Marin County, County Probation (2020-2022 inspection cycle)

Initial Inspection Report 2020-2022 Biennial Inspection Cycle Date of Exit Briefing: 6/9/2021 Inspection Type: Biennial County: Marin Facility Name(s): Marin County Juvenile Hall BSCC #(s): 7293 BSCC Type: Juvenile Hall Facility Representatives: Victoria Creighton BSCC Field Representative: Craigus Thompson and Forrest Coleman Corrective Action Plan Required? YES DATE CAP DUE TO BSCC: 7/11/2022 Current Items of Noncompliance Title 15. Section Description Section (A): Building inspection out of compliance. The last building inspection was completed 10/30/2019. The agency states that efforts have been made to schedule an inspection but did not provide documentation. § 1313. County Inspection and Evaluation of Section (F): JJC inspection out of compliance. No Building and Grounds. inspection occurred in 2020 0r 2021. The agency indicates it will provide documentation to show the Judge’s Court 2020 and 2021 Inspections were also on behalf of the JJC. Section (B): Monthly Fire and Life Safety inspection is out of compliance. From July 2020 to December 2021 the facility did not perform a monthly Fire and Life Safety inspection. Although, this has been § 1325. Fire Safety Plan. corrected, the period of non-compliance was excessive during the inspection cycle. Since the BSCC PIB on 1/4/2022, the facility has completed all monthly inspections for 2022. Section C: Youth on Administrative Separation (AD- SEP) are not provided Title 15 minimum requirements § 1354. Separation. of one hour of programming, recreation, and exercise per day. Marin County Initial Inspection Report Page 2 Title 15. Section Description Section (a)(2): The facility utilizes a program titled “Room Reflection Time” which requires a youth to be placed in a locked room for violating facility’s rules. § 1354.5. Room Confinement. Section (a)(1): Room Reflection Time was often given to youth with pre-determined time periods. This is a “room restriction” which is no longer compliant with Title 15 Regulations. Section (b)(1)(3): The facility staff are not completing Case Plans per requirements § 1355. Institutional Assessment and Plan. stated within the regulation. Section (a)(7): the facility is not consistently providing notification to the parent(s) of youth § 1357. Use of Force. who have been involved in use of force incidents Title 24. Section Description Choose an item. N/A Technical Assistance Provided • Technical Assistance was provided to assist MCJH with formulating a detailed Fire Life and safety monthly inspection form. We also provided guidance to assist with forms distinguishing differences between Fire life and Safety inspections, Fire Drills, and emergency equipment checks. • We recommend that MCJH create a program log or form of documentation to show that youth on AD-SEP are provided equal programming opportunities as all youth detained. We also recommend that the agency update language and rationale pertaining to the Administrative Separation of youth. • We recommend that MCJH only utilize “Room Reflection Time” after other less restrictive options have been used and or if the youth is becoming emotionally unregulated causing safety and security concerns and needs a brief “cool off period”. • We recommend MCJH formulate a Case Plans document that will guide the staff and that contain the elements for minimum standard of this regulation. • We recommend MCJH update their incident reports to provide an area that shows parental notification made when Use of Force incidents occur. Or provide a system of documentation to ensure parental notifications have been made following Use of Force incidents. Marin County Initial Inspection Report Page 2 Additional Information The agency acknowledges the items of non-compliance and is intent on submitting corrective actions with 30- days of the inspection debrief. August 25, 2022 Marlon Washington, Chief Probation Officer Marin County Probation Department 3501 Civic Center Dr # 265, San Rafael, CA 94903 RE: MARIN COUNTY 2020/2022 BIENNIAL INSPECTION, PURSUANT TO WELFARE AND INSTITUTIONSCODESECTION209 Dear Chief Washington: The 2020/2022 biennial inspection of the Marin County Probation Department’s Juvenile Hall (MCJH) has been completed. A pre-inspection briefing was held on January 4, 2022. A full comprehensive facility inspection began on May 17, 2022. The inspection was completed on June 9, 2022. Due to a COVID-19 outbreak at MCJH, the inspection was partially conducted remotely from May 17th thru the 20th. The in-person portion of the inspection was conducted from June 8th thru the 9th. The complete Board of State and Community Corrections (BSCC) inspection report is enclosed and consists of the following: this transmittal letter; a Title 15 Procedures checklist, outlining applicable minimum standards for juvenile detention facilities; a Physical Plant Evaluation, outlining applicable Title 24 minimum standards; and the Living Area Space Evaluation (LASE), summarizing the physical plant configuration and outlining the rated capacity of the Juvenile Hall. Please refer to the Title 15 Procedures checklist for a summary of all relevant minimum standards, indication of compliance or noncompliance, and information that was used to determine compliance. Mandatory Local Inspections In addition to the biennial inspection, Title 15, Section 1313 and its authorizing statute also require local inspections conducted by the following local authorities: county building inspector or person designated by the Board of Supervisors fire authority having jurisdiction local health officer county Superintendent of Schools Juvenile Court Juvenile Justice Commission. Results of those inspections are considered a part of this report. The dates of the local inspections may be found in the accompanying Procedures Checklist. Marlon Washington Chief Probation Officer Page 2 Scope of the Inspection The inspection consisted of a review of the Juvenile Hall Policy and Procedure Manual1, a site visit to review operations, physical plant and relevant documentation, and interviews with administration, facility staff, youth, and collaborative partners. During the inspection, we evaluated consistency between policy and practices. BSCC Inspection Results Title 15, CCR Minimum Standards Upon final review of the inspection and all documentation, there were six items of non-compliance with Title 15 minimum standards at the Marin County Juvenile Hall (MCJH). MCJH Superintendent Tori Creighton provided a Corrective Action Plan (CAP) on July 1, 2022 and proceeded to ensure that all items of non-compliance were corrected. As of the date of this letter, MCJH has no outstanding items of non-compliance remaining. To ensure compliance with Title 15 Regulations and to ensure procedures and process are consistent with policies, the inspection process included, but was not limited to, substantial reviews of incident reports, grievances, admission and classification documents, room confinement procedures, safety check documentation, case plans, and disciplinary reports and their findings. As part of the inspection process, we also interviewed youth, staff, and collaborative partners. We had the opportunity to discuss several policies and procedures with staff and provided technical assistance and best practice recommendations that may bring clarity and specificity to the facility policy and procedure manual. At the onset of the inspection, we were able to assess that the COVID-19 pandemic had a significant effect on administrative processes. Specifically, multiple local inspections were not conducted per Title 15 regulation, § 1313, County Inspection and Evaluation of Building and Grounds. As of the date of this inspection, the last completed inspection occurred on October 30, 2019. As a result, it was determined that the MCJH was non-compliant with the minimum standards for this regulation. We understand that local agency scheduling and presence is beyond your agency’s control. However, being able to provide efforts made to have inspections conducted would lessen your agencies accountability for lack of compliance regarding this regulation. As of the date of this report, MCJH has a county building inspection scheduled for July 25, 2022. We offered MCJH technical assistance and recommendations with many areas, including but not limited to policy and procedure formulation, documentation procedures, emergency procedures, administrative annual reviews, suicide prevention plan, sick call slip procedures, etc. Some of these items were either not consistent with practice or were vague in ensuring compliance but were resolved during the inspection process. Other issues were determined to be non-compliant with Title 15 1BSCC reviews only those policy and procedures required by, and applicable to, Title 15, CCR. BSCC staff do not “approve” policies and procedures or assess them for constitutional or legal issues. Agencies should seek review through their legal advisor, risk manager, and other persons deemed appropriate for such evaluation. 