ICE Detention Standards Compliance Audit - El Centro Service Processing Center, El Centro, CA, ICE, 2007

ICE Detention Standards Compliance Audit - El Centro Service Processing Center, El Centro, CA, ICE, 2007

• June 2, 2016 • Locations: United States of America -> California • Topics: Corrections Audits, Immigration

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Office of Detention and Removal Operations

U.S. Department of Homeland Seem'ity
425 I Street, NW
Washington, DC 20536

U.S. Immigration
and Customs
Enforcement

MEMORANDUM FOR:

FROM:

I'vJ )
\\

Robin Baker
Field Office Director
San Diego .eld Offi
/f\]
John P. T~rr s IJ \
Director . .,'-.~_./

SUBJECT:

EI Centro Service Processing Center Annual Review

The annual review of the EI Centro Service Processing Center conducted June 19-21,2007, in
EI Centro, California has been received. A final rating of Superior 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
suppOliing documentation. The Field Office Director must now initiate the following actions
in accordance with the Detention Management Control Program (DMCP):
1) The Field Office Director, Detention and Removal Operations, shall notify the facility
within five business days of receipt of this memorandum. Notification shall include
copies of the Form G-324A, Detention Facility Review Form, the G-324A Worksheet,
RIC Summary Memorandum, and a copy of this memorandum.
2) The Field Office Director shall schedule the next annual review on or before
June 19,2008.
Should you or your staff have any questions regarding this matter, please contact
b6, b7c
, Acting Deputy Assistant Director, Detention Management Division at
b2
high
(202) 732
cc: Official File
b2 high, (b)(6), (b)(7)c

www.ice.goY

•
MEMORANDUM FOR:

oar

Detention aild Removal Operations

U.S. Department of Homclaml Secm·ity
425 I Street, NW
Washington. DC 20536

John P. Torres
b6, b7c

FROM:

b6, b7c

Detention and Deportation Officer
Detention Standards Compliance Unit
SUBJECT:

EI Centro Service Processing Center Annual Review

The Detention Standards Compliance Unit conducted the annual headquarters detention review
of the EI Centro Service Processing Center (SPC) conducted June 19-21,2007. Headquarters
b6, b7c
Staff Officer
supervised the review and was assisted by team members b6, b7c
b6, b7c
b6, b7c
b6, b7c
b6, b7c
,
,
and
.
Type of Review

This review is a scheduled Headquarters Review and was conducted to determine overall
compliance with the Immigration and Customs Enforcement (ICE) National Detention
Standards.
Review Summary

The American Correctional Association (ACA), the National Commission on Correctional
Health care (NCCHC) and the Joint Commission for Accreditation of Healthcare Organizations
(JCAHO) accredit EI Centro SPC. The following information summarizes last dates of
successful accreditation and those standards that are not in compliance.
ACA:
NCCHC:
JCAHO:
2006 Review
Acceptable
Deficient
Repeat Deficiency
At-Risk

August 2006
June 2006
August 2006
38

o
o

2007 Review
Acceptable
Deficient
Repeat
At-Risk

o
o
o

www.ice,gov

SUBJECT: EI Centro Sere Processing Center Annual Detention.iew
Page 2

RIC Observations
Areas of Best Practice
Staff-Detainee Communication
Detention and Deportation Officers conduct weekly scheduled visits with detainees and
respond within 72 hours to Detainee Request Fonns. Request Forms were tracked in a
logbook. Management Staff also conduct unscheduled visits throughout the facility. The
detainees seemed content and had no issues with the conditions of confinement or complaints
against the staff.

Access to Legal Materials
The EI Centro Service Processing Center exceeds the standard by pennitting detainees to
access the Law Library seven days a week, instead of the specified five days per week.

Correspondence and Other Mail
The facility exceeds the standard by permitting detainees and indigent detainees the
opportunity to mail an unlimited number of outgoing mail per week. The current National
Detention Standard (NDS) states that detainees are pennitted to mail truee one-ounce letters
per week. The mailroom was found to be well organized and logbooks reviewed were
accurate.

Tool Control
The tool room was found to be immaculate. As required, the Maintenance Supervisor
maintains a computer generated Master Inventory List of all tools and equipment and the
location in which tools are stored. The logbooks were found to be accurate during the review.
There is an excellent system in place to immediately identify lost or broken tools.

Environmental Health and Safety
The EI Centro Service Processing Center maintains excellent control of all flammable, toxic
and caustic materials. Material Safety Data Sheets (MSDS) were located next to all chemicals
as required by the NDS. The chemical control logs truoughout the facility were found to be
accurate with a running balance of chemicals received and distributed.

American Correctional Association (ACA) Accreditation Team
The facility's American Correctional Association (ACA) team conducts daily and weekly
inspections to ensure compliance with chemical, tool control and sanitation of the facility.

Advisories
Hunger Strikes
In August 2006, it was documented that a detainee housed in segregation had been placed on a
hunger strike. The detainee was then isolated and housed in the medical unit. Documentation

SUBJECT: EI Centro
Page 2

Sea

Processing Center Annual Detention.iew

in the detainee's record was unclear if the detainee was actually on a hunger strike or if he
accepted a meal.
Recommended Plan of Action
If a detainee is officially placed on a Hunger Strike, ensure that everything is documented to on
the appropriate forms to include if a detainee refuses a meal.
Sick Call
A detainee requested to see the Dentist on March 15,2007 but was not seen by the provider
until 5 days later on March 20,2007. Another dental request on April 15,2007 was never
addressed. The Health Services Administrator (HSA) stated that this problem had been
identified and corrected.
Recommended Plan of Action
Ensure that detainees are seen by the Dentist in a timely manner and that the follow-up is
documented.
Refusal and Consent Forms
It was noted that several charts were found without documentation regarding medicine refusal
forms. Additionally, the forms did not include the patient's signature.

Recommended Plan of Action
All detainees must be seen face-to-face and educated on the consequences of medicine refusal.
The refusal form DIHS-820 must be completed with a witness signature.
Suicide Prevention and Intervention
Two cases of suicide observation were found to have one missing nurse check. Per procedure,
nurses must access the patient and document this check every two hours.
Recommended Plan of Action
If a detainee is placed on suicide observation, the medical staff shall check the detainee every
two hours and document the observation.
Recommended Rating and Justification
It is the RIC recommendation that the facility receive a rating of "Superior." The facility
currently complies with 38 of 38 Immigration and Customs Enforcement, National Detention
Standards.

RIC Assurance Statement
Findings of compliance are documented on the G-324a inspection form and are fully supported
by documentation in the review file.

SUBJECT: EI Centro Seree Processing Center Annual Detention.view
Page 2

cc: Official File
b2 high, (b)(6), (b)(7)c

•

Department Of Homeland Security
Immigration and Customs Enforcement

Detention Facility Inspection Form
Facilities Used Over 72 hours

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

T~pe

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

IZI
D

G. Accreditation Certificates
List all State or National Accreditation[s] received:

·~~--C~~------"----

B. Current Inspection
Type of Inspection
D Field Office IZI HQ Inspection
Date[s] of Facility Review
June 19-21,2007

.
H P ro bl ems IC omp I amts
(C OPles must be attached)
The Facility is under Court Order or Class Action Finding
D Court Order
D Class Action Order
The Facility has Significant Litigation Pending
D Major Litigation
D Life/Safety Issues
IZI Check if None.

C. Previous/Most Recent Facility Review

Date[s] of Last Facility Review
July 11-13,2006
Previous Rating
IZI Superior D Good D Acceptable
D

Check box if facility has no accreditation[s]

D Deficient IZI At-Risk

N arne an dL ocatlOn 0 f FacIlIty

Name
El Centro Service Processing Center
Address (Street and Name)
1115 N. Imperial Avenue
City, State and Zip Code
El Centro, CA 92243
County
Imperial
Name and Title of Chief Executive Officer (Warden/OIC/Superintendent)
, Officer-In-Charge
b6, b7c
Telephone # (Include Area Code)
(760) 336- b6, b7c
Field Office / Sub-Office (List Office with ovel"sight responsibilities)
San Diego, CA
Distance from Field Office
120

1 FaCI
TIty H'Istory
Date Built
1975
Date Last Remodeled or Upgraded
Ongoing
Date New Construction I Bedspace Added
N/A

Future Construction Planned
IZI Yes D No Date:
Current Bedspace
I Future Bedspace (# New Beds only)
544
Number:
Date:

J. Total Facilitv Population
Total Facility Intake for previous 12 months
5,409
Total ICE Mandays for Previous 12 months
168,492
K

E ICE Information
Name ofInspector (Last Name, Title and Duty Station)
b6, b7c I DDO I Washington DC
Name of Team Member I Title 1 Duty Location
b6, b7c l lEAl Portland
Name of Team Member I Title 1 Duty Location
l DOl Phoenix
b6, b7c
Name of Team Member I Title I Duty Location
b6, b7c
PHS I San Diego

F CDF/IGSA I n f ormatIOn 0 my
I
Contract Number

I
Basic Rates per Man-Day
Other Charges: (If None, Indicate N/A)

CI ass ITIca f IOn L eve I (ICE SPC san d CDFs 0 my,
I )
L-l
L-2
L-3
I Adult Male
(b)(2)High
I Adult Female
F
aCI
T
JtyC apaclty
Rated
544
Adult Male
Adult Female
0
L

Operational
480
0

Emergency
562
0

Facilitv holds Juveniles Offenders 16 and older as Adults

M. Average Daily Population
ICE
462
I Adult Male
I Adult Female
0

USMS
0
0

Other
0
0

N. Facility Staffing Level

Estimated Man-days Per Year

b2 high

Form G-324A (Rev. 8113/04) No Prior Version May Be Used After 1011104

•

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

0
Assault:
Offenders on
Offenders!

Assault:
Detainee on
Staff

Number of Forced Moves,
inc!. Forced Cell moves 3
Disturbances4
of Times Chemical

# Times Four/Five Point
Restraints applied/used
Offender / Detainee Medical
Referrals as a result of
sustained.

N/A

Escapes
Actual
Grievances:

# Received
# Resolved in favor of
Offender/Detainee
Reason (V=Violent, I=I1Iness,
S=Suicide, A=Attempted

Deaths

Psychiatric / Medical
Referrals

# Medical Cases referred for
Outside Care
# 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.

Form G-324A (Rev. 8113/04) No Prior Version May Be Used After 10/1/04

•

1.
2.
3.
4.

Access to Legal Materials
Group Presentations on Legal Rights
Visitation
T
Access

Detainee Services
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.

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
V
Work Prf)ar"ITl

Health Services
18.
19.
20.

Hunger Strikes
Medical Care
Suicide Prevention and Intervention
Terminal
Advanced Directives and Death

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

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

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

Form G-324A (Rev. 8113/04) No Prior Version May Be Used After 10/1/04

•

•
RIC Review Assurance Statement

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

Reviewer-In-Charge: (Print Name)
b6, b7c

b6, b7c

Title & Duty Location

Date

DDOI Washington DC

June 28, 2007

C/,),', / (' I
ff
!

