U.S. Department of Homeland Security
Immigration and Customs Enforcement
Office of Professional Responsibility
Inspections and Detention Oversight
Washington, DC 20536-5501

Office of Detention Oversight
Compliance Inspection

Enforcement and Removal Operations
San Antonio Field Office
East Hidalgo Detention Center
La Villa, Texas

February 12 – 14, 2013

COMPLIANCE INSPECTION
EAST HIDALGO DETENTION CENTER
SAN ANTONIO FIELD OFFICE
TABLE OF CONTENTS
EXECUTIVE SUMMARY ...............................................................................................1
INSPECTION PROCESS
Report Organization .................................................................................................7
Inspection Team Members .......................................................................................7
OPERATIONAL ENVIRONMENT
Internal Relations .....................................................................................................8
Detainee Relations ...................................................................................................8
ICE NATIONAL DETENTION STANDARDS
Detention Standards Reviewed ...............................................................................9
Environmental Health and Safety ..........................................................................10
Medical Care ..........................................................................................................12
Staff-Detainee Communication .............................................................................15

conducts oversight of the facility’s daily operations, as well as the facility’s adherence to the ICE
NDS. The EHDC Compliance Officer revises the detainee handbook quarterly; maintains
records, logs, policies, and procedures; and addresses any issues affecting the health and welfare
of the detainees. The EHDC Compliance Officer works closely with ICE staff on a daily basis
on detention oversight issues.
Sanitation levels in food service, the medical clinic, admission and release areas, and male
detainee housing units were observed to be high; however, sanitation concerns were noted in the
female housing units. In one female housing unit ODO observed dirt and trash in corners, soap
scum in the showers, and dirty sink/toilet combination fixtures. In other female housing units,
ODO observed graffiti on the walls; beverage stains on the floors in sleeping areas; peeling paint
on partitions, walls and tables; and grimy and dusty floor corners. ODO observed poor
sanitation and cleanliness in shower areas within the above-mentioned female housing units such
as hair in drains, rust, soap scum, and mildew. Sink/toilet combination fixtures were also dirty,
and toilet paper littered the floor. Prior to completion of the inspection, the facility initiated
corrective actions.
During the admissions process, detainees are given a medical screening, attend a facility
orientation, and receive both the EHDC facility detainee handbook and the ICE National
Detainee Handbook. Both the ICE “Know Your Rights” and the EHDC orientation videos are
shown to detainees during the admissions process. Both handbooks are available in the English
and Spanish languages. Detainee property is inventoried and logged during the admissions
process, and documented on a personal property form, which is attached to detainees’ property
bags. Valuables are placed in property bags and stored in a secure storage area. Detainees are
provided with appropriate clothing and free hygiene supplies. ODO reviewed 20 detainee
detention files and found all files had classification forms signed by a reviewing supervisor,
proof of receipt of hygiene items, and signatures of detainees acknowledging receipt of the
detainee handbooks. Upon release, detainees are properly processed, required to sign all closing
documents and related funds and personal property forms, fingerprinted, and required to
surrender facility-issued clothing and bedding.
The law library is located in a quiet room with sufficient furnishings, equipment, and supplies to
support effective legal research and case preparation. There is one computer in the law library
for use by detainees. ODO verified the Lexis-Nexis version installed on the computer is current
as of December 2012. The law library schedule is posted in all housing units. Interviews of
detainees confirmed all were aware of the law library location and access procedures, but
because of the short duration of stay at the facility, no ICE detainees have requested the use of
the library. ODO confirmed with EHDC staff that no ICE detainees have requested access to the
law library in over a year.
Detainees are classified by ICE staff assigned to the Port Isabel Detention Center before
transporting detainees to EHDC. The FOD San Antonio provides EHDC with a folder
containing Form I-203A, Order to Detain Aliens; the Detainee Classification System Primary
Assessment Form; Form I-213, Record of Deportable Alien; and, when applicable, the criminal
history information. The facility uses the classification level applied by ICE as a base, and then
enters information from the I-213 into the Eagle Classification System Program to validate the
classification level for internal purposes. Review of 15 files confirmed all contained the
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documentation necessary to verify each detainee’s classification level. A Sergeant or Lieutenant
reviews and approves each detainee’s classification. Procedures are in place to reclassify
detainees who received a disciplinary incident report, if necessary. Detainees may appeal their
classification level through the grievance system. At the time of the CI, only Level I detainees
were assigned to the facility.
EHDC has a grievance system by which detainees can file informal or formal grievances. EHDC
attempts to resolve oral and written detainee grievances informally and at the lowest level
possible. Detainees are free to bypass or terminate the informal grievance process and proceed
directly to filing a formal grievance. Results of oral and written grievances are documented, and
copies of resolved grievances are placed in the detainees’ detention files. The EHDC has
procedures for identifying and handling an emergency grievance, and the grievance process is
recorded in the facility-specific detainee handbook. EHDC staff stated, due to the short length of
detainee stay, no formal grievances have been filed by ICE detainees since November 2011,
when EHDC began housing ICE detainees. A review of the EHDC informal grievance log
revealed one documented informal grievance that was addressed in a timely manner, and a copy
of the resolution was placed in the detainee’s detention file.
The EHDC Disciplinary Hearing Officer informed ODO there were no disciplinary reports
written on ICE detainees during the last 18 months. The facility’s disciplinary policy addresses
