Marin PROB (2025-2026 inspection cycle)

December 15, 2025 Marlon Washington, Chief Probation Officer Marin County Probation Department 3501 Civic Center Dr. #265 San Rafael, CA 94903 2025-2026 UNANNOUNCED INSPECTION, WELFARE & INSTITUTIONS CODE SECTIONS 209 & 885, MARIN COUNTY PROBATION DEPARTMENT DETENTION FACILITY Dear Chief Washington: An Unannounced Inspection of the Marin County Probation Department was completed for the following facility on Thursday, November 13, 2025: FACILITY NAME BSCC # FACILITY TYPE Marin County Juvenile Hall 7293 JH This inspection was 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 The focus of the Unannounced Inspection was to evaluate five (5) random Title 15 regulations. To ensure compliance with Title 15, we reviewed documentation for the following Title 15 regulations: • 1354.5 Room Confinement • 1357 Use of Force • 1353 Orientation • 1361 Grievance Procedure • 1371 Programs, Recreation, and Exercise We identified no items of noncompliance with Title 15 Minimum Standards. Refer to the attached Title 15 Modified Procedures Checklist for detailed information. An Exit Briefing with your staff was held on Thursday, November 13, 2025; BSCC staff presented an inspection overview and discussed technical assistance and best practice recommendations. * * * Marlon Washington Chief Probation Officer Page 2 Please email me at craigus.thompson@bscc.ca.gov or call (916) 597-4610 if you have any questions. Sincerely, CRAIGUS THOMPSON SR. Field Representative Facilities Standards and Operations Division Enclosures Cc: Presiding Judge, Marin County Juvenile Court* Chair, Juvenile Justice Commission, Marin County* Chair, Board of Supervisors, Marin County* County Administrator, Marin County* Rosaura De Alvarez, Superintendent, Marin County *Copies of the inspection are available upon request or online at www.bscc.ca.gov. 7293 Marin JH UI LTR 25-26 JUVENILE HALLS, SPECIAL PURPOSE JUVENILE HALLS AND CAMPS Board of State and Community Corrections PROCEDURES CHECKLIST1,2 BSCC Code: 7293 FACILITY NAME: Marin County Juvenile Hall (MCJH) FACILITY TYPE: JH PERSON(S) INTERVIEWED: Marlon Washington, Chief Probation Officer; Rosaura De Alverez, Juvenile Hall Superintendent; Dave Fahy, Supervising Juvenile Corrections Officer (SJCO); Omar Padilla, Juvenile Corrections Officer (JCO) III; Lee Lancaster, JCO III; Eve Rosen, School Teacher; FIELD REPRESENTATIVE: Craigus Thompson Sr and Eric Raley DATE: November 13, 2025 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS3 1353 ORIENTATION Policy 401 Intake/Initial Screening The facility administrator shall develop and implement We reviewed 10 examples from August 2025 written policies and procedures to orient a youth prior to to present of youths’ intake orientation placement in a living area. Both written and verbal packets. In review, MCJH follows the information shall be provided and supplemented with minimum standards with this regulation. video orientation if feasible. Provision shall be made to provide accessible orientation information to all detained It should be noted that during the youth including those with disabilities, limited literacy, or ☒ ☐ ☐ comprehensive inspection earlier this year, English language learners. BSCC staff identified outdated language Orientation shall include information that addresses: within the facility’s Orientation form. We suggested removing outdated language and adding new Title 15 regulation language. During the inspection, it was discovered that the Orientation form has been updated. (a) facility rules including contraband and searches and Policy 401 Intake/Initial Screening disciplinary procedures; MCJH provides youth with a well-detailed ☒ orientation packet regarding facility rules, ☐ ☐ including contraband, searches, and disciplinary procedures. (b) facility’s system of positive behavior interventions Policy 401 Intake/Initial Screening and supports, including behavior expectations, incentives that youth will receive for complying with ☒ Policy 409 Booking Protocol ☐ ☐ facility rules, and consequences that may result when youth violate the rules of the facility; 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 Juvenile Facilities, Division 1, Chapter 1, Subchapter 5 for the complete list and text of regulations. 