Results of Unannounced 

Inspections of Conditions 

for Unaccompanied Alien 

Children in CBP Custody 

September 28, 2018 

OIG-18-87 
 

 

 

DHS OIG HIGHLIGHTS 

Results of Unannounced Inspections of Conditions for 

Unaccompanied Alien Children in CBP Custody 

September 28, 2018 

Why We Did This 

Inspection 

In light of the heightened public 

and congressional interest in 

the Department of Homeland 

Security’s (DHS) separation of 

families at the southern border 

pursuant to the government’s 

Zero Tolerance Policy, the DHS 

Office of Inspector (OIG) 

conducted unannounced 

inspections of Customs and 

Border Protection (CBP) 

facilities in Texas on June 26-

28, 2018, to assess conditions 

of unaccompanied alien 

children in CBP custody. This is 

one of a series of inspections we 

will conduct of CBP facilities. 

What We 

Recommend 

This report contains no 

recommendations. 

For Further Information: 

Contact our Office of Public Affairs at (202) 

981-6000, or email us at 

DHS-OIG.OfficePublicAffairs@oig.dhs.gov. 

What We Found 

CBP facilities we visited appeared to be operating in 

compliance with the 2015 National Standards on 

Transport, Escort, Detention, and Search. With the 

exception of inconsistent cleanliness of the hold 

rooms, we observed that unaccompanied alien 

children had access to toilets and sinks, drinking 

water, beverages (including milk and juice drinks), as 

well as snacks and food. Unaccompanied alien 

children had access to hygiene items and clean 

bedding at all facilities we visited. We did not 

encounter issues with temperatures or ventilation, 

access to emergency medical care, inadequate 

supervision, or access to telephones. We also 

observed that CBP Office of Field Operations (OFO) 

ports of entry had offices and storage spaces 

redesigned into hold rooms to be able to hold more 

unaccompanied alien children, family units, and 

other border crossers referred for processing. The 

observations provided in this report are limited to the 

times and locations of the team’s visits and cannot 

be generalized to other times or locations. 

CBP Response 

Appendix B provides CBP management response in 

its entirety. 

www.oig.dhs.gov OIG-18-87 
 

 

 

 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Washington, DC 20528 / www.oig.dhs.gov 

September 28, 2018 

MEMORANDUM FOR: The Honorable Kevin K. McAleenan 

Commissioner 

U.S. Customs and Border Protection 

FROM: John V. Kelly 

Senior Official Performing the Duties of the 

Inspector General 

SUBJECT: Results of Unannounced Inspections of Conditions for 

Unaccompanied Alien Children in CBP Custody 

For your action is our final report, Results of Unannounced Inspections of 

Conditions for Unaccompanied Alien Children in CBP Custody. We incorporated 

the formal comments provided by your office. This report is observational and 

contains no recommendations. 

Consistent with our responsibility under the Inspector General Act, we will 

provide copies of our report to congressional committees with oversight and 

appropriation responsibility over the Department of Homeland Security. We will 

post the report on our website for public dissemination. 

Please call me with any questions, or your staff may contact Jennifer Costello, 

Chief Operating Officer, at (202) 981-6000. 

Attachment 
 

 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Background 

On April 6, 2018, President Trump directed several Federal agencies, including 

the Department of Homeland Security, to report on their efforts to end a 

practice developed under prior administrations of releasing certain individuals 

suspected of violating immigration law into the United States pending 

resolution of their administrative or criminal cases — a practice sometimes 

referred to as “catch and release.”1 The same day, Attorney General Jeff 

Sessions directed all Federal prosecutors along the Southwest Border to work 

with DHS “to adopt immediately a zero-tolerance policy” requiring that all 

improper entry offenses be referred for criminal prosecution “to the extent 

practicable” (referred to as the Zero Tolerance Policy).2 

Within DHS, U.S. Customs and Border Protection (CBP) played a critical role in 

implementing the Administration’s Zero Tolerance Policy. CBP’s Office of Field 

Operations (OFO) inspects all foreign visitors and goods entering at established 

ports of entry, while U.S. Border Patrol is responsible for apprehending 

individuals who enter the United States illegally between ports of entry. Both 

OFO and Border Patrol temporarily detain individuals who do not have 

authorization to be in the United States. 

