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ICE Detention Standards Compliance Audit - Pasadena City Jail, Pasadena, CA, ICE, 2004

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U. S. Immigration
and Customs
Enforcement

'.ill t\

MEMORANDUM FOR:

FROM:

')
L

Gloria Kee
Field Office DirectorffiCJ
Los Angeles Field ~,

1

.

SUBJECT:
The Annual Detention Review of the Pasadena Police Department City Jail conducted on
September 3, 2004, in Pasadena, California has been received. A final rating of Acceptable has
been assigned. The Field Office shall decide on the custody levels that are to be housed at this
facility since classification is not conducted by the IGSA facility.
The rating was based on the Reviewer-In-Charge (RIC) Summary Memorandum and supporting
documentation. The Field Office Director must remedy the deficiencies in the RIC Memorandum,
and initiate the following actions in accordance with the Detention Management Control Program
(DMCP):
1) The Field Office Director, Detention and Removal Operations. shall notify the facility within
five business days of receipt of this memorandum. Notification shall include copies of the
Form G-324B, Detention Facility Review Form. the G-324B Worksheet, RIC Summary
Memorandum. and a copy of this memorandum.
2) The Field Office Director is responsible for ensuring that the facility responds to all findings
and a Plan of Action (POA) is submitted to the Review Authority (RA) within 30 days.
3) The RA will advise the Field Office Director once the Plan of Action is approved.
4) Once a Plan of Action is approved, the Field Office Director shall schedule and follow-up on
the above noted deticiencies within 90 days.
The RIC is responsible for assisting the Intergovernmental Service Agreement (lGSA) facility to
respond to the Immigration and Customs Enforcement tindings \vhen assistance is requested.
Notification to the facility shall include information that this assistance is available.

Subject: Pasadena Police Department City Jail Annual Detention Review
Page 2

Should you or your staff have any questions regarding this matter, please contact
Deputy Assistant Director, Detention Management Division at (202) 305 b2 high

b6, b7c

O/lia II(Detent;1I1I {I/1l1 Removal Operatiuns

U.S. Department of Homeland Security
San Pedro Processing Center
200 1 South Seaside Avenue
San Pedro, Cal ifornia 90731

U. S. Immigration
and Customs
Enforcement

09/18/2004

MEMORANDUM FOR: VICTOR CERDA
DIRECTOR, DETENTION AND REMOVAL
FROM:

b6, b7c

Reviewer-in-Ch;ge
SUBJECT:

b6, b7c
b6, b7c

Review Summary Report, Pasadena City Jail

The Los Angeles Field Office of Detention and Removal performed a review of the Pasadena
City Jail, an IGSA facility. The review was conducted on September 3,2004. It was performed
b6, b7c
under the supervision of
, Reviewer-in-Charge. Team members consisted of officers
assigned from the Los Angeles Field Office.
The review measured compliance with ICE Detention Standards. No other assessments were
performed or requested at this time. Attached to this memorandum is a copy of the original Form G324a Detention Inspection Form. All worksheets and working papers are maintained in the
appropriate file system and are available for review by the Review Authority.

Type of Review:
This review was a routine scheduled assessment and was conducted for the sole purpose of
determining overall compliance with ICE Detention Standards. The team consisted of the Reviewerb6, b7c
in-charge and
, Deportation Officer, Los Angeles Field Office.

Review Summary:
The facility is accredited by the California Board of Corrections. The accreditation is current
and the facility is in good standing. This review summarizes those standards that were found not to
be in compliance. Each standard is identified and a summary of the relevant issues is provided. It
should be noted that one of the standards were repeat deficiencies. These particular standards met
the criteria for the California Board of Corrections, but did not meet the intent of the ICE standard.
There was a total of 22 compliant standards, 3 deficient standards, and 1 non-applicable standard.

-

Memorandum For: Victor Cerda
Subject: Review Summary Report, Pasadena City Jail
Page 2
The following is a summary of those standards found to be deficient:
Classification-Deficient

•

There is currently no mechanism in place to separate criminals from non-criminals.

Detainee Handbook-Repeat Deficiency'

•

There is no printed detainee handbook. A video was produced in both English and Spanish,
but it does not meet the intent of the standard.

Population Counts-Deficient

•

Fonnal counts are not conducted on each shift.

Overall, the facility was in compliance approximately 88% of the ICE Detention Standards.
All staff members encountered were enthusiastic and cooperative. The facility was clean and
detainees appeared to be relatively satisfied with the environment. The deficiencies that exist do not
hamper the mission of ICE. It is the recommendation of this Reviewer-in-Charge that the facility be
rated as ACCEPTABLE.