2 This is a modified version of the Procedures Checklist and is only intended for the 2025 Unannounced Inspection of the Marin County Juvenile Hall. 3 Excerpts from facility policies, procedures, or other reference documents are indicated in italicized text. 7293 Marin JH UI PRO 25-26 Page 1 of 10 J453 JUV PRO eff. 01.01.25 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS3 (c) age appropriate information that explains the facility’s Policy 401 Intake/Initial Screening 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; ☒ Policy 401 Intake/Initial Screening ☐ ☐ (e) the existence of the grievance procedure, the steps Policy 401 Intake/Initial Screening 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 Policy 401 Intake/Initial Screening ☒ process; ☐ ☐ Policy 401 Intake/Initial Screening (g) access to routine and emergency health and mental ☒ health care; ☐ ☐ Policy 409 Booking Protocol (h) access to education, religious services, and Policy 401 Intake/Initial Screening ☒ recreational activities; ☐ ☐ (i) housing assignments; ☒ Policy 401 Intake/Initial Screening ☐ ☐ (j) opportunity for personal hygiene and daily showers Policy 401 Intake/Initial Screening including the availability of personal care items ☒ ☐ ☐ Policy 409 Booking Protocol (k) rules and access to correspondence, visits and Policy 401 Intake/Initial Screening ☒ telephone use; ☐ ☐ (l) availability of reading materials, programming, and Policy 401 Intake/Initial Screening ☒ other activities; ☐ ☐ (m) facility policies on the use of force, use of restraints, Policy 401 Intake/Initial Screening ☒ chemical agents and room confinement; ☐ ☐ (n) immigration legal services; ☒ Policy 401 Intake/Initial Screening ☐ ☐ (o) emergencies including evacuation procedures; ☒ Policy 401 Intake/Initial Screening ☐ ☐ (p) non-discrimination policy and the right to be free from Policy 401 Intake/Initial Screening physical, verbal or sexual abuse and harassment by ☒ ☐ ☐ other youth and staff; (q) availability of services and programs in a language Policy 401 Intake/Initial Screening ☒ other than English if appropriate; ☐ ☐ (r) the process for requesting different housing, Policy 401 Intake/Initial Screening ☒ education, programming and work assignments; ☐ ☐ (s) a process for which parents/guardians receive Policy 401 Intake/Initial Screening 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 Policy 401 Intake/Initial Screening 15 Minimum Standards for Juvenile Facilities. ☒ During the intake process, the Intake Packet ☐ ☐ provides Title 15 accessibility guidance to youth. 7293 Marin JH UI PRO 25-26 Page 2 of 10 J453 JUV PRO eff. 01.01.25 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS3 1354.5 ROOM CONFINEMENT Policy 468 Room Confinement 0B (a) The facility administrator shall develop and During this inspection cycle, the MCJH has implement written policies and procedures addressing had four (4) incidents, which resulted in youth the confinement of youth in their room that are consistent being placed on Room Confinement. with Welfare and Institutions Code Section 208.3. The Documentation provided and review of policy placement of a youth in room confinement shall be ☒ and procedure revealed compliance with this accomplished in accordance with the following ☐ ☐ regulation. guidelines: It should be noted that all room confinement reports reviewed youth were placed on room confinement for less than an hour. (1) Room confinement shall not be used before other, Policy 468 Room Confinement less restrictive, options have been attempted and exhausted, unless attempting those options poses a BSCC staff expressed the importance of threat to the safety or security of any youth or staff. documenting, within the incident report, de- escalation efforts made by staff prior to ☒ placing a youth in his or her room. This would ☐ ☐ provide clarity in exhausting less restrictive options. The facility acknowledged. MCJH complies with this regulation. (2) Room confinement shall not be used for the Policy 468 Room Confinement purposes of punishment, coercion, convenience, or retaliation by staff. Guidelines for Room Confinement B. ☒ ☐ ☐ Guidelines for Room Confinement A. (3) Room confinement shall not be used to the extent Policy 468 Room Confinement that it compromises the mental and physical health of ☒ the youth. ☐ ☐ Guidelines for Room Confinement C. (b) A youth may be held up to four hours in room Policy 468 Room Confinement confinement. After the youth has been held in room ☒ confinement for a period of four hours, staff shall do one ☐ ☐ Guidelines for Room Confinement A. or more of the following: Policy 468 Room Confinement (1) Return the youth to general population. ☒ ☐ ☐ Use of Room Confinement B1. Policy 468 Room Confinement Use of Room Confinement B2. (2) Consult with mental health or medical staff. ☒ ☐ ☐ Review of documentation provided revealed compliance with this regulation. (3) Develop an individualized plan that includes the Policy 468 Room Confinement goals and objectives to be met in order to reintegrate ☒ the youth to general population. ☐ ☐ Use of Room Confinement B3. 