BSCC
Los Angeles SYTF at Barry J Nidorf Facility SYTF Targeted Insp (2023-2024 inspection cycle)
Read the report at Los Angeles SYTF at Barry J Nidorf Facility SYTF Targeted Insp ↗
September 20, 2023
Guillermo Viera Rosa, Interim Chief Probation Officer
C/O Sheila Williams, Deputy Director
Los Angeles County Probation Department
9150 E. Imperial Hwy.
Downey, CA 90242
RE: 2023 TARGETED INSPECTION OF BARRY J. NIDORF SYTF - (WELF. & INST. CODE,
§ 209)
Dear Interim Chief Viera Rosa:
The Targeted Inspection of the Los Angeles County Probation Department’s Secure Youth
Treatment Facility (SYTF) at Barry J. Nidorf Facility has been completed. We appreciate all the
hard work and time spent by your staff preparing for, organizing, and making themselves
available during the onsite visit.
The Board of State and Community Corrections (BSCC) Targeted Inspection report is enclosed
and consists of the following: This transmittal letter and a Targeted Title 15 Procedures Checklist,
outlining applicable the minimum standards we targeted during this inspection.
Please refer to the Title 15 Procedures Checklist for a summary of all relevant minimum
standards, indicators of compliance or noncompliance, and information that was used to
determine compliance.
Scope of the Inspection
For the targeted inspection, we focused on the following Title 15 minimum standards:
1321 Staffing 1360 Searches
1322 Youth Supervision Staff Orientation & 1361 Grievance Procedure
Training 1370 Education Program
1324 Policy and Procedures Manual 1371 Programs, Recreation, And Exercise.
1325 Fire Safety Plan 1374 Visiting
1327 Emergency Procedures 1390 Discipline
1328 Safety Checks 1433 Requests for Health Care Services
1353 Orientation 1480 Standard Facility Clothing Issue
1354.5 Room Confinement 1482 Clothing Exchange
1357 Use of Force 1485 Issue of Personal Care Items
1358 Use of Physical Restraints 1487 Shaving
1358.5 Use of Restraint Devices for Movement 1488 Hair Care Services
and Transportation Within the Facility
Guillermo Viera Rosa, Interim Chief Probation Officer
C/O Sheila Williams, Deputy Director
Page 2
The inspection consisted of a review of the relevant policy and procedures1, a review of
applicable documentation to ensure that practice and policies are aligned and consistent with
Title 15, an on-site visit to review operations and physical plant, and interviews with
administration, facility staff, youth, and collaborative partners.
BSCC INSPECTION RESULTS
Title 15, CCR Minimum Standards
As indicated in the Initial Inspection Report (IIR) provided on August 11, 2023, we found the
following items of noncompliance at the facility; please refer to the Procedures Checklist for
detailed information regarding each section.
1. § 1321. Staffing.
2. § 1322. Youth Supervision Staff Orientation and Training.
3. § 1324. Policy and Procedures Manual.
4. § 1328. Safety Checks.
5. § 1353. Orientation.
6. § 1357. Use of Force.
7. § 1360. Searches.
8. § 1370. Education Program.
9. § 1371. Programs, Recreation, and Exercise.
10. § 1390. Discipline.
Corrective Action Required
As indicated in your IIR, an approved Corrective Action Plan (CAP) must be submitted to the
BSCC no later than October 10, 2023 (Welfare and Institutions Code section 209 (d)). The CAP
must clearly outline how the agency plans to correct each area of noncompliance, within a
reasonable timeframe, not to exceed 90 days from the submittal of the CAP. BSCC staff is
available for technical assistance as needed; you may submit a draft CAP at any time before the
October 10 due date for preliminary review.
Should you have questions, please email me at lisa.southwell@bscc.ca.gov or call me at (916)
838-9132.
Sincerely,
LISA SOUTHWELL
Field Representative
Facilities Standards and Operations Division
1 BSCC reviews only those policies and procedures required by, and applicable to, Title 15, CCR. BSCC staff do not “approve”
policies and procedures. Agencies should seek review through their legal advisor, risk manager, and other persons deemed
appropriate.
7205 Los Angeles SYTF @ BJN SYTF LTR 23-24
Guillermo Viera Rosa, Interim Chief Probation Officer
C/O Sheila Williams, Deputy Director
Page 3
Enclosures
Cc: Presiding Judge, Juvenile Court, Los Angeles County*
Chair, Juvenile Justice Commission, Los Angeles County*
Chair, Board of Supervisors, Los Angeles County*
County Administrator, Los Angeles County*
*Copies of the full inspection are available online at www.bscc.ca.gov.
7205 Los Angeles SYTF@BJN LTR 23-24
JUVENILE HALLS, SPECIAL-PURPOSE JUVENILE HALLS AND CAMPS
Board of State and Community Corrections
TARGETED INSPECTION PROCEDURES CHECKLIST1
BSCC Code: 7205
FACILITY NAME: FACILITY TYPE:
Secure Youth Treatment Facility (SYTF) @ Barry J Nidorf Secure Youth Treatment Facility
PERSON(S) INTERVIEWED:
Tracy Novak, Marlon Barbarin, Curtis Miller and Scott Sanders. Various youth and staff throughout the facility.
FIELD REPRESENTATIVE: DATE:
Lisa Southwell August 7-11, 2023
TITLE 15 SECTION Yes No NA P/P REFERENCE – COMMENTS
1321 STAFFING DSB Manual Section 206: Staffing
Requirement and Ratios
Each juvenile facility shall:
(a) have an adequate number of personnel
Facility shift staffing forms were provided for
sufficient to carry out the overall facility operation
the week of July 20-July 27, 2023.
and its programming, to provide for safety and
security of youth and staff, and meet established
Some shifts were minimally staffed. Staff
standards and regulations;
report they are routinely held over with no
notice to cover shifts and report they are
exhausted as a result. Most staff believe the
unscheduled, mandatory holdovers
negatively impact attendance.
We noted instances in which youth were in
dayrooms alone because the assigned unit
☐ ☒ ☐
staff were busy with other operational
requirements (in and out of the office or down
the hallway) or needed to use the restroom.
Youth also report not feeling safe due to the
lack of staff. Those youth we spoke to spoke
highly of most staff but noted “we need more
staff.” It was also reported by some youths
that they are urinating in receptacles in their
rooms due to a lack of staff and having to wait
for long periods of time late at night.
Staffing is an ongoing issue of
noncompliance.
(b) ensure that no required services shall be denied DSB Manual Section 206: Staffing
because of insufficient numbers of staff on duty Requirement and Ratios
absent exigent circumstances;
There were periods noted where youth were
not participating in required activities due to a
☐ ☒ ☐ lack of staff. We spoke with youth who
confirmed that there has been some positive
progress in youth going to school, high school
graduates attending college classes, and
youth getting outside for exercise
1 This document is intended for use as a tool during the 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 Local Facilities, Division 1, Chapter 1, Subchapter 5 for the complete list and
text of regulations.
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TITLE 15 SECTION Yes No NA P/P REFERENCE – COMMENTS
(c) have a sufficient number of supervisory level DSB Manual Section 206: Staffing
staff to ensure adequate supervision of all staff Requirement and Ratios
members;
At the time of inspection, the facility population
average was 61 youth and staffing was
minimal. The facility has recently undergone a
management change, including senior
management, directors, and some
supervisors.
During the time period reviewed, and per the
documentation reviewed, we did not note any
operational issues or concerns related to or
due to lack of supervision and do not find the
facility to be noncompliant in this area. Most
☒ ☐ ☐
shifts had a Supervisor (OD) and a Back-Up
(BU) Supervisor on shift except for the 10 PM-
6 AM shifts, during which a few had only a
Supervisor (OD) on duty. There were four
additional shifts of the 21 reviewed, where
other supervisors were noted to be on shift;
however, there was no consistency as to how
many supervisors were on which shift.
