ICE/DRO DETENTION STANDARD

KEY AND LOCK CONTROL

# PURPOSE AND SCOPE. This Detention Standard maintains facility safety and security by requiring that keys and locks be properly controlled and maintained.

It applies to the following types of facilities housing ICE/DRO
detainees:

-   Service Processing Centers (SPCs);

-   Contract Detention Facilities (CDFs); and

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-   State or local government facilities used by DRO through
    Intergovernmental Service Agreements (IGSAs) to hold detainees for
    more than 72 hours.

***Procedures in italics are specifically required for SPCs and
CDFs***.  IGSAs must conform to these procedures or adopt, adapt or
establish alternatives, provided they meet or exceed the intent
represented by these procedures.

Some terms used in this document may be defined in the separate
**Definitions** Standard.

# EXPECTED OUTCOMES. The expected outcomes of this Detention Standard are:

1.  All staff will be trained in the proper care and handling of keys
    and locks.

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1.  Keys will be controlled and accounted for.

2.  Locks and locking devices will be continually inspected, maintained,
    and inventoried.

3.  Employees will store their firearms in secure gun lockers before
    entering the facility.

# DIRECTIVES AFFECTED. This Detention Standard replaces Key and Lock Control dated 9/20/2000.

# REFERENCES

> American Correctional Association 4th Edition Standards for Adult
> Local Detention Facilities: 4-ALDF-2D-01, 7B-10.

# EXPECTED PRACTICES

## Proper Care and Handling of Keys and Locks

All staff shall be trained and held responsible for adhering to proper
procedures for the care and handling of keys, including electronic key
pads where they are used. Initial training shall be accomplished before
staff is issued keys, and key control shall be among the topics covered
in subsequent annual training. Ordinarily, such training shall be done
by the Security Officer (Key Control Officer), described below.

1.  *An employee who leaves the facility with a key ring shall return it
    immediately upon realizing his or her mistake. Such act constitutes
    unauthorized possession of U.S. property as well as a breach of
    procedures.*

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4.  *An employee, who loses, misplaces, or otherwise cannot account for
    a key or key ring shall immediately alert the shift supervisor and
    promptly submit a written report.*

5.  *Under no circumstances shall staff allow a detainee to handle
    facility keys.*

6.  *Key rings, including those for gun lockers, shall be securely
    fastened to a belt with a metal clip or other approved device.
    Fastening keys to a holsters or belt loop is prohibited.*

7.  *Employees shall not refer to key numbers or other means of key
    identification within earshot of a detainee.*

8.  *Employees shall neither throw nor slide keys to one another.*

9.  *Force shall not be used to operate locks.*

10. *If a key breaks inside a lock, the employee shall maintain visual
    oversight of the lock until the problem is repaired. If the key
    breaks inside a padlock, the padlock itself shall be removed and
    taken to the Control Center. In every instance, the employee shall
    submit a memorandum on the incident to the facility administrator.*

11. It is good practice for every facility to use key covers for large
    security keys to prevent detainees or other unauthorized persons
    from observing and duplicating them.

## Security Officer (Key-Control Officer)

> Each facility administrator shall establish the position of Security
> Officer, or at a minimum, assign a staff member the collateral
> security officer duties, as described herein.

### Major Duties and Responsibilities of the Security Officer

The Security Officer shall have a written position description that
includes duties, responsibilities, and chain of command.

