Alameda County Probation (2023-2024 inspection cycle)

July 23, 2024 Brian Ford, Interim Chief Probation Officer Alameda County Probation Department P.O. Box 2059 1111 Jackson Street Oakland, CA 94604-2059 2023-2024 TARGETED INSPECTION, WELFARE & INSTITUTIONS CODE SECTIONS 209 & 885, ALAMEDA COUNTY PROBATION DEPARTMENT DETENTION FACILITIES Dear Chief Ford: A Targeted Inspection of the Alameda County Probation Department has been completed. A pre-inspection briefing was held on Tuesday, March 5, 2024, and the following facilities were inspected between Tuesday, June 3, 2024, and Tuesday, June 11, 2024: FACILITY NAME BSCC # FACILITY TYPE Alameda County Juvenile Justice Center 7001 JH Alameda Camp Sweeney 7003 CAMP Alameda Secure Youth Treatment Facility (Firm 7002 SYTF Roots Academy) These inspections were conducted pursuant to Welfare and Institutions Code Sections 209 and 885 to determine compliance with the Minimum Standards for Juvenile Detention Facilities as outlined in Titles 15 and 24, California Code of Regulations. INSPECTION RESULTS We identified the following item(s) of noncompliance with Title 15 Minimum Standards. Refer to the attached Procedures Checklist for detailed information. The following item(s) of noncompliance Alameda County Juvenile Justice Center: § 1321. Staffing: Insufficient detention staff to carry out the overall operation of the facility including, but not limited to, programming. § 1354.5. Room Confinement: Youth on Reintegration Safety Plans (RSP) are placed in their rooms for extended periods when the high-risk level of safety and security is no longer evident and/or Brian Ford Interim Chief Probation Officer Page 2 not documented as such. RSPs were required to eat meals in their rooms and remain in their rooms during school hours for educational services. § 1371. Programs, Recreation, and Exercise: Youth on RSP were not consistently provided the required programs, recreation, and exercise. Firm Roots Academy: § 1321. Staffing: Insufficient detention staff to carry out the overall operation of the facility including, but not limited to, programming. § 1354.5. Room Confinement: • Room confinement was utilized before other, less restrictive options were attempted and exhausted. • Whether intended or not, room confinement was used for the purposes of punishment, coercion, convenience, or retaliation by staff. • Youth were not returned to the general population when there was no longer a risk to safety and security. • Title 15 and facility policies were not followed when room confinement was extended beyond four hours. § 1371. Programs, Recreation, and Exercise: Youth on RSP were not consistently provided the required programs, recreation, and exercise. Alameda Camp Sweeney: § 1328. Safety Checks: Safety checks were not documented with the actual time the check was completed. CORRECTIVE ACTION PLAN (CAP) An Initial Inspection Report (IIR) outlining items of noncompliance was provided to your staff at the Exit Briefing on June 11, 2024. Pursuant to Welfare and Institutions Code section 209(d), a CAP must be provided to the BSCC for approval no later than 60 days following the notice of noncompliance in the IIR, which is June 11, 2024. Failure to submit a CAP by August 10, 2024, will result in the facility being deemed unsuitable for the confinement of youth. Upon receipt and approval of your CAP, BSCC staff will follow up with further information regarding the implementation of the corrective action plan and reinspection for compliance. Failure to correct the items of noncompliance within the approved timeframe following CAP approval will result in the county’s appearance before the BSCC Board for a determination of suitability. * * * 7001+ Alameda County Probation JH SYTF CAMP Targeted LTR 23-24 Brian Ford Interim Chief Probation Officer Page 3 Please email me at forrest.coleman@bscc.ca.gov or call (916) 508-7559 if you have any questions. Sincerely, FORREST COLEMAN Field Representative Facilities Standards and Operations Division Enclosures Cc: Presiding Judge, Alameda County Juvenile Court* Chair, Juvenile Justice Commission, Alameda County* Chair, Board of Supervisors, Alameda County* County Administrator, Alameda County* Shauna Conner, Deputy Chief Probation Officer, Alameda County Probation Dept. Superintendent of Institutions, John Ebrahimi, Alameda County Probation Dept. Superintendent Albert Banuelos, Alameda County Probation Dept. *Copies of the inspection are available upon request or online at www.bscc.ca.gov. 7001+ Alameda County Probation JH SYTF CAMP Targeted LTR 23-24 JUVENILE HALLS, SPECIAL PURPOSE JUVENILE HALLS AND CAMPS Board of State and Community Corrections PROCEDURES CHECKLIST1 BSCC Code: 7001 FACILITY NAME: Alameda County Juvenile Justice Center FACILITY TYPE: JH PERSON(S) INTERVIEWED: Chief Probation Officer (Interim), Brian Ford; Shauna Conner, Deputy Chief Probation Officer (Juvenile Facilities); John Ebrahimi, Superintendent-JH; Julie Marques, Assistant Superintendent-JH; Richard Valle, Institutional Supervisor II (ISII); Esmeralda Pulido, Juvenile Institutional officer (JIO); Michael Postell Behavioral Health Clinician; Ray Nickaloff, Food Service Manager; Chad Reed, Teacher (Interim); Christie Aganon, RN; Andrea Parish, Health Services Executive Director; Male youth age 17; Male youth 15; two Female youths’; Random youth during physical facility inspection. FIELD REPRESENTATIVE: Forrest Coleman DATE: June 3rd through June 11th, 2024 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS 1321 STAFFING Chapter 3, Section 1321, II Policy 1 ⁋ JH: Chapter 3, Section 1322.18, III Staffing Each juvenile facility shall: (a) have an adequate number of personnel sufficient to The Alameda County Juvenile Justice carry out the overall facility operation and its Center (ACJJC) is commonly referred to as programming, to provide for safety and security of Juvenile Hall. This facility utilizes staff youth and staff, and meet established standards and support from the Alameda County Secure regulations; Youth Treatment Facility (ACSYTF). The ACSYTF is a housing unit located within the Juvenile Justice Center complex. Additionally, staff support is provided by Camp Sweeney (CS) which is a detention camp located on the same campus and adjacent to the ACJJC complex. Detention staff are cross-trained to allow the agency to utilize staff from either facility if needed. ☐ ☒ ☐ BSCC staff reviewed the above policies and procedures, as well as the agency’s Organization Chart, random weekly staff schedules, and daily unit schedule covering the first eight days of March, April, and May of 2024. Additionally, we made personal observations and interviewed youth housed at the facility, collaborative partners, and detention staff. Noncompliance was discovered when BSCC staff found that when staffing levels were low, the facility separated youth into two groups that alternated between being locked in their rooms and being out of their rooms for normal program times. 1 This document is intended for use as a tool during the targeted inspection process; this worksheet may not contain each Title 15 regulation that is required. Additionally, many regulations on this worksheet are SUMMARIES of the regulation; the text on this worksheet may not contain the entire text of the actual regulation. Please refer to the complete California Code of Regulations, Title 15, Minimum Standards for Juvenile Facilities, Division 1, Chapter 1, Subchapter 5 for the complete list and text of regulations. 7001 Alameda County Juvenile Justice Center JH Targeted PRO 23-24 Page 1 of 21 A453 JUV Targeted PRO eff. 1/2024 Additional noncompliance was discovered when BSCC staff were made aware that when staffing levels were low, youth were kept in their rooms for much of the shift and only rotated out of their rooms in groups of two youth for ten or 15-minute intervals during a shift. This practice also results in noncompliance with Section 1354.5, Room Confinement, and 1371, Programs, Recreation, and Exercise. The agency is working toward submitting an approved Corrective Action Plan (CAP) to BSCC that identifies dates of resolution for the noncompliance. 7001 Alameda County Juvenile Justice Center JH Targeted PRO 23-24 Page 2 of 21 A453 JUV Targeted PRO eff. 1/2024 (b) ensure that no required services shall be denied Chapter 3, Section 1321, II Policy 2 ⁋ because of insufficient numbers of staff on duty absent exigent circumstances; Per the above policy, absent exigent circumstances, the institutional Supervisor II (ISII) shall ensure that youth are not denied any required services due to insufficient staffing. This regulation has been determined to be noncompliant. BSCC found that, in part, due to low staffing levels, youth who were on Reintegration Safety Plans (RSP), were not receiving the required structured programming services. Noncompliance was also discovered when BSCC staff found that, in part, due to low staffing levels, the facility separated youth into two groups that alternated between being locked in their rooms and being out of their rooms for normal program times. Additional noncompliance was discovered when BSCC staff were made aware that ☐ ☒ ☐ when staffing levels were below required ratios, youth were kept in their rooms for much of the shift and only rotated out of their rooms in groups of two youth for ten or 15-minute intervals during a shift. These practices also result in noncompliance with Section 1354.5, Room Confinement, and 1371, Programs, Recreation, and Exercise. BSCC observed that an ISI and or an ISII are always on-site in the facility. Therefore, BSCC staff provided technical assistance in recommending the utilization of supervisory staff (ISI and ISII) to provide the support needed to ensure the required services in programming for RSP youth. Further technical assistance included, but was not limited to, follow-up training with supervisors, and updating oversight and review procedures for youth on RSP. 7001 Alameda County Juvenile Justice Center JH Targeted PRO 23-24 Page 3 of 21 A453 JUV Targeted PRO eff. 1/2024 (c) have a sufficient number of supervisory level staff to Chapter 3, Section 1321, II Policy 3 ⁋ ensure adequate supervision of all staff members; After reviewing the daily staff schedule and interviews with youth housed at the facility and staff, BSCC staff confirmed that there is an Institutional Supervisor II (ISII) and or an Institutional Supervisor I (ISI) present at the facility on each shift. While the ISII ensures operations are being conducted accordingly during each shift, the facility Superintendent, with the assistance of the Assistant ☒ ☐ ☐ Superintendent, is responsible for the daily overall operations of the facility Monday through Friday during the day shift. At the time of inspection, the facility was budgeted for the following supervisory- level staff: • 1 Superintendent • 1 Assistant Superintendent • 16 Institutional Supervisor Is • 9 Institutional Supervisor IIs (d) have a clearly identified person on duty at all times Chapter 3, Section 1321, II Policy 4 ⁋ who is responsible for operations and activities and has completed the Juvenile Corrections Officer Core The elements of this regulation are Course and PC 832 training; confirmed in the Chief Probation Officer ☒ ☐ ☐ (CPO) Appointment and Qualifications Letter, written by Interim Chief Probation Officer (CPO) Brian Ford, and dated June 4, 2024. (e) have at least one staff member present on each Chapter 3, Section 1321, II Policy 3 (p 3) ⁋ living unit whenever there are youth in the living unit; Through personal observations, as well as through interviews with staff and youth housed at the facility, ACJJC regularly ☒ ☐ ☐ ensures that there is always a staff present in the unit or where a youth is present. Youth are never left unsupervised. (f) have sufficient food service personnel relative to the Chapter 3, Section 1321, III Procedures number and security of living units, including staff Support Staff 2 ⁋ qualified and available to: plan menus meeting nutritional requirements of youth; provide kitchen Food is provided by an outside vendor supervision; direct food preparation and servings; identified as Epicurean Foods conduct related training programs for culinary staff; and maintain necessary records; or, a facility may serve ☒ ☐ ☐ Current food service personnel staffing food that meets nutritional standards prepared by an consists of: outside source; • 1 Food and Support Service Manager • 7 Full-time Food Service Workers 7001 Alameda County Juvenile Justice Center JH Targeted PRO 23-24 Page 4 of 21 A453 JUV Targeted PRO eff. 1/2024 (g) have sufficient administrative, clerical, recreational, Chapter 3, Section 1321, III Procedures medical, dental, mental health, building maintenance, Support Staff 1 and 3 ⁋ transportation, control room, facility security and other support staff for the efficient management of the facility, BSCC staff interviewed medical services and to ensure that youth supervision staff shall not be personnel, education services, and diverted from supervising youth; and, detention staff. We also made personal observations over the course of the inspection week. The agency is fortunate to have such a significant base of collaborative partners and support staff. Behavioral Health staff clinicians operate under the Alameda County Behavioral Health Services. Six Behavioral Health ☒ ☐ ☐ Clinicians and two psychiatrists provide services to the Alameda County Juvenile Justice Center, Secure Youth Treatment Facility (Firm Roots), and Camp Wilmont Sweeney. The nursing staff operates under the University of San Francisco, Children’s Hospital. There are 21 nursing staff personnel available to provide services to the same facilities indicated above. The nursing staff are on-site 24 hours per day, seven days per week. (h) assign sufficient youth supervision staff to provide Chapter 3, Section 1321, II Policy 5 ⁋ continuous wide awake supervision of youth, subject to temporary variations in staff assignments to meet BSCC staff interviewed detention staff and special program needs. Staffing shall be in compliance reviewed housing unit logs, programming with a minimum youth-staff ratio for the following facility schedules, and employee daily schedules. types: At the time of inspection, the facility was budgeted for the following youth supervision staff: ☒ ☐ ☐ • 144 Juvenile Institutional Officers • 18 Institutional Officer Associates Detention staff from Camp Sweeney and from the ACSYTF/ Firm Roots provide additional youth supervision support to the ACJJC. 7001 Alameda County Juvenile Justice Center JH Targeted PRO 23-24 Page 5 of 21 A453 JUV Targeted PRO eff. 1/2024 (1) Juvenile Halls Chapter 3, Section 1321, III Procedures (A) during the hours that youth are awake, one Juvenile Facilities 1 ⁋ wide-awake youth supervision staff member on duty for each 10 youth in detention; Noncompliance was discovered when BSCC staff found that, at times, staffing levels were below the required staffing ratios. During those times, youth were kept in their rooms for much of the shift and only rotated out of their rooms in groups of two youth for ten or 15-minute intervals. ☐ ☒ ☐ The agency is working toward submitting an approved Corrective Action Plan (CAP) to the BSCC that identifies dates of resolution for the noncompliance. At the time of this inspection, there were 45 youths in the ACJJC detention facility, not including the units housing the SB823 SYTF youth (13). (B) during the hours that youth are confined to Chapter 3, Section 1321, III Procedures their room for the purpose of sleeping, one wide- Juvenile Facilities 2 ⁋ awake youth supervision staff member on duty ☒ ☐ ☐ for each 30 youth in detention; (C) at least two wide-awake youth supervision Chapter 3, Section 1321, III Procedures staff members on duty at all times, regardless of Juvenile Facilities 3 ⁋ the number of youth in detention, unless an arrangement has been made for backup support ☒ ☐ ☐ services which allow for immediate response to emergencies; and, (D) at least one youth supervision staff member Chapter 3, Section 1321, III Procedures on duty who is the same gender as youth Juvenile Facilities 4 ⁋ housed in the facility. According to shift schedules, the housing unit logs, visual observations, and interviews with staff and youth, there is always a male and female youth supervision staff in the facility. To ensure ☒ ☐ ☐ compliance, BSCC staff suggested indicating, on the unit schedule, the gender (M/F) of the staff working in a particular housing unit. At the time of this inspection, there were 13 female youth detained at the ACJJC. (E) personnel with primary responsibility for Chapter 3, Section 1321, III Procedures other duties such as administration, supervision Support Staff 1 ⁋ of personnel, academic or trade instruction, clerical, kitchen or maintenance shall not be The above policy identifies the roles and classified as youth supervision staff positions. ☒ ☐ ☐ responsibilities of staff who are not deemed youth supervision staff. Only youth supervision staff provide supervision of the youth. (2) Special Purpose Juvenile Halls The Alameda County Juvenile Justice (A) during hours that youth are awake, one wide- Center is not a Special Purpose Juvenile awake youth supervision staff member on duty ☐ ☐ ☒ Hall. The below sections A through E are for each 10 youth in detention; not applicable to this facility. 