.....

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

-

- - Detention Facility Review Fonn

U.S. Department Of Homeland Security
U.S. Immigration and Customs Enforc ement
ICE Intergovernmental Service Agreement
used Under 72 Hours or Less
A. Current Ins ection
Type of Review
I2J Field Office D H Review
Date[s] of Review
09/0312004

Facilities Used Under 72 hours

I Estimated Man-days Per Year

I

7839
Accreditation Certificates
E.
Accredited By:
NCCHC:D JCAHO: D
ACA: D
Date:
Date:
Date:
F.
Problems / Complaints (Copies must be attached)
The Facility is under Court Order or Class Action Finding
D Class Action Order
D Court Order
The Facility has Significant Litigation Pending
D Major Litigation
D Life/Safety Issues
Checked Box above requires a detailed written memorandum.

PreviousIMost Recent Review
Date[s] of Last Review
0911112003
Previous Rating
I2J Acce table D Deficient D At-Risk

G. Facility History
Date Built
1991
Date Last Remodeled or Upgraded

B. Name and Location of
Name

•u"wvJ.t.:/~uper
b6, b7c

N/A
Date New Construction 1 Bedspace Added
N/A
Future Construction Planned
DYes I2J No Date:
Current Bedspace
Future Bedspace
104

I

b6, b7c

C. ICE Information
Name of Reviewer (Last Name, Title and Duty Station)
Cortes 1 CIEA / SPP
Last Name / Title of Team Members (Re viewers)
Arcinas 1 DO;
1
I
Controlling Field Office
Los An e1es
Nearest Field or Sub-Office
Los An eles

Contract Number
Contract or IGSA
WRO-J-095
1
Basic Rates per Man-Day
$75
Other Charges: (If None, Indicate N/A)

H. Total Facility Population
Total Intake for previous 12 months
5838
Total Mandays for Previous 12 months
7839
Facility Ca )acity
Rated
Adult Male
45
Adult Female
12

I.

Average Daily Population
ICE
Adult Male
19
Adult Female
1.5
StamD!!: Level
Security:
b2 high

Operational

32

Emer2ency
48

6

12

USMS

Other

Support:
Incorporated with Police
Department

Form G-324B (9/25/03)

Significant Incident Summary Worksheet
r ICE to complete its Review of your facility, the following information must be completed prior to the scheduled review dates.
Ie information on this form should contain data for the past twelve months in the boxes provided. The information on this form is
used in conjunction with the ICE Detention Standards in assessing your Detention Operations against the needs of the ICE and its
detained population. This form should be filled out by the facility prior to the start of any inspection.

Assault:
Offenders on
Offenders!

0

0

0

0

0

0

0

0

Assault:
Detainee on
Staff

0

0

0

0

0

0

0

0

0

0

0

o

o

o

o

o

o

o

o

o

o

o

o

o

o

o

o

o

o

o

o

# Times fourlFive Point
Restraints applied/used

')ffender I Detainee Medical
Referrals as a result of injuries

su tained.
Escapes

o

# Psychiatric Cases referred for
Outside Care

4

o

o

o

o

0

o

o

An y 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,;onsenting
Routine transportation of detaineeS/o ffenders is not considered "forced"
Any incident that involves four or more detainees/offenders, includes gang fights, organized nrultiple hunger strikes, work stoppages, hostage situations,
major fires, or other large scale incidents.

Form G-324B (11/6/03)

Admission and Release
Classification System
Detainee Handbook
Food Service
Funds and Personal Property
Detainee Grievance Procedures
Issuance and Exchange of Clothing, Bedding, and Towels
Practices

Detention Files
Disciplinary Policy
Emergency Plans
Environmental Health and Safety
Hold Rooms in Detention Facilities
Key and Lock Control
Population Counts
Security Inspections
Special Management Units (Administrative Segregation)
Special Management Units (Disciplinary Segregation)
Tool Control
Transportation (Land management)
Use of Force
Staff / Detainee Communication
Detainee Search
All findIngs (At-Risk., Repeat Defitiency and Deficient) require written comment describing the finding and what is nete sary
to meet compliance.