Technical Assistance was provided, and it was
suggested to management to review the
facility supervisor and director roles and
schedules to always ensure consistent
supervisory coverage.
(d) have a clearly identified person on duty at all DSB Manual Section 206: Staffing
times who is responsible for operations and Requirement and Ratios
activities and has completed the Juvenile
☒ ☐ ☐
Corrections Officer Core Course and PC 832
training;
(e) have at least one staff member present on each DSB Manual Section 206: Staffing
living unit whenever there are youth in the living unit; Requirement and Ratios
☒ ☐ ☐
(f) have sufficient food service personnel relative to DSB Manual Section 206: Staffing
the number and security of living units, including Requirement and Ratios
staff qualified and available to: plan menus meeting
nutritional requirements of youth; provide kitchen
supervision; direct food preparation and servings;
☒ ☐ ☐
conduct related training programs for culinary staff;
and maintain necessary records; or, a facility may
serve food that meets nutritional standards
prepared by an outside source;
(g) have sufficient administrative, clerical, DSB Manual Section 206: Staffing
recreational, medical, dental, mental health, Requirement and Ratios
building maintenance, transportation, control room,
facility security and other support staff for the
efficient management of the facility, and to ensure
that youth supervision staff shall not be diverted ☒ ☐ ☐
from supervising youth; and,
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TITLE 15 SECTION Yes No NA P/P REFERENCE – COMMENTS
(h) assign sufficient youth supervision staff to DSB Manual Section 206: Staffing
provide continuous wide awake supervision of Requirement and Ratios
youth, subject to temporary variations in staff
assignments to meet special program needs. The documentation reviewed provided staffing
☒ ☐ ☐
Staffing shall be in compliance with a minimum numbers that met the ratio. The SYTF @ the
youth-staff ratio for the following facility types: BJN is compliant by ratio.
(1) Juvenile Halls DSB Manual Section 206: Staffing
(A) during the hours that youth are awake, Requirement and Ratios
one wide-awake youth supervision staff
member on duty for each 10 youth in LA County Probation requires by policy, a
☒ ☐ ☐
detention; PREA Staffing standard of 1-8 which exceeds
Title 15 regulation. Both 1-10 and 1-8 have
been met.
(B) during the hours that youth are confined DSB Manual Section 206: Staffing
to their room for the purpose of sleeping, one Requirement and Ratios
wide-awake youth supervision staff member
on duty for each 30 youth in detention; LA County Probation requires by policy, a
☒ ☐ ☐ PREA Staffing standard of 1-16 which exceeds
Title 15 regulation. The facility does not meet
its own policy but does meet the Title 15 ratio
of 1-30.
(C) at least two wide-awake youth DSB Manual Section 206: Staffing
supervision staff members on duty at all Requirement and Ratios
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 DSB Manual Section 206: Staffing
member on duty who is the same gender as Requirement and Ratios
☒ ☐ ☐
youth housed in the facility.
(E) personnel with primary responsibility for DSB Manual Section 206: Staffing
other duties such as administration, Requirement and Ratios
supervision of personnel, academic or trade
instruction, clerical, kitchen or maintenance ☒ ☐ ☐
shall not be classified as youth supervision
staff positions.
2(a-e), Special Purpose JH and Removed as does not apply.
3(a-e), Camps
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TITLE 15 SECTION Yes No NA P/P REFERENCE – COMMENTS
1322 YOUTH SUPERVISION STAFF DSB Manual Section 205: Youth Supervision
ORIENTATION AND TRAINING Staff Orientation and Training
(a) Prior to assuming any responsibilities each
Staff assigned to the facility to conduct youth
youth supervision staff member shall be properly
supervision duties consist of regularly
oriented to their duties, including:
assigned facility staff, deployed staff from the
(1) youth supervision duties;
field, and staff who may have been
(2) scope of decisions they shall make;
reassigned back into the facility.
(3) the identity of their supervisor;
(4) the identity of persons who are responsible
There has been a significant movement of
to them;
staff to cover shifts and to staff the facility. It
(5) persons to contact for decisions that are
appears staff have been oriented, and those
beyond their responsibility; and
we spoke with were aware of the items
(6) ethical responsibilities.
identified in the regulation; however, we found
no formalized process to ensure consistency
in how the orientation was conducted.
Technical assistance was provided,
suggesting the development of a formalized
orientation process to include a sign-off line
that could be documented for the 40-hour
☒ ☐ ☐
training. This would ensure all staff coming
into the facility receive a consistent
orientation.
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TITLE 15 SECTION Yes No NA P/P REFERENCE – COMMENTS
(b) Prior to assuming any responsibility for the DSB Manual Section 205: Youth Supervision
supervision of youth, each youth supervision staff Staff Orientation and Training
member shall receive a minimum of 40 hours of
facility-specific orientation, including: The facility has had a significant movement of
(1) individual and group supervision techniques; staff (as noted in 1322(a) above) in and out of
(2) regulations and policies relating to discipline the facility and regularly uses a significant
and rights of youth pursuant to law and the number of deployed and reassigned staff to
provisions of this chapter; cover the staffing shortages in addition to the
(3) basic health, sanitation and safety regularly assigned staff.
measures;
(4) suicide prevention and response to suicide We are unable to verify the 40 hours of
attempts required facility-specific training as training
(5) policies regarding use of force, de- records have not been provided.
☐ ☒ ☐
escalation techniques, chemical agents,
mechanical and physical restraints;
(6) review of policies and procedures
referencing trauma and trauma-informed
approaches;
(7) procedures to follow in the event of
emergencies;
(8) routine security measures, including facility
perimeter and grounds;
(9) crisis intervention and mental health
referrals to mental health services;
(10) documentation; and
(11) fire/life safety training
(c) Prior to assuming sole supervision of youth, No training records were provided.
each youth supervision staff member shall
successfully complete the requirements of the
☐ ☒ ☐
Juvenile Corrections Officer Core Course pursuant
to Penal Code Section 6035.
(d) Prior to exercising the powers of a peace officer No training records were provided.
youth supervision staff shall successfully complete
training pursuant to Section 830 et seq. of the Penal ☐ ☒ ☐
Code.
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TITLE 15 SECTION Yes No NA P/P REFERENCE – COMMENTS
1324 POLICY AND PROCEDURES MANUAL The Detention Services Bureau manual was
last updated in 2022. The policy has not been
All facility administrators shall develop, publish, and
updated to reflect policy or procedure changes
implement a manual of written policies and
specific to the Secure Youth Treatment Facility
procedures that address, at a minimum, all
(SYTF) population now that the Juvenile Hall
regulations that are applicable to the facility. Such a
has been closed. A policy manual specific to
manual shall be made available to all employees,
SYTF @ BJN has been drafted; however, the
reviewed by all employees, and shall be
policy and procedures specific to SYTF are not
administratively reviewed at a minimum every two
final or available to staff working at the facility.
years, and updated, as necessary. Those records
relating to the standards and requirements set forth
We have been advised that the manual is
in these regulations shall be accessible to the Board
pending additional updates as upper
on request.
management and labor representatives still
The manual shall include:
need to review, approve, and finalize. SYTF
staff do not have access to the draft manual
and continue to use the Detention Services
Bureau (DSB) manual; all policy cited in this
report is from this manual.
Multiple directives and full DSB policy sections
have been approved and released to facility
staff as recently as July 25, 2023; however,
there is no consistency between these
documents and actual practice, nor are staff
required to sign off when a new policy update
☒
☐ ☐ or directive is released to be sure it has been
received, read and understood by facility staff,
or that they have been trained on the new
policy or directive.
We suggest that all documents that are policy
or procedure-based are reviewed to ensure
that clear, consistent, and specific directions
are provided to staff. We will continue to
provide Technical Assistance as requested
and assist with reviewing the individual
sections as they become available upon
request.