7001 Alameda County Juvenile Justice Center JH Targeted PRO 23-24 Page 6 of 21 A453 JUV Targeted PRO eff. 1/2024 (B) during the hours that youth are confined to their room for the purpose of sleeping, one wide- awake youth supervision staff member on duty ☐ ☐ ☒ for each 30 youth in detention; (C) at least two wide-awake youth supervision staff members on duty at all times, regardless of the number of youth in detention, unless an arrangement has been made for backup support ☐ ☐ ☒ services which allow for immediate response to emergencies; and, (D) at least one youth supervision staff member on duty who is the same gender as youth ☐ ☐ ☒ housed in the facility. (E) personnel with primary responsibility for other duties such as administration, supervision of personnel, academic or trade instruction, ☐ ☐ ☒ clerical, kitchen or maintenance shall not be classified as youth supervision staff positions. (3) Camps The Alameda County Juvenile Justice (A) during the hours that youth are awake, one Center is not a Camp. Therefore, the wide-awake youth supervision staff member on ☐ ☐ ☒ below camp sections A through F are not duty for each 15 youth in the camp population; applicable to this facility. (B) during the hours that youth are confined to their room for the purpose of sleeping, one wide- awake youth supervision staff member on duty ☐ ☐ ☒ for each 30 youth present in the facility; (C) at least two wide-awake youth supervision staff members on duty at all times, regardless of the number of youth in residence, unless arrangements have been made for backup ☐ ☐ ☒ support services which allow for immediate response to emergencies; (D) at least one youth supervision staff member on duty who is the same gender as youth ☐ ☐ ☒ housed in the facility; (E) in addition to the minimum staff to youth ratio required in (h)(3)(A)-(B), consideration shall be given to the size, design, and location of the camp; types of youth committed to the camp; ☐ ☐ ☒ and the function of the camp in determining the level of supervision necessary to maintain the safety and welfare of youth and staff; (F) personnel with primary responsibility for other duties such as administration, supervision of personnel, academic or trade instruction, clerical, farm, forestry, kitchen or maintenance ☐ ☐ ☒ shall not be classified as youth supervision staff positions. 7001 Alameda County Juvenile Justice Center JH Targeted PRO 23-24 Page 7 of 21 A453 JUV Targeted PRO eff. 1/2024 1328 SAFETY CHECKS Chapter 3, Section 1328 III Policy 1 0B ⁋ The facility administrator shall develop and implement BSCC staff reviewed safety checks for the policy and procedures that provide for direct visual first ten days of March, April, and May of observation of youth at a minimum of every 15 2024. We also reviewed random video minutes, at random or varied intervals during hours surveillance recordings showing safety when youth are asleep or when youth are in their checks. rooms, confined in holding cells or confined to their bed in a dormitory. Supervision is not replaced, but In review, documentation on the safety may be supplemented by, an audio/visual electronic check forms was inconsistent in the surveillance system designed to detect overt, comment section that identified when a aggressive or assaultive behavior and to summon aid particular youth was in his/her room and at in emergencies. All safety checks shall be ☒ ☐ ☐ what point the same youth was allowed documented with the actual time the check is out of his/her room. completed. To maintain ongoing compliance, the BSCC discussed the importance of providing standard and detailed documentation in identifying the youth that remains in his/her room. In addition, the agency should work to ensure that supervisory staff are meeting facility expectations by periodically auditing safety checks. 7001 Alameda County Juvenile Justice Center JH Targeted PRO 23-24 Page 8 of 21 A453 JUV Targeted PRO eff. 1/2024 1354.5 ROOM CONFINEMENT Chapter 5, Section 1354.5 Room 1B Confinement (RC) and Reintegration and (a) The facility administrator shall develop and Safety Plan. implement written policies and procedures addressing the confinement of youth in their room that are BSCC staff reviewed 15 examples of room consistent with Welfare and Institutions Code Section confinement documentation that occurred 208.3. The placement of a youth in room confinement between March, April, and May of 2024. shall be accomplished in accordance with the BSCC staff also interviewed the youth following guidelines: housed at the facility, detention staff, education personnel, and the behavioral and mental health partners that work within the facility. The facility reported the following number of room confinements for the below ☒ ☐ ☐ months of 2024: • March (15) • April (16) • May (17) The reported room confinement was not consistent with observations made by BSCC staff. Multiple subsections of this regulation were found to be noncompliant. The agency is working toward submitting an approved Corrective Action Plan (CAP) to BSCC that identifies dates of resolution for the noncompliance discovered. (1) Room confinement shall not be used before Chapter 5, Section 1354.5 II Policy 2 (p. ⁋ other, less restrictive, options have been 2) attempted and exhausted, unless attempting those Chapter 5, Section 1354.5 IV Procedure A options poses a threat to the safety or security of Room Confinement any youth or staff. The facility was determined to be noncompliant with this subsection. BSCC ☐ ☒ ☐ staff found that ACJJC youth on Reintegration Safety Plans (RSP) were placed in their rooms for extended periods when the high-risk level of safety and security was no longer evident and or not documented as such. (2) Room confinement shall not be used for the Chapter 5, Section 1354.5 II Policy 2 (p. ⁋ purposes of punishment, coercion, convenience, 1) or retaliation by staff. Noncompliance was discovered when BSCC staff found that, at times, staffing levels were below the required staffing ratios. During those times, youth were kept in their rooms for much of the shift and only rotated out of their rooms in ☐ ☒ ☐ groups of two youth for ten or 15-minute intervals. Noncompliance was also discovered when BSCC staff found that, in part, due to low staffing levels, the facility separated youth into two groups that alternated between being locked in their rooms and being out of their rooms for normal program times. 7001 Alameda County Juvenile Justice Center JH Targeted PRO 23-24 Page 9 of 21 A453 JUV Targeted PRO eff. 1/2024 (3) Room confinement shall not be used to the Chapter 5, Section 1354.5 II Policy 3 (p. ⁋ extent that it compromises the mental and physical 2) ☒ ☐ ☐ health of the youth. (b) A youth may be held up to four hours in room The facility uses the following confinement. After the youth has been held in room documentation tools to help track and log confinement for a period of four hours, staff shall do room confinement, which include, but are one or more of the following: not limited to: ☒ ☐ ☐ • Room Confinement Checklist • Unit Logbook • Reintegration and Safety Plan Chapter 5, Section 1354.5 III Procedure A- 1 and 2 JIO and ISI Responsibilities Per policy, youth are assessed a minimum of every 15 minutes by staff and 45 minutes by the supervisor, to ascertain the youth’s ability to return to regular programming, with or without a reintegration plan. BSCC staff found that the facility is not (1) Return the youth to general population. ☐ ☒ ☐ following its policy for room confinement and youth on RSP programming. BSCC staff found that the facility is noncompliant as youth on RSP were required to eat meals in their rooms and remain in their rooms during school hours for educational services; there was no documented justification of risk to safety and security for these youth to remain in their locked rooms. Chapter 5, Section 1354.5 III Procedure (2) Consult with mental health or medical staff. C-1 ☒ ☐ ☐ (3) Develop an individualized plan that includes the Chapter 5, Section 1354.5 III Procedure C goals and objectives to be met in order to 2 ⁋ reintegrate the youth to general population. Individualized plans are identified as Reintegration Safety Plans (RSP). BSCC ☒ ☐ ☐ staff provided technical assistance to the facility recommending that supervisors are properly trained on the use and intent of the RSP. 7001 Alameda County Juvenile Justice Center JH Targeted PRO 23-24 Page 10 of 21 A453 JUV Targeted PRO eff. 1/2024 (4) If room confinement must be extended beyond Chapter 5, Section 1354.5 III Procedure C four hours, staff shall do each of the following: (A) Document the reasons for room Chapter 5, Section 1354.5 III Procedure C- confinement and the basis for the extension, 2, 3 and 4 the date and time the youth was first placed in room confinement, and when he or she is The policies articulate the incident reports, eventually released from room confinement. the Reintegration Plan, and Room Confinement checklists to be completed, reviewed, and audited by the ☐ ☒ ☐ administration. Noncompliance was discovered when BSCC staff found that, at times, staffing levels were below the required staffing ratios. During those times, youth were kept in their rooms for much of the shift and only rotated out of their rooms in groups of two youth for ten or 15-minute intervals. (B) Develop an individualized plan that includes Chapter 5, Section 1354.5 III Procedure C ⁋ the goals and objectives to be met in order to 4 and # 2 integrate the youth to general population. The Institutional Supervisor II notifies the Guidance Clinic and requests assistance in the development of a Reintegration Plan. ☒ ☐ ☐ Individualized plans are identified as Reintegration Safety Plans (RSP). BSCC staff provided technical assistance to the facility recommending that supervisors are properly trained on the use and intent of the RSP, and that the facility follow its policy and procedures regarding the RSP. (C) Obtain documented authorization by the Chapter 5, Section 1354.5 IV-A, 4 facility superintendent or his or her designee ☒ ☐ ☐ every four hours thereafter. (5) This section is not intended to limit the use of Chapter 5, Section 1354.5 III Procedure B- single-person rooms or cells for the housing of 2 (p. 7) youth in juvenile facilities and does not apply to ☒ ☐ ☐ normal sleeping hours. (6) This section does not apply to youth or wards Chapter 5, Section 1354.5 III Procedure B- in court holding facilities or adult facilities. 2 (p. 7) ☒ ☐ ☐ This facility is not either a court-holding Facility or an Adult Facility. (7) Nothing in this section shall be construed to Chapter 5, Section 1354.5 III Procedure B- conflict with any law providing greater or additional 1 (p. 7) ☒ ☐ ☐ protections to youth. (8) This section does not apply during an Chapter 5, Section 1354.5 III Procedure B- extraordinary emergency circumstance that 3 (p. 7) requires a significant departure from normal institutional operations, including a natural disaster or facility-wide threat that poses an imminent and ☒ ☐ ☐ substantial risk of harm to multiple staff or youth. This exception shall apply for the shortest amount of time needed to address this imminent and substantial risk of harm. 7001 Alameda County Juvenile Justice Center JH Targeted PRO 23-24 Page 11 of 21 A453 JUV Targeted PRO eff. 1/2024 (9) This section does not apply when a youth is Chapter 5, Section 1354.5 III Procedure B- placed in a locked cell or sleeping room to treat 4 (p. 7) and protect against the spread of a communicable disease for the shortest amount of time required to reduce the risk of infection, with the written approval of a licensed physician or nurse practitioner, when the youth is not required to be in an infirmary for an illness. Additionally, this section ☒ ☐ ☐ does not apply when a youth is placed in a locked cell or sleeping room for required extended care after medical treatment with the written approval of a licensed physician or nurse practitioner, when the youth is not required to be in an infirmary for illness. 1357 USE OF FORCE Chapter 5, Section 1357 Use of Force Chapter 5, Section 1357 II Policy 2 (p. 2) The facility administrator, in cooperation with the ⁋ responsible physician, shall develop and implement Chapter 5, Section 1357 II Policy Last ⁋ written policies and procedures for the use of force, (p.3) which may include chemical agents. Force shall never Policy Development with the be applied as punishment, discipline, retaliation or Superintendent and responsible physician. treatment. (a) At a minimum, each facility shall develop policies BSCC staff reviewed Use of Force and procedures which: documentation for the months of March, April, and May 2024 and or the most recent 15 examples from each facility showing procedural and incident reports documentation for this regulation. We also ☒ ☐ ☐ interviewed youth housed at the Facility, facility detention staff, and collaborative partners to gain further insight and confirm compliance with this regulation. The facility reported the following number of use-of-force incidents for the following months of 2024: • March (11) • April (10) • May (2) (1) restricts the use of force to that which is deemed Chapter 5, Section 1357 II Policy 2 (p. 2) ⁋ reasonable and necessary, as defined in Section 1302 to ensure the safety and security of youth, ☒ ☐ ☐ staff, others and the facility. (2) outline the force options available to staff Chapter 5, Section 1357, IV Procedures including both physical and non-physical options Intervention Options and define when those force options are ☒ ☐ ☐ appropriate. 7001 Alameda County Juvenile Justice Center JH Targeted PRO 23-24 Page 12 of 21 A453 JUV Targeted PRO eff. 1/2024 (3) describe force options or techniques that are Chapter 5, Section 1357, IV Procedures expressly prohibited by the facility. Prohibited Actions ACJJC force options that are prohibited include, but are not limited to, the below: • Alternate Restraint Device • Choke Holds • Hogtie ☒ ☐ ☐ ACJJC force options that are allowed include, but are not limited to, the below: • Oleoresin Capsicum (OC) • Mechanical Restraints • Physical Intervention • Leg Shackles (4) describe the requirements of staff to report any Chapter 5, Section 1357 II Policy Last ⁋ inappropriate use of force, and to take affirmative (p.2) ☒ ☐ ☐ action to immediately stop it. (5) define a standardized reporting format that Chapter 5, Section 1357 IV Procedure includes time period and procedure for Follow-up to a Use of Force Incident A documenting and reporting the use of force, Debriefing (p.20) and B. Documentation including reporting requirements of management (p. 11) and line staff and procedures for reviewing and tracking use of force incidents by supervisory and A review of incident reports requested or management staff, which include procedures for shows that ACJJC documents and reports debriefing a particular incident with staff and/or ☒ ☐ ☐ incidents in accordance with Title 15 youth for the purposes of training as well as minimum standards. mitigating the effects of trauma that may have been experienced by staff and /or the youth involved. If questions or concerns are present, an audio-video surveillance review of the incident will be conducted as part of the debrief. (6) Include an administrative review and a system Chapter 5, Section 1357 IV Procedure for investigating unreasonable use of force. Unnecessary or Excessive Use of Force and Administrative Review (p. 13) Through a review of the Use of Force incident reports, BSCC staff observed that incidents are reviewed by senior staff and administrators at five levels to determine whether the force was within policy. The ☒ ☐ ☐ ISII provides a final analysis and debrief of the incident. Comprehensively, the agency has an Employee Use of Force Review Committee (EUFRC) which meets monthly to review every use of force incident. There is also a Use of Force Coordinator. 7001 Alameda County Juvenile Justice Center JH Targeted PRO 23-24 Page 13 of 21 A453 JUV Targeted PRO eff. 1/2024 (7) define the role, notification, and follow-up Chapter 5, Section 1357 IV Procedure procedures required after use of force incidents for Required Notifications: A. Medical Staff medical, mental health staff and parents or legal and Behavior Health Clinicians; and B guardians. Parents/Guardians (p. 8) BSCC staff interviewed supervisory, detention, and medical and behavioral health staff to help determine compliance with the elements of this regulation. ☒ BSCC staff discussed with the facility staff ☐ ☐ that to maintain compliance when use-of- force incidents occur, the agency must be able to provide substantiation that a youth’s parent(s) was notified. We discussed favorable outcomes when parent notification duties are assigned to the supervisor (ISI or ISII) working the shift that the incident occurred on and ensure confirmation is documented in a standard area of the report. (8) describe the limitations of use of force on Chapter 5, Section 1357, IV Procedures pregnant youth in accordance with Penal Code Prohibited Actions Bullet 4 and 2 ⁋ Section 6030(f) and Welfare and Institutions Code ☒ ☐ ☐ Section 222. Policy 514 Use of Force Policy 515 Restraints (b) Facilities that authorize chemical agents as a force Chapter 5, Section 1357.2 Use of option shall include policies and procedures that: Chemical Intervention (1) identify who is approved to carry and/or utilize Chapter 5, Section 1357.2 II Policy 2 ⁋ chemical agents in the facility and the type, size and ☒ ☐ ☐ Chapter 5, Section 1357.2 III Procedure the approved method of deployment for those Staff Authorized to Carry and Use OC chemical agents. Spray (p. 3) (2) mandate that chemical agents only be used Chapter 5, Section 1357.2 II Policy 4 (p. ⁋ when there is an imminent threat to the youth’s 2) safety or the safety of others and only when de- Chapter 5, Section 1357.2 III Procedure escalation efforts have been unsuccessful or are Criteria for Use of OC (p. 5) not reasonably possible. We reviewed the policy and interviewed ☒ ☐ ☐ JIOs, ISIs, and ISIIs to determine that ACJJC meets compliance with Title 15 minimum standards for this regulation. We also interviewed youth housed at the facility. (3) outline the facility’s approved methods and Chapter 5, Section 1357.2 III Procedure timelines for decontamination from chemical Decontamination Process (p. 8) agents. This shall include that youth who have been exposed to chemical agents shall not be left BSCC staff reviewed incident reports, ☒ ☐ ☐ unattended until that youth is fully decontaminated interviewed medical staff, and interviewed or is no longer suffering the effects of the chemical youth housed at the facility. agent. 