Form G-324B (1116/03)

RIC Review Assurance Statement

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

Signature
b6, b7c

b6, b7c

Title & Duty Location

Date

ChiefInuni ation Enforcement Officer

09/17/2004

[;eam Members
Print Name & Duty Location
b6, b7c

Print Name & Duty Location

LOS Field Office

Print Name & Duty Location

RIC Rating Recommendation:

Print Name & Duty Location

[8J Acceptable

D Deficient
OAt-Risk

RIC Comments:

Form G-324B (1116/03)

•

HEADQUARTERS EXECUTIVE REVIEW

~ew

Authority

The signature below constitutes review of this report and acceptance by the Review Authority. OIC/CEO will have 30 days from
receipt of this report to respond to all findings and recommendations.
HQDRO EXECUTlvr: RFVII-W:

(l'lca~e

Print Name)

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

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

D Superior
DGood
[8] Acceptable
D Deficient
D At-Risk
Comments:
The Review Authority (RA) concurs with the recommended rating of "Acceptable" made by the
Reviewer-In-Charge based on the evidence in the (RIC) Summary Memorandum and in the G-324B Worksheets.

Form G-324A (Rev. 811101) No Prior Version May Be Used After 12/31/0 1

Department of HomelAecurity

-

Immigration and Customs Enforcement
Office of Detention and Removal

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

Field Office Detention Review W orksheet
~

o

Local Jail- IGSA
State Facilitiy - IGSA

Name
Pasadena Ci Jail
Address (Street and Name)
207 N. Garfield A venue
City, State and Zip Code
Pasadena, CA 91101
County
LosAn eeles
Name and Title of Chief Executive Officer (Warden/a/CIS uperintendent)
b6, b7c
Chief
Name and title of Reviewer-In-Charge
b6, b7c
Chief Immi ration Enforcement Officer
Date[s] of Review
0910312004

S eeial Assessment

o Other

G·324B Detention Review Worksheet for IGSAs (Unde r72 Hours)

ADMISSlON.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
classification process; a body search; and a search of personal belongings, which will be inventol'i$d,
documented, and safeguarded as necessary.

Components
In-processing includes orientation information.
Medical screenings are performed by a medical staff 2!:
persons who have received specialized training for the
purpose of conducting an initial health screening.
All new arrivals are searched in accordance with the
"Detainee Search" standard. An officer of the same
sex as the detainee conducts the search and the
search is conducted in an area that affords as much
privacy as possible.
The "Contraband" standard governs all personal property
searches. IGSAs use or have a similar contraband
standard. Staff prepare 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. IGSA
facilities forward all 1-387 claims to ICE.
Detainees are issued appropriate and sufficient clothing
and bedding for the climatic conditions.
All releases are coordinated with the ICE office of
jurisdiction.
ICE Staff enter all information on detainees admitted,
released, or transferred into the Deportable Alien Control
System (DACS).

Yes

No

NA

~

0

0

~

0

0

~

0

0

~

0

0

~

0

0

~

0

0

~

0

0

~

0

0

Remarks

Standard Rating:

D Deficient

[8J Acceptable

D
ClASSI

D Repeat Finding

At-Risk

:nON SYSTEM
K

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

Components

Yes

The facility has a system for separating criminal and
non-criminallCE detainees. Violent offenders are
se arated from non-violent offenders.
Housin assi nmoots are based on threat level-level.

o

No

NA

Remarks

o

Standard Rating:

D Acceptable

t8I Deficient

D

At-Risk

D Repeat Finding

Page 2 of 17
G-324B Detention Review Worksheet for IGSAs (Under 72 Hours)
. .

ReVIewer SIgnature:

b6, b7c

Date:

ie -1- Hi

DETAJNEE HANDBOOK
Policy: Every OIC will develop a site-speclfic 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 organiza~
etc. Every detainee will receive a copy of this handbook upon admission to the facUlty.
Components
Vea No
NA
Remarks
The detainee handbook is written in English and
No written detainee
translated into Spanish or into the next most-prevalent
0 handbook
0
181
Language(s).
The detainee handbook states in clear language basic
f8I
0
0
detainee responsibilities.
The handbook identifies:
• Initial issue of clothing and bedding and
personal hygiene items.
• when a medical examination will be conducted.
• the telephone policy, debit card procedures,
direct and frees calls; Locations of telephones;
Policy when telephone demand is high; Policy
f8I
0
0
and procedures for emergency phone calls,
and the Detainee Message System.
• facility search procedures and contraband
policy.
• facility visiting hours and schedule and visiting
rules and regulations
The handbook describes the detainee disciplinary
policy and procedures:
Including:
• Prohibited acts and severity scale sanctions.
• Time limits in the Disciplinary Process.
0
f8I
0
• Summary of Disciplinary Process.
• The detainee handbook describes the sick call
procedures for general population and
segregation.
• The handbook specifies the rights and
responsibilities of all detainees.
Standard Rating:

D Acceptable

f8I Deficient

D

o Repeat Finding

At-Risk

FOOD SERVICE

Policy: Every facility wilt provide detainees in Its care with nutritious and appetizing meals, prepared in
accordance with the highest sanitary standarcls.
Remarks
NA
Components
Vea No
The food service program is supervised by trained
0
0
f8I
staff.
Knife cabinets close with an approved locking device
and the on-duty cook foreman maintains control of the
0
0
f8I
ke that locks the device.