In early May 2018, DHS determined that the Zero Tolerance Policy would cover 

alien adults arriving illegally in the United States with minor children. Because 

minor children cannot be held in criminal custody with an adult, alien adults 

attempting to enter the United States illegally were separated from any 

accompanying minor children when the adults were referred for criminal 

prosecution. The children, who DHS then classified as unaccompanied alien 

children,3 were held in DHS custody until they could be transferred to the U.S. 

Department of Health and Human Services (HHS) Office of Refugee 

Resettlement (ORR).4 

1 Presidential Memorandum for the Secretary of State, the Secretary of Defense, the Attorney 

General, the Secretary of Health and Human Services, and the Secretary of Homeland Security, 

April 6, 2018. 

2 Dept. of Justice, Memorandum for Federal Prosecutors Along the Southwest Border, April 6, 

2018. Entering the United States without inspection and approval is a civil offense and may 

also result in criminal charges. See 8 United States Code (U.S.C.) §§ 1227 (civil grounds for 

removal), 1325 (crime of improper entry), 1326 (crime of reentry), 1182(a)(6)(A) (grounds of 

inadmissibility for entering without inspection). The Department of Justice has the authority to 

decide whether and to what extent to prosecute Federal crimes. 

3 Unaccompanied alien children are aliens under the age of 18 with no lawful immigration 

status in the United States and without a parent or legal guardian in the United States 

“available” to care and physical custody for them. 6 U.S.C. § 279(g)(2). 4 The Homeland Security Act of 2002 gave primary responsibility for the custody and care of 

unaccompanied alien children to the ORR; while DHS was delegated the task of apprehension, 

transfer, and repatriation of unaccompanied alien children. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Generally, CBP must transfer unaccompanied alien children into the custody of 

ORR within 72 hours of identifying them as such.5 While temporarily holding 

unaccompanied alien children at OFO ports of entry, Border Patrol stations, 

and processing centers, CBP must provide safe and sanitary holding facilities, 

as detailed in CBP’s 2015 National Standards on Transport, Escort, Detention, 

and Search (TEDS Standards).6 These standards outline protocols for CBP on 

how to treat vulnerable populations, including unaccompanied alien children, 

and specify requirements for general care and conditions for children in 

temporary custody. 

In response to significant congressional and public interest related to the Zero 

Tolerance Policy, a multi-disciplinary team of DHS Office of Inspector General 

(OIG) attorneys, inspectors, and criminal investigators conducted 

unannounced site inspections at CBP facilities in part to assess compliance 

with the TEDS Standards. Between June 26 and 28, 2018, the OIG team 

visited nine CBP facilities in McAllen and El Paso, Texas, including five Border 

Patrol stations and four OFO ports of entry. Based on these inspections, we 

reported on CBP holding alien children separated under the Zero Tolerance 

Policy in facilities intended solely for short-term detention for longer than the 

72 hours generally permitted by law and the TEDS Standards.7 

This report describes the OIG team’s general observations with respect to the 

following TEDS Standards: 

x Access to Toilets, Sinks, and Drinking water; 

x Access to Food and Snacks; 

x Access to Hygiene Items, Bedding, and Clothes; 

x Temperature Control and Ventilation; 

x Emergency Medical Care; and 

x General Care and Condition of Unaccompanied Alien Children. 

Appendix A provides more information on the scope and methodology of the 

inspection. The observations provided in this report are limited to the times 

5 DHS must meet this timeline unless there are “exceptional circumstances.” 8 U.S.C. § 

1232(b)(3). 

6 In 1997, the Flores v. Reno Settlement Agreement established standards for the treatment of 

minors while in Federal custody and recognized the particular vulnerability of unaccompanied 

alien children while detained without a parent or legal guardian present. The Flores Agreement 

includes a requirement that immigration officials hold minors immediately following arrest in 

facilities that provide (1) access to food and drinking water; (2) medical assistance in the event 

of emergencies; (3) toilets and sinks; (4) adequate temperature control and ventilation; (5) 

adequate supervision to protect minors from others; (6) separation from unrelated adults 

whenever possible; and (7) contact with family members who were arrested with the minor. 

