ICE Detention Standards Compliance Audit - Atlanta City Detention Center Annual Review, Atlanta, GA, ICE, 2008

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ICE Detention Standards Compliance Audit - Atlanta City Detention Center Annual Review, Atlanta, GA, ICE, 2008

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

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Office ofDetention and Removal Operations

U.S. Department of Homeland Security

801 I Street, NW
Washington, DC 20536

u.s. Immigration
and Customs

Enforcement

MEMORANDUM FOR:

Raymond A. Simonse
Field Office Director
Atlanta Field Offi

FROM:

b6,b7c

Acting Chief
Detention Standards Compliance Unit
Atlanta City Detention Center Annual Review

SUBJECT:

The annual review of the Atlanta City Detention Center conducted on May l3-15, 2008 in
Atlanta, Georgia has been received. A fmal rating of Good has been assigned. No further
action is required and this review is closed.
The rating was based on the Reviewer-In-Charge (RIC) Summary Memorandum and
supporting documentation. The Field Office Director must now initiate the following actions
in accordance with the Detention Management Control Program (DMCP):
1) The Field Office Director, Detention and Removal Operations, shall notify the facility
within five business days of receipt of this memorandum. Notification shall include
copies of the Form G-324A, Detention Facility Review Form, the CC-324A Worksheet,
RIC Summary Memorandum, and a copy of this memorandum.
2) The next annual review will be scheduled on or before May 13,2009.
b6,b7c
Should your staff have any questions regarding this matter, please contact
Detention and Deportation Officer, Detention Standards Compliance Unit at (202) 732

cc: Official File
ICE:HQDRO:

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,
b6,b7c

:2-2436:05/22/2008
b2High

www.ice.goY

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)

.ICE Detention Standards '
.Compliance Review
Atlanta City Detention Center
May 13-15,2008
REPORT DATE - May 23, 2008

reative

corrections

Contract Number: ODT"6-D-0001
Order Number: HSCEOP-07-F-OI016
b6

Executive Vice President
Creative Corrections
6415 Calder, Suite B
Beaumont, TX 77706

b6
COTR
U.S. Immigration and Customs Enforcement
Detention, Standards Compliance Unit
, 801 I Street NW
Washington, DC 20536

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)

.} .

..#.4'J.lt;r.:~'J'

~l;·

\,: C · reatlve

1 1•

cor r e c t ion s

6415 Calder, Suite B • Beaumont, Texas 77706
409.866.9920 • www.correctionalexperts.com

Making a Difference!
May 23, 2008
MEMORANDUM FOR:

FROM:

Gary E Mead, Acting Director
Office of Detention and Removals
b6,b7c

Reviewer-In-Char
Creative Corrections

b6,b7c

Atlanta City Detention Center Annual Review

SUBJECT:

Creative Corrections conducted an Annual Detention Review (ADR) of the Atlanta City
Detention Center, located in Atlanta, Georgia, on May 13-15,2008. The facility is operated by
the City of Atlanta, Georgia. The City has an Intergovernmental Services Agreement for
housing federal detainees dated
. As noted on the attached documents, my team of
b6,b7c
Subject Matter Experts included
Security;
, Health Services; b6,b7c
b6
b6,b7c
b6
Safety; and
Food Services.
b6,b7c
A closeout meeting was conducted on May 15, 2008, with Chief
r, Assistant Chief
Major b6,b7c , Immigration Enforcement Agent
, and several facility
b6,b7c
b6,b7c
supervisory staff. The closeout included a discussion of all concerns and recommendations
noted during this review.

Type of Review:
This review is a scheduled Detention Standard Review to determine general compliance with
established ICE National Detention Standards for facilities used for over 72 hours.

Review Summary:
The Atlanta City Detention Center is not accredited by American Correctional Association
(ACA), National Commission on Correctional Health Care (NCCHC), or the Joint Commission
on Accreditation of Healthcare Organizations (JCAHO).

Standards Compliance:
The following statistical information provides a direct comparison of the 2007 ADR and this
ADR conducted for 2008.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)

1/3

May 13-15. 2008 Review

May 8-10, 2007 Review
Compliant
Deficient
At-Risk
Not-Applicable

o
o
3

Compliant
Deficient
At-Risk
Not-Applicable

o
3

RIC Issues and Concerns
Emergency Plans:
Facility policies should be amended to emphasize the protection of detainees from disease,
property damage, or harassment from other detainees. The Emergency Plans should also address
confidentiality, accountability, annual review procedureS/schedule and revisions. A
comprehensive general section with procedures applicable to most emergency situations should
accompany the contingency plans.
Locations of shut-offvalves and switches for all utilities (water, gas, electric) should be included
in the Emergency Plans. Written procedures should also cover work/food strikes, internal
searches, detainee transportation system plans, and civil disturbances.

Environmental Health and Sa(etv:
Fire drills are currently being conducted and documented quarterly. It is recommended the fire
drills be conducted and documented monthly. These drills should be conducted during every
shift at least once per quarter.

Security Inspections:
The facility does not have a comprehensive security inspection policy. Several policies address
inspections, but are fragmented and do not address guidelines for checking all security features
with procedures for reporting weak spots, recurring problems, areas needing improvement,
failure to take corrective action, or inconsistencies. The facility does not have written procedures
in place to compel searches of storage/supply rooms, plumbing fixtures, accesses, and drains. It
is recommended the policies be amended to address these concerns.

Use of Force:
Written procedures should direct a health professional be consulted as part of the confrontation
avoidance procedures, and that medication not be used for restraint purposes unless authorized
by the Medical Department The use of protective gear when restraining detainees with open
cutS or wounds, in order to prevent injury or exposure to communicable disease, should be
reflected in written procedures. Standard procedures associated with using four-point restraints
should also be defined in written policy.

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2/3

Recommended Rating and Justification
It is the Reviewer-in-Charge (RIC) recommendation that the facility receive a rating of "Good".

RIC Assurance Statement
All findings of this review have been documented on the Detention Review Worksheet and are
supported by the written documentation contained in the revIew file .

. FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)

3/3

't:~'
rea t i v e

~corrections

I
I

DETENTION FACILITY INSPECTION FORM

FACILITIES USED LoNGER THAN 72 HOURS
A. TYPE OF FACILITY REVIEWED
ICE Service Processing Center
ICE Contract Detention Facility
ICE Intergovernmental Service Agreement

Other Charges: (If None, Indicate N/A)
; IZI N/A
Estimated Man-days Per Year
62,000

B. CURRENT INSPECfION
[:0e ofInspection
,
Field Office IZI HO Inspection
Date[s] of Facility Review
May 13-15,2008

G. ACCREDITATION CERTIFICATES IZI N/A
List all State or National Accreditation[s] received:

D
D
IZI

C. PREVIOUslMoST RECENT FACILITY REVIEW
Date[s] of Last Facility Review
May 8-10 2007
Previous Rating
D Superior D Good IZI Acceptable 0 Deficient D At-Risk
D. NAME AND LOCATION OF FACILITY
Name
Atlanta City Detention Center
Address
254 Peachtree Street, SW
City, State and Zip Code
Atlanta GA 30303
County
Fulton
Name and Title of Chief Executive Officer
(Warden/O IC/Superintendent)
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Chief
Telephone Number (Include Area Code)
404-865 b6,b7c
Field Office / Sub-Office (List Office with Oversight)
Atlanta Field Office
Distance from Field Office
1 Mile
E. CREATIVE CORRECfIONS INFORMATION
Name of Inspector (Last Name, Title and Duty Station)
b6,b7c
RIC / Creative Corrections
m Member / Title I Duty Location
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SME I Food
Name of Team Member I Title / Duty Location
b6,b7c
SME I Safety
Name of Team Member / Title I Duty Location
SME I Security
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m Member / Title I Duty Location
/ SME I Medical
b6
Name of Team Member / Title I Duty Location
I
I
F. CDFIIGSA INFORMATION ONLY
Contract Number
Date of Contract or IGSA
05-01-1991
J-B19-M-958
Basic Rates per Man-Day
$68.00

i
I

I
it

H. PROBLEMS I COMPLAINTS (COPIES MUST BE ATTACHED)
Facility is under Court Order or Class Action Finding
Court Order
D Class Action Finding
The Facility has Significant Litigation Pending
D Major Litigation
Life/Safety Issues

-0

~None

I. FACILITY HISTORY
Date Built
1995
Date Last Remodeled or Upgraded
2001
Date New Construction / Bed Space Added
20011300
Future Construction Planned
DYes l8l No Date:
Current Bed space
Future Bed Space (# New Beds only)
Number:
Date:
1314
J. TOTAL FACILITY POPULATION
TQtal Facilily Intake for Previous 12 months
33,492
Total ICE Man Days for Previous 12 months
62,233

K. CLASSIFICATION LEVEL (ICE SPCs AND CDFs 'ONLY)
L-2
L-l
L-3
Adult Male
Adult Female
L. FACILITY CAPACITY
Rated
Adult Male
1,000
Adult Female
314

Ooerational

899
284

Emergency
101
30

i l Facility Holds Juveniles Offenders 16 and Older as Ad ults
M. AVERAGE DAILY POPULATION
ICE
Adult Male
138
Adult Female
22

N. FACILITY STAFFING LEVEL
b2High

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
«:> 2007 Creative Corrections, LLC (Rev. 12/8/07)

USMS
899
11

Other
101
45

SIGNIFICANT INCIDENT SUMMARY WORKSHEET
In order for Creative Corrections to complete its review of your facility, you must complete the following worksheet prior to your
scheduled review dates. This worksheet must contain data for the past twelve months. We will use this worksheet in conjunction with
the ICE Detention Standards to assess your detention operations with regard to the needs ofICE and its detainee population. Failure
to complete this worksheet will result in a delay in processing this report, and may result in a reduction or removal of ICE detainees
from your facility.

Offender I Detainee Medical
Referrals as a Result of Injuries

Escapes

172

151

171

N/A

NlA

352

301

314

330

227

339

347

321

Assault:
Offenders on
Offenders'

Assault:
Detainee on
Staff

# Times FourlFive Point
Restraints AppliedlUsed

Grievances:

Deaths

Psychiatric I Medical Referrals
# Psychiatric Cases Referred
for Outside Care

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

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<02007 Creative Corrections, LLC (Rev. 12/8/07)

Page 2 of4

_ _-_-__-----------

- - _.._........

.....

DHSIICE DETENTION STANDARDS REVIEW SUMMARY REpORT
3. AT-RISK

8.
9.
10.
11.
12.·
13.

14.

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

37.
38.

4. REPEAT
FINDING

S.NOT
MPUCABLE ..

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

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

ALL FINDINGS OF DE~CIENT AND AT~J.tISK REQUIRE wRI'I'TEN COMMENT DESCRIBING THE FINDING AND
WHAT IS NECESSARY TO REACH COMPLIANCE.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
(:) 2007 Creative Corrections, LLC (Rev. 1218/07)

Page 3 of4

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

RIC REVlEW ASSURANCE STATEMENT
By signing below, the Reviewer-In-Charge (RIC) certifies that:
All fmdings of non-compliance with policy or inadequate controls, and findings of noteworthy accomplishments, contained in this
Inspection Report, are supported by evidence that is sufficient and reliable; and
Within the scope of this review, the facility is operating in accordance with applicable law and policy, and property and resources are
being efficiently utilized and adequately safeguarded, except for any deficiencies noted in the report.

b6,b7c

Title & Duty Location

RIC, Creative Corrections

Ma 15,2008

Print Name, Title, & Duty Location

SME Food

b6,b7c

Print Name, Title, & Duty Location
b6,b7c

, SME, Security

RECOMMENDED RATING:

SME, Safety

Print Name, Title, & Duty Location
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SME, Medical

DSUPERIOR
[gIGOOD

D ACCEPTABLE
DDEFICIENT

OAT-RIsK
COMMENTS: In September 2007, a 41 year old female inmate (not ICE detainee) collapsed in her cell. CPR was initiated and she
was transferred to Grady Medical Center where she was pronounced dead. Autopsy revealed the cause of death "Natural Causes".
The mortality review concluded no further action was required. .

The Atlanta City Detention Center is in the process of seeking ACA Accreditation and it is evident that a lot of effort has exerted
towards meeting this goal. In recognition of the improvements made the reviewing team recommends a rating of "Good".

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Correction~. TJ ,C (Rev. 121&107)

P8.Qe 4 of4

HEADQUARTERS EXECUTIVE REVIEW

I Review Authority
The signature below constitutes review of this report and acceptance by the Review Authority. OIC/CEO will have 30 days from
receipt of this report to respond to all findings and recommendations.
HQDRO EXECUTNE REVIEW: (please Print Name)
b6,b7c
b6,b7c

Title

Actin Chief

Final Rating:

Superior

[8l Good

o Acceptable
o Deficient
OAt-Risk
ONoRating

Comments:

The Review Authority concurs with the "Good" rating.

Form CC-324A

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)

Creative Corrections
6415 Calder, Suite B
Beaumont, Texas 77706

Condition of Confinement Review Worksheet
(This document must be attached to each Inspection Form)

This Form to be used for Inspections of Facilities used longer than 72 Hours

reative
corrections
Detention Review Worksheet
[8J

o
o

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

Name
Atlanta City Detention Center
Address (Street and Name)
254 Peachtree Street SW
City, State and Zip Code
Atlanta, Georgia 30303
County
Fulton
Name and Title of Chief Executive Officer (Warden/OIC/Superintendent)
b6,b7c
, Chief
Name and Title of Reviewer-In-Charge
b6,b7c
, RIC
Date[s] of Review
May 13-15,2008

TJf2tHeadquarters
of Review

D Operational

DSpecial Assessment

o Other

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
02007 Creative Corrections, LLC (Rev. 12/8/07)

T ABLE OF CONTENTS ·
SECTION I. LEGAL ACCESS.STANDARDS ..................................................................................................................................... 3
ACCESS TO LEGAL MATERIALS ................................................................................................................................. ...................... ..
GROUP PRESENTATIONS ON LEGAL RIGHTS .................................................... ~ ................................................................................ .
VISITATION ....................................................................................................................................................................................... ..
ACCESS TO TELEPHONES ......................................................................................... ;................... ~ ......... ~; ....................................... :.

SECTION II. DETAINEE SERVICES STANDARDS ........................................~ ......................;.......................................... 11
ADMISSION AND RELEASE ............................................................................... , ................................................................................ .
CLASSIFICATION SYSTEM ............................................................................... :................... ...............................................................
CORRESPONDENCE AND OTHER MAIL .........................................\ ................................................................................................... .
DETAINEE HANDBOOK ..................................................................................................................................................................... .
FOOD SERVICE ................................................................................................................. ............................................................... ...
FuNDS AND PERSONAL PROPERlY .................................................................................................................................................. .
DETAINEE GRIEVANCE PROCEDURES ................................................................................................................... :......................... ..
ISSUANCE ·AND EXCHANGE OF CWTHING, BEDDING, AND TOWELS ............................................................................................... .
MARRIAGE REQUESTS ..................................................................................................... ................................................. , ................. .
NON-MEDICAL ESCORTED TRIPs ............................................................................................ .......................................................... ..
RECREATION ........................................................................................................................................... ........................... ............... .
RELIGIOUS PRACTICES ................ , ............................................... :.................................................................................................... ..
VOLUNTARYWORKPROGRAM ........................................................................................................................................................ .
SECTION III. HEALTH SERVICES STANDARDS .................. ;...................................................................................................... 31
HUNGER STRIKES ........................................................................................................................ ;.................................................... ..
MEDICAL CARE ........ :........................................................................................................................................................................ .
SUICIDE PREVENTION AND INTERVENTION ............................................................................................................. ........................ .
TERMINAL ILLNESS, ADVANCED DIRECTIVES AND DEATH .......................................................................................: ........ ............ .
SECTION IV. SECURffY AND CONTROL STANDARDS .............................................................................................................. 40
CONTRABAND ................................................... ................................................................................................................................ .
DETENTION FILES ...... ....................................................................................................................................................................... .
DISCIPLINARY POLICY ......................................................................................................................................................... ............. .
EMERGENCY PLANS .......................................................................................................................................................................... .
ENVIRONMENTAL HEALTH AND SAFETY ............................... :......................................................................................................... .
HOLD ROOMS IN DETENTION FACILITIES ................................................................................... ;................................................... ..
KEy AND LOCK CONTROL ..................................... :......... :............................................................................................................... ..
POPULATION COUNTS ........ ;............................................................................................................................................................. ..
POST ORDERS .................................................................................................................................................................................. ..
SECURITY INSPECTIONS ................................................................................................................................................................... .
SPECIAL MANAGEMENT UNIT (ADMINISTRATIVE SEGREGATION) ................................................................................................. .
SPECIAL MANAGEMENT UNIT (DISCIPLINARY SEGREGATION) ............................................. ........................................................... '
TOOL CONTROL ............................................................................................................................................................................... ..
TRANSPORTATION (LAND) ..................................................... :....................................................................................................... ..
USE OF FORCE .............................................................................................. :.................................................................................... .
STAFFIDETAINEE COMMUNICATIONS ............................................................................................................................................. ..
DETAINEE TRANSFER STANDARD .................................................................................................................................................... .

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
@

2007 <;;reative Corrections, LLC (Rev. 12/8/07)

Page 2 of72

SECTION I. LEGAL ACCESS STANDARDS

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C 2007 Creative Corrections, LLC (Rev. 1218/07)

Page 3 of72

'P()LICY:

FAcli~~>~6LDn:;oI2Eriir..\INI3Es SHALL ~E~])E;iriiEEt; A~Es'S TO ~.ii~ LIJ3RARV;ANDPR()W,E LE()AL~~RIAi:.s;

:PAciLrrrEs,EQUll?MENT, DQCiJMEmCOPYING ~RIVILEGES,ANDTIlEOPPORTUNrr/TopRiw~LEGAL OOcuMmITs. .
'

COMPONENts

The facility provides a designated law library for detainee use.

The law library contains all materials listed in the "Access to Legal
Materials" Standard, Attaclunent A. The listing of materials is posted in
the law library.
.
The library contains a sufficient number of chairs, is well lit, and is
reasonably isolated from noisy areas.
The law .library is adequately equipped with typewriters ancl/or
computers and has sufficient supplies for daily use by the detainees.
In addition to the physical law library, detainees have access to the Lexus
Nexus electronic law library.
Where provided, the Lexus Nexus library is updated and is current.

Outside persons and organizations are permitted to submit published legal
material for inclusion in the legal library. Outside published material is
forwarded and reviewed by ICE prior to inclusion.
There is a designated ICE or facility employee who inspects, updates, and
maintains/replaces legal materials and equipment on a routine basis.
Detainees are offered a minimum 5 hours per week in the law library.
Detainees are not required to forego recreation time in lieu Qf library
~. Detainees facing a court deadline are given priority use of the law
library.
Detainees may request materials not currently in the law library. Each
request is reviewed and, where appropriate, an acquisition request is
timely initiated.
Requests for copies of court decisions are
accommodated within 3 - 5 business days.
Detainees are permitted to assist other detainees, voluntarily and free of
charge, in researching and preparing legal documents, consistent with
security.
Illiterate or non-English-speaking detainees without legal r.epresentation
receive access to more than just English-language law books after
indicating their need for help.
Detainees may retain a reasonable amount of personal legal material in
the general population and in the special management unit. Stored legal
materials are accessible within 24 hours of a written request.
Detainees housed in Administrative Detention 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 liftingof sanctions.
All denials of access to the law library fully documented.
Facility staff informs ICE Management when a detainee or group of
detainees is denied access to the law library or law materials.
Detainees who seek judicial relief on any matter are not subjected to
reprisals, retaliation, or penalties.

~ ACCEPTABLE

DEFICIENT

D AT-RISK

. ...

·. REMARKS .

There is a designated law
library; in addition LexisNexis
is available in the housing area.

LexisNexis is available to
detainees.

o
o
o

Time allowable per SOP-500-02
exceeds this time frame.

SOP-500-02 provides for these
requests and states material will
be provided within 48 hrs.
excluding weekends.

This is an acceptable practice
per Majorb6,b7c .

A free legal assistance list is
provided.

[]

o
o

ICE Agent
states
b6,b7c
that update
whenever they are issued.
There have been no requests,
however; Major b6,b7c states they
would be forwarded to ICE for a
decision.