> *In SPCs and CDFs, the Security Officer:*

-   *Reports directly to the chief of security;*

-   *Conducts physical security surveys of all buildings and provides
    the chief of security written recommendations regarding deficiencies
    and needed corrective actions;*

-   *Plans and implements adequate preventive maintenance/replacement of
    locks and other security-devices;*

-   *Identifies technical problems or malfunctions in
    electronic/automated and manually operated security systems and
    immediately repairs them or coordinates prompt repairs with the
    facility maintenance department;*

-   *Overhauls, adjusts, and replaces worn parts on locking devices and
    systems;*

-   *Maintains, adjusts, and services machines used in the Lock Shop;*

-   *Is trained in operation of gas/oxygen-cutting tools and end-saw
    equipment in case of an emergency;*

-   *Conducts routine tests on emergency-exit doors;*

-   *Checks the keys to all emergency exits every 30 days and all other
    keys needed in emergencies quarterly, and documents the results;
    and*

-   *Reviews all major work orders and in-house designs, plans, and
    specifications with the facility maintenance department for
    compliance with security requirements.*

> *The facility maintenance supervisor (or equivalent) shall consult
> with the chief of security (or equivalent) and Security Officer before
> proceeding with new construction and renovation projects involving
> door hardware.*

### Required Locksmith Training

> All security officers shall successfully complete an approved
> locksmith training program.
>
> *In SPCs and CDFs, the Security Officer shall complete formal
> locksmith training.*
>
> *This should be supplemented with training in Occupational Safety and
> Health Administration standards and the National Fire Prevention
> Association's life safety codes. Manufacturer's instructions, user
> manuals, product orientations, and demonstrations can also provide
> useful guidance and should be stored in a secure location.*

### Administrative Responsibilities

> The Security Officer is responsible for all administrative duties,
> including recordkeeping, concerning keys, locks, and related security
> equipment.
>
> *In SPCs and CDFs, the Security Officer:*

-   *Maintains a recordkeeping system that cross-references keys in the
    Control Center and Lock Shop, alphabetically and numerically, to
    facilitate quick identification of the key or key ring needed for a
    particular lock;*

-   *Maintains accurate inventories of padlocks in use, master keys for
    cabinets, key blanks, and all keys currently in use;*

-   *Maintains for the historical record a collection of reference
    material on locking devices and systems, including devices and
    systems previously used in the facility.*

### Supervision and Training

> The Security Officer shall train and direct employees in key control,
> including electronic key pads where they are used.
>
> *In SPCs and CDFs, the Security Officer is responsible for training an
> Assistant Security Officer in all duties related to the position. The
> Security Officer must be proficient in all phases of security and be
> able to demonstrate proper equipment use to other employees.*

## Lock Shop Operation

### Inventories

> The Security Officer shall maintain inventories of all keys, locks and
> locking devices in the Lock Shop.
>
> *In SPCs and CDFs, Lock Shop inventories shall include, at a minimum:*

-   *A secure master-key cabinet containing at least one pattern key
    (never issued), and one or more spare keys. The cabinet shall be
    kept locked; except when in immediate use. The contents shall be
    itemized on an inventory form.*

-   *All key blanks, identified by model number and manufacturer\'s
    name, inventoried in a bound ledger or electronic database.*

-   *All unassigned padlocks.*

-   *An inventory of assigned padlocks, with locations identified
    alphabetically or numerically.*

### Compromised Keys and Locks

> The facility administrator or chief of security shall establish
> procedures for handling compromised keys and locks.
>
> *In SPCs and CDFs, compromised keys shall be cut into pieces until
> irretrievably destroyed. The facility shall document the type of key
> or lock, the number of keys or locks compromised, and the date, time,
> and method of destruction.*

### Safe Combinations

> The Security Officer shall implement procedures for protecting the
> integrity of all safe combinations.
>
> *In SPCs and CDFs, the combination for each safe shall be changed at
> least every 12 months and any time a staff member with access to a
> combination is assigned to another post. The combination to a safe
> shall be sealed in an envelope bearing across the flap the date and
> signature of the person who deposited and sealed the combination
> inside the envelope. Any person(s) authorized to open the envelope
> shall be listed, by title, on the front of the envelope. Envelopes
> containing safe combinations shall be stored in the Lock Shop.*

### Keying, Authorized, and Non-Authorized Locks

-   Either deadbolts or deadlocks shall be used in detainee-accessible
    areas.