This item will remain out of compliance until a
final policy and procedure manual is available
to all employees and the manual consistently
addresses each of the required items for the
facility.
*Includes Regulation 1327: Emergency
Procedures
The remainder of the checkboxes in this
regulation are left blank.
(a) table of organization, including channels of
communications and a description of job
☐ ☐ ☐
classifications;
(b) responsibility of the probation department,
purpose of programs, relationship to the juvenile
court, the Juvenile Justice/Delinquency Prevention
Commission or Probation Committee, probation ☐ ☐ ☐
staff, school personnel and other agencies that are
involved in juvenile facility programs;
(c) responsibilities of all employees;
☐ ☐ ☐
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TITLE 15 SECTION Yes No NA P/P REFERENCE – COMMENTS
(d) initial orientation and training program for
employees; ☐ ☐ ☐
(e) initial orientation, including safety and security
issues and anti-discrimination policies, for support
staff, contract employees, school,
☐ ☐ ☐
mental/behavioral health and medical staff,
program providers and volunteers;
(f) maintenance of record-keeping, statistics and
communication system to ensure: ☐ ☐ ☐
(1) efficient operation of the juvenile facility;
☐ ☐ ☐
(2) legal and proper care of youth;
☐ ☐ ☐
(3) maintenance of individual youth's records;
☐ ☐ ☐
(4) supply of information to the juvenile court
and those authorized by the court or by the law;
☐ ☐ ☐
and,
(5) release of information regarding youth.
☐ ☐ ☐
(g) ethical responsibilities;
☐ ☐ ☐
(h) trauma-informed approaches;
☐ ☐ ☐
(i) culturally responsive approaches;
☐ ☐ ☐
(j) gender responsive approaches;
☐ ☐ ☐
(k) a non-discrimination provision that provides
that all youth within the facility shall have fair and
equal access to all available services, placement,
care, treatment, and benefits, and provides that no
person shall be subject to discrimination or
harassment on the basis of actual or perceived
race, ethnic group identification, ancestry, national
☐ ☐ ☐
origin, immigration status, color, religion, gender,
sexual orientation, gender identity, gender
expression, mental or physical disability, or HIV
status, including restrictive housing or classification
decisions based solely on any of the above
mentioned categories;
(l) storage and maintenance requirements for any
chemical agents related security devices, and
☐ ☐ ☐
weapons and ammunition, where applicable;
(m) establishment of procedures for collection of
Medi-Cal eligibility information and enrollment of
☐ ☐ ☐
eligible youth; and,
(n) establishment of a policy that prohibits all forms
of sexual abuse, sexual assault and sexual
harassment. The policy shall include an approach
to preventing, detecting and responding to such
☐ ☐ ☐
conduct and any retaliation for reporting such
conduct, as well as a provision for reporting such
conduct by youth, staff or a third party.
1325 FIRE SAFETY PLAN The Fire Suppression Plan was completed
and signed off by Brian Whalen on February 9,
The facility administrator shall consult with the local
2023.
fire department having jurisdiction over the facility,
or with the State Fire Marshal, in developing a plan ☒
☐ ☐
for fire safety which shall include, but not be limited
to:
(a) a fire prevention plan to be included as part of
the manual of policy and procedures;
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TITLE 15 SECTION Yes No NA P/P REFERENCE – COMMENTS
(b) monthly fire and life safety inspections by facility DSB Manual Section 911: Fire Prevention and
staff with two-year retention of the inspection Suppression
record; ☒ ☐ ☐
Completed.
(c) fire prevention inspections as required by DSB Manual Section 911: Fire Prevention and
Health and Safety Code Section 13146.1(a) and Suppression
(b); ☒ ☐ ☐
The facility has a current fire clearance.
(d) an evacuation plan; DSB Manual Section 920: Emergency
Evacuation and County of Los Angeles
Building Emergency Plan of County Buildings
☒ ☐ ☐ Evacuation maps are in the units. Technical
assistance was provided while in some of the
units to reprint those that were marked up with
graffiti.
(e) documented fire drills not less than quarterly; DSB Manual Section 911: Fire Prevention and
Suppression
Fire drills have been completed monthly up
until June 2023. Four units T, V, Y1, or Y2 did
☒ ☐ ☐
not participate in the monthly fire drill in July.
Title 15 requires fire drills to be completed
quarterly.
(f) a written plan for the emergency housing of DSB Manual Section 921: Operation FLEE
youth in the case of fire; and, and County of Los Angeles Building
Emergency Plan of County Buildings
If a full evacuation and emergency housing
were necessary, the youth would be housed at
☒ ☐ ☐ Campus Kilpatrick per facility administration.
Attempts were made to receive the updated
policy and to date, we have not received a
written plan. The agency is working on this
process; this will need to be addressed in
corrective action.
(g) development of a fire suppression pre-plan in DSB Manual Section 911: Fire Prevention and
cooperation with the local fire department. Suppression
☒ ☐ ☐
The fire suppression pre-plan was completed
with Brian Whelan in February 2023.
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TITLE 15 SECTION Yes No NA P/P REFERENCE – COMMENTS
1327 EMERGENCY PROCEDURES DSB Manual Section 900: Emergency
Procedures to include:
The facility administrator shall develop facility-
DSB Manual Section 906: Escapes (Code
specific policies and procedures for emergencies
Green)
that shall include, but not be limited to:
DSB Manual Section 908: Major Disturbances
(Code Red)
DSB Manual Section 916: Hostages
DSB Manual Section 907: Outside Intruder
(Code Yellow)
DSB Manual Section 917: Active Shooter
DSB Manual Section 918: Terrorist Attack
DSB Manual Section 919: Civil Disturbance
☒
☐ ☐ DSB Manual Section 911: Fire Prevention and
Suppression
DSB Manual Section 913: Power Failure
DSB Manual Section 915: Earthquakes
DSB Manual Section 910: Testing of
Emergency Equipment
DSB Manual Section 920: Emergency
Evacuation
Emergency procedures are pending updates;
the SYTF continues to use DSB Emergency
Procedures in the interim.
(a) escape, disturbances, and the taking of See above.
☒
hostages; ☐ ☐
(b) civil disturbance, active shooter and terrorist
☒
attack; ☐ ☐
(c) fire and natural disasters; ☒
☐ ☐
(d) periodic testing of emergency equipment; ☒
☐ ☐
(e) emergency evacuation of the facility; and ☒
☐ ☐
(f) a program to provide all youth supervision DSB Manual Section 920: Emergency
staff with an annual review of emergency Evacuation
procedures.
Annual Emergency Procedure Reviews are
compliant.
☒ ☐ ☐
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TITLE 15 SECTION Yes No NA P/P REFERENCE – COMMENTS
1328 SAFETY CHECKS DSB Manual Section 209: Duty Statement-
Senior Detention Services Officer
The facility administrator shall develop and
DSB Manual Section 210: Duty Statement-
implement policy and procedures that provide for
Detention Services Officer
direct visual observation of youth at a minimum of
DSB Manual Section 211: Group Supervisor
every 15 minutes, at random or varied intervals
Nights
during hours when youth are asleep or when
DSB Manual Section 630: Safety Checks
youth are in their rooms, confined in holding cells
or confined to their bed in a dormitory.
Safety checks were reviewed for July 20, 2023
Supervision is not replaced, but may be
-July 27, 2023, for Units N, O, Z1, Z2, Y1, Y2,
supplemented by, an audio/visual electronic
T, and V for all shifts. This review consisted of
surveillance system designed to detect overt,
reviewing electronic records of the Guard 1
aggressive or assaultive behavior and to summon
☐ ☒ ☐ System.
aid in emergencies. All safety checks shall be
documented with the actual time the check is
The review of the Guard 1 system report
completed.
indicated that safety checks exceed 15
minutes. We conducted a review of a random
sample of video, which indicates
inconsistencies with the Guard 1 report. We
also noted that staff are not recording late
checks in the system, as required by policy,
nor are there any audits or reviews being
completed by seniors or supervisors as
required by Directive 1490.