7293 Marin County JH LTR 20-22 Marlon Washington Chief Probation Officer Page 3 regulations and technical assistance was provided. The items of non-compliance that were identified and resolved prior to the issuance of this report are as follows: § 1313. County Inspection and Evaluation of Building and Grounds, Section (A): No inspection was scheduled during the 2020/2022 inspection cycle. A county building inspection has been scheduled for July 28, 2022. § 1354. Separation, Section (C): Youth on Administrative Separation (AD-SEP) were not provided Title 15 minimum requirements of one hour of programming, recreation, and exercise per day. An Administrative Separation (Ad/Sep) logbook was created ensuring that all youth on Ad/Sep receive equity in programing, recreation, and exercise. A supervisor or Lead JCO will review the Ad/Sep logbook each shift. Ad/Sep policy deleted that the separation of youth upon intake at admission based solely on admission for 707 (b) offenses or out of county bookings unless there is a present safety and security concern. § 1354.5 Room Confinement, Sections (a)(20) and (a)(1): Via “Room Reflection Time”, youth were placed in their respective rooms for violating facility rules opposed to being placed in their rooms for safety and security risk to staff, him/herself, or others. A “Temporary Separation Time Out Tracking” form was developed and instituted. That will be signed off by a supervisor or Lead JCO. Separation policy updated to reflect different types of “Separations” and use expectations. § 1355 Institutional Assessment and Plan, Section (b)(1), (b)(3): MCJH staff are not providing Institutional Case Plans to youth as outlined in the Title 15 Regulations. Institutional Assessment and Plan policy updated to institute, every Monday (if necessary), youth will be assigned to JCO’s by administration personnel. JCO staff will review Case Plans monthly with their assigned youth. § 1357 Use of Force, Section (a)(7): MCJH is not consistently providing notification to the parent(s) of youth who had been involved in use of force incidents. Use of Force Policy updated that requires staff to notify parents of youth involved with Use of Force Incidents. Parental notification will be documented on the Incident Report and in the Unit Logbook. Title 24, CCR Physical Plant There were no changes made to the physical plant and your rated capacity remains at 40 youth. MCJH grounds was very well kept. The youths’ rooms and shower areas were properly maintained and in good working order. There are no outstanding items of noncompliance with Title 24 minimum standards. 7293 Marin County JH LTR 20-22 Marlon Washington Chief Probation Officer Page 4 Training According to the most recent Standards and Training for Corrections audit, Marin County Probation Department is in compliance with all relevant regulations and mandates and mitigating circumstances if applicable. Juvenile Justice and Delinquency Prevention Act (JJDPA) Compliance Monitoring We reviewed applicable documentation for the inspection cycle and found no violations of the JJDPA. Please refer to Title 15 Procedures checklist for detailed information. -- Field Representative Craigus Thompson and Iwould liketo acknowledge Superintendent Creighton for her hard work in preparing for the inspection. Superintendent Creighton was challenged with preparing for the inspection in an unfamiliar format of uploading many documentsto BSCC Field Representatives. She, as well as your staff, were good hosts and open to technical assistance and recommendations that we provided. We also would like to thank JDO Michelle Pitts who stayed over beyond her graveyard shift to sit and talk with us. As well, we would like to thank Supervisor Chris Perine who was very transparent and welcomed feedback. Your collaborative partners are very passionate about working with the youth and speak highly of youth with MCJH staff relationships. This concludes the 2020/2022biennial inspection report. I am available to assist as needed and happy to provide technical assistance when requested. I look forward to continuing to work together. Please do not hesitate to email me at Forrest.coleman@bscc.cs.gov or call (916) 508-7559 if you have any questions. Sincerely, Forrest Coleman Field Representative Facilities Standards and Operations Division Enclosures cc: Presiding Judge, Juvenile Court, Marin County* Chair, Juvenile Justice Commission, Marin County* Chair, Board of Supervisors, Marin County* County Administrator, Marin County* Superintendent, Marin County Juvenile Hall* *Copies of full inspection are available upon request or are available online at www.bscc.ca.gov. 7293 Marin County JH LTR 20-22 JUVENILE HALLS, SPECIAL PURPOSE JUVENILE HALLS AND CAMPS Board of State and Community Corrections PROCEDURES CHECKLIST1 BSCC Code: 7293 FACILITY NAME: Marin County Juvenile Hall (MCJH) FACILITY TYPE: JH PERSON(S) INTERVIEWED: Tori Creighton, Juvenile Hall