There have been no such
instances.
Included inHandbook
Amendment.
REPEAT FINDING

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE) .
© 2007 Creative Corrections, LLC (Rev. 1218/07)

. ..

Page 4 of 72

REMARKS:

In a memo dated 06-14-2007, Gary E. Mead, Assistant Director (currently Acting Director), ICE Management states "facilities which
have Lexis N exis do not have to also have the hard copy oflegal references in attachment A. "

b6,b7c

/May 15.2008

b6,b7c

AUDITOR'SSIGNATURE/DATE

p.~

FOR OFFICIAL USE ONLY (LA W ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 5 of 72

p<>Llcf:

GROUP LEGAL RIGHTS PRESENTATIONS,

FACILrirns HOUSING ICE DETAINEES SHALL PERMIT AUTHORIZED PERSONS TO MAKE PRESENTATIONS lUGROuPS OFDETA!NEES'FOR
'TmiPuRPoSE OF INFORMING
OF U.S. IMMIGRATION LAW AND PROCEDURES; CONSISTENT WUH rnESECORiTY ANDORDERIXOPERATION
., OFEACHFACILrrY. ICEENCOURAGEs SUCH PRESENTATIONS, WHICH mSTRUCTDETAINEES ABOUT THE IMMIGRATION SYSTEM AND THEIR
AND ()wONSWriHIN I T . '
" .
.
.
.
.

nffiM

RIqms

. Cfu CO:ECKHERE Il" N6GROUP PRESENTATIONS WERE CONDUCTED WlnllN THE PAST 12 MONTHS. MARK STANDMm As ACCEPTABLE

.' OvERALL AND CoNTINUE ON wi:mNEXT PORTION OF WORKSHEET.

..'

COMPONENTS

YES

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 timely and proper notification to
attorneys or accredited rej>resentatives.
The facility follows policy and procedure when rejecting or requesting
modifications to objectionable material provided or presented by the
attorney 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 provides a sufficient number of presentations so that all
detainees signed up may attend.
Detainees in segregation, unable to attend for security reasons, inay
request separate sessions withj)I'esenters. Such requests are documented.
Interpreters are admitted when necessary to assist attorneys 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.
Presenters are permitted to meet with small groups of detainees to discuss
their cases after the group presentation. ICE or authorized detention staff
is 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 designee; 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.
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 r~quest

[ ]

The

[g] ACCEPTABLE

o DEFICIENT

OAT-RISK

REMARKS

o REPEAT FINDING

REMARKS:

There have been no requests for Group Legal Rights Presentations in the past year.

b6,b7c

I May 15.2008

AUDITOR'S SIGNATURE I DATE

b6,b7c

'Y
0'.

I'-

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<C 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 6 of72

COMPONENTS

N ... .· NA

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

Included in SOP-500-03 and
Inmate Handbook Amendment.

The visitation hours tailored to the detainee population and the demand
for visitation.

Facility allows 2 visits per week.

o
o

Included on facility web page
andQ<>sted in lobby.

o
o

Included on web page and
posted in lobby.

The detainees are pennitted to retair. personal property items specified
.
in the standard.

o
o
o
o
o

A visitor dress code is available to the public.

Visitors are searched and identified according to standard requirements.

o
o

The requirement on visitation by minors is complied with.

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.

o
Visitors must produce 2 forms
of identification and pass
through a metal detector.

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

Minors are allowed to visit if
accompanied by an adult.

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

See above.

Detainees in special housing are afforded visitation.

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

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

o
o

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

All categories in special housing
except disciplinary are allowed.
Legal visiting is allowed 2417 .
SOP-500-03 provides for 24
hour legal visits 7 days per
week.

o
o

Contact visits are allowed for
attorney visits.

[]

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

SOP-06-13 Inmate Searches.
Legal visits can be non-contact
based on wishes of either the
detainee or attorney.
Attorneys must produce proper
identification including their bar
card.

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

The decision to pennit or deny a tour is not delegated below the level of
Field Office Director.

o
o

Private consultation rooms are available for attorney meetings. There is
a mechanism for the detainee and his/her representative to exchange
documents.
There are written procedures governing detainee searches.
When strip searches are required after every contact visit with a legal
representative, the facility provides an option for non-contact visits with
legal representatives.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
02007 Creative Corrections, LLC (Rev, 12/8/07)

Page 7 of72

r"""";"'~"""'<~''''''''''''1J!I!?'1'''r.'''=",,~~=' -~"m"'_1'R"'"=l'''''''''F'""s-;-'e'",'", ""',,,,-.

i~JI~l~1;~f;~~~~'~!ijiii~;~~;.~'Y4&~~Jl~IIl~~~~1i~~\~~1~~~~

ot~~·i.)-&Y,llii
.~~"j,' ~~2'~:l
:6!i~.ib""~~~~;~W&1~i~f~I.rt:'~~~~f~f'1 ~~~~~~~
"l.ioi.
_ c\;~,1;(~
:.c...w:
.!L..oi...1. •

s.;_~\.I,;

~:o:Q.;ii;

~ ... ~~ ~~

X~~\:

Law enforcement officials who request to visit with a detainee are referred
to the ICE Field Office for approval.

18'1

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

121

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

121

[8J ACCEPTABLE

DEFICIENT

OAT-RIsK

.,,;:

This is a requirement per SOP500-03.

REPEAT FINDING

REMARKS:

The standard operating procedures of this facility provide that adequate access to detainees by family, law enforcement, special interests,
attorneys, and the news media is guaranteed.
b6,b7c

{May 15.2008

AUDITOR'S SIGNATURE I DATE

b6,b7c

()

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 8 of72

DETAIl\ffi:E TELEPH9N.E.{CC~ .
",-,,,.-, '

. ..POUCV: . ALL FAciLITIES HOUSIN(J ICE DETAINEES WILL i:>ERMITDETNNEES' REi\sONABLEAND EQuITABI.E ACCESS TO TELEPHONES.
. COMPONENTs ...
REMARKs'
Y
N
NA ..... .
Detainees are allowed access to telephones during established facility
waking hours.

t8I

Upon admittance, detainees are made aware of the facility's telephone
access poli(;Y.
Access rules are posted in housing units.
The facility makes a reasonable effort to provide key information to
detainees in languages spoken by any significant portion of the facility's
population.
Telephones are provided at a minimum ratio of one telephone per 25
detainees in the facility population.

t8I
181

[]

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

t8I

18I

t8I

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

t8I

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

t8I

Detainees are afforded a reasonable degree ofprivacy for legal phone
calis.
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.

t8I
l8J

Special Access calls are at no charge to the detainees.
The DIG phone number for reporting abuse is programmed into the
detainee phone system and the phone number was checked by the
inspector during the review.
In facilities unable to fully meet this requirement initially because of
limitations of its telephone service, ICE makes alternate arrangements to
provide required access within 24 hours 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".

l8J

[]

l8J

Special arrangements are made to allow detainees to speak by telephone
with an immediate family member detained in another Facility.

l8J

Any telephone restrictions are documented.
The facility has a system for taking and delivering emergency detainee
telephone messages.

IZJ

l8J

Emergency phone call messages are immediately given to detainees.

l8J

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 inunigration case or other legal matters, including
consultation calls.

l8J

Housing unit phones are
available during day room
activity.
Included in Inmate Handbook
and its amendment.
Both the Handbook and its
amendment are published in
English and Spanish.
There are 6 phones in each 80
bed housing unit

There is an Information
Technology Specialist
responsible for monitoring and
coordinating repairs.

Special provisions can be made
to accommodate specific needs.
SOP-07-09 provides for these
provisions.

Programmed into the system.
Programmed into the system and
checked weekly by the ICE
Officer who visits each Weds.
Facility is able to meet this
requirement.

Has not happened and would be
a highly unusual situation per
Majo b6,b7c
SOP-07-09

After verification by a
supervisor.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
(02007 Creative Corrections, LLC (Rev. 12/8/07)

Page 9 of 72

I':

'·

DETAlNEKTELE~llO~:A~cESS :. " .. : ,

". ,

.POLICir:.i\LL ~ACILrrIES HOUSING ICE DETAIN~ESWILL PERMITDE1'AJ1IffiEs'REASO:N~tE~E94rrABLE ACCESS TO TELEPHONEs.
. . ..
.. COMPONENTS
Y;N·
NNe
REMARKs
Detainees in disciplinary segregation are allowed phone calls to
consular/embassy officials.
Detainees in disciplinary segregation are allowed phone calls for family
emergencies.
Detainees in administrative detention and protective custody are
afforded the same telepJlone privileges as those in general population.
When detainee phone calls are monitored, notification is posted by
detainee telephones that phone calls made by the detainees may be
monitored. Special Access calls are not monitored.

[8] ACCEPTABLE

DEFICIENT

OAT-RIsK

o
o
o
o

o
o
o

This notice is not posted; it is in
the Handbook amendment and is
in a recorded message.

.D REPEAT FINDING

REMARKS:

ICE provides access to their "PCS Platform" from the facility's system; therefore, detainees have easy access to the required toll free
numbers.

b6,b7c

May 18.2008

AUDITOR'S SIGNATURE / DATE

b6,b7c

FOR OFFICIAL USE ONL Y (LAW ENFORCEMENT SENSITIVE)
<02007 Creative Corrections, LLC (Rev. 12/8/07)

Page 10 of72

SECTION II. DETAINEE SERVICES STANDARDS

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
«::l 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 11 of 72

~; ,:

ADMISSION AND RELEASE
..

,'"

'r',

potlcriALl. DETArnEEs WILL BE ADMITTED ANDRELBASED IN A MANNER-fHATENSU~TllEm.H13k.nf,SAFETY; AND WELFAJffi.THE
"ADMiSSiONS PROCEDURE wiLL, AMONG OTHER THINGS INCLUDE: MEDICAL SCREENING; A FILE:'BASEDASSESSMENT AND CLAsSIFICATION
PRocEss; A JlODY SEARCH; AND A SEARCH OF PERSONAL BELONGINGS; WlJIC:H
rNvmrrOR.lEP, DOCUMJ3NTED, ~ SAFEGUARDED AS
.....
NECESSARY;
.'

WILL B¥

Staff completes Form 1-387 or similar form for CDFs and IGSAs for
every lost or missing property claim. Facilities 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 properly coordinated with ICE using a Form 1-203.
Staff completes paperwork/forms for release as required.

IZI ACCEPTABLE

. COMPONENTS

In-processing includes an orientation of the facility. The orientation
includes: Unacceptable activities and behavior, and corresponding
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" and the
detainee handbook.
Medical screenings are performed by medical staff.2! persons who have
received specialized training for the purpose of conducting an initial
health screening.
Each new arrival is classified according to criminal history and threat
levels. Criminal history is provided for each detainee by the ICE field
office.
All new arrivals are searched in accordance with the "Detainee Search"
standard. An officer of the same sex as the detainee conducts the search
and the search is conducted, in an area that affords as much privacy as
possible.
Detainees are stripped searched only when cause has been established
and not as routine policy. Non-criminal detainees are not strip-searched
but are patted down unless reasonable suspicion is established.
The "Contraband" standard governs all personal property searches.
IGSAslCDFs use or have a similar contraband standard. Staff prepares
a complete inventory of each detainee's possessions. The detainee
receives a copy.

DDEFIClENT

REMARKS

I8l

At initial reception each
detainee is issued an Inmate
Handbook. In addition
throughout the intake procedure
the Intake Officers make verbal
presentations of material
contained in the Handbook.

I8l

Initial medical screening is done
by the intake officer.

I8l

r.gJ

Procedures for all types of
searches are contained in SOP06-13 and meet these
requirements.

r.gJ

These procedures are included
in the above SOP.

r.gJ

Upon initial entry into the
facility all property and funds
are inventoried, the detainee
signs the inventory and it is
placed in his file.

r.gJ

A report of incident is filed and
investigated by a supervisor.

r.gJ

181
181

[]

[]
LJ

OAT-RISK

Replenished to indigent
detainees.

o REPEAT

FINDING

REMARKS:

Appropriate procedures are in place to ensure that all admissions receive proper screening to ensure the safety of other detainees as
well as their own.

b6,b7c

/ May 15,2008

AUDITOR'S SIGNATURE / DATE

b6,b7c

FOR OFFICIAL USE ONL Y (LAW ENFORCEMENT SENSITIVE)
02007 Creative Corrections, LLC (Rev. 12/8/07)

Page 12 of72

, .:': -..

CLASSIFlCATION
SY$TJ;M;" •• "
.
', "';'.:-' , ' . "" '; ', ' ', '.,'.:, ' . . v: ",. ' .

.",

WILLDEVELOP ' AND
SYSTEM AGCQRJjINO .TOwHId.iICEDIIT~ARB CLASSIFmV. THE
CLASSIFI~TION SYSTEM WIll ENSURE THAT EACH DETAINEE IS'PLACED IN THE A.PPROPRIATE CATEGORY; PHYSlOOLYSEPARATED FROM,
DEtAINEEs rN()TIlER CATEGORIES "
"
,',. .
' '
" ". .', '". "
".
, ,.. .
'

IMl'r.EMeNTA

IlqLICY: AtLfACILITIES
, . ,'. . .

COMPONENTSY " "

The facility has a system for classifying detainees. In CDFs and IOSAs,
an Objective Classification System or similar is used.
The facility classification system includes:
• Classifying detainees upon arrival;
• Separating from the general population those individuals who
cannot be classified upon arrival; and
• The rust-line supervisor or designated classification specialist
reviewing every classification decision.
The intake/processing officer reviews work-folders, A-files, etc., to
identify and classify each new arrival.
Staff uses only infonnation that is factual, and reliable to detennine
classification assignments. Opinions and unsubstantiated! unconfrrmed
reports may be filed but are not used to score detainees classifications.
Housing assiJmments are based on classification-level.
A detainee's c1assification~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. At
IOSA's detainees may request reassessment 60 days after arrival.
Procedures exist for a detainee to appeal their classification assignment.
Only a designated supervisor or classification specialist has the,authority
to reduce a classification-level on appeal.
Classification appeals are resolved within five business days and
detainees are notified of the outcome within 10 business days.
Classification designations may be appealed to a higher authority, such
as the Warden or equivalent.
The Detainee Handbook or equivalent for lOSAs explains the
classification levels, with the conditions and restrictions applicable to
each.
'

~ ACCEPTABLE

o DEFICIENT

'REMARKs '

" NA

Facility uses a 3-tier~ system
described in SOP-06-S7.

These requirements are all
included in SOP-06-S7.

SOP-06-87, section 8.4.

medical requirements.
Initial classification is
reassessed after 72 hours.

f8I

There is a classification appeal
form.

f8I

SOP-06-S7, section 8.12.1.

Highest level of appeal is the
Classification Supervisor.
The Inmate Handbook
Amendment has a brief
explanation.

f8I

0
I8J

OAT-RISK

Must be no higher than

minimum plus must meet all

REPEAT FINDING

REMARKS:

The facility uses a 3-tiered classification system which considers charge, history, and current behavior. The system insures that violent
detainees are housed separately from non-violent detainees.

b6,b7c

/MayJS,2QOS

b6,b7c

AUDITOR'S SIGNATURE / DATE

tJ-~

FOR OFFICIAL USE ONL Y (LAW ENFORCEMENT SENSITIVE)
CO 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 13 of72

·.

CORRE~PONDENCEANDQ'i'~~MAIL

.poLicy: ;ALL FACILITIES '.VILL:ENSORE THAT DErAINEESS:cNDANoRECElVir COIUtEsP6NDENCE IN A TIMELY MANNER, SUBJECT TO .
.· ·i!MirATI6NSREQUIREDFOI~.TImSAFE1Y,SECUrurY,ANDORDERLYOPERAfIONO~TIIEFAcn;riY.OtHERMA.iLwiILl3EPER,MIT:fED,SUBJECT'TO
.· ,THE S'MmLIMITATIONS.- .EACH FACILITY WILL WIDELY DisTRIBUTE ITS GUIOELINESCONCERNmO CORRESPO~ENCE ANDOTImR MAIL. :'
".COMPONENfS
' 'YES . No ' • NA . . .
REMARKS
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 is distributed to detainees within 24 hours or I business
day after it is received and inspected.
Outgoing mail is delivered to the postal service within one business day
of its entering the internal mail system (excluding weekends and
holidays).
Staff does 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 security reasons.
Staff does not read incoming general correspondence without the
Warden's prior written approval.
Staff does not inspect incoming special Correspondence for physical
contraband or to verify the "special" status of enclosures without the
detainee present.
Staff is prohibited from reading or copying incoming special
correspondence.
Staff is only authorized to inspect outgoing correspondence or other mail
without the detainee present when there is reason to believe the item
might present a threat to the facility's secure or orderly operation,
endanger the recipient or the public or might facilitate criminal activity.
Con:espondence 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 notice.
Staff maintains a written record of every item removed from detainee
mail.
The Warden or equivalent monitors staff handling of discovered
contraband and its disposition. Records are accurate and up to date.
The procedure for safeguarding cash removed from a detainee protects
the detainee from loss of funds and theft. The amount of cash credited to
detainee accounts is accurate. Discrepancies are docwnented and
investigated. Standard procedure includes issuing a receipt to the
detainee.
Original identity documents (e.g., passports, birth certificates) are
immediately removed and forwarded to ICE staff for placement in Afiles.
Staff provides the detainee a copy ofhislher 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.

Page 25 of Inmate Handbook.

Handbook is in Spanish and
English.

Excluding weekends and
holidays.

l'8I

o
o

All incoming general
correspondence is opened and
.inspected prior to delivery.

This is the procedure as outlined
in SOP-07-05.

o
o
o
Only U.S. Postal and Western
Union money orders are
accepted. The detainee is issued
a receipt.

o
o

Only if the need is justified.

Procedures are outlined in SOP07-05.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
10 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 14 of 72

CORRESPONDENCE," ANDOTHERMAn>:·
.'
..... ... . ... .. ..

.~.-:

POLIcY: Au · F~CILITIES~IlL ENSURE TIIAT DETAINEES ·SEND AND-REcll'iECO_roNoENtE -~ ATiMEI.Y_ ~R, StmJECf TO·-

LI;"UTATIONS REQUIRED FOR THE SAFETY, SECtJRITy,ANDORDERLYOPEAAno~'OFTHEFACILITY. OTImRMAIL WILL aEPERMfITED, StiBJEcTTO ·
EACH FACILITY WILL WIDELY DISrRmUT~ ITS GUIDELINES CONCERN
CORRESPOND£~CE
OTHER

INa

··TIffi SAME LIMITATIONS.

Every indigent detainee has the opportunity to mail, at govenunent
expense, reasonable correspondence about a legal matter, in three one
ounce letters per week and packages deemed necessary by ICE.
The facility has a system for detainees to purchase stamps 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.

[8J ACCEPTABLE

o DEFICIENT

[8'J

AND

[8'J

OAT-RISK

MAIL.