1353 ORIENTATION DSB Manual Section 416: Orientation Process
for Detained Youth
The facility administrator shall develop and
implement written policies and procedures to
The documentation provided did not include
orient a youth prior to placement in a living area.
any information specific to the SYTF
Both written and verbal information shall be
population.
provided and supplemented with video orientation
if feasible. Provision shall be made to provide
☒ Technical Assistance provided that a
accessible orientation information to all detained ☐ ☐
handbook and documentation will need to be
youth including those with disabilities, limited
implemented specific to the population and
literacy, or English language learners. Orientation
facility that includes the specific items required
shall include information that addresses:
by regulation for compliance.
The remainder of the checkboxes in this
regulation are left blank.
(a) facility rules including contraband and searches
and disciplinary procedures; ☐ ☐ ☐
(b) facility’s system of positive behavior
interventions and supports, including behavior
expectations, incentives that youth will receive for
complying with facility rules, and consequences ☐ ☐ ☐
that may result when youth violate the rules of the
facility;
(c) age appropriate information that explains the
facility’s policy prohibiting sexual abuse and sexual
harassment and how to report incidents or ☐ ☐ ☐
suspicions of sexual abuse or sexual harassment;
(d) identification of key staff and their roles;
☐ ☐ ☐
(e) the existence of the grievance procedure, the
steps that must be taken to use it, the youth’s right
to be free of retaliation for reporting a grievance,
☐ ☐ ☐
and the name of the person or position designated
to resolve the issue;
(f) access to legal services and information on the
court process; ☐ ☐ ☐
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TITLE 15 SECTION Yes No NA P/P REFERENCE – COMMENTS
(g) access to routine and emergency health and
mental health care; ☐ ☐ ☐
(h) access to education, religious services, and
recreational activities; ☐ ☐ ☐
(i) housing assignments;
☐ ☐ ☐
(j) opportunity for personal hygiene and daily
showers including the availability of personal care
☐ ☐ ☐
items
(k) rules and access to correspondence, visits and
telephone use; ☐ ☐ ☐
(l) availability of reading materials, programming,
and other activities; ☐ ☐ ☐
(m) facility policies on the use of force, use of
restraints, chemical agents and room confinement; ☐ ☐ ☐
(n) immigration legal services;
☐ ☐ ☐
(o) emergencies including evacuation procedures;
☐ ☐ ☐
(p) non-discrimination policy and the right to be
free from physical, verbal or sexual abuse and
☐ ☐ ☐
harassment by other youth and staff;
(q) availability of services and programs in a
language other than English if appropriate; ☐ ☐ ☐
(r) the process for requesting different housing,
education, programming and work assignments; ☐ ☐ ☐
(s) a process for which parents/guardians receive
information regarding the youth’s stay in the facility
that at a minimum includes answers to frequently
asked questions and provides contact information ☐ ☐ ☐
for the facility, medical, school and mental health;
and,
(t) a process by which youth may request access
to Title 15 Minimum Standards for Juvenile
☐ ☐ ☐
Facilities.
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1354.5 ROOM CONFINEMENT DSB Manual Section 1303: Room
Confinement.
(a) The facility administrator shall develop and
implement written policies and procedures
As noted in DSB Manual Section 1324,
addressing the confinement of youth in their room
additional policy documentation was provided
that are consistent with Welfare and Institutions
including Policy Section 600, which includes
Code Section 208.3. The placement of a youth in
607: Modified Program. There are conflicts
room confinement shall be accomplished in
between the policies and directives that need
accordance with the following guidelines:
clarification.
We requested documentation for July 20-27,
2023. We were told that there was no room
confinement between those times and were
eventually provided with three (3) room
confinement packets dating back to May
2023. One of the packets lacked a director’s
four-hour review.
Youth reported they may be placed in their
room for time outs to calm down until they can
be counseled after an incident, or after an
incident for various reasons. Staff report
some of the same; however, no egregious
lengths of time were reported.
Based upon these conversations, it appears
staff are either not aware of what constitutes
☐ ☐ ☐ room confinement or do not have adequate
resources to place youth in room confinement
safely. The policy lacks clarity; in parts, the
policy directs staff to seclude youth from the
rest of the group utilizing the youth’s room for
a cool-down period where officers provide
continued direct observation. The policy is not
specific to whether the door remains open or
is closed. If the door is closed, this becomes
room confinement. Since the policy is not
specific, we are unsure what the actual
procedure is.
The policy should be updated, and all staff
should be retrained to recognize room
confinement to maintain compliance. Any use
of room confinement must be documented to
ensure compliance with both statute and
regulation.
Without documentation, we are unable to
determine when and how room
confinement is occurring. We will be
conducting follow-up inspections to
determine compliance. The remainder of
the checkboxes in this regulation are left
blank.
(1) Room confinement shall not be used before
other, less restrictive, options have been
attempted and exhausted, unless attempting
☐ ☐ ☐
those options poses a threat to the safety or
security of any youth or staff.
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(2) Room confinement shall not be used for the
purposes of punishment, coercion,
☐ ☐ ☐
convenience, or retaliation by staff.
(3) Room confinement shall not be used to the
extent that it compromises the mental and
☐ ☐ ☐
physical health of the youth.
(b) A youth may be held up to four hours in room
confinement. After the youth has been held in
room confinement for a period of four hours, staff ☐ ☐ ☐
shall do one or more of the following:
(1) Return the youth to general population.
☐ ☐ ☐
(2) Consult with mental health or medical staff.
☐ ☐ ☐
(3) Develop an individualized plan that includes
the goals and objectives to be met in order to
☐ ☐ ☐
reintegrate the youth to general population.
(4) If room confinement must be extended
beyond four hours, staff shall do each of the
☐ ☐ ☐
following:
(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 the goals and objectives to be met
in order to integrate the youth to general ☐ ☐ ☐
population.
(C) Obtain documented authorization by the
facility superintendent or his or her designee
☐ ☐ ☐
every four hours thereafter.
(5) This section is not intended to limit the use
of single-person rooms or cells for the housing
of youth in juvenile facilities and does not apply ☐ ☐ ☐
to normal sleeping hours.
(6) This section does not apply to youth or
wards in court holding facilities or adult
☐ ☐ ☐
facilities.
(7) Nothing in this section shall be construed to
conflict with any law providing greater or
☐ ☐ ☐
additional protections to youth.
(8) This section does not apply during an
extraordinary emergency circumstance that
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.
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(9) This section does not apply when a youth is
placed in a locked cell or sleeping room to treat
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 Directive 1477: Detention and Residential
Treatment Services Bureaus Manual-Physical
The facility administrator, in cooperation with the
Intervention Policy (DSB Manual Section
responsible physician, shall develop and
DSB-1000/RTSB-1700) Issued 06/22/2022.
implement written policies and procedures for the
Policy 1000 was issued on July 25, 2023, and
use of force, which may include chemical agents.
approved by DSB Bureau Chief Kevin Woods.
Force shall never be applied as punishment,
Policy Section 1000 was reapproved from
discipline, retaliation or treatment.
previous Directive 1477.
(a) At a minimum, each facility shall develop
policies and procedures which:
All staff, including those deployed or
reassigned to the facility, have not been
trained as required in the Use of Force,
including the use of OC, despite the original
directive being approved in June 2022.
Training requires initial training and an annual
refresher. We understand that training has
been developed and scheduling is in progress.
During our review of incident documentation,
there were a few packets missing the incident
☒ ☐ debriefs or parent contact as required. There
☐
have been changes in personnel lately; while
this does not appear to be an ongoing issue, it
is being addressed through a training memo to
the supervisors responsible for the tasks.