7293 Marin JH UI PRO 25-26 Page 3 of 10 J453 JUV PRO eff. 01.01.25 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS3 (4) If room confinement must be extended beyond Policy 468 Room Confinement four hours, staff shall do each of the following: (A) Document the reasons for room confinement Use of Room Confinement C 1. 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 Policy 468 Room Confinement Use of Room the goals and objectives to be met in order to ☒ Confinement C 2. ☐ ☐ integrate the youth to general population. (C) Obtain documented authorization by the Policy 468 Room Confinement Use of Room facility superintendent or his or her designee ☒ Confinement C 3. ☐ ☐ every four hours thereafter. (5) This section is not intended to limit the use of Policy 468 Room Confinement Section (5) 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 Policy 468 Section (6) ☒ court holding facilities or adult facilities. ☐ ☐ (7) Nothing in this section shall be construed to Policy 468 Section (7) conflict with any law providing greater or additional ☒ ☐ ☐ protections to youth. (8) This section does not apply during an Policy 468 Section (8) 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. (9) This section does not apply when a youth is Policy 468 Section (9) 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. 7293 Marin JH UI PRO 25-26 Page 4 of 10 J453 JUV PRO eff. 01.01.25 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS3 1357 USE OF FORCE Policy 448 Use of Force The facility administrator, in cooperation with the Policy 448 Use of Force contains the responsible physician, shall develop and implement elements for the minimum standards of this written policies and procedures for the use of force, regulation. which may include chemical agents. Force shall never be applied as punishment, discipline, retaliation or At the time of the inspection, MCJH only had treatment. ☒ two (2) incidents in which the use of force (a) At a minimum, each facility shall develop policies and ☐ ☐ was utilized on a youth. procedures which: Review of the incident report and review of policy and procedures, as well as interviews with youth and staff, revealed compliance with this regulation. (1) restricts the use of force to that which is deemed Policy 448: Use of Force, Section (a) (1) 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 including Policy 448: Use of Force, Section (a) (2) both physical and non-physical options and define ☒ ☐ ☐ when those force options are appropriate. (3) describe force options or techniques that are Policy 448: Use of Force, Section (a) (3) ☒ expressly prohibited by the facility. ☐ ☐ (4) describe the requirements of staff to report any Policy 448: Use of Force, Section (a) (4) inappropriate use of force, and to take affirmative ☒ ☐ ☐ action to immediately stop it. (5) define a standardized reporting format that Policy 448: Use of Force, Section (a) (5) 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 Policy 448: Use of Force, Section (a) (6) ☒ investigating unreasonable use of force. ☐ ☐ (7) define the role, notification, and follow-up Policy 448, Section VIII (C) procedures required after use of force incidents for medical, mental health staff and parents or legal ☒ The policy contains the minimum standards ☐ ☐ guardians. for this regulation. (8) describe the limitations of use of force on pregnant Policy 448: Use of Force, Section (a) (8) youth in accordance with Penal Code Section 6030(f) ☒ ☐ ☐ and Welfare and Institutions Code Section 222. (b) Facilities that authorize chemical agents as a force MCJH does not authorize the use of chemical option shall include policies and procedures that: agents. Therefore, section (b) of this (1) identify who is approved to carry and/or utilize regulation is non-applicable. ☒ chemical agents in the facility and the type, size and ☐ ☐ the approved method of deployment for those chemical agents. 7293 Marin JH UI PRO 25-26 Page 5 of 10 J453 JUV PRO eff. 01.01.25 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS3 (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 procedures required after use of force incidents ☒ involving chemical agents for medical, mental health ☐ ☐ staff and parents or legal guardians. (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 which Policy 448, Section (c) (1) require that agencies provide initial and 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 Policy 448, Section (c) (2) ☒ ☐ application. ☐ (3) signs or symptoms that should result in immediate Policy 448, Section (c) (3) ☒ ☐ referral to medical or behavioral health. ☐ (4) instruction on the Constitutional Limitations of Use Policy 448, Section (c) (4) ☒ ☐ of Force. ☐ (5) physical training force options that may