ICE/DRO DETENTION STANDARD

TOOL CONTROL

# PURPOSE AND SCOPE. This Detention Standard protects detainees, staff, contractors, and volunteers from harm and contributes to orderly facility operations by maintaining control of tools, culinary utensils, and medical and dental instruments, equipment, and supplies.

It applies to the following types of facilities housing 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 OUTCOME. The expected outcome of this Detention Standard is:

Tools, maintenance implements, culinary utensils, medical and dental
instruments, equipment, and supplies (particularly syringes, needles,
and other sharps) will be maintained on an inventory, continually
controlled and accounted for to insure the safe and orderly operation of
the facility.

# DIRECTIVES AFFECTED. This Detention Standard replaces Tool Control dated 9/20/2000.

# REFERENCES

> American Correctional Association 4thd Edition Standards for Adult
> Local Detention Facilities: 4-ALDF-2D-02, 2D-03.

# EXPECTED PRACTICES

## Overview

> In a detention environment, all staff must be alert for any situation
> where tools, culinary utensils (such as kitchen knives and other food
> preparation implements but not including basic eating utensils), and
> medical and dental instruments, equipment, and supplies (particularly
> syringes, needles, and other sharps) are in the possession of, or
> available to, detainees, other than those authorized to have them
> (such as on work details).
>
> Control, care, and accountability for tools:

-   Prevents their use in escape attempts, as weapons, and in other ways
    that can be hazardous to individual safety or the good order of the
    facility;

-   Improves the appearance of shop and construction areas;

-   Helps ensures tools are good repair when needed;

-   Reduces the costs of tool maintenance and inventory; and

-   Detainees will be held accountable for tools that have been assigned
    to them.

## Written Policy and Procedures Required

> Each facility administrator shall develop and implement a written tool
> control system that establishes:

1.  A staff position responsible for:

-   Developing and implementing tool control procedures, and

-   Establishing an inspection system to ensure accountability;

    *In SPCs and CDFs, the facility administrator shall delegate these
    responsibilities to the chief of security and shall also assign, in
    writing, the duties of Tool Control Officer to a staff member of the
    facility maintenance department.*

1.  A tool classification system;

2.  Procedures for marking tools so they are readily identifiable;

3.  Procedures for storing tools;

4.  Procedures and schedules for regular inventories of tools;

5.  Procedures for issuing tools to staff and detainee workers;

6.  Procedures governing lost tools;

7.  Procedures for surveying and destroying excess, broken, or worn-out
    tools; and

8.  Procedures for inspecting and controlling tools and equipment
    brought into the facility temporarily (repair and maintenance
    workers, sports teams. etc.)

## Tool Classification

> The facility shall develop and implement a tool classification system.
>
> *In SPCs and CDFs, tools are assigned one of two categories:*

-   *Restricted (Class "R") \-- Dangerous/hazardous tools*

-   *Non-Restricted \-- Non-hazardous tools*

> *Class "R" tools include:*

-   *Tools too dangerous for detainees to handle without constant staff
    supervision*

-   *Tools to which detainee access is prohibited*

-   *Tools that could facilitate an escape or an escape attempt*

-   *Tools useful in making weapons, that could double as weapons, or
    that are capable of causing serious bodily harm*

-   *Power hand tools, with or without cords*

-   *Other tools that are generally hazardous to facility security or
    personal safety*

> *Examples of restricted tools include:*

-   *Metal cutting blades*

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-   *Mixing chambers*

-   *Bolt cutters*

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-   *Ramset gun and ammunition (stored in armory only)*

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-   *Diamond-tipped tools*

-   *Core drills*

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-   *Drills*

-   *Circular saws*

-   *Knives and other sharp culinary utensils*

> *The facility administrator shall establish a policy document on
> facility tool use and storage that includes separate, comprehensive,
> alphabetical lists of both restricted and non-restricted tools.*

-   *The lists shall indicate which of the listed tools are available
    on-site; describe them by type; and specify tool sizes.*