The policy also notes the availability of
resource teams comprised of mental health,
nursing, and probation staff to respond to
situations to defuse and de-escalate crises.
There were no such teams at the facility at the
time of inspection.
We noted that for most of the incidents
reviewed, a debrief was not completed; the
First Team reports not receiving reports timely.
Aside from specific items of
noncompliance, the remainder of the
checkboxes in this regulation are left
blank.
(1) restricts the use of force to that which is
deemed reasonable and necessary, as defined
in Section 1302 to ensure the safety and security ☐ ☐ ☐
of youth, staff, others and the facility.
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(2) outline the force options available to staff
including both physical and non-physical options
and define when those force options are ☐ ☐ ☐
appropriate.
(3) describe force options or techniques that are
expressly prohibited by the facility. ☐ ☐ ☐
(4) describe the requirements of staff to report
any inappropriate use of force, and to take
☐ ☐ ☐
affirmative action to immediately stop it.
(5) define a standardized reporting format that
includes time period and procedure for
documenting and reporting the use of force,
including reporting requirements of
management and line staff and procedures for
reviewing and tracking use of force incidents by
supervisory and or management staff, which ☐ ☐ ☐
include procedures for debriefing a particular
incident with staff and/or youth for the purposes
of training as well as mitigating the effects of
trauma that may have been experienced by staff
and /or the youth involved.
(6) Include an administrative review and a
system for investigating unreasonable use of
☐ ☐ ☐
force.
(7) define the role, notification, and follow-up Parent contact was not consistently
procedures required after use of force incidents documented.
☒
for medical, mental health staff and parents or ☐ ☐
legal guardians.
(8) describe the limitations of use of force on
pregnant youth in accordance with Penal Code
Section 6030(f) and Welfare and Institutions ☐ ☐ ☐
Code Section 222.
(b) Facilities that authorize chemical agents as a Only one use of OC was provided for review in
force option shall include policies and procedures eight (8) incidents reviewed; documentation
that: indicates it was deployed consistent with
(1) identify who is approved to carry and/or policy and procedure.
☐ ☐ ☐
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
when there is an imminent threat to the youth’s
safety or the safety of others and only when de-
☐ ☐ ☐
escalation efforts have been unsuccessful or are
not reasonably possible.
(3) outline the facility’s approved methods and
timelines for decontamination from chemical
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 No parent was notified in this instance.
procedures required after use of force incidents
☒
involving chemical agents for medical, mental ☐ ☐
health staff and parents or legal guardians.
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(5) provide for the documentation of each
incident of use of chemical agents, including
the reasons 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 The facility has not completed training as
which require that agencies provide initial and required by policy.
☒
regular training in use of force and chemical agents ☐ ☐
when appropriate that address:
(1) known medical and behavioral health
conditions that would contraindicate certain ☒
☐ ☐
types of force;
(2) acceptable chemical agents and the
☒
methods of application. ☐ ☐
(3) signs or symptoms that should result in
immediate referral to medical or behavioral ☒
☐ ☐
health.
(4) instruction on the Constitutional Limitations
☒
of Use of Force. ☐ ☐
(5) physical training force options that may
☒
require the use of perishable skills. ☐ ☐
(6) timelines the facility uses to define regular
☒
training. ☐ ☐
1358 USE OF PHYSICAL RESTRAINTS Directive 1477: Detention and Residential
Treatment Services Bureaus Manual-Physical
The facility administrator, in cooperation with the
Intervention Policy (DSB Manual Section
responsible physician and mental health director,
DSB-1000/RTSB-1700) Issued on June 22,
shall develop and implement written policies and
2022.
procedures for the use of restraint devices.
Restraint devices include any devices which
☒ Policy 1000 was issued on July 25, 2023, and
immobilize a youth's extremities and/or prevent the ☐ ☐
approved by DSB Bureau Chief Kevin Woods.
youth from being ambulatory.
Restraints are not generally used. Of the
incidents reviewed for the time period
requested, only one incident included the use
of restraints.
Physical restraints may be used only for those
youth who present an immediate danger to
themselves or others, who exhibit behavior which
results in the destruction of property, or reveals the
☒
intent to cause self-inflicted physical harm. ☐ ☐
Physical restraints should be utilized only when it
appears less restrictive alternatives would be
ineffective in controlling the youth’s behavior.
In no case shall restraints be used as punishment
or discipline, or as a substitute for treatment. The
use of restraint devices that attach a youth to a wall,
floor or other fixture, including a restraint chair, or
through affixing of hands and feet together behind ☒
☐ ☐
the back (hogtying) is prohibited. The use of
restraints on pregnant youth is limited in accordance
with Penal Code Section 6030(f) and Welfare and
Institutions Code Section 222.
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The provisions of this section do not apply to the use
of handcuffs, shackles or other restraint devices
when used to restrain youth for movement or
transportation within the facility. Movement within ☒
☐ ☐
the facility shall be governed by Section 1358.5,
Use of Restraint Devices for Movement Within the
Facility.
Youth shall be placed in restraints only with the
approval of the facility manager or designee. The
facility manager may delegate authority to place a
☒
youth in restraints to a physician. Reasons for ☐ ☐
continued retention in restraints shall be reviewed
and documented at a minimum of every hour.
A medical opinion on the safety of placement and
retention shall be secured as soon as possible, but
no later than two hours from the time of placement. ☒
☐ ☐
The youth shall be medically cleared for continued
retention at least every three hours thereafter.
A mental health consultation shall be secured as The Physical Interventions Policy was not
soon as possible, but in no case longer than four clear regarding the four (4) hour requirement
hours from the time of placement, to assess the for MH assessment for treatment if an incident
need for mental health treatment. occurs after hours. Facility management has
☒
☐ ☐ drafted a training memo that has been sent to
facility supervisors to clarify the procedure to
resolve the issue until the policy can be
updated.
Continuous direct visual supervision shall be
conducted to ensure that the restraints are properly
employed, and to ensure the safety and well-being
of the youth. Observations of the youth's behavior ☒
☐ ☐
and any staff interventions shall be documented at
least every 15 minutes, with actual time of the
documentation recorded.
In addition to the requirements above, policies and
procedures shall address:
☒ ☐ ☐
(a) documentation of the circumstances leading to
an application of restraints.
(b) known medical conditions that would
contraindicate certain restraint devices and/or ☒ ☐ ☐
techniques.
(c) acceptable restraint devices. ☒ ☐ ☐
(d) signs or symptoms which should result in
☒ ☐ ☐
immediate medical/mental health referral.
(e) availability of cardiopulmonary resuscitation
☒ ☐ ☐
equipment.
(f) protective housing of restrained youth. While in
restraint devices, all youth shall be housed alone
or in a specified housing area for restrained youth ☒ ☐ ☐
which makes provision to protect the youth from
abuse.
(g) provision for hydration and sanitation needs. ☒ ☐ ☐
(h) exercising of extremities. ☒ ☐ ☐
(a) identification of acceptable restraint devices,
staff approved to utilize restraint devices and the
☒ ☐ ☐
required training.
(b) the circumstances leading to the application of
restraints must be documented. ☒ ☐ ☐
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1358.5 USE OF RESTRAINT DEVICES FOR DSB Manual Section 809: The Use of
MOVEMENT AND TRANSPORTATION Mechanical Restraints for Movement and
WITHIN THE FACILITY. Transport Within the Facility
The Facility Administrator, in cooperation with the
responsible physician and behavioral/mental
☒ ☐ ☐
health director, shall develop and implement
written policies and procedures for the use of
restraint devices when the purpose is for
movement or transportation within the facility that
shall include the following:
(a) identification of acceptable restraint devices,
staff approved to utilize restraint devices and the
☒ ☐ ☐
required training.