Handbook Amendment makes
this provision.
May have up to 4 books of
stamps in their possession.
There is no specified limit for
general correspondence.
This material is provided to
indigent detainees.

o REPEAT FINDING

REMARKS:

Procedures for mail ensure that detainees are able to have sufficient contact with the public, legal, and govenunental officials.

b6,b7c

1 May IS. 2008.

AUDITOR'S SIGNATURE 1DATE

b6,b7c

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
10 2007 Creative CorreCtions, LLC (Rev. 1218/07)

Page 15 of72

, ,

DETAINEE HANDBOOK '

': ' "

" , POJj.CY:EVERy6ICWlLLDEVELOPASrril~SPECIFICDrrrArNEEHANDBoOK ·T6SER~ASANOVERViEWOF,ANDGUIDETO,THEDETPNl19N
, ~qGIES> R~ES, AND, PROCEDURES IN EFi/Ecr AT THE FACILITY. THE HAN'DBOQKWILL ALSO DESciuBE THE SERVICES,PROQRAMS~' AND

,OPPOR1VNITIES AVAn.ABLE 1JiROUqH VAIUOUS SOURCES~ INCLUDINOrHEFACILiTY, ICE, PRlVATE OR,GANIZATIONS, ETC. EVEIWDETAINEE
"WILL RECErVEA COPY OFTHISHANDBoO~ uPON ADMISSION TO TIlE FACILITY.
'
' y
COMPONENTS
N
NA
REMARKS
The detainee handbook is written in English and translated into Spanish,
18I
0
0
or into the next most-prevalent Lang\}ag€:(s).
The handbook is supplemented by the facility orientation video, where
18I
0
0
one is provided.
All staff members receive a handbook and training regarding the
Training is conducted during
18I
0
0 initial orientation.
handbook contents.
The handbook is revised as necessary and there are procedures in place
18I
0
0
for immediately. communicating any. revisions to staff and detainees.
There an iumual review ofthe handbook by a designated committee or
18I
0
0
staff member.
The detainee handbook addresses the following issues:
Atlanta City Detention Center
Handbook
Personal
Items
permitted
to
be
retained
by
the
detainee;
and
•
t8l
0
0 Issuance ofAmendments
Clothing and Hygiene
• Initial issue of clothes, bedding and personal hygiene items.
Items
The detainee handbook states in clear language the ' basic detainee
Atlanta City Detention Center
responsibilities.
18I
0
0 Inmate Handbook - Inmate Rights
and Responsibilities Page 5.
The handbook clearly outlines the methods for classification of
Atlanta City Detention Center
detainees, explains each level, and explains the classification appeals
t8l
0
0 Handbook Amendments process.
Classification / Preciassification.
The handbook states when a medical examination will be conducted.
Atlanta City Detention Center
t8l
0
0 Inmate Handbook - Medical and
Mental Health Services page 15
The handbook describes the facility, housing units, dayroorns, in-dorm
Atlanta City Detention Center
activities, and special housing units.
Handbook - Typical
[81
0
0 Inmate
Housing Area Daily Schedule,
Page 3
The handbook describes official count times and count procedures; meal
times and feeding procedures; procedures for medical or religious diets;
Atlanta City Detention Center
smoking policy; clothing exchange schedules; and, if authorized, clothes
18I
0
0 Handbook
Amendments
washing and drying procedures, and expected personal, hygiene
practices.
The handbook describe times and procedures for obtaining disposable
Atlanta City Detention Center
razors, and allows that detainees attending court will be afforded the
t8l
0
0 Handbook Amendments - Razor
opportunity to shave fIrst.
and Hair Care Services
The handbook'describes barber hours and hair cutting restrictions.
Atlanta City Detention Center
l'8I
0
0 Handbook Amendments - Razor
and Hair Care Services
The handbook describes the telephone policy; debit card procedures;
Atlanta City Detention Center
[81
direct and free calls; locations of telephones; policy when telephone
Handbook
Amendments 0
0
demand is high: and policy and procedures for emergency phone calls.
Telephone Calls
The handbook addresses religious programming.
Atlanta City Detention Center
[81
0
0 Inmate Handbook - Religious
Services page 23
The handbook states times and procedures for commissary or vending
Atlanta City Detention Center
[81
machine usage, where available. '
0 Inmate Handbook - Commissary,
0
page 17
The handbook describes the detainee voluntary work program.
A voluntary work program is in
0
~
0 place but ICE detainees are not
allowed to participate.
,

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 16 of72

hlU1tdb<x>k np.•,,,rilhp... the library location and hours of operation, and
schedules.
The handbook descnoes attorney and regular visitation hours, policies, and
procedures.

C8I

Atlanta City Detention Center
Inmate Handbook - Rules of
Conduct, page 6.

C8I

Atlanta City Detention Center
Handbook Amendments Grievances

C8I

Atlanta City Detention Center
Inmate Handbook - Medical and
Health
15.
Atlanta City Detention Center
Handbook Amendments Recreation
Atlanta City Detention Center
Handbook Amendments - Issuance
and
Items
Atlanta City Detention Center
Inmate Handbook - Inmate Rights
and
5

The handbook describes the facility contraband policy.

The handbook describes the facility visiting hours and schedule, and
visiting rules and regulations.

C8I

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; and
•
of the
Process.
The grievance section of the handbook explains all steps in the grievance
process - Including:
.
•
Informal (ifused) and formal grievance procedures;.
•
The appeals process;
•
I.!l..Q2f facilities: procedures for filing an appeal of a grievance
with ICE.
Ii
Staff/detainee availability to help during the grievance process.
•
Guarantee against staff retaliation for filing/pursuing a grievance.
•
How to file a complaint about officer misconduct with the
of Homeland
detainee handbook descnoes the medical sick call procedures for
general population and segregation.
The handbook descnoes the facility recreation policy including:
•
Outdoor recreation hours.
•
Indoor recreation hours.
The handbook describes the detainee dress code for daily living; and work
assignments.
The handbook specifies the rights and responsibilities of all detainees.

C8l ACCEPTABLE
REMARKS:

::::."2::;

~p~ ro

b6,b7c

AUDITOR'S SIGNATURE 1DATE

D AT-RIsK

DDEFICIENT

b6,b7c

Atlanta City Detention Center
Handbook Amendments Contraband
Atlanta City Detention Center
Handbook Amendments - Inmate
Visitation
Atlanta City Detention Center
Inmate Handbook - Incoming 1
25.

o REPEAT FINDING

moetilien«d, ofili'

fudliW.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 17 ofn

The food service program is under the direct supervision of a
professionallY trained and certified food service admin.i.strator.
Responsibilities of cooks and cook foremen are in writing. The Food
Service AdministratOr (FSA) determines the responsibilities of the Food
Service Staff.

Food Service
b6
Manager, has an extensive
training record and is Serv-Safe
certified.

The Cook Supervisor is on duty on days when the FSA is off duty and vice
versa.

The staff schedule reflects
supervisory coverage 7 days per
week.

The FSA provides food service employees with training that specifically
addresses detainee-related issues.

•

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

ICE detainees are not assigned to
the food service department.

Knife cabinets close with an approved locking device, and the on-duty
cook foreman maintains control of the key that locks the device.

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

Operating procedures include daily searches (shakedowns) of detainee
work areas.
The FSA monitors staffirnplementatioo of the facility's population counts
procedures. Staff is trained in count procedures.
The detainees assigned to the food service department look neat and clean.
Their clothing and grooming comply with the "Food Service" standard.
The FSA annually reviews detainee-volunteer job descriptions to ensure
they are accurate and up-to-date.
The Cook Foreman or equivalent instructs newly assigned detainee
workers in the rules and procedures of the food service department.
During orientation and training session(s), the CS explains and
demonstrates:
•
Safe work practices and methods;
•
Safety features of individual products/pieces of equipment; and
•
Training covers the safe handling of hazardous material[s] the
detainees are likely to encounter in their work.
The Cook Supervisor documents all training in individual detainee
detention files.
Detainees at CDFs are paid in accordance with the "Voluntary Work
Program" standard. Detainee workers at IGSAs are subject to local and
state rules and regulations regarding detainee pay.
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.

o
o
o
o
o
o

The facility does not use food
items which require special
securi.tymeasures.

o
o

o
o
o

o
o

b2High

Food service workers receive
instruction on rules and
procedures the department.

ICE detainees are not assigned to
food service.

Hot meals are served at breakfast
and dinner. Meal times are
Breakfast, 4:30 AM; Lunch,
11 :00 AM; Dinner, 4:30 PM.

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© 2007 Creative Corrections, ILC (Rev. 12/8/07)

Page 18 of72

...

....

. . ..

FOOD,SERVICE

., .
" " ,'

. ' ..

ItoAN6E Wl1li

J»OLICY:.
EvERY
FACILITY
Wq.LPROVIDE OETAlNEES
IN ITS CARE WIU-l NirrRnrou'SANDAPPETIZING
MEAls; PREPA:REO
IN ACco
'.
_.:
.
..'
': ,' , .
'
.
...
THE HIGHEST SANITARYSTANOARDS. ·
..
....
:y
."
· . NA
COMPONENTS
. "
N
REMARKS
-.' ,

."-

For cafeteria style operations, a transparent "sneeze guard" protects both
the serving line and salad bar line.
The facility has a standard 35-day menu cycle. IGSAs use a 35 day
or similar system for rotating meals.
The FSA or facility considers the ethnic diversity of the facility's
detainee population when developing menu cycles (provide
examples).
A registered dietitian conducts a complete nutritional analysis of every
master-cycle menu planned.
The FSA has established procedures to ensure that items on the mastercycle menu are prepared and presented according to approved recipes.
The Cook Foreman has the authority to change menu items ifnecessary.
• 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.

- ,

l8J

There are no cafeteria style
operations at this facility.
The facility has a 4-week cycle
menu.

Spaghetti, Chili, Grits, etc.

A complete nutritional analysis
of the cycle menus is on file.

l8J

l8J
A common-fare menu available to detainees whose dietary requirements
cannot be met on the main line.
Changes to the planned common-fare menu can be made at the
facility level;
Hot entrees are offered three times a week;
• The common-fare menus satisfY nutritional recommended daily
allowances (RDAs);
• Staff routinely provide hot water for instant beverages and
foods;
Common-fare meals are served with:
0
• Disposable plates and utensils .
• Reusable plates and utensils .
• Staff use separate cutting boards, knives, spoons, scoops, etc.,
to prepare the common-fare diet items.
A supervisor at the command level must approve a detainee's removal
from the Common-Fare Program.
The Warden, in conjunction with the chaplain and/or local religious
leaders, provides the FSA a schedule of the ceremonial meals for the
following calendar year.
The common-fare program ~ccommodates detainees abstaining from
particular foods or fasting for religious purposes at prescribed times of
the year.
• Muslims fasting during Ramadan receive their meals after
sundown.
Jews who observe Passover but do !lot 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 Cook Foreman must contact
the Food Service Administrator
to have the menu changed.

Interviews with the Chaplain
and Food Service Manager
revealed resources are available
to quickly obtain religious menu .
items when required.

A common-fare program is not
utilized. Religious diets are
addressed on a case-by-case
basis. The facility is pork-free.

•

l8J

[8J

A schedule of ceremonial meals
is not provided to the FSA
annually.

181

Religious fasting needs are
accommodated on a case-bycase basis.

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Page 19 of 72

F()OI) SERVICE .'
..

,PoLicY: EVERY FACILITY WILL PROVIDE DET~EIlS IN ITS CARE wrmNUTRITIOU~ AND APPETIZING MEAts, PREPARED IN ACCORDANCEWITH
THE mGHEST SANITARY STANDARDS.
COMPONENTS

Satellite-feeding programs follow guidelines for proper sanitation.
Hot and cold foods are maintained at the prescribed, "safe"
temperature(s) while being served.
r'
All meals are provided in nutritionally adequate portions.
Food is not used to punish or reward detainees based upon behavior.
The food service staff instructs detainee volunteers on:
• Personal cleanliness and hygiene;
• Sanitary techniques for preparing, storing, and serving food;
and
• The sanitaryoperation care and maintenance of equipment.
Everyone working in the foOd service department complies with food
safety and sanitation requirements.

A medical diet program is in
place to accommodate
detainees' dietarY needs.

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

[8J ACCEPTABLE

o DEFICIENT

[gI

0
0
0

[]

[gI
[gI
[gI

'REMARKs

,NA

The food service program addresses medical diets.

[gI

Food service workers are
instructed on hygiene and
sanitation. ICE detainees are
not assigned to work in food
service.

[gI

Inspections are conducted daily
by the food service staff and
annually by the Fulton County
Health Department. Inspection
documentation is maintained on
file.

[gI

The Fulton County health
Department conducted an
inspection in June 2007.

[gI

0
0

[gI

OAT-RIsK

Cleaning requirements are
posted in each area throughout
the operation.

o REPEAT FINDING

REMARKS:

The food service program provides nutritionally adequate meals to detainees, prepared in a safe and sanitary environment. The
medical diet program effectively satisfies the dietary requirements of all detainees. Observations indicated a high level of sanitation is
being maintained throughout the ,department.
The Cook Foreman is not allowed to make menu changes without contacting the FSA, who then acquires approval from the dietician.
A common-fare menu is not in place. The facility is pork free and religious diet requests are addressed by the Chaplain and FSA.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
«::l2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 20 of72

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

Resources are available to immediately acquire religious food items if necessary.
A list of ceremonial meals is not provided to the FsA for the following calendar year. Ceremonial meals are provided on an as-needed
basis.

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/ May 15.2008

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© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 21 of72

FUNDS AND PERSONA.I:'PROP~RTY
','
"

POllCY: ALL fAcIiITIES WILL IMPLEMENT PROCEDinrns TO CONTROL AND SAFEGUARD DETAINEES; PERs~NAL PROPERTY. PROCEDURES wn.L
PROVIDE JlOR Tim SECURE STORAGE OF, FUNDS, VALUABLES, BAGGAGE AND OTHER PERSONAL PROPERTY; THE'DOCUMENTATION AND
'R,ECEWrINGOF SURRENDERED PROPERTY; AND THE INITIAL AND REGULARLY SCHEDUIED INVENTORYING OF ALL FuNDs, VALUABLEs, AND
'OTHER PROPERTY.
·..,STANDARD NA: (IGSA ONLY)CHECInIDSBox IF ALLICE DETAIl'iEE FUN.DS, VALUABLESAND PROPERTY ARE HANDLED ONLY
,
,BY THE ICE FIELD OFFICE OR SUB-OFFICE IN CONTROL OF THE DETAiNEE CASE.
COMPONENTS
YES
NA
'REMARKS
No

Detainee funds (U1d valuables are properly separated, stored, and are
accessible only by designated supervisor(s).
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
(including funds and valuables). For IGSAs and CDFs, using a personal
property inventory form that meets the ICE standard?
Staff forwards an arriving detainee's medication to the medical staff.
Audits of baggage and non-valuable property occur each quarter and
audits are logged and verified.
Two officers are present during the processing of detainee funds and
valuables during in-processing to the facility. Both officers verify funds
and valuables.
Staff searches arriving detainees and their personal property for
contraband.
Staff procedures follow written policy for returning forgotten property to
detainees.
Property discrepancies are immediately reported to the CDEO or Chief of
Security.
Staff fo llows written procedures when returning property to detainees.

CDFIIGSA 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; and
• 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.

[gI ACCEPTABLE

DEFICIENT

[]

OAT-RISK

Policies and procedures do not
address a time frame or schedule
for conducting audits.

Forgotten property belonging to
ICE detainees is forwarded to
ICE.

Standard Operating Procedure
06-16 (Inmate property
management)

Standard Operating Procedure
06-16.
REPEAT FINDING

REMARKS

The facility's policies and procedures maintain proper accountability and storage of detainee funds and property.

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/ May 15,2008

AUDITOR'S SIGNATURE/DAT

2.,,--.-

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Page 22 ofn

DETAINEE GRIEVANCE PROCEDURES

EVERYFAdLITY WILL DEVELOP AND IMPLEMENT STANDARD OPERATING l'ROCEJ)URES (SOPS) FOR AoDlrnSSINGDETAINEE
GRIEVANCES. IN TrivmLYFASHION. EACH STEP IN THE PROCESS WILL OCCl,JR WITHIN THE PRESCR.I6BD TIME FRAME. AMONG OTHER TlIINGS, A
GiuEVANCEWILL BE PROCESSED, INVESTIGATED, AND DECIDED (SUBmcr TO APPEAL) iN' ACcORDANCE wmITHE SOPS; A GRIEVANCE
cOMMiTTEE WILt CONVENE AS PROVIDED IN THE SOPS. STANDARD PROCEDURE WILL INCLUDE PROVIDING THE DETAINEE WITH AWRITTEN
RESPONSETO ANy FORMAL GRIEVANCE; WHICH WILL INCLUDE Tim BASIS F()R THE DECISION. TIlE FACILITY WILL ALSO ESTABLISH STANDARD
. PRoCEDURES FOR HANDLING EMERGENCY GRIEVANCES. ALLGRIEVANCES WILL RECEIVE SUPERVISORY REVIEW. REPJU<lALAGAlNSTTHE FILER
OF A GRIEVANCE WILL NOT BE TOLERATED.
POLlet:.

COMPONENTS

Written' procedures provide for the infonnal resolution of oral
grievances (Not mandatory).
• If yes; the detainee has up to five days within which to make
hlslher concern known to a member of the staff.
Detainees have access to the grievance committee (or equivalent in
IGSA), using fonnal 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 staffknows how to identify emergency grievances,
including the procedures for expediting them.

There are documented or substantiated cases of staff harassing,
disciplining, penalizing, or otherwise retaliating against a detainee who
lodged a complaint:
• If yes, explain.
Procedures include maintaining a Detainee Grievance Log.
• If not, an alternative acceptable record keeping system is
maintained.
• "Nuisance complaints" are identified in the records.
• For quality control purposes, staff document nuisance
complaints received but not filed.
Staff is required to forward any grievance that includes officer
misconduct to a higher official or, in a CDFIIGSA facility, to ICE.

~ ACCEPTABLE

D DEFICIENT

Standard Operating Procedure
07-08, Section 8.4.1

Standard Operating Procedure
07-08, Section 8.2.2

REMARKS

The Inmate Services Supervisor
reviews each grievance prior to
assignment. Any grievance that
appears to be emergency related
is expedited Quickly.
There were no cases of staff
harassing, disciplining, or
retaliating against a detainee
reported.

A log is maintained by the
Program Manager / Inmate
Services Supervisor.

Verbal verification was received
from Inmate Services staff.

AT-RISK

D REPEAT FINDING

REMARKS:

The facility has developed and implemented standard operating procedures (SOPs) for addressing detainee grievances in timely
fashion. Grievances are processed, investigated, and decided (subject to appeal) in accordance with the SOPs.

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AUDITOR'S SIGNATURE / DATE

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Page 23 of72

ISSUANCE
AND EXCHANGE OF CLOTH,ING,.BEDDING,AND
TOWELS
:.
.
. . ....
..'-"
';""
,

. '.'

.'.

,'.

POLICY: ICE REQUIRES THAT ALL FACILITIES HOUSING

....

ICE DETAINEES PROVIDEci.EAN CLOTHING, B:EDDING; UNENS AND TOWELS TO EVERY"

. ICE DETAINEE UPoN ARRN..v.: FURTHER, FACILITIES SHALL PROVIDEICE DETAINEES wrmRECmLAREXCHANGES OF CLOTHING, UNENS, AND
TOWEls FOR AS LONG AS THEY REMAIN IN DETENTION.
.
.
COMPONENTS

The facility has a policy and procedure for the regular issuance and
exchange of clothing, bedding, linens, and towels.
•
The supply of these items exceeds the minimum required for the
number of detainees.
All new detainees are issued clean, temperature-appropriate, presentable
clothing during in-processing. Detainees receive:
•
One uniform shirt and one pair of uniform pants, or one
jumpsuit;
•
One pair of socks;
• One pair of underwear (Daily change); and
• One pair of facility-issued footwear.
Additional clothing is available for changing weather conditions, or as
seasonally appropsiate.
New detainees are issued clean bedding, linens, and towels. They receive
at a minimum:
One mattress;
• One blanket;
• Two sheets;
• One pillowcase;
• One towel; and
• 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 gannents - twice weekly.
Sheets - weekly.
• Towels - weekly.
Pillowcases - weekly.
Food service detainee volunteer workers are permitted to exchange outer
garments daily.
Volunteer detainee workers are permitted to exchange outer garments
more frequently.

YES

- NA

181

Standard Operating Procedure
06-53

181

Standard Operating Procedure
06-53 Section 8.4.1

181

[8J

Standard Operating Procedure
06-53 Section 8.4

181

Standard Operating Procedure
06-53 Section 6.2

181

Standard Operating Procedure
06-53 Section 8.4

[8J

181

•

[8] ACCEPTABLE

DEFICIENT

OAT-RIsK

REPEAT FINDING

REMARKS:

The facility provides clean clothing, bedding, linens, and towels to every ICE detainee upon arrival. They also provide regular
exchanges of clothing, linens, and towels for as long as they remain in detention.
.

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I Moy 15. 2008

AUDITOR'S SIGNATURE I DATE

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~

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Page 24 of72

' :

';:',.' ,

. MARRlAGE

REQtJE~

.-···::r.:.:'"

;"
"., .

: poi.~CY:ALLDETAmEE MARRIAGE REQimsTS WIlL'REcENE CASE-BY~~B&NSIDERATi~N FRb~.iICE MAN~GEMENT.
Y

t8I

The Field Office Director reviews every marriage request rejected by a
Warden/OlC or IGSA. Rejections are documented.
It is standard practice to require a written request for pennission to marry.

t8I

The written request includes a signed statement or comparable
documentation from the intended spouse confuming marital intent.
The Warden/OlC provides a written copy of his/her decision to the
detainee and hislher legal representative.
When permission is denied, the Warden/OlC states the basis for hislher
decision.
The Warden/OlC provides the detainee with a place and time to make
wedding arrangements.

t8I

COMPONENTS
The Field Office considers detainee marriage requests on a case-by-case
basis.

