Maintain Highest Level of Security Practices

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DEFINITION

Sound security policies provide standardized procedures for a variety of security systems that, when properly utilized, are designed to minimize vulnerabilities in the workplace. Maintaining the highest level of these practices in a Correctional Industries (CI) setting helps to create an environment that safeguards the life, health, and personal safety of staff, offenders and the public while at the same time providing the necessary education, work, and rehabilitative opportunities that enable an offender to be productive while incarcerated and prepare for successful reentry to the community.

Security practices in a CI encompass policies and procedures that are in alignment with the institution’s policies and procedures. A collaborative environment with open communication between CI and the institution is integral to implementing security and personal safety procedures. CIs with the strongest security practices create a culture that understands and prioritizes the importance of security and programming to run an effective, safe, secure and productive correctional industry program within an institution.

RATIONALE/BENEFIT

The CI workplace differs from the typical workplace in that the operation exists in a correctional environment and the workforce is made up of civilian staff and offenders. It is imperative that the overall security operations have open channels of communication and a continuity between CI and the institution, creating a well-balanced ‘security and personal safety mindset’ for staff and offenders. In a CI environment, security and personal safety remain a top priority, while ensuring production requirements and quality standards are met.

It is essential that CI’s have a robust safety program to protect civilian staff and offenders from workplace accidents and injuries.

PRACTICES

Please note that the following best practices may need to be modified by each CI based on departmental regulations, institutional policies and contingent upon other factors including, but not limited, physical plant design, level of security, location of plant, level of programs, cost of implementation and state/local statutes. The following best practices have been shown by research and/or experience to produce optimal results for CI programs, however, it is recognized that not all-practices cited can be implemented throughout all CI shops.

1. Follow Sound Security Control Policies – Policies and procedures are necessary to ensure strict security practices. In addition to standard operating procedures, CI safety and security policies must follow the institution’s policies and departmental procedures. Shop-specific policies should be developed in cooperation with the institutional security staff, as applicable. If a policy or procedure is restricted, staff must ensure that it is not distributed to the public or offenders. Unrestricted policies should be distributed to staff and offenders to ensure that they are understood and followed. Policies should be reviewed annually.

a. Tool Control Policies – should ensure proper classification, control and accountability for all tools. Tools are typically classified in groups that identify their potential to cause major bodily harm, effect an escape or facilitate a security risk. These classifications utilize a scoring system, such as A, B or C or I, II or III. These classifications also identify which custody level, offender, or program can use which tools with or without direct supervision.

A tool control officer or other staff should be assigned to the program with responsibility for:

  • Maintaining a master inventory and sub inventories of individual tool boards, boxes, cabinets, vehicle tool kits, etc.
  • Receipt of new tools and disposal of worn-out/broken/excess tools, ensuring there are safeguards to prevent delivery of tools throughout the institution.

Tools maintained within the shop should be limited to those used on a weekly basis. Seldom-used tools should be inventoried and kept in a secure location.

At a minimum, supervising staff should inventory tools at the beginning and end of all shifts. Security staff should conduct a full audit and comprehensive review of the tool room not less than every six months.

All contractors and temporary staff working inside the shop should receive written instructions outlining their responsibilities regarding tool control. In addition, their tools should be inventoried at the beginning and end of each work day, or as required by institutional policy.

b. Key Control Policies – should provide control and accountability for all keys and locking systems and establish key control and inventory procedures that restrict distribution. Policy should also include procedures for loss, breakage and failure to return keys. Keys to all areas within the CI should be readily available by custody in the event of an emergency.

A key control officer or other staff should be assigned to the program with responsibility for:

  • Maintaining a key inventory
  • Issuing keys to staff depending on their area of responsibility
  • Controlling and maintaining locking devices

Daily operational keys should be issued from a secure control system (staffed or mechanical) and be required to be turned in daily. Security keys should never leave the institution and all keys should be accounted for at the beginning and end of each shift. Security keys should never be handled by offenders.