DHS and HHS recently proposed regulations that, once implemented, would terminate the 

Flores Agreement. 83 Fed. Reg. 45,486 (Sept. 7, 2018). 

7 More information on this issue is available in Initial Observations Regarding Family Separation 

Issues Under the Zero Tolerance Policy, OIG-18-84, September 2018. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

and locations of the team’s visits and cannot be generalized to other times or 

locations. 

Observations of Conditions for Unaccompanied Alien Children 

in CBP Custody 

CBP facilities we visited appeared to be operating in compliance with the TEDS 

Standards. With the exception of inconsistent cleanliness of the hold rooms, we 

observed that unaccompanied alien children had access to toilets and sinks, 

drinking water, beverages (including milk and juice drinks), as well as snacks 

and food. Unaccompanied alien children had access to hygiene items and clean 

bedding at all facilities we visited. We did not encounter issues with 

temperatures or ventilation, access to emergency medical care, inadequate 

supervision, or access to telephones. We also observed that OFO ports of entry 

had offices and storage spaces redesigned into hold rooms to be able to hold 

more unaccompanied alien children, family units, and other border crossers 

referred for processing. 

Access to Toilets, Sinks, and Drinking Water 

The TEDS Standards require CBP facilities holding unaccompanied alien 

children to provide toilets and sinks that are cleaned and sanitized at least 

once per day and drinking fountains or drinking water along with clean 

drinking cups. In all nine CBP facilities (five Border Patrol facilities and four 

OFO ports of entry) we visited, unaccompanied alien children had adequate 

access to toilets, sinks, and drinking water. In four Border Patrol facilities, 

unaccompanied alien children had access to a standard toilet and sink unit 

typically built inside the hold rooms. Signs above the sinks typically stated that 

the water was potable, and the sinks worked when we tested them. The hold 

rooms also had plastic water coolers, but cups were not always in the rooms. 

Two Border Patrol stations had bottled water available in addition to sinks or 

water coolers. At the Ursula Central Processing Center, shown in figure 1, 

which is different from the other four, more typical Border Patrol facilities,8 

bottled water was available for drinking, and portable toilets were placed in the 

holding areas. 

8 The Ursula Central Processing Center (also known as McAllen Central Processing Center) 

opened in 2014 to accommodate the overflow of unaccompanied alien children from and 

consolidate processing operations for the Rio Grande Valley sector. The facility is a retrofitted 

warehouse that can hold more than 1,000 people. 

www.oig.dhs.gov 4 OIG-18-87 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Figure 1. Bottled water in pods and toilets at the Ursula Central Processing Center, 

observed on June 26, 2018. 

Source: DHS OIG 

At the four OFO ports of entry we visited, we saw no issues except for one 

unsanitary bathroom. Figure 2 shows a typical hold room toilet and sink unit 

and also illustrates that the cleanliness of hold rooms was inconsistent (photo 

on the right). 

Figure 2. Toilets and sinks in Border Patrol and OFO hold rooms, observed on 

June 26–27, 2018. 

Source: DHS OIG 

Access to Food and Snacks 

The TEDS Standards require CBP facilities to provide unaccompanied alien 

children with regular access to snacks, milk, and juice and to offer a meal at 

least every six hours, with at least two of those meals served hot. The TEDS 

Standards also require that food must be appropriate for a child’s age and 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

capabilities, such as formula and baby food. In all nine CBP facilities we 

visited, unaccompanied alien children had access to food and snacks. All five 

Border Patrol facilities had meals, snacks, juice, milk, and baby formula 

available. Food available at these stations included frozen burritos, canned 

food, instant oatmeal, ramen noodles, applesauce, crackers, and granola bars. 

However, we observed expired baby formula at one facility, though no infants 

were held at that facility at the time of our visit. Figure 3 shows the typical 

assortment of foods we saw at Border Patrol stations. All four OFO facilities we 

visited had snacks, food, and beverages available. Figure 4 captures the food 

and beverages we saw at OFO ports of entry. At one Border Patrol facility, we 

directly observed children eating warm burritos; at another Border Patrol 

facility, we observed children with juice and snack bars; and at the Ursula 

Central Processing Center, we saw apples, milk, and juice in areas where 

children were held. Unaccompanied alien children we spoke with did not 

complain of hunger and said they had enough food. 