IZI ACCEPTABLE

DEFICIENT

OAT-RISK

REMARKS.

Standard Operating Procedure
04-101 (Inmate Marriages)

REPEAT FINDING

REMARKS:

A review of policy and procedures indicates a program is in place to acCommodate marriage requests. Standard Operating Procedure
04-10 1 (Inmate Marriages)

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May 15. 2008

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~
~

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IC 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 25 of72

NON-MEDICAL EMERGENCY ESCORTEDT:iUJ>S
•

•

,,"

••

~".',

._.

rOLtCY: THE IMMIGRATION AND CUSTOMS ENFORCEMENT(ICE)MAY PROVIDEDETAJNEES WiTH STfJ'F-ESCO~TED tRIP$~OTHE
cOMMuNITY FOR THE PURPOSE OF VISITING CRmCALLYILL MEMBERS OF THE DETAINEE'S IMMEDIATE FAMILY, ..
OR FOR ATTffiII])iNG FUNERALS;
..

I8lSTANDARDN/A:, CHECKTms BOXlF ALL ICE NON-M:EDICAL EMERGENCY ES(:ORTEllTRIPS ARE HANDLED ONLY BY THE.ICE
FIELD OFFICE OR SUB-OFFICE IN CONTROL OF THE DETAiNEE CASE•.
.
COMPONENTS
The Field Office Director considers and approves, on a case-by-case
basis, trips to an immediate family member's:
• Funeral; or
• Deathbed'
The facility recognizes mother, father, brother, sister, spouse, child, stepparent, and foster parent as "immediate family".
The IGSA facility notifies ICE of all detainee requests for non-medical
escorts.
The detainee's Deportation Officer reviews the file 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.
Each escort includes at least two officers.
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 increase or decrease minimum
restraints in accordance with written procedures and classification level of
the detainee.
Escort officers are precluded from accepting gifts/gratuities from a
detainee, or 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;
• Make no unauthorized phone calls; and
• Know they are subject to search, urinalysis, breathalyzer, or
comparable test upon return.
Standard procedure requires the immediate return to the facility of any
detainee who violates trip rules.

o ACCEPTABLE

o DEFICIENT

YES

"NA.

OAT-RISK

REMARKs

o REPEAT FINDING

REMARKS:
All detainee transportation is accomplished by ICE.
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/ May 15. 2008
AUDITOR'S SIGNATURE I DATE

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Page 26 of72

RECREATION

'·

P6f.IcY: 'IT is ICE poLICY TO PROVIDE ACCESSTO RECREATIONAf;PROORAMs Al-JD ACrWITIES TO ALL ICE DETAINEES, TO THE EXTENT
'pdSSrotE,
ANDWEl.2ARE.
.
' ,
. . . . uNDER 'CONDITIONS OF SECUlUTY AND SUPERVISION
:. . THAT PROTECT TImIRSAFETY
,.
,'

., '

-."

"",'

COMPOJliENTS

', .

The facility has a recreation program and facility.

181

A recreational specialist (for facilities with more than 350 detainees) tailors
the program activities and offerings to the detainee population.
Regular mamtenance keeps recreational facilities and equipment in good
condition.
The recreational specialist or trained equivalent supervises detainee
recreation workers.
The recreational specialist or trainee equivalent oversees recreation
programs for special housing units (SHU) and special-needs detainees.
Dayrooms offer sedentary activities e.g., boardgames, cards television.
Outside activities are restricted to limited-contact sports.

181

[gI

IZI

[gI

0
0
0

Each detainee has the opportunity to participate in daily recreation.
Detainees have access to recreation activities outside the housing units for
at least one hour daily, 5 days a week.

[gI

[]

[gI

Staff checks all items for damage and condition when equipment is
returned.
Staff conducts searches of recreation areas before and after use.

181

[gI

IZI

[]
[]

All recreation areas under constant staff supervision.
Supervising staff is equipped with radios.
The facility provides detainees in the SHU at least one hour of outdoor
recreation time daily, five times per week.
Detainees in disciplinary/administrative segregation receive a written
explanation when a panel revokes his/her recreation privileges.
Special programs or religious activities are available to detainees.

,,'

REMARKS

The facility has indoor and
outdoor recreation facilities.
Recreation is supervised by
correctional staff.

Detainees are not assigned to the
recreation program.
There is no recreation specialist
on staff.
Outside activity is limited to
basketball.
Detainees have access to
recreation at a minimum of 1
hour per day, seven days per
week.

Observations indicated searches
are conducted during population
counts.

Each housing unit has a program
room available to detainees for
special activities and religious
programs.

Volunteers are required to sign a waiver ofliability before entering a secure
IZI
0
0
portion of the facility where detainees are present.
'
Visitors, relatives or friends are not allowed to serve as volunteers.
~
[]
[]
f8J If outdoor recreation is offered, check this box. No further Information Is required when outdoor recreation is offered.
If the facility has no outside recreation, are detainees considered for
transfer after six months?
•
If yes, written procedures ensure timely review of all eligible
detainees.
Case officers make written transfer recommendations about every sixmonth detainee to the OIC.
[]
The OIC documents all detainee-transfer decisions whether yes or no.
[J
lJ
The detainee's written decision for or against an offered transfer
D
documented in his/her A-me.
Staff notifies the detairiee's legal representative of his/her decision to
accCQtldecline a transfer.
If no recreation is available, the ICE Districts routinely review transfer
eligibility for all detainees after 60 days.

o
o
o

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(:) 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 27 of72

:. . . .. .

. ... ..

; •...;

, ....
"

. ..

......

'; ..

POP~y: IT ISICE fPLicVTO PROVD;>E ACCESSrORECRM110NALPR()()RAMS ANoAciivti:ms l'o.AiLICEOETAINEES, TO THEmcrENT
pOSSIBLE,
uNDSRCoNPmONS
OF SECuRrrYAND SUPERVISION'mATPRo-rncrTIffim:'sAiirry:ANi>
WELFARE. : .' . . '
. '. . .'.
/.:..
. .
. ..
. . ' ':.
'
..
..
.
..
.

....

The A-file of every detainee who is held more than 60 days without
accesS to recreation contains either a transfer-waiver signed by the
detainee, or the 0 rc' s written determination of the detainee's ineligibility
for transfer.
The detainee's legal representative is notified of the detainee'sIOrC's
decision.

t8l ACCEPTABLE

o DEFICIENT

.•...

. ...

OAT-RISK

. .

REPEAT FINDING

REMARKS:

Indoor and outdoor recreation is available to all detainees throughout the facility. A minimum of one hour per day is offered.

I May 15. 2008
AUDITOR'S SIGNATURE I DATE
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Page 28 of 72

REUGIOUS PRACfICES>
- ·;C

,',

POLlCY:FACILITJESWlLL PROVIDE ICE DETAINEES OF MLFAITHs WITHREAS.ONABLEJ\Nl) EQUITABLEOPpORTTJNffrnS TO PARTIClPATB IN mE
" PRAel1~ES OF THEm FATIH, LIMITED ONLYBYTIIE CONSTRAINTS OF SAfETY, SECpruTI, Tiffi ORDERLY OPERATIONS OF THE FACILITY AND
BUDGETARY CONSIDERATIONS.
COMPONENTS
REMARKs'
NA
.Y
N

Detainees are allowed to engage in religious services.
Space is available for detainees to conduct religious services.

The facility allows detainees to observe the major "holy days" of their
religious faith.
• List any exceptions.
The facility accommodates recognized holy-day observances by:
• Providing special meals, consistent with dietary restrictions;
Honoring fasting requirements;
• Facilitating religious services; and
• Allowing activity restrictions.
Each detainee is allowed religious items in his/her immediate possession.
Volunteer's credentials are checked and verified before allowing
participation in detainee programs.

•

Members of faiths not represented by clergy may conduct their own
services within security allowances.
Detainees in the Special Management Unit are allowed to participate in
religious practices Wlless otherwise documented for the safety and
security of the facility.

rgj ACCEPTABLE

DEFICIENT

IZI

O·

181

[]

IZI

lZJ

181

OAT-RISK

Religious services are held in
the program rooms of each ,
housing area.

Standard Operating Procedure
07-06 (Inmate Access to
Religious Services)

Background checks are
performed on all prospective
volunteers.

o REPEAT FINDING

REMARKS:

Religious programs offered are available to all detainees. Detainees are allowed soft cover reading materials, prayer rugs, rosaries, etc.
in their possession. Religious services are performed in the program rooms of each housing unit.

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May 15,2008

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AUDITOR'S SIGNATURE 1 DAT

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 29 of 72

. .•.

VOLUNTARYWORKPR()GRAM

, .
.

PdtI<~Y: ·. IN .EVERY FACnxrvOFFERINO AVOLUNTARY WORK PROGRAM; ICE DETAINEEs WILL iiAVETHa oPPOlrrul-nTv TO V;;ORK ~EARN' .
MONEY BYPARTICIPATINO~ WHILE NOT LEGALLY REQUIRED, iCE AFFoRIisPlITAJNE~'wORK.ERS BAstc OCcUPATIONAL SAFij"rv AND.1IEALm

ADMINISTRAtION (OSHA) Pit9TEcrIONS.

. .

' .

I2SICHECKHEREIFICEDETAINEESARENOTAUTHORIZEDTOWORKATTHEIGSAFACILITY; MARKNAONF()RMG-324A,PAGE3
ANn MOVE TO NID(,f SEctl()N;
.'
.
.
'
, '. '
,' ,
..
COMPONENTS .
Does the facility have a voluntary work program?
• Do ICE detainees participate?
Detainee housekeeping meets neatness and cleanliness standards.
Detainees have the opportunity to participate in special details, however,
are never allowed to work outSide the secure perimeter.
Written procedures govern selection of detainees for the Voluntary Work
Program.
Where possible, physically and men-tally challenged detainees participate
in the program.
The facility complies with work-hour requirements for detainees, not
exceeding:
• Eight hours a day and Forty hours a week.
Detainee volunteers generally work according to fixed schedule.
If a detainee is removed from a work detail, staff places the written
justification for the action in the detainee's detention file.
Staff, in accordance with written procedure, ensure that detainee
volunteers understand their responsibilities as workers before they join
the work program.
The voluntary work program meets:
• OSHA, NFPA, ACA standards
Medical staff screen and formally certify detainee food service
volunteers.
• Before the assignment begins; and
• As a matter of written procedure
Detainees receive safety equipment! training sufficient for the assignment.
Proper procedure is followed when an ICE detainee is injured on the job.

ACCEPTABLE

o DEFICIENT

., y

[]

0
0

[]
[]

OAT-RISK

REMARKS

REPEAT FINDING

REMARKS

The facility's voluntary work program is offered to sen
b6,b7c

May 15,2008

AUDITOR'S SIGNATURE IDAT

b6,b7c

d detainees, therefore; ICE detainees do not qualify for participation.

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. '

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02007 Creative Corrections, LLC (Rev. 12/8/07)

Page 30 of72

SECTION TIl. HEALTH SERVICES STANDARDS

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 31 of72

'.,

iNo

ADMn-iciTRATIVE MANAOEMENT'OF ICE DETAINEES
ENOACHNO INinJNOER sTRIKEs. By MqNITOruNOOF Tlffii-rBALri:I ANti WELFARE OF THE INDivIDUAL DETAINEES, FACILITIES WILL STRIVE TO .
SUSTArN THEIR LIVES.
<,
,
'.
.'

POLICY: ALL FACILITIES WILLPOLL6WSTANDN:U;6UIDELlNESFORTHE MEDICAL

.. '

.' ...' COMPONENTS . . .

••.. . •. . ;

N .... ···NA:

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

CDFs and IGSAs immediately report a hunger strike to the ICE.
The facility has established procedures to ensure staff respond
immediately to a hunger strike.
Policy and procedure require that staff isolate a hunger-striking 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.
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 document and provide 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 1839 or similar IGSA form.
The medical staffhas written procedures for treating hunger strikers.
Staff documents all treatment attempts, including attempts to persuade
hunger striker of mediCal risks.
Staff has received training in identification of hunger strikes. Medical
staff receives early training in hunger-strike evaluation and treatment.
Staff remains current in evaluation and treatment techniques.

IZI ACCEPTABLE

DDEFICIENT

D
D

D
AT-RISK

REMARKs
Per Atlanta City Detention
Center SOP # 06-86 titled
lNMATE HUNGER STRIKES
"When staff consider it prudent
to do so, a referral for medical
evaluation may be made without
waiting 72 hours."

The facility commander will
authorize re-assignment to a dry
cell for monitoring of all food
and liquid intake and output.
This is done by custody in
conjunction with medical.

. This is done by medical staff.

SOP # 06.86 cited above.

There is no indication that staff
receives training in recognition
of hunger strikes although the
Director of Nursing states this is
being done.

D REPEAT FINDING

REMARKS:

There were two documented hunger strikes in 2007, but none so far in 2008. Records show that protocol was followed.
The hunger strike policy in place is very good with the exception of the m~ntion of training.

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(02007 Creative Corrections, LLC (Rev. 12/8/07)

Page 32 of72

There is currently no indication that staff receives training in recognition of hunger strikes.

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/ May 15,2008

AUDITOR'S SIGNATURE I DATE

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Page 33 of72

-------------------------------------.....

. .... ' .•......

. ":

.....

,. .....'.::.

· t · ACtESS;TOMEDICALC~

....:.:.

,-.

..:.: -

. .

.. ".

.:'"

. '.:'

'. ....

.- ":L" ".'

-."!

.', -' :., . " . . ,.:
..'
.'.
'..,.
POLlCY: EVERYFACILITY~EST,ABIJSHAND MAINTAIN AN,ACCREDITED/ACCREOITATION'WORTHYHEALTH PROGRAM FOR THE GENERAL.

....

. '.'

....

WELL~BEIN'GOFI~DETAlNEES.

...... ' :

.'.

COMPONENTS

. _.

.:....'.

'. -'

N -.

. NA

Facilities operate a health care facility in compliance with state and local
laws and guidelines.

The facility's in-processing procedures for arriving detainees include
medical screening.
All detainees have access to and receive medical care.

The facility has access to a PHSIDIHS Managed Health Care
Coordinator.

[]

The medical staff is large enough to provide, examine, and treat the
facility's detainee population.

The facility has sufficient space and equipment to afford detainee privacy
when receiving health care.

The medical facility has its own restricted-access area. The restricted
access area is located within the confines of the secure perimeter.
The medical facility entrance includes a holding/waiting room.
The medical facility's holding/waiting room is under the direct
supervision of custodial staff.
Detainees in the holding/waiting room have access to 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; and
•
Procedurally, no copies made and placed in detainee fIles.
Pharmaceuticals are stored in a secure area.
Medical screening includes a Tuberculosis (TB) test.
• Every arriving detainee receives a TB test during the admission
process;
•
Detainee's TB-screening does not occur more than one business
day after his/her arrival at the facility; and
• Detainees not screened are housed separate from the general
population.

,.·REMARKS
Per City of Atlanta DOC SOP #
07-11 titled
.ADMINISTRATION OF
lNMATE MEDICAL
SERVICES/SICK CALL states,
"It is the policy of the Health
Authority (Medical Directory)
to make decisions relating to
medical services."
This is reviewed within 8 hours
by a Health Care Professional.
Per City of Atlanta DOC SOP #
07-11, "It is the policy of the
Atlanta Dept of Corrections to
provide all inmates with the
opportunity to report a medical
illness or other health problem
and to receive diagnosis and/or
treatment by a qualified health
care professional."
This is accessed via the ICE
field office in Atlanta and
Washington, DC.
There is a doctor here' 7 days per
week and on-call 2417. A
dentist is here 2 days per week
for 8 hours per day. There is a
total of 15 nursing/tech staff to
cover 2417.
Severnl exam rooms are
available in the medical area
along with a triage room on each
cell block floor.

This is done on arrival at the
facility during medical/mental
health screening.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 34 of72

.<, .

~,:o

; 'ACCESST() MEDICALCARE·
. : .. ·

.~'"

.....

:':.

0" •

-~."

: )'()Licv:EVERY ~ACtt;rrY W]u;ESTAB'UsHAND MAwr~iNACcR~D~D/~cGREbrrAi16N~w(irHY ~fu PROORAMF~R THE GENERAL
'WELI>BElN9 OF ICE DET~ES.
'.': .'- ", .' :'.

' .'

All detainees receive a mental-health screening upon arrival. It is
conducted:
• By a health care provider or specially trained officer; and
• Before a detainee's assignment to a housing unit.
The facility health care provider promptly reviews all 1-794s (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.

C8l

Detainees in the Special Management Unit have access to health care
services.

Staff provides detainees with health services (sick call) request slips
daily, upon request.
• Request slips are available in languages other than English,
including every language spoken by a sizeable number of the
facility's detainee population.
• Service-request slips are delivered in a timely fashion to the
health care provider.
The facility has a written plan for the delivery of 24-hour emergency
health care when no medical personnel are on duty at the facility, or when
immediate outside medical attention is required.
The plan includes an on-call provider.
The plan includes a list of telephone numbers for local ambulance 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 Form 1-819 (or IGSA equivalent) is used to notify the
WardenlFacility ofa detainee that has special medical needs.
A signed and dated consent form is obtained from a detainee before
medical treatment is administered.

This is done in the
intake/receiving area and
reviewed by a health care
provider.
This is completed within 8 hours
of admission to the facili!Y,
Per SOP # 06-71 titled
INMATE HEALTH
APPRAISALS, "An appropriate
health care provider will
conduct a health appraisal on
inmates within 14 days of their
arrival to the facility."
Per SOP # 07-11, "A Health
Care Provider will perform daily
rounds in special management
housing units and check directly
with (detainees) as to whether
they have any medical
concerns."

C8l

Request slips are not available
in Spanish but a number of staff
speaks Spanish and a language
telephone line is available 2417,

C8l

Grady Medical Center is the
designated backup treatment
facility.

C8l

[J
D

C8l

Per ACDC SOP # 05-119 titled
EMERGENCY CARE AND
CPR TRAINING states, "Both
health trained and correctional
personnel are trained and
certified in CPR at least every
two years."
The only people who distribute
medication are nursing staff.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
<C 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 35 of72

.AC<;ESSTQMEDICAL.CA,RE
•

POllCY: EVERyFACll..lTY wui ESTABLISH ANDMAwrAlNAN ACCREbrfEOIACcREDITA11ON~WORnlY-HBALTH PR~RAMFOR tim OENERAL
WELL-BEiNO OF ICE DETAINEES~'

'.'..

Detainees use the 1-813 (or IGSA equivalent) to authori~ 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 A-number and marked "MEDICAL
CONFIDENTIAL".

!ZI ACCEPTABLE

DEFICIENT

18I

OAT-RIsK

ACDC SOP # 06-62 titled
HEALTH RECORD FILES
mdicates requests for reviewing
or copying a medical record will
require proper consent or release
of information form.
This sometimes is very short
notice but medical is staffed
2417 and records for transfer are
easily obtained.

REPEAT FINDING

REMARKS:

The medical area is located on the 3rd floor with an adjacent cell block that is handicap accessible. The area is clean and well lighted.
No expired medications were noted. Narcotics are in a double locked cabinet behind a locked door. Needles/syringeS/sharps are in
locked cabinets and accounted for on a running inventory every shift. All staff providing care to detainees are licenSed, certified, or .
registered in the State of Georgia.

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/ May 15. 2008

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AUDITOR'SS'GNATUR.IDATE

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
(02007 Creative Corrections, LLC (Rev. 12/8/07)

Page 36 ofn

...

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

SUICIDE )JREVEl'ffION;ANDINT~VENTI()N:

.. ....