-   *The lists shall be kept current by formatting them as attachments
    to the policy document, maintained and updated electronically.*

-   *The lists shall be updated and distributed at least quarterly.*

> *Tools included in tool sets and tools sized sequentially in standard
> increments may appear as a single listing. For example:*
>
> *Drill bits, metal/wood 1/32\" -- 7/8\"*
>
> *Drill bits, metal/wood 7/16\" ‑ 7/8\"*
>
> *Wrench, comb. box/open end 1/4\" ‑ 7/16\"*
>
> *Wrench, comb. box/open end 7/16\" ‑ 7/8\"*
>
> *When a single set listing would not be sufficiently clear, however,
> each tool must be listed separately. For example, if a facility had:*
>
> *A single \"wrench, combination box/open end, 1 7/8 inches\" but not
> the smaller or larger sizes; or*
>
> *Several wrenches in different sizes, but the size differences are not
> standard.*

## Daily Removal and Storage of Class "R" Tools

> *In SPCs and CDFs, staff shall remove restricted tools from work areas
> at the end of each workday for safekeeping in a secure tool room, the
> armory, or the Control Center.*

## Acetylene

> *In SPCs and CDFs, staff shall:*

-   *Restrict the supply of acetylene entering the facility to the
    amount needed in a single day, and*

-   *At the end of each workday, store the used and unused acetylene
    tanks outside the secured perimeter in accordance with applicable
    codes, standards, and regulations (Occupational Safety and Health
    Administration\'s industrial safety regulations, etc.).*

## Departmental Responsibilities

> At a minimum, the following departments shall maintain tool
> inventories:

1.  Facility Maintenance Department

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9.  Medical Department

10. Food Service Department

11. Electronics Shop

12. Recreation Department

13. Armory

> *In SPCs and CDFs, each department head is responsible for
> implementing tool control procedures in that department, and the
> following procedures are specifically required of the Facility
> Maintenance Department Head, Health Services Administrator (HSA), Food
> Service Manager, Electronics Technician, Recreation Specialist, and
> Senior Firearms Instructor:*

1.  *Prepare a computer-generated inventory of all class \"R\" tools in
    the maintenance restricted-tool room, the medical facility, the food
    service department; the electronics work area, recreation areas, and
    the armory.*

2.  *Post a copy of the class \"R\" tool inventory with the equipment in
    a prominent position in the equipment area.*

3.  *Submit a second copy of the inventory to the chief of security.*

4.  *Retain a third copy in the department.*

5.  *Repeat the class \"R\" tool inventory on a regular schedule:*

-   *Weekly \-- food service*

-   *Monthly \-- facility maintenance, medical*

-   *Quarterly \-- electronics work area, recreation areas, armory*

> *6. Send a copy of the inventory report to the facility
> administrator.*
>
> *7. Report missing tools in accordance with procedures specified
> below.*
>
> *8. All inventory sheets will include the date of issuance/revision.*

## Tool Identification

> The facility administrator shall establish written procedures for
> marking tools, making them readily identifiable.
>
> *In SPCs and CDFs:*
>
> *1. The Tool Control Officer shall mark every tool in every work
> location with a symbol signifying its storage location ("Armory,"
> "Control Center," etc.) Some tools require \"AMIS\" bar-coding.*
>
> *2. Tools too small, fragile, or otherwise susceptible to damage
> (surgical instruments, micrometers, small drill bits, etc.) shall be
> inventoried and kept in locked storage when not in use.*

## Storage in Work Areas

> The facility administrator shall establish written procedures for a
> tool-storage system that ensures accountability. Commonly used,
> mounted tools shall be stored so that a tool\'s disappearance will not
> escape attention.