7001 Alameda County Juvenile Justice Center JH Targeted PRO 23-24 Page 14 of 21 A453 JUV Targeted PRO eff. 1/2024 (4) define the role, notification, and follow-up Chapter 5, Section 1357.2 III Procedure procedures required after use of force incidents Decontamination Process #3 and #9 involving chemical agents for medical, mental Chapter 5, Section 1357 IV Procedure health staff and parents or legal guardians. Required Notifications A and B BSCC staff discussed with the facility that to maintain compliance when use-of-force incidents occur, the agency must be able ☒ ☐ ☐ to ensure consistency by documenting that a youth’s parent(s) was notified. We discussed favorable outcomes when parent notification duties are assigned to the supervisor (ISI or ISII) working the shift that the incident occurred on and ensure confirmation is documented in a standard area of the report. (5) provide for the documentation of each incident Chapter 5, Section 1357.2 III Procedure of use of chemical agents, including the reasons Documentation Process (p. 9) for which it was used, efforts to de-escalate prior to use, youth and staff involved, the date, time and BSCC staff observed that the facility location of use, decontamination procedures ☒ ☐ ☐ utilizes a “Use of Oleoresin Capsicum applied and identification of any injuries sustained (OC)” Form. In part, the form provides de- as a result of such use. escalation efforts, witnesses, and supervisory review. (c) Facilities shall develop policies and procedure Chapter 5, Section 1357 IV Procedures which require that agencies provide initial and regular Training (p. 22) training in use of force and chemical agents when Chapter 5, Section 1357.2 III Procedure appropriate that address: Staff Authorized to Carry and Use OC Spray (p. 3) # 2 (Training Prerequisites) and #3 (Annual Training) Chapter 5, Section 1357 IV Procedures (1) known medical and behavioral health ☒ ☐ ☐ Training (p. 22) Bullet 1 conditions that would contraindicate certain types of force; The elements of this regulation are confirmed in the Chief Probation Officer (CPO) Appointment and Qualifications Letter, written by Interim Chief Probation Officer (CPO) Brian Ford, and dated June 4, 2024. (2) acceptable chemical agents and the methods Chapter 5, Section 1357 IV Procedures of application. ☒ ☐ ☐ Training (p. 22) Bullet 2 (3) signs or symptoms that should result in Chapter 5, Section 1357 IV Procedures immediate referral to medical or behavioral health. ☒ ☐ ☐ Training (p. 22) Bullet 3 (4) instruction on the Constitutional Limitations of Chapter 5, Section 1357 IV Procedures Use of Force. ☒ ☐ ☐ Training (p. 22) Bullet 4 (5) physical training force options that may require Chapter 5, Section 1357 IV Procedures the use of perishable skills. Training (p. 22) Bullet 5 The elements of this regulation are confirmed in the Chief Probation Officer ☒ ☐ ☐ (CPO) Appointment and Qualifications Letter, written by Interim Chief Probation Officer (CPO) Brian Ford, and dated June 4, 2024. (6) timelines the facility uses to define regular Chapter 5, Section 1357.2 III, Procedure training. Staff Authorized to Carry and Use OC ☒ ☐ ☐ Spray (p. 3) #3 Annual Training after Initial Training 7001 Alameda County Juvenile Justice Center JH Targeted PRO 23-24 Page 15 of 21 A453 JUV Targeted PRO eff. 1/2024 1361 GRIEVANCE PROCEDURE Chapter 5, Section 1361 Grievances The facility administrator shall develop and implement BSCC staff reviewed grievances for written policies and procedures whereby any youth January through May 2024, and the may appeal and have resolved grievances relating to Grievance Log covering the past six any condition of confinement, including but not limited months. This included due process to health care services, classification decisions, documentation. program participation, telephone, mail or visiting procedures, food, clothing, bedding, mistreatment, BSCC staff also interviewed youth housed harassment or violations of the nondiscrimination at the facility, detention staff, health policy. There shall be no time limit on filing grievances. services, behavior health, and education Policies and procedures shall include provisions services collaborative partners. whereby the facility manager ensures: ☒ ☐ ☐ BSCC staff observed that the agency has incorporated, to youth, supplemental access to grievances through tablets that are individually assigned to youth and allowed to be kept in their rooms. Although it is viewed as a favorable option, BSCC staff provided technical assistance by recommending updating the grievance policy and procedure, as well as, the youth orientation handbook, to include expectations and processes for filing a grievance via the tablets. (a) a grievance form and instructions for registering a Chapter 5, Section 1361 IV Procedure grievance, which includes provisions for the youth to Filing a Grievance 1 ⁋ have free access to the form; During our physical inspection, we observed that grievances were readily available to youth. In addition, grievance ☒ ☐ ☐ lock boxes were in the housing pods to allow youth to confidentially submit a grievance if needed. Also, filing a grievance via individually assigned tablets has been incorporated into the grievance process. (b) the youth shall have the option to confidentially file Chapter 5, Section 1361 IV Procedure the grievance or to deliver the form to any youth Filing a Grievance 1 ⁋ supervision staff working in the facility; The youth were aware of the grievance ☒ ☐ ☐ procedures, the location of the grievances, and the grievance lockbox to confidentially file a grievance, if needed. (c) resolution of the grievance at the lowest Chapter 5, Section 1361 IV Procedure appropriate staff level; Staff Responsibilities #1 IS1 ☒ ☐ ☐ The Institution Supervisor I is identified as the lowest staff level via policy and labor relations. 7001 Alameda County Juvenile Justice Center JH Targeted PRO 23-24 Page 16 of 21 A453 JUV Targeted PRO eff. 1/2024 (d) provision for a prompt review and initial response Chapter 5, Section 1361 IV Procedure to grievances within three (3) business days, Grievance Timeframes. grievances that relate to health and safety issues must be addressed immediately; Per policy, below is the response process for grievances: • ISI to respond by the end of the shift on the day it was received • ISII to respond if not resolved by the end of the shift on the day received • Assistant Supt/Manager must respond within 72 hours of receipt ☒ ☐ ☐ BSCC reviewed grievances for the months of January through May of 2024 and reviewed the Grievance Log for the past six months. The facility does well in ensuring a prompt review and initial response is provided within three business days. With the implementation of the tablets as an option to submit a grievance, BSCC staff discussed the importance of ensuring that response timelines remain consistent with policy and Title 15 Regulations. (1) The youth may elect to be present to explain Chapter 5, Section 1361 IV Procedure his/her version of the grievance to a person not Filing a Grievance 3 ⁋ directly involved in the circumstances which led to the grievance. The youth interviewed indicated that ☒ ☐ ☐ during the intake and orientation process, the grievance procedure was clearly explained. (2) Provision for a staff representative approved by Chapter 5, Section 1361 IV Procedure the facility administrator to assist the youth. ☒ ☐ ☐ Filing a Grievance 2 ⁋ (e) provision for a written response to the grievance Chapter 5, Section 1361 IV Procedure which includes the reasons for the decisions; Filing a Grievance 3 ⁋ ☒ ☐ ☐ The documentation as well as interviews show that detention staff respond professionally. (f) a system which provides that any appeal of a Chapter 5, Section 1361 IV Procedure grievance shall be heard by a person not directly Staff Responsibilities involved in the circumstances which led to the ☒ ☐ ☐ grievance; (g) resolution of the grievance must occur within ten Chapter 5, Section 1361 IV Procedure (10) business days unless circumstances dictate a Grievance Timeframes 7 (p. 6) ⁋ longer time frame. The youth shall be notified of any delay; and, ☒ ☐ ☐ The documentation as well as interviews show that detention staff respond to grievances in a timely fashion. (h) the policy shall provide multiple internal and Chapter 5, Section 1361 IV Procedure external methods to report sexual abuse and sexual Reporting Sexual Abuse and Sexual ☒ ☐ ☐ harassment. Harassment Whether or not associated with a grievance, concerns Chapter 5, Section 1361 IV Procedure of parents, guardians, staff or other parties shall be Grievance Timeframes Last (p. 7) ⁋ addressed and documented in accordance with ☒ ☐ ☐ written policies and procedures within a specified timeframe. 7001 Alameda County Juvenile Justice Center JH Targeted PRO 23-24 Page 17 of 21 A453 JUV Targeted PRO eff. 1/2024 1371 PROGRAMS, RECREATION, AND Chapter 6, Section 1371 2B EXERCISE. The facility’s policy and procedures are The facility administrator shall develop and implement applicable to the elements of this written policies and procedures for programs, regulation as required. recreation, and exercise for all youth. The intent is to minimize the amount of time youth are in their rooms BSCC staff reviewed the facility’s or their bed area. Programs, Exercise, and Recreation policy and procedure. We also reviewed pertinent documentation that covered the first 15 days of March, April, and May 2024. The documentation included, but ☒ ☐ ☐ was not limited to program logs, and program entries in shift reports indicating programming offered to all youth. The facility was found to be noncompliant with multiple subsections of this regulation. The agency is working toward submitting an approved Corrective Action Plan (CAP) to BSCC that identifies dates of resolution for the noncompliance discovered. Juvenile facilities shall provide the opportunity for Chapter 6, Section 1371 II Policy 1 ⁋ programs, recreation, and exercise a minimum of three hours a day during the week and five hours a BSCC staff found that youth on RSP were day each Saturday, Sunday or other non-school days, not consistently provided the required of which one hour shall be an outdoor activity, weather programs, recreation, and exercise when permitting. the high-risk level of safety and security no longer existed or was reduced. RSP youth were not consistently provided an hour each of programming, exercise, and recreation. ☐ ☒ ☐ BSCC staff found the noncompliance to be, in part, due to staffing challenges and the lack of training for detention staff to utilize the RSP as intended in policy and regulation. BSCC staff provided technical assistance in recommending that supervisory staff be trained accordingly. Additionally, to ensure staffing levels are sufficient for all required services to youth. 7001 Alameda County Juvenile Justice Center JH Targeted PRO 23-24 Page 18 of 21 A453 JUV Targeted PRO eff. 1/2024 A youth’s participation in programs, recreation, and Chapter 6, Section 1371 II Policy 3 ⁋ exercise may be suspended only upon a written finding by the administrator/manager or designee that BSCC staff reviewed the program tracker a youth represents a threat to the safety and security document for the months of March, April, of the facility. and May of 2024. We also interviewed a youth. BSCC staff discovered noncompliance with this subsection of the regulation. BSCC staff found that youth on Reintegration Safety Plans (RSP) are not consistently provided equity in programming requirements when the high level of safety risk and security no longer exist to the extent of suspending programming requirements. Specifically, RSP youth were not consistently receiving one hour of structured programming daily. The facility acknowledges that the ☐ ☒ ☐ noncompliance is, in part, attributed to a deficiency in ACJJC detention personnel staffing. As a result, the facility was found to be noncompliant with Title 15, Section, 1321 Staffing, and Section, 1354.5 Room Confinement. Additionally, BSCC staff observed inconsistencies with the use of the program tracker being utilized as intended in policy to track all youth programming, including youth on RSP. BSCC staff provided technical assistance for the facility to provide all detention staff with training in the use of the program tracker and to ensure supervisory staff review the program tracker periodically throughout each shift. Such program, recreation, and exercise schedule Chapter 6, Section 1371 III Procedures shall be posted in the living units. Staff Responsibility 1 ⁋ ☒ ☐ During the physical inspection of both ☐ facilities, BSCC observed program and recreation schedule calendars posted in the living units. There will be a written annual review of the programs, Chapter 6, Section 1371 II Policy 5 ⁋ recreation, and exercise by the responsible agency to ensure content offered is current, consistent, and A letter dated May 31, 2024, written by relevant to the population. Superintendent John Ebrahimi provides confirmation that an annual review of the ☒ ☐ ☐ programs, recreation, and exercise by the responsible agency was conducted to ensure content offered is current, consistent, and relevant to the population. 7001 Alameda County Juvenile Justice Center JH Targeted PRO 23-24 Page 19 of 21 A453 JUV Targeted PRO eff. 1/2024 (a) Programs. All youth shall be provided with the Chapter 6, Section 1371 III Procedure opportunity for at least one hour of daily programming Programming, 1-18 (p. 3) to include, but not be limited to, trauma focused, cognitive, evidence-based, best practice interventions Noncompliance was identified with this that are culturally relevant and linguistically subsection of the regulation. BSCC staff appropriate, or pro-social interventions and activities found that youth on RSP were not designed to reduce recidivism. These programs consistently provided the required should be based on the youth’s individual needs as programs, recreation, and exercise when required by Sections 1355 and 1356. Such programs the high-risk level of safety and security no may be provided under the direction of the Chief longer existed or was reduced. RSP youth Probation Officer or the County Office of Education and were not receiving one hour of structured can be administered by county partners such as mental programming daily and did not health agencies, community based organizations, consistently receive an hour each of faith-based organizations or Probation staff. programming, exercise, and recreation. Programs may include but are not limited to: (1) Cognitive Behavior Interventions; BSCC staff reviewed the facility’s (2) Management of Stress and Trauma; Programs, Exercise, and Recreation policy (3) Anger Management; and procedure. We also reviewed (4) Conflict Resolution; pertinent documentation that covered the (5) Juvenile Justice System; first 15 days of March, April, and May (6) Trauma-related interventions; 2024. The documentation included, but (7) Victim Awareness; was not limited to program logs, and (8) Self-Improvement; program entries in shift reports indicating (9) Parenting Skills and support; programming offered to all youth. We also ☐ ☒ ☐ (10) Tolerance and Diversity; interviewed youth housed at the facility, (11) Healing Informed Approaches; detention staff, behavioral health staff, and (12) Interventions by Credible Messengers; education service staff. (13) Gender Specific Programming; (14) Art, creative writing, or self-expression; ACJJC offers programs including, but not (15) CPR and First Aid training; limited to the following: (16) Restorative Justice or Civic Engagement; (17) Career and leadership opportunities; and, • Aggression Replacement Training (18) Other topics suitable to the youth population. • Beat Within • La Familia (Substance Abuse Education • Niroga/Yoga (Mind, Body, Wellness • Junior College program • Education Program (SEEP) for High School Graduates • Skillsoft (developing work readiness skills) • Ted Talks • American Data Prison Systems Tablets Applications • Deputy Sheriff Athletic League • MC3 Tech/Construction Program (b) Recreation. All youth shall be provided the Chapter 6, Section 1371 III Procedure opportunity for at least one hour of daily access to Recreation (p. 4) unscheduled activities such as leisure reading, letter writing, and entertainment. Activities shall be ☒ ☐ ☐ supervised and include orientation and may include coaching of youth. (c) Exercise. All youth shall be provided with the Chapter 6, Section 1371 III Procedure opportunity for at least one hour of large muscle activity Large Muscle Exercise (p. 5) each day. ☒ ☐ ☐ 7001 Alameda County Juvenile Justice Center JH Targeted PRO 23-24 Page 20 of 21 A453 JUV Targeted PRO eff. 1/2024 The administrator/manager may suspend, for a period Chapter 6, Section 1371 III Procedure not to exceed 24 hours, access to recreation and Last (p. 4) ⁋ programs. The administrator/manager shall document ☒ ☐ ☐ the reasons why suspension of recreation and programs occurs. 