Office of Detention Oversight

U.S. Department of Homeland Security

Immigration and Customs Enforcement

Office of Professional Responsibility

Inspections and Detention Oversight Division

Washington, DC 20536-5501

Office of Detention Oversight

Compliance Inspection

Enforcement and Removal Operations

ERO Boston Field Office

Plymouth County Correctional Facility

Plymouth, Massachusetts

July 28¨C30, 2015

COMPLIANCE INSPECTION

for the

PLYMOUTH COUNTY CORRECTIONAL FACILITY

PLYMOUTH, MASSACHUSETTS

TABLE OF CONTENTS

EXECUTIVE SUMMARY

Overall Findings...................................................................................................................2

Findings by National Detention Standard (NDS) 2000 Major Categories ..........................3

INSPECTION PROCESS .............................................................................................................4

DETAINEE RELATIONS ............................................................................................................5

INSPECTION FINDINGS

DETAINEE SERVICES

Access to Legal Material .....................................................................................................7

Detainee Grievance Procedures ...........................................................................................7

Detainee Handbook ..............................................................................................................7

Food Service ........................................................................................................................8

Staff-Detainee Communication ...........................................................................................8

SECURITY AND CONTROL

Environmental Health and Safety ........................................................................................8

HEALTH SERVICES

Medical Care ........................................................................................................................9

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*

*

*

*

INSPECTION TEAM MEMBERS

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

Office of Detention Oversight

July 2015

OPR 201507556

Lead Inspections and Compliance Specialist

ODO

Inspections and Compliance Specialist

ODO

Inspections and Compliance Specialist

ODO

Inspections and Compliance Specialist

ODO

Inspections and Compliance Specialist

ODO

Contractor

Creative Corrections

Contractor

Creative Corrections

Contractor

Creative Corrections

Contractor

Creative Corrections

1

Plymouth County Correctional Facility

ERO Boston

EXECUTIVE SUMMARY

The Office of Detention Oversight (ODO) conducted a compliance inspection of the Plymouth

County Correctional Facility (PCCF) in Plymouth, Massachusetts, from July 28 to 30, 2015. 1

PCCF opened in 1994 and is owned by the Commonwealth of Massachusetts and operated by the

Plymouth County Sheriff¡¯s office. Enforcement and Removal Operations (ERO) began housing

detainees at PCCF in 1998 pursuant to an Intergovernmental Service Agreement (IGSA), under

the oversight of ERO¡¯s Field Office Director (FOD) in Boston, Massachusetts.

ERO staff members and a Detention

Capacity and Population Statistics

Quantity

Services Manager are assigned to the

1140

facility. A PCCF Superintendent is Total Bed Capacity

340

responsible for oversight of daily facility ICE Detainee Bed Capacity

1073

operations and is supported by (b)(7)e Average Daily Population

80

personnel.

Trinity Services Group Average ICE Detainee Population

provides food services and Correctional Average Length of Stay (Days)

88

Psychiatric Services (CPS) of Sherborn, Male Detainee Population (as of 07/28/2015)

51

Massachusetts and Plymouth County Female Detainee Population (as of 07/28/15)

N/A

employees provide medical services.

The facility is not contractually obligated to comply with the ICE Performance-Based National

Detention Standards (PBNDS) 2011, Sexual Abuse and Assault Prevention and Intervention

(SAAPI) standard but made efforts to comply. 2 The facility is accredited by the American

Correctional Association (ACA).

OVERALL FINDINGS

In November 2012, ODO conducted

an inspection of PCCF under the

National Detention Standards (NDS)

2000, reviewing the facility¡¯s

compliance with 21 standards and

finding the facility compliant with 16

standards. There were a total of 18

deficiencies in the remaining five

standards.