Figure 3. Food, snacks, and juice at Border Patrol facilities, observed on June 26–27, 

2018. 

Source: DHS OIG 

www.oig.dhs.gov 6 OIG-18-87 
 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Figure 4. Beverages and food items at OFO ports of entry, observed on June 27, 2018.
 

Source: DHS OIG 

Access to Hygiene Items, Bedding, and Clothes 

The TEDS Standards specify that unaccompanied alien children will be given 

access to basic hygiene articles, clean bedding,9 and, when available, clean and 

dry clothing. In all nine CBP facilities we visited, unaccompanied alien children 

had access to hygiene items. All facilities also provided clean bedding, 

supplying either space blankets (made of Mylar) or cloth blankets for the 

children. In addition, eight out of nine CBP facilities we visited had either cots 

or floor mats for unaccompanied alien children. We observed supplies, such as 

clean clothing and towels at the five Border Patrol facilities including the 

Ursula Central Processing Center, as shown in figure 5. 

Figure 5. Clothing, towels, and hygiene items at Border Patrol facilities, observed on 

June 26–27, 2018. 

Source: DHS OIG
 

9 The TEDS Standards define bedding as “A (or any combination of) blanket, mat, or cot.” 

www.oig.dhs.gov 7 OIG-18-87 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

At the four OFO ports of entry visited, we observed supplies of clothing and 

hygiene items to include soap, toothbrushes, toothpaste, sanitary napkins, 

diapers, and baby wipes, as shown in figure 6. 

Figure 6. Clothing and hygiene items at OFO ports of entry, observed on June 27, 2018. 

Source: DHS OIG 

Temperature Control and Ventilation 

The TEDS Standards require CBP facilities holding unaccompanied alien 

children to provide “adequate temperature control and ventilation,” and further 

suggest that when it is within CBP control, hold room temperatures should be 

“reasonable and comfortable.” During our visits, we observed that 

temperatures met this standard. Although some unaccompanied alien children 

at the Ursula Central Processing Center complained that they felt cold, the 

temperatures we observed on thermostats or measured in the five Border Patrol 

and four OFO facilities were within 68 to 76 degrees Fahrenheit. 

Emergency Medical Care 

The TEDS Standards specify that any physical or mental injury or illness 

observed by or reported to CBP personnel should be reported to a supervisor 

and appropriate medical care should be provided, including calling emergency 

services in the event of a medical emergency. The TEDS Standards also require 

non-U.S.-prescribed medication to be validated by a medical professional. All 

facilities we visited have procedures in place to refer unaccompanied alien 

children to local hospitals and to procure or validate prescription medication. 

CBP and medical staff control access to prescription medications, and we 

observed prescription medication logs in two facilities to document detainee 

administered prescriptions. We observed first aid kits in all facilities. Although 

not specifically required under CBP standards, three of the nine facilities we 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

visited had trained medical staff to conduct medical screening and provide 

basic medical care. 

General Care and Condition of Unaccompanied Alien Children 

The TEDS Standards require CBP staff to check hold rooms regularly. In all 

nine CBP facilities, CBP staff monitored the unaccompanied alien children in 

hold rooms by direct observation and, in some cases, using video monitoring. 

The TEDS Standards specify that all unaccompanied alien children must be 

advised of their right to consular access and granted telephone access. All 

facilities we visited had working phones available for unaccompanied alien 

children use. We observed call logs documenting phone calls and observed one 

unaccompanied alien child calling a relative in the United States during Border 

Patrol processing. 

The TEDS standards require CBP to make “reasonable efforts” to provide 

showers to unaccompanied alien children who are approaching 48 hours in 

detention. Shower facilities were available for unaccompanied alien children at 

one OFO and three Border Patrol facilities we visited. These four facilities also 

had the ability to launder unaccompanied alien children’s clothes. At the other 

facilities, we observed supplies of clean clothes for unaccompanied alien 

children’s use as necessary. 