7001 Alameda County Juvenile Justice Center JH Targeted PRO 23-24 Page 21 of 21 A453 JUV Targeted PRO eff. 1/2024 JUVENILE HALLS, SPECIAL PURPOSE JUVENILE HALLS AND CAMPS Board of State and Community Corrections PROCEDURES CHECKLIST1 BSCC Code: 7002 FACILITY NAME: Alameda Secure Youth Treatment Facility (Firm Roots FACILITY TYPE: SYTF Academy) PERSON(S) INTERVIEWED: Chief Probation Officer (Interim), Brian Ford; Shauna Conner, Deputy Chief Probation Officer (Juvenile Facilities); John Ebrahimi, Superintendent-JH; Julie Marques, Assistant Superintendent-JH; Albert Banuelos, Superintendent- Camp Sweeney; Richard Valle, Institutional Supervisor II (ISII); Esmeralda Pulido, Juvenile Institutional officer (JIO); Michael Postell Behavioral Health Clinician; Ray Nickaloff, Food Service Manager; Arthur Hogenauer; Christie Aganon, RN; Andrea Parish, Health Services Executive Director; Male youth age 17; Male youth 17; Random youth during physical facility inspection. FIELD REPRESENTATIVE: Forrest Coleman DATE: June 3rd through June 11th, 2024 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS 1321 STAFFING Chapter 3, Section 1321, II Policy 1 ⁋ JH: Chapter 3, Section 1322.18, III Staffing Each juvenile facility shall: (a)have an adequate number of personnel sufficient to The Alameda County Secure Youth carry out the overall facility operation and its Treatment Facility (ACSYTF), newly named programming, to provide for safety and security of the Firm Roots Academy, is a facility youth and staff, and meet established standards and located within the Alameda County Juvenile regulations; Justice Center (ACJJC) complex. Additionally, Camp Sweeney (CS) is a detention camp located on the same campus and adjacent to the ACJJC complex. The ACSYTF, the Camp, and the ACJJC conduct staff training together. Cross-training the staff provides an opportunity to utilize staff from either facility if needed. Further, the ACSYTF and Camp Sweeney abide by the same ACJJC ☐ ☒ ☐ policies and procedures, as well as the Title 15 regulations including, but not limited to, staffing and training qualifications. BSCC staff reviewed the above policies and procedures, as well as, the agency’s Organization Chart, random weekly staff schedules, and daily unit schedule covering the first eight days of March, April, and May of 2024. Additionally, we made personal observations and interviewed youth housed at the facility, collaborative partners, and detention staff. Noncompliance was discovered when BSCC staff found that when staffing levels were low, the facility separated youth into 1 This document is intended for use as a tool during the targeted inspection process; this worksheet may not contain each Title 15 regulation that is required. Additionally, many regulations on this worksheet are SUMMARIES of the regulation; the text on this worksheet may not contain the entire text of the actual regulation. Please refer to the complete California Code of Regulations, Title 15, Minimum Standards for Juvenile Facilities, Division 1, Chapter 1, Subchapter 5 for the complete list and text of regulations. 7002 Alameda Secure Youth Treatment Facility SYTF PRO 23-24 Page 1 of 17 A453 JUV Targeted PRO eff. 1/2024 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS two groups that alternated between being locked in their rooms and being out of their rooms for normal program times. Additional noncompliance was discovered when BSCC staff were made aware that when staffing levels were low, youth were kept in their rooms for much of the shift and only rotated out of their rooms in groups of two youth for 10 and or 15- minute intervals during a shift. This practice also results in noncompliance with Section 1354.5, Room Confinement, and 1371, Programs, Recreation, and Exercise. The agency is working toward submitting an approved Corrective Action Plan (CAP) to BSCC that identifies dates of resolution for the noncompliance. (b) ensure that no required services shall be denied Chapter 3, Section 1321, II Policy 2 ⁋ because of insufficient numbers of staff on duty absent exigent circumstances; Per the above policy, absent exigent circumstances, the institutional Supervisor II (ISII) shall ensure that youth are not denied any required services due to insufficient staffing. This regulation has been determined to be noncompliant. BSCC found that, in part, due to low staffing levels, youth who were on Reintegration Safety Plans (RSP), were not receiving the required structured programming services. Noncompliance was also discovered when BSCC staff found that, in part, due to low staffing levels, the facility separated youth into two groups that alternated between being locked in their rooms and being out ☐ ☒ ☐ of their rooms for normal program times. Additional noncompliance was discovered when BSCC staff were made aware that when staffing levels were below required ratios, youth were kept in their rooms for much of the shift and only rotated out of their rooms in groups of two youth for ten and or 15-minute intervals during a shift. These practices also result in noncompliance with Section 1354.5, Room Confinement, and 1371, Programs, Recreation, and Exercise. BSCC observed that an ISI and or an ISII are always on-site in the facility. Therefore, BSCC staff provided technical assistance in recommending the utilization 7002 Alameda Secure Youth Treatment Facility SYTF PRO 23-24 Page 2 of 17 A453 JUV Targeted PRO eff. 1/2024 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS of supervisory staff (ISI and ISII) to provide the support needed to ensure required services in programming for RSP youth. Further technical assistance included, but was not limited to, follow-up training with supervisors, and updating oversight and review procedures for youth on RSP. (c)have a sufficient number of supervisory level staff to Chapter 3, Section 1321, II Policy 3 ⁋ ensure adequate supervision of all staff members; After reviewing the daily staff schedule, and interviews with youth housed at the facility and staff, BSCC staff confirmed that there is an Institutional Supervisor II (ISII) and or an Institutional Supervisor I (ISI) present at the facility during each shift. While the ISII ensures operations are being conducted accordingly during each shift, the facility Superintendent, with the ☒ ☐ ☐ assistance of the Assistant Superintendent, is responsible for the daily overall operations of the facility Monday through Friday during the day shift. At the time of inspection, the facility, in conjunction with the ACJJC, is budgeted for the following supervisory-level staff: •1 Superintendent •1 Assistant Superintendent •16 Institutional Supervisor Is •9 Institutional Supervisor IIs (d)have a clearly identified person on duty at all times Chapter 3, Section 1321, II Policy 4 ⁋ who is responsible for operations and activities and has completed the Juvenile Corrections Officer Core The elements of this regulation are Course and PC 832 training; confirmed in the Chief Probation Officer ☒ ☐ ☐ (CPO) Appointment and Qualifications Letter, written by Interim Chief Probation Officer (CPO) Brian Ford, and dated June 4, 2024. (e) have at least one staff member present on each Chapter 3, Section 1321, II Policy 3 (p 3) ⁋ living unit whenever there are youth in the living unit; Through personal observations, as well as through interviews with staff and youth housed at the facility, Firm Roots ☒ ☐ ☐ Academy (FRA) regularly ensures that there is always a staff present in the unit or where a youth is present. Youth are never left unsupervised. (f)have sufficient food service personnel relative to the Chapter 3, Section 1321, III Procedures number and security of living units, including staff Support Staff 2 ⁋ qualified and available to: plan menus meeting nutritional requirements of youth; provide kitchen Food is provided by an outside vendor supervision; direct food preparation and servings; ☒ ☐ ☐ identified as Epicurean Foods. conduct related training programs for culinary staff; and maintain necessary records; or, a facility may serve Current food service personnel staffing consists of: 7002 Alameda Secure Youth Treatment Facility SYTF PRO 23-24 Page 3 of 17 A453 JUV Targeted PRO eff. 1/2024 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS food that meets nutritional standards prepared by an •1 Food and Support Service outside source; Manager •7 Full-time Food Service Workers (g)have sufficient administrative, clerical, recreational, Chapter 3, Section 1321, III Procedures medical, dental, mental health, building maintenance, Support Staff 1 and 3 ⁋ transportation, control room, facility security and other support staff for the efficient management of the facility, BSCC staff interviewed medical services and to ensure that youth supervision staff shall not be personnel, education services, and diverted from supervising youth; and, detention staff. We also made personal observations over the course of the inspection week. The agency is fortunate to have such a significant base of collaborative partners and support staff. Behavioral Health staff clinicians operate under the Alameda County Behavioral Health Services. There are six Behavioral ☒ ☐ ☐ Health Clinicians and two psychiatrists who provide services to the Alameda County Juvenile Justice Center, Secure Youth Treatment Facility (Firm Roots Academy), and Camp Wilmont Sweeney. The nursing staff operates under the University of San Francisco, Children’s Hospital. There are 21 nursing staff personnel available to provide services to the same facilities indicated above. The nursing staff are on-site 24 hours per day, seven days per week. (h) assign sufficient youth supervision staff to provide Chapter 3, Section 1321, II Policy 5 ⁋ continuous wide awake supervision of youth, subject to temporary variations in staff assignments to meet BSCC staff interviewed detention staff and special program needs. Staffing shall be in compliance reviewed housing unit logs, programming with a minimum youth-staff ratio for the following facility schedules, and employee daily schedules. types: At the time of inspection, in conjunction with the ACJJC, the facility was budgeted ☒ ☐ ☐ for the following youth supervision staff: •144 Juvenile Institutional Officers •18 Institutional Officer Associates Detention staff from Camp Sweeney and the ACJJC provide additional youth supervision support to the FRA. (1)Juvenile Halls Chapter 3, Section 1321, III Procedures (A) during the hours that youth are awake, one Juvenile Facilities 1 ⁋ wide-awake youth supervision staff member on duty for each 10 youth in detention; Noncompliance was discovered when BSCC staff found that, at times, staffing levels were below the required staffing ☐ ☒ ☐ ratios. During those times, youth were kept in their rooms much of the shift and only rotated out of their rooms in groups of two youth for ten and or 15-minute intervals. 7002 Alameda Secure Youth Treatment Facility SYTF PRO 23-24 Page 4 of 17 A453 JUV Targeted PRO eff. 1/2024 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS The agency is working toward submitting an approved Corrective Action Plan (CAP) to BSCC that identifies dates of resolution for the noncompliance. At the time of this inspection, there were 13 youths in the Firm Roots Academy facility in addition to the 45 youths who were in the Alameda County Juvenile Justice Center detention facility. (B) during the hours that youth are confined to Chapter 3, Section 1321, III Procedures their room for the purpose of sleeping, one wide- Juvenile Facilities 2 ⁋ awake youth supervision staff member on duty ☒ ☐ ☐ for each 30 youth in detention; (C) at least two wide-awake youth supervision Chapter 3, Section 1321, III Procedures staff members on duty at all times, regardless of Juvenile Facilities 3 ⁋ the number of youth in detention, unless an arrangement has been made for backup support ☒ ☐ ☐ services which allow for immediate response to emergencies; and, (D)at least one youth supervision staff member Chapter 3, Section 1321, III Procedures on duty who is the same gender as youth Juvenile Facilities 4 ⁋ housed in the facility. According to shift schedules, the housing unit logs, visual observations, and interviews with staff and youth, there is always a male and female youth supervision staff in the facility. To ensure ☒ ☐ ☐ compliance, BSCC staff suggested indicating, on the unit schedule, the gender (M/F) of the staff working in a particular housing unit. At the time of this inspection, there were zero female youth detained at the FRA. (E) personnel with primary responsibility for Chapter 3, Section 1321, III Procedures other duties such as administration, supervision Support Staff 1 ⁋ of personnel, academic or trade instruction, clerical, kitchen or maintenance shall not be The above policy identifies the roles and classified as youth supervision staff positions. ☒ ☐ ☐ responsibilities of staff who are not deemed youth supervision staff. Only youth supervision staff provide supervision of the youth. (2)Special Purpose Juvenile Halls The Firm Roots Academy is not a Special (A) during hours that youth are awake, one wide- Purpose Juvenile Hall. The below sections awake youth supervision staff member on duty ☐ ☐ ☒ A through E are not applicable to this for each 10 youth in detention; facility. (B) during the hours that youth are confined to their room for the purpose of sleeping, one wide- awake youth supervision staff member on duty ☐ ☐ ☒ for each 30 youth in detention; (C) at least two wide-awake youth supervision staff members on duty at all times, regardless of the number of youth in detention, unless an arrangement has been made for backup support ☐ ☐ ☒ services which allow for immediate response to emergencies; and, 7002 Alameda Secure Youth Treatment Facility SYTF PRO 23-24 Page 5 of 17 A453 JUV Targeted PRO eff. 1/2024 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS (D)at least one youth supervision staff member on duty who is the same gender as youth ☐ ☐ ☒ housed in the facility. (E) personnel with primary responsibility for other duties such as administration, supervision of personnel, academic or trade instruction, ☐ ☐ ☒ clerical, kitchen or maintenance shall not be classified as youth supervision staff positions. (3)Camps The Firm Roots Academy is not a Camp. (A) during the hours that youth are awake, one Therefore, the below camp sections A wide-awake youth supervision staff member on ☐ ☐ ☒ through F are not applicable to this facility. duty for each 15 youth in the camp population; (B) during the hours that youth are confined to their room for the purpose of sleeping, one wide- awake youth supervision staff member on duty ☐ ☐ ☒ for each 30 youth present in the facility; (C) at least two wide-awake youth supervision staff members on duty at all times, regardless of the number of youth in residence, unless arrangements have been made for backup ☐ ☐ ☒ support services which allow for immediate response to emergencies; (D)at least one youth supervision staff member on duty who is the same gender as youth ☐ ☐ ☒ housed in the facility; (E)in addition to the minimum staff to youth ratio required in (h)(3)(A)-(B), consideration shall be given to the size, design, and location of the camp; types of youth committed to the camp; ☐ ☐ ☒ and the function of the camp in determining the level of supervision necessary to maintain the safety and welfare of youth and staff; (F) personnel with primary responsibility for other duties such as administration, supervision of personnel, academic or trade instruction, clerical, farm, forestry, kitchen or maintenance ☐ ☐ ☒ shall not be classified as youth supervision staff positions. 1328 SAFETY CHECKS Chapter 3, Section 1328 III Policy 1 0B ⁋ The facility administrator shall develop and implement BSCC staff reviewed safety checks for the policy and procedures that provide for direct visual first ten days of March, April, and May observation of youth at a minimum of every 15 2024. We also reviewed random video minutes, at random or varied intervals during hours surveillance recordings showing safety when youth are asleep or when youth are in their checks. rooms, confined in holding cells or confined to their bed in a dormitory. Supervision is not replaced, but To maintain ongoing compliance, BSCC may be supplemented by, an audio/visual electronic ☒ ☐ ☐ discussed the importance of being surveillance system designed to detect overt, consistent in providing aggressive or assaultive behavior and to summon aid standard and detailed documentation in in emergencies. All safety checks shall be identifying the youth that remains in documented with the actual time the check is his/her room. In addition, the agency completed. should work to ensure that supervisory staff are meeting facility expectations by periodically auditing safety checks. 1354.5 ROOM CONFINEMENT Chapter 5, Section 1354.5 Room 1B Confinement (RC) and Reintegration and (a) The facility administrator shall develop and ☒ ☐ ☐ Safety Plan. implement written policies and procedures addressing the confinement of youth in their room that are 7002 Alameda Secure Youth Treatment Facility SYTF PRO 23-24 Page 6 of 17 A453 JUV Targeted PRO eff. 1/2024 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS consistent with Welfare and Institutions Code Section BSCC staff reviewed examples of room 208.3. The placement of a youth in room confinement confinement documentation that occurred shall be accomplished in accordance with the between March, April, and May of 2024. following guidelines: BSCC staff also interviewed the youth housed at the facility, detention staff, education personnel, and the behavioral and mental health partners that work within the facility. The facility reported the following number of room confinements for the below months of 2024: • March (1) • April (1) • May (0) The reported room confinement was not consistent with observations made by BSCC staff. Multiple subsections of this regulation were found to be noncompliant. The agency is working toward submitting an approved Corrective Action Plan (CAP) to BSCC that identifies dates of resolution for the noncompliance discovered. (1) Room confinement shall not be used before Chapter 5, Section 1354.5 II Policy 2 (p. ⁋ other, less restrictive, options have been 2) attempted and exhausted, unless attempting those Chapter 5, Section 1354.5 IV Procedure A options poses a threat to the safety or security of Room Confinement any youth or staff. The facility was determined to be noncompliant with this subsection. BSCC ☐ ☒ ☐ staff found that Firm Roots Academy youth on Reintegration Safety Plans (RSP) were placed in their rooms for extended periods of time when the high- risk level of safety and security was no longer evident and or not documented as such. (2) Room confinement shall not be used for the Chapter 5, Section 1354.5 II Policy 2 (p. ⁋ purposes of punishment, coercion, convenience, 1) or retaliation by staff. Noncompliance was discovered when BSCC staff found that, at times, staffing levels were below the required staffing ratios. During those times, youth were kept in their rooms for much of the shift and only rotated out of their rooms in ☐ ☒ ☐ groups of two youth for ten or 15-minute intervals. Noncompliance was also discovered when BSCC staff found that, in part, due to low staffing levels, the facility separated youth into two groups that alternated between being locked in their rooms and being out of their rooms for normal program times. 