*In SPCs and CDFs:*

1.  *Work-detail supervisors shall account for all tools at the end of
    every work period.*

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14. *Shadow boards shall provide storage for tools that can be mounted,
    as follows:*

-   *One tool per shadow,*

-   *Tool and shadow identical in size and shape, and*

-   *Color-coded:*

    -   *White backgrounds for all shadow boards*

    -   *Red shadows for restricted tools*

    -   *Black shadows for non-restricted tools*

15. *When a tool is removed from the inventory, its shadow shall
    likewise be removed from the shadow board.*

16. *Shadow boards accessible to detainees shall have expanded-metal
    covers and shall be locked when not in use.*

17. *All restricted tools shall be secured in a central tool room,
    isolated from the housing units.*

18. *If maintenance workers are assigned personal shadow boards, the
    boards must have expanded-metal covers.*

19. *Infrequently used tools may be stored in individual tool cages with
    shadow boards, secured by hasp and padlock.*

-   *They must be included in the regular inventory checks.*

-   *A tag shall indicate the tool has been removed from its cage and a
    sign-in/-out board shall indicate area, date, times, and user.*

-   *The staff member responsible shall maintain an inventory sheet in
    the tool cage and provide a copy to the Tool Control Officer.*

20. *Tools not adaptable to shadow boards shall be kept in a locked
    drawer or cabinet.*

21. *Staff shall not open sterile packs for inventory or any other
    non-medical reason, except when tampering or theft is suspected, in
    which case staff shall contact the health services department before
    opening a pack from which instruments may have been removed. To
    prevent such incidents, sterile packs shall be stored under lock and
    key at all times.*

22. *Individual toolboxes containing tools used on a daily basis must be
    secured with hasp and padlock. The individual responsible for the
    toolbox shall keep an inventory sheet in the toolbox, and the Tool
    Control Officer shall maintain copies of all such inventory sheets.*

## Receipt of Tools

> *In SPCs and CDFs:*

1.  *If the warehouse is located outside the secure perimeter, the
    warehouse shall receive all tool deliveries.*

    *If the warehouse is located within the secure perimeter, the
    facility administrator shall develop site-specific procedures, for
    example, storing the tools at the rear sallyport until picked up and
    receipted by the Tool Control Officer. The Tool Control Officer
    shall immediately place certain tools (for example, band saw blades,
    files, and all restricted tools) in secure storage.*

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23. *The new tools shall be issued only after the Tool Control Officer
    has marked and inventoried them. Inventories that include any
    portable power tools shall provide brand name, model, size,
    description, and inventory control/AMIS number.*

## Tool Inventories

> The facility administrator shall schedule, and establish procedures
> for, the quarterly inventorying of all tools. Facilities shall use
> inventory control number/AMIS bar code labels as necessary.

*In SPCs and CDFs,*

1.  *Inventory maintenance at each work location is the responsibility
    of the detail supervisor and department head.*

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24. *The work detail supervisor or staff member assigned a toolbox shall
    be accountable for the control of his or her assigned tools on a
    daily basis.*

25. *Any tool permanently removed from service shall be turned in to the
    Tool Control Officer for recordkeeping and safe disposal.*

26. *Tool inventories shall be numbered and posted conspicuously on all
    corresponding shadow boards, toolboxes, and tool kits. While all
    posted inventories must be accurate, only the Master Tool Inventory
    Sheet in the office of the chief of security requires the
    certifiers\' signatures.*

27. *Tools in current use shall be inventoried in accordance with the
    following schedule:*

-   ***Annual.** At least once each year, the Tool Control Officer and
    employees responsible for tools shall together inventory all
    tools/equipment on-site.*

    -   *Each inventory-taker shall certify the accuracy of that
        inventory, which must be approved by the facility maintenance
        supervisor and chief of security.*

    -   *The Tool Control Officer shall provide the chief of security a
        complete set of the separate inventories (for example,
        restricted tools, non-restricted tools), referred to as the
        Master Tool Inventory Sheet.*