NIC recommends staff not carry personal keys in their possession and that a procedure for the storage of personal staff keys be developed. CIs should participate in an institutional policy review regarding the storage of personal keys to see if these recommendations can be implemented.

c. Chemical Control Policies – should ensure that all hazardous and/or caustic materials are kept in a separate storage area and locked at all times. A perpetual inventory should be maintained and materials should be issued only by designated staff.

Chemicals should only be issued to offenders in the quantity required to accomplish the immediate task. Unused chemicals should not be allowed in work areas at the end of the workday and should be inventoried and secured before offenders leave the work area. Label all hazardous material containers/dispensers to identify contents. Safety Data Sheets (SDS) should be maintained and available for all hazardous materials.

d. Contraband Control – CI’s should be trained in and follow institutional policies on identification, search and disposal of contraband. Policies regarding allowable items for offenders to have in the shop should be understood by CI staff. Custody and CI staff should be diligent in performing constant checks for contraband, particularly in industries with high rates of availability to receive and distribute contraband. CI staff should be accountable for approved personal items brought on site and maintain control of those items.

  • All contractors working inside the CI shop should receive written instructions outlining their responsibilities regarding contraband control.
  • Offender workers should not have access to staff uniforms or personal clothing at any time. Officer uniforms should be issued from a location outside of the CI shop. Where uniforms are manufactured in a CI shop, offenders should never have access to a completed uniform. CI supervisors and staff should wear clothing that distinguishes them from offender workers.

2. Define Policy for Offender Assignment and Behavior - Most offenders who work in CI have access to tools, manufacturing equipment and/or warehousing/trucking equipment. Proper offender assignment to CI is an important security factor. Work with the institution to define policies for identifying and screening offenders for CI programs through classification, institutional behavior, group compliance, educational completion, etc.

a. Written Procedures – Institutional assignment procedures should define who is eligible to work in CI based on institutional policy and set minimum standards. Standards ensure offenders have maintained acceptable behavior over a set period of time, as well as a commitment to bettering themselves.

b. Screening – Institutional risk reviews should be conducted prior to program assignment. The screening process should include criminal history, victimology, history of violence, infraction behavior, medical/mental health concerns, documented behavior observations and gang affiliation.

c. Offender Behavior Agreement/Contract - Offenders working or training in CI should sign an Offender Behavior Agreement. This provides offenders with clear expectations and standards of behavior necessary to retain their job.

d. Allowable items - CI shops should clearly define allowable items for offenders. The list should be reviewed and updated annually by the institution. This sets expectations for a professional and uncluttered work environment, promotes effective searches and helps reduce contraband.

3. Promote Staff and Offender Personal Safety - Continuing education, training, coaching and modeling ensure staff are exposed to the knowledge and tools necessary to provide the highest level of personal safety and security in the CI setting. The American Correctional Association (ACA) recommends 120 hours of pre-service training and an additional 80 hours of job specific training. Safety and security training should be ongoing and frequent.

a. Safety programs are developed to ensure safe and healthful working conditions for all staff and offenders. The program should provide detailed information on the following:

  • Protecting staff and offenders from job-related injuries and health impairment
  • Preventing accidents and fires
  • Planning for emergencies and emergency medical procedures
  • Identifying and controlling physical, chemical, and biological hazards in the workplace
  • Communicating potential hazards to staff and offenders
  • Assuring adequate housekeeping and sanitation

b. In addition to the policies, procedures and practices identified above, CI staff should be trained in:

  • Offender manipulation, staff complacency and overfamiliarity with offenders.
  • Situational Awareness

Ø Remaining alert and aware of the environment around them

Ø Identifying what constitutes irregular behavior and warning signs of offender disturbances

  • Effective communication with offenders such as utilizing motivational interviewing techniques.

c. Staff Equipment – Provide staff with necessary safety equipment to supervise offenders. This will be institution or state specific and may include radios, panic buttons, pepper spray, and others.