7002 Alameda Secure Youth Treatment Facility SYTF PRO 23-24 Page 7 of 17 A453 JUV Targeted PRO eff. 1/2024 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS (3) Room confinement shall not be used to the Chapter 5, Section 1354.5 II Policy 3 (p. ⁋ extent that it compromises the mental and physical 2) ☒ ☐ ☐ health of the youth. (b) A youth may be held up to four hours in room The facility uses the following confinement. After the youth has been held in room documentation tools to help track and log confinement for a period of four hours, staff shall do room confinement, which include, but are one or more of the following: not limited to: ☒ ☐ ☐ •Room Confinement Checklist •Unit Logbook •Reintegration and Safety Plan Chapter 5, Section 1354.5 III Procedure A- 1 and 2 JIO and ISI Responsibilities Per policy, youth are assessed a minimum of every 15 minutes by staff and 45 minutes by the supervisor, to ascertain the youth’s ability to return to regular programming, with or without a reintegration plan. BSCC staff found that the facility is not (1)Return the youth to general population. ☐ ☒ ☐ following its policy for room confinement and youth on RSP programming. BSCC staff found that the facility is noncompliance as youth on RSP were required to eat meals in their rooms and remain in their rooms during school hours for educational services; there was no documented justification of risk to safety and security for these youth to remain in their locked rooms. Chapter 5, Section 1354.5 III Procedure (2)Consult with mental health or medical staff. C-1 ☒ ☐ ☐ (3) Develop an individualized plan that includes Chapter 5, Section 1354.5 III Procedure C the goals and objectives to be met in order to 2 ⁋ reintegrate the youth to general population. Individualized plans are identified as Reintegration Safety Plans (RSP). BSCC ☒ ☐ ☐ staff provided technical assistance to the facility recommending that supervisors are properly trained on the use and intent of the RSP. (4)If room confinement must be extended beyond Chapter 5, Section 1354.5 III Procedure C four hours, staff shall do each of the following: (A) Document the reasons for room Chapter 5, Section 1354.5 III Procedure C- confinement and the basis for the extension, 2, the date and time the youth was first placed in 3 and 4 room confinement, and when he or she is eventually released from room confinement. The policies articulate the incident reports, ☐ ☒ ☐ The Reintegration Plan, and Room Confinement checklists to be completed, reviewed, and audited by the administration. Noncompliance was discovered when BSCC staff found that, at times, staffing 7002 Alameda Secure Youth Treatment Facility SYTF PRO 23-24 Page 8 of 17 A453 JUV Targeted PRO eff. 1/2024 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS levels were below the required staffing ratios. During those times, youth were kept in their rooms for much of the shift and only rotated out of their rooms in groups of two youth for ten or 15-minute intervals. (B)Develop an individualized plan that includes Chapter 5, Section 1354.5 III Procedure C ⁋ the goals and objectives to be met in order to 4 and # 2 integrate the youth to general population. The Institutional Supervisor II notifies the Guidance Clinic and requests assistance in the development of a Reintegration Plan. ☒ ☐ ☐ Individualized plans are identified as Reintegration Safety Plans (RSP). BSCC staff provided technical assistance to the facility recommending that supervisors are properly trained on the use and intent of the RSP, and that the facility follow its policy and procedures regarding the RSP. (C) Obtain documented authorization by the Chapter 5, Section 1354.5 IV-A, 4 facility superintendent or his or her designee ☒ ☐ ☐ every four hours thereafter. (5) This section is not intended to limit the use of Chapter 5, Section 1354.5 III Procedure B- single-person rooms or cells for the housing of 2 (p. 7) youth in juvenile facilities and does not apply to ☒ ☐ ☐ normal sleeping hours. (6) This section does not apply to youth or wards Chapter 5, Section 1354.5 III Procedure B- in court holding facilities or adult facilities. 2 (p. 7) ☒ ☐ ☐ This facility is not either a court-holding facility or an adult facility. (7) Nothing in this section shall be construed to Chapter 5, Section 1354.5 III Procedure B- conflict with any law providing greater or additional 1 (p. 7) ☒ ☐ ☐ protections to youth. (8) This section does not apply during an Chapter 5, Section 1354.5 III Procedure B- extraordinary emergency circumstance that 3 (p. 7) requires a significant departure from normal institutional operations, including a natural disaster or facility-wide threat that poses an imminent and ☒ ☐ ☐ substantial risk of harm to multiple staff or youth. This exception shall apply for the shortest amount of time needed to address this imminent and substantial risk of harm. (9) This section does not apply when a youth is Chapter 5, Section 1354.5 III Procedure B- placed in a locked cell or sleeping room to treat 4 (p. 7) and protect against the spread of a communicable disease for the shortest amount of time required to reduce the risk of infection, with the written approval of a licensed physician or nurse practitioner, when the youth is not required to be in an infirmary for an illness. Additionally, this section ☒ ☐ ☐ does not apply when a youth is placed in a locked cell or sleeping room for required extended care after medical treatment with the written approval of a licensed physician or nurse practitioner, when the youth is not required to be in an infirmary for illness. 1357 USE OF FORCE Chapter 5, Section 1357 Use of Force ☒ ☐ ☐ 7002 Alameda Secure Youth Treatment Facility SYTF PRO 23-24 Page 9 of 17 A453 JUV Targeted PRO eff. 1/2024 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS The facility administrator, in cooperation with the Chapter 5, Section 1357 II Policy 2 (p. 2) ⁋ responsible physician, shall develop and implement Chapter 5, Section 1357 II Policy Last ⁋ written policies and procedures for the use of force, (p.3) which may include chemical agents. Force shall never Policy Development with the be applied as punishment, discipline, retaliation or Superintendent and Responsible Physician treatment. (a)At a minimum, each facility shall develop policies BSCC staff reviewed Use of Force and procedures which: documentation for March, April, and May 2024 and/or the most recent 15 examples from each facility showing procedural and Incident reports documentation for this regulation. We also interviewed youth housed at the facility, facility detention staff, and collaborative partners to gain further insight and confirm compliance with this regulation. The facility reported the following number of use-of-force incidents for the following months of 2024: • March (2) • April (0) • May (5) (1)restricts the use of force to that which is deemed Chapter 5, Section 1357 II Policy 2 (p. 2) ⁋ reasonable and necessary, as defined in Section 1302 to ensure the safety and security of youth, ☒ ☐ ☐ staff, others and the facility. (2) outline the force options available to staff Chapter 5, Section 1357, IV Procedures including both physical and non-physical options Intervention Options and define when those force options are ☒ ☐ ☐ appropriate. (3) describe force options or techniques that are Chapter 5, Section 1357, IV Procedures expressly prohibited by the facility. Prohibited Actions ACJJC and Firm Roots Academy force options that are prohibited include, but are not limited to, the below: •Alternate Restraint Device •Choke Holds •Hogtie ☒ ☐ ☐ ACJJC and Firm Roots Academy force options that are allowed include, but are not limited to, the below: •Oleoresin Capsicum (OC) •Mechanical Restraints •Physical Intervention •Leg Shackles (4) describe the requirements of staff to report any Chapter 5, Section 1357 II Policy Last ⁋ inappropriate use of force, and to take affirmative (p.2) ☒ ☐ ☐ action to immediately stop it. (5) define a standardized reporting format that Chapter 5, Section 1357 IV Procedure includes time period and procedure for Follow-up to a Use of Force Incident A. documenting and reporting the use of force, Debriefing (p.20) and B. Documentation ☒ ☐ ☐ including reporting requirements of management (p. 11) and line staff and procedures for reviewing and 7002 Alameda Secure Youth Treatment Facility SYTF PRO 23-24 Page 10 of 17 A453 JUV Targeted PRO eff. 1/2024 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS tracking use of force incidents by supervisory and A review of incident reports requested or management staff, which include procedures for shows that FRA documents and reports debriefing a particular incident with staff and/or incidents in accordance with Title 15 youth for the purposes of training as well as minimum standards. mitigating the effects of trauma that may have been experienced by staff and /or the youth involved. If questions or concerns are present, an audio-video surveillance review of the incident will be conducted as part of the debrief. (6) Include an administrative review and a system Chapter 5, Section 1357 IV Procedure for investigating unreasonable use of force. Unnecessary or Excessive Use of Force and Administrative Review (p. 13) Through a review of the Use of Force incident reports, BSCC staff observed that incidents are reviewed by senior staff and administrators at five levels to determine whether the force was within policy. The ☒ ☐ ☐ ISII provides a final analysis and debrief of the incident. Comprehensively, the agency has an Employee Use of Force Review Committee (EUFRC) which meets monthly to review every use of force incident. There is also a Use of Force Coordinator. (7) define the role, notification, and follow-up Chapter 5, Section 1357 IV Procedure procedures required after use of force incidents for Required Notifications: A. Medical Staff medical, mental health staff and parents or legal and Behavior Health Clinicians; and B. guardians. Parents/Guardians (p. 8) BSCC staff interviewed supervisory, detention, and medical and behavioral health staff to help determine compliance with the elements of this regulation. BSCC staff discussed with the facility staff ☒ ☐ ☐ that to maintain compliance when use-of- force incidents occur, the agency must be able to provide substantiation that a youth’s parent(s) was notified. We discussed favorable outcomes when parent notification duties are assigned to the supervisor (ISI or ISII) working the shift that the incident occurred on and ensure confirmation is documented in a standard area of the report. (8) describe the limitations of use of force on Chapter 5, Section 1357, IV Procedures pregnant youth in accordance with Penal Code Prohibited Actions Bullet 4 and 2 ⁋ Section 6030(f) and Welfare and Institutions Code ☒ ☐ ☐ Policy 514 Use of Force Section 222. Policy 515 Restraints (b)Facilities that authorize chemical agents as a force Chapter 5, Section 1357.2 Use of option shall include policies and procedures that: Chemical Intervention (1) identify who is approved to carry and/or utilize chemical agents in the facility and the type, size and Chapter 5, Section 1357.2 II Policy 2 ☒ ☐ ☐ ⁋ the approved method of deployment for those Chapter 5, Section 1357.2 III Procedure chemical agents. Staff Authorized to Carry and Use OC Spray (p. 3) 7002 Alameda Secure Youth Treatment Facility SYTF PRO 23-24 Page 11 of 17 A453 JUV Targeted PRO eff. 1/2024 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS (2) mandate that chemical agents only be used Chapter 5, Section 1357.2 II Policy 4 (p. ⁋ when there is an imminent threat to the youth’s 2) safety or the safety of others and only when de- Chapter 5, Section 1357.2 III Procedure escalation efforts have been unsuccessful or are Criteria for Use of OC (p. 5) not reasonably possible. ☒ ☐ ☐ We reviewed the policy and interviewed JIOs, ISIs, and ISIIs to determine that FRA meets compliance with Title 15 minimum standards for this regulation. We also interviewed youth housed at the facility. (3) outline the facility’s approved methods and Chapter 5, Section 1357.2 III Procedure timelines for decontamination from chemical Decontamination Process (p. 8) agents. This shall include that youth who have been exposed to chemical agents shall not be left BSCC staff reviewed incident reports, ☒ ☐ ☐ unattended until that youth is fully decontaminated interviewed medical staff, and interviewed or is no longer suffering the effects of the chemical youth housed at the facility. agent. (4) define the role, notification, and follow-up Chapter 5, Section 1357.2 III Procedure procedures required after use of force incidents Decontamination Process #3 and #9 involving chemical agents for medical, mental Chapter 5, Section 1357 IV Procedure health staff and parents or legal guardians. Required Notifications A and B BSCC staff discussed with the facility that to maintain compliance when use-of-force incidents occur, the agency must be able ☒ ☐ ☐ to ensure consistency by documenting that a youth’s parent(s) was notified. We discussed favorable outcomes when parent notification duties are assigned to the supervisor (ISI or ISII) working the shift that the incident occurred on and ensure confirmation is documented in a standard area of the report. (5)provide for the documentation of each incident Chapter 5, Section 1357.2 III Procedure of use of chemical agents, including the reasons Documentation Process (p. 9) for which it was used, efforts to de-escalate prior to use, youth and staff involved, the date, time and BSCC staff observed that the facility location of use, decontamination procedures ☒ ☐ ☐ utilizes a “Use of Oleoresin Capsicum applied and identification of any injuries sustained (OC)” Form. In part, the form provides de- as a result of such use. escalation efforts, witnesses, and supervisory review. (c) Facilities shall develop policies and procedure Chapter 5, Section 1357 IV Procedures which require that agencies provide initial and regular Training (p. 22) training in use of force and chemical agents when Chapter 5, Section 1357.2 III Procedure appropriate that address: Staff Authorized to Carry and Use OC Spray (p. 3) #2 (Training Prerequisites) and #3 (Annual Training) (1) known medical and behavioral health Chapter 5, Section 1357 IV Procedures ☒ ☐ ☐ conditions that would contraindicate certain types Training (p. 22) Bullet 1 of force; The elements of this regulation are confirmed in the Chief Probation Officer (CPO) Appointment and Qualifications Letter, written by Interim Chief Probation Officer (CPO) Brian Ford, and dated June 4, 2024. 7002 Alameda Secure Youth Treatment Facility SYTF PRO 23-24 Page 12 of 17 A453 JUV Targeted PRO eff. 1/2024 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS (2)acceptable chemical agents and the methods Chapter 5, Section 1357 IV Procedures of application. ☒ ☐ ☐ Training (p. 22) Bullet 2 (3)signs or symptoms that should result in Chapter 5, Section 1357 IV Procedures immediate referral to medical or behavioral health. ☒ ☐ ☐ Training (p. 22) Bullet 3 (4)instruction on the Constitutional Limitations of Chapter 5, Section 1357 IV Procedures Use of Force. ☒ ☐ ☐ Training (p. 22) Bullet 4 (5)physical training force options that may require Chapter 5, Section 1357 IV Procedures the use of perishable skills. Training (p. 22) Bullet 5 The elements of this regulation are confirmed in the Chief Probation Officer ☒ ☐ ☐ (CPO) Appointment and Qualifications Letter, written by Interim Chief Probation Officer (CPO) Brian Ford, and dated June 4, 2024. (6)timelines the facility uses to define regular Chapter 5, Section 1357.2 III, Procedure training. Staff Authorized to Carry and Use OC ☒ ☐ ☐ Spray (p. 3) #3 Annual Training after Initial Training. 