-   ***Quarterly.** To ensure the accuracy and completeness of current
    inventory listings and check the condition of shadows and markings,
    every three months the employees responsible for tools shall conduct
    verification inventories and initial the appropriate column on the
    Master Tool Inventory Sheet in the office of the chief of security.*

    *The chief of security shall assign an officer to monitor the
    quarterly inventories. This officer shall initial the bottom of each
    form certifying the records have been checked and all inventories
    completed.*

28. ***Inventory Files.** The facility administrator's designee shall
    maintain a separate file folder for each shop or area in which tools
    are stored.*

-   *The left side of the folder shall contain the Master Tool Inventory
    Sheet(s).*

    *When an addition or deletion is made to the master inventory, the
    page on which the change is made shall be completely retyped or
    reprinted and inserted into the master inventory. Staff shall not
    destroy any of the original pages but move them to the right side of
    the folder for future reference.*

-   *The right side of the folder shall also contain (but is not limited
    to):*

    -   *Lost or missing tool reports,*

    -   *Requests for inventory additions or deletions,*

    -   *Survey requests and reports,*

    -   *Storeroom requisition forms, and*

    -   *Any other document directly related to site-specific tool
        control procedures.*

-   *When the annual inventory is completed, staff shall place the form
    on the left side of the folder and move the previous year's to the
    right side. Each folder shall contain the materials for the current
    year plus the preceding two years, with a divider to separate the
    annual records.*

29. ***Tools Used by Contractors.** Staff shall conduct an inventory of
    all contractor tools upon their admission and release. The chief of
    security shall establish control procedures, particularly for
    restricted tools. The chief of security, facility maintenance
    supervisor, and construction foreman shall maintain copies of all
    such inventories and control procedures.*

30. ***Tools Purchased from Surplus Property.** Tools purchased or
    acquired from surplus property shall be stored in the designated,
    secure storage area. The responsible employee shall maintain a
    perpetual inventory of unmarked or excess tools returned to secure
    storage for issue or reissue. The Tool Control Officer has sole
    authority to draw tools from this source. Any such tools kept in the
    Tool Control Officer\'s storage area shall be registered in a
    perpetual inventory.*

31. ***Control and Inventory of Certain Items Not Classified as Tools.**
    Other items that require strict property management controls, like
    weapons (other than firearms), chemical agents, restraints, other
    use-of-force and disturbance control equipment, binoculars;
    communication equipment, and similar items shall be inventoried
    (with serial numbers), maintained, issued, and disposed of in
    accordance with the procedures established herein for tools.*

    *Control, inventory, maintenance, and destruction of ICE
    **firearms** are governed by the **ICE Interim Firearms Policy**
    (7/7/2004)*

    *10. **Tool and Equipment Accountability***

    *All tools and equipment will be accounted for and documented on a
    regular basis.*

## Issuing Tools

> Each facility shall have procedures in place for

-   The issuance of tools to staff and detainees;

-   Security issues of restricted and unrestricted tools;

-   Control of ladders, extension cords, and ropes.

> *In SPCs and CDFs:*
>
> *1. The chief of security shall issue a restricted tool only to the
> individual who will be using it.*
>
> *2. Detainees may use non-restricted tools under intermittent
> supervision; however, the detail supervisor shall account for all
> tools at the end of every work period.*
>
> *3. A metal or plastic chit receipt shall be taken for all tools
> issued, and when a tool is issued from a shadow board, the receipt
> chit shall be visible on the shadow board.*

4.  *The facility administrator shall establish site-specific procedures
    for the control of ladders, extension cords, ropes, and hoses.*

-   *All ladders, extension cords, ropes, and hoses over three feet long
    shall be stored in the designated location when not in use.*

-   *Every staff member supervising the use of extension ladder and/or
    heavy equipment shall have at his or her disposal a portable two-way
    radio.*

-   *Ladders shall be inventoried and stored by size to facilitate
    inspection and handling.*

-   *Extension cords must be inventoried and have a metal or plastic tag
    attached, indicating issue number (by location) and length of cord.*