all requirements of the NDS. Review of the detainee handbook confirmed it includes all required
disciplinary information; however, the information is provided in two different sections.
Detainee rights, the disciplinary process, and procedures for appealing disciplinary findings are
addressed in the Disciplinary System section of the handbook; prohibited acts and sanctions are
addressed in the Classification section. ODO recommends covering all matters relating to
detainee discipline in the Disciplinary System section for ease of access.
The facility has a system for storing, issuing, and maintaining accountability for hazardous
materials. ODO verified hazardous substances were safely stored and controlled in all areas, and
Material Safety Data Sheets (MSDS) were available. Inspection confirmed running inventories
are maintained. A master index of hazardous substances and a master file of MSDS is
maintained, to include emergency telephone numbers and documentation of semi-annual
reviews. A letter dated May 23, 2012, states the EHDC master index and fire emergency plan
were forwarded to the city fire department. ODO verified monthly fire drills were conducted on
each shift, and documentation is on file. Reports for water and pest control were current and
readily available. Internal testing of the facility’s emergency generators is conducted weekly for
60 minutes; however, quarterly testing and servicing by an external generator servicing company
is not conducted.
The Food Service Administrator has over ten years of food service experience and is certified in
SERVSAFE, which is a food safety training and certification program administered by the
National Restaurant Association. The food service operation is supported by a crew of inmate
workers, and no ICE detainees work in food service. ODO confirmed all staff and inmate
workers received medical clearances and completed necessary training. A Chaplain is available
to review and approve detainee requests for religious diets. Written procedures, supplies, and
equipment are in place to accommodate detainees with religious dietary needs. ODO verified
procedures for providing medical diets are in place, and observed the distribution of four medical
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ODO cites as a best practice the partnership between the facility and county health department.
EHDC reports suspect TB cases to the health department as required and thereafter, health
department staff visits the patients on-site and assists in the management of the cases.
ODO cites as a second best practice the “Daily Health Services Shift Report” used by medical
staff to ensure information flow between the three shifts. Included on the report are arriving and
departing detainees and inmates, required glucometer checks, sick call numbers, the medical
isolation roster, emergency room transfers, and other information as appropriate. This
information supports sharing of information and continuity of care, and is a consolidated source
of important data.
Detainees request health care services by completing written medical requests available in
English and Spanish, and depositing them in designated locked boxes. Medical staff retrieves the
requests once daily, five days a week. A retrieval log documents when they are picked up,
supporting accountability. Sick call requests are dated and triaged upon receipt. The medical
record review reflected same or next day triage, with medical requests addressed and completed
in a timely manner as appropriate to the nature of the complaint. Sick call is conducted on a
daily basis during the week, and on weekends upon verbal request. There have been no detainee
deaths at EHDC.
Detainees have the opportunity to use the outdoor recreation areas five days a week for one hour
per day. Outdoor recreation areas are located between each housing unit, each with a single
basketball court, and a stainless steel sink-toilet combination fixture with a privacy wall. In
addition, EHDC has two large outdoor recreation areas with capacity to accommodate the
combined population of four to five housing units. Fresh drinking water is available in all
recreation areas. Leisure activities within the housing units consist of board games, cards, and
television viewing from 8:00 am to 10:30 pm. In addition, detainees may attend volunteer-led
group activities and religious services.
ODO was informed there have been no detainee suicides, suicide attempts, or suicide watches at
EHDC; however, in the event of a suicide watch or attempt, comprehensive local policies are in
place, which exceeds NDS requirements. All staff receives initial and ongoing suicide
prevention training, which includes the identification of suicide risk factors, recognizing the
signs of suicidal thinking and behavior, referral procedures, suicide prevention techniques, and
responding to an in-progress suicide attempt. ODO verified detainees are screened for suicide
risk during the intake process.
EHDC has policies and procedures in place to address prevention, intervention, and handling of
alleged sexual abuse and sexual assault incidents. Information concerning Sexual Abuse and
Assault Prevention and Intervention (SAAPI) is posted in English and Spanish in all housing
units and common areas, and is included in the facility handbook. Review of (b)(7)etraining files
confirmed EHDC staff completed SAAPI training. According to EHDC’s SAAPI policy, EHDC
management has zero tolerance towards all forms of sexual abuse and sexual harassment.
Additionally, the EHDC’s intake questionnaire form inquires if inmates/detainees have ever been
victims of sexual abuse or assault. For any affirmative answers, EHDC sends those detainees to
the McAllen Medical Center for an examination. ODO reviewed EHDC policy and confirmed
written procedures are in place for reporting incidents through the chain-of-command and ICE
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INSPECTION PROCESS
ODO inspections evaluate the welfare, safety, and living conditions of detainees. ODO primarily
focuses on areas of noncompliance with the ICE NDS or the ICE Performance-Based National
Detention Standards, as applicable. The NDS apply to EHDC. In addition, ODO may focus its
inspection based on detention management information provided by ERO Headquarters and
ERO field offices, and on issues of high priority or interest to ICE executive management.
ODO reviewed the processes employed at EHDC to determine compliance with current policies
and detention standards. Prior to the inspection, ODO collected and analyzed relevant
allegations and detainee information from multiple ICE databases including the Joint Integrity
Case Management System, the ENFORCE Alien Booking Module, and the ENFORCE Alien
Removal Module. ODO also gathered facility facts and inspection-related information from
ERO Headquarters staff to prepare for the site visit at EHDC.