Team Members
Print Name, Title, & Duty Location

Print Name, Title, & Duty Location
b6, b7c

lEAl Portland Oregon
b6, b7c

b6, b7c

DDO IWashington DC

Print Name, Title, & Duty Location

l DOl Phoenix, Arizona
b6, b7c

Recommended Rating:

PHSI San Diego

[g] Superior
DGood

D Acceptable

D Deficient
D At-Risk
Comments:

It is the recommendation of the RIC that the facility receive a rating of "Superior." The facility now fully
complies with 38 of38 standards.

Form G-324A (Rev. 8/13/04) No Prior Version May Be Used After 1011104

•

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.
II

HQDRO EXECUTIVE REVIEW: (Please Print Name)

s7,re""'/(I~'/1 11t

John P. Torres

Date

Title

~~-~

_,~ ~

".'"--

Director

Final Rating:

IXI Superior

o Good
o Acceptable
o Deficient
OAt-Risk

Comments:

The Review Authority has recommended an overall rating of Superior. The facility was found to be in
compliance with 38 out of 3 8 standards. Several advisories were noted in Medical but were addressed
prior to the teams departure.

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

•

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

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

. .

...
. '.

.. ;

,
r'·

". ,"

•

,.-j

. --'

Field Office Detention Review Worksheet
D
D

Local Jail- IGSA
State Facility - IGSA
~
ICES ervlce
. P rocessmg
. C ent er
Name
EI Centro Service Processing Center
Address (Street and Name)
1115 N. Imp'erial Avenue
City, State and Zip Code
EI Centro, CA
County
Imperial
Name and Title of Chief Executive Officer (Warden/OIC/Superintendent)
b6, b7c
, Officer-In-Charge (OIC)
Name and title of Reviewer-In-Charge
s/ Detention and Deportation Officer (000)
b6, b7c
Date[sJ of Review
June 19-21, 2007
Type of Review
DSpecial Assessment DOther
~ Headquarters D Operational

•

Table of Contents

DETAINEE SERVICES STANDARDS

•

(SECTION I)

PL,'\"JACCESS TO LEGAL MATERIALS,,-,=,~,=-c~=~-,-,-,-, cc
... c..... ..
ADMISSION AND RELEASE ....................................................................................................................... .
CLASSIFICATION SySTEM ........................................................................................................................ .
DETAINEE HANDBOOK~."'=~-'-'=.._,-'-'-'"_,,c~~~=~~'-'_"_, ....... " .. .
FOOD
FUNDS AND PERSONAL PROPERTY .......................................................................................................... .
DETAINEE GRIEVANCE PROCEDURES ...................................................................................................... .
GROUP PRESENTATIONS ON LEGAL
ISSUANCE AND EXCHANGE OF CLOTHING, BEDDING, AND TOWELS "'="="='==-'-'
MARRIAGE REQUESTSc"'.... 'c, ... : ......... , ........ ".'." ... c, ..... c.............. ..
NON-MEDICAL ESCORTED
RECREATION ............................................................................................................................................ .
RELIGIOUS PRACTICES _____ .-'-'-'-_~_._.,,_.,=-'-~.=

VOLUNTARY WORK PROGRAM ............................................................................................................... .

HEAL TH SERVICES STANDARDS (SECTION II)
HUNGER STRIKES .................................................................................................................................... .
MEDICAL CARE ....................................................................................................................................... .
SUICIDE PREVENTION AND INTERVENTION ............................................................................................. .
TERMINAL ILLNESS, ADVANCED DIRECTIVES AND DEATH..= " .............................. ,... . ....... .

SECURITY AND CONTROL STANDARDS (SECTION III)

CONTRABAND .......................................................................................................................................... .
DETENTION
DISCIPLINARY POLICy ............................................................................................................................. .
EMERGENCY PLANS, '" ·,',·cc'-'~·-'-'==,·c~'-'-·'-"-'·=_··:_·, ,,' :,':·'''cc~~''--'-CO< ...,',''_,,_·-'-·'-'~'-'-'-''--C-'-__=--'-''-''-'-'-~-'-~~
ENVIRONMENTAL HEALTH AND SAFETY ................................................................................................. .
HOLD ROOMS IN DETENTION FACILITIES ...... ' . ',"",'C',-",-" -,-,",~~','" ,,·.:·,-'--:_··'-oc·=c~===---"-~'-'-"-='-KEY AND LOCK CONTROL ....................................................................................................................... .
POPULA TI ON CO UNTS.",.,.,,",--,,-,-,==_,_,-,-,-,-,-,-,-,_,,.':,,_,_,.,,-, ... , ... ,__,-",-,-, _____,,,_,-,,,_,,,, ___,,._,.,._,,_._,-,_, '-'-=','-'-'-'-'-"-'-'-'--'-'-',' ,'. '-'-'-"