1361 GRIEVANCE PROCEDURE Chapter 5, Section 1361 Grievances The facility administrator shall develop and implement BSCC staff reviewed grievances for written policies and procedures whereby any youth January through May 2024, and the may appeal and have resolved grievances relating to Grievance Log covering the past six any condition of confinement, including but not limited months. This included due process to health care services, classification decisions, documentation. program participation, telephone, mail or visiting procedures, food, clothing, bedding, mistreatment, BSCC staff also interviewed youth housed harassment or violations of the nondiscrimination at the facility, detention staff, health policy. There shall be no time limit on filing grievances. services, behavior health, and education Policies and procedures shall include provisions services collaborative partners. whereby the facility manager ensures: ☒ ☐ ☐ BSCC staff observed that the agency has incorporated, to youth, supplemental access to grievances through tablets that are individually assigned to youth and allowed to be kept in their rooms. Although it is viewed as a favorable option, BSCC staff provided technical assistance by recommending updating the grievance policy and procedure, as well as, the youth orientation handbook, to include expectations and processes for filing a grievance via the tablets. (a)a grievance form and instructions for registering a Chapter 5, Section 1361 IV Procedure grievance, which includes provisions for the youth to Filing a Grievance 1 ⁋ have free access to the form; During our physical inspection, we observed that grievances were readily available to youth. In addition, grievance ☒ ☐ ☐ lock boxes were in the housing pods to allow youth to confidentially submit a grievance if needed. As well, filing a grievance via individually assigned tablets has been incorporated into the grievance process. (b)the youth shall have the option to confidentially file Chapter 5, Section 1361 IV Procedure the grievance or to deliver the form to any youth Filing a Grievance 1 ☒ ☐ ☐ ⁋ supervision staff working in the facility; 7002 Alameda Secure Youth Treatment Facility SYTF PRO 23-24 Page 13 of 17 A453 JUV Targeted PRO eff. 1/2024 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS The youth were aware of the grievance procedures, the location of the grievances, and the grievance lockbox to confidentially file a grievance, if needed. (c) resolution of the grievance at the lowest Chapter 5, Section 1361 IV Procedure appropriate staff level; Staff Responsibilities #1 ISI ☒ ☐ ☐ The Institution Supervisor I is identified as the lowest staff level via policy and Labor Relations. (d) provision for a prompt review and initial response Chapter 5, Section 1361 IV Procedure to grievances within three (3) business days, Grievance Timeframes. grievances that relate to health and safety issues must be addressed immediately; Per policy, below is the response process for grievances: • ISI to respond by the end of the shift on the day it was received • ISII to respond if not resolved by the end of the shift on the day received • Assistant Supt/Manager must respond within 72 hours of receipt ☒ ☐ ☐ BSCC reviewed grievances for January through May of 2024 and reviewed the Grievance Log for the past six months. The facility does well in ensuring a prompt review and initial response is provided within three business days. With the implementation of the tablets as an option to submit a grievance, BSCC staff discussed the importance of ensuring that response timelines remain consistent with policy and Title 15 Regulations. (1) The youth may elect to be present to explain Chapter 5, Section 1361 IV Procedure his/her version of the grievance to a person not Filing a Grievance 3 ⁋ directly involved in the circumstances which led to the grievance. The youth interviewed indicated that ☒ ☐ ☐ during the intake and orientation process, the grievance procedure was clearly explained. (2)Provision for a staff representative approved by Chapter 5, Section 1361 IV Procedure the facility administrator to assist the youth. ☒ ☐ ☐ Filing a Grievance 2 ⁋ (e) provision for a written response to the grievance Chapter 5, Section 1361 IV Procedure which includes the reasons for the decisions; Filing a Grievance 3 ⁋ ☒ ☐ ☐ The documentation as well as interviews show that detention staff respond professionally. (f) a system which provides that any appeal of a Chapter 5, Section 1361 IV Procedure grievance shall be heard by a person not directly Staff Responsibilities involved in the circumstances which led to the ☒ ☐ ☐ grievance; (g) resolution of the grievance must occur within ten Chapter 5, Section 1361 IV Procedure (10) business days unless circumstances dictate a Grievance Timeframes 7 (p. 6) ⁋ longer time frame. The youth shall be notified of any ☒ ☐ ☐ delay; and, The documentation as well as interviews 7002 Alameda Secure Youth Treatment Facility SYTF PRO 23-24 Page 14 of 17 A453 JUV Targeted PRO eff. 1/2024 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS show that detention staff respond to grievances in a timely fashion. (h) the policy shall provide multiple internal and Chapter 5, Section 1361 IV Procedure external methods to report sexual abuse and sexual Reporting Sexual Abuse and Sexual ☒ ☐ ☐ harassment. Harassment Whether or not associated with a grievance, concerns Chapter 5, Section 1361 IV Procedure of parents, guardians, staff or other parties shall be Grievance Timeframes Last (p. 7) ⁋ addressed and documented in accordance with ☒ ☐ ☐ written policies and procedures within a specified timeframe. 1371 PROGRAMS, RECREATION, AND Chapter 6, Section 1371 2B EXERCISE. The facility’s policy and procedures are The facility administrator shall develop and implement applicable to the elements of this written policies and procedures for programs, regulation as required. recreation, and exercise for all youth. The intent is to minimize the amount of time youth are in their rooms BSCC staff reviewed the facility’s or their bed area. Programs, Exercise, and Recreation policy and procedure. We also reviewed pertinent documentation that covered the first 15 days of March, April, and May ☒ ☐ ☐ 2024. The documentation included, but was not limited to program logs, and program entries in shift reports indicating programming offered to all youth. The facility was found to be noncompliant with subsections of this regulation. The agency is working toward submitting an approved Corrective Action Plan (CAP) to BSCC that identifies dates of resolution for the noncompliance discovered. Juvenile facilities shall provide the opportunity for Chapter 6, Section 1371 II Policy 1 ⁋ programs, recreation, and exercise a minimum of three hours a day during the week and five hours a BSCC staff found that youth on RSP were day each Saturday, Sunday or other non-school days, not consistently provided the required of which one hour shall be an outdoor activity, weather programs, recreation, and exercise when permitting. the high-risk level of safety and security no longer existed or was reduced. RSP youth were not consistently provided an hour each of programming, exercise, and recreation. ☐ ☒ ☐ BSCC staff found the noncompliance to be, in part, due to staffing challenges and the lack of training for detention staff to utilize the RSP as intended in policy and regulation. BSCC staff provided technical assistance in recommending that supervisory staff be trained accordingly. Additionally, to ensure staffing levels are sufficient for all required services to youth. A youth’s participation in programs, recreation, and Chapter 6, Section 1371 II Policy 3 ⁋ exercise may be suspended only upon a written finding by the administrator/manager or designee that BSCC staff reviewed the program tracker ☐ ☒ ☐ a youth represents a threat to the safety and security document for March, April, and May of of the facility. 2024. We also interviewed a youth. 7002 Alameda Secure Youth Treatment Facility SYTF PRO 23-24 Page 15 of 17 A453 JUV Targeted PRO eff. 1/2024 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS BSCC staff discovered noncompliance with this subsection of the regulation. BSCC staff found that youth on Reintegration Safety Plans (RSP) are not consistently provided equity in programming requirements when the high level of safety risk and security no longer exist to the extent of suspending programming requirements. Specifically, RSP youth were not consistently receiving one hour of structured programming daily. The facility acknowledges that the noncompliance is, in part, attributed to a deficiency in detention personnel staffing. As a result, the facility was found to be noncompliant with Title 15, Section, 1321 Staffing, and Section, 1354.5 Room Confinement. Additionally, BSCC staff observed inconsistencies with the use of the program tracker being utilized as intended in policy to track all youth programming, including youth on RSP. BSCC staff provided technical assistance for the facility to provide all detention staff with training in the use of the program tracker and to ensure supervisory staff review the program tracker periodically throughout each shift. Such program, recreation, and exercise schedule Chapter 6, Section 1371 III Procedures shall be posted in the living units. Staff Responsibility 1 ⁋ ☒ ☐ During the physical inspection of both ☐ facilities, BSCC observed program and recreation schedule calendars posted in the living units. There will be a written annual review of the programs, Chapter 6, Section 1371 II Policy 5 ⁋ recreation, and exercise by the responsible agency to ensure content offered is current, consistent, and A letter dated May 31, 2024, written by relevant to the population. Superintendent John Ebrahimi provides confirmation that an annual review of the ☒ ☐ ☐ programs, recreation, and exercise by the responsible agency was conducted to ensure content offered is current, consistent, and relevant to the population. (a) Programs. All youth shall be provided with the Chapter 6, Section 1371 III Procedure opportunity for at least one hour of daily programming Programming, 1-18 (p. 3) to include, but not be limited to, trauma focused, cognitive, evidence-based, best practice interventions Noncompliance was identified with this that are culturally relevant and linguistically subsection of the regulation. BSCC staff appropriate, or pro-social interventions and activities ☐ ☒ ☐ found that youth on RSP were not designed to reduce recidivism. These programs consistently provided the required should be based on the youth’s individual needs as programs, recreation, and exercise when required by Sections 1355 and 1356. Such programs the high-risk level of safety and security no may be provided under the direction of the Chief longer existed or was reduced. RSP youth 7002 Alameda Secure Youth Treatment Facility SYTF PRO 23-24 Page 16 of 17 A453 JUV Targeted PRO eff. 1/2024 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS Probation Officer or the County Office of Education and were not receiving one hour of structured can be administered by county partners such as mental programming daily and did not health agencies, community based organizations, consistently receive an hour each of faith-based organizations or Probation staff. programming, exercise, and recreation. Programs may include but are not limited to: (1) Cognitive Behavior Interventions; BSCC staff reviewed the facility’s (2) Management of Stress and Trauma; Programs, Exercise, and Recreation policy (3) Anger Management; and procedure. We also reviewed (4) Conflict Resolution; pertinent documentation that covered the (5) Juvenile Justice System; first 15 days of March, April, and of May (6) Trauma-related interventions; 2024. The documentation included, but (7) Victim Awareness; was not limited to program logs, and (8) Self-Improvement; program entries in shift reports indicating (9) Parenting Skills and support; programming offered to all youth. We also (10)Tolerance and Diversity; interviewed youth housed at the facility, (11)Healing Informed Approaches; detention staff, behavioral health staff, and (12)Interventions by Credible Messengers; education service staff. (13)Gender Specific Programming; (14)Art, creative writing, or self-expression; Firm Roots Academy offers programs (15)CPR and First Aid training; including, but not limited to the following: (16)Restorative Justice or Civic Engagement; (17)Career and leadership opportunities; and, • Aggression Replacement Training (18)Other topics suitable to the youth population. • Beat Within • La Familia (Substance Abuse Education • Niroga/Yoga (Mind, Body, Wellness • Junior College program • Education Program (SEEP) for High School Graduates • Skillsoft (developing work readiness skills) • Ted Talks • American Data Prison Systems Tablets Applications • Deputy Sheriff Athletic League • MC3 Tech/Construction Program (b) Recreation. All youth shall be provided the Chapter 6, Section 1371 III Procedure opportunity for at least one hour of daily access to Recreation (p. 4) unscheduled activities such as leisure reading, letter writing, and entertainment. Activities shall be ☒ ☐ ☐ supervised and include orientation and may include coaching of youth. (c) Exercise. All youth shall be provided with the Chapter 6, Section 1371 III Procedure opportunity for at least one hour of large muscle activity Large each day. Muscle Exercise (p. 5) ☒ ☐ ☐ The administrator/manager may suspend, for a period Chapter 6, Section 1371 III Procedure not to exceed 24 hours, access to recreation and Last (p. 4) ⁋ programs. The administrator/manager shall document ☒ ☐ ☐ the reasons why suspension of recreation and programs occurs. 7002 Alameda Secure Youth Treatment Facility SYTF PRO 23-24 Page 17 of 17 A453 JUV Targeted PRO eff. 1/2024 JUVENILE HALLS, SPECIAL PURPOSE JUVENILE HALLS AND CAMPS Board of State and Community Corrections PROCEDURES CHECKLIST1 BSCC Code: 7003 FACILITY NAME: Alameda Camp Sweeney (ACCS) FACILITY TYPE: CAMP PERSON(S) INTERVIEWED: Chief Probation Officer (Interim), Brian Ford; Shauna Conner, Deputy Chief Probation Officer (Juvenile Facilities); Albert Banuelos, Superintendent- Camp Sweeney; Esmeralda Pulido, Juvenile Institutional officer (JIO); Michael Postell Behavioral Health Clinician; Ray Nickaloff, Food Service Manager; Arthur Hogenauer; Christie Aganon, RN; Andrea Parish, Health Services Executive Director; Male youth age 17; Male youth 17; Random youth during physical facility inspection. FIELD REPRESENTATIVE: Forrest Coleman DATE: June 3rd through June 11th, 2024 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS 1321 STAFFING Chapter 3, Section 1321, II Policy 1 ⁋ JH: Chapter 3, Section 1322.18, III Staffing Each juvenile facility shall: (a)have an adequate number of personnel sufficient to The Alameda County Camp Sweeney carry out the overall facility operation and its (ACCS) is a detention camp located on the programming, to provide for safety and security of same campus and adjacent to the Alameda youth and staff, and meet established standards and County Juvenile Justice Center (ACJJC) regulations; complex. The Camp and the ACJJC conduct staff training together. Cross- training the staff provides an opportunity to utilize staff from either facility if needed. Further, with minimal distinctions, Camp Sweeney abides by the same ACJJC ☒ ☐ ☐ policies and procedures, as well as the Title 15 regulations including, but not limited to, staff training and qualifications. BSCC staff reviewed the above policies and procedures, as well as, the agency’s Organization Chart, random weekly staff schedules, and daily unit schedule covering the first eight days of March, April, and May of 2024. Additionally, we made personal observations and interviewed youth housed at the facility, collaborative partners, and camp staff. 1 This document is intended for use as a tool during the targeted inspection process; this worksheet may not contain each Title 15 regulation that is required. Additionally, many regulations on this worksheet are SUMMARIES of the regulation; the text on this worksheet may not contain the entire text of the actual regulation. Please refer to the complete California Code of Regulations, Title 15, Minimum Standards for Juvenile Facilities, Division 1, Chapter 1, Subchapter 5 for the complete list and text of regulations. 7003 Alameda Camp Sweeney CAMP Targeted PRO 23-24 Page 1 of 17 A453 JUV Targeted PRO eff. 1/2024 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS (b) ensure that no required services shall be denied Chapter 3, Section 1321, II Policy 2 ⁋ because of insufficient numbers of staff on duty absent exigent circumstances; Per the above policy, absent exigent circumstances, the institutional Supervisor II (ISII) shall ensure that youth are not denied any required services due to insufficient staffing. Through our review of the above policy, visual observations, a review of work ☒ ☐ ☐ schedules, and programming documentation, BSCC staff determined that ACCS regularly ensures that the staffing levels are adequate. Detention staff from the ACJJC provide additional youth supervision support to the ACCS. In addition, involuntary overtime has been instituted. (c)have a sufficient number of supervisory level staff to Chapter 3, Section 1321, II Policy 3 ⁋ ensure adequate supervision of all staff members; After a review of the daily staff schedule, as well as, through interviews with youth housed at the facility and staff, BSCC staff confirmed that there is an Institutional Supervisor II (ISII) and or an Institutional Supervisor I (ISI) present at the facility on each shift. There are two ISI Supervisors assigned to ☒ ☐ ☐ the facility and a senior staff working as Acting ISI. There is no ISI on-site during the graveyard shift. While the ISII ensures operations are being conducted accordingly during each shift, the facility Superintendent is responsible for the daily overall operations of the facility Monday through Friday during the day shift. 