Page 3 of 17
G-324B Detention Review Worksheet for IGSAs (Under 72 Hours)
Reviewer Signature:

-

_.

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__

Date:

II "I - ~ y

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

FOODSERVJCE
Policy: Every facility will provldadetalnees in its care with nutritious and appetizing meals. prepared in
accordance with the highest sanitary standards.
Components
No
NA
Remarks
Ves
All knives not in a secure cutting room are physically
secured to the workstation and staff directly supervise
0
181
0
detainees using knives at these workstations. Staff
monitor the condition of knives and dining utensils
Detainees are served at least three meals daily. No
more than 14 hours elapse between the last meal
0
181
0
served and the first meal of the followill9 day.
A registered dietitian conducts a complete nutritional
181
0
0
analysis of every master-cycle menu planned.
The food service program addresses medical diets.
Satellite-feeding programs follow guidelines for proper
sanitation.
Hot and cold foods are maintained at the prescribed,
·safe· temperature(s) after two hours. (140 degrees for
hot - 40 ~rees for cold)
All meals provided in nutritionally adequate portions.
Food is not used to punish or reward detainees based
upon behavior.
Standard operating procedures include weekly
inspections of all food service areas, including dining
and food-preparation areas and eQuipment.
Equipment is inspected daily.
Procedures include inspecting all incoming food
shipments for damage, contamination, and pest
infestation.
Storage areas are locked.
Standard Rating:

181 Acceptable

o Deficient

181
181

0
0

0
0

181

0

0

181
181

0
0

0
0

181

0

0

181

0

0

181

0

0

~

[J

[J

OAt-Risk

o Repeat Deficiency

FUNDS AND PERSONAL PROPERTY
Policy: All facilities will implement procedures to control and safeguard detainees' personal property.
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: Check this box If all ICE detainee Funds, Valuables and Property are handled only by
the ICE Field Office or Sub-Offlce In control of the detainee case.
Remarks
Components
No
NA
Ves
Detainee funds and valuables are properly separated
and stored away. Detainee funds and valuables are
0
~
0
accessible to designated supervisor(s) only.

Page 4 of 17
G-324B Detention Review Worksheet for IGSAs (Under 72 Hours)
Reviewer Signature:

b6, b7c

Date:

If - I -

t,

FUNDS AND PERSONAL PROPERTY
.'

Policy: All f8CUitIes.willimplement procedures to control and safeguard detainees' personal property.
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: Check this box If all ICE detainee Funds, Valuables and Property are handled only by

.the ICE Field, OffIce or Sub-Offlce In conlr91 of the detainee case.
Detainees' large valuables are secured in a location
accessible to designated supervisor(s) or processing
181
0
0
staff only.
Staff forwards an arriving detainee's medicine to the
181
0
0
medical staff.
Staff searches arriving detainees and their personal
0
0
181
property for contraband.
There is a written policy for retuming forgotten property
0
0
181
to detainees and staff follows procedures.
Property discrepancies are immediately reported to the
181
0
0
CDEO or Chief of Security.
CDF/IGSA facility procedures for handling detainee
0
0
181
property claims are similar with the ICE standard.
Standard Rating:

[8J Acceptable

o Deficient

o Repeat Finding

OAt-Risk

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
Ves
No
NA
Remarks

o o
o o
[8J Acceptable

o Deficient

o Repeat Finding

OAt-Risk

REUGIOUS 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.tha facility and budgetary considerations.

Vea

No

NA

Page 5 of 17
G-324B Detention Review Worksheet for IGSAs (Under 72 Hours)
Reviewer Signature:

b6, b7c

;

Date:

Ie' '-/ " r: 't

REUGIOUS PRACTICES

'

".t

'-,I'T

,,;

Policy: FacUlties 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.
Each detainee is allowed religious items in his/her
immediate possession.
1 0 1 0
Standard Rating:

1

I~

[gI Acceptable

o Deficient

o Repeat Finding

OAt-Risk

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

Components
Detainees allowed access to telephones during
established facility waking hours.
Upon admittance, detainees are made aware of the
facility's telephone access POlicv.
Detainees are afforded a reasonable degree of privacy
for leQal phone calls.
Emergency phone call messages are immediately given
to detainees.
Detainees are allowed to return emergency phone calls
as soon as possible.
Detainees are allowed phone calls to consular/embassy
officials.
Detainees in disciplinary segregation allowed phone
calls for family emergencies. Detainees in
administrative segregation and protective custody
afforded the same telephoning privileges as those in
aeneral 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.
Standard Rating:

[gI Acceptable

o Deficient

Yes

No

M.A .•.