._._•• ,_, ••,._ •••• __ •• ,.,.•_. ,._ ••

POST ORDERS .......................................................................................................................................... .
SECURITY INSPECTIONS. ____~~_
.. _... _____
..............
" .. ' .. c.... .
SPECIAL MANAGEMENT UNIT (ADMINISTRATIVE SEGREGATION) .......................................................... .

~~~~~LO~;~~~~~:~ ~~I~ (~I.S~I.P~INARY:~,~~~G~TI~:).,--,-,-,--~-, •• ~::.~.~:: .. :' :~.-.::~--.::-'-~.:~_::-.::~ I
TRANSPORTATION (LAND) ...................................................................................................................... .
USE OF FORCE ___ .""-,--,._c__

_ "-_ .... '..._____ .",. ............... .

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

STAFF/DETAINEE COMMUNICATIONS _-'-"_:.':,',-,-:_c:._=,-,-==~~.~ .. , .. OC'_'-"_-'-"-_:.'c:.:.c-'-"=_:::_,. " __":_:.'
DETAINEE TRANSFER STANDARD

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

•

For each standard rated below Acceptable, facilities must attach a Plan of Action for bringing
operations into compliance. Each facility should examine the entire worksheet to identifY areas of
improvement including those standards where an overall finding of acceptable was achieved.

Section I

Detainee Services Standards

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

•

ACCESS TO LEGAL MATERIALS

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

4
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01104/05

Remarks

New and updated version
is in use.

Exceeds requirement.
Detainees may access 7
days a week. May stay
for more than 1 hour if
permitted.

No denials.
Reported directly to the
OIC.

•

ACCESS TO LEGAL MATERIALS

Detainees who seek judicial relief on any matter are not
subjected to reprisals, retaliation, or penalties.

I:8J Acceptable

D Deficient

[g]

At-Risk

Remarks

D Repeat Finding

Remarks: (Record significant facts, observations, alternate source used for verification, etc.)
Best PracticeDetainees may have access to the law library seven days a week and for more than one hour if
permitted. All software is up to date. The space provided is more than efficient. No detainee has been
refused access. Excellent collection of legal books, materials, and references.

b6, b7c

~/z., 101-

Yuditor's SignatJre / Date

5
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01104105

•

ADMISSION AND RELEASE

Policy: All detainees will be admitted and released in a manner that ensures their health, safety, and welfare.
The admissions procedure will, among other things include: medical screening; a file-based assessment and
I classification process; a body search; and a search of personal belongings, which will be inventoried,
e ,an d sa feguardd
documen td
e as necessary.

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, etc., and the
detainee handbook.
Medical screenings are performed by medical staff or
persons who have received specialized training for the
purpose of conducting an initial health 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 2ossible.
Detainees are stripped searched only when cause has
been established and not as routine policy. Noncriminal detainees are not strip-searched but are patted
down unless reasonable suspicion is established.
The "Contraband" standard governs all personal property
searches. IGSAs/CDFs use or have a similar contraband
standard. Staff prepares a complete inventory of each
detainee's possessions. The detainee receives a copy.
Staff completes Form 1-387 or similar form for CDFs and
IGSAs for every lost or missing property claim. Facilities
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.
~ Acceptable

rg]

Performed by PHS.

rg]

D
D

rg]

At-Risk

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

JiJ::2i

'2-\

Remarks
Handbook is available in
Spanish and English.

Deficient

(C> 76

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

Verified by non-active
detention files.

Repeat Finding

•

CLASSIFICATION SYSTEM

Policy: All facilities will develop and implement a system according to which ICE detainees are classified. The
classification system will ensure that each detainee is placed in the appropriate category, physically separated
from detainees in other categories
The facility has a system for classifying detainees. In
CDFs and IGSAs, an Objective Classification System
or similar is used.
The facility classification system includes:
• Classifying detainees upon arrival.
• Separating individuals who cannot be classified
upon arrival from the general population.
• The first-line supervisor or designated
classification specialist reviewing every
classification decision.
The intake/processing officer reviews work-folders, Afiles, etc., to identify and classify each new arrival.
Staff use only information that is factual, and reliable to
determine classification assignments. Opinions and
unsubstantiated/ unconfirmed reports may be filed but
are not used to score detainees classifications.
Housing assignments are based on classificationlevel.
A detainee's classification-level does not affect his/her
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 IGSA'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 IGSAs
explains the classification levels, with the conditions
and restrictions applicable to each.
~ Acceptable

D Deficient
atjons,

b6, b7c

Components

At-Risk

other sources used, etc.)

'/2-1/077
G·324A Detention Inspection Fonn Worksheet for IGSAs . Rev: 01104/05

Remarks

Classification determined
by criminal history reports
and actual
documentation.

Audit of 15 detention
files. All reviews were
completed before
deadlines.

D Repeat Finding

•

CORRESPONDENCE AND OTHER MAIL

Policy: All facilities will ensure that detainees send and receive correspondence in a timely manner, subject to
limitations required for the safety, security, and orderly operation of the facility. Other mail will be permitted,
subject to the same limitations. Each facility will widely distribute its guidelines concerning correspondence and
other mail.
Components
The rules for correspondence and other mail are posted
in each housing or common area or provided to each
detainee via a detainee handbook.
The facility provides key information in languages other
than English; In the language(s) spoken by significant
numbers of detainees. List any exceptions.
Incoming mail distributed to detainees within 24 hours or
1 business day after it is received and inspected.
Outgoing mail is delivered to the postal service within
one business day of its entering the internal mail system
(excluding weekends and holidays).
Staff do not open and inspect incoming general
correspondence and other mail (including packages and
publications) without the detainee present unless
documented and authorized in writing by the Warden or
equivalent for 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 are prohibited from reading or copying incoming
special correspondence.
Staff are only authorized to inspect outgoing
correspondence or other mail without the detainee
present when there is reason to believe the item might
present a threat to the facility's secure or orderly
operation, endanger the recipient or the public, or might
facilitate criminal activity.
Correspondence to a politician or to the media is
processed as special correspondence and is not read or
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 documented and
investigated. Standard procedure includes issuing a
receipt to the detainee.

Yes

Remarks

Delivered same day.

Verified log book.

A receipt is issued. AI
items stored in safe.

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

•

CORRESPONDENCE AND OTHER MAIL

Deficient

At-Risk

IEA's provide control and
disposal of all
contraband.
Detainees may mail as
many letters as they wish.

Repeat Finding

Remarks: (Record significant facts, observations, other sources used, etc.)
Best PracticeThis area was very organized, log books were filled in with no blanks, every piece of mail was logged
in and then handed out to the detainees with in an hour. Detainee letters that are received after a detainee
has left the facility is documented and kept for 180 days and then destroyed. Money that is given to ICE
Officers for mail is documented and receipt is issued. Every purpose dealing with mail has its own log book.

b6, b7c

Auditor's Sign ure / Date

('/2-1 flo=!-

~~I

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

•

DETAINEE HANDBOOK

Policy: Every OIC will develop a site-specific detainee handbook to serve as an overview of, and guide to, the
detention policies, rules, and procedures in effect at the facility. The handbook will also describe the services,
programs, and opportunities available through various sources, including the facility, ICE, private organizations,
etc. Every detainee will receive a copy of this handbook upon admission to the facility.
I

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

10
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01104/05

Remarks

Training video is used.

Anually, New book
updated March
2007.

I
!

•

DETAINEE HANDBOOK

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

[g]

Also posted in barracks.

[g]

0
0
0

Also posted in barracks.

[g]

0
0
0

[g]

o Deficient

IZI Acceptable

[g]

OAt-Risk

Remarks

o Repeat Finding

Remarks: (Record slgntflcant facts, observatIons, other sources used, etc.)
The Law Library hours of operation are not printed in the handbook but referred to the bulletin boards. This
information is currently posted on all bulletin boards in the common areas and living areas .
b6, b7c

Auditor's Signature / Date

c.lj'/or
11
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01/04/05

•

FOOD SERVICE

Policy: Every facility will provide detainees in its care with nutritious and appetizing meals, prepared in
accordance with the highest sanitary standards.

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

•

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

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

Remarks
Certified Service
Administrator is

b6, b7c

Video is used.

Yeasts and Nutmeg not
used in the facility.
Shakedowns performed
every shift .

No Handouts used. All
Training Videos.

12
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01104/05

•

FOOD SERVICE

Policy: Every facility will provide detainees in its care with nutritious and appetizing meals, prepared in
accordance with the highest sanitary standards.
Components
Detainees are served at least two hot meals every day.
No more than 14 hours elapse between the last meal
served and the first meal of the following day.
For cafeteria style operations, a transparent "sneeze
guard" protects both the serving line and salad bar line.
The facility has a standard 35-day menu cycle. IGSAs
use a 35 day or similar system for rotating meals.
The FSA or facility considers the ethnic diversity of the
facility's detainee population when developing menu
cycles. (Provide examples)
A registered dietitian conducts a complete nutritional
analysis of every master-cycle menu planned.
The FSA has established procedures to ensure that
items on the master-cycle menu are prepared and
presented according to approved recipes.
The Cook Foreman has the authority to change menu
items if necessary.
• If yes, documenting each substitution, along
with its justification
• With copy to FSA
All staff and volunteers know and adhere to written
"food preparation" procedures.
Detainees whose religious beliefs require the
adherence to particular religious dietary laws are
referred to the Chaplain or FSA.
A common-fare menu available to detainees whose
dietary requirements cannot be met on the main.
• Changes to the planned common-fare menu
can be made at the facility level.
• Hot entrees are offered three times a week.
• The common-fare menus satisfy nutritional
recommended daily allowances (RDAs).
• Staff routinely provides hot water for instant
beverages and foods.
0
Common-fare meals are served with:
Disposable plates and utensils.
0
Reusable plates and utensils.
0
• Staff use separate cutting boards, knives,
spoons, scoops, etc., to prepare the commonfare diet items.
A supervisor at the command level must approve a
detainee's removal from the Common-Fare Program.
The Warden, in conjunction with the chaplain and/or
local religious leaders, provide the FSA a schedule of
the ceremonial meals for the following calendar year.

rg]

Remarks

No salad bar. Served
through a portal.
See attatched menu.

Verified Creds.
All recipes are
computerized. Printed as
needed.

Same as main menu. A
substitute from the main
menu may occur.

rg]

13
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01/04105

•

FOOD SERVICE

i Policy: Every facility will provide detainees in its care with nutritious and appetizing meals, prepared in
accordance with the highest sanitary standards.
i
Components
N
Y
NA
Remarks
The common-fare program accommodates detainees
abstaining from particular foods or fasting for religious
purposes at prescribed times of the year.
• Muslims fasting during Ramadan receive their
meals after sundown.
• Jews who observe Passover but do not
participate in the Common-Fare Program
receive the same Kosher-for- Passover meals
as those who do participate.
• Main-line offerings include one meatless meal
(lunch or dinner) on Ash Wednesday and
Fridays during Lent.
The food service program addresses medical diets.

(g]

satellite-feeding programs follow guidelines for proper
sanitation.

(g]

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

(g]

All meals provided in nutritionally adequate portions.

(g]

D
D

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

(g]

The food service staff instructs detainee volunteers on:
• Personal cleanliness and hygiene;
• Sanitary techniques for preparing, storing, and
serving food, and;
• The sanitary operation, care, and maintenance
of equipment.
Everyone working in the food service department
complies with food safety and sanitation requirements.
Standard operating procedures include weekly
inspections of all food service areas, including dining
and food-preparation areas and equipment.
• who conducts the inspections?
Equipment is inspected for compliance with health and
safety codes and regulations.
• When was the most recent inspection?
• Which agency conducted the inspection?
Reports of discrepancies are forwarded to the Warden
or designated department head and corrective action is
scheduled and completed.
Standard procedure includes checking and
documenting temperatures of all dishwashing
machines after each meal.
Staff documents the results of every 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.

(g]

Inspected by the Food
Service Supervisor.

All equipment is checked
daily.
Inspected by Food Service
Supervisor.

Cooks check 3 times daily.

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

Verified logs. lEA's check
in AM hours.

•

FOOD SERVICE