-   Locks not authorized for use in detainee-accessible areas include,
    but are not limited to: snap-, key-in-knob, thumb-turn, push-button,
    rim-latch, barrel or slide bolt, and removable-core-type locks
    (including padlocks). Any such locks in current use shall be phased
    out and replaced with mortise lock sets and standard cylinders.

-   Grand master-keying systems are not authorized.

-   A master-keying system may be used only in housing units where
    detainees have individual room keys. The number of doors shall be
    kept to a minimum and the unit officer\'s key must override all
    functions of such locks.

-   After removing the facility number and key cuts, the Security
    Officer shall cut up and dispose of worn or discarded keys and
    locks.

-   Entrance/exit door locks of housing units, work areas, chapels,
    gyms, and other areas with room capacity of 50 or more people shall
    meet the standards specified in the National Fire Protection
    Association Life Safety Code (#101). Specifically, the doors shall
    be equipped with prison‑type locking devices modified to function
    when pressure is applied from inside the room. Panic-hardware is an
    acceptable alternative to the prison-type-locking device.

-   Individual doors to areas with room capacity of 50 or more people
    shall have no more than one lock each. Padlocks shall not be used on
    exit doors or intermediate doors along the exit route.

-   Padlocks and/or chains may not be used on cell doors.

> *In SPCs and CDFs:*
>
> *a. Padlocks and hasps may be used only where specified below:*
>
> *1. Fence-gates in areas without ceilings;*
>
> *2. Freezer-door interiors whose lock-release systems include
> panic-release device(s);*
>
> *3. Vehicle roll-up door walk-through exit(s).*

b.  *Entrances and exits from the secured perimeter shall be controlled
    by sally ports, with all doors and gates interlocking electronically
    (Only one door can unlock at a time, canceling the electrical
    control of other doors until the unlocked door is returned to its
    secure position).*

> *c. Under no circumstances may prison-type security keys and/or blanks
> (active, non-active, or discarded) be used or distributed for
> presentation purposes.*

### Preventive Maintenance

> The Security Officer shall implement a preventive maintenance program.
>
> *In SPCs and CDFs, the Security Officer shall perform the following
> preventive maintenance services, among others:*
>
> *a. Adjust and service all cellblock-locking mechanisms in the Special
> Management Unit and in housing units with secure rooms, at least once
> per year.*
>
> *b. Adjust and service vehicle-gates for changing (hot/cold) weather
> conditions twice a year, in the spring and early fall.*

c.  *Adjust and service front-entrance and other gate operations at
    least once a year.*

> *d. Lubricate all other locks quarterly, per manufacturers'
> instructions.*

a.  *Perform maintenance checks on locks and locking systems, taking
    corrective action as necessary.*

> *f. At least once every five years: steam-clean vehicle-gates; clean
> locking mechanisms of front-entrance gates, other gates, and cellblock
> locking mechanisms using steam or other means.*
>
> *The facility maintenance supervisor is responsible for door-hardware
> installation and maintenance (closures, hinges, pulls, kick plates,
> etc.), and for providing certain support services (welding,
> electrical-work) to the Security Officer, as needed.*

### Preventive Maintenance Documentation

> The Security Officer shall maintain all preventive maintenance
> records.
>
> *In SPCs and CDFs, the Security Officer's preventive maintenance files
> shall include:*
>
> *1. Date,*
>
> *2. Location of lock or locking mechanism,*
>
> *3. Type of maintenance,*
>
> *4. Rationale for changing key combination(s), and*
>
> *5. Signature of service provider.*

## Key Cabinet

### Location

> An operational keyboard large enough to accommodate all facility key
> rings, including keys in use, shall be located in a secure area.
>
> *In SPCs and CDFs, this operational keyboard shall be located in the
> Control Center. An electronic key control box may be placed outside
> the Control Center if it is a secure unit.*