REPORT ORGANIZATION
This report documents inspection results, serves as an official record, and is intended to provide
ICE and detention facility management with a comprehensive evaluation of compliance with
policies and detention standards. It summarizes those NDS that ODO found deficient in at least
one aspect of the standard. ODO reports convey information to best enable prompt corrective
actions and to assist in the on-going process of incorporating best practices in nationwide
detention facility operations.
OPR defines a deficiency as a violation of written policy that can be specifically linked to the
NDS, ICE policy, or operational procedure. When possible, the report includes contextual and
quantitative information relevant to the cited standard. Deficiencies are highlighted in bold
throughout the report and are encoded sequentially according to a detention standard designator.
Comments and questions regarding the report findings should be forwarded to the Deputy
Division Director, OPR ODO.

INSPECTION TEAM MEMBERS

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

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

7

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

East Hidalgo Detention Center
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OPERATIONAL ENVIRONMENT
INTERNAL RELATIONS
ODO interviewed supervisory ICE and EHDC staff, including the Warden, (b)(7)eDeputy Warden,
a Major, an SDDO, and an SIEA. All stated the working relationship between EHDC and ICE
personnel is excellent. EHDC and ICE staff stated morale is high, and the working conditions
are adequate to accomplish all required duties. No vacancies exist at the facility. The Warden
stated he regularly observes ICE staff visiting detainees in the housing units throughout the
week, communicating with detainees and addressing detainee concerns.
Although ICE does not have a permanent staff assigned to EHDC, ICE staff stated they have the
necessary resources to carry out their duties and responsibilities. The SDDO and SIEA both
stated complaints received from detainees are minimal, because of their short duration of stay at
EHDC. During interviews with staff, it was determined EHDC personnel have not received any
formal training on the ICE NDS.