·~Q(ICY:·.· ALi~lITENnO~·S;~F WbRKING"~ ICgDk~~·.~·~~·~~()·~~~·St1;CIDE-RlSK INtiicATORS.·. ·STAFp·wrrL·

HANbm POTENTIm.YSUIcIDAL IWNWUALS WrrHSBNSITIVriY, SUPERVIsIOkANDREFE~'; Aa.ooCALLySUICIDAL DETAINEE WILL
'RECEIVEPREVIDmVESUPERVISIONANoTREATMENr:: ., . . ',,: ' ., ". ~ . '. ." ,' . .. ..'
, , . . ..
..
. . COMPONENTS' , :
y
. N
NA :
REMARks
Every new staff member receives suicide-prevention training. Suicideprevention training occurs duriilg the employee orientation program.
~

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

Written procedures cover when and how to refer at-risk detainees to
medical staff andprocedures are followed.
The facility has a designated isolation room for evaluation and treatment.
The de~ignated isolation room does not contain any structures or smaller
items that could be used in a suicide attempt
Medical staffhas approved the room for thispurQose.
Staff observes and documents the status of a suicide-watch detainee at
least once every 15 minutes.

[8J ACCEPTABLE

o DEFICIENT

OAT-RISK

[]

Per ACDC SOP # 06-68 titled
SUICIDE PREVENTION, "All
staff members who have contact
with inmates will be trained in
the recognition of verbal and
behavioral clues which indicate
potential suicide risk. "

Per above referenced policy,
"During the initial screening
process, the Health Care
Provider will complete the
'Intake Screening' form which
will include aD assessment of
suicide risk. "

REPEAT FINDING '

REMARKS:
There have been no suicides in the last year. The suicide program/policy in place is very adequate. Mental health is accessible from
0700 to 2300 and on call during the remainder of time.

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I May 15.2008

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AUDITOR'SS'GNATURE/DAB

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4)

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Page 37 of72

TE~AL ILLNESS, AnVANCED DIl{ECTIVES,AND DEATH .

ANn

.'JioLicy ALL FACILITIES HOUSING ICE DETAINEEs sHAll. HAvB POLIcIEs
PROCEDURES ADDRESSING TIIE ISSUES OF TERMINAL rrllrnsSOR'
, INJURY;.MEoICAL AnvANCED DIRECTIVES, AND J)ETAlNEE DEAm,TO INC~UDErnE PROCEDURES TO E~SURE PROPER NOTIFICATION IS.
PROVroEI) TO ICEOFFICIALS, FAMILYMEMBERS AND OTHJ3R INTERESTED PARTIES INTIIEEVENTOF ADETAJNEE BECOMINGTERMlNALI,YILLOR'
u.trtJRED OR DEATHOF A DETAINEE OCCURS .. IN ADDmON, THE POLICY WILL COVER PROCEDmrnsro BE TAKEN IFTIIEDEATH OF A DETAINEE
, 6cCURSWHILEIN TRANSIT.
18I',C:~'cKTHISBQX IFTHE FAOLITY DOFS NOT ACCEPT ICE DETAINEFS WH.O ARE SEvERELY OR TERMINALLY ILL.

INDICATE NA IN

TIlE APPROPRIATE BOX FOR THIS PORTION OF mE WORKSHEET. AiWAYS COMPLETE ALL REFERENCFS TO DETAINEE DEATH AND
'IaLATEDNOTIFICATiONS,
.....•..
COMPONENTS
"

Detainees who are chronically or tennina\ly ill are transferred to an
appropriate offsite medical facility.
The facility or appropriate ICE office promptly notifies the next of kin of
the detainee's medicalcondition, to include:
•
The detainee's location; and
•
The limitations placed on visiting.
There are guidelines addressing the State Advanced Directive Fonn for
Implementing Living Wills and Advanced Directives.
•
The guidelines include instructions for detainees who wish to
have a living will other than the generic fonn the D IHS provides
or who wishes to appoint another to make advance decisions for
him or her.
The guidelines provide the detainee the opportunity to have a private
attorney prepare the documents.
There is a policy addressing "Do Not Resuscitate Orders"

. .'.

o
o

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

o
o

o
o
o

REMARKS

ACDC SOP # 06-55 titled
INMATE TERMINAL
ILLNESS states, "The Director
of Nursing is responsible for
ensuring that each inmate is
infonned ofthe right to establish
a DNR order upon hislher
admittance to the facility."
These detainees would not be
housed at this facility.

This is covered in the above
sited policy.

FOR OFFICIAL USE ONLY (LA W ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 38 of 72

The facility follows established policy and procedures describing when to
contact the local coroner regarding such issues as:
• .Perfonnance of an autopsy;
• Who will perfotnl the autopsy;
•
Obtaining state approved death certificates; and
•
Local
of the
ICE staff follows established procedures to properly close the case of a
deceased detainee.

~ ACCEPTABLE

OAT-RIsK

DEFICIENT

REPEAT FINDING

REMARKS:

According to the ICE agent, this facility would not house tenninally ill detainees. They would be transferred to a facility that had United
States Public Health Service staff and a compassionate release would be pursued or the individual may be deported to their COWltry of
origin.

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/May 15. 2008

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L..
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SECTION IV. SECURITY AND CONTROL

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 40 of 72

coNTRABAND·

PoiicY: ALL DETENTION FACILITIDS. WILL BNSURETHE PROPER HANDLING AND D,ISPoSAL OF
CONTItAaAiID DESTRUCTION IS REQUI:R.ED.· •
....

COMPONENts

The facility follows a Written procedure for handling illegal contraband.
Staff inventory, hold, and report it when necessary to the proper authority
for action/possible seizure.

AlL coNfiwjAND. DoCuMENTATION OF.
NA

o
o

Contraband that is government property is retained as evidence for
potential disciplinary action or criminal prosecution.

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

Altered property is destroyed following documentation and using
established procedures.
.
Before confiscating religious items, the OIC or designated investigator
contacts a religious authority.
Staff follows written procedures when destroying hard contraband that 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 specified written
procedures. Hard contraband is secured when not in use.

[8J ACCEPTABLE

DDEFICIENT

AT-RIsK

... REMARKs

...

SOP 200-6 (Control, Handling
and Disposal of Contraband)
outlines procedures for
inventorying, holding, and
reporting contraband for
action/possible seizure.
SOP 06-29 (Cell Search
Security) states that evidence to
be used in a disciplinary hearing
will be secured in the Watch
Commander's custody.
SOP 06-29 (Cell Search
Security) directs that property
not needed as evidence is
returned to the proper authority.

SOP 200-06 (Control, Handling
and Disposal of Contraband)
states that hard contraband will
be transferred to the responding
or investigating police personnel
for disposition.

D REPEAT FINDING

REMARKS:

The facility policy governing contraband was significantly revised during the review resulting in an acceptable rating in this section.

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/MayI5,2008

AUDITOR'S SIGNATURE I DAT

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Page 41 of72

DETENTION' FiL"tS....

P6LICY(~VERY FACilITY
OOATE ADE-mNrIONFILE FOR EVERY ICE DjITkum BoOI<.ED
TIIEFACILITY, EXCLuD~G ONLY
DETAINEESScirnDULED TO DEPART WITHIN 24 HOURS. THE DETENTION FILE WILL CONTAIN COPIES AND, IN SOME CASES,THE ORIGINAL OF ·
'SPECIFIEDDOc()MENTSCONCERNINQ
DETAiNEE'S STAYIN THEJ!A6LITY: :cLASsIFI0TIO~SHEBT, MEDICAL QuEsTIONNAIRE, PROPERTY
INVEN'rORY SHEE-r, DISCIPLINARY OOCMNTS, ETC.
...
, ....
. ...
. C O M P O N E N r s Y .. •. N:
NA
REMARKs , ·

n:tro

TIIE

A detention file is created for every new arrival whose stay will exceed
24 hours.
The detainee detention file contains either originals or copies of
documentation and forms generated during the admissions process.
The detainee's detention file also contains docwnents generated during
the detainee's custody.
• Special requests
• Any G-589s and/or 1-77s closed-out during the detainee's stay
• Disciplinary forms/Segregation forms
•
Grievances complaints and the disposition(s) of same
The detention files are located and maintained in a secure 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 docwnentation.
The officer closing the detention file makes a notation that the file is
complete and ready to be archived.
Staff makes copies and sends docwnents from the file when properly
requested by supervisory personnel at the receiving facility or office.
Appropriate staff has access to the detention files, and other departmental
requests are accommodated by making a request for the file. Each file is
properly logged out and in by a representative. of the responsible
department.

IZI ACCEPTABLE

o DEFICIENT

OAT-RIsK

Special requests and grievances
are filed in the Program's section
of the facility.

Detention files are secured in a
locked cabinet in a separate
room.

A review of25 ICE detainee
files revealed release related
documents were included.

o
o

An activity log tracks files.

REPEAT FINDING

REMARKS:

25 detainee files were reviewed. All contained medical questionnaire forms, property forms, classification docwnentation, and
disciplinary information (when applicable) .

b6,b7c

I May 15.2008

b6,b7c
b6,b7c

AUDITOR'S SIGNATURE I DAT

0~
.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 42 of72

,, "
'

. .' :

. " -;.

...

,"-.•.

". . .. •. ... .. ....mSCIPLIN)\RYPOIJCY " .

" ;,

•· P~I-ICY:.C~~t~~~~~~~Ru;~~~it~i~EIl~o· u.wd~E.DlS¢WUNE()NhET~EEs·· WHOSE.U~~OR IS.Ndr·W
.. . . ....

COMPONENTs

..... .

NA ' . . .•

The facility has a written disciplinary system using progressive levels of
reviews and appeals.

The facility rules state that disciplinary action shall not be capricious or
retaliatory.

Written rules prohibit staff from imposing or permitting the following
sanctions:
• corporal punishment
• deviations from normal food service
•
clothing deprivation
• bedding deprivation
• denial of personal hygiene items
•
loss of correspondence privileges
• deprivation of physical exercise
The rules of conduct, sanctions, and procedures for violations are defined
.in writing and communicated to all detainees verbally and in writing.

The following items are conspicuously posted in Spanish and English,
and other dominate languages used in the facility:
•
Rights and Responsibilities
• Prohibited Acts
• Disciplinary Severity Scale
• Sanctions
When minor rule violations or prohibited acts occur, informal resolutions
are encouraged.
Incident reports and Notice of Charges are promptly forwarded to the
designated supervisor.
Incident reports are investigated within 24 hours of the incident. The
Unit Disciplinary Committee (DDC) or equivalent does not convene
before an investigation ends.

[gI

REMARKS

Standard Operating Procedure
07-25 (Inmate Discipline
Procedure) provides a written
disciplinary system using
progressive levels of reviews
and appeals.
SOP 07-25 (Inmate Discipline
Procedure) precludes staff from
imposing discipline in a
capricious or retaliatory manner.

SOP 07-25 (Inmate Discipline
Procedure) prohibits staff from
imposing or permitting corporal
punishment or other deviations
and deprivations.

The rules of conduct, sanctions,
and procedures for violations
are defined in writing and
communicated to all detainees
verbally by a staff member
during orientation.

[gI

An intermediate disciplinary process is used to adjudicate minor
infractions.

A review of disciplinary packets
confirmed that incident reports
are investigated within 24 hours
of incidents.
The facility endorses a "negative
contact" method as an
intermediate disciplinary
process to adjudicate infractions
of moderate severity. Detainees
may receive 8 hours of cell
restriction as a sanction imposed
by the shift commander.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)

o 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 43 ofn

...

: ..

DISCIPLINARY I'OLICY
.,

POLuN:,'ALiFACIUTIES HOUSING ICE DETAINEES.ARE AUTHORIZED:TO IMPOSEDISCWLINE'ONI;>ETAINEES WHOSE BEHAVIOR IS NOT IN
. . cOMPLIANcE WITH FACILITY RULES AND REGULATIONS.
. . . . -'". .
,"
.y
,NA
COMPONENTS
REMARKs
N

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 detainees and staff representatives;
• Bases its findings on the preponderance of evidence; and
• Imposes only authorized sanctions
A staff representative is available if requested for a detainee facing a
disciplinary hearing,

•

181

The inmate discipline hearing
coordinator (Sergeant) conducts
hearings on all charges.

Standard Operating Procedure
07-25 (Inmate Discipline
Procedure) affordS detainees
staff representation during
disc~lin~proceedin~.

The facility permits hearing postponements or continuances when
conditions warrant such a continuance. Reasons are documented.
The duration of punishment set by the OlC, as recommended by the
disciplinary panel, does not exceed established sanctions. The maXimum
time in disciplinary segregation is limited to 60 days for a single offense.
Written procedures govern the handling of confidential-informant
information. Standards include criteria for recognizing "substantial
evidence"

181

All forms relevant to the incident, investigation, committee/panel reports,
etc., are completed and distributed as required.

181

I:8J ACCEPTABLE

DEFICIENT

OAT-RISK

The facility does not have
written criteria governing the
handling of confidentialinformant information.

REPEAT FINDING

REMARKS:

The facility does not have written criteria governing the handling of confidential-informant information.

LMay1S,2008
b6,b7c
AUDITOR'SSIGNATURE/D

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FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
© 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 44 of72

..... .' ':",

. :.- .:~." .': ',:

" .,

· J!:MEJlGENGy:«:pmlNGEN~Y),PLANS ··' ,

'POiI~~ AllFA~ILtrIES HOU)lNhICibEf~~WIiL~I'O~~~~~ENcwi~APREoim~sr~AiwIZED PLAN TO MINiMizE .'

.. rnBl-WwIl'lO OF HuMAN LIFE 00 THE DaSTRl)CfIONOFPROPERT'l.: It)S'Rii!cOM:Ml3NDEDTHI\.T SPCSANJ)CDFSmtrERflI!TO AOREEMENT,VlA

MEMORANDUM OF.UNDERSTANDINQ·(MoU),wrm FEDERAL,L6CAL AND STATE AOENCllisTo ASSIST IN TIMES OF EMEROENCY.
COMllONOOS
.....
Policy precludes detainees or detainee groups from exercising control or
authority over other detainees.

Detainees are protected from:
• Personal abuse
• Corporal punishment
• Personal injury
• Disease
• Property damage
• Harassment from other detainees
Staff is trained to identifY signs of detainee unrest.
• What type of training and how often?

NAREMARKS

jgI

I8J

Staff is trained 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.

Staff effectively disseminates information on facility climate, detainee
attitudes, and moods to the Officer In Charge.(Ole)

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:
• Local law enforcement agencies
•
State agencies
• Federal agencies
All staff receives copies of Hostage Situation Management policy and
procedures.

Facility policies protect
detainees from personal abuse,
corporal punishment, and
personal injury, but do not
address disease, property
damage or harassment from
other detainees.
Facility staff receives two hours
of Jail Climate training during
Basic Jail Training.
Information relevant to facility
climate, detainee attitudes, and
moods is documented in
individual unit log books.
Additionally, this information is
documented in the Supervisor's
"pass on" book for further
dissemination.
The Emergency Management
Coordinator (Lieutenant) is
responsible for emergency
plans and their implementation.
The Emergency Plans do not
address confidentiality,
accountability, annual review
procedures/schedule or
revisions.
Contingency plans do not
include a comprehensive
general section with procedures
appliCable to most emergency
situations.
The facility has memorandums
of understanding with local,
state and federal agencies,
including Fulton County and
.
the USP Atlanta, Ga.
All staff signs for their
individual copies of the
Hostage Situation Management
policy and procedures.
SOP 06-04 (Riot and Hostage
Situations) states that all staff
members relinquish all power
and authority if taken hostage.

FOR OFFICIAL USE ONLY (LAW-ENFORCEMENT SENSITIVE)
02007 Creative Corrections, LLC (Rev. 12/8/07)

Page 45 of72

EMERGENCY(COra'lNGENcy)
..
.
- PLANs:
"

,.'

' . '

'POilb~ALL ~ACIiITIESHbLDINO ICEDIITMNEES,WniRESP0ND TO EMmtG~cri3SwITHAPREDErnRimrno,STANDARDIZED PLAN TO MINIMIZE

'. THE ~GOF HUMANLIFEANDTHE PESTRUCTIONOFPROPERTY. IT IS RECoMMENDEoTIlAT SPCS OOCPFSENTERINTO AGREEMEm,VIA

MEMORANDUM OF'UNDERSTANDING {M()U),wrrn FEDERAL

LOCAL AND STArBAGENCIEs.TO,ASSIST IN TIMES OF EMERGENCY.

",'"
, ' , ' 'CoMPONENTs
Food service maintains at least 3 days' worth of emergency meals for staff
and detainees.
Written plans identitY locations of shut-off valves and switches for all
utilities (water, gas, electric).

",' Y

o
Written procedures cover:
• WorkIFood Strike
• Disturbances
• Escapes
• Bomb Threats
• Adverse Weather
• Internal Searches
• Facility Evacuation
• Detainee Transportation System Plan
• InternalIIostages
• Civil Disturbances
~ ACCEPTABLE

DEFICIENT

OAT-RISK

o
o

The facility contingency plans
do not identitY locations of
shut-offvalves and switches for
all utilities (water, gas"
electric). SOP 06-10 (Bomb
Threats) states that maintenance
staff would be summoned to
terminate utilities if necessary.

Written procedures cover
disturbances, escapes, bomb
threats, adverse weather,
facility evacuation, and
hostages, but do not cover
work/food strike, internal
searches, detainee
transportation system plan, or
civil disturbances.

REPEAT FINDING

REMARKS:

Facility policies protect detainees from personal abuse, corporal punishment, and personal injury, but do not address disease, property
damage, or harassment from other detainees.
The Emergency Plans do not address confidentiality, accountability, annual review procedures/schedule, or revisions.
Contingency plans do not include a comprehensive general section with procedures applicable to most emergency situations.
The facility contingency plans do not identitY locations of shut-off valves and switches for all utilities (water, gas, electric). SOP 06to (Bomb Threats) states that maintenance staff would be summoned to terminate utilities if necessary.
Written procedures cover disturbances, escapes, bomb threats. adverse weather, facility evacuation, and hostages, but do not cover
work/food strike, internal searches, detainee transportation system plan, or civil disturbances.

b6,b7c

/ May 15.2008

AUDITOR'S SIGNATURE I D

b6,b7c

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
CO 2007 Creative Corrections, LLC (Rev. 12/8/07)

REMARKS

Page 46 of 72

ENVIRONMENTALlIEAI..TH AND
SAll'ETY .
,
.

_,·ft.

'~':.

"."

POLICY: EVERY FACILITY WILL CONTRO~FLAMMA:aLE; TOXIC, AND CAUsTICM!-TEruALs TIIRCJlrGHAHAZARDC)uS MATERwB PR()ORAM. THE
PItOGRAMwiLLINCLUDE. AMONO OTIffiR THINGS, THE IDENTIFICATION ANDuBELINO OF HAZARDOUS MATERIALS IN ACCOIwANCE WITH
APPLiCABLESTANDARoS (E.O.; NATIONAL FIRE PROTECTION AsSOCIATION [NFPAj); 'IDENTIFICATION OF. INCOMPATIBLE MATERIALS, ANn
'SAFE-lIANDLlNO PROCEDURES .
.
. .
.'
COMPONENTs.
Y
REMARKs
N
NA
The facility has a system for storing, issuing, and maintaining inventories
Inventories are maintained in the
of hazardous materials.
~
0
0 food service and maintenance
areas.
Constant inventories are maintained for all flammable, toxic, and caustic
Inventories are maintained in the
substances used/stored in each section of the facility.
~
0
0 food service and maintenance
areas.
The manufacturer's Material Safety Data Sheet (MSDS) file is up-to-date
for every hazardous substance used.
• The files list all storage areas, and include a plant diagram and ~
0
0
legend.
• The MSDSs and other infonnation in the files are available to
personnel managing the facility's safety program.
All personnel using flammable, toxic, and/or caustic substances follow
the prescribed procedures. They:
~
0
0
• Wear personal protective equipment; and
Report
hazards
and
spills
to
the
designated
official.
•
The MSDSs are readily accessible to staff and detainees in work areas.
~
0
0
Hazardous materials are always issued under proper supervision.
All Cleaning solutions are
~
0
0 diluted in the laundry area prior
• Quantities are limited; and
to issuance to the housing units.
• Staff always supervises detainees using these substances.
All "flammable" and "combustible" materials (liquid and aerosol) are
Flammable storage cabinets are
~
0
0 located in the maintenance area.
stored and used according. to label recommendations.
Lighting fixtures and electrical equipment installed in storage rooms and
No flammable storage rooms
0
0
~
other hazardous areas meet National Electrical Code requirements.
were noted.
The facility has sufficient ventilation, and provides and ensures clean air
~
0
0
exchanges throughout all buildings.
Vents, return vents, and air conditioning ducts are not blocked or
~
0
0
obstructed in cells or anywhere in the facility.
Living units are maintained at appropriate temperatures in accordance
with industry standards. (68 to 74 degrees in the winter and 72 to 78
~
0
0
degrees in the summer.)
Shower and sink water temperatures do not exceed the industry standard
~
0
0
of 120 degrees.
All toxic and caustic materials are stored in their original containers in a
~
0
0
secure area.
Excess flammables, combustibles, and toxic liquids are disposed of
~
0
0
properly and in accordance with MSDSs.
Staff directly supervise and account for products with methyl alcohol.
Material Safety Data Sheets
Staff receives a list of products containing diluted methyl alcohol, e.g.,
were reviewed and there were
shoe dye. All such products are clearly labeled. "Accountability"
~
0
0 no
products containing methyl
includes issuing such products to detainees in the smallest workable
alcohol noted.
qUantities.
Every employee and detainee using flammable, toxic, or caustic materials
is provided during
~
0 Training
0
receives advance training in their use storage and disposal.
initial orientation.
The facility complies with the most current edition of applicable codes,
Sprinkler, smoke alann, and
standards, and regulations of the National Fire Protection Association and
~
0
0 portable fire extinguisher testing
the Occupational Safety and Health Administration (OSHA).
is current

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
10 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 47 of72

:,'

.. ... .