7003 Alameda Camp Sweeney CAMP Targeted PRO 23-24 Page 2 of 17 A453 JUV Targeted PRO eff. 1/2024 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS (d) have a clearly identified person on duty at all times Chapter 3, Section 1321, II Policy 4 ⁋ who is responsible for operations and activities and has completed the Juvenile Corrections Officer Core The elements of this regulation are Course and PC 832 training; confirmed in the Chief Probation Officer (CPO) Appointment and Qualifications Letter, written by Interim Chief Probation Officer (CPO) Brian Ford, and dated June 4, 2024. ☒ ☐ ☐ Through personal observations, as well as through interviews with staff and youth housed at the facility, ACCS regularly ensures that there is always staff present in the unit or where a youth is present. Youth are never left unsupervised. (e) have at least one staff member present on each Chapter 3, Section 1321, II Policy 3 (p 3) ⁋ living unit whenever there are youth in the living unit; Through personal observations, as well as through interviews with staff and youth ☒ ☐ ☐ housed at the facility, ACCS regularly ensures that there is always staff present in the unit or where a youth is present. Youth are never left unsupervised. (f) have sufficient food service personnel relative to the Chapter 3, Section 1321, III Procedures number and security of living units, including staff Support Staff 2 ⁋ qualified and available to: plan menus meeting nutritional requirements of youth; provide kitchen Food is provided by an outside vendor supervision; direct food preparation and servings; identified as Epicurean Foods conduct related training programs for culinary staff; and maintain necessary records; or, a facility may serve The facility’s kitchen is closed and does food that meets nutritional standards prepared by an not prepare regular meals. Food service outside source; ☒ ☐ ☐ personnel are those of the adjacent ACJJC. Current food service personnel staffing consists of: • 1 Food and Support Service Manager • 7 Full-time Food Service Workers 7003 Alameda Camp Sweeney CAMP Targeted PRO 23-24 Page 3 of 17 A453 JUV Targeted PRO eff. 1/2024 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS (g) have sufficient administrative, clerical, recreational, Chapter 3, Section 1321, III Procedures medical, dental, mental health, building maintenance, Support Staff 1 and 3 ⁋ transportation, control room, facility security and other support staff for the efficient management of the facility, BSCC staff interviewed medical services and to ensure that youth supervision staff shall not be personnel, education services, and camp diverted from supervising youth; and, staff. We also made personal observations over the course of the inspection week. The agency is fortunate to have such a significant base of collaborative partners and support staff. Behavioral Health staff clinicians operate under the Alameda County Behavioral Health Services. There are six Behavioral ☒ ☐ ☐ Health Clinicians and two psychiatrists who provide services to the Alameda County Juvenile Justice Center, Secure Youth Treatment Facility (Firm Roots), and Camp Wilmont Sweeney. The nursing staff operates under the University of San Francisco, Children’s Hospital. There are 21 nursing staff personnel available to provide services to the same facilities indicated above. The nursing staff are on-site 24 hours per day, seven days per week. (h) assign sufficient youth supervision staff to provide Chapter 3, Section 1321, II Policy 5 ⁋ continuous wide awake supervision of youth, subject to temporary variations in staff assignments to meet BSCC staff interviewed camp staff and special program needs. Staffing shall be in compliance reviewed dorm logs, programming with a minimum youth-staff ratio for the following facility schedules, and employee daily schedules. types: The Alameda County Camp Sweeney regularly provides youth supervision ☒ ☐ ☐ staffing levels that enable the facility to meet the minimum standards for this regulation. Detention staff from JJC and the ACSYTF/ Firm Roots provide additional youth supervision support to Camp Sweeney. (1) Juvenile Halls The Alameda County Camp Sweeney is (A) during the hours that youth are awake, one not a Juvenile Hall. The below sections A wide-awake youth supervision staff member on ☐ ☐ ☒ through E do not apply to this facility. duty for each 10 youth in detention; (B) during the hours that youth are confined to their room for the purpose of sleeping, one wide- awake youth supervision staff member on duty ☐ ☐ ☒ for each 30 youth in detention; 7003 Alameda Camp Sweeney CAMP Targeted PRO 23-24 Page 4 of 17 A453 JUV Targeted PRO eff. 1/2024 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS (C) at least two wide-awake youth supervision staff members on duty at all times, regardless of the number of youth in detention, unless an arrangement has been made for backup support ☐ ☐ ☒ services which allow for immediate response to emergencies; and, (D) at least one youth supervision staff member on duty who is the same gender as youth ☐ ☐ ☒ housed in the facility. (E) personnel with primary responsibility for other duties such as administration, supervision of personnel, academic or trade instruction, ☐ ☐ ☒ clerical, kitchen or maintenance shall not be classified as youth supervision staff positions. (2) Special Purpose Juvenile Halls The Alameda County Camp Sweeney is (A) during hours that youth are awake, one wide- not a Special Purpose Juvenile Hall. The awake youth supervision staff member on duty ☐ ☐ ☒ below section A through E does not apply for each 10 youth in detention; to this facility. (B) during the hours that youth are confined to their room for the purpose of sleeping, one wide- awake youth supervision staff member on duty ☐ ☐ ☒ for each 30 youth in detention; (C) at least two wide-awake youth supervision staff members on duty at all times, regardless of the number of youth in detention, unless an arrangement has been made for backup support ☐ ☐ ☒ services which allow for immediate response to emergencies; and, (D) at least one youth supervision staff member on duty who is the same gender as youth ☐ ☐ ☒ housed in the facility. (E) personnel with primary responsibility for other duties such as administration, supervision of personnel, academic or trade instruction, ☐ ☐ ☒ clerical, kitchen or maintenance shall not be classified as youth supervision staff positions. (3) Camps Chapter 3, Section 1321, III Procedures (A) during the hours that youth are awake, one Juvenile Facilities 1 ⁋ wide-awake youth supervision staff member on duty for each 15 youth in the camp population; Through documentation review, personal observations, as well as interviews with youth and camp staff, and a review of safety check logs, the facility regularly ☒ ☐ ☐ ensures that there is one wide-awake youth supervision staff member on duty for each 15 youths in detention. At the time of this inspection, there were five youths in Camp Sweeney. (B) during the hours that youth are confined to Chapter 3, Section 1321, III Procedures their room for the purpose of sleeping, one wide- Juvenile Facilities 2 ⁋ awake youth supervision staff member on duty ☒ ☐ ☐ for each 30 youth present in the facility; 7003 Alameda Camp Sweeney CAMP Targeted PRO 23-24 Page 5 of 17 A453 JUV Targeted PRO eff. 1/2024 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS (C) at least two wide-awake youth supervision Chapter 3, Section 1321, III Procedures staff members on duty at all times, regardless of Juvenile Facilities 3 ⁋ the number of youth in residence, unless arrangements have been made for backup In a review of the camp activity log, Safety support services which allow for immediate ☒ ☐ ☐ Check documentation, and daily schedules, response to emergencies; ACCS ensures at least two wide-awake youth supervision staff members are always on duty. (D) at least one youth supervision staff member Chapter 3, Section 1321, III Procedures J on duty who is the same gender as youth According to shift schedules, housing unit housed in the facility; According to shift schedules, camp activity logs, visual observations, and interviews ☒ ☐ ☐ with staff and youth, there is always a male and female youth supervision staff in the facility. The ACCS does not house female youth. (E) in addition to the minimum staff to youth ratio Chapter 3, Section 1321, III Procedures required in (h)(3)(A)-(B), consideration shall be Juvenile Facilities 5 ⁋ given to the size, design, and location of the camp; types of youth committed to the camp; The above policy identifies the roles and and the function of the camp in determining the ☒ ☐ ☐ responsibilities of staff who are not deemed level of supervision necessary to maintain the youth supervision staff. Only youth safety and welfare of youth and staff; supervision staff provide supervision of the youth. (F) personnel with primary responsibility for Chapter 3, Section 1321, III Procedures other duties such as administration, supervision Support Staff 1 Chapter III, Section 1322 ⁋ of personnel, academic or trade instruction, clerical, farm, forestry, kitchen or maintenance ☒ ☐ ☐ shall not be classified as youth supervision staff positions. 7003 Alameda Camp Sweeney CAMP Targeted PRO 23-24 Page 6 of 17 A453 JUV Targeted PRO eff. 1/2024 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS 1328 SAFETY CHECKS Chapter 3, Section 1328 III Policy 1 0B ⁋ The facility administrator shall develop and implement BSCC staff reviewed safety checks for the policy and procedures that provide for direct visual first ten days of March, April, and May of observation of youth at a minimum of every 15 2024. We also reviewed random video minutes, at random or varied intervals during hours surveillance recordings showing safety when youth are asleep or when youth are in their checks. rooms, confined in holding cells or confined to their bed in a dormitory. Supervision is not replaced, but BSCC discovered that Camp Sweeney may be supplemented by, an audio/visual electronic graveyard staff created an unapproved surveillance system designed to detect overt, safety check document that contained aggressive or assaultive behavior and to summon aid predetermined times that safety checks in emergencies. All safety checks shall be would be conducted throughout a shift. documented with the actual time the check is The same document with the completed. predetermined times was copied and utilized for safety checks weekly over the three-month period reviewed by BSCC staff. This practice does not provide assurance that the documentation reflects the actual time the safety checks were completed. The agency is noncompliant with following its policy and procedures. ☐ ☒ ☐ Additionally, upon a video surveillance review of safety checks, BSCC staff observed noncompliance with staff conducting safety checks during the graveyard shift. BSCC staff found that graveyard staff, routinely, did not physically conduct direct visual observation safety checks as required by Title 15 Regulations and facility policy. It was observed that the safety checks were typically conducted from a seated position at the enclosed counselor’s station. The facility was unable to provide assurance that safety checks were conducted per Title 15 requirements. The agency is working toward submitting an approved Corrective Action Plan (CAP) to BSCC that identifies dates of resolution for the noncompliance discovered. 7003 Alameda Camp Sweeney CAMP Targeted PRO 23-24 Page 7 of 17 A453 JUV Targeted PRO eff. 1/2024 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS 1354.5 ROOM CONFINEMENT Chapter 5, Section 1354.5 Room 1B Confinement (RC) and Reintegration and (a) The facility administrator shall develop and Safety Plan. implement written policies and procedures addressing the confinement of youth in their room that are consistent with Welfare and Institutions Code Section ☒ ☐ ☐ Camp Sweeney is a dormitory-style facility. 208.3. The placement of a youth in room confinement There are no locked sleeping rooms at the shall be accomplished in accordance with the facility. In addition, youth are not confined following guidelines: to their bed areas for extended periods. (1) Room confinement shall not be used before Chapter 5, Section 1354.5 II Policy 2 (p. ⁋ other, less restrictive, options have been 2) attempted and exhausted, unless attempting those Chapter 5, Section 1354.5 IV Procedure A ☒ ☐ ☐ options poses a threat to the safety or security of Room Confinement any youth or staff. (2) Room confinement shall not be used for the Chapter 5, Section 1354.5 II Policy 2 (p. ⁋ purposes of punishment, coercion, convenience, 1) or retaliation by staff. ☒ ☐ ☐ (3) Room confinement shall not be used to the Chapter 5, Section 1354.5 II Policy 3 (p. ⁋ extent that it compromises the mental and physical 2) ☐ ☐ ☒ health of the youth. (b) A youth may be held up to four hours in room Chapter 5, Section 1354.5 II Policy 3 (p. ⁋ confinement. After the youth has been held in room 2) confinement for a period of four hours, staff shall do ☐ ☐ ☒ one or more of the following: Chapter 5, Section 1354.5 III Procedure A- 1 and 2 JIO and ISI Responsibilities (1) Return the youth to general population. ☐ ☐ ☒ Chapter 5, Section 1354.5 III Procedure (2) Consult with mental health or medical staff. C-1 ☒ ☐ ☐ (3) Develop an individualized plan that includes Chapter 5, Section 1354.5 III Procedure C ⁋ the goals and objectives to be met in order to 2 reintegrate the youth to general population. ☒ ☐ ☐ (4) If room confinement must be extended beyond Chapter 5, Section 1354.5 III Procedure C- four hours, staff shall do each of the following: 2, 3 and 4 (A) Document the reasons for room confinement and the basis for the extension, ☐ ☐ ☒ the date and time the youth was first placed in room confinement, and when he or she is eventually released from room confinement. (B) Develop an individualized plan that includes Chapter 5, Section 1354.5 III Procedure C ⁋ the goals and objectives to be met in order to 4 and # 2 integrate the youth to general population. ☒ ☐ ☐ 7003 Alameda Camp Sweeney CAMP Targeted PRO 23-24 Page 8 of 17 A453 JUV Targeted PRO eff. 1/2024 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS (C) Obtain documented authorization by the Chapter 5, Section 1354.5 IV-A, 4 facility superintendent or his or her designee ☒ ☐ ☐ every four hours thereafter. (5) This section is not intended to limit the use of Chapter 5, Section 1354.5 III Procedure B- single-person rooms or cells for the housing of 2 (p. 7) youth in juvenile facilities and does not apply to ☒ ☐ ☐ normal sleeping hours. (6) This section does not apply to youth or wards Chapter 5, Section 1354.5 III Procedure B- in court holding facilities or adult facilities. 2 (p. 7) ☒ ☐ ☐ This facility is not either a Court Holding Facility or an Adult Facility. (7) Nothing in this section shall be construed to Chapter 5, Section 1354.5 III Procedure B- conflict with any law providing greater or additional 1 (p. 7) ☒ ☐ ☐ protections to youth. (8) This section does not apply during an Chapter 5, Section 1354.5 III Procedure B- extraordinary emergency circumstance that 3 (p. 7) requires a significant departure from normal institutional operations, including a natural disaster or facility-wide threat that poses an imminent and ☒ ☐ ☐ substantial risk of harm to multiple staff or youth. This exception shall apply for the shortest amount of time needed to address this imminent and substantial risk of harm. (9) This section does not apply when a youth is Chapter 5, Section 1354.5 III Procedure B- placed in a locked cell or sleeping room to treat 4 (p. 7) and protect against the spread of a communicable disease for the shortest amount of time required to reduce the risk of infection, with the written approval of a licensed physician or nurse practitioner, when the youth is not required to be in an infirmary for an illness. Additionally, this section ☒ ☐ ☐ does not apply when a youth is placed in a locked cell or sleeping room for required extended care after medical treatment with the written approval of a licensed physician or nurse practitioner, when the youth is not required to be in an infirmary for illness. 7003 Alameda Camp Sweeney CAMP Targeted PRO 23-24 Page 9 of 17 A453 JUV Targeted PRO eff. 1/2024 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS 1357 USE OF FORCE Chapter 5, Section 1357 Use of Force Chapter 5, Section 1357 II Policy 2 (p. 2) The facility administrator, in cooperation with the ⁋ responsible physician, shall develop and implement Chapter 5, Section 1357 II Policy Last ⁋ written policies and procedures for the use of force, (p.3) which may include chemical agents. Force shall never Policy Development with the be applied as punishment, discipline, retaliation or Superintendent and responsible physician. treatment. (a) At a minimum, each facility shall develop policies BSCC staff requested to review Use of and procedures which: Force documentation for March, April, and May 2024 and the most recent examples ☒ ☐ ☐ showing procedural and Incident report documentation for this regulation. There was one use of force incident reported to have occurred during the time period requested. We also interviewed youth housed at the facility and facility camp staff. We also interviewed collaborative partners to gain further insight to confirm compliance with this regulation. (1) restricts the use of force to that which is deemed Chapter 5, Section 1357 II Policy 2 (p. 2) ⁋ reasonable and necessary, as defined in Section 1302 to ensure the safety and security of youth, ☒ ☐ ☐ staff, others and the facility. (2) outline the force options available to staff Chapter 5, Section 1357, IV Procedures including both physical and non-physical options Intervention Options and define when those force options are ☒ ☐ ☐ appropriate. (3) describe force options or techniques that are Chapter 5, Section 1357, IV Procedures expressly prohibited by the facility. Prohibited Actions ACCS force options that are prohibited include, but are not limited to, the below: • Alternate Restraint Device • Choke Holds ☒ ☐ ☐ • Hogtie ACCS force options that are allowed include, but are not limited to, the below: • Mechanical Restraints • Physical Intervention • Leg Shackles (4) describe the requirements of staff to report any Chapter 5, Section 1357 II Policy Last ⁋ inappropriate use of force, and to take affirmative (p.2) ☒ ☐ ☐ action to immediately stop it. 7003 Alameda Camp Sweeney CAMP Targeted PRO 23-24 Page 10 of 17 A453 JUV Targeted PRO eff. 1/2024 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS (5) define a standardized reporting format that Chapter 5, Section 1357 IV Procedure includes time period and procedure for Follow-up to a Use of Force Incident A. documenting and reporting the use of force, Debriefing (p.20) and B. Documentation including reporting requirements of management (p. 11) and line staff and procedures for reviewing and tracking use of force incidents by supervisory and A review of incident reports requested or management staff, which include procedures for shows that ACCS documents and reports debriefing a particular incident with staff and/or ☒ ☐ ☐ incidents in accordance with Title 15 youth for the purposes of training as well as minimum standards. mitigating the effects of trauma that may have been experienced by staff and /or the youth involved. If questions or concerns are present, an audio-video surveillance review of the incident will be conducted as part of the debrief. (6) Include an administrative review and a system Chapter 5, Section 1357 IV Procedure for investigating unreasonable use of force. Unnecessary or Excessive Use of Force and Administrative Review (p. 13) Through a review of the Use of Force incident reports, BSCC staff observe that incidents are reviewed by senior staff and administrators to determine whether the ☒ ☐ ☐ force was within policy. The ISII provides a final analysis and debrief of the incident. Comprehensively, the agency has an Employee Use of Force Review Committee (EUFRC) that meets monthly to review every use of force incident. There is also a Use of Force Coordinator. (7) define the role, notification, and follow-up Chapter 5, Section 1357 IV Procedure procedures required after use of force incidents for Required Notifications: A. Medical Staff medical, mental health staff and parents or legal and Behavior Health Clinicians; and B. guardians. Parents/Guardians (p. 8) BSCC staff interviewed supervisory, camp, and medical and behavioral health staff to help determine compliance with ☒ ☐ ☐ the elements of this regulation. BSCC staff discussed with the agency that the best outcomes occur when the notification to parents is documented and confirmed as a standard location of the incident report. (8) describe the limitations of use of force on Chapter 5, Section 1357, IV Procedures pregnant youth in accordance with Penal Code Prohibited Actions Bullet 4 and 2 ⁋ Section 6030(f) and Welfare and Institutions Code Section 222. Policy 514 Use of Force ☒ ☐ ☐ Policy 515 Restraints The facility does not house female youth. 