-   *Extension cords longer than 10 feet are classified and handled as
    Class R tools.*

-   *In high-rise SPCs and CDFs, electrical cords attached to buffers,
    vacuum cleaners, etc., may not exceed two feet.*

5.  *Scissors used for in-processing shall be securely tethered to the
    furniture at which they are used.*

6.  *Issuance of tools from a storage location for a specified project
    for extended periods requires approval of the chief of security. The
    work detail supervisor shall conduct daily on-site checks of
    extended-use tools issued from the central tool room, and the
    facility maintenance supervisor shall conduct them at least
    monthly.*

## Lost Tools

> The facility administrator shall develop and implement procedures
> governing lost tools, including:

-   Verbal and written notification to supervisory officials

-   Handling detainees with prior access to the tool(s) in question

-   Documentation and review

> *In SPCs and CDFs:*

1.  *When a **restricted or non-restricted** tool is missing or lost,
    staff shall notify the chief of security in writing as soon as
    possible.*

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1.  *When the tool is a **restricted (Class "R")** tool, staff shall
    inform the shift supervisor orally immediately upon discovering the
    loss. Any detainee(s) who may have had access to the tool shall be
    held at the work location pending completion of a thorough search.*

2.  *When a **medical department tool or equipment item** is missing or
    lost, staff shall immediately inform the HSA, who shall make the
    immediate verbal notification to the chief of security or shift
    supervisor and written notification to the facility administrator.*

3.  *The shift supervisor\'s office shall maintain a lost-tool file,
    monitor the individual reports for accuracy, ascertain any unusual
    patterns or occurrences of loss in one or more shops, document
    search efforts, and send written notification to the chief of
    security.*

4.  *On the day a tool is recovered, staff shall complete and send
    copies of the Lost or Missing Tool Report to the chief of security
    and shift supervisor.*

5.  *The facility administrator shall implement quarterly evaluations of
    lost/missing tool files, reviewing the thoroughness of
    investigations and efforts to recover tools. Documentation of the
    quarterly evaluations shall be maintained on the right side of the
    tool inventory folder for the shop or area concerned.*

## Disposition of Excess Tools

> All broken or worn-out tools shall be surveyed and destroyed in
> accordance with the written procedures established by the facility
> administrator.
>
> *In SPCs and CDFs:*

1.  *The Tool Control Officer or Security Officer shall implement
    procedures for storing broken and/or worn-out tools in a secure
    area, pending survey and disposition.*

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6.  *Excess tools not being surveyed shall remain in a designated,
    secure storage area until included in a subsequent survey, or
    returned to use.*

7.  *To maintain tool inventories at the most efficient operating level,
    staff in every shop and department shall identify and move to a
    secure storage area all rarely used tools. Bin cards shall account
    for the tools moved from shop to storage areas.*

8.  *Either the Tool Control Officer or Security Officer shall be
    responsible for destroying all surveyed tools.*

9.  *The office of the chief of security shall maintain records of all
    tool surveys.*

## Private/Contract Repair and Maintenance Workers

> All visitors, including repair and maintenance workers who are not
> ICE/DRO or facility employees, shall submit to an inspection and
> inventory of all tools, tool boxes, and equipment that could be used
> as weapons before entering and leaving the facility.
>
> The contractor shall maintain a copy of the tool inventory with them
> while inside the facility.
>
> *In SPCs and CDFs:*
>
> *An officer shall accompany non-employee workers in the facility to
> ensure that security and safety precautions and procedures are
> followed at all times, including removing tools at the end of each
> shift.*
>
> *Before a detainee, employee, or contractor may enter a housing unit,
> the housing officer shall inventory tools and similar items to be
> carried into that unit and then, before departure from the unit,
> verify their removal in a second inventory. The housing officer shall
> immediately report discrepancies to the shift supervisor.*

**Standard Approved:**

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

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

**James T. Hayes, Jr Date**

**Director**

**Office of Detention and Removal Operations**