FY 2013

(NDS 2000)

FY2015

(NDS 2000)

Standards Reviewed

21

15

Deficient Standards

5

7

Overall Number of Deficiencies

18

10

Corrective Actions Initiated

0

4

0

N/A

1

N/A

Inspection Results Compared

Best Practice

Deficient Priority Components

In FY2015, ODO conducted an

inspection of PCCF under the NDS 2000 reviewing the facility¡¯s compliance with 15 standards

and finding the facility compliant with eight standards. ODO found ten deficiencies in the

remaining seven standards. Finally, ODO identified four opportunities where the facility

initiated corrective action and one best practice during the course of the inspection. 3

1

Male and detainees with low, medium and high security classification levels are detained at the facility for longer

than 72 hours.

2

The facility has a zero tolerance policy articulated in PCCF Policy 268, Sexual Abuse and Harassment of Inmates.

All facility staff, including volunteers and contractors receives training in sexual assault and abuse prevention and

intervention. The training curriculum specifically addresses the Prison Rape Elimination Act (PREA).

3

Corrective actions, where immediately implemented, best practices and ODO recommendations, as applicable,

have been identified in the Inspection Findings section and annotated with a ¡°C¡±, ¡°BP¡± or ¡°R¡±, respectively.

Office of Detention Oversight

July 2015

OPR 201507556

2

Plymouth County Correctional Facility

ERO Boston

FINDINGS BY NDS 2000 MAJOR CATEGORIES

NDS 2000 STANDARDS INSPECTED 4

DEFICIENCIES

Part 1 ¨C Detainee Services

Access to Legal Material

Admission and Release

Detainee Classification System

Detainee Grievance Procedures

Detainee Handbook

Food Service

Funds and Personal Property

Staff-Detainee Communication

Telephone Access

Sub-Total

1

0

0

3

1

1

0

1

0

7

Part 2 ¨C Security and Control

Environmental Health and Safety

Special Management Unit (Administrative)

Special Management Unit (Disciplinary)

Use of Force

Sub-Total

2

0

0

0

2

Part 3 ¨C Health Services

Medical Care

Suicide Prevention and Intervention

Sub-Total

1

0

1

Total Deficiencies

4

10

For greater detail on ODO¡¯s findings, see the Inspection Findings section of this report.

Office of Detention Oversight

July 2015

OPR 201507556

3

Plymouth County Correctional Facility

ERO Boston

INSPECTION PROCESS

Every fiscal year, the Office of Detention Oversight (ODO), a unit within U.S. Immigration and

Customs Enforcement¡¯s (ICE) Office of Professional Responsibility (OPR), conducts

compliance inspections at detention facilities in which detainees are accommodated for periods

in excess of 72 hours and with an average daily population greater than ten detainees, to

determine compliance with the applicable ICE National Detention Standards (NDS) 2000, or the

Performance-Based National Detention Standards (PBNDS) 2008 or 2011.

During the compliance inspection, ODO reviews each facility¡¯s compliance with those detention

standards that directly affect detainee health, safety, and/or well-being. 5 ODO then identifies as

a ¡°deficiency,¡± any violation of written policy specifically linked to ICE detention standards,

policies, or operational procedures. ODO will also highlight any deficiencies found involving

those standards that ICE has designated with either the PBNDS 2008 or 2011 to be ¡°priority

components.¡± 6 ICE considers those components to be of critical importance, given their impact

on facility security and/or the health and safety, legal rights, and quality of life of detainees in

ICE custody.

Immediately following an inspection, ODO hosts a closeout briefing in person with both facility

and ERO field office management to discuss their preliminary findings, which are summarized

and provided to ERO in a preliminary findings report. Thereafter, ODO provides ERO with a

final compliance inspection report to: (i) assist ERO in working with the facility to develop a

corrective action plan to resolve identified deficiencies; and (ii) provide senior ICE and ERO

leadership with an independent assessment of the overall state of ICE detention facilities. The

reports enable senior agency leadership to make decisions on the most appropriate actions for

individual detention facilities nationwide.

5

6

ODO reviews the facility¡¯s compliance with selected standards in their entirety.

Priority components have not been identified for the NDS.

Office of Detention Oversight

July 2015

OPR 201507556

4

Plymouth County Correctional Facility

ERO Boston

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