(b) the circumstances leading to the application of
restraints must be documented. ☒ ☐ ☐
(c) an individual assessment of the need to apply Eight (8) incidents/Safe Crisis Management
restraints for movement or transportation that (SCM) reports were provided for our review.
includes consideration of less restrictive Other documentation reviewed consisted of
alternatives, consideration of a youth’s known Room Confinement and Special Incident
medical or mental health conditions, trauma Reviews.
informed approaches, and a process for
☒ ☐ ☐
documentation and supervisor review and It is rare that the facility staff use handcuffs to
approval. control the movement of youth post-incident.
We found only one of eight (8) use-of-force
incidents in which handcuffs were utilized and
the assessment was not completed.
(d) consideration of safety and security of the
facility, with a clearly defined expectation that
restraint devices shall not be used for the ☒ ☐ ☐
purposes of discipline or retaliation.
(e) the use of restraints on pregnant youth is
limited in accordance with Penal Code Section
6030(f) and Welfare and Institutions Code Section ☒ ☐ ☐
222.
1360 SEARCHES DSB Manual Section 700: Searches
The facility administrator shall develop and
implement written policies and procedures ☒ ☐ ☐
governing the search of youth, the facility, and
visitors. Policies and procedures shall provide that:
(a) Searches shall be conducted to ensure the DSB Manual Section 701: Introduction
safety and security of the facility, public, visitors,
youth, and staff. According to policy, room and unit area
searches are required daily, and two thorough
contraband searches are required weekly.
A July Search Log was provided for review.
☐ ☒ ☐ Room and facility searches were not
completed as required; only unit searches
were completed.
It is unknown if any individual rooms were
searched during the month as no other
documentation was received.
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(b) Searches shall be conducted in a manner that We have provided technical assistance on
preserves the privacy and dignity of the person several occasions regarding the searches and
being searched and shall not be conducted for how they are conducted. We will continue to
harassment or as a form of discipline or follow up with facility managers and seek to be
punishment. ☐ ☐ ☐ present during unit searches.
The section is left blank as we did not view
a search in progress.
(c) Strip searches and visual or physical body DSB Manual Section 701: Introduction
cavity searches shall comply with Penal Code
☒ ☐ ☐
Section 4030.
(d) Physical body cavity searches shall only be Policy DSB Manual Sections:
conducted by a medical professional. 702: Types of Searches and Definitions
711: Admissions Procedures - Strip Search
and/or Visual Body Cavity Search
☒ ☐ ☐
We are unaware of any physical body cavity
searches completed.
(e) Any youth held after a detention hearing shall DSB Manual Section 703: Searches of Youth
only be strip searched with prior approval of a Housed in Juvenile Facilities - General
supervisor when there is reasonable suspicion Information
based on specific and articulable facts to believe ☒ ☐ ☐
that youth is concealing contraband. The Documentation was provided for our review
reasonable suspicion shall be documented. and was found to be compliant.
(f) Searches of transgender and intersex youth DSB Manual Section 706: Transgender Youth
shall comply with Section 1352.5. Searches
☒ ☐ ☐
We are unaware of any transgender or
intersex youth being searched.
(g) Cross-gender pat-down searches and strip DSB Manual Section 705: Cross-Gender
searches are prohibited except in exigent Searches
circumstances or when conducted by a medical
☒ ☐ ☐
professional. Such searches must be justified and We are unaware of any cross-gender pat-
documented in writing. down searches being completed.
1361 GRIEVANCE PROCEDURE Policy DSB Manual Section 1715: Youth
Grievance Procedures
The facility administrator shall develop and
implement written policies and procedures
whereby any youth may appeal and have resolved
grievances relating to any condition of
confinement, including but not limited to health
care services, classification decisions, program ☒ ☐ ☐
participation, telephone, mail or visiting
procedures, food, clothing, bedding, mistreatment,
harassment or violations of the nondiscrimination
policy. There shall be no time limit on filing
grievances. Policies and procedures shall include
provisions whereby the facility manager ensures:
(a) a grievance form and instructions for registering Policy DSB Manual Section 1715: Youth
a grievance, which includes provisions for the Grievance Procedures
youth to have free access to the form;
(b) the youth shall have the option to confidentially ☒ ☐ ☐ Youths can submit a grievance either by paper
file the grievance or to deliver the form to any youth or by computer while in school.
supervision staff working in the facility;
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(c) resolution of the grievance at the lowest Policy DSB Manual Section 1715: Youth
appropriate staff level; Grievance Procedures
Grievances are addressed by the grievance
officer and or supervisors. Issues that can be
☒ ☐ ☐ addressed informally by unit staff are not
considered grievances. Youth report they can
turn their grievances into any staff member or
into the confidential box for pick up by the
grievance officers.
(d) provision for a prompt review and initial Policy DSB Manual Section 1715: Youth
response to grievances within three (3) business Grievance Procedures
days, grievances that relate to health and safety
issues must be addressed immediately; We found the practice for submitting a
grievance electronically was not working in the
manner prescribed by regulation and there are
limitations as to the number of characters that
could be used.
This was discussed with agency subject
matter experts who are actively working with
their developers to address this issue.
Technical assistance was provided and it was
agreed that in the interim, the agency will be
notifying and educating all current youth of this
malfunction and have designated a
workaround. Future youth will be noticed
☒ ☐ ☐ through orientation until the issue is
addressed. The agency will provide
documentation of all youth noticed by
September 15, 2023.
Also noted was “immediate response” was not
shown to be made available for emergent
issues as required for electronic submissions
due to IT issues. This too is being addressed.
All youth will be notified that for assistance with
any health and safety issues, they should seek
assistance from a staff member immediately
regardless of grievance status or type of
grievance submitted.
This issue will continue to be under review at
future visits to ensure compliance.
(1) The youth may elect to be present to explain Policy DSB Manual Section 1715: Youth
his/her version of the grievance to a person not Grievance Procedures
☒ ☐ ☐
directly involved in the circumstances which led
to the grievance.
(2) Provision for a staff representative approved
☒ ☐ ☐
by the facility administrator to assist the youth.
(e) provision for a written response to the
grievance which includes the reasons for the ☒ ☐ ☐
decisions;
(f) a system which provides that any appeal of a
grievance shall be heard by a person not directly
☒ ☐ ☐
involved in the circumstances which led to the
grievance;
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(g) resolution of the grievance must occur within
ten (10) business days unless circumstances
☒ ☐ ☐
dictate a longer time frame. The youth shall be
notified of any delay; and,
(h) the policy shall provide multiple internal and
external methods to report sexual abuse and ☒ ☐ ☐
sexual harassment.
Whether or not associated with a grievance,
concerns of parents, guardians, staff or other
parties shall be addressed and documented in ☒ ☐ ☐
accordance with written policies and procedures
within a specified timeframe.
1370 EDUCATION PROGRAM This section was reviewed for attendance only.
All other sections in 1370 have been deleted
as they were not reviewed during this targeted
b(6) The minimum school day shall be
inspection.
consistent with State Education Code
Requirements for juvenile court schools. The
Daily attendance reports have been received
facility administrator, in conjunction with
directly from LACOE. While attendance has
education staff, must ensure that operational
improved since past inspections, and youth
procedures do not interfere with the time
are attending class in the classrooms, these
afforded for the minimum instructional day.
☐ ☒ ☐ reports continue to indicate that youth are
Absences, time out of class or educational
arriving late to school. Probation must focus
instruction, both excused and unexcused, shall
on getting youths to school on time.
be documented.
Youths enrolled in college courses are also
reporting having daily access to their courses.
Documentation of sign-in sheets were
provided for review along with a schedule of
courses.
