinect DetentIon Enforcement omcer. or 8UIhorfzed contnICt personnel.

t0
!

aland8rd NA: Check thIa box If .11 leI! TraQaportldio. aN hmclied only by- the ICE F1eId 0trIce or
.... control of the deIaInM caM.
Compone. .
Y..
No NA
RMnaIb

Su~

Policies and procedures are in place addressing 1he use of
restraining equipment on transportation vehicles.
Officers ensure that no one contacts the detainees.
• One offICer remains in the vehicle at all times
when detainees are m-esent.
Meals are provided during long distance transfers.
• The meals meet the minimum dietary standards,
as identified by dieticians utilized by the Service.
The vehicle crew inspects all Food Service pickups before
accepting delivery (food wrapping, portions, quality,
quantity, thermos-transport containers, etc.).
• Before accepting the meals, the vehicle crew
raises and resolves questions, concerns, or
discrepancies
with
the
Food
Service
representative.
drinking-water
and
• Basins, latrines,
containers/dispensers are cleaned and sanitized
on a fixed schedule.
Vehicles have:
• Two-way radios .
• Cellular telephones.
• Equipment boxes stocked in accordance with the
Use of Force Standard.
The vehicles are clean and sanitary at all times.
Personal property of a detainee transferring to another
facility:
• Is inventoried.
Is inspected.
Accompanies the detainee.
The following contingencies are included in the written
procedures for vehicle crews:
• Attack
Escape
• Hostage-taking
• Detainee sickness
Detainee death
Vehicle fire
Riot
• Traffic accident
• Mechanical problems
• Natural disasters
• Severe weather
Passenger list is not exclusively men or women
or minors

·•

·
··
·

181

l2SI

181

Vans are not equiped
with radios, officers hand
held are used instead .

Contingency plans for the
following emergencies
are not in place at this
time.

181

Hostage Taking
Detainee Death
Riot
Natural Disaster
Severe Weather

Page 68
G-324A Detention lnspectlOD Form Worksheet fOT IGSAs - Rev: 10/18104

•

. -.--- - ..,-- ~ TRANlPORTATlON
,
(Land T,..portIItIon)

181 Acceptable

o o.fIclent

At-Rllk

•

--~- --~ ,

o Repeat Finding

Remarks: (Record significant facts, observations, other sources used, etc.)
A complete emergency contingency plan including those topics missing should be created and posted in
each vehicle for quick referooca by transport officers.
b6, b7c

\O\'U> los

Page 69
G-324A Detention Inspection Form Worklbeet for IGSAs - Rev: 10/18/04

•

UlEOFFORCE

Pollc:y: The U,S. ~ ofHomeland Security atIIhOrizes ~ ~offcn:e only as aillat 8IIIImaIive IIft8r all
other reaonable effOna to !-..oNe alitu8tion have failed. Only that 8mount of force necessary to gain control
of the det.einee. 10 protect and ensure !he I8f8ty of detainees, IIt8I'f end others. to prevent serious property
damage and to ensure fnatiIutIon securtty and good order may be used. Physical reaI1aIn1s necesaaryto gain
control of a detalnee-who ~ til be cIangeroUs may be empJo/;led when the detainee:
Compoa....
y- No NA
A.marb
Written policy authorizes staff to respond in an
immediate-use-of-force situation without a supervisor's
presence 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 celculated rather than
immediate use of force is feasible In most cases.
The facility subscribes to the prescribed Confrontation
Avoidance Procedures.
Ranking detention offiCial, health
profeSSional, and others confer before every
calculated use of force.
When a detainee must be forcibly moved and/or
restrained and there is time for a calculated use of force,
staff use the Use-of-Force Team Technique.
• Under staff supervision.
Staff members are trained In the performance of the
Use-of-Force Team Technique.
All use-of-force incidents are documented and reviewed .
Staff:
Does not use force as punishment.
• Attempts to gain the detainee's voluntary
cooperation before resorting to force
Uses only as much force as necessary to
control the detainee.
Uses restraints only when other nonconfrontational means, including verbal
persuasion have failed or are impractical.
Mecication may only be used for restraint purposes
when authorized by the Medical Authority as medically
necessary.
Use-of-Force Team follow written procedures that
attempt to prevent injury and exposure to communicable
disease(s).