Policy: Every facility will provide detainees in its care with nutritious and appetizing meals, prepared in
accordance with the highest sanitary standards.

Components

[gJ Acceptable

Deficient

YIN
At-Risk

Remarks
Repeat Deficiency

Remarks: (Record significant facts, observations, other sources used, etc.)
The dishwashing machine temperature gauge for the final rinse cycle was not working properly. A temp of
180 degrees was found using a hand thermometer. A requisition for it to be fixed was submitted immediately.

b6, b7c

Auditor's SignGure / Date

o7
I

15
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01/04/05

•

FUNDS AND PERSONAL PROPERTY

All facilities will implement procedures to control and safeguard detainees' personal property.
Policy:
Procedures will provide for the secure storage of funds, valuables, baggage and other personal property; the
documentation and receipting of surrendered property; and the initial and regularly scheduled inventorying of all
funds, valuables, and other property.

o Standard NA:

(IGSA ONLY) Check this box if all ICE detainee Funds, Valuables and Property are
handled only by the ICE Field Office or Sub-Office in control of the detainee case.

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

[g] Acceptable

o Deficient

Yes

OAt-Risk

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

'i~llo?
16
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01104/05

Remarks
This is a restricted area.

A detailed list is in the
Detention files.

Reported to the SIEA.

Property unclaimed after
180 is disposed of.
Verified logbooks.

o Repeat Finding

•

GROUP LEGAL RIGHTS PRESENTATIONS

Policy: Facilities housing ICE detainees shall permit authorized persons to make presentations to groups of
detainees for the purpose of informing them of U.S. immigration law and procedures, consistent with the
security and orderly operation of each facility. ICE encourages such presentations, which instruct detainees
about the immigration system and their rights and options within it.

[g] Check here if No Group Presentations were conducted within the past 12 months. Mark Standard as
Acceptable overall and continue on with next portion of worksheet.
Components

The Field Office is responsive to requests by attorneys
and accredited representatives for group presentations.
Upon receipt of concurrence by the Field Office Director,
the facility or authorized ICE Field Office ensures proper
notification to attorneys or accredited representatives in
a timely manner.
The facility follows policy and procedure when rejecting
or requesting modifications to objectionable material
provided or presented by the 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 allows a sufficient
number of presentations so that all detainees signed up
may attend.
Detainees in segregation, unable to attend for security
reasons may request separate sessions with presenters.
Such requests are documented.
Interpreters are admitted when necessary to assist
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.
The facility permits presenters to meet with small groups
of detainees to discuss their cases after the group
presentation. ICE or authorized detention staff are
present but do not monitor conversations with legal
providers.
Group presenters who have had their privileges
suspended are notified in writing by the Field Office
Director or disignee; and the reasons for suspension are
documented. The Headquarters Office for Detention
and Removal, Field Operations and Detention
management Division is notified when a group or
individual is suspended from making presentations.
The facility plays ICE-approved videotaped
presentations on legal rights, at regular opportunities at
the request of outside organizations.

Yes

17
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01/04/05

Remarks

•

GROUP LEGAL RIGHTS PRESENTATIONS

!Z;;] Check here if No Group Presentations were conducted within the past 12 months. Mark Standard as
Acceptable overall and continue on with next portion of worksheet.
Components

A copy of the Group Legal Rights Presentation policy,
including attachments, is available to detainees upon
request

!Z;;] Acceptable

o Deficient

Yes

OAt-Risk

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

Auditor's Sign ture / Date

"2.,/07-

18
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01104/05

Remarks

o Repeat Finding

•

DETAINEE GRIEVANCE PROCEDURES

Policy: Every facility will develop and implement standard operating procedures (SOPs) for addressing
detainee grievances in timely fashion. Each step in the process will occur within the prescribed time frame.
Among other things, a grievance will be processed, investigated, and decided (subject to appeal) in accordance
with the SOPs; a grievance committee will convene as provided in the SOPs. Standard procedure will include
providing the detainee with a written response to any formal grievance, which will include the basis for the
decision. The facility will also establish standard procedures for handling emergency grievances. All
grievances will receive supervisory review. Reprisal against the filer of a grievance will not be tolerated.
Components
Written procedures provide for the informal resolution
of oral grievances (Not mandatory).
• If yes, the detainee has up to five days within
which to make his/her concern known to a
member of the staff.
Detainees have access to the grievance committee (or
equivalent in IGSA), using formal procedures.
• Detainees may seek help from other detainees
or facility staff when preparing a grievance.
• Illiterate, disabled, or non-English-speaking
detainees receive special assistance when
necessary.
Every member of the staff knows how to identify
emergency grievances, including the procedures for
expeditinq them.
There are documented or substantiated cases of staff
harassing, disciplining, penalizing, or otherwise
retaliating against a detainee who lodges a complaint.
• If yes, explain.
Procedures include maintaining a Detainee Grievance
Log.
• If not, an alternative acceptable record keeping
system is maintained.
"Nuisance
complains" are identified in the
•
records.
• For quality control purposes, staff documents
nuisance complaints received but not filed.
Staff is required to forward any grievance that includes
officer misconduct to a higher official or, in a CDF/IGSA
facility, to ICE.
~ Acceptable

Deficient

At-Risk

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

Auditor's Signature / Date

"/ZI lOT

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

Remarks

Repeat Finding

•

ISSUANCE AND EXCHANGE OF CLOTHING, BEDDING, AND TOWELS
: Policy: ICE requires that all facilities housing ICE detainees provide clean clothing, bedding, linens and towels
to every ICE detainee upon arrival. Further, facilities shall provide ICE detainees with regular exchanges of
clothing, linens, and towels for as long as they remain in detention.
Components

Yes

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

rg] Acceptable

rgJ

At-Risk

ts, observations, other sources used, etc.)
b6, b7c

Auditor's

/ Date

Remarks
Due to climate, changed
daily.

Deficient

blzl/o '1I

20
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01/04/05

Changed daily after work
detail.

Repeat Finding

•

MARRIAGE REQUESTS

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

D Deficient

At-Risk

ts, observations, other sources used, etc.)
b6, b7c

Auditor's Signature / Date

'/ZI/O"/

21
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01104/05

Remarks

No denials exist.

D Repeat Finding

•

NON-MEDICAL EMERGENCY ESCORTED TRIPS

Policy: The Immigration and Customs Enforcement (ICE) may provide detainees with staff-escorted trips into
the community for the purpose of visiting critically ill members of the detainee's immediate family, or for
attending funerals.

D Standard NA: Check this box if all ICE Non-Medical Emergency Escorted Trips 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 immediate family member's:
• Funeral
• 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 do not accept gifts/gratuities from a
detainee, detainee's relative or friend for any reason.
Escort officers ensure that detainees:
• Conduct themselves in a manner that does not bring
discredit to the ICE.
• Do not violate federal, state, or local laws.
• Do not purchase, possess, use, consume, or
administer narcotics, other drugs, or intoxicants.
• Make no unauthorized phone calls.
• Know they are subject to search, urinalysis,
breathalyzer, or comparable test uf'on return.
Standard procedure requires the immediate return to the
facility of any detainee who violates trip rules.
~ Acceptable

Deficient

Yes

[g]

At-Risk

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

Auditor's Signature / Date

?/U/0122
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01104/05

Remarks

Repeat Finding

•

RECREATION

•

Policy: It is ICE policy to provide access to recreational programs and activities to all ICE detainees, to the
extent possible, under conditions of security and supervision that protect their safety and welfare.
Components
Y i N
NA
[g]
The facility has a recreation proQram and facility.
D
D
A recreational specialist (for facilities with more than 350
[g]
detainees) tailors the program activities and offerings to
D
D
the detainee population.
Regular maintenance keeps recreational facilities and
[g]
D
D
equipment in -.9ood condition.
The recreational specialist or trained equivalent
[g]
D
D
supervises detainee recreation workers.
The recreational specialist or trainee equivalent
[g]
oversees recreation programs for Special Management
D
D
Unit and special-needs detainees.
Dayrooms offer sedentary activities, e.g., board games,
[g]
D
D
cards, television.
[g]
Outside activities are restricted to limited-contact sports.
D
D
Each detainee has the opportunity to participate in daily
[g]
D
D
recreation.
Detainees have access to recreation activities outside
[g]
the housing units for at least one hour daily, 5 days a
D
D
week.
Staff checks all items for damage and condition when
[g]
D
D
eguipment is returned.
Staff conducts searches of recreation areas before and
[g]
D
D
after use.
[g]
All recreation areas under constant staff supervision.
D
D
[g]
Supervising staff is equipped with radios.
D
D
The facility provides detainees in the SMU at least one
[g]
hour of outdoor recreation time daily, five times per
D
D
week.
Detainees in disciplinary/administrative segregation
[g]
receive a written explanation when a panel revokes
D
D
his/her recreation privileges.
Special programs or religious activities are available to
[g]
D
D
detainees.
Volunteers are required to sign a waiver of liability
[g]
before entering a secure portion of the facility where
D
D
detainees are present.
Visitors, relatives or friends are not allowed to serve as
[g]
D
D
volunteers.
~ If outdoor recreation is offered check this box. No further information is
recreation is offered.
If the facility has no outside recreation, are detainees
considered for transfer after six months?
D
D
D
• If yes, written procedures ensure timely review
of all eligible detainees.
Case officers make written transfer recommendations
D
D
D
about every six-month detainee to the OIC.
The OIC documents all detainee-transfer decisions,
D
D
D
whether yes or no.
The detainee's written decision for or against an offered
D
D
D
transfer documented in his/her A-file.

23
G·324A Detention Inspection Form Worksheet for IGSAs • Rev: 01/04/05

Remarks

Detainees are allowed 7
days a week. Weather
permitting.

Contract services
used.

required when outdoor
I

•

RECREATION

Policy: It is ICE policy to provide access to recreational programs and activities to all ICE detainees, to the
extent possible, under conditions of security and supervision that protect their safety and welfare.
Staff notifies the detainee's legal representative of
hislher decision to accept/decline a transfer.
If no recreation is available, the ICE District routinely
review transfer eligibility for all detainees after 60 days.
Does the A-file of every detainee is held more than 60
days without access to recreation contains either a
transfer-waiver signed by the detainee or the OIC's
written determination of the detainee's ineligibility for
transfer.
The detainee's legal representative is notified of the
detainee'sIOIC's decision.

cg] Acceptable

Deficient

At-Risk

b6, b7c

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

Repeat Finding

•

RELIGIOUS PRACTICES

Policy: Facilities will provide ICE detainees of all faiths with reasonable and equitable opportunities to
participate in the practices of their faith, limited only by the constraints of safety, security, the orderly operations
of the facility and budgetary considerations.
Components

Detainees are allowed to engage in religious services.
Space is available for detainees to conduct religious
services.
The facility allows detainees to observe the major "holy
days" of their religious faith.
• List any exceptions.
The facility accommodates recognized holy-day
observances by:
• Providing special meals, consistent with dietary
restrictions.
• Honoring fasting requirements.
• Facilitating religious services.
• Allowing 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 conduct
may request to present their own services within security
allowances.
Detainees in the Special Management Unit to participate
in religious practices unless otherwise documented for
the safety and security of the facility.

[g]
[g]

0
0

[g]

I
I
,

~ Acceptable

Deficient

Remarks

Yearly calendar has been
established.

[g]

At-Risk

Repeat Finding

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

b6, b7c

Auditor's Sign ture / Date

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

•

DETAINEE TELEPHONE ACCESS

•

Policy: All facilities housing ICE detainees will permit detainees' reasonable and equitable access to
telephones.

[gJ

[gJ
[gJ

D
D

[gJ

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

[gJ

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

[gJ

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

[gJ

[gJ
[gJ

D
D

[gJ

[gJ
[gJ

D
D

[gJ

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

Detainees are afforded a reasonable degree of privacy
for leQal phone calls.
A procedure exists to assist a detainee who is having
trouble placing a confidential call.
The facility provides the detainees with the ability to
make non-collect (special access) calls.
Special Access calls are at no charge to the detainees.
In facilities unable to fully meet this requirement initially
because of limitations of its telephone service, the ICE
makes alternate arrangements to provide required
access within 24 hours of a request by a detainee.
No restrictions are placed on detainees attempting to
contact attorneys and legal service providers who are
on the approved "Free LeQal Services List".
Special arrangements are made to allow detainees to
speak by telephone with an immediate family member