Superintendent; Chris Perine, Supervising JCO; Michelle Pitts, JCO; Monica Rosenberg, JH Nurse; Aleksei Rajamachvili, Supervising Nurse; Jeana Reynolds, MH Supervisor; Eve Rosen, Teacher; Fred Mosher, Cook; 2 male youth and 1 female youth. FIELD REPRESENTATIVE: Forrest Coleman and Craigus Thompson DATE: June 9, 2022 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS 1313 COUNTY INSPECTION AND County Inspections and evaluation of EVALUATION OF BUILDING AND GROUNDS grounds were performed by authorized persons and agencies per Title 15 Regulation On an annual basis, or as otherwise required by law, each 1313. However, MCJH expressed that due to juvenile facility administrator shall obtain a documented COVID-19, some inspections did not occur inspection and evaluation from the following: as regularly prescribed. Through Technical Assistance, we suggested that if an inspection cannot be completed on- site, if possible, request the local agency to perform a virtual or desk audit inspection. (A) County building inspection by agency designated by No inspections have occurred during 2020, the Board of Supervisors to approve building safety; 2021 and as of the date of this inspection. The last completed inspection occurred on 10/30/2019. ☐ ☒ ☐ MCJH is non-compliant with elements of this of this regulation. As of the date of this report, MCJH provided documentation to show that an inspection occurred on July 25, 2022. (B) Fire authority having jurisdiction, including a fire 2020: clearance as required by Health and Safety Code Completed on November 23, 2020, by Section 13146.1 (a) and (b); Engineer Paramedic, Jamal Cook. 2022: ☒ ☐ ☐ Completed on February 23, 2022, by Marin County Fire Department, Captain, Jake Rosebrock. The inspections were performed by the State Fire Marshall MCJH is compliant with minimum standards for this regulation. 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. 7293 Marin County JH PRO 20-22 - 1 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS (C) Local health officer, inspection in accordance with 2020: Health and Safety Code Section 101045; Medical/Mental Health: Per Superintendent Tori Creighton, the Supervising nurse reported that no inspection occurred due to COVID. Nutritional Health: Completed July 30, 2020, by San Mateo Correctional Health Dietician, Denise Chu. Mrs. Chu completed the BSCC Nutritional Health Evaluation form. Mrs. Chu indicated that MCJH exceeds Title 15 Regulations in multiple areas. Environmental Health: Completed on July 30, 2020, by Environmental Health Specialist, Charles Futoran, and on August 20, 2020, by Environmental Health Specialist, Rebecca Ng. As a result of the Environmental Health Inspection, violations were discovered and MCJH has begun performing corrective actions. ☒ ☐ ☐ 2021: Medical/Mental Health: Completed by Carl Finley, RN on July 18, 2021. Finley reported that minimum standards were met. Nutritional Health: Completed July 21, 2021, by San Mateo Correctional Health Dietician, Denise Chu. Mrs. Chu completed the BSCC Nutritional Health Evaluation. Mrs. Chu indicated that MCJH exceeds Title 15 Regulations in multiple areas. Environmental Health: Completed on July 21, 2021, and August 2, 2021, by Senior Environmental Health Specialists Eithne Bullick, and Loni Ward. Corrective actions regarding violations discovered are being addressed accordingly. 2022: Environmental Health: Completed on March 15, 2022, by Senior Environmental Health Specialists Eithne Bullick. Most corrective actions were completed while others are being addressed accordingly by MCJH. 7293 Marin County JH PRO 20-22 - 2 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS (D) County superintendent of schools on the adequacy 2019: Completed March 2019, by of educational services and facilities as required in Alternative Education Consultant, Lisa Section 1370; Schwartz. 2021: Completed in November 2021 by, ☒ ☐ ☐ Alternative Education Consultant, Lisa Schwartz. For both inspections Mrs. Schwartz completed the Juvenile Facility Education Program Review and Evaluation form. Schwartz indicated minimum standards were met. (E) Juvenile court as required by Section 209 of the 2020: Completed November 5, 2020, by Welfare and Institutions Code Judge Beverly K. Wood. 2021: Completed October 22, 2021, by Judge Beverly K. Wood. ☒ ☐ ☐ For both inspections, Judge Wood completed a well detailed form. Judge Wood indicated that although the Corona Virus caused Emergency Suspensions of Standards, MCJH overall is compliant with minimum standards. (F) Juvenile Justice Commission as required by Section Per MCJH Superintendent, Tori Creighton, 229 of the Welfare and Institutions Code or Judge Beverly K. Wood completed the 2020 Probation Commission as required by Section 240 of and 2021 inspections during the Juvenile the Welfare and Institutions Code. Court inspections. Following our BSCC inspection, Judge Wood confirmed her intent to also perform the JJC Inspection. ☒ ☐ ☐ We provided Technical Assistance to inform MCJH that the intent of the regulation is that the County ensures each local agency performs a separate and independent inspection. 