•

181

·
•
•

Page 70
G-324A Detention Inspection Form Worksheet for IGSAs - JUv: lO/Uit04

•
-

USE OF FORCE

Poley: The U.S. Departmentot HomeI8.nd securlly ~1tie UIIIIofftiR:eonly • • Jaat.~ after ..

olher rasonabfe efforts to resolVe. sftuatiofl have failed. Only that .mount dforce neceuary to gain control
of the detainee, to prot.et and ensure the ..r.ty of detllfnees.. staff and others, to preIMnI teriOuI property
damage and to ensure institution security and good order !'MY be used. Physical restnIintI neceuary to gain
contrcI of. detain.. Who eppeera to be dangerous !'MY be employed when the detainee;
No
R.....rb
I
V..
Componenta
H-'
Standard procedures associated with using four-point
restraints include:
Soft restraints (e.g., vinyl)
0
Dressing the detainee appropriately for the
temperature.
A bed, mattress, end blanket/sheet.
• Checking the detainee at least every 15
minutes.
Logging each check.
0
Tuming the bed-restrained detainee often
enough to prevent soreness or stiffness.
0
Medical evaluation of the restrained
detainee twice per eight-hour shift.
0
When qualified medical staff is not
immediately available, staff position the
detainee "face-up •.
The shift supervisor monitors the detainee's
position/condition every two hours.
0
He/she allow the detainee to use the rest
room at these times under safeguards.
All detainee checks are loooed.
In immediate-use-of-force situations, staff contacts
medical staff once the detainee Is under control.
When the OIC authorizes use of non-lethal weapons:
0
Medical staff is consulted before staff use
pepper spray/non-lethal weapons.
0
Medical staff review the detainee's medical
file before use of a non-lethal weapon is
authorized.
Special precautions are taken when restraining pregnant
detainees.
0
Medical personnel are consulted
Protective gear is worn when restraining detainees with
open cuts or wounds.
Staff documents every use of force and/or non-routine
application of restraints.
It standard practice to review any use of force and the
non-routine application of restraints.
All offICers receive training in self-defense,
confrontation-avoidance techniques and the use of force
to control detainees.
• Specialized training is given Officers are
certified in all devices they use.
The officers are thoroughly trained in the use of soft and
hard restraints .
~ is the Use of Force form is used. in other
facilities (IGSAs / CDFs) this form or its equivalent is
used.

•

[2J

[8J

[]

[8J

[2J

r2l

[2J

r2l

Page 71
G-314A Detention [mpection Form Worksheet for IGSAs - Rev: 10/18/04

•
181 Acceptable

USE OF FORCE

o Oeflclent

At-Risk

•
o Repeat Finding

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

b6, b7c

ature I Date

Page 72
G-324A Detention Inspection Form Worksheet for I08As - Rev: 10/18104

e
;------ " --

-'--- - - - - - - : ; =
AFF=-=DE1:=g==EI!=C-=OII=
..=UNICA==n0N8==- - - -- -- - ----.

, ICE stdancllCEdetaineellnd to permit detaIneeI to maIce writIIIn requ8IIS to ICE staff and recelYe an
answer In an ax:epIabIfi lime fraqle.
' j
y
~
___2
NA
~:.;.;;;,.. ___...-.-....-,ComDOMnb
, "_
N
-~
- ,~
,

The ICE Field Office Director ensures that weekly
announced and unannounced visits occur at the IGSA.
Detention and Deportation Staff conduct scheduled
weekly visits with detainees held In the IGSA.
Scheduled visits are 20Sied in ICE detainee areas.
VISiting staff observe and note current climate and
conditions of confinement at each IGSA.
ICE information request Forms ara avaHable at the
IGSA for use by ICE detainees.
The IGSA treats detainee correspondence to ICE staff
as Special Correspondence.
ICE staff respond to a detainee request from an IGSA
within 72 hours.
ICE detainees are notified ion writing upon admission to
the facility of their right to correspond with ICE staff
regarding their case or conditions of conftnemenl.