7003 Alameda Camp Sweeney CAMP Targeted PRO 23-24 Page 11 of 17 A453 JUV Targeted PRO eff. 1/2024 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS (b) Facilities that authorize chemical agents as a force The facility does not authorize the use of option shall include policies and procedures that: chemical agents at the camp. (1) identify who is approved to carry and/or utilize chemical agents in the facility and the type, size and ☐ ☐ ☒ the approved method of deployment for those chemical agents. (2) mandate that chemical agents only be used Chapter 5, Section 1357.2 II Policy 4 (p. ⁋ when there is an imminent threat to the youth’s 2) safety or the safety of others and only when de- Chapter 5, Section 1357.2 III Procedure escalation efforts have been unsuccessful or are ☐ ☐ ☒ Criteria for Use of OC (p. 5) not reasonably possible. (3) outline the facility’s approved methods and Chapter 5, Section 1357.2 III Procedure timelines for decontamination from chemical Decontamination Process (p. 8) agents. This shall include that youth who have been exposed to chemical agents shall not be left ☐ ☐ ☒ unattended until that youth is fully decontaminated or is no longer suffering the effects of the chemical agent. (4) define the role, notification, and follow-up Chapter 5, Section 1357.2 III Procedure procedures required after use of force incidents Decontamination Process #3 and #9 involving chemical agents for medical, mental ☐ ☐ ☒ Chapter 5, Section 1357 IV Procedure health staff and parents or legal guardians. Required Notifications A and B (5) provide for the documentation of each incident Chapter 5, Section 1357.2 III Procedure of use of chemical agents, including the reasons Documentation Process (p. 9) for which it was used, efforts to de-escalate prior to use, youth and staff involved, the date, time and ☐ ☐ ☒ location of use, decontamination procedures applied and identification of any injuries sustained as a result of such use. (c) Facilities shall develop policies and procedure Chapter 5, Section 1357 IV Procedures which require that agencies provide initial and regular Training (p. 22) training in use of force and chemical agents when Chapter 5, Section 1357.2 III Procedure appropriate that address: Staff Authorized to Carry and Use OC Spray (p. 3) # 2 (Training Prerequisites) and #3 (Annual Training) (1) known medical and behavioral health Chapter 5, Section 1357 IV Procedures ☒ ☐ ☐ conditions that would contraindicate certain types Training (p. 22) Bullet 1 of force; The elements of this regulation are confirmed in the Chief Probation Officer (CPO) Appointment and Qualifications Letter, written by Interim Chief Probation Officer (CPO) Brian Ford, and dated June 4, 2024. (2) acceptable chemical agents and the methods Chapter 5, Section 1357 IV Procedures of application. ☒ ☐ ☐ Training (p. 22) Bullet 2 (3) signs or symptoms that should result in Chapter 5, Section 1357 IV Procedures immediate referral to medical or behavioral health. ☒ ☐ ☐ Training (p. 22) Bullet 3 (4) instruction on the Constitutional Limitations of Chapter 5, Section 1357 IV Procedures Use of Force. ☒ ☐ ☐ Training (p. 22) Bullet 4 7003 Alameda Camp Sweeney CAMP Targeted PRO 23-24 Page 12 of 17 A453 JUV Targeted PRO eff. 1/2024 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS (5) physical training force options that may require Chapter 5, Section 1357 IV Procedures the use of perishable skills. Training (p. 22) Bullet 5 The elements of this regulation are confirmed in the Chief Probation Officer ☒ ☐ ☐ (CPO) Appointment and Qualifications Letter, written by Interim Chief Probation Officer (CPO) Brian Ford, and dated June 4, 2024. (6) timelines the facility uses to define regular Chapter 5, Section 1357.2 III, Procedure training. Staff Authorized to Carry and Use OC ☒ ☐ ☐ Spray (p. 3) #3 Annual Training after Initial Training. 1361 GRIEVANCE PROCEDURE Chapter 5, Section 1361 Grievances The facility administrator shall develop and implement BSCC staff requested to review grievances written policies and procedures whereby any youth for January through May 2024, and the may appeal and have resolved grievances relating to Grievance Log covering the past six any condition of confinement, including but not limited months. This included due process to health care services, classification decisions, documentation. There were no grievances program participation, telephone, mail or visiting reported to have been submitted during the procedures, food, clothing, bedding, mistreatment, period requested. harassment or violations of the nondiscrimination policy. There shall be no time limit on filing grievances. BSCC staff also interviewed youth housed Policies and procedures shall include provisions at the facility, camp staff, health services, whereby the facility manager ensures: behavior health, and education services collaborative partners. It is commendable and clearly indicates the ☒ ☐ ☐ relationships between camp youth with staff that no grievances have been filed during this inspection cycle. BSCC staff observed that the agency has incorporated, to youth, supplemental access to grievances through tablets that are individually assigned to youth and allowed to be kept in their rooms. Although it is viewed as a favorable option, BSCC staff provided technical assistance by recommending updating the grievance policy and procedure, as well as, the youth orientation handbook, to include expectations and processes for filing a grievance via the tablets. 7003 Alameda Camp Sweeney CAMP Targeted PRO 23-24 Page 13 of 17 A453 JUV Targeted PRO eff. 1/2024 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS (a) a grievance form and instructions for registering a Chapter 5, Section 1361 IV Procedure grievance, which includes provisions for the youth to Filing a Grievance 1 ⁋ have free access to the form; During our physical inspection, we observed that grievances were readily available to youth. In addition, a grievance ☒ ☐ ☐ lock box was in the dorm to allow youth to confidentially submit a grievance if needed. As well, filing a grievance via individually assigned tablets has been incorporated into the grievance process. (b) the youth shall have the option to confidentially file Chapter 5, Section 1361 IV Procedure the grievance or to deliver the form to any youth Filing a Grievance 1 ⁋ supervision staff working in the facility; The youth were aware of the grievance ☒ ☐ ☐ procedures, the location of the grievances, and the grievance lockbox to confidentially file a grievance, if needed. (c) resolution of the grievance at the lowest Chapter 5, Section 1361 IV Procedure appropriate staff level; Staff Responsibilities #1 ISI ☒ ☐ ☐ The Institution Supervisor I is identified as the lowest staff level via policy and Labor Relations. (d) provision for a prompt review and initial response Chapter 5, Section 1361 IV Procedure to grievances within three (3) business days, Grievance Timeframes. grievances that relate to health and safety issues must be addressed immediately; Per policy, below is the response process for grievances: • ISI to respond by the end of the shift on the day it was received. • ISII to respond if not resolved by ☒ ☐ ☐ the end of the shift on the day received. • Assistant Supt/Manager must respond within 72 hours of receipt. With the implementation of the tablets as an option to submit a grievance, BSCC staff discussed the importance of ensuring that response timelines remain consistent with policy and Title 15 Regulations. (1) The youth may elect to be present to explain Chapter 5, Section 1361 IV Procedure his/her version of the grievance to a person not Filing a Grievance 3 ⁋ directly involved in the circumstances which led to the grievance. The youth interviewed indicated that ☒ ☐ ☐ during the intake and orientation process, the grievance procedure was clearly explained. (2) Provision for a staff representative approved by Chapter 5, Section 1361 IV Procedure the facility administrator to assist the youth. ☒ ☐ ☐ Filing a Grievance 2 ⁋ 7003 Alameda Camp Sweeney CAMP Targeted PRO 23-24 Page 14 of 17 A453 JUV Targeted PRO eff. 1/2024 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS (e) provision for a written response to the grievance Chapter 5, Section 1361 IV Procedure which includes the reasons for the decisions; ☒ ☐ ☐ Filing a Grievance 3 ⁋ (f) a system which provides that any appeal of a Chapter 5, Section 1361 IV Procedure grievance shall be heard by a person not directly Staff Responsibilities involved in the circumstances which led to the ☒ ☐ ☐ grievance; (g) resolution of the grievance must occur within ten Chapter 5, Section 1361 IV Procedure (10) business days unless circumstances dictate a Grievance Timeframes 7 (p. 6) ⁋ longer time frame. The youth shall be notified of any ☒ ☐ ☐ delay; and, (h) the policy shall provide multiple internal and Chapter 5, Section 1361 IV Procedure external methods to report sexual abuse and sexual Reporting Sexual Abuse and Sexual ☒ ☐ ☐ harassment. Harassment Whether or not associated with a grievance, concerns Chapter 5, Section 1361 IV Procedure of parents, guardians, staff or other parties shall be Grievance Timeframes Last (p. 7) ⁋ addressed and documented in accordance with ☒ ☐ ☐ written policies and procedures within a specified timeframe. 1371 PROGRAMS, RECREATION, AND Chapter 6, Section 1371 2B EXERCISE. The facility’s policy and procedures are The facility administrator shall develop and implement applicable to the elements of this written policies and procedures for programs, regulation as required. recreation, and exercise for all youth. The intent is to minimize the amount of time youth are in their rooms BSCC staff reviewed the facility’s or their bed area. Programs, Exercise, and Recreation policy ☒ ☐ ☐ and procedure. We also reviewed pertinent documentation that covered the first 15 days of March, April, and of May 2024. The documentation included, but was not limited to program logs, and program entries in shift reports indicating programming offered to all youth. Juvenile facilities shall provide the opportunity for Chapter 6, Section 1371 II Policy 1 ⁋ programs, recreation, and exercise a minimum of three hours a day during the week and five hours a Camp Sweeney has a variety of programs. day each Saturday, Sunday or other non-school days, Some programs are off-site and of which one hour shall be an outdoor activity, weather encompass programming, recreation, and permitting. exercise. To ensure compliance with each youth receiving the elements of this ☒ ☐ ☐ regulation on a daily basis, BSCC staff provided technical assistance to the facility to document which elements of this regulation are covered on such off-site field trips. It was recommended to add “structured Programming” to the daily shift report. A youth’s participation in programs, recreation, and Chapter 6, Section 1371 II Policy 3 ⁋ exercise may be suspended only upon a written finding by the administrator/manager or designee that BSCC staff reviewed the program tracker a youth represents a threat to the safety and security ☒ ☐ ☐ document for the months of March, April, of the facility. and May of 2024. We also interviewed a youth. 7003 Alameda Camp Sweeney CAMP Targeted PRO 23-24 Page 15 of 17 A453 JUV Targeted PRO eff. 1/2024 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS Such program, recreation, and exercise schedule Chapter 6, Section 1371 III Procedures shall be posted in the living units. Staff Responsibility 1 ⁋ During the physical inspection of both ☒ ☐ ☐ facilities, BSCC observed program and recreation schedule calendars posted in the living units. There will be a written annual review of the programs, Chapter 6, Section 1371 II Policy 5 ⁋ recreation, and exercise by the responsible agency to ensure content offered is current, consistent, and A letter written by Superintendent Albert relevant to the population. Banuelos provides confirmation that an annual review of the programs, recreation, ☒ ☐ ☐ and exercise by the responsible agency was conducted to ensure content offered is current, consistent, and relevant to the population. (a) Programs. All youth shall be provided with the Chapter 6, Section 1371 III Procedure opportunity for at least one hour of daily programming Programming 1-18 (p. 3) to include, but not be limited to, trauma focused, cognitive, evidence-based, best practice interventions The Alameda County Camp Sweeney that are culturally relevant and linguistically offers programs including, but not limited to appropriate, or pro-social interventions and activities the following: designed to reduce recidivism. These programs should be based on the youth’s individual needs as • Aggression Replacement Training required by Sections 1355 and 1356. Such programs may be provided under the direction of the Chief • Beat Within Probation Officer or the County Office of Education and • La Familia (Substance Abuse can be administered by county partners such as mental Education health agencies, community based organizations, • Niroga/Yoga (Mind, Body, Wellness faith-based organizations or Probation staff. • Junior College program Programs may include but are not limited to: • Education Program (SEEP) for (1) Cognitive Behavior Interventions; High School Graduates (2) Management of Stress and Trauma; • Skillsoft (developing work (3) Anger Management; readiness skills) (4) Conflict Resolution; ☐ ☒ ☐ (5) Juvenile Justice System; • Ted Talks (6) Trauma-related interventions; • American Data Prison Systems (7) Victim Awareness; Tablets Applications (8) Self-Improvement; • Today’s Future Sound (Music (9) Parenting Skills and support; Therapy (10) Tolerance and Diversity; • Cooking classes (staff-led) (11) Healing Informed Approaches; • Weight training (12) Interventions by Credible Messengers; • Laney College Courses (online) (13) Gender Specific Programming; (14) Art, creative writing, or self-expression; (15) CPR and First Aid training; BSCC staff discussed the importance of (16) Restorative Justice or Civic Engagement; clearly documenting specific programs that (17) Career and leadership opportunities; and, occurred to ensure that required structured (18) Other topics suitable to the youth population. programming is accounted for. In addition, it was advised to document specifics explaining why a particular program did not occur. 7003 Alameda Camp Sweeney CAMP Targeted PRO 23-24 Page 16 of 17 A453 JUV Targeted PRO eff. 1/2024 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS (b) Recreation. All youth shall be provided the Chapter 6, Section 1371 III Procedure opportunity for at least one hour of daily access to Recreation (p. 4) unscheduled activities such as leisure reading, letter writing, and entertainment. Activities shall be ☒ ☐ ☐ supervised and include orientation and may include coaching of youth. (c) Exercise. All youth shall be provided with the Chapter 6, Section 1371 III Procedure opportunity for at least one hour of large muscle activity Large Muscle Exercise (p. 5) each day. After a review of program activity logs, and interviews with youth housed at the facility and camp staff, Alameda County Camp Sweeney meets compliance with the Title ☒ ☐ ☐ 15 minimum standards for this regulation. BSCC staff thought well of the Weightlifting for Wellness and Golfing for Greatness programs facilitated by behavioral health staff. The administrator/manager may suspend, for a period Chapter 6, Section 1371 III Procedure not to exceed 24 hours, access to recreation and Last (p. 4) ⁋ programs. The administrator/manager shall document ☒ ☐ ☐ the reasons why suspension of recreation and programs occurs. 7003 Alameda Camp Sweeney CAMP Targeted PRO 23-24 Page 17 of 17 A453 JUV Targeted PRO eff. 1/2024