detained in another Facility.
Any telephone restrictions are documented.
The facility has a system for taking and delivering
emergency detainee telephone messages.
Emergency phone call messages are immediately
given to detainees.
Detainees are allowed to return emergency phone calls
as soon as possible.
Detainees in disciplinary segregation are allowed
phone calls relating to the detainee's immigration case
or other legal matters, includinQ consultation calls.
Detainees in disciplinary segregation are allowed
phone calls to consular/embassy officials.
Detainees in disciplinary segregation are allowed
phone calls for family emergencies.

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

Remarks

Exceeds the requirement.
Inspected twice per
month.

•

DETAINEE TELEPHONE ACCESS

•

Policy: All facilities housing ICE detainees will permit detainees' reasonable and equitable access to
telephones.
Components

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

Deficient

At-Risk

Remarks

Repeat Finding

Remarks: (Record significant facts, observations, other sources used, etc.)
Verified the phone system by making phone calls to multiple consular numbers. All in working order.

b6, b7c

42-1(0=1-

27
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 0 l/04/05

•

VISITATION

Policy: ICE shall permit detainees to visit with family, friends, legal representatives, special interest groups and
the news media.

[2J

The visitation schedule and rules are available to the
public.

[2J

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

[2J

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

[2J

A general visitation log is maintained.

[2J

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

[2J

A visitor dress code is available to the public.

[2J

Visitors are searched and identified according to
standard requirements.

[2J

The requirement on visitation by minors is complied
with.

[2J

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

At facilities where there is no provision for visits by
minors, the ICE arranges for visits by children and
stepchildren, on request, within the first 30 days.
After that time, on request, ICE considers a transfer,
when possible, to a facility that will allow minor
visitation. At a minimum, monthly visits are allowed.
Detainees in special housing afforded visitation.

[2J

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

[2J

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

[2J

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

[2J

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

28
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01/04/05

Remarks

Posted in the visitation
area. Handout also
available.

Verified logs.

Minors are allowed to
visit.

Contact visits are not
allowed. Paperwork is
passed through a portal.

Contact visits not
allowed.

•

VISITATION

Policy: ICE shall permit detainees to visit with family, friends, legal representatives, special interest groups and
the news media.
The current list of pro bono legal organizations is
posted in the detainee housing areas and other
appropriate areas.

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

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

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

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

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

~ Acceptable

D Deficient

OAt-Risk

cts, observations, other sources used, etc.)
b6, b7c

Auditor's Signature / Date

"/7-1/0:7'

29
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01104/05

o Repeat Finding

•
VOLUNTARY WORK PROGRAM

•

Policy: In every facility offering a voluntary work program, ICE detainees will have the opportunity to work and
earn money by participating. While not legally required, ICE affords detainee workers basic Occupational
Safety and Health Administration (OSHA) protections.

D Check here if ICE detainees are not authorized to work at the IGSA facility. Mark NA on Form G324A, page 3 and move to next section.
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 mentally challenged
detainees participate in the program.
The facility complies with work-hour requirements for
detainees, not exceeding:
• Eight hours a day and Forty hours a week.
Detainee volunteers generally work according to fixed
schedule.
If a detainee is removed from a work detail, staff places
the written justification for the action in the detainee's
detention file.
Staff, in accordance with written procedure, ensures that
detainee volunteers understand their responsibilities as
workers before they join the work program.
The voluntary work program meets:

•

OSHA,NFPA,ACA~anda~s

Medical staff screens and formally certifies detainee food
service volunteers.
• Before the assignment begins
• As a matter of written procedure
Detainees receive safety equipment! training sufficient for
the assignment
Proper procedure is followed when an ICE detainee is
injured on the job.

[g] Acceptable

vations,
b6, b7c

Deficient

[8J

At-RisK

other sources used, etc.)

(,(<-d01-

30
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01104/05

Remarks
All ICE detainee facility.
Cleaning done daily.

Verified detention files for
workers.

Video is used for initial
and yearly training.

Repeat Finding

• Section II •
Health Services
Standards

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

•

HUNGER STRIKES

Policy: All facilities will follow standard guidelines for the medical and administrative management of ICE
detainees engaging in hunger strikes. By monitoring of the health and welfare of the individual detainees,
facilities will strive to sustain their lives.
Components

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

[g]

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

[g]

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

[g]

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

[g]

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

[g]

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

[g]

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

[g]

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

[g]

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

[g]

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

[g]

The medical staff has written procedures for treating
hunger strikers.

[g]

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

[g]

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

[g]

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

[g] Acceptable

D Deficient

At-Risk

Remarks

Not observed (last H.S. in
2002); no recent cases
for monitoring.

Per policy

Available in medical unit
rooms

D Repeat Finding

Remarks:
Last "official" hunger strike was in 2002. In August 2006, detainee was reported to have been on "hunger
strike" (however, this was per the detainee's self-report according to the initial provider). Patient was then
isolated/housed in medical and medical staff began monitoring intake and output.

32
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01104/05

•

The Health Services Administrator explained that this detainee was not yet "officially" on hunger strike but
was being housed in medical for the initial 72 hours. After this time frame, if he continued to refuse, then he
would be "officially" on hunger strike and protocol would start.
This case had numerous notes in the chart by different providers/nursing documenting "hunger strike" in the
diagnosis; "hunger strike continues", "refusal to come to medical for observation and monitoring of his hunger
strike (per protocol)", "if cooperative do daily weight, VS (vital signs) ... /abs"; this charting would lead one
(especially a layman with no medical background) to believe that the hunger strike was "official" and protocol
(per the National Detention Standards) initiated.
ADVISORY:
1. According to the medical chart, this detainee was already housed in Special Management Unit.
Upon interview, the detention officer in medical stated there is no commissary in SMU and the detention
officers document if meals were refused. Therefore, it should be known that 9 documented meals (within 72
hours) were refused and Hunger Strike protocol would have been initiated (including the initial evaluation:
height, weight, vital signs, psychiatric/psychological evaluation and DIHS-839 Hunger Strike Monitoring
Form). However, if the detainee "accepted" the meal there is no further documentation by detention staff if
the meals were actually eaten. The SMU log book for August 2006 was requested but not available (due to it
being in their warehouse and it was unable to be located).
2. Documentation in the patient's record was unclear that this detainee was NOT on Hunger Strike.
Therefore, clearer, concise documentation is advised to show if there is a true Hunger Strike and its
protocol is "official."
Recommended Changes:
1. If detainee is already housed in SMU with no access to commissary in these rooms and meals are
being recorded, medical staff could review with the SMU Officer their logs to see if 9 meals were
refused. Recommend documenting for example "Detainee verbally reported he has not eaten in the
last 3 days. Reviewed SMU log, this detainee has refused 4 of 6 meals" or " .. .has accepted 6 of 6
meals."
2. A void charting that would indicate or imply a hunger strike is actually taking place. Plan
(interventions) in the patient record should not include charting such as "continue hunger strike
protocol" or "hunger strike continues." Rather document "If patient continues to refuse 3 more meals,
official Hunger Strike will begin and Hunger Strike protocol will be initiated." In the Diagnosis, rather
than documenting "Hunger Strike", document "Refused to eat x 6 meals; POSSIBLE hunger strike IF
continues to refuse 3 more meals. "

b6, b7c

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

•

ACCESS TO MEDICAL CARE

•

Policy: Every facility will establish and maintain an accredited/accreditation-worthy health program for the
general well-being of ICE detainees.
Components

Facilities operate a health care facility in compliance
with State and Local laws and guidelines.
The facility's in-processing procedures of arriving
detainees include medical screening.
All detainees have access to and receive medical care.
The facility has access to a PHS/DIHS Managed Health
Care Coordinator.
The medical staff is large enough to provide, examine,
and treat the facility's detainee population.
The facility has sufficient space and equipment to afford
each detainee privacy when receiving health care.
The medical facility has its own restricted-access area.
The restricted access area is located within the confines
of the secure perimeter.
The medical facility entrance includes a holding/waiting
room.
The medical facility's holding/waiting room under the
direct supervision of custodial staff.
Detainees in the holding/waiting room
have access to a toilet and a drinking fountain.
Medical records are kept apart from other files. They
are:
• Secured in a locked area within the medical
unit.
With
physical access restricted to authorized
•
medical staff.
• Procedurally, no copies made and placed in
detainee files.
Pharmaceuticals are stored in a secure area.
Medical screening includes a Tuberculosis (TB) test.
• Every arriving detainee receives a TB test.
• During the admission process.
• Detainee's TB-screening does not occur more
than one business day after his/her arrival at the
facility.
• Detainees not screened are housed separate
from the general population.
All detainees receive a mental-health screening upon
arrival. It is conducted:
• By a health care provider or specially trained
officer;
• Before a detainee's aSSignment to a housing
unit.
The facility health care provider promptly reviews all 1794s (or equivalent) to identify detainees needing
medical attention.

~
~

D
D
D

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

34
G-324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 01104/05

Remarks
NCCH, JCAHO, ACA,
NOS

1-794 no longer being
used (per DIHS HQ);
questions are included in
Standard Initial Screening
questionnaire.

•

ACCESS TO MEDICAL CARE

•

Policy: Every facility will establish and maintain an accredited/accreditation-worthy health program for the
general well-being of ICE detainees.
Detainees in the Special Management Unit have access
to health care services.
Staff provides detainees with health- services (sick call)
request slips daily, upon request.
• Request slips are available in the languages
other than English, including every language
spoken by a sizeable number of the facility's
detainee population.
• Service-request slips are delivered in a timely
fashion to the health care provider.
The facility has a written plan for the delivery of 24-hour
emergency health care when no medical personnel are
on duty at the facility, or when immediate outside
medical attention is required.
The plan includes an on-call provider.
The plan includes a list of telephone numbers for local
ambulances and hospital services.
The plan includes procedures for facility staff to utilize
this emergency health care consistent with security and
safety.
Detention staff is trained to respond to health-related
emergencies within a 4-minute response time.
Where staff is used to distribute medication, a health
care provider properly trains these officers.

r:gJ

The medical unit keeps written records of medication
that is distributed.
The 1-819 (or IGSA equivalent) is used to notify the
Warden/Facility of a detainee that has special medical
needs.
A signed and dated consent form is obtained from a
detainee before medical treatment is administered.

Detainees use the 1-813 (or IGSA equivalent) to
authorize the release of confidential medical records to
outside sources.
The facility health care provider is given advance notice
prior to the release, transfer, or removal of a detainee.
Detainee's medical records or a copy thereof, are
available and transferred with the detainee.
Medical records are placed in a sealed envelope or
other container labeled with the detainee's name and Anumber and marked "MEDICAL CONFIDENTIAL".

r:gJ Acceptable

D Deficient

r:gJ

r:gJ
r:gJ

D
D

r:gJ

OAt-Risk

Medical staffed 24/7;
outside hospitals
available for 9-1-1

OTC Acetaminophen per
DIHS Standard Operating
Procedure 11.9.6.2.

Present in form of hard
copy, but some infirmary
patients' consents not yet
scanned into electronic
medical record. Problem
was already identified
and being addressed.

o Repeat Finding

Remarks:
Many /-794's (In-Processing Health Screening Form) were found in recent charts incomplete (questions were
not filled out and the name/signature of screener was missing). According to NOS "Access to Care" - section

35
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01104/05

•

D: Medical Screening (new Arrivals): "In SPC's .. .the health care provider or officer will complete ... 1-794.