1371 PROGRAMS, RECREATION, AND DSB Manual Section 622: Programs
EXERCISE. DSB Manual Section 623: Recreation and
Exercise
The facility administrator shall develop and
implement written policies and procedures for ☐ ☒ ☐
programs, recreation, and exercise for all
youth. The intent is to minimize the amount of
time youth are in their rooms or their bed area.
Juvenile facilities shall provide the opportunity for DSB Manual Section 622: Programs
programs, recreation, and exercise a minimum of DSB Manual Section 623: Recreation and
three hours a day during the week and five hours Exercise
a day each Saturday, Sunday or other non-school
days, of which one hour shall be an outdoor Based upon on review of documentation and
☐ ☒ ☐
activity, weather permitting. conversations with youth, it is apparent that
youth do not receive their full complement of
Title 15 requirements for programs and
recreation consistently.
A youth’s participation in programs, recreation, and DSB Manual Section 622: Programs
exercise may be suspended only upon a written DSB Manual Section 623: Recreation and
finding by the administrator/manager or designee Exercise
that a youth represents a threat to the safety and ☒ ☐
security of the facility.
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Such program, recreation, and exercise schedule DSB Manual Section 622: Programs
shall be posted in the living units. DSB Manual Section 623: Recreation and
Exercise
We found schedules to be posted for the most
part; however, schedules do not always match
☒ ☐ ☐ what is being provided operationally.
We recommend unit staff be sure that these
schedules are reviewed periodically. Many
times, the documents are illegible, and staff
are not aware of the actual program schedule.
There will be a written annual review of the DSB Manual Section 622: Programs
programs, recreation, and exercise by the DSB Manual Section 623: Recreation and
responsible agency to ensure content offered is Exercise
current, consistent, and relevant to the population. ☐ ☐ ☐
This section is left blank as we did not
inspect this section.
(a) Programs. All youth shall be provided with the DSB Manual Section 622: Programs
opportunity for at least one hour of daily DSB Manual Section 623: Recreation and
programming to include, but not be limited to, Exercise
trauma focused, cognitive, evidence-based, best
practice interventions that are culturally relevant The documentation we reviewed indicates
and linguistically appropriate, or pro-social that programs are not consistently being
interventions and activities designed to reduce provided. In some cases, the program
recidivism. These programs should be based on provider keeps sign-in sheets of youth
the youth’s individual needs as required by Sections attendance, but facility documentation does
1355 and 1356. Such programs may be provided not consistently match sign-ins. We suggest
under the direction of the Chief Probation Officer or that staff be retrained in how the BSCC
the County Office of Education and can be Section 1371 activity form should be
administered by county partners such as mental completed to ensure compliance going
health agencies, community-based organizations, forward.
faith-based organizations or Probation staff.
Programs may include but are not limited to: We suggest that staff be retrained in how the
(1) Cognitive Behavior Interventions; form should be completed to ensure
(2) Management of Stress and Trauma; compliance going forward.
☐ ☒ ☐
(3) Anger Management;
(4) Conflict Resolution;
(5) Juvenile Justice System;
(6) Trauma-related interventions;
(7) Victim Awareness;
(8) Self-Improvement;
(9) Parenting Skills and support;
(10) Tolerance and Diversity;
(11) Healing Informed Approaches;
(12) Interventions by Credible Messengers;
(13) Gender Specific Programming;
(14) Art, creative writing, or self-expression;
(15) CPR and First Aid training;
(16) Restorative Justice or Civic Engagement;
(17) Career and leadership opportunities; and,
(18) Other topics suitable to the youth
population.
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(b) Recreation. All youth shall be provided the DSB Manual Section 623: Recreation and
opportunity for at least one hour of daily access Exercise
to unscheduled activities such as leisure
reading, letter writing, and entertainment. Youth are not provided with age-appropriate,
Activities shall be supervised and include stimulating recreational activities to engage in
orientation and may include coaching of youth. during their recreational period. Youth do not
have access to other entertaining or
recreational activities such as television with
sports and age-appropriate programs.
Staff provide youth with game consoles in
some units as they are not provided by the
agency. It has been repeatedly noted that
“they (the youth) break them or take them
☐ ☒ ☐ apart”, which is why they are not provided by
the agency. This is a supervision issue.
It was also noted there is no consistency
between units in what items are offered. We
understand there are different units and
different phases to the facility; however,
recreation and related activities should be
provided to all youth consistently. Moreover,
Probation Managers should have access to
replacement items. Youth must have age-
appropriate, suitable, engaging recreation
and recreational activities.
(c) Exercise. All youth shall be provided with the DSB Manual Section 623: Recreation and
opportunity for at least one hour of large muscle Exercise
activity each day.
Documentation reviewed and interviews with
youth and staff indicated that youth are
☒ ☐ ☐ receiving outdoor exercise except for during
inclement weather (too hot) or if a youth or a
group of youth refuse to participate. If a youth
refuses to exercise, it is documented and
captured by the youth’s signature.
The administrator/manager may suspend, for a DSB Manual Section 622: Programs
period not to exceed 24 hours, access to recreation DSB Manual Section 623: Recreation and
and programs. The administrator/manager shall Exercise
☒ ☐ ☐
document the reasons why suspension of
recreation and programs occurs.
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1374 VISITING DSB Manual Section 304: Visiting
Documentation was provided for the period of
The facility administrator shall develop and
July 12, 2023, to July 27, 2023.
implement written policies and procedures for
visiting, that include provisions for special visits.
Youth were questioned as to the visiting
Youth shall be allowed to receive visits by parents,
process and if they had children, were they
guardians or persons standing in loco parentis, and
allowed to visit with them. Those youths who
children of youth. Other family members, such as
have children but did not visit with them
grandparents and siblings, and supportive adults,
indicated that the youth were either not listed
may be allowed to visit with the approval of the ☒ ☐ ☐
on the child’s birth certificate or they were in
facility administrator or designee, and in conjunction
the process of being approved and
with the youth’s case plan or in the best interest of
transportation of the child being arranged.
the youth.
The youth noted that they were given their full
two (2) hours with their parents and had
additional time on a different date with their
child.
All visits shall occur at reasonable times, subject DSB Manual Section 304: Visiting
only to the limitations necessary to maintain order
and security. Visitation shall not be denied solely Formal Visitation occurs on the weekends.
based on the visitor’s criminal history. The staff shall Parents can make special arrangements as
determine in each case, whether the visitor’s necessary and if needed if they cannot make
☒ ☐ ☐
criminal history represents a risk to the safety of the weekend visits.
youth or staff in the facility. Any denial of visitation or
limitation on visitations shall be communicated to
the youth, person denied and facility administrator.
Opportunity for visitation shall be a minimum of two DSB Manual Section 304: Visiting
hours per week. Visits may be supervised, but
conversations shall not be monitored unless there is Documentation was provided noting that
a security or safety need. visitation was being offered during the
☒ ☐ ☐
appropriate times as required. The youth we
spoke to confirmed that regular visitation is
occurring.
Provisions for special visits, in addition to the two- DSB Manual Section 304: Visiting
hour minimum and/or outside of the regular visiting
hours, shall be accommodated as necessary and Youth stated special visits had been provided
within the discretion of the facility administrator or more freely in the recent past; however, due to
designee. Family therapy and professional visits contraband and other facility operational
shall be accommodated outside the provisions of issues (staffing), these visits have been
this regulation. Facilities may provide visitation limited.
☒ ☐ ☐
opportunities outside of normal visiting hours to
accommodate special visits. Youth stated special visits had been provided
more freely previously; however, due to
contraband and other facility operational
issues (staffing), these visits have been limited
in the last 3 to 4 months.
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The facility may provide access to technology as an DSB Manual Section 304: Visiting
alternative, but not as a replacement, to in-person DSB Manual Section 306: Virtual
visiting. Communication
The facility is not currently utilizing technology
as a resource for visits or communications.