### Basic Construction

> *In SPCs and CDFs, the key cabinet shall be constructed so that keys
> are visible only when being issued. Keys may never be seen by
> detainees or visitors.*
>
> *Small, closet-type space in the Control Center may be used instead of
> a cabinet, as long as:*

-   *Access limitations are the same as for a key cabinet,*

-   *All other key/lock standards are met, and*

-   *The space is used solely for key control.*

> *In the key cabinet:*

-   *Keys in vertical rows shall be arranged in alphabetical order, and*

-   *Keys in horizontal rows shall be arranged in numerical order.*

-   *The label identifying the letter or number of the key ring that
    belongs on a particular hook shall be visible even when the key ring
    is on the hook.*

-   *Any hook without an assigned key ring shall be tagged with a metal
    chit that indicates \"hook not in use.\"*

### Key Rings

> The Security Officer shall implement procedures for identifying every
> key ring and every key on each key ring, and for preventing keys from
> being removed from key rings, once issued.
>
> *In SPCs and CDFs, all key rings shall be heavy-gauge wire that has
> been welded or brazed to prevent removal of keys from the ring.*
>
> *Two metal tags of unequal size shall be attached to each key ring:*

-   *The larger tag shall identify the key ring with a number/letter
    corresponding to the hook number/letter.*

-   *The smaller tag shall identify the number of keys on the key ring.*

### Emergency Keys

> Emergency keys shall be on hand for every area to or from which entry
> or exit might be necessary in an emergency.
>
> *In SPCs and CDFs:*
>
> *a. Emergency keys may be kept in a separate key cabinet or in a
> readily identified area of the regular-issue key cabinet. A separate
> key cabinet located in the Control Center is recommended for the
> emergency keys.*

b.  *The emergency key cabinet shall contain a hook for each key ring.
    If an emergency key ring is kept outside the main emergency key
    cabinet (for example, in a tower), a metal tag providing the key
    ring\'s location shall hang on the hook intended for that key ring
    in the main emergency key cabinet.*

c.  *The emergency keys shall be cut precisely to manufacturer's
    specifications.*

d.  *Emergency keys shall not be rotated in and out of the Lock Shop.*

## Issue of Key Rings

### Chit System

> Facilities shall use a chit system or other standard system for the
> issuance and accountability of key rings. A key chit is a tag (usually
> metal) that identifies the person who has drawn a set of keys.
>
> *In SPCs and CDFs, the chit shall be labeled with the officer's first
> initial and last name. All key rings shall be issued as needed (at the
> beginning of a shift, etc.) with the exchange of a chit for a key and
> the chit placed on the hook from which the key was removed.*
>
> *An employee who reports to work without chits must obtain temporary
> chits from the Control Officer, which he or she can exchange for keys
> according to standard procedure.*

-   *The Control Officer shall maintain accountability for the issued
    chits.*

-   *At the end of the shift, the employee shall personally return the
    temporary chits to the Control Officer.*

> *At shift rotation, to obtain keys from an officer on post, the relief
> officer must first exchange his or her key chit at the Control Center
> for the key chit of the employee being relieved. The relief officer
> shall take his or her key chit to the employee being relieved and
> exchange the key chit for the appropriate ring of keys. The officer
> shall immediately count the keys on his or her ring, immediately
> reporting any discrepancies to the shift supervisor. If the relief
> officer needs to gain access to any location(s) while heading from the
> control enter to his or her post, the Control Officer may issue
> him/her a second set of keys. In this case, the officer shall return
> the extra set of keys to the Control Officer at the end of the relief
> shift.*

### Restricted Keys

> The facility administrator shall establish rules and procedures for
> authorizing use of restricted keys.
>
> *In SPCs and CDFs, the Control Officer must have authorization from
> the shift supervisor to issue a restricted key.*

#### Pharmacy

> Pharmacy keys shall be strictly controlled.
>
> Ordinarily, such controls include:

-   Maintaining pharmacy keys in a Restricted Keys cabinet in the
    Control Room and issuing them only to authorized pharmacy staff.