. .

. -.

ENVI:jU,)NMENTAL lIE.-\LTHAN.DSA~'fY
",<

I: . . .'

.
"

iPOLICv: EvER.Y MClLrrY WILL CoNTROL FLAMMABLE;:i6Xic, OOCAUirICMATBRrALS!HROUGHA~{JS MArERW.s PROGRAM. THE·

PR()oRAMWILL INCLUDE, AMONG <YrHERniIN(jS,T~ IDENTIFICATION ANI? tABELiNGOF~US MATERWS IN ACCORDANCEWfm
APPLiCABLE8TANDARDS (RG.,N~TIONAL FIRE PROTEctION ASSOCIATION [NFPA]); IDENTIFICAiio~OFINCOMPATIBLE MATERIALs, AND
>:
.
'.
SAFE~HANDLING PROCEDURES . '
.
..
y
.. ..
.. COMPONENTS '
N
NA
REMARKs
Five officers have received
A teclmically qualified officer conducts the fife and safety inspections.
training from the local fire
department to conduct weekly
~
D
D fire
safety inspections. These
officers conduct aU weekly fife
safety insp_ections.
[]
The Safety Office (or officer) maintains files of inspection reports.
[J
~
Standard Operating Procedure
The facility has an approved fire prevention, contro~ and evacuation plan.
-

Standard Operating Procedure

Fire drills are being conducted
quarterly.

A sanitation program covers barbering operations.

The barber shop has the facilities and equipment necessary to meet
sanitation requirements.
The sanitation standards are conspicuously posted in the barbershop.

Written procedures regulate the handling and disposal of used needles
and other sharp objects.
All items representing potential safety or security risks are inventoried
and a designated individual checks this inventory weekly.
Standard cleaning practices include:
• Using specified equipment; cleansers; disinfectants and
detergents.
An
established schedule of cleaning and follow-up inspections.
•

The facility follows standard cleaning procedures.

Spill kits are readily available.

A licensed medical waste contractor disposes of infectiouslbio-hazardous
waste.
Staff is trained to prevent contact with blood and other body fluids and
written procedures are followed.

The plan requires:
• Monthly fife inspections;
• Fire protection equipment strategically located throughout the
facility;
• Public posting of emergency plans with accessible
building/room floor plans;
• Exit signs and directional arrows; and
• An area-specific exit diagram conspicuously posted in the
diagrammed area.
Fire drills are conducted and documented monthly.

07-24

Sanitation standards are
laminated on the barber tool
case.
Standard Operating Procedure
400-03 Section 8.1
Standard Operating Procedure
400-03 Section 8.1

•

Do the methods for handling/disposing of refuse meet all regulatory
requirements?

Standard Operating Procedure
06-61 section 8.7.1

Standard Operating Procedure

I8l

06-61, Section 8.6.1. Standard
Operating Procedure 400-06,
section 8.8.1

FOR OFFICIAL USE ONLY (LA W ENFORCEMENT SENSITIVE)
10 ,2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 48 of 72

ENVIRONMENTAL
HEALTH
AND SAFETY'.
,
.•. .
"I"

.. POLICY: EVERY FACILITY WILL CONTROL FLAMMABLE,TOXIC; AND CAUSTIC MAT'BRIAlS THROUoHAHAZA:RDoUS MATERIAlS PROGRAM. THE
PROGRAM WilL INCLUDE, AMONG oTHERTHmGS, THE IDENTIFICATION AND LABELING OFlIAZARDoUS MATERIALS rNACCoRDANCE WITH
APl'LICABLE S1'ANDARDS (E.G.; NATIONAL FIRE PROTECTION AsSOCIATION [NFPA]); IQENTIFICATION OF INCOMPATIBLE MATERIALS, AND
SAFE-HANDLING PROCEDURES·
...
...
..
.. . .
.
.
COMPONENTS

Y·

A licensediCertifiedlTrained pest-control professional inspects for
rodents, insects, and vennin.
• At least monthly.
•
The pest-control program includes preventative spraying for
indigenous insects.
Drinking water and wastewater is routinely tested according to a fixed
schedule.
Emergency power generators are tested at least every two weeks.
•
Other emergency systems and equipment receive testing at least
quarterly.
•
Testing is followed-up with timely corrective actions (repairs
and replacements).

[gI ACCEPTABLE

D DEFICIENT

[8l

At-RISK

REMARKS·

Orkin has a city contract to treat
all buildings weekly.

The city water department tests
drinking and waste water.

Generators are tested weekly
and load tested quarterly.

D RE,PEAT FINDING

REMARKS:

Fire drills are being conducted quarterly. ICE standards require monthly fire drills.

b6,b7c

I May 15.2008

AUDlTOR'SSIGNATIJ.EIDATE

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1,..0

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
CO 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 49 of 72

... '. ';'

1./·. . . . . . . .

HOLD R,OQMS IN DErENTIONF'ACILI:flES

.... . ..... '. .. '. . '.' .'. . ...<, ; .• . •:;: .'~". ,': <' "

. .

'. '. : ., .•.. .. . .., . '..
"
.' POLICY: HOLD ROOMS WILL BE USED ONLY FOR TEMPORARY DETENTION OF DETAINEESAWAITING REMOVAL,TRANSFER, EOIR HEARINGS;
.' MEbICALTREATMENr,INTRA-iw::ILriYMOVEMEmOR OTHERPROCEsSINOOOOOR ouT OF T~ FACILITY. . .. ' ... ; ..'. .
.
.
."
COMPONENTS
'
.' Y
N . INA
:REMARKs
The hold rooms are situated within the secure perimeter.
~

o
o

[]

Male and females are segregated from each other.
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 au4ible range to allow
detainees access to toilet facilities on a regular basis.

[J
[J

All detainees are given a pat down search for weapons or contraband
before being placed in the room.
Officers closely supervise the detention hold rooms using direct
supervision (Irregular visual monitoring.).
• Hold rooms are irregularly monitored every 15 minutes.
• Unusual behavior or complaints are noted.
When the last detainee has been removed from the hold room, it is given
a thorough inspection.
There is a written evacuation plan that includes a designated officer to
remove detainees from hold rooms in case of rue and/or building
evacuation.

An appropriate emergency service is called immediately upon a
detennination that a medical emergency may exist.

The hold rooms are well ventilated, well lighted, and all activating
switches are located outside the room.
The hold rooms contain sufficient seating for the number of detainees
held.

Bunks, cots, beds, or other related make-shift sleeping apparatus are
precluded from use inside hold rooms.
The walls and ceilings of the hold rooms are tamper and escape proof.
Individuals are not held in hold rooms for more than 12 hours.

~ ACCEPTABLE

DEFICIENT

AT-RISK

The facility has six hold rooms
with each having a capacity of
three detainees.

Detainees are not normally held
in hold rooms in excess of two
hours:

Officers are within easy audible
range for detainees to summon
assistance if needed. Each hold
room is equipped with toilet
facilities.

The Intake Officer is
responsible for removing
detainees from hold rooms in
case of fire or evacuation.

REPEAT FINDING

REMARKS:

The ACDC has a sufficient number (6) of hold rooms to accommodate detainees awaiting removal, transfer, medical treatment, or
other processing needs.

b6,b7c

I May 15.2008

b6,b7c
b6,b7c

AUDlTOR'SSIGNATURE/DA

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0"'-

Page 50 of72

.,. :. .'
. ," KEY AND LOCK CONtJlOL . . "' C . .
'(SECURItY;ACGOUNTABILITY
'·ANQ· ~kANCE)
. .
.
.
.
:. ... . ,,;:: ,- -' ..
:,..

.' ' .'

". '

'. PQud i'r IS THii POLICY OF THE ICE,SERVICB TO MAlNTAlNAN I3FFICrENT SYSTEM FOR.TIrnUSE,ACCOUNfABiLITYAND~ANCEOF'ALL'

:KEySANoWcKs.

.... ... ....

COMPO~

.' . ,

" ' ,'

' :

The security officer(s], or equivalent in IGSAs, has attended an approved
locksmith training program.
The security officer, or equivalent in IGSAs, has responsibly for all
administrative duties and responsibilities relatin~ 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.
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;
Only authorized locks (as specified in the Detention Standard) are used in
detainee accessible areas.
Grand master keying systems are prohibited.
AU worn or discarded keys and locks are cut up and properly disposed of.

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

Emergency keys are available for all areas of the facility.
The facilities use a key accountability system.
~uthorization is necessary to issue any restricted key.

.. .

. ..

. .

REMARKS

The Maintenance Supervisor has
attended a 100 hour ACME
locksmith accreditation course.

I8'J

I8l

D
Staff receive 40 hours annual
refresher training during which
time the locksmith provides 30
minutes of key control training.

IZI

Maintenance records confirmed
that preventive maintenance is
performed every 6 months.
SOP 06-27 addresses the issue
of compromised keys and locks.

181

The facility does not have a
safe.

181

IZI
IZI

0
[J

181

I8l

[]

181

I8l

b2High

SOP 06-27 (Key and Access
Card Control) addresses the
disposal of worn and discarded
keys and locks.

o
o

b2High

0
0

SOP 06.27 (Key and Access
Card Control) addresses the
issuance of restricted keys.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
\C 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 51 of72

... - "

,.. . ,

'. ,

KEYANDWCKCOIffROL :· ' ""." " ,

" ' (SECUruTY;AC¢O:lJNTABIii~~~M~;T:EN~f:i9~) " ' "

.'!&V§AND
~~L;~~ITLOCKS.
ISTHE POLICY
OFTHE ICE SERVtCETO
MAlNT~J\N
EFFicmm
SYS~~oiTim. USE;
A~Oum
ABILITY
AND MAlNrENANCE OF ALL
. . . . .' "
...
. .
.. . . .. . . ' . .
'"
;,
'
.
N

Individual gun lockers are provided.
•
They are located in an area that pennits constant officer
observation.
•
In an area that does not allow detainee or public access.

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

COMPONENTS

: Y '

All staff members are trained and held responsible for adhering to proper
procedures forthe handling of keys.
•
Issued keys are returned immediately in the event an employee .
inadvertently carries a key ring home.
•
When a key or key ring is lost, misplaced, or not accounted for,
the shift supervisor is immediately notified.
•
Detainees are Dot permitted to handle keys assigned to staff.

[gI ACCEPTABLE

DDEFICIENT

AT-RISK

REMARKS

b2High

D REPEAT FINDING

REMARKS:
b2High

b6,b7c

M.y 15.2008

AUDITOR'S SIGNATURE/DATE

b6,b7c

!~r'-./

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
(C

2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 52 of 72

:,,: ' > , .'

'.PQ)JULA'fION C.OUN"rS c

. ... . .

;P6LI~: A4DBlEm:rON FACrUTIEssHAtlENSURE ~OON~riIE~ACCC;UNTM.JI£rrY FORALLDETA.lNEEs. TmsREQUIRES niATnmy

.' CONDUCT
AT LEAsT ONE FORMAL COUNT OF mE DETAINEE PoPULATION PEidHrFT, 'WITH ADDITIONAL FORMAL AND INFORMAL COUNTS
CONPUcTEDAs NECESSARY. '
.
.
, '. ' " . . .'
. .' .
'.. .
. '
.
... ... . .. .
COMPONENTS
Staff conduct a fonnal COWlt at least once each shift.

Activities' cease or are strictly controlled while a fonnal COWlt is being
conducted.
Certain operations cease during fonnal counts.
All movement ceases for the duration of a fonnal count.
Fonnal counts in all units take place simultaneously.
Detainee participation in COWlts is prohibited.
A face-to-photo COWlt follows each unsuccessful recount.

· 'NA

•

The control officer (or other designated position) maintains an out count record of all detainees temporarily leaving the facility.

[81

This trainin~ is documented in each officer's training folder.

[2'J ACCEPTABLE

o DEFICIENT

OAT-RISK

_ Photographs of each detainee
are maintained in each
individual housing unit and are
used to facilitate face-to-photo
counts.
Staff observations con finned
that officers positively identify
each detainee before counting
himlher as present.
Additionally, staff utilizes a
computer-generated roster and
calls each detainee by name
during count.
Standard Operating Procedure
06-20 (Inmate Counts) offers
clear definition to infonnal and
emergency counts.
The shift commander maintains
an out count record of all
detainees temporarily leaving
the facility.

o REPEAT FINDING

REMARKS:

The Atlanta City Detention Center ensures around-the-clock accountability for all detainees.

b6,b7c

1 May 15,2008

b6,b7c

AUDmlR'SSIGNATURE/DAT

".a~
v

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
(>

2007 Creative Corrections, LLC (Rev. 12/8/07)

Officers positively identify each detainee before counting himlher as
present.

Written procedures cover infonnal and emergency counts.
They are followed during infonnal counts and emergencies .

REMARKs ·
Fonnal COWlts are conducted
during each of the three shift
changes daily.

Page 53 of72

....../
.. ' .'

- ...

.. ..:: ..

.PO~~<;Y; Ic:E PROYmESorncarciAiLNECI3SS,'\RY GuIDAN¢EF9tt C~Y1NGo&r~IRDll1'lES' THis GUIDANCE'INCWDEs THE P()ST ORDERS
. ESTABLISHED FOR EvERY POST wHICH ARE~vn=:viED AT LEASTANNuALLY AND GIVEN TO EACH OFFICER UPON AsSIGNhlENTTOTHAT POST~
' :.
.: COMPONENTs
..
.
y.
Every fixed post has a set of post orders.
'rgj
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 flle) of post orders.
The central file is accessible to all staff.
The OIC or Contract / IGSA equivalent initiates/authorizes all post-order
changes.
The OIC or Contract / IGSA equivalent has signed and dated the last page
of every section.
.

NA .

[]

[J
[J

[]

REMARKs

Each set of post orders contains
latest inserts and relevant
policies (standard operating
procedures).
The Accreditation Manager
(Lieutenant) is responsible for
keeping all post orders current
with revisions that take place
between reviews.

(]

The Ole authorizes all postorder chall&es.
The frrst page of every section is
signed and dated by the OIC
instead of the last page of every
section.

A review/updating/reissuing of post orders occurs regularly and at a
minimum annually.
Procedures keep post orders and logbooks secure from detainees at all
times.

Every armed-post officer qualifies with the post weapon(s) before
assuming post duty.

Armed-post post orders provide instructions for escape attempts.
The post orders for housing units track the event schedule.
Housing-unit post officers record all detainee activity in a log. The post
order includes instructions on maintaining the logbook.

[]

o
o REPEAT FINDING

IZI ACCEPTABLE

DEFICIENT

OAT-RISK

o
The general section of the post
orders specifically state that all
post orders are sensitive
documents.
Every armed-post officer
qualifies with post weapons
annually.

REMARKS:

The first page of every section is signed and dated by the OIC instead of the last page of every section.

b6,b7c
/ May \5, 2008
AUDITOR'S SIGNATURE I DAT

b6,b7c

Page 54 of 72

":.: ....: ,".:... ... ::>, ~.....:;.

',.~,-'~-:. '

,., SECUlU'(Y~SPEqI'()'NS < ' , 7 ;

>'-"::"':: . -.:' .: ,:." >~_;:'.'~~;.~:':<, ":~;:'::;:'>: ~'~ "">':~.~''-:': .<. :~>~../.'_>.;.:_ .:' ... _, ".; : /.' ,,:""::·.Y-:,<::> \:; , :.": .: ', : ··i'···· '.' '.. .
POLICY: .POST AsSIGNMENTS IN THE FACILITY'S HIGH-RisK AREAs, 'wHERE SPECIAL 'SECURffYPROCEOUREs MUSTBE FOLLOWED; WILL BE
.RESTRIcTEI) TO EXPERIENCED PERsoNNEL Wrrn ATFlOROUCJHOROUNDING rNFAGILITY OPERATIONS. . ..
,
'
.. . .. _ .

COMPoNENTS

'j:'_:

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; and
•
Procedures for reporting weak spots, inconsistencies, and other
areas needing improvement

YES
-

No.

NAREMARKS
The facility does not have a

IZI

Every officer is required to conduct a security check ofhis/her assigned
area. The results are documented.

Documentation of security inspections is kept on file.
Procedures ensure that recurring problems and a failure to take corrective
action are reported to the appropriate manager.

The front-entrance officer checks the ID of everyone entering or exiting
the facility.

All visits are officially recorded in a visitor logbook or electronically
recorded.
The facility has a secure visitor pass system;
Every Control Center officer receives specialized training.

The Control Center is staffed around the clock.
Policy restricts staff access to the Control Center.
Detainees are restricted from 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; and
•
Name of employee responsible for the vehicle during the visit

comprehensive security
inspection policy. Several
policies address inspections, but
are fragmented and do not
address guidelines for checking
all security features with
'
procedures for reporting weak
spots, inconsistencies or areas
needing improvement.
SOP 08-04 (Random Cell
Security Searches) and SOP 0629 (Cell Security Search) give
clear definition for housing unit
officers to conduct security
checks ofhislher assigned areas
with documented results.
Each shift commander maintains
security .inspection files.
Facility policy does not ensure
that recurring problems and
failure to take corrective action
are reported to the appropriate
manager.
SOP 200-0 I (Facility Perimeter
and Access) directs the frontentrance officer to check the ID
of everyone entering or exiting
the facility.
All visits are manually recorded
in a visitor logbook.

]

Control Room Officers receive
approximately 80 hours of onthe-job training.

The control center officers
monitor all vehicular traffic by
use of video surveillance.

SOP 200-01 (Facility Perimeter
and Access) attachment
(delivery inspection log) of all
incoming and departing vehicles
includes all pertinent .
information.

Page 55 of 72

',: .,

....

SEctJRITYINSPECfIONS

,.
.,

POLICY: .PosT AsSI~NTSIN THE FAcILirYig HIGl-f·rusK. AREAs, WHElm SPECIAL SECUIUTY PRoCEDUR:eSMuST BE FOLLoWED, WILL BE

. REsTructEDTO EXPERlENCEI) PERSONNELWtrH ATHOROUGHGROUNDINGINFACILITY OPERATIONS . .'
YES .. ' No
NA .
CoMPoNENTs ".
Officers thoroughly search each vehicle entering and leaving the facility.

", '

C8J

0
0

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 enteringandJ)rior to departure.
The SMU entrance has a sally port.
Written procedures govern searches of detainee housing units and
personal areas.

C8J
,C8J

Housing area searches occur at irregular times.
Every search of the SMU and other housing units is documented.
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 alarm system tests;
• Physical checks of the perimeter fence; and
• Documenting the results.
Visitation areas receive frequent, irregular inspections.

[8J ACCEPTABLE

DDEFICIENT

[81

[]

[J
[J

131

C8J

[]

AT-RIsK

REMARKs

All vehicles entering and
leaving the loading dock are
thoroughly searched.
SOP 200-01 (Facility Perimeter
and Access) provides a thorough
written policy with procedures
to prevent the introduction of
contraband into the facility and
any of its components.