For other facilities that do not use the ... 1-794 ... the INS Health Services Division must approve any substitute
form."
However, per a DIHS HQ directive, the 794's were no longer required since it was substituted with 1-795A
Intake Screening Form. The HSA reported that she had e-mailed HQ in October 2006 (copy of this e-mail
dated 10/05/06 of this inquiry given to this Reviewer) to confirm and did receive a verbal confirmation from
two administrators at HQ. When asked for this in writing, the HSA e-mailed HQ immediately to confirm that
this has been the case. She received a written reply confirming 1-794's were discontinued since the 795 was
implemented. Furthermore, the reply included an instruction to "put a line through the questions ... and say
see EMR." This reply dated that same day, June 20, 2007 was shown to this Reviewer in the form of a hard
copy e-mail. HSA will now direct staff to follow this exact process.
Sick Calls: Dental- one request (dated 3/15) was seen by a provider 5 days later (3/20). Another request
for dental 4/15 was never addressed. There is no on-site dentist so they must be addressed by
nursing/provider. HSA reported this problem had already been identified and she showed this Reviewer a
copy of an e-mail sent to all her staff (April 17, 2007) informing them that ALL dental requests (when on-site
dentist was not present) must be seen by nursing and referred to a provider as needed.
Refusal forms: Some found without documentation of "the consequences of refusal" filled in; some found
without a witness signature. These identified forms did have the patient signature and thus a face to face
encounter was done, so the patient should have been educated at that time on the consequences of refusing
treatment.

ADVISORY: all patients seen face to face should be educated on the consequences of refusing
treatment/evaluation and documented on the Refusal Form DIHS-820 with a witness signature.
RECOMMENDED CHANGES: Ensure all blanks are filled (including Consequences of Refusal and all
signature blocks, including the witness) before the detainee leaves the medical clinic. Medical Records
should review all forms for completion prior to scanning into the electronic medical record.
Consent Forms: One chart found without a signed consent form. The HSA was informed of this finding and
was able to show this Reviewer a hard copy of this patient's signed consent. She further showed an e-mail
dated 06/05/07 from the Nurse Program Manager, identifying this problem; (consents of detainees admitted
straight to infirmary from intake were being kept on-site but were not getting scanned into the record until
after discharge from the infirmary). Nurse Manager directed staff to have hard copy scanned into eMR first
and then return the paperwork to the Infirmary.

b6, b7c

36
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01104/05

•

SUICIDE PREVENTION AND INTERVENTION
Policy: All detention staff working with ICE detainees will be trained to recognize suicide-risk indicators. Staff
will handle potentially suicidal individuals with sensitivity, supervision, and referrals. A clinically suicidal detainee
will receive preventive supervision and treatment.
Components
Every new staff member receives suicide-prevention
training. Suicide-prevention training occurs during the
employee orientation program.
Training prepares staff to:
• Recognize potentially suicidal behavior;
• Refer potentially suicidal detainees, following
facility procedures;
• Understand and apply suicide-prevention
techniques.
A health-care provider or specially trained officer
screens all detainees for suicide potential as part of the
admission process.
• Screening does not occur later than one working
day_ after the detainee's arrival.
Written procedures cover when and how to refer at-risk
detainees to medical staff and procedures are followed.
The facility has a designated isolation room for
evaluation and treatment.
The designated isolation room does not contain any
structures or smaller items that could be used in a
suicide attempt.
Medical staff has approved the room for this purpose.
Staff observes and documents the status of a suicidewatch detainee at least once every 15 minutes.

I:2:l

Acceptable

D
D

Deficient

At-Risk

Remarks

Constant watch by
detention staff.

Repeat Finding

Remarks:
Two different cases of Suicide ObseNation were found to have one missing nursing check each. Per
procedure, nurse assesses patient and documents every 2 hours. In August 2006, in reviewing the
documentation in the patient's chart, there was a four hour gap in-between two nursing checks. Therefore,
one "every 2 hour" nursing check was missed. In December 2006, in another case, a nursing check was not
documented. An encounter (in the electronic medical record, this is similar to an appointment) was present,
but there is no note or documentation within this blank shell.
Note: most recent Suicide ObseNation (June 2007) documentation was found to be more timely (only 1
nursing note was 40 minutes late) and all notes were present (every 2 hour nursing notes, provider notes with
renewal orders at least every 24 hours per protocol).

ADVISORY: Nursing Checks must be documented in the patient's record every 2 hours.
RECOMMENDED CHANGES: 1. At the end of each shift, each nurse should review the electronic medical
record to ensure their encounters for the every 2 hour nursing checks were documented. 2. If there is a
delay in charting the every 2 hour nursing checks then this should be documented with a late entry or
annotation specifying the actual time the check was done.
b6, b7c

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

•

TERMINAL ILLNESS, ADVANCED DIRECTIVES, AND DEATH
Policy All facilities housing ICE detainees shall have policies and procedures addressing the issues of terminal
illness or injury, medical advanced directives, and detainee death, to include the procedures to ensure proper
notification is provided to ICE officials, family members and other interested parties in the event of a detainee
becoming terminally ill or injured or death of a detainee occurs. In addition, the policy will cover procedures to
be taken if the death of a detainee occurs while in transit.

Check this box if the facility does not accept ICE detainees who are severely or terminally ill.
Indicate NA in the appropriate box forthis portion of the worksheet. ALWAYS complete all references
to detainee death and related notifications.
Components
Y
N
NA
Remarks
Detainees, who are chronically or terminally ill, are
transferred to an aQflfopriate offsite medical facility.
The facility or appropriate ICE office promptly notifies
the next of kin of the detainee's: medical condition.
• The detainee's location.
• The limitations j)laced on visitir}g.
There are guidelines addressing State Advanced
Directive Form for Implementing Living Wills and
Advanced Directives.
• The guidelines include instructions for detainees
who wish to have a living will other than the
generic form the 01 HS provides or who wish to
appoint another to make advance decisions for
him or her.
The guidelines provide the detainee the opportunity to
have a private attorney_prepare the documents.
There is a policy addressing "Do Not Resuscitate
Orders"
Detainees with a "Do Not Resuscitate" order in the
medical record receive maximal therapeutic efforts short
of resuscitation?
The facility notifies the DIHS Medical Director and
Headquarters' Legal Counsel of the name and basic
circumstances of any detainee with a "Do Not
Resuscitate" order in the medical record. In the case of
IGSAs, this notification is made through the local ICE
representative.
The facility has written procedures to address the issues
of organ donation by detainees.
The facility has written procedures to notify ICE officials,
deceased family members and consulates, when a
detainee dies while in Service.
The facility has a policy and procedure to address the
death of a detainee while in transport.
At all ICE locations the detainee's remains disposed of
in accordance with the provisions detailed in this
standard.
In the event that neither family nor consulate claims the
remains, the Field Office schedules an indigent's burial,
consistent with local procedures.
• If the detainee's is a U.S. military veteran is the
Department of Veterans Affairs notified.
An original or certified copy of a detainee's death
certificate is placed in the subject's a-file.

No cases to review
Per policy.
No cases to review.

Per written policy

0
No cases to review

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

No cases to review

•

TERMINAL ILLNESS, ADVANCED DIRECTIVES, AND DEATH

Policy All facilities housing ICE detainees shall have policies and procedures addressing the issues of terminal
illness or injury, medical advanced directives, and detainee death, to include the procedures to ensure proper
notification is provided to ICE officials, family members and other interested parties in the event of a detainee
becoming terminally ill or injured or death of a detainee occurs. In addition, the policy will cover procedures to
be taken if the death of a detainee occurs while in transit.

[gJ Acceptable

Deficient

[gJ

At-Risk

No cases to review

Repeat Finding

Remarks:
Per the HSA, there are no detainees with terminal illness here at EI Centro, thus no actual patient records to
review at this time.

b6, b7c

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

•

Suicide Prevention Program
Attachment C

PURPOSE: TO DESCRIBE THE PROCEDURES THAT MUST BE
FOLLOWED WITH ALL DETAINEES WHO, VERBALLY OR BY THEIR
ACTIONS INDICATE THAT THEY INTEND TO HARM THEMSELVES.

A. Referral, Evaluation and General Suicide Watch/Constant Observation Procedures
All detainees (new and those transferring from other detention facilities) will receive
an initial mental health screening from PHS staff within 24 hours of arrival as per
DIHS/ICE standards. The screening will include an assessment of suicide risk. The
results of the screening will be documented in the mental health screening form and
placed in the detainee's medical record. If there are no suicide or other mental health
concerns the patient may be placed with the general population.
Patients threatening suicide are considered emergencies and require prompt attention.
Detention staff shall notify the medical clinic and escort the detainee to the clinic
immediately. The detainee will immediately be removed from the general population
of the facility and be placed in a secure environment where they can be constantly
observed until an evaluation can be conducted by the DIHS mental health staff. This
is especially important if the suicide threat occurs during normal duty hours.
Individuals voicing suicide threats or actions outside normal working hours shall be
brought to the medical clinic for evaluation immediately.
If the detainee's behavior suggests that he/she presents an imminent risk for selfharm, the mental health clinician or other designated physician may write a medical
order for Suicide Watch/Constant Observation. The order will be carried out by the
nursing staff. The patient will then be placed in the Mental Health Short Stay Unit.
Ordinarily, suicide watch will occur in the Mental Health Unit. Extenuating
circumstances may dictate that Suicide Watch/Constant Observation occur in other
locations (i.e., isolation, medical unit).
All patients on Suicide Watch/Constant Observation, regardless of their housing
location, will be reviewed daily by the mental health provider or other physician. On
weekends or holidays the NP/PA will do the review and discuss results with the
physician on-call. The progress note must include, though not be limited to:

1. Assessment of suicide risk

2. Justification why continued housing under constant watch is the least
Suicide Prevention Program

Page I of 5

•

Section III

Security and Control

40
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01/04105

•

CONTRABAND

Policy: All detention facilities will ensure the proper handling and disposal of all contraband. Documentation of
contraband destruction is required.
Components
The facility follows a written procedure for handling
illegal contraband. Staff inventories, holds, and reports
it when necessary to the proper authority for
action/possible seizure.
Contraband that is government property is retained as
evidence for potential disciplinary action or criminal
prosecution.
Staff returns property not needed as evidence to the
proper authority. Written procedures cover the return of
such property.
Altered property is destroyed following 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.

[g] Acceptable

Deficient

At-Risk

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

41
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01104/05

Remarks

Contraband such as
knifes etc kept for training
outside the peri miter, if
illegal substance it is
turned over to local
authorities

Repeat Finding

•

DETENTION FILES

Policy: Every facility will create a detention file for every ICE detainee booked into the facility, excluding only
detainees scheduled to depart within 24 hours. The detention file will contain copies and, in some cases, the
original of specified documents concerning the detainee's stay in the facility: classification sheet, medical
questionnaire, property inventory sheet, disciplinary documents, etc.
Components

Remarks

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

r:gJ

A file is created on every
detainee.

r:gJ

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.

D Deficient

~ Acceptable

l: t:

~
I

Notated on detention file
check list.

File does not leave
processing area

r:gJ

At-Risk

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

Limited to Supervisors
and lEA assigned to
_processing

/'~

'*~/, "I>' ~_,~

Auditor's Signature / Date

42
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01/04/05

D Repeat Finding

•

DISCIPLINARY POLICY

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

Detainee hand book in
spanish and english
Also provided in the
detainee hand book

43
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01104/05

I
i
I

•

DISCIPLINARY POLICY

Policy: All facilities housing ICE detainees are authorized to impose discipline on detainees whose behavior is
not in compliance with facility rules and regulations.
Components
Y
N
NA
Remarks
The duration of punishment set by the OIC, as
recommended by the disciplinary panel does not exceed
established sanctions. The maximum time in disciplinary
segregation does not exceed 60 days for a single
offense.
Written procedures govern the handling of confidentialinformant information. Standards include criteria for
recognizing "substantial evidence"
All forms relevant to the incident, investigation,
committee/panel reports, etc., are completed and
distributed as required.

I:8J Acceptable

Deficient

At-Risk

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

b6, b7c

Auditor's Signature / Date

44