  • CI Staff should have radios programmed with a personal safety feature and tied into the institution’s personal alarm notification system.
  • Plants should have a public address system for mass communications, as applicable.
  • CI staff should be issued a personal alarm.

d. Offender Training – Ensure that offenders receive basic safety training prior to being allowed to work on the shop floor. Training should include hazardous workplace identification and reporting and mandatory training modules (i.e. personal protective equipment (PPE), fire extinguisher, blood borne pathogens, etc.). Safety training on specific equipment should occur prior to operation. Safety awareness training should be conducted frequently.

e. Personal Protective Equipment (PPE) – Staff and offenders should be provided the necessary safety equipment for all assignments.

f. Safety Inspections - Staff should conduct comprehensive, documented safety inspections. An inspector (non-shop staff) should perform a safety audit. Violations posing an imminent threat should be corrected immediately. A plan should be developed to mitigate other documented deficiencies within 30 days.

g. Staff Accountability – Maintain compliance with institutional staff accountability procedures.

h. Implement Sound Occupational Health and Safety Programs- It is mandatory that CI’s have a robust safety program to protect staff and offenders. CI’s are responsible for providing a safe and healthful workplace and must comply with all applicable safety standards.

All staff are responsible to conduct their work in a safe manner, make recommendations to improve safety and health, notify supervisors of any accident involving injury, illness or near-miss. Participate in safety awareness training weekly and formal safety refresher training semi-annually.

i. Safe Staffing Models - The process for determining adequate staffing for a CI shop should consider physical plant design, level of security, location of plant, level of programs and activities, equipment/tools used, and state and local standards and statutes to recommend a specific officer and CI staff-to-offender ratio.

4. Set Standards for Offender Counts and Controlled Movement

a. Counts - Offenders should be accounted for at all times. Per institutional policies and procedures, official and unofficial counts are required at set intervals during the day. In addition, situational (unofficial) counts are taken as circumstances dictate. Report and document unaccounted-for offenders immediately.

b. CI programs may institute additional counts based on staff to offender ratio, custody level and the nature of the work or training. Many CIs have outside work crews. The general location of all outside work crews should be known by the supervisor and institution’s control center at all times. Official and unofficial count times may still apply. Staff supervising outside work crews should have a current picture ID of each offender, assigned to their supervision, with them whenever they are out of the institution.

c. Defined Areas/Controlled Movement – Develop procedures to define all access areas for offenders, as well as prohibited access. Post clear signage limiting access to restricted areas. For larger shops, clearly state defined areas in procedures and offender job descriptions. Document and report offenders outside of assigned areas.

d. Staff Escorts – Develop procedures for offenders leaving the CI shop location outside of normal movement. Ensure that offenders are formally turned over to the appropriate staff prior to leaving the shop or when they arrive at the unit/pod, depending on institutional policy, and that the offender location is updated upon arrival and departure.

5. Develop Offender Entry/Exit Procedures

a. Check-in/out Procedures – Offenders arriving at or leaving a work location should be checked in/out with a photo ID, work roster verification or electronic scanning.

b. Searches – CI staff should be trained in the proper method to perform routine searches of offenders whenever entering or departing their work area in compliance with Institutional policy and Prison Rape Elimination Act (PREA) guidelines. Written policy should clearly state the frequency of these searches and define gender-specific search procedures.

c. Metal Detectors – Metal detectors should be used in shops where feasible.

6. Develop Loading Dock Procedures – Delivery trucks pose a high risk for escape and receipt of contraband. Staff should check all incoming trucks and materials for contraband and order accuracy. Custody and/or CI staff should thoroughly search all outbound trucks. Use of technology such as heartbeat monitors is recommended for high traffic shops.

a. Supervision - Offenders should be under direct supervision at all times during the loading / unloading process.

b. Material Search - Staff should conduct a search of all materials upon receipt. The use of an x-ray machine or other technology is recommended for material receipt, where feasible, with the potential for hidden contraband.

c. Truck Driver Entry/Exit Procedures - All delivery trucks should be subject to search upon entering and exiting the premises or facilities.