require Policy 448, Section (c) (5) ☒ ☐ the use of perishable skills. ☐ (6) timelines the facility uses to define regular Policy 448, Section (c) (6) ☒ ☐ training. ☐ 1361 GRIEVANCE PROCEDURE Policy 431: Minor’s Information on Grievances The facility administrator shall develop and implement written policies and procedures whereby any youth may We reviewed youth grievances from April appeal and have resolved grievances relating to any 2025 to the present. In all, we reviewed a condition of confinement, including but not limited to total of fifteen (15) grievances. health care services, classification decisions, program ☒ ☐ ☐ participation, telephone, mail or visiting procedures, BSCC staff concluded that the MCJH food, clothing, bedding, mistreatment, harassment or complies with Title 15 minimum standards of violations of the nondiscrimination policy. There shall be this regulation. no time limit on filing grievances. Policies and procedures shall include provisions whereby the facility manager ensures: 7293 Marin JH UI PRO 25-26 Page 6 of 10 J453 JUV PRO eff. 01.01.25 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS3 (a) a grievance form and instructions for registering a Policy 431: Minor’s Information on grievance, which includes provisions for the youth to Grievances have free access to the form; Policy Statement #1. ☒ ☐ ☐ 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. (b) the youth shall have the option to confidentially file Policy 431 Minor’s Information on Grievances the grievance or to deliver the form to any youth supervision staff working in the facility; Policy Statement #1. ☒ ☐ ☐ The youth were aware of the grievance procedures and the location of the grievance forms and the grievance lockbox to confidentially file a grievance if needed. (c) resolution of the grievance at the lowest appropriate Policy 431 Minor’s Information on Grievances staff level; ☒ ☐ ☐ Policy Statement #2. (d) provision for a prompt review and initial response to Policy 431 Minor’s Information on Grievances grievances within three (3) business days, grievances that relate to health and safety issues must be Policy Statement #1. addressed immediately; ☒ ☐ ☐ All grievances were initially responded to within three (3) business days. In fact, all grievances reviewed were initially responded to within 24 hours. (1) The youth may elect to be present to explain Policy 431: Minor’s Information on his/her version of the grievance to a person not Grievances directly involved in the circumstances which led to the grievance. Procedure #1 ☒ ☐ ☐ 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 Policy 431: Minor’s Information Procedure #1 ☒ ☐ ☐ the facility administrator to assist the youth. (e) provision for a written response to the grievance Policy 431: Procedure #3 which includes the reasons for the decisions; The documentation as well as interviews ☒ ☐ ☐ show that detention staff respond professionally. (f) a system which provides that any appeal of a Policy 431: Procedure #3 grievance shall be heard by a person not directly ☒ ☐ ☐ involved in the circumstances which led to the grievance; 7293 Marin JH UI PRO 25-26 Page 7 of 10 J453 JUV PRO eff. 01.01.25 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS3 (g) resolution of the grievance must occur within ten (10) Policy 431 Minor’s Information on Grievances business days unless circumstances dictate a longer time frame. The youth shall be notified of any delay; and, Policy Statement #1. ☒ ☐ ☐ All grievances were resolved within ten business days. In fact, all grievances reviewed were resolved within 48 hours. (h) the policy shall provide multiple internal and external Policy 431 Minor’s Information on Grievances methods to report sexual abuse and sexual harassment. ☒ ☐ ☐ Policy Statement #5. Whether or not associated with a grievance, concerns of Policy 431: Procedure # 5 parents, guardians, staff or other parties shall be ☒ ☐ ☐ addressed and documented in accordance with written policies and procedures within a specified timeframe. 