~

0

0

~

0

0

~

0

0

~

0

0

~

0

0

~

0

0

~

0

0

~

0

0

OAt-Risk

Remarks

o Repeat Finding

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

1Yes I No 1 NA 1

Components

Remarks

Page 6 of 17
G-324B Detention Review Worksheet for IGSAs (Under 72 Hours)
Reviewer Signature:

b6, b7c

Date:

/(;

j -

1,;

q

VISITATION

" : ""c ,

Policy: ICE shall permit detainees to visit with family, friends, JegaI representatives, special interest groups and

the news media.
There is a written visitation schedule and hours for
general visitation. Hours for both General and Legal
Visitation are noted.
The visitation schedule and rules are available to the
public.
A general visitation log is maintained.
Visitors are searched and identified according to
standard requirements.
Standard Rating:

181 Acceptable

~~Deficient

181

0

0

181
181
181

0
0
0

0
0
0

Visitation is available
upon request.

b6, b7c

o Repeat Finding

OAt-Risk

ACCESS TO MEDICAL CARE
Policy: Every facility will establish and maintain an accreditedfaccreditation-worthy health program for the
generalwelJ.being of ICE detainees.

Components

Yes

No

NA

The Facility operates a health care facility in compliance
with State and Local laws and guidelines.
The facility's in-processing procedures of arriving
detainees include medical and mental health screening.
All detainees have access to and receive medical care.

181

0

0

181

0

0

0

D

181

[81

[J

[81

[]

[81

[J

181

0

0

181

0

0

181

D

D

D

D

181

D

D

181

D

D

181

Pharmaceuticals are stored in a secure area.
Medical screening includes a Tuberculosis (TB) test.
Detainees in the Special Management Unit have access
to health care services.
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.
Detention staff is trained to respond to health-related
emergencies within a 4-minute response time.
If staff is used to distribute medication, a health care
provider properly trains these officers.
The medical unit keeps written records of medication
that is distributed.
Detainees are required to sign a refusal to consent form
when medical treatment is refused.

Remarks

Detainees with medical
conditions are not
accepted.

Standard Rating:

181 Acceptable

o Deficient

OAt-Risk

o Repeat Finding

Page 7 of 17
G-324B Detention Review Worksheet for IGSAs (Under 72 Hours)
Reviewer Signature:

-

b6, b7c

-,- -

Date:

/1., i -

C l.j

....

SUICIDE PREVENTION AND INTERVENTION

:

.:'

Polley: 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. Suicickrprevention 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.

Vee

No

NA

181

0

0

181

0

0

Remarks

•
•

Standard Rating:

o Deficient

181 Acceptable

o Repeat Finding

OAt-Risk

CONTRABAND
Policy: All detention facilities will ensure the proper handling and disposal of all contraband. Documentation of
contraband destruction Is required.
Components

V..

The facility follows a written procedure for handling
illegal contraband. Staff inventories, holds, and reports
it when necessary to the proper authority for
action! ossible seizure.
Upon admittance, detainees reqeive notice of items they
can and cannot possess.

No

NA

Remarks

o o
o

o

Standard Rating:

181 Acceptable

o Deficient

o Repeat Finding

OAt-Risk

DISClPLINARV POLlCV
Polley: All facilities housing ICE detainees are authorizecUo impose discipline on detainees whose behavior is
not in com liance with facil rules and
ulations.
Components
V..
No
NA
Remarks
The facility has a written disciplinary system using
Problem detainees are
pciked up by ICE and
progressive levels of reviews and appeals.
transported to another
facili .
The facility rules state that disciplinary action shall not
be ca ricious or retallato .

o

o

o

o

Page 8 of 17
G-324B Detention Review Worksheet for IGSAs (Under 72 Hours)
Reviewer Signature:

b6, b7c

Date:

DISCIPLINARY POUCY
Policy: AU facilities housing ICE detainees are authorized to impose discipline on.detalnees whose behavior Is
not in compliance with facility rules and regulations.
Yes
No
NA
Remarks
Components
Written rules prohibit staff from imposing or permitting
the following sanctions:
• corporal punishment
• deviations from normal food service
0
0
181
• 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
0
0
181
detainees verbally and in writino.
The following conspicuously posted in Spanish and
English or other dominate languages used in the facility:
• Rights and Responsibilities
0
0
0
• Prohibited Acts
• Disciplinary Severity Scale
• Sanctions
• If so, where posted
When minor rule violations or prohibited acts occur,
181
0
0
informal resolutions are encouraged.
Standard Rating:
~ Acceptable

o Deficient

o Repeat Finding

OAt-Risk

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.
Yes
No
Remarks
Components
NA
No Detainee or detainee groups exercise control or authority
0
0
181
over other detainees.
Detainees are protected from:
• Personal abuse I Corporal punishment
• Personal injury
0
0
181
• Disease
• Property damage
• Harassment from other detainees

Page 9 of 17
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EMERGENCY (CONTINGENCy) PLANS
Policy All facilities hoJdingJCE detainees will respond to emergencies with a predetermined standardized plan to
minimize the harming of human life and the destruction of property. IUs recommended that SPes and COFs enter
into agreement, via Memorandum of Understanding (MOU), with federal, local and state agencies to assist in
times of erneraencv.
Components
Yes
No
NA
Remarks
The facility has written emergency plans that cover:
• Work/Food Strike
• Disturbances
• Escapes
D
D
181
• Bomb Threats
Adverse
Weather
•
• Facility Evacuation
• Internal Hosta~es
Standard Rating:

181 Acceptable

o Deficient

o Repeat Finding

OAt-Risk

ENVIRONMENTAL HEALTH AND SAFETY
POlicy: Every facility wm 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
Yes
No
Remarks
Components
NA
The facility has a system for storing, issuing, and
181
D
D
maintaining inventories of hazardous materials.
No toxic substances are
Constant inventories are maintained for all flammable,
toxic, and caustic substances used/stored in each
D
181 stored at facility..
D
section of the facility.
The manufacturer's Material Safety Data Sheet (MSDS)
181 D
D
file is up-Jo-date for every hazardous substance used.
All personnel using flammable, toxic, and/or caustic
substances follow the prescribed procedures. They:
• Wear personal protective
181
D
D
• Equipment.
• Report hazards and spills to the
• designated official.
The MSDS are readily accessible to staff and detainees
D
181 D
in the work areas.
Hazardous materials are always issued under proper
supervision.
D
181
D
• quantities are limited.
• Staff always supervises detainees using these
substances.

Page 10 of 17
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ENVIRONMENTAL HEALTH AND SAFETY

Policy: Every facUity 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 s~ds (e.g., National Fire Protection Association [NFPA]); identification of
incompatible materials, and safe-handling procedures
NA
Components
Yea
No
Remarks
No methyl alcohol
Staff directly supervises and accounts for products with
methyl alcohol. Staff receive a list of products
containing diluted methyl alcohol, e.g., shoe dye. All
0
0
181
such products clearly labeled as such. "Accountability"
includes issuing such products to detainees in the
smallest workable quantities.
[ ]
[]
The facility conducts the fire and safety inspections.
Done by city
IZI
The facility has an approved fire prevention, control, and
181
0
0
evacuation plan.
The plan requires:
Yearly inspections
• Monthly fire inspections.
• Fire protection equipment strategically located
throughout the faCility.
181 0
0
• 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.
Written procedures regulate the handling and disposal
0
0
181 No sharps permitted
of used needles and other sharp objects.
Standard cleaning practices include:
• Using specified equipment; cleansers;
disinfectants and detergents.
0
0
181
• An established schedule of cleaning and followup inspections.
A licensedlCertifiedlTrained pest-control professional
inspects for rodents, insects, and vermin.
0
181
0
• At least monthly.
• The pest-control program includes preventive
spraying for indigenous insects.
Standard Rating:

o Acceptable

181 Deficient

OAt-Risk

o Repeat Finding

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.
Remarks
Components
Yes No
NA
The hold room is situated in a location within the secure
0
181
0
perimeter.
The hold rooms well ventilated, well lighted and all
181
0
0
activating switches located outside the room.

Page 11 of 17
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HOLD ROOMS IN DETENTION FACIUTIES

.