DETAINEE RELATIONS
ODO interviewed 24 randomly-selected ICE detainees (16 male and eight female) at EHDC to
assess detention conditions at EHDC. No complaints were received regarding issuance of
hygiene supplies, food service, medical care, recreation, access to religious services and
telephones, visitation, or the law library. All detainees stated they did not know their DO. An
ERO schedule is posted in each of the housing units; however, the names of the DOs are not
posted on the schedules in the housing units.
One female complained about having difficulty reading because her eyeglasses were stored with
her personal property when she was initially admitted to the facility. EHDC staff immediately
resolved the issue by retrieving and providing the eyeglasses to the detainee when ODO brought
this issue to their attention.

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ICE NATIONAL DETENTION STANDARDS
ODO reviewed a total of 16 NDS and found EHDC fully compliant with the following
13 standards:
Access to Legal Material
Admission and Release
Detainee Classification System
Detainee Handbook
Detainee Transfers
Disciplinary Policy
Food Service
Funds and Personal Property
Recreation
Suicide Prevention and Intervention
Telephone Access
Use of Force
Visitation
As these 13 standards were compliant at the time of the review, a synopsis for these standards is
not prepared for this report.
ODO found deficiencies in the following three standards:
Environmental Health and Safety
Medical Care
Staff-Detainee Communication
Findings for each of these standards are presented in the remainder of this report.

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ENVIRONMENTAL HEALTH AND SAFETY (EH&S)
ODO reviewed the Environmental Health and Safety standard at EHDC to determine if the
facility maintains high standards of cleanliness and sanitation, safe work practices, and control of
hazardous materials and substances, in accordance with the ICE NDS. ODO toured the facility,
interviewed staff, and reviewed policies, fire prevention and control procedures, and
documentation of inspections, hazardous chemical management, pest control, and generator
testing.
The facility has a system for storing, issuing, and maintaining accountability for hazardous
materials. ODO verified hazardous substances were safely stored and controlled in all areas, and
MSDS were available. Inspection confirmed running inventories are maintained. A master
index of hazardous substances and a master file of MSDS is maintained, to include emergency
telephone numbers and documentation of semi-annual reviews. A letter dated May 23, 2012,
states the EHDC master index and fire emergency plan were forwarded to the city fire
department.
ODO verified monthly fire drills were conducted on each shift, and documentation is on file.
Reports for water and pest control were current and readily available. Internal testing of the
facility’s emergency generators is conducted weekly for 60 minutes; however, quarterly testing
and servicing by an external generator servicing company is not conducted
(Deficiency EH&S-1). Routine testing and servicing of generators by a professional service
company ensures operability in the event of a power failure.
Barbering and hair care is conducted in a designated area in Unit 3. Inspection found the
barbershop was spacious and clean. The shop is equipped with hot and cold water, shelving, a
locked closet, barber chair, covered metal trash container, clippers, disinfectant solution, and
other necessary equipment for hair care. Sanitation regulations are posted, and an ample supply
of laundered towels was available.
Sanitation levels in food service, the medical clinic, admission and release areas, and male
detainee housing units were observed to be high; however, sanitation concerns were noted in the
female housing units. In female housing unit 8-A, ODO observed dirt and trash in corners, soap
scum in the showers, and dirty sink/toilet combination fixtures. In female housing units 7A-2,
7B-2, 9A-2, and 9A-3, ODO observed graffiti on the walls and beverage stains on the floors in
sleeping areas. Peeling paint was observed on partitions, walls, and tables; and floor corners
were grimy and dusty. In the showers, ODO observed hair in drains, rust, soap scum, and
mildew. Sink/toilet combination fixtures were dirty and toilet paper littered the floor. ODO
notes these conditions, particularly mildew, pose a health hazard. Prior to completion of the
review, the walls were painted, and all soap scum and mildew on the sinks, toilets, and shower
fixtures was removed. It is recommended that steps be taken to ensure on-going measures are
taken to ensure proper sanitation is maintained in the female housing units, commensurate with
that maintained elsewhere in the facility.
ODO confirmed needles and sharps are strictly accounted for and controlled. Review of
inventories confirmed their accuracy. Bio-hazardous medical waste is handled properly within
the facility and removed by a licensed transporter.
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STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY EH&S-1
In accordance with the ICE NDS, Environmental Health and Safety, section (III)(O), the FOD
must ensure power generators will be tested at least every two weeks. Other emergency
equipment and systems will undergo quarterly testing, with follow-up repairs or replacement as
necessary.
The biweekly test of the emergency electrical generator will last one hour. During that time, the
oil, water, hoses and belts will be inspected for mechanical readiness to perform in an emergency
situation. The emergency generator will also receive quarterly testing and servicing from an
external generator-service company. Among other things, the technicians will check starting
battery voltage, generator voltage and amperage output.