1320 APPOINTMENT AND QUALIFICATIONS Chief Marlon Washington’s Appointment BSCC Note: Compliance with this section is letter dated May 3, 2022. The letter and determined by receipt of the Chief Probation Officer’s policy identify responsibilities and expectations of the regulation. certification letter confirming that all elements of regulation are met. (a) Appointment ☒ ☐ ☐ Policy 200 Appointment and Qualifications In each juvenile facility there shall be a superintendent, Section A. director or facility manager in charge of its program and We provided technical assistance for MCJH to create a new policy number for this employees. Such superintendent, director, facility regulation. A “Policy 200” is also indicated manager and other employees of the facility shall be in Policy 200 Staffing. appointed by the facility administrator pursuant to applicable provisions of law. 7293 Marin County JH PRO 20-22 - 3 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS (b) Employee Qualifications Policy 200 Appointment and Qualifications Each facility shall: Section B We provided technical assistance for MCJH to create a new policy number for this regulation. A “Policy 200” is also indicated in Policy 200 Staffing. (1) recruit and hire employees who possess Policy 200 Appointment and Qualifications, knowledge, skills and abilities appropriate to Section B (1) their job classification and duties in accordance with applicable civil service or merit system ☒ ☐ ☐ We provided technical assistance for MCJH to create a new policy number for this rules; regulation. A “Policy 200” is also indicated in Policy 200 Staffing. (2) require a medical evaluation and physical Policy 200 Appointment and Qualifications, examination including tuberculosis screening Section B (2) test and evaluation for immunity to contagious illnesses of childhood (i.e., diphtheria, rubeola, ☒ ☐ ☐ We provided technical assistance for MCJH to create a new policy number for this rubella, and mumps); regulation. A “Policy 200” is also indicated in Policy 200 Staffing. (3) adhere to the minimum standards for the Policy 200 Appointment and Qualifications, selection and training requirements adopted by Section B (3) the Board pursuant to Section 6035 of the Penal We provided technical assistance for MCJH Code; and to create a new policy number for this ☒ ☐ ☐ regulation. A “Policy 200” is also indicated in Policy 200 Staffing. MCJH is up to date and in compliance with its BSCC Standards and Training for Corrections training requirements. (4) conduct a criminal records review, on each new Policy 200 Appointment and Qualifications employee, and psychological examination in Section B (4) accordance with Section 1031 et seq. of the Government Code. ☒ ☐ ☐ We provided technical assistance for MCJH to create a new policy number for this regulation. A “Policy 200” is also indicated in Policy 200 Staffing. (c) Contract personnel, volunteers, and other non- Policy 200 Appointment and Qualifications, employees of the facility, who may be present at the Section C facility, shall have such clearance and qualifications ☒ ☐ ☐ We provided technical assistance for MCJH as may be required by law, and their presence at the to create a new policy number for this facility shall be subject to the approval and control of regulation. A “Policy 200” is also indicated the facility manager. in Policy 200 Staffing. 1321 STAFFING Policy 200 Staffing identifies all expectations and responsibilities of the Each juvenile facility shall: regulation’ minimum standards. 