"

Polley: Hold rooms will be used only for temporary detentlonfor detainees awaiting removal, transfer, EOIR
hearlngs,medicaJtreatment,mtra-facUlty movement, or other processing into or out of thef~illty.
NA .
··.Remarks
V..
Components
No
The hold rooms contain sufficient seating for the
number of detainees held.
The walls of the hold rooms escape proof.
• The hold room ceilings are escape and tamper
resistant.
Individuals are not held in hold rooms for more than 12
hours.
Male and females are segregated from each other at
all times.
Detainees under the age of 18 are not held with adult
detainees.
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.).
Standard Rating:

181 Acceptable

D Deficient

D

181

0

0

181

0

0

181

0

0

181

0

0

0

0

181

181

0

0

181

0

0

181

0

0

No juveniles at facility

D Repeat Finding

At-Risk

KEV AND LOCK CONTROL
(SECURITY, ACCOUNTABILITY AND MAINTENANCE)
Polley It is the policy of the ICE Service to maintain an efficient system for the use, accountability and
maintenance of aU keys and locks.
V..
NA
Componenta
No
Remarks
Facility policies and procedures address the issue of
0
0
181
compromised keys and locks.
[8J
[]
Padlocks and/or chains are not used on cell doors.
LJ
Occupant load under 50
The entrance/exit door locks to detainee living quarters, or
people.
areas with an occupant load of 50 or more people,
conform to
0
181
• Occupational Safety and Environmental Health 0
Manual, Chapter 3
• National Fire Protection ASSOCiation Life Safety
Code 101.
Emergency keys are available for all areas of the facility.
0
181
0
No keys-electronic
The facilities use a key accountability system.
0
0
181 interlock
Individual gun lockers are provided.
• They are located in an area that permits constant
officer observation.
0
0
181
• In an area that does not allow detainee or public
access.

Page 12 of 17
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KEY AND LOCK CONTROL
(SECURITY, ACCOUNTABIUTY 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

V..

No

o

o

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.
•
Detainees are not permitted to handle keys
assi ned to staff.

NA

Remarks

Standard Rating:

o Deficient

181 Acceptable

o Repeat Finding

OAt-Risk

POPULATION COUNTS - RaUng
Policy: All detention facilities shall ensure around-the-clock accountability for aU detainees. This requires that
they conduct at Jeast one formal count of the detainee population per shift, with additional fonnal and informal
counts conducted as necessary.
Component.
Staff conducts a formal count at least once each shift.
Activities cease or are strictly controlled while a formal
count is beil}g conducted.
Formal counts in all units take place simultaneously.
Officers do not allow detainee participation in the count.
Officers positively identify each detainee before
countinQ him/her as present.
Written procedures cover informal and emergency
counts.
The control officer (or other deSignated position)
maintains an out -count record of all detainees
temporarily leaving the facility.

V..
[]

N0A'

NA

~

[]

0

I8l

0

[]

~
~

[]

[]

0

I8l

0

0

I8l

0

0

181

0

Remarks

[]

Standard Rating:

o Acceptable

I8J Deficient

o Repeat Finding

OAt-Risk
SECURITY INSPECTIONS

The facility has a comprehensive security inspection
rocedures I ro ram.
Every officer is required to conduct a security check of
his/her assi ned area. Results are documented.
The front-entrance officer checks the 10 of everyone
entering or exiting the faCility.

I8l

0

0

181

0

0

181

0

0

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.

I - 'f)

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

SECURITY INSPECTIONS

:,

'

PolICy: Post assignments in the facHity's high-risk areas, where spacial security procedures.must be followed.
will be restricted to experienced personnel with a thorough grounding in facility q:>erations.
'Remarks
Components
Vea
No
NA
The Control Center is staffed around the clock. Every
181
0
0
Control Center officer receives trainino.
Policy restricts staff access to the Control Center.
~
11 11
Detainees do not have access to the Control Center.
IZI 11 11
Officers monitor all vehicular traffic entering and leaving
181
0
0
the faCility.
The facility maintains a log of all incoming and departing
181
0
0
vehicles to sensitive areas of the facility.
Officers thoroughly search each vehicle entering and
0
0
181
leavino the facility.
Every search of the SMU and other housing units
181
0
0
documented.
Standard Rating:

I:8J Acceptable

o Deficient

OAt-Risk

o 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 Segregatlonr standard).
Components
No
NA
Vea
Remarks
The Administrative Segregation unit provides
non-punitive protection from the general population and
individuals undergoing diSCiplinary segregation.
0
0
181
• 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.
0
181
0
• A copy of the order given to the detainee within
24 hours.
Administratively segregated detainees enjoy the same
general privileges as detainees in the general
0
181
0
population.
The SMU is well ventilated.
• Adequately lighted.
181
0
0
• Appropriately heated.
Maintained
in
a
sanitary
condition.
•
All cells are equipped with beds.
[J
[J
IZI
The number of detainees in any cell does not exceed
0
181
0
the occupancy limit.
Detainees receive three nutritious meals per day.
IZI
1J
LJ

Page 14 of 17
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------~~~~~~~--------