1371 PROGRAMS, RECREATION, AND EXERCISE. Policy 444: Programs, Recreation, and 1B Exercise Program The facility administrator shall develop and implement written policies and procedures for programs, recreation, BSCC staff reviewed the program, recreation, and exercise for all youth. The intent is to minimize the and exercise schedules, logs, and records for amount of time youth are in their rooms or their bed area. the months of April, October, and November ☒ ☐ ☐ of 2025. In total, we reviewed a total of fifteen (15) MCJH Daily Activity reports. We concluded that the facility complies with Title 15 minimum standards for this regulation. Juvenile facilities shall provide the opportunity for Policy 444: Programs, Recreation, and programs, recreation, and exercise a minimum of three Exercise Program hours a day during the week and five hours a day each ☒ ☐ ☐ Saturday, Sunday or other non-school days, of which Policy Statement #1. one hour shall be an outdoor activity, weather permitting. A youth’s participation in programs, recreation, and Policy 444: Programs, Recreation, and exercise may be suspended only upon a written finding Exercise Program by the administrator/manager or designee that a youth ☒ ☐ ☐ represents a threat to the safety and security of the Policy Statement #3. facility. Such program, recreation, and exercise schedule shall Policy 444: Programs, Recreation, and be posted in the living units. Exercise Program Policy Statement #4. ☒ ☐ ☐ During the physical facility inspection, we observed program and recreation schedule calendars posted in the living units. 7293 Marin JH UI PRO 25-26 Page 8 of 10 J453 JUV PRO eff. 01.01.25 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS3 There will be a written annual review of the programs, Policy 444: Programs, Recreation, and recreation, and exercise by the responsible agency to Exercise Program ensure content offered is current, consistent, and relevant to the population. On March 25, 2025, Superintendent Rosaura De Alvarez provided a memo ensuring that ☒ ☐ ☐ an annual review of the programs, recreation, and exercise was conducted by MCJH. Policy Statement #5. (a) Programs. All youth shall be provided with the Policy 444: Programs, Recreation, and opportunity for at least one hour of daily programming to Exercise Program, Section (a) include, but not be limited to, trauma focused, cognitive, evidence-based, best practice interventions that are BSCC staff reviewed program activity logs culturally relevant and linguistically appropriate, or pro- and interviewed youth housed at the facility, social interventions and activities designed to reduce detention staff, behavioral health staff, and recidivism. These programs should be based on the education service staff. In addition, we youth’s individual needs as required by Sections 1355 reviewed three months of program schedules and 1356. Such programs may be provided under the showing programs provided and individual direction of the Chief Probation Officer or the County youth participation. Office of Education and can be administered by county partners such as mental health agencies, community Policy 444: Programs, Recreation, and based organizations, faith-based organizations or Exercise Program, Section (a) Probation staff. Programs may include but are not limited to: BSCC staff commend the MCJH in (1) Cognitive Behavior Interventions; conjunction with Behavioral Health staff for (2) Management of Stress and Trauma; ☒ ☐ ☐ the array of pro-social programming offered (3) Anger Management; to youth detained at the facility. To name a (4) Conflict Resolution; few, the behavioral health staff facilitates ART (5) Juvenile Justice System; groups, Psycho-Education groups, and (6) Trauma-related interventions; support groups for girls in custody. (7) Victim Awareness; (8) Self-Improvement; We concluded that the facility meets (9) Parenting Skills and support; compliance with Title 15 minimum standards (10) Tolerance and Diversity; for this regulation. (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. (b) Recreation. All youth shall be provided the opportunity Policy 444 Recreation and Exercise Program for at least one hour of daily access to unscheduled Policy Guidelines activities such as leisure reading, letter writing, and entertainment. Activities shall be supervised and include ☒ ☐ ☐ Review of daily program schedules and orientation and may include coaching of youth. interviews with the staff and youth revealed compliance with this regulation. (c) Exercise. All youth shall be provided with the Policy 444 Recreation and Exercise Program opportunity for at least one hour of large muscle activity Policy Guidelines each day. ☒ ☐ ☐ Review of daily program schedules and interviews with the staff and youth revealed compliance with this regulation. 7293 Marin JH UI PRO 25-26 Page 9 of 10 J453 JUV PRO eff. 01.01.25 TITLE 15 SECTION YES NO N/A P/P REFERENCE – COMMENTS3 The administrator/manager may suspend, for a period not Policy 444: Recreation and Exercise Program to exceed 24 hours, access to recreation and programs. Policy Exception #4 The administrator/manager shall document the reasons why suspension of recreation and programs occurs. ☒ ☐ ☐ It should be noted that no recreation or programs have been suspended thus far this inspection cycle. 7293 Marin JH UI PRO 25-26 Page 10 of 10 J453 JUV PRO eff. 01.01.25