The OFO ports of entry we visited have a very limited number of holding cells 

for short-term custody. We observed that when unaccompanied alien children, 

who are required to be held separately from unrelated adults, occupy space at 

a port of entry, there is limited ability to hold other people. 

We observed offices and storage spaces redesigned to make more rooms for 

holding unaccompanied alien children, family units, and other border crossers 

referred for processing. For example, at the Gateway International Bridge in 

Brownsville, one hold room with a bathroom and sink was only used as a 

bathroom so that temporary hold rooms that did not have bathroom facilities 

could have access to them. To meet the requirement to hold unaccompanied 

alien children and other categories of detainees separately, CBP had converted 

regular office space into hold rooms. Figure 7 shows converted offices that held 

unaccompanied alien children or families during our visit. 

www.oig.dhs.gov 9 OIG-18-87 
 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Figure 7. Offices converted into holding spaces at an OFO facility, observed June 27, 

2018. 

Source: DHS OIG
 

Management Response and OIG Analysis 

We obtained management comments to the draft report from CBP. We included 

a copy of those comments, in their entirety, in appendix B. We also made other 

revisions, where appropriate, to address separate technical comments CBP 

provided. 

www.oig.dhs.gov 10 OIG-18-87 
 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix A 

Objective, Scope, and Methodology 

The Department of Homeland Security (DHS) Office of Inspector General (OIG) 

was established by the Homeland Security Act of 2002 (Public Law 107−296) by 

amendment to the Inspector General Act of 1978. 

The objective of this inspection report is to detail some of our observations from 

visits to CBP facilities in and around McAllen and El Paso, Texas, pertaining to 

conditions for unaccompanied alien children in CBP custody. The observations 

provided in this report are limited to the times and locations of the team’s visits 

and cannot be generalized to other times or locations. We selected facilities in 

and around McAllen because the Rio Grande Valley Border Patrol sector had 

more apprehensions of family units and unaccompanied alien children than 

any other sector during April–May 2018. We selected facilities in and around El 

Paso because the El Paso Border Patrol sector had the third-most 

apprehensions during that time and has active ports of entry. We conducted 

our unannounced inspections at the following facilities: 

Rio Grande Valley, Texas 

CBP Border Patrol facilities: 

o McAllen Station; 

o Ursula Central Processing Center; 

CBP OFO facilities: 

o Gateway International Bridge Port of Entry; 

o Brownsville and Matamoros International Bridge Port of Entry; 

o Hidalgo Port of Entry. 

El Paso, Texas 

CBP Border Patrol facilities: 

o Clint Station; 

o Paso Del Norte Processing Center; 

o El Paso Station; 

CBP OFO facility: 

o Paso del Norte International Bridge Port of Entry. 

Throughout our visits, we spoke with CBP employees, including line officers, 

agents, and senior management officials as well as unaccompanied alien 

children. We also reviewed relevant guidance, policies, and procedures. 

We conducted this inspection between June 26 and 28, 2018, under the 

authority of the Inspector General Act of 1978, as amended, and according to 

the Quality Standards for Inspections issued by the Council of the Inspectors 

General on Integrity and Efficiency. 

www.oig.dhs.gov 11 OIG-18-87 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix B 

DHS’ Management Response to the Draft Report 

www.oig.dhs.gov 12 OIG-18-87 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

www.oig.dhs.gov 13 OIG-18-87 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix C 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff 

Deputy Chiefs of Staff 

General Counsel 

Executive Secretary 

Director, GAO/OIG Liaison Office 

Assistant Secretary for Office of Policy 

Assistant Secretary for Office of Public Affairs 

Assistant Secretary for Office of Legislative Affairs 

CBP Liaison 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees 

www.oig.dhs.gov 14 OIG-18-87 
Additional Information and Copies 

To view this and any of our other reports, please visit our website at: 

www.oig.dhs.gov. 

For further information or questions, please contact Office of Inspector General 

Public Affairs at: DHS-OIG.OfficePublicAffairs@oig.dhs.gov. 

Follow us on Twitter at: @dhsoig. 

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on the red "Hotline" tab. If you cannot access our website, call our hotline at 

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