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Nursing staff conduct the medical and mental health intake screenings in a private room in the
intake area. Although the HSA stated EHDC only accepts detainees with stable or low level
medical acuity, ODO noted detainees identified with medication needs or medical issues were
immediately referred to a provider for follow-up. Essential medications were ordered and
provided. Physical examinations are completed by registered nurses and reviewed by a provider
in accordance with the NDS and National Commission on Correctional Health Care
requirements. ODO verified registered nurses received appropriate training in performing
physical examinations. Full compliance with intake screening and physical examination
components of the standard was confirmed by review of 30 detainee medical records. ODO
notes physical examinations were performed between seven and 13 days of detainee admission.
The medical record review confirmed every male detainee received a chest x-ray (CXR) to
screen for the presence of TB at the Rio Grande Valley staging facility at Port Isabel prior to
transfer to EHDC. Females received a purified protein derivative (PPD) skin test on admission
to EHDC. Females are not released to the general population unless the PPD is negative. If the
PPD is positive, a CXR is performed that same day. Review of seven suspect TB cases
confirmed all were managed according to NDS requirements. ODO cites as a best practice the
partnership between the facility and county health department. EHDC reports suspect TB cases
to the health department as required and thereafter, health department staff visits the patients onsite and assists in the management of the cases. In addition, the health department has provided
training to EHDC staff.
ODO cites as a second best practice the “Daily Health Services Shift Report” used by medical
staff to ensure information flow between the three shifts. Included on the report are arriving and
departing detainees and inmates, required glucometer checks, sick call numbers, the medical
isolation roster, emergency room transfers, and other information as appropriate; for example,
sputum collections needed or other treatments ordered. This information supports sharing of
information and continuity of care, and is a consolidated source of important data.
Detainees request health care services by completing written medical requests available in
English and Spanish, and depositing them in designated locked boxes. Medical staff retrieves
the requests once daily, five days a week. A retrieval log documents when they are picked up,
supporting accountability. Sick call requests are dated and triaged upon receipt. The medical
record review reflected same or next day triage, with medical requests addressed and completed
in a timely manner as appropriate to the nature of the complaint. Sick call is conducted on a
daily basis during the week and on weekends upon verbal request.
A review of all healthcare and(b)(7)edetention staff training records confirmed all healthcare staff
had current certification in cardiopulmonary resuscitation (CPR). This training includes first aid,
use of an automated external defibrillator, as well as CPR. (b)(7)e of the(b)(7)edetention staff files
had no documentation of CPR training (Deficiency MC-2). According to the Warden and the
Training Manager, who had only been in that position for three months, arrangements had
already been made to provide the training to all staff not currently certified.