-   Maintaining a second set in the lock shop.

> In the event of an emergency that necessitates entry into the pharmacy
> by other than authorized pharmacy staff, the highest-ranking
> supervisor currently on shift may authorize the withdrawal, document
> the reasons, and sign the authorization.
>
> Such documentation is ordinarily done on a Restricted Key form. A copy
> shall be sent to the Pharmacist, who shall maintain a file of such
> emergency authorizations.

#### ICE and EOIR Offices

> Keys to ICE and EOIR (Executive Office for Immigration Review) office
> and courtroom areas shall similarly be restricted and controlled. If a
> key is authorized for emergency withdrawal, a copy of the Restricted
> Key form is to be provided to ICE.

### 24-Hour Issue Keys

> No key or key ring may be issued on a 24-hour basis without the
> facility administrator\'s written authorization.
>
> *In SPCs and CDFs, a key chit identifying the borrower of the key ring
> shall be placed on the appropriate hook in the key cabinet, along with
> a metal tag marked \"24-hour issue.\"*
>
> *Individual authorizing record forms shall be used to record the
> following information about each set of 24-hour-issue keys: the key
> ring identifiers (number and title), the number of keys on the ring,
> the individual key numbers and the door each key unlocks. Each record
> must bear the signatures of the authorizing facility administrator,
> chief of security, and the employee to whom the keys are issued.*

### Security Keys

> *Key rings used but not issued on a 24-hour basis because of the
> attached security keys shall be kept in a dedicated, glass-front,
> lockable box in the Control Center. Identical boxes may be kept and
> used in different departments, provided staff is authorized to receive
> 24-hour keys. The key to every such box shall be issued on a 24-hour
> basis.*
>
> *The staff member removing keys from the box shall place his or her
> chit on the hook in place of the key ring, returning the keys and
> reclaiming the chit at the end of the shift. The individual to whom
> the keys were issued shall personally return the keys to the box,
> without exception.*
>
> *Security keys may not be taken off facility property (except for bus,
> van and other authorized-vehicle keys). As a rule, security keys shall
> not be issued on a 24-hour basis.*

### Key Accountability

> The facility administrator shall establish written policy and
> implementing procedures to ensure key accountability.
>
> *In SPCs and CDFs, the Control Officer shall conduct a key ring audit
> upon reporting for duty, accounting for each key ring in the Control
> Center logbook and shall immediately report discrepancies in the
> record to the shift supervisor.*
>
> *The Control Officer shall also identify broken or bent keys. All keys
> (regular-issue and emergency) shall be checked and counted daily.*
>
> *To ensure accountability, keys shall be issued only on the assigned
> key rings.*

### Request for Key Change

> *Key-change requests shall be submitted, in writing, to the facility
> administrator. Upon facility administrator approval, only the Security
> Officer may add or remove a key from a ring.*

### Split Key Ring

> *The splitting of key rings into separate rings is not authorized.*

## Gun-Locker Keys

> Officers shall store all their weapons in individual lockers before
> entering the facility.

The facility administrator shall develop and implement site-specific
procedures for controlling gun-locker access.

In all facilities, gun lockers shall:

-   Be placed in locations where officers can continuously observe them,
    in person or on a video-monitor, and not in any area that has
    detainee or public access.

-   Be used to store the weapons of all on-duty officers, except those
    whose assignments require them to carry weapons.

-   Not be used for long-term storage. (A staff member may arrange with
    the facility firearms control officer for long-term storage of a
    weapon in the armory.)

Chits and logbooks are useful for maintaining accountability for gun
locker keys and gun locker use.

**Standard Approved:**

**James T. Hayes, Jr. /s/ 12/5/2008**

**\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_**

**James T. Hayes, Jr. Date**

**Director**

**Office of Detention and Removal Operations**