SOP 06-29 (Cell Security
Search) and SOP 06-13 (Inmate
Searches) give clear defmition
for searching detainee housing
units and personal areas.

The facility does not have
written procedures in place to
compel searches of
storage/supply rooms, plumbing
fixtures accesses and drains.

A microwave motion detection
system in concert with video
surveillance cameras and
physical checks of the perimeter
afford the facility with sound
perimeter security.

D REPEAT FINDING

REMARKS:

The facility does not have a comprehensive security inspection policy. Several policies address inspections, but are fragmented and do
not address guidelines for checking all security features with procedures for reporting weak spots, inconsistencies or areas needing
improvement.
Facility policy does not ensure that recurring problems and failure to take corrective action are reported to the appropriate manager.
The facility does not have written procedures in place to compel searches of storage/supply rooms, plumbing fixtures, accesses, and
drains.

b6,b7c

/ May 15.2008

b6,b7c

AUDITOR'S SIGNATURE I DATE

-!u-1

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
02007 Creative Corrections, LLC (Rev. 12/8/07)

Page 56 of72

SPF;CIAtMA,NAGEME~TUNiT(SMu)
.

Ai>MImsiRA:TMSEGREGA
nON: .•. •
' .
.
- ".' . . .... ..
". " ", ":"..;.: ."• . <" .: ......

. POLICY: THE SPECIAL MANAGEMENT UNITREQUIREDrN EVERY IlACILrtY ISOLATESCERTAIN PETAINEES.PR(>MTIm GENERAL POPULATION .
.nmSPECIALMANAGEMENT UNIT WILL CONSIST OF TWQ imcTIONS. ONE~ ~TRATIVE SEGREGATION, HoUSES Din'AINEESISOLATEb FOR
.THEIR· owN PROTECfION; THE OTImR FOR PETAlNEES BEING DISCIPLINED .FOR, WRONGDOING (SEE THB"SPECIAL MANAGEMENT UNIT
. n)ISCWLIN-A.RYSEGRBGATION1"STANDARo),
'
. . . . ...
.

COMPONENTS
The Administrative Segregation unit provides non-punitive protection
from the general population and individuals undergoing disciplinary
segregation.
•
Detainees are placed in · the SMU (administrative) in
accordance with written criteria.
In exigent circumstances, staff may place a detainee in the SMU
(administrative) before a written order has been approved.
•
A copy of the order given to the detainee within 24 hours.

NA .

The OIC (or equivalent) regularly reviews the status of detainees in
administrative detention.
•
A supervisory officer conducts a review within 12 hours of the
detainee's placement in the SMU (administrative).

A supervisory officer conducts another review after the detainee has
spent seven days in administrative segregation, and:
•
Every week thereafter for the first month; and
•
Every 30 days after the first month.
•
Does each review include an interview with the detainee?
•
Is a written record made of the decision and the justification?

The detainee is given a copy of the decision and justification for each
review.
•
The detainee is given an opportunity to appeal the reviewer's
decision to someone else in the facility.
The OIC (or equivalent) routinely notifies the Field Office Director (or
staff officer in charge of IGSAs) any time a detainee's stay in
administrative detention exceeds 30 days.
•
Upon notification that the detainee's administrative segregation
has exceeded 60 days, the FD forwards written notice to HQ
Field Operations Branch Chieffor DRO.
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 have remained in administrative segregation for seven
consecutive days.
Administratively segregated detainees enjoy the same general privileges
as detainees in the general population.

o
o

REMARKS

Staff may place a detainee in the
SMU before a written order has
been approved; however, copies
of such orders are not provided
to detainees.
The Facility Commander
regularly reviews the status of
detainees in administrative
detention and conducts a review
within 72 hours of the detainee's
placement in the Administrative
SMU.
A review team consisting of a
security sergeant, classification
officer and mental health
professional conduct weekly
reviews of detainees for the first
sixty days. The team then
conducts reviews every 30 days
after the 60 day period has
expired.
Review decisions and
justifications are documented,
but detainees are not provided
copies.

o
o

Detainees do not receive copies
. of reviews when they object to
administrative segregation after
30 days in the SMU.

Page 57 ofn

I·.··· .
I··... '

', '

· '.

'\ .

.....

,, ".

. SPECIAL MANAGEMENT UNrr(sl\1tJ) ··: ".

: ' .tjMJi.risTIiATIVESEG'REGATION :, ,
" " :i

•

" :',':"
"

.. '

. .. .

,.'

.~
"

.... .

. . j ...

...

POUCY:THE SPECIAL MANAGEMENT UNIT REQUlR\3J)IN EVERYI'ACILITY IS()LATEScERTAINOETAINEESFiWM TImGENEAALPOPULATION.

·.Tim SPECli\L MANAGEMENTUNrr WuCPNSIST OF TWO SEcnONS, ONB,AI>MOOsTRATlvE SEGREGAPON, HOVSE$'OETMIEES ISOLATED FOR
THEiR OWN PROTECTION;

THE' OTHERFOR DETAINEES BErNGoiscIPLINED FOR\VRONGOOING(SEE nm"SPECIALMANAGEMENT 0Nrr .
rDrSCJ;PLINARYSEGREGATlON1" STANDARD); .'
.
..
.
,
.. ' --,- '
. "
,
COMPONENl's
Y
N
NA
REMARKs
The SMU is:
• Well ventilated;
• Adequately lighted;
~
0
0
• Appropriately heated; and
• Maintained in a sanitary condition.
All cells are equipped with beds.
~
0
0
• Every bed is securely fastened to the floor or wall.
The number of detainees in any cell does not exceed the occupancy
limit.
• When occupancy exceeds recommended capacity, do basic ~
0
0
living standards decline?
• Do criteria for objectively assessing living standards exist?
• If yes, are the criteria included in the written procedures?
The segregated detainees have the same opportunities to
[gJ
exchange/launder clothing, bedding, and linen as detainees in the
0
0
general population.
Detainees receive three nutritious meals per day, from the general
population's menu of the day.
[gJ
0
0
• Do detainees eat only with disposable utensils?
• Is food ever used as punishment?
Each detainee maintains a nonnallevel of personal hygiene in the SMU.
Standard Operating Procedure
07.14 (Special Management
• The detainees have the opportunity to shower and shave at
Procedures) directs that
least three times a week.
r8I
0
0
detainees be afforded the
• Ifnot, explain.
opportunity to shower and shave
at least three times a week.
The detainees are provided:
• Barbering services;
Barbering services are provided
• Recreation privileges in accordance with the "Detainee
once weekly. SOP 07.14
Recreation" standard;
(Special Management
• Non-legal reading material;
Procedures) directs that all other
r8I
0
0
• Religious material;
privileges are afforded to
• The same correspondence privileges as detainees in the general
detainees in Administrative
population;
Detention status.
• Telephone access similar to that of the general population; and
• Personal legal material.
A health care professional visits every detainee at least three times a
week.
A health care professional visits
r8I
0
0
every detainee twice daily.
• . The shift supervisor visits each detainee daily.
Weekends
and
holidays.
•
Procedures comply with the "Visitation" standard.
• The detainee retains visiting privileges; and
r8I
0
0
The
visiting
room
is
available
during
normal
visiting
hours.
•
Visits from clergy are allowed.
[J
~
LJ

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
!O 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 58 of72

. SPECIAL MANAGEMEN',I' UNIT(SMU) .....
. .' ADMINISTRATIVE ' SEcRiGAnON
.
-"

. ',

"I,.' . .

. POLIC)': nrn SPECIAL MANAGEMENT UNIT REQUIRED IN EVERY FACILITY ISOLATES CERTAIN DETAINEES FROMlHE GENERAL POPULATION.
',TiffisPOCIAL MANAGEMENT UNIT WJLL.CONSIST OFTWO SECfIONS: ONE; ADMINisTRATIVE'SEGREGATION, HOusEs DETAINEES IsOUTED FOR
THEIR· ()WN: PROTECfION; THE oureR FOR- DETAINEES. BEING DIscIPLINED F()R· WRONGDoING (SEE lHE "SPECIAL MANAGEMENT UNIT
roISCiPLINARY SEGREGATiON)" STANnARD). . .
..
COMPONENTs·
Y
N
NA
REMARKS
Detainees have the same law-library access as the general population.
Detainees are afforded legal
• Are they required to use the law library DSeparately, or
C8J
D
0
materials upon written request
DAs a group?
Are
legal
materials
brought
to
them?
•
A seven day log is affixed to
The SMU maintains a permanent log of detainee-related activity, e.g.,
each detainee's cell door to
meals served, recreation, visitors etc.
D
C8J
D
record all detainee-related
activity.
SPC procedyres include completing the SMU Housing Record (I-888)
immediately upon a detainee's placement in the SMU.
D,
D
C8J
• Staff completes the form at the end of each shift.
• CDFs and IGSA facilities use Form 1-888 (or local equivalent).
Staff record whether the detainee ate, showered, exercised, and took any
applicable medication during every shift.
• Staff logs record all pertinent information, e.g., a medical
condition, suicidal/assaultive behavior, etc;
C8J
D
D
• The medical officerlhealth care professional signs each
individual's record during each visit; and
The
housing officer initials the record when all detainee
•
services are completed or at the end of the shift.
A new record is created for each week the detainee is in Administrative
Segregation.
0
D
• The weekly records are retained in the SMU until the C8J
detainee's return to the general population.

~ ACCEPTABLE

o DEFIC,IENT

OAT-RISK

o REPEAT FINDING

REMARKS:

Staff may place a detainee in the SMU before a written order has been approved; however, copies of such orders are not provided to
detainees.
Review decisions and justifications are documented, but detainees are not provided copies.

Detainees do not receive copies of reviews when they object to administrative segregation after 30 days in the SMU.

b6,b7c
(May IS. 20Q8
AUDITOR'SSIGNATURE/D

b6,b7c

/! ~

Page 59 of72

SPECIAL MANAGEMENT UNIT,
,

DISrnI.I:NARYSEGREGAnON
"

< -

,
"

POLICY: EACH FACILITY WILL ESTABLISH A SPECIAL MANAGEMENT UNIT IN WHICH TO ISOLATE CERTAIN DETAINEES F~OM THE GENERAL
POPULATION. THE SPECIAL MANAGEMENT UNIT WILL HAVE TWO SECTIONS; ONE FOR DETAINEEs IN ADMINISTRATIVE SEGREGAnON; THE
, OTHER FOR DETAINEES BEJNG SEGREGATED FoRDISCIPLINARY REASONS;,
'
REMARKS
COMPONENTs
Y
N
NA
Officers placing detainees in disciplinary segregation follow written
[gJ
0
0
procedures.
The sanctions for violations committed during one incident are limited
[gJ
0
0
to 60 days.
A completed Disciplinary Segregation Order accompanies the detainee
A disciplinary disposition form
into the SMU.
[gJ
0
0 accompanies detainees into the
• The detainee receives a copy of the order within 24 hours of
SMU.
placement in disciplinary segregation.
Standard procedures include reviewing the cases of individual detainees
Standard procedures include
housed in disciplinary detention at set intervals.
reviewing the cases of detainees
housed in disciplinary detention
• ,After each formal review, the detainee receives a written copy of
[gJ
at seven day intervals; however,
the decision and supporting reasons.
0
0
detainees do not receive written
copies of decisions and
supporting reasons.
The conditions of confinement in the SMU are proportional to the
[gJ
0
0
amount of control necessary_ to protect detainees and staff.
Detainees in disciplinary segregation have fewer privileges than those
Detamees in disciplinary SMU
[gJ
housed in administrative segregation.
are not afforded commissary
0
0
privileges.
Living conditions in disciplinary SMUs remain the same regardless of
behavior.
'
[gJ
0
0
• Ifno, does staff prepare written documentation for this action?
Does the OlC sign to indicate approval.
Every detainee in disciplinary segregation receives the same humane
[gJ
0
0
treatment. regardless of offense.
The quarters used for segregation are:
• Well-ventilated.
[gJ
• Adequately lighted.
0
0
• Appropriately heated.
• Maintained in a sanitary condition.
All cells are equipped with beds that are securely fastened to the floor or
[gJ
0
0
wall of the cell.
The number of detainees confined to each cell or room is limited to the
[gJ
number for which the space was designate.
0
0
Does
the
OIC
approve
excess
occupancy
on
a
telllPUHUY
basis?
•
When a detainee is segregated without clothing, mattress, blanket, or
[gJ
pillow (in a dry cell setting), a justification is made and the decision is
0
0
reviewed each shift. Items are returned as soon as it is safe.
Detainees in the SMU have the same opportunities to exchange clothing,
Clothing and bedding exchanges
[gJ
0
0
bedding, etc. as other detainees.
are accomplished weekly.
Detainees in the SMU receive three nutritious meals per day, selected
[gJ
from the Food Service's menu of the day.
0
0
Food
is
not
used
as
punishment.
•
Detainees are allowed to maintain a normal level of personal hygiene,
[gJ
0
0
including the opportunity to shower and shave at least three times/week.

•

Page 60 of72

SPECIAL MANAGEMENT UNIT ·' .',:

",'DISCIPLiNAiiy SEGREGATION'., <,

'.· phil<:\': 'Rt\CH FACILllYWILL ESTABUSHA ~PEc:IAL MANAGI?MENT UNIT IN \VHI~TC)ISO~TBCEKrAINPE:rAINEESFROMTHE GENERAL ·
' POPULAtiON. THE SPECIAL MANAGEMENT UNIT WILL HAYE TWO SEcTIONS, ONE FOR DETAiNEES IN ADMiNIS'fRATNESEGREGATION; THE
OTHERF()RDETAINEESBEING SEGREGATEo FOR DISCIPl.IN.AAyREAsONS.
.' .
' .,
"
.. '
.'
. .

. COMPONENTS
Detainees receive, unless documented as a threat to security:
• Barbering services;
• Recreation privileges;
• Other-than-Iegal reading material;
• Religious material;
• The same correspondence privileges as other detainees; and
• Personal legal material.
When phone access is limited by number or type of calls, the following
areas are exempt:
• Calls about the detainee's immigration case or other legal
matters;
• Calls to consular/embassy officials; and
• Calls during family emergencies (as determined by the
OIClWarden).
A health care professional visits every detainee in disciplinary
segregation every week day.
• The shift supervisor visits each segregated detainee daily
• Weekends and holidays.
SMU detainees are allowed visitors, in accordance with the "Visitation"
standard.

SMU detainees receive legal visits, as provided in the "Visitation"
standard.
• Legal service providers are notified of security concerns
arising before a visit
Visits from clergy are allowed.
• The clergy member is given the option of visiting/not visiting
the segregated detainee.
• Violent/uncooperative detainees are denied access to religious
services when safety and security would otherwise be affected.
SMU detainees have law library access.
• Violent/uncooperative detainees retain access to the law library
unless adjudicated a security threat in writing.
• Legal material brought to individuals in the SMU on a case-bycase basis.
• Staff documents every incident of denied access to the law

NA'

REMARKs

Barbering services are offered to
detainees on a weekly basis.

A Health Care Professional
visits each detainee twice daily.

Detainees in SMU
(Disciplinary) are not afforded
visits in accordance with the
"Visitation" standard.

o
o

libr~.

All detainee-related activities are documented, e.g. meals served,
recreation activities visitors etc.
The SPC's, the Special Management Housing Unit Record (I-8880r
equivalent), is prepared as soon as the detainee is placed in the SMU.
• .All 1-888s are filled out by the end of each shift.
• The CDFaGSA facility use Form.
• 1-888 (or equivalent local form).

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
<02007 Creative Corrections, LLC (Rev. 12/8/07)

Page 61 of72

..... SPECIALMANAGEMENtuNrt· ,·. ".
.'
DISCrPLINARYSEG~GATIO~ '

,,
i

p~Li~~: EACH FACILITY WILL EsTABUSll A SPECIAL ~AGEMENT UNrf 'lNwWCH'TO iSOLATIiCE~+AlNDETAINEES FROM THE GENERAL .
WrrL

POPtrrATION:THE SPEGIALMANAGEMENT UNIT
HAVE1WO SECTIONS, ONE FOR DETAINEES lNADMlNISTRA1WE SEGREOATION; THE
()Ti-niR'FOR DETAwEESBElNG SEGREGATED FOR DISCIPLINARY REASC)NS. ·
. . ;
.. .. . . '
.
'. . . . .
"
<
COMPONENTS
'..' Y .
. N ." . NAREMARKs
SMU staff record whether the detainee ate, showered, exercised, took
medication, etc.
•
Details about the detainee logged, e,g., a medical condition,
suicidaVviolent 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.
..

' ,:.

,' "

.....;:: .. ....

rgJ ACCEPTABLE

o DEFICIENT

OAT-RISK

:'"

D REpJ!;AT FINDING

REMARKS:
Standard procedures include reviewing the cases of detainees housed in disciplinary detention at seven day intervals; however,
detainees do not receive written copies of decisions and supporting reasons.
Detainees in SMU (Disciplinary) are not afforded visits in accordance with the "Visitation" standard.

b6,b7c

May 1;,200S

AUDITOR'S SIGNATURE/DA

b6,b7c

'r-h'-

FOR OFFICIAL USE ONLY (LA W ENFORCEMENT SENSITIVE)
¢)

2007 Creative Corrections, LLC (Rev. 12/S/07)

Page 62 of72

TOOLCON1'ROL

POLICY: It IS nmPOLICY OF ALL FACILITIES THAT AtLEMPLOYEES SHALL BE RESPONSIBLE FOR COMPLYING WITH TIffiTOOL CONTROL roUCy.
THE MAINTENANCE SUPERVIsOR SHALL
A COMPUTER GENERATED OR rnEWIUITEN MAsTER INVENTORY LIST OF TOOLS AND.
EQtJIPMENT AND THE LOCATION INwlnCHTOOis ARE STO~D.THEsE INVENTORIES SHALL BE CURRENT, FILED ANn READILY AVAU.ABLE FOR
. TOOL INVinrrORY AND ACCOUNTABILITY DURING AN AuDIT.
. .
.
.

MAINTAIN

. COMPONENTS

N·

181

There is an individual who is responsible for developing a tool control
procedure and·an inspection system to insure accountability.

Department heads are responsible for implementing this standard in their
departments.

Tool inventories are required for the:
• Maintenance Department;
• Medial Department;
• Food Service Department;
• Electronics Shop;
• Recreation Department; and
• Armory.
The facility has a 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.

181

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 is readily notice.

181

Each facility has procedures for the issuance of tools to staff and
detainees.
The facility has policies and procedures to address the issue oflost tools.
The policy and procedures include:
• Verbal and written notification;
• Procedures for detainee access; and
• Necessary documentation/review for all incidents oflost tools.

181

The facility has a tool classification system. Tools are classified
according to:
• Restricted (dangerous/hazardous); and
• Non-Restricted (non-hazardous).

181

REMAlU<S
Officer
is the designated
staff m b6,b7c esponsible for
developing tool control
procedures with an inspection
system to insure accountability.
The food service department,
medical department,
maintenance department, and
armory personnel are
responsible for implementing
the tool control standard.

Tool inventories are required for
all departments that maintain
tools.

Standard Operating Procedure
200-04 (Tool Control
Procedures) directs that
inventories be conducted weekly
and Quarterly.
SOP 200-04 (Tool Control
Procedures) classifies tools into
two categories (Class A and
Class B). A visual observation
confirmed that the Class A
(restricted) tools were afforded
additional security and control
in contrast to the Class B Tools.

All tools were etched and
readily identifiable.
A chit system is in place to
ensure accountability of tools .
Commonly used tools are
displayed neatly on shadow
boards in such a way that a
missing tool would be readily
noticed.

SOP 200.04 (Tool Control
Procedures) addresses the issue
oflost tools, including written
and verbal notification.