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01104/05

o Repeat Finding

•

EMERGENCY (CONTINGENCY) PLANS

Policy All facilities holding ICE detainees will respond to emergencies with a predetermined standardized plan to
minimize the harming of human life and the destruction of property. It is recommended that SPCs and CDFs enter •
into agreement, via Memorandum of Understanding (MOU), with federal, local and state agencies to assist in
times of emergency.
Components
Y
N
NA
Remarks
No Detainee or detainee groups exercise control or authority
over other detainees.
Detainees are protected from:
• Personal abuse
• Corporal punishment
• Personal injury
• Disease
• Property damage
• Harassment from other detainees
Staff are trained to identify signs of detainee unrest.
• What type of training and how often?
Staff effectively disseminates information on facility climate,
detainee attitudes, and moods to the Officer In Charge (OIC)
There is a designated person or persons responsible for
emergency plans and their implementation. Sufficient
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 receive copies of Hostage Situation Management
policy and procedures.
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.
The food service maintain at least 3-days' worth of
emergency meals for staff and detainees.
Written plans locate shut-off valves and switches for all
utilities (water, gas, electric).

45
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01/04/05

Trained during initial and
annual training.

ACNComplinance team
tasked with developing
and implimenting plans

Trained during initial and
annual training.

•

EMERGENCY (CONTINGENCY) PLANS

[gJ

D Deficient

[gJ Acceptable

At-Risk

D Repeat Finding

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

::,-

-:-/><~:.'~~

46
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01104/05

•

ENVIRONMENTAL HEALTH AND SAFETY

Policy: Every facility will control flammable, toxic, and caustic materials through a hazardous materials
program. The program will include, among other things, the identification and labeling of hazardous materials in
accordance with applicable standards (e.g., National Fire Protection Association [NFPA]); identification of
incompatible materials, and safe-handling procedures
i
i

Components
The facility has a system for storing, issuing, and
maintaining inventories of hazardous materials.

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

[g]

Remarks

Kept in fire proof locker in
a secure area out of
detainee area

Only chemical issued in
limited quantity is
disenfectant used in
barber shop
Flamable and
combustible materials
kept out of detainee area

Not used in facility

[g]

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

I
I

•

ENVIRONMENTAL HEALTH AND SAFETY

A technically qualified officer conducts the fire and
safety inspections.
The Safety Office (or officer) maintains files of
inspection reports; Including corrective actions taken.
The facility has an approved fire prevention, control, and
evacuation plan.
The plan requires:
• Monthly fire inspections.
• Fire protection equipment strategically located
throughout the facility.
• Public posting of emergency plan with
accessible building/room floor plans.
• Exit signs and directional arrows.
• An area-specific exit diagram conspicuously
posted in the diagrammed area.
Fire drills are conducted and documented monthly.
A sanitation program covers barbering operations.
The barbershop has the facilities and equipment
necessary to meet sanitation requirements.
The sanitation standards are conspicuously posted in
the barbershop.
Written procedures regulate the handling and disposal
of used needles and other sharp objects.
All items representing potential safety or security risks
are inventoried and a designated individual checks this
inventory weekly.
Standard cleaning practices include:
• Using specified equipment; cleansers;
disinfectants and detergents.
An
established schedule of cleaning and follow•
up inspections.
The facility follows standard cleaning procedures.
Spill kits are readily available.
A licensed medical waste contractor disposes of
infectious/bio-hazardous waste.

rg]

rg]
rg]
rg]

D
D
D

rg]

rg]
rg]

D
D

rg]

Staff are trained to prevent contact with blood and other
body fluids and written procedures are followed.
Do the methods for handling/disposing of refuse meet
all regulatory requirements.
A licensed/Certified/Trained pest-control professional
inspects for rodents, insects, and vermin.
• At least monthly.
• The pest-control program includes preventive
spraying for indigenous insects.
Drinking water and wastewater is routinely tested
according to a fixed schedule.

Remarks

Very clean area

In all housing units.
Kept in secure area untill
contractor removes
waste

Specific policy on indig
african bees

rg]

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

Water is tested by the
city.

I
I

•

ENVIRONMENTAL HEALTH AND SAFETY

Emergency power generators is tested at least every
two weeks.
• Other emergency systems and equipment
receive testing at least quarterly.
• Testing is fOllowed-up with timely corrective
actions (repairs and replacements).

IZI Acceptable

Remarks
Emergency generators
are tested once a week

Deficient

At-Risk

Repeat Finding

Remarks: (Record significant facts, observations, other sources used, etc.)
Extensive policies written to address local conditions, weather and indigenous Insects.

b6, b7c

Auditor's Signature"! Date

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

•

HOLD ROOMS IN DETENTION FACILITIES

Policy: Hold rooms will be used only for temporary detention for detainees awaiting removal, transfer, EOIR
hearings, medical treatment, intra-facility movement, or other processing into or out of the facility.

Y
[g]

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

[g] Acceptable

D Deficient

[g]

0
0

[g]

0
0

0
0
0
0

0
0

[g]

At-Risk

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

50
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01104/05

Remarks

Females not held in EGG
Juveniles not held in EGG

D Repeat Finding

•

KEY AND LOCK CONTROL
(SECURITY, ACCOUNTABILITY AND MAINTENANCE)

I
i

Policy It is the policy of the ICE SeNice to maintain an efficient system for the use, accountability and
maintenance of all keys and locks.
Components

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

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

Remarks

Keys sre inventoried
every shift
Twice a year

D
D
D
D

~
~
~

D
D
D

~
~

51
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01104/05

Located in Central
Control Center.

•

KEY AND LOCK CONTROL
(SECURITY, ACCOUNTABILITY AND MAINTENANCE)
Policy It is the policy of the ICE Service to maintain an efficient system for the use, accountability and
maintenance of all keys and locks.

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

Deficient

Remarks
Log in a book kept in the
control room

At-Risk

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

'Auditor's Signatuf'€ / Date

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

Repeat Finding

I
:

•

POPULATION COUNTS

i Policy: All detention facilities shall ensure around-the-clock accountability for all detainees. This requires that
they conduct at least one formal count of the detainee population per shift, with additional formal and informal
counts conducted as necessary.
Components

Staff conducts a formal count at least once each shift.
Activities cease or are strictly controlled while a formal
count is being conducted.
Do certain operations continue during formal counts.

lZl
lZl

D
D

lZl

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

D
lZl
lZl
D

lZl
D
D
lZl

D
D
D
D

lZl

[g] Acceptable

Deficient

At-Risk

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

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

Remarks

Kitchen workers kept in
area

Repeat Finding

•

POST ORDERS
Policy: ICE provides officers all necessary guidance for carrying out their duties. This guidance includes the ,
post orders established for every post, which are reviewed at least annually, and given to each officer upon :
assignment to that post.
Components
Every Fixed post has a set of post orders.
Each set contains the latest inserts (emergency
memoranda, etc.) and revisions.
One individual or department is responsible for keeping
all post-orders current with revisions that take place
between reviews.
The IGSA maintains a complete set (central file) of post
orders.
The central file accessible to all staff.
The OIC or Contract / IGSA equivalent
initiate/authorizes all post-order changes.
The OIC or Contract / IGSA equivalent has signed and
dated the last page of every section.
A review/updating/reissuing of post orders occurs
regularly and at a minimum, annually.

Y
~

Procedures keep post orders and logbooks secure from
detainees at all times.
Every armed-post officer qualifies with the post
weapon(s) before assuming post duty.
Armed-post post orders provide instructions for escape
attempts.
The post orders for housing units track the event
schedule.
Housing-unit post officers record all detainee activity in a
log. The post order include instructions on maintaining
the logbook.

[8J Acceptable

o Deficient

0
0

~
~

0
0
0

OAt-Risk

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

54
G-324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 01104/05

Remarks

Compliance team
assigned task

Post orders are reviewed
and updated by
compliance team
Secured in the officers
desk.

o Repeat Finding

•

SECURITY INSPECTIONS

Policy: Post assignments in the facility's high-risk areas, where special security procedures must be followed,
will be restricted to experienced personnel with a thorough grounding in facility operations.
Components
No
NA
Remarks
Yes
The facility has a comprehensive security inspection
policy. The policy specifies:
• Posts to be inspected
• Required inspection forms
• Frequency of inspections
• Guidelines for checking security features
• Procedures for reporting weak spots,
inconsistencies, and other areas needing
improvement
Every officer is required to conduct a security check of
his/her assigned area. The results are documented.
Documentation of security 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.

D
D

All visits officially recorded in a visitor logbook or
electronically recorded.
The facilit~ has a secure visitor pass system.
Every Control Center officer receives specialized training.
The Control Center is staffed around the clock.
Policy restricts staff access to the Control Center.

Detainees do not have access to the Control Center.
Communications are centralized in the Control Center.
Officers monitor all vehicular traffic entering and leaving
the facility.

~
~
~

D
D
D
D
D
D
D
D

D
D
D

The facility maintains a log of all incoming and departing
vehicles to sensitive areas of the facility. Each entry
contains:
• The driver's name
• Company represented
• Vehicle contents
• Delivery date and time
• Date and time out
• Vehicle license number
• Name of employee responsible for the vehicle
during the facili~ visit
Officers thoroughly search each vehicle entering and
leaving the facility.
The facility has a written policy and procedures to prevent
the introduction of contraband into the facility or any of its
components.
Tools being taken into the secure area of the facility are
inventoried before entering and prior to departure.
The SMU entrance has a sallyport.
Written procedures govern searches of detainee housing
units and personal areas.
Housing area searches occur at irregular times.

~
~
~
~

D
D

55
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01/04/05

Security inspections are
conducted each shift.

Supervisory or assigned
Officer

Inv. on a three part
reciept and checked off
when departing
SMU Inside the facility

•

SECURITY INSPECTIONS

Every search of the SMU and other housing units
documented.
Storage and supply rooms; walls, light and plumbing
fixtures, accesses, and drains, etc. undergo frequent,
irreQular 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.
• Documenting the results.
Visitation areas receive frequent, irreQular inspections.
~ Acceptable

Deficient

At-Risk

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

56
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01/04/05

Once a shift by ICE and
Security Supervisors

Repeat Finding

•

SPECIAL MANAGEMENT UNIT (SMU)
Administrative Segregation

Policy: The Special Management Unit required in every facility isolates certain detainees from the general
population. The Special Management Unit will consist of two sections. One, Administrative Segregation,
houses detainees isolated for their own protection; the other for detainees being disciplined for wrongdoing (see
the "Special Management Unit [Disciplinary Segregation]" standard).
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.
The OIC (or equivalent) regularly reviews the status of
detainees in administrative detention.
• A supervisory officer conducts a review within
72 hours of the detainee's placement in the
SMU (administrative).
A supervisory officer conducts another review after the
detainee has spent seven days in administrative
segregation.
• Every week thereafter for the first month.
• Every 30 days after the first month.
• Does each review include an interview with the
detainee.
• Is a written record made of the decision and
the justification.
The detainee is given a copy of the decision and
justification for each review.
• The detainee is given an opportunity to appeal
the reviewer's decision to someone else in the
facility.
The OIC (or equivalent) routinely notifies the Field
Office Director (or staff officer in charge of IGSAs) any
time a detainee's stay in administrative detention
exceeds 30 days.
• Upon notification that the detainee's
administrative segregation has exceeded 60
days, the FD forwards written notice to HQ
Field Operations Branch Chief for 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 has remained
in administrative segregation for seven consecutive
days.

[g]

57
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01104/05

Remarks

A written order must
accompany detainee
being placed in SMU

•

SPECIAL MANAGEMENT UNIT (SMU)
Administrative Segregation

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

r:gJ

Remarks

Clthing exchanged on a
daily basis

Daily

r:gJ

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

Health Services visits
daily.

•

SPECIAL MANAGEMENT UNIT (SMU)
Administrative Segregation

rg] Acceptable

Deficient

At-Risk

..
Remarks: (Record sIgnifIcant facts, observatIons, other sources used, etc.)
b6, b7c

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

Remarks
Weekly/and on needed
basis
Daily at 1900

Repeat Finding

•

SPECIAL MANAGEMENT UNIT
(Disciplinary Segregation)

•

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

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