,-

SPECIAL MANAGEMENT UNJT(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 wrongdoil'lg (see
the .oospeclal Management Unit {Disciplinary Segregationr standard).
Yea
No '. NA
Remarks
Components
Each detainee maintains a normal, level of personal
0
0
~
hygiene in the SMU.
A health care professional visits every detainee at least
~
0
0
three times a week.
The SMU maintains a permanent log.
~
0
0
• Detainee-related activity, e.g., meals served,
recreation, visitors etc.
At a minimum staff record whether the detainee ate,
showered, exercised and took any medication during
~
0
0
every shift and records all pertinent information, e.g., a
medical condition, suicidal/assaultive behavior, etc.
Standard Rating:

t8I Acceptable

o Deficient

o Repeat Findings

OAt-Risk

SPECIAL MANAGEMENT UNIT
(Disciplinary Segregation)
~

"

Policy: Each facility will establish a Special Management Unit in which to Isolate certain detalneesfrom'the
general population. The Special Management Unit will have two sectiOns, one tor detainees in A(imir)istratlve
Segregation; the other for detainees being segregated tor disciplinary reasons.
No
Yea
Remarks
NA
Components
Officers placing detainees in disciplinary segregation
0
0
~
follow written procedures.
A completed Disciplinary Segregation Order
181
0
0
accompanies the detainee into the SMU.
Standard procedures include reviewing the cases of
individual detainees housed in disciplinary detention at
0
~
0
set intervals.
The conditions of confinement in the SMU are
proportional to the amount of control necessary to
0
0
181
protect detainees and staff.
All cells are equipped with beds.
[]
[J
~
When a detainee is segregated without clothing,
mattress, blanket, or pillow, a justification is made and
~
0
0
the decision is reviewed each shift. Items are returned
as soon as it is safe.
Detainees in the SMU receive three nutritious
mealslda~.

Detainees are allowed to maintain a normal level of
personal hygiene, including the opportunity to shower
and shave at least three times/week.

0

0

181

0

0

~

Page 15 of 17
G-324B Detention Review Worksheet for IGSAs (Under 72 Hours)
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/1> )

~b L(

SPECIAL MANAGEMENT UNIT
(Disciplinary Segregation)

"

-

,

,

'~,'

.

--

Policy: Each facility wiN establish a Special Management Unit in which to isolate certain detainees from the
general P9PulatiQn. The Special Management Unit will have two sections, one for detainees In Administrative
Segregation; the otheffor detainees being segregated for disciplinary reasons.
Components

Yes

No

NA

A health care professional visits every detainee in
disciplinary segregation every day, M - F.
All detainee-related activities are documented, e.g.,
meals served, recreation activities, visitors, etc.
At a minimum staff record whether the detainee ate,
showered, exercised and took any medication during
every shift and records all pertinent information, e.g., a
medical condition, suicidaVassaultive behavior, etc.

0

0

181

0

0

181

0

0

181

Remarks

Standard Rating:

o Deficient

181 Acceptable

o Repeat Finding

OAt-Risk

TOOL CONTROL
Polley: 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
The facility has a tool classification system. Tools are
classified according to:
•
Restricted (dangerous/hazardous)
•

Yes

No

o

o

0

o

NA

Non Restricted (non-hazardous).

Each facility has procedures for the issuance of tools to
staff and detainees.

Remarks
No tools are stored in
facility. All work is
completed by city
maintenance workers.

Standard Rating:

181 Acceptable

o Deficient

OAt-Risk

o Repe8t Finding

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

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 ~ount of for~ 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 ofa detainee who appears to be dangerous may be employed when the detainee:
Components
Vea
No
NA
Remarks
There is a use of force policy outling immediate and
0
181
0
calculated use of force, and confrontation avoidance.
Staff members are trained in the performance of the
181
0
0
Use-of-Force Team TechniQue.
[]
All use-of-force incidents are documented and reviewed.
[J
~
Staff:
• Does not use force as punishment.
• Attempts to gain the detainee's voluntary
0
t8l
0
cooperation before resorting to force
• Uses only as much force as necessary to
control the detainee.
No medicinal restraints
Mecication may only be used for restraint purposes
when authorized by the Medical Authority as medically
0
0
181 used
necessary.
In immediate-use-of-force situations, staff contacts
0
181
0 Paramedics are notified.
medical staff once the detainee is under control.
Special precautions are taken when restraining pregnant
0
181
0
detainees and medical personnel are consulted
The officers are thoroughly trained in the use of soft and
0
0
t8l
hard restraints.
For incidients involving calculated use of force, a
0
t8l
0
videotape is made and retained for review.
Standard Rating:
[81 Acceptable D Deficient D Repeat Deficiency D At-Risk

Page 17 of 17
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