7293 Marin County JH PRO 20-22 - 4 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS a) have an adequate number of personnel sufficient to Policy 200 Staffing, Section (A) carry out the overall facility operation and its In review of documents including safety programming, to provide for safety and security of youth and staff, and meet established standards and ☒ ☐ ☐ check records, grievances, disciplinary actions, incidents reports, shift schedules and regulations; programing, MCJH meets minimum standards for this regulation. b) ensure that no required services shall be denied Policy 200 Staffing, (b) Ensure that no because of insufficient numbers of staff on duty required services shall be denied because of absent exigent circumstances; insufficient numbers of staff on duty absent exigent circumstances. We made visual observations, reviewed work schedules for February 2022 and March 2022, as well as the staff “Daily Activity Reports”. The observations documentation show that MCJH consistently meets minimum standards for this regulation. ☒ ☐ ☐ At the time of inspection staffing consisted of: 1 Superintendent 3 Supervisors 9 Juvenile Corrections Officers (JCO) 1Vacant JCO positions 14 Extra-help staff c) have a sufficient number of supervisory level staff to Policy 200 Staffing, Section (c) ensure adequate supervision of all staff members; A Supervisor is assigned to each shift. In the ☒ ☐ ☐ supervisor’s absence, a JCO III (Acting Supervisor) is assigned to assume the supervisory duties for that shift. d) have a clearly identified person on duty at all times Policy 200 Staffing, Section (d) Have a who is responsible for operations and activities and clearly identified person, always who is has completed the Juvenile Corrections Officer Core responsible for operations and activities and Course and PC 832 training; has completed the Juvenile Corrections Officer Core Course and PC 832 training. ☒ ☐ ☐ The Supervisor or JCO III (Acting Supervisor) is clearly listed on the staff daily schedules. Policy 200 Staffing, Section (c) e) have at least one staff member present on each living Policy 200 Section, (e) Have at least one unit whenever there are youth in the living unit; ☒ ☐ ☐ staff member present on each living unit whenever there are youth in the living unit 7293 Marin County JH PRO 20-22 - 5 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS f) have sufficient food service personnel relative to the Sufficient food service personnel relative to number and security of living units, including staff the number of youth and security of living qualified and available to: plan menus meeting units appear to be consistently present to nutritional requirements of youth; provide kitchen carry out the required responsibilities to meet supervision; direct food preparation and servings; nutritional standards. conduct related training programs for culinary staff; ☒ ☐ ☐ Current food service personnel staffing and maintain necessary records; or, a facility may consists of: serve food that meets nutritional standards prepared by an outside source; 1 Supervising Cook 1 Part Time Cook g) have sufficient administrative, clerical, recreational, Sufficient administrative, clerical, medical, dental, mental health, building recreational, medical, dental, mental health, maintenance, transportation, control room, facility building maintenance, transportation, control security and other support staff for the efficient room, facility security and other support staff management of the facility, and to ensure that youth are present and youth supervision staff are ☒ ☐ ☐ supervision staff shall not be diverted from not distracted by support duties. supervising youth; and, Current administrative support staffing consists of: 1 Support Staff h) assign sufficient youth supervision staff to provide Policy 200 Staffing, Section (h) continuous wide-awake supervision of youth, In review of housing unit logs, programming subject to temporary variations in staff assignments ☒ ☐ ☐ schedules, and employee daily schedules, the to meet special program needs. Staffing shall be in elements of this regulation comply with compliance with a minimum youth-staff ratio for the minimum standards for this regulation. following facility types: (1) Juvenile Halls (minimum youth-staff ratio) Policy 200 Staffing, Section (A) (A) during the hours that youth are awake, one wide- Through observation and in review of the awake youth supervision staff member on duty for each 10 youth in detention; ☒ ☐ ☐ housing unit log, Safety Check documentation, and staffing schedules, staffing ratios are consistently in compliance with Title 15 minimum standards. (B) during the hours that youth are confined to their Policy 200 Staffing, Section (1) (B) during room for the purpose of sleeping, one wide-awake the hours that youth are confined to their youth supervision staff member on duty for each ☒ ☐ ☐ room for the purpose of sleeping, one wide 30 youth in detention; awake youth supervision staff member on duty for each 30 youth in detention. (C) at least two wide-awake youth supervision staff Policy 200 Staffing, Section (C) members on duty at all times, regardless of the In review of the housing unit log, Safety number of youth in detention, unless an arrangement has been made for backup support ☒ ☐ ☐ Check documentation, and the daily schedules, MCJH ensures at least