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

Remarks

Seg order must
accompany detainee
when placed in seg

Disp. Seg. detainees not
allowed to have cash
All have same living
conditions unless threat
to themselves or others
documentation prepared
to support modifications

On a daily basis

•

SPECIAL MANAGEMENT UNIT
(Disciplinary Segregation)

•

Policy: Each facility will establish a Special Management Unit in which to isolate certain detainees from the
general population. The Special Management Unit will have two sections, one for detainees in Administrative
Segregation; the other for detainees being segregated for disciplinary reasons.
Components
Detainees in the SMU receive three nutritious
meals/days.
• Selected from the Food Service's menu of the
day.
• Food is not used as punishment.
Detainees are allowed to maintain a normal level of
personal hygiene, including the opportunity to shower
and shave at least three times/week.
The detainees receive, unless documented as a threat
to security:
• Barbering services.
• Recreation privileges.
• Other-than-Iegal reading material.
• Religious material.
• The same correspondence privileges as other
detainees.
• Personal legal material.
When phone access is limited by number or type of calls,
limits do not apply to the following:
• Calls about the detainee's immigration case or
other legal matters.
• Calls to consular/embassy officials.
• Calls during family emergencies (as determined
by the OIClWarden).
A health care professional visits every detainee in
disciplinary segregation every day, Monday through
Friday.
• The shift supervisor visit each segregated
detainee daily
• Weekends and holidays.
SMU detainees are allowed visitors, in accordance with
the "Visitation" standard.
SMU detainees receive legal visits, as provided in the
"Visitation" standard.
• Legal service providers notified of security
concerns arising before a visit.
Visits from clergy are allowed.
• The clergy member given the option of
visiting/not visiting the segregated detainee.
Violent/uncooperative
detainees 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-by-case basis.
• Staff document every incident of denied
access to the law library.

Remarks

Ability to shower and
shave on a daily basis

Health Services visits
daily.

D
Clergy visits segregation
weekly.

D
Must have Supervisor
authorization

61
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01/04/05

•

SPECIAL MANAGEMENT UNIT
(Disciplinary Segregation)

•

All detainee-related activities are documented, e.g.,
meals served, recreation activities, visitors, etc.
Is the SPC's, the Special Management Housing Unit
Record (1-8880r equivalent) is prepared as soon as the
detainee is placed in the SMU.
• All 1-888s filled out by the end of each shift
• The CDF/IGSA facility use Form
• 1-888 (or equivalent local form).
SMU staff records whether the detainee ate, showered,
exercised, took medication, etc.
• Details about the detainee logged, e.g., a
medical condition, suicidal/violent behavior,
etc.
• The health care official sign individual records
after each visit.
The
housing officer initials the record when all
•
detainee services are completed or at the end
of the shift.
• A new record is created weekly for each
detainee in the SMU.
• The SMU retains these records until the
detainee leaves the SMU.

[gJ

[g]

[gJ

[gJ Acceptable

Deficient

At-Risk

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

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

Remarks

Repeat Finding

•

TOOL CONTROL

Policy: It is the policy of all facilities that all employees shall be responsible for complying with the tool control
policy. The Maintenance Supervisor shall maintain a computer generated or typewritten Master Inventory list of
tools and equipment and the location in which tools are stored. These inventories shall be current, filed and
readily available for tool inventory and accountability during an audit.
Components
There is an individual who is responsible for developing
a tool control procedure and an inspection system to
insure accountability.
Department heads are responsible for implementing this
standard in their departments.
Tool inventories are required for:
• Maintenance Department
• Medial Department
• Food Service Department
• Electronics Shop
• Recreation Department
• Armory
The facility has a facility policy for the regular inventory
of all tools.
• The policy sets minimum time lines for physical
inventory and all necessary documentation.
ICE
facilities use AMIS bar code labels when
•
required.
The facility has a tool classification system. Tools are
classified according to:
• Restricted (dangerous/hazardous)

•

Remarks

Inventoried on a daily
basis

Non Restricted (non-hazardous).

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

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

Shadow board used each
tool numbered, master
list kept on file
Shadow board used

Tools not issued to
detainees.

Contractors tools
inventoried by security
officer assigned to tool
room upon admin/depart

•

TOOL CONTROL

Components

[gJ Acceptable

Deficient

At-Risk

Remarks
Repeat Finding

Remarks: (Tool room officer very professional and knowledable excelent system in place to identify lost or
broken tools I was able to pick up the master list and randomly select a tool and locate it on the shadow
board.
b6, b7c

64
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01104/05

•
:

•

TRANSPORTATION
(Land Transportation)

Policy The Immigration and Naturalization Service will take all necessary precautions to protect the lives,
safety, and welfare of our officers, the general public, and those in ICE custody during the transportation of
detainees. Standards have been established for professional transportation under the supervision of
experienced and trained Detention Enforcement Officers or authorized contract personnel.

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

Yes

Remarks

State of Ca. P.U.L.L.
system. Records kept by
bus instructor

65
G-324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 01/04/05

Identification is confirmed
by ICE staff.

•

TRANSPORTATION
(Land Transportation)

Policy The Immigration and Naturalization Service will take all necessary precautions to protect the lives,
safety, and welfare of our officers, the general public, and those in ICE custody during the transportation of .
detainees. Standards have been established for professional transportation under the supervision of
experienced and trained Detention Enforcement Officers or authorized contract personnel.

Standard NA: Check this box if all ICE Transportation are handled only by the ICE Field Office or :
Sub -Office in control of the detainee case
I
Components

Yes

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

Remarks

Meals provided if transp.
occurs during reg feeding
times

Each officer issued cell
phones

66
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01104/05

•

TRANSPORTATION
(Land Transportation)

D Standard NA: Check this box if all ICE Transportation are handled only by the ICE Field Office or
Sub-Office in control of the detainee case.
Components

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

rgJ Acceptable

Deficient

Yes

At-Risk

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

67
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01104/05

Remarks

Repeat Finding

•

USE OF FORCE

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

Yes

~
~

D
D

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

Remarks

All methods are
exhausted before using
force

During firearms
qualifications

•

USE OF FORCE

Policy: The U.S. Department of Homeland Security authorizes the use of force only as a last alternative after all
other reasonable efforts to resolve a situation have failed. Only that amount of force necessary to gain control
of the detainee, to protect and ensure the safety of detainees, staff and others, to prevent serious property
damage and to ensure institution security and good order may be used. Physical restraints necessary to gain
control of a detainee who appears to be dangerous may be employed when the detainee:
Components
Standard procedures associated with using four-point
restraints include:
• Soft restraints (e.g., vinyl)
• Dressing the detainee appropriately for the
temperature.
• A bed, mattress, and blanket/sheet.
• Checking the detainee at least every 15
minutes.
• Logging each check.
• Turning the bed-restrained detainee often
enough to prevent soreness or stiffness.
• Medical evaluation of the restrained
detainee twice per eight-hour shift.
When
qualified medical staff is not
•
immediately available, staff position the
detainee "face-up".
The shift supervisor monitors the detainee's
position/condition every two hours.
• He/she allow the detainee to use the rest
room at these times under safeguards.
All detainee checks are logged.
In immediate-use-of-force situations, staff contacts
medical staff once the detainee is under control.
When the OIC authorizes use of non-lethal weapons:
• Medical staff is consulted before staff use
pepper spray/non-lethal weapons.
• Medical staff review the detainee's medical
file before use of a non-lethal weapon is
authorized.
Special precautions are taken when restraining pregnant
detainees.
• Medical personnel are consulted
Protective gear is worn when restraining detainees with
open cuts or wounds.
Staff documents every use of force and/or non-routine
application of restraints.
It standard practice to review any use of force and the
non-routine application of restraints.
All officers receive training in self-defense,
confrontation-avoidance techniques and the use of force
to control detainees.
• Specialized training is given Officers are
certified in all devices they use.
The officers are thoroughly trained in the use of soft and
hard restraints.
In SPCs is the Use of Force form is used. In other
facilities (IGSAs / CDFs) this form or its equivalent is
used.

Yes

[g]

D
D

[g]

Remarks

Pepper spray not used in
facility close proximity to
neighbor hood.

Females not held in ECC

Documentation includes
housing cards w/pictures

During firearms training

[g]

69
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01/04/05

•

USE OF FORCE

•

I Yes I No I NA I

Components

I2J Acceptable

Deficient

At-Risk

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

--/ /

t: it

~'<

I / ,,-' I

70
G-324A Detention Inspection Fonn Worksheet for IGSAs - Rev: 01104/05

Remarks
Repeat Finding

•

STAFF DETAINEE COMMUNICATIONS

Policy' Procedures must be in place to allow for formal and informal contact between key facility staff and
ICE staff and ICE detainee and to permit detainees to make written requests to ICE staff and receive an
answer in an acceptable time frame.
Components
The ICE Field Office Director ensures that weekly
announced and unannounced visits occur at the IGSA.
Detention and Deportation Staff conduct scheduled
weekly visits with detainees held in the IGSA.
Scheduled visits are posted in ICE detainee areas.
Visiting staff observe and note current climate and
conditions of confinement at each IGSA.
ICE information request Forms are available at the
IGSA for use by ICE detainees.
The IGSA treats detainee correspondence to ICE staff
as Special Correspondence.
ICE staff respond to a detainee request from an IGSA
within 72 hours.
ICE detainees are notified ion writing upon admission to
the facility of their right to correspond with ICE staff
regarding their case or conditions of confinement.

I2$J Acceptable

D
D
D

Schedule times posted
on bulletin board.

D
D
D

At officers desk.

Deficient

At-Risk

Remarks: (Record Significant facts, observations, other sources used, etc.)
ICE s~aff needs to sign log book during every visit.
b6, b7c

....

ate

ct~/~ I It., /
.

71
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01/04/05

Remarks

Repeat Finding

•

DETAINEE TRANSFER STANDARD

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

[g]

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

Remarks

Signed by a supervisor

•

DETAINEE TRANSFER STANDARD

Policy: ICE will make all necessary notifications when a detainee is transferred. If a detainee is being
transferred via the Justice Prisoner Alien Transportation System (JPATS), ICE will adhere to JPATS
.
ICE'II
.
pro toco Is. In d eCI'd'Ing w heth er t0 t rans f er a detalnee,
WI ta ke .In t0 consl'd era f Ion w heth er th e d et alnee
is represented before the immigration court. In such cases, the Field Office Director will consider the
detainee's stage within the removal process, whether the detainee's attorney is located within reasonable
driving distance of the facility, and where the immigration court proceedings are taking place.
Components
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.
A Files are forwarded to the receiving office via
overnight mail no later than one business day following
the transfer.

[g] Acceptable

D Deficient

[g]

At-Risk

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

73
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01/04/05

Remarks

D Repeat Finding

•

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

3
4
5
6

Standard - Policy Development and Monitorina
Item
Written Policy and Procedures are in place to provide staff with the necessary
information to operate and maintain the facility on a daily basis and in accordance
with local, state, and federal law
Written policy and procedure are reviewed annually and updated accordingly
Standard - Reportina Requirement
The facility provides for a system of monitoring through internal audits and reviews
The internal administrative audit is separate from any external audits or reviews
Audit or inspection reports identify areas of concern, identify necessary corrective
action, and provide for a system follow-up
Audit and Inspection reports are maintained on file until at least the next review is
conducted
Standard - Direct SUDervision
To the extent Possible, physical plant design facilitates continuous personal contact
and interaction between staff and detainees in the housing unit and recreation /
leisure areas.
Written policies and procedures are in place that outline a comprehensive program
that promotes and encourages staff/detainee communications. A daily rotation
schedule should be established to ensure adequate staff coverage is provided
throughout the meal.
Standard - Cultural Diversity
Staff are provided appropriate annual cultural diversity or sensitivity training. Such
training is deSigned and implemented in a fashion that will further enhance
staff members' ability to communicate with detainees in an effective manner.

DOJ Core Standards - Rating
IGSA's Only

IZI Acceptable 0

Deficient

Repeat Deficiency

At-Risk

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

74
G-324A Detention Inspection Form Worksheet for IGSAs - Rev: 01/04/05

[g]

[g]
[g]
[g]

0
0
0

[g]

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