7. Conduct Security Checks and Implement Vulnerability Assessments

a. Conduct Routine Security Checks – In addition to CI policies and procedures regarding key, tool and movement control, routine security checks of all areas by CI staff are essential to providing security within the CI shop.

  • CI supervisors should perform routine checks to ensure that all policies are being enforced. Custody staff should also observe the operation and routinely conduct security checks.
  • CI staff should regularly conduct thorough reviews/searches of all areas of the shop.
  • Develop written procedures for outside work crews. Custody staff and CI management should randomly spot check outside work crews, documenting each contact.
  • Conduct K-9 searches, if available, at each CI shop periodically.

b. Implement Security/Vulnerability Assessments- Security audits are tools that identify and isolate possible security risks. CI programs should be included in the DOC’s security and performance audits. In addition, a thorough security review of the CI should be conducted in conjunction with the DOC at least annually to review adherence to policies, procedures, standards and best practices. It is imperative that all security deficiencies are corrected timely and refresher training on policy is provided if needed. An audit should identify any weaknesses, deficiencies and areas of vulnerability.

  • Train selected CI staff as security auditors and include them on DOC security auditing team if possible. Utilize them to conduct internal security audits of shops.
  • Create a security inspection instrument for shops in conjunction with the institution.
  • Conduct unannounced security inspections routinely.

8. Practice Emergency Drills - In conjunction with custody staff, CI’s should actively participate in all drills associated with emergency procedures. Practicing drills is important for staff and offender safety in an emergency. Drills are a means of pointing out deficiencies in the plan, testing staff knowledge and equipment, practicing response, and building confidence with staff and offenders. All staff should be trained, prepared and know their responsibilities in the event of a crisis. Types of drills include but may not be limited to: Fire, Man-down, Fight/Riot and Natural Disasters.

9. Review Physical and Working Design of Plant - The layout, design, location within the institution, age and level of maintenance of CI shops have a direct impact on the level of security.

a. Cameras, Alarms and Mirrors - Where possible, cameras and door alarms should be installed throughout all CI shops and monitored. Doors leading to the outside of the plant should have an audible door alarm that notifies CI and institutional staff when a door is opened without staff approval. Evaluate camera systems and coverage often to ensure blind spot coverage. Convex mirrors should be used to provide additional coverage for corners and hallways.

b. Blind Spots/Line of Sight

  • Equipment Placement - Care should be taken in the initial layout of the shop to ensure clear line of sight whenever possible. Line of sight should be taken into consideration when designing/ordering new equipment.
  • Material Storage - It is easy to create a blind spot with moveable boxes. Boxes/pallets should be stacked so they do not interfere with the line of sight whenever possible. Install cameras and mirrors where shelving interferes with line of sight.
  • Clutter - CI’s should limit the supply of material, equipment and tools in the shop to the minimum amount needed. Store excess material, equipment and tools in a secure location outside of the shop. Keep shop clean and aisles clear at all times.

c. Offender Boundaries

  • Signage should be used to clearly delineate boundary areas for offenders. Do not allow offenders to freely walk the shop or enter the tool room or office areas without a staff member present.
  • Offender Stations – Do not allow offenders to lock desks or cabinets. Offenders should not be allowed to create “comfort stations” with personal possessions, photos, magazines and/or food.
  • Telephones – If offenders have access to telephones as part of their regular job duties, where appropriate, lock the telephones with a passcode or require the offender to go through a main switch board. Telephone printouts should be closely monitored for unauthorized use by offender workers. Such telephones are preferably equipped with monitoring and recording capability.
  • Computers – Develop written policy/procedures that allow offender use of computers and computer technology as part of their work assignment. Policy should define offender internet access, if applicable. Keep all computers or equipment with external access (fax, copier and modem) in secured areas. An audit of computers should be conducted regularly by knowledgeable staff to prevent abuse or unauthorized use of systems.