Page 63 of72

.. '

···pouci;:IT IS

TOOL
. ..
. CONTROL
.
..
. ..

nm POLICY OF ALLFACIlirIES THATALLIlMPLoYEES SHALL IJEREsP6Nsmu~roR COMPLYINo \VITHTIIB TOOL CONlROL POLICY.

rim ~CE SUPERVISORSHALLMAINrAIN ACOMPlITER GENERATED OR TYPEWRITTEN M'AsTERINVENTORY LIST OF TOOLS .AND

EQUIPMENT AND THE LocATION IN WHICH TOOLS ARESTORED. THEsE INVENTORmsSlWL BE cliRRENT, FILED AND READILY AVAIl.ABrEFOR
.' TOOL INV:ENTORY AND ACCOuNrABILTty DURING AN AUDIT.
' . ' .
.
.'
COMPONENTS
REMARKS
Y
N
NA
Broken or worn out tools are surveyed and disposed of in an appropriate
0
t8J
0
and secure manner.
All private or contract repairs and maintenance workers under contract to
SOP 200.04 (Tool Control
ICE, or other visitors, submit an inventory of all tools prior to admittance
Procedures) directs the
into or departure from the facility.
inventory of tools of contractors
0
t8J
0 and vendors upon entrance and
prior to departure from the
facility.
.'

[8] ACCEPTABLE

DEFICIENT

OAT-RISK

D REPEAT FINDING

REMARKS:

Tool control at the Atlanta City Detention Center is excellent.

b6,b7c

I May 15,2008

b6,b7c

AUDITOR'S SIGNATURE I DA

aPAY'-

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
10 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 64 of 72

....

TRANSPORTATION
LANOTAANSPORl'ATI()N

POl,ICY:THEIMMIGRATIONANoNATURALIZATIONSERVICEWILLTAKEALLNECESSARYPRECAunONStOPROTECTTIm UVES,'SAFmY, AND
WELFARE OF OUR OFFICERS, TIm GENERAL PUBLIC, AND THOSE IN ICE CUSTODY DURIN011!E TRANSPORTATIONOFDETAINEES~ STANDARDS
I:lAVE.BBEN,ESTA/3LISHED FOR PROFESSIONAL TRANSPORTATION UNDER THE SUPERVISIC)N OF EXPERIENCED AND~ED DETENTION
ENFORCE~NT OFFICERS OR AUTHORIZED CONTRACT PERSONNEL.

l8J STANDAru; NA:
CHECK THIS BOX IF ALL ICE TRANSPORTATION IS IWmLED ONLY BY TIm ICE FlEW OFFICE OR SUB-OFFICE IN
..
CONTROL OF THE DETAINEE CASE.
COMPONENTS
NA
REMARKS
YES
No
Transporting officers comply with applicable local, state, and federal
motor vehicle laws and regulations. Records support this finding of
0
0
0
compliance.
Every transporting officer required to drive a commercial size bus has a
valid Commercial Driver's License (CDL) issued by the state of
0
0
0
employment.
[]
[]
[]
Supervisors maintain records for each vehicle operator.
Officers use a checklist during every vehicle inspection ..
• Officers report deficiencies affecting operability; and
0
0
0
• Deficiencies are corrected before the vehicle goes back into
service.
Transporting officers:
• Limit driving time to 10 hours in any 15 hour period;
• Drive only after eight consecutive off-duty hours;
• Do not receive transportation assignments after having been on
duty, in any capacity, for 15 hours;
0
0
• Drive a 50-hour maximwn in a given work week; a 70-hour 0
maximum during eight consecutive days;
• During emergency conditions (including bad weather), officers
may drive as long as necessary and safe to reach a safe
area-exceeding the 10-hour limit.
Two officers with valid CDLs required in any bus transporting detainees.
• When buses travel in tandem with detainees, there are two 0
0
0
qualified officers per vehicle.
• An unaccompanied driver may transport an empty vehicle.
Before the start of each detail the vehicle is thoroughly searched.
LJ
LJ
LJ
[J
Positive identification of all detainees beinAtransported is confmned.
[J
[l
All detainees are searched immediately prior to boarding the vehicle by
0
0
0
staff controlling the bus or vehicle.
The facility ensures that the number of detainees transported does not
0
0
0
exceed the vehicles manufacturer's occupancy level.
[J
Protective vests are provided to all transporting officers.
[J
LJ
The vehicle crew conducts a visual count once all passengers are on
board and seated.
0
0
• Additional visual counts are made whenever the vehicle makes a 0
scheduled or unscheduled stop.
Policies and procedures are in place addressing the use of restraining
0
0
0
equipment on transportation vehicles.
Officers ensure that no one contacts the detainees.
0
0
• One officer remains in the vehicle at all times when detainees 0
are present.
Meals are provided during long distance transfers.
0
0
• The meals meet the minimwn dietary standards, as identified by 0
dieticians utilized by ICE.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
02007 Creative Corrections, LLC (Rev. 12/8/07)

Page 65 of72

'tRANSPORTATlQN .. ..... .

, ":

LAND TRANSPORTA;l'ION

. ...

POLict: THE IMMIGRATION AND NATURALlZATIONSERVICEWILL TAim AIL NECEs~ARY PRECAUTIONS TO PROTECr'ritE L~S,SAFEiY,'oo

WELFARlIOF OURomCERS; nrn G~ERAL PUBLIC, ANDTIIOSE IN ICE CUSTODYDuruNO TIrnTRANSPORTATION OIl DETAINEEs. STANDARDS
HA~: a,EEN' EsTABLISHED FOR, PROFEsSIONAL TRANSPORTATION (,lNDER nm'SUPERVIsiON-OF: EXPERmNam AND TRAINED DETENTION
. E~RCEMENT OFFICERS OR AU11IORIZED CONTRACT PERSONNEL.

I81.S:rArWARD NA: ~IIECK

nus

BOX IF AliICE TRANSP. O~TATION IS HANDLED ONLY By'1m ICEFD:LDOFFicEORSlJB,.OFFI~JlI!
.
'. .
.

CONtROLOF rilE DETAINEE CASE.
.

COMPoNENTS .

YES

The vehicle crew irispectS all Food Service pickups before accepting
delivery (food wrapping, portions, quality, quantity, thennos-transport
containers, etc.).
•
Before accepting the meals, the vehicle crew raises and resolves
.questions, concerns, or discrepancies with the Food Service
representative;
•
Basins, latrines, and drinking-water containers/dispensers are
cleaned and sanitized on a fixed schedule.
Vehicles have:
•
Two-way radios;
•
Cellular telephones; and
•
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;
• . Inspected; and
•
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 includes women or minors

o ACCEPTABLE

o DEFICIENT

NoNA

OAT-RISK

REMARKS

o REPEAT FINDING

REMARKS:
Detainee transportation is facilitated by ICE.

b6,b7c

/ May 15.2008

AUDITOR'S SIGNATURE I DAT

b6,b7c
b6,b7c

Page 66 of 72

,USE:QFFORCE: '.
.. POLlCY:

n-ffi U:S: DEPARTMENT OF HoMEi:.ANDSEcillurr'Ath1loRizES;HE US~OF FOR~ ONLY ~ A LAST ALTERNATIVE AFTER.AIi OTIIER

REASONABLE EFFORisTO RESOLvE ASmJATION. .HAVE
. . .FAILED.
.

ONLY
riiAi
AMouNT
'
,'.
.
,.'
. ' ..
. FORCE NECESSARY TO GAIN CONTROL OF THE
DETAlNEE, TO PROTECT AND ENSURE THE SAFETY OF DETAINEES, STAFF AND OTHERS,.TO PREVENT SERIOUSPROPERTv DAMAGE ANDTO
ENSuRE)NSTITunON SECtJRrrvAND oOOD ORDmtMAY BE USED. PHYSICAL RESTRAINTS NECESSARY TO
CONTROL OF A DETAINEE WHO
.
. APPEARS TO BE DANGEROUS MAYBE EMPLOYED WHEN THE DETAINEE:
. No
COMPONENTS
YES
, ' .

(JAIN

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., locked
cell, a range), posing no direct threat to the detainee or others, officers
must try to resolve the situation without resorting to force.

Written policy asserts that calculated rather than 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 offorce.

When a detainee must be forcibly moved and/or restrained, and there is
time for a calculated use of force, staff uses 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:
• Do not use force as punishment;
• Attempt to gain the detainee's voluntary cooperation before
resorting to force;
• Use only as much force as necessary to control the
detainee; and
• Use restraints only when other non-confrontational means,
including verbal persuasion, have failed or are impractical.
Medication may only be used for restraint purposes when authorized by
the Medical Authority as medically necessary.

Use-of-Force Team follows written procedures that attempt to prevent
injury and exposure to communicable disease(s).

o
o

(]

Standard Operating Procedure
06-77 (Use of Physical Force)
directs that a staff member is
authorized to respond to an
immediate-use-of-fQrce situation
without a supervisor's presence
or direction.
SOP 06-77 states that an officer
will first exhaust all lesser
means of restraints to control a
recalcitrant or assaultive inmate,
including verbal persuasion.

The facility subscribes to
Confrontation Avoidance
Procedures; however, written
procedures do not direct that a
health professional be consulted
as part of the avoidance
. procedures.
The facility has a Corrections
Emergency Response Team
(CERT) to facilitate calculated
use of force situations.

SOP 06-77 (Use of Physical
Force) prohibits staff from using
force as punishment.

Facility policy does not prohibit
the use of medication for
restraint purposes unless
authorized by the Medical
Authority.
Facility policy and procedures
do not address the prevention of
injury or exposure to
communicable disease.

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
(;) 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 67 of 72

.,'

.,
' ,

' USEOg¥9RC~>

'. '

POU¢y::iI)~VJ DEPARTMBNrOFHOMEL~~ SI!CIDUTY'A~O~~~~EOFI'~~SEo~~As), LAsTJ\I/fERNA11VEAFrER~onrni

REASONABLE EFFORTS TO RESOLVE A SITUATION HAVE FAILED: ONLY'rnATAMOUNTOPF0RCENECESSARY TO GAIN CONTROL OF THE
DirMmE, TPPROTECrANDE;NSURE THE SAFBTYOF DETAJlIlEE8, STAFF~QTIiERS;TO~REvENrSERI6US PROfERTYDAIvlAOE ANDTO
.:' ENSUR.EINSTITUTlONSEcURrrY AND GOOD ORDERMAVDE USED~ PHYSICALRESTRA.INTs NECESSARY TO GAIN CONTROL OFA DETA1Nim WHO
APPEARS,T O BE DANGEROUS.MAY BE EMPLOYED WI:iENTHE DETAINEE:
. ,REMARKs
. COMPONENTS
No,: . NA .,.
' YEs
Standard procedures associated with using four-point restraints include:
• Soft restraints (e.g., vinyl);
SOP 06-117 (Use of Physical
• Dressing the detainee appropriately for the temperature;
Restraints)
addresses the use of
• Abed, mattress, and blanket/sheet;
four-point restraints and
• Checking the detainee at least every i 5 minutes;
checking the detainee at least
• Logging each check;
every fifteen minutes and
0
IZI
0
• Turning the bed-restrained detainee often enough to prevent
observation by medical staff
soreness or stiffness;
every two hours, but does not
• Medical evaluation of the restrained detainee twice per
include other standard
eight-hour shift; and
procedures.
• When qualified medical staffis not immediately available,
staff position the detainee "face-up".
The shift supervisor monitors the detainee's position/condition every two
Facility policy does not direct
hours.
the shift superVisor to monitor
IZI
0 the detainee's position/condition
• He/she allows the detainee to use the rest room at these 0
every two hours with use of the
times under safeguards.
restroom.
All detairiee checks are logged.
SOP 06-117 (Use of Physical
D
181
0 Restraints) direct that all
detainee checks be logged.
In immediate-use-of-force situations, staff contacts medical staffonce the
SOP 06-77 (Use of Physical
detainee is under control.
Force directs that staff contact
181
0
0
medical personnel once the
detainee is under control.
When the OIC authorizes use of non-lethal weapons:
• Medical staff is consulted before staff use pepper
facility does not employ the _
spray/non-lethal weapons.
0
0
181 The
use of non-lethal weapons.
• Medical staff reviews the detainee's medical file before use
of a non-lethal weapon is authorized.
Special precautions are taken when restraining pregnant detainees.
0
181
0
• Medical personnel are consulted
Protective gear is worn when restraining detainees with open cuts or
Facility policies do not address
wounds.
the use of protective gear when
0
IZI
0
restraining detainees with open
cuts or wounds .
. Staff documents every use of force and/or lion-routine application of
SOP 06-77 (Use of Physical
restraints.
Force) directs that staff submit a
use of force incident report to
D
181
0 the supervisor when use of
force is used or non-routine
application of restraints are
applied.
It is standard practice to review any use of force and the non-routine
181
0
0
application of restraints.
All officers receive training in self-defense, confrontation-avoidance
techniques and the use of force to control detainees.
0
0
• Specialized training is given and Officers are certified in all IZI
devices they_use.
, '.

.'_

•

; .

•

' -

"' ,

' 0'

' . '

•

FOR OFFICIAL USE ONLY (LAW ENFORCEMENT SENSITIVE)
02007 Creative Corrections, LLC (Rev. 12/8/07)

Page 68 of72

181 ACCEPTABLE

o D EFICIENT

OAT-RISK

RUEAT FINDING

REMARKS:

The facility subscribes to Confrontation Avoidance Procedures; however, written procedures do not direct that a health professional be
consulted as part of the avoidance procedure.
Facility policy does not prohibit the use of medication for restraint purposes unless authorized by the medical authority.
Facility policy and procedures do not address the prevention of injury or exposure to conununicable disease.
SOP 06-117 (Use of Physical Restraints) addresses the use offour-point restraints and checking the detainee at least every fifteen minutes
and observation by medical staff every two hours, but does not include other standar~ procedures listed in the checklist for four point
restraints.
Facility policy does not direct the shift supervisor to monitor the detainee's position/condition every two hours with use of the rest room.
Facility policies do not address the use of protective gear when restraining detainees with open cuts or wounds.

b6,b7c

{MayI5.2008

b6,b7c

AUDlTOR'SSIGNATURE / D

Page 69 of72

STAFFDET
COMMUNICATIONS
' .
. " '-".-AlNEE
. ........ '.
. .. . . ...
" .
"

P()LICY:

': '

PRoCEDUR:ES·MtJSTBE~ PLAtE'to AiLow~Oi~6JUvfALANDINF6~ C6NTACT B~ENKEY FACll..ITY sTAFF AND ICE STAFF

..ANoICE DIITAINEE
AND TOPERMrr.DlITA1NEES To MAKE wruTrENREQlJEsTSTo ICE STAFF AND RECElVEANANSwER
IN.ANACCEPTABLE TIME
'.
....
. . -.

.. .

-'-

". . .

. .

·PRAME.

. COMPONENTs ·

The ICE Field Office Director ensW'es that weekly announced and
unannounced visits occw' at the IGSA.
Detention and Deportation Staff conduct scheduled weekly visits with
detainees held in the IGSA.
Scheduled visits are posted in ICE detainee areas.

. ... . .

IZSI

jgJ

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

OAT-RISK

' "

' ,.

ICE staff responds to a detainee request from an IGSA within 72 hoW's.

o DEFICIENT

IZSI

Visiting staff_observe and note current climate and conditions of
confinement at each IGSA.
ICE information request Forms are available at the IGSA for use by ICE
detainees. The IGSA treats detainee correspondence to ICE staff as Special
Correspondence.

1.81 ACCEPT ABLE

, ..

REMARKs

Unannounced visits oCCW'
usually due to a request from a
detainee of an urgent nat\U'e.
ICE conducts scheduled visits
every Wednesday.
The detainees are infonned that
the ICE Officer will visit each
Weds. In addition the officer
sees each detainee on every
visit.

All mail to government officials
is treated as special
correspondence.
Usually within 24 hrs per Agent
b6,b7c

REPEAT FINDING

REMARKS:

According to Agen
a high level.

b6,b7c

and Major b6,b7c conununication between ICE and the detainees and ICE and the facility are functioning at

/ May 15, 200

AUDITOR'S SIGNATURE I DATE

b6,b7c

Page 70 of72

'DETAINEE '.I'IUNSFER.STANpARQ

'.'

•POLICY; 'iCE"WlLLlvfAKE ALL NECESSARY NOTIFICATIONS WHEN ADBTAINEEis TRANSFERPJIDi IF kDEtAiNEE IS BEiNG TRANSFERRBovrA TIm

.' JUSTIcE PruSONER ALmN TRANSPORTATION SySTEM (Jl>ATS), ICE WILL ADHERE TOJPAi's PROTOCOLS. ,IN DocIDINGWHETHER TO
TRANSFERADErAINEE, ICE Wni TAKE INTO CONSIDERATION WHETHERTHEDETAThlliEIs IWPlU3SENTED BJWORE 'IHli lMMIGRATION COURT.· IN
SUCH CASES, THE FmLD OFFICE DIRECTOR WILL CONSIDER TIm DETAlNEE'S STAGE WIIl'IiNTImREM:O'lALPROCESS, WHB11IER THE DETAINEE'S
ATTORNEY IS LOCATEDWTUIIN REASONABLE DRIVING DISTANCE OF THE FACiLirY, AND WHERE rim IMMIGRATION COURT PROCEEDINGS ARE
TAIaNG PLACE. .
'
.
.'
COMPONENTS

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; and
• When the A File is not available, notification is noted within
DACS
Notification includes the reason for the transfer and the location of the
new facility.
The deportation officer is allowed discretion regarding the timing of the
notification when extenuating circumstances are involved.
The attorney and detainee are notified that it is their responsibility to
notify family members regarding a transfer.
Facility policy mandates that:
• Times and transfer plans are never discussed with the detainee
prior to transfer;
• The detainee is not notified of the transfer until immediately
prior to departing the facility; and
• 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 ofa 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;
and
A
• medical transfer summary is completed and accompanies the
detainee.
Detainees in ICE facilities having DIHS staff and medical care are
transferred with a completed transfer summary sheet in a sealed envelope
with the detainee's name and A-number, and the envelope is marked
Medical ConfidentiaL
For medical transfers, transporting officers receive instructions regarding
medical issues.
Detainee's funds, valuables, and property are returned and transferred
with the detainee to hislher new location.
Transfer and documentary procedures outlined in Section C and D are
followed.
Meals are provided when transfers occur during normally schedule meal
times.
An A File or work folder accompanies the detainee when transferred to a
different field office or sub-office.
Files are forwarded to the receiving office via overnight mail no later than
one business day following the transfer.

REMARKS

According to Agent b6,b7c this
notification is part of the
Deportation Officer's check list
and is a routine step.

0
These are the routine procedures
followed by the facility per
Major b6,b7c and SOP-Q7-09
section8.1.5 .

Per Agent

Meals would be provided if
requested.
A-Files either accompany him or
precede him.

See above.

There is no DIHS staff at this
facility.

b6,b7c

FOR OFFICIAL USE ONLY (LAWENFORCEMENT SENSITIVE)
10 2007 Creative Corrections, LLC (Rev. 12/8/07)

Page 71 of72

,', : '

DETAINEE.TRANSFERSTANDARD .

': :. " ,, ' ,'

~()LIc.v: ICEW1LLM<\KEALL NE~S.#Y~OT1FICATioNSwtm}J A'I)E1'AINEEISiRANS~'- IF ADeTAINEE IS BEiNG lRANSPeRRED ~ THE"
'USTICE PRISONER ALIEN 'fRAl'ISPoRTATION,SYSTEM·(.n>A.T:S), ·IGE WJI.L ADHERE TO WATS PROTOCOLS. 'n.r DECIDrNG.WH,ETIlER TO '
TRANSFER A DETAINEE; ICE WILL Ti\KEiNTOCClNSIDERATION 'WHETHERTHEDETAiNm;ISREPRESENfED BEFORE nffi nviMioRAnONCoURT. IN: .
SUC~CASES, tHEFIELb OFFICEDIREcrOR WILL CONSIDER THE DETMNEE'S STAciE WirHINTI-m REMOVALPRoCESS,WHETHERTHE DETAINEE'S
ArtORNEYISLOCATED WrrlirnRE;\soNAin.;E DRIVING DISTANCED!? THE FAcir..frr,ANDWHEIW niB ~GRATION COURT PRocEEDINGS ARE
TAK.INO PLACE; ..
.
. ..
. .
.
..

1.y .

COMPONENTs .'

IZI ACCEPTABLE

DEFICIENT

NINA

OAT-RISK

I·

REMARKS

REPEAT FINDING

REMARKS:

According to Agent

b6,b7c

these are the standard procedures for transfers and'any exception to them would be rare.

May 15. 2008.

AUDITOR'S SIGNATURE / DATE

b6,b7c

Page 72 ofn

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