o Acuptable

I8l Deficient

t8:I

181

Log book visit entris
verified

Verified

181

r8J

181

o Al-Risk

Copies are not retained in
detainee detention files

o Repeat Finding

Remarks: (Record Significant facts, observations, other sources used, etc.)
ICE created a detainee tracking log using the Access computor system to track receipt and response actMty
of detainee request forms. This program, prepared in conjunction with the ICE National Detention Standard,
can be used to prepare reports for tracking entry and nationality totals. This program was recognized as a
"Best Practice" during this review.
The facility does not maintain copies of detainee request responses within the detainee detention files . This
was verified by reviewing approximately 25 files . This standard Is "Deficient.·

b6, b7c

Page 73
G-324A Detention Inspection Form Worlaiheet for IGSAs - Rev: 10/18104

r -·- ·-·- --· - - --::-

DETAINEE TRANIFER STANDARD
Poley: ICE will make all .,ec:eu.y ootIfIr*Ions when. detIIInee ll1ran1fem1d. If. detaI ..... II beir9
transferred via the Justice Prisoner Alien Transportation SysI8m (JPATS1ICE will adhert to JPATS
! praCDcols. In deciding whether !D transfer a detainee.. ICE win take 1Oto conaJderation whether the detainee
t II ~Ied before the IIt1mlgratiol) court In such cases, the FIeld 0tIIce DIr8ctor WIll consider the
: ' detainee'a . . . wIthk1 the remcMll process, Whether ttle detainee'. atIDmey llloc:ated within reaaoneble
:" driving dlaCance of the facIt,y, and whera the immigration court proceedings are taking place.
i
IQ
Y
N
CoIn
Remar1ca

II
"

When a detainee Is represented by legal counselor a
legal representative, and a G-28 has been filed, the
representative of record is notified by the detainee's
Deportation OffIcer.
• The notification is recorded in the detainee's file
When the A File is not available, notification is
noted within DACS
Notification Includes the reason for the transfer and the
location of the new facility,
The deportation offIcar Is allowed discretion regarding
the timing of the notification when extenuating
circumstancas are involved.
The attorney and detainee are notified that it is their
responsibility to notify fam ily members regarding a
transfer.
Facility policy mandates that:
Times and transfer plans are never discussed
with the detainee prior to transfer.
• The detainee is not notified of the transfer until
immediately prior to departing the facility.
• The detainee is not permitted to make any
phone calls or have contact with any detainee in
the general population.
The detainee is provided with a completed Detainee
Transfer NotifICation Form .
Form G-391 or equivalent authorizing the
removal of a detainee from a facility is used.
For medical transfers:
• The Detainee Immigration Health Service (or
IGSA)(DIHS) Medical Director or designee
approves the transfer.
• Medical transfers are coordinated through the
local ICE office.
• A medical transfer summary is completed and
accompanies the detainee.
Detainees in ICE facilities having DIHS staff and
medical care are transferred with a completed transfer
summary sheet in a sealed envelope with the detainee's
name and A-number and the envelope is marked
Medical Confidential.
For medical transfers. transporting officers receive
instructions regarding medical issues.
Detainee's funds and valuables and property are
retumed arid transferred with the detainee to his/her
new location .
Transfer and documentary procedures outlined in
Section C arid 0 are foUowed.
Meals are provided when transfers occur during
normally schedule meal times .

Noted In DACS as well as

file.

•

Completed worksheet
verified

•

All transfers are
accompanied by Medical
Summary.

Page 74
G-314A DeteDtiOD Io&peetioD Form Worksbeet for IGSAs - Rev: 10/18104

,~.--------

•

DETAINEE TRANSFER STANDARD
ICE wIR make all ~ nptificaIIoM wh!In a
Is lranar.m.d, If a ctet.lnee Is being
l ~ via the Justice Prisoner Allen T~ System (JPATS) ICE wlUadhere to JPATS
protDcoll.. In deCidIng whether to transfer a dmInee, ICE wiDlike Into consideration whether 1M detainee
. Is represented before the lmmlgratloo court. In such cues, the FJeld 0fIIce DIrector will consider the
! . detalnee~. ttage within the remoYaI prooeu. whether the detainee'a aIIDmey Is located wfttIln ru.anable
:. driving-distance of the facIlitY. and where the imtJIigration court proceedings are taking place..
~ .',
N
NA
RematIr.aComDOnanta
Y

! Policy:

An A File or work folder accompanies the detainee when
transferred to a different field office or sub-office.
A FUes are forwarded to the receiving office via
overnight mail no later than one business day following
the transfer.

I2l

DetaInH TI'UISfer Standard

181 Acceptable

o Deficient

At-Rlak

o Repeat Finding

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

Auditor's Signature I Date

Page 75
G-324A Detention Inspection Form Worksheet for IGSAt - Rev: 10/18/04