10. Evaluate Waste Removal Procedures - A perpetual inventory of all hazardous materials in each shop should be maintained at the point of storage.

a. Scrap Metal - For CI programs located inside facilities and depending on custody level, all waste product that can be made into a weapon must be collected, secured and disposed of in secure waste bins at the end of every shift. Make sure all scrap metal is accounted for and secured prior to offenders leaving metal plants. Secure waste bins may only be emptied in areas not accessible by offenders. Offender involvement in this activity should be supervised.

b. Sharps Containers - Strategically place locked sharps containers in areas for disposal. Inventory and dispose of sharps frequently. Offender involvement in this activity should be supervised.

c. Waste Clutter - Work areas should remain clean and clear of all waste and debris.

d. Trash Storage and Removal - Waste bins should be located throughout the work areas and emptied daily. Dispose of any waste that could be made into a weapon in a secure waste bin.

e. Hazardous Waste – Disposal of hazardous waste should be consistent with OSHA codes. All hazardous materials issued to offenders or drawn by staff from a point of supply and put in containers should be labeled to identify contents.

11. Develop and Maintain Institution/CI Partnership - Developing a cooperative partnership with the institution centered on respect, collaboration and proactive communication is imperative to ensuring security of the offenders and safety of all staff. The CI and the institutional staff must work together and respect each other to accomplish all objectives.

a. Institutional Leadership - The CI shop manager(s) and the institution’s head and custody managers are the leaders in setting the tone of cooperation and respect. The CI shop manager should attend appropriate security and safety related institutional meetings led by the warden/superintendent or designated staff.

b. Building Relationships through Communication- Communication is the key to building a strong relationship between the institution and CI staff.

c. Training - CI staff should attend orientation and required DOC training with department staff.

12. Obtain compliance verification in conjunction with the DOC or through external sources.

a. PREA Audits

b. Security Audits

c. Safety and Environmental Audits

d. ACA Audits

MEASUREMENTS

Employee Turnover

Loss Time Worked

Employee Accidents - OSHA 300 Log

Assaults on Staff

Security Audit Incidents

Safety Audit Incidents

RESOURCES

ACA Standards - http://www.aca.org/ACA_Prod_IMIS/ACA_Member/Standards___Accreditation/Standards/ACA_Member/Standards_and_Accreditation/StandardsInfo_Home.aspx?hkey=7c1b31e5-95cf-4bde-b400-8b5bb32a2bad

OSHA Safety Program Samples

https://www.osha.gov/dcsp/compliance_assistance/sampleprograms.html

State of NC Employee Safety Handbook

https://files.nc.gov/ncoshr/documents/files/Safety_Health_Handbook.pdf

Situational Awareness in a Correctional Environment

https://www.correctionsone.com/cert/articles/2140196-Situational-awareness-in-the-correctional-environment/

“Nobody Gets Hurt” - Situational Awareness PowerPoint

http://www.nobodygetshurt.com/files/2914/1772/9040/243_102114KBGNwsltrSituationalAwarenessac.pdf

TOOLS

Sample Behavior Contract: http://members.nationalcia.org/resources/E-Learning/SDD%20Worker%20Behavior%20Agreement%202018.pdf

NIC Staffing Analysis Clearing House – Includes NIC’s 9-Step Staffing Analysis flow chart - http://correction.org/staffing-analysis-clearinghouse/

Prison Staffing Analysis: A Training Manual with Staffing Considerations for Special Populations - https://nicic.gov/prison-staffing-analysis-training-manual-staffing-considerations-special-populations

ACA Accreditation Policy and Procedure Manual - http://www.aca.org/ACA_Prod_IMIS/docs/standards%20and%20accreditation/ALM-1-3_15_17-Final.pdf

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