Assigned facility cell phones had been used
previously but are not currently being used due
to inadequate supervision resources and
oversight of the calls.
We noted in speaking with several youths that
☒ ☐ ☐
their family members are unable to visit due to
distance, lack of transportation, or other
reasons. We encouraged the reintegration of
technology to provide youth with the
opportunity to have face-to-face
communication with their families, especially
for those youth who do not receive visits. We
noted that some youths have not had contact
with their family in quite some time. Using
technology such as FaceTime or Duo would
mitigate this issue.
1390 DISCIPLINE DSB Manual Section 1103: Discipline
Guidelines
The facility administrator shall develop and
DSB Manual Section 1104: Corporal
implement written policies and procedures for the
Punishment
discipline of youth that shall promote acceptable
behavior; including the use of positive behavior
The facility continues to operate with no
interventions and supports. Discipline shall be
contemporary behavior management process
imposed at the least restrictive level which promotes
or disciplinary process for negative behavior
the desired behavior and shall not include corporal
including assaultive behavior.
punishment, group punishment, physical or
psychological degradation. Deprivation of the
The facility lacks a suitable discipline process.
following is not permitted:
There were eight (8) SCMs provided, of which,
two (2) were missing the Sanctions and
Appeals form, one (1) was a Mental Health
Incident, and five (5) were not completed
☐ ☒ ☐ correctly. Of the five (5), three (3) did not have
sanctions identified and in the other two (2),
the form was not completed correctly.
A suitable, age-appropriate incentive-based
program to encourage positive and proactive
behavior and include disciplinary actions as
appropriate must be developed and
implemented.
This section also impacts 1391 and Due
Process forms. We strongly suggest
reviewing both for implementation purposes
and to ensure consistency between the two
policies.
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The facility administrator shall establish rules of DSB Manual Section 1103: Discipline
conduct and disciplinary penalties to guide the Guidelines
conduct of youth. Such rules and penalties shall DSB Manual Section 1106: Rules and
include both major violations and minor violations, Regulations
be stated simply and affirmatively, and be made
available to all youth. Provision shall be made to Facility rules and penalties or sanctions must
provide accessible information to youth with be established. As neither the policy nor the
☐ ☒ ☐
disabilities, limited English proficiency, or limited orientation manual have been completed, this
literacy. section is also marked as noncompliant as a
result.
The remainder of this regulation has been
deleted.
1433 REQUESTS FOR HEALTH CARE DSB Manual Section 1702: Access to
SERVICES (EXCERPT) Care/Request for Services
The health administrator, in cooperation with the
The youth we spoke to are aware of the
facility administrator, shall develop policy and
process to access emergency and non-
procedures to establish a daily routine for youth to ☒ ☐ ☐
emergency medical, dental, and
convey requests for emergency and non-
behavioral/mental health care services.
emergency medical, dental and behavioral/mental
Services were said to be provided in a timely
health care services.
manner.
1480 STANDARD FACILTY CLOTHING ISSUE DSB Manual Section 403: Procedures for
Newly Admitted Youth
The youth’s personal clothing, undergarments and
footwear may be substituted for the institutional
clothing and footwear specified in this regulation. ☒ ☐ ☐
The facility has the primary responsibility to
provide clothing and footwear. Clothing provisions
shall ensure that:
Clothing is clean, reasonably fitted, durable, easily DSB Manual Section 403: Procedures for
laundered, in good repair, and free of holes and Newly Admitted Youth
tears. ☒ ☐ ☐
Clothes were noted to be clean and fit well.
(a) The standard issue of climatically suitable DSB Manual Section 403: Procedures for
clothing for youth shall consist of but not be limited Newly Admitted Youth
☒ ☐ ☐
to:
DSB Manual Section 403: Procedures for
Newly Admitted Youth
(1) Socks and serviceable footwear;
☒ ☐ ☐
The youth had socks and shoes. Neither had
holes nor were in disrepair.
DSB Manual Section 403: Procedures for
Newly Admitted Youth
(2) Outer garments;
☒ ☐ ☐
Jackets are not currently necessary due to
summer weather.
(3) New non-disposable underwear which shall DSB Manual Section 403: Procedures for
remain with the youth throughout their stay, Newly Admitted Youth
and;
☒ ☐ ☐
Youth stated they believe they are provided
with their own underwear.
(4) Undergarments, that are freshly laundered DSB Manual Section 403: Procedures for
and free of stains, including tee shirts and bras. Newly Admitted Youth
☒ ☐ ☐ Youth stated their undergarments are clean,
and free from stains and returned clean to
them.
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(b) Clothing is laundered at the temperature DSB Manual Section 403: Procedures for
required by local ordinances for the commercial Newly Admitted Youth
laundries and dried completely in a mechanical
dryer or other laundry method approved by the
☒ ☐ ☐
local health officer.
(c) Suitable clothing is issued to pregnant youth. The facility houses only males.
☐ ☐ ☒
1482 CLOTHING EXCHANGE DSB Manual Section 505: Housekeeping
The facility administrator shall develop and
The facility has a practice in place for clothing
implement written policies and site-specific
exchange.
procedures for the cleaning and scheduled
exchange of clothing. Unless work, climatic The youth we spoke with noted receiving clean
conditions, or illness necessitates more frequent clothing as required.
☒ ☐ ☐
exchange, outer garments, except for footwear,
shall be exchanged at least once each week. Tee
shirts, bras, and underwear shall be exchanged
daily; youth shall receive their own underwear
back at exchange.
1485 ISSUE OF PERSONAL CARE ITEMS DSB Manual Section 508: Housekeeping:
Personal Hygiene Supplies
There shall be written policies and site-specific
procedures developed and implemented by the
All youth we spoke with noted having access
facility administrator for the availability of personal
☒ ☐ ☐ to all required items.
hygiene items. Each female youth shall be
provided with sanitary napkins, panty liners and
tampons as requested. Each youth to be held over
24 hours shall be provided with the following
personal care items;
Toothbrush; DSB Manual Section 508: Housekeeping:
(a) Toothpaste; Personal Hygiene Supplies
(b) Soap;
(c) Comb; All youth we spoke with noted having access
(d) Shaving implements; to all required items.
(e) Deodorant;
DSB Manual Section 508: Housekeeping:
(f) Lotion;
Personal Hygiene Supplies
(g) Shampoo; and,
(h) Post-shower conditioning hair products.
(i) Youth shall not be required to share any
☒ ☐ ☐
personal care items listed in items (a) through (d).
Liquid soap provided through a common
dispenser is permitted. Youth shall not share
disposable razors. Double edged safety razors,
electric razors, and other shaving instruments
capable of breaking the skin, when shared among
youth, shall be disinfected between individual
uses by the method prescribed by the State
Board of Barbering and Cosmetology in Sections
979 and 980, Chapter 9, Title 16, California Code
of Regulations.
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1487 SHAVING DSB Manual Section 510: Shaving and
Haircut Procedures
Youth shall have access to a razor daily, unless
their appearance must be maintained for reasons
Most youth we spoke to noted having access
of identification in Court. All youth shall have equal
☒ ☐ ☐ to shaving upon request. There were a few
opportunity to shave face and body hair. The
youths who noted that their unit ran out of
facility administrator may suspend this
razors but they were able to shave after staff
requirement in relation to youth who are
retrieved more.
considered to be a danger to themselves or others.
1488 HAIR CARE SERVICES (EXCERPT) DSB Manual Section 510: Shaving and
Haircut Procedures
Hair care services shall be available in all juvenile
facilities. Youth shall receive hair care services
All the youth presented as well-groomed. The
monthly. Equipment shall be cleaned and ☒ ☐ ☐
youth I spoke with said the Barber does not
disinfected after each haircut or procedure, by a
come but staff are cutting those youth’s hair
method approved by the State Board of Barbering
who are requesting a haircut.
and Cosmetology.
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