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STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY MC-1
In accordance with the ICE NDS, Medical Care, section (III)(B), the FOD must ensure adequate
space and equipment will be furnished in all facilities so that all detainees may be provided basic
health examinations and treatment in private.
DEFICIENCY MC-2
In accordance with the ICE NDS, Medical Care, section (III)(H)(2), the FOD must ensure, in
each detention facility, the designated health authority and the OIC will determine the
availability and placement of first aid kits consistent with the American Correctional Association
requirements.
Detention staff will be trained to respond to health-related emergencies within a 4-minute
response time. This training will be provided by a responsible medical authority in cooperation
with the OIC and will include the following [among others]:
2. The administration of first aid and cardiopulmonary resuscitation (CPR);
Whenever an officer is unsure whether a detainee requires emergency care by a health care
provider, the officer should contact a health care provider or an on-duty supervisor immediately.

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STAFF-DETAINEE COMMUNICATION (SDC)
ODO reviewed the Staff-Detainee Communication standard at EHDC to determine if procedures
are in place to allow formal and informal contact between detainees and key ICE and facility
staff; and if ICE detainees are able to submit written requests to ICE staff and receive responses
in a timely manner, in accordance with the ICE NDS. ODO interviewed ICE and EHDC staff
and detainees; and reviewed the facility liaison visit checklists, housing unit postings, the ICE
detainee request logbook, and EHDC housing unit logbooks.
The SDDO and SIEA make monthly visits to meet with facility management and to observe
conditions of confinement. DOs and IEAs conduct two scheduled visits and several unscheduled
visits per week with detainees to address concerns and requests. According to EHDC staff, the
Assistant Field Office Director and Deputy Field Office Director visit the facility annually;
however, review of the logbooks did not support that ERO department heads, including the FOD,
conduct regular unscheduled visits to EHDC’s housing units, food service area, recreation areas,
and the medical area (Deficiency SDC-1).
ODO reviewed ICE Facility Liaison Visit Checklists generated over the past six months, which
are used to document ICE’s visits, and all were filled out correctly and verified visits by ICE
staff. ODO verified ICE visitation schedules are posted in each housing unit; however, names of
DOs are not posted on the schedule. EHDC has written procedures for detainees to submit
written questions, requests, or concerns to ICE. Detainee request forms are available in the
housing units. ODO reviewed the electronic detainee request log from October 2012 through
February 13, 2013, and confirmed all requests were logged and responded to within 72 hours of
receipt.
During interviews of ICE staff, ODO confirmed ICE staff does not conduct telephone
serviceability checks. Serviceability checks, which include conducting random calls to preprogrammed numbers posted on the pro bono/consulate list, are to be conducted weekly for all
telephones in the detainee housing units (Deficiency SDC-2). ODO tested all telephones in the
detainee housing areas, and found them to be in good working order. Detainees expressed no
complaints about telephone services.

STANDARD/POLICY REQUIREMENTS FOR DEFICIENT FINDINGS
DEFICIENCY SDC-1
In accordance with the ICE NDS, Staff-Detainee Communication, section (III)(A)(1), the FOD
must ensure policy and procedures shall be in place to ensure and document that the ICE Officer
in Charge (OIC), the Assistant Officer in Charge (AOIC) and designated department heads
conduct regular unannounced (not scheduled) visits to the facility’s living and activity areas to
encourage informal communication between staff and detainees and informally observing living
and working conditions. These unannounced visits shall include but not be limited to:
a. Housing Units;
b. Food Service preferably during the lunch meal;
c. Recreation Area;

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d. Special Management Units (Administrative and Disciplinary Segregation); and Infirmary
rooms
DEFICIENCY SDC-2
In accordance with the ICE Detainee Telephone Services Memorandum, dated April 6, 2007, the
FOD must ensure, effective immediately, concurrent with staff/detainee communications visits,
ICE staff will verify serviceability of all telephones in detainee housing units by conducting
random calls to pre-programmed numbers posted on the pro bono/consulate list. ICE staff will
also interview a sampling of detainees and review written detainee complaints regarding detainee
telephone access. The Field Office Director (FOD) shall ensure that all phones in all applicable
facilities are tested on a weekly basis.
Each serviceability test shall be documented using the attached [Telephone Serviceability
Worksheet] form. The field office shall maintain forms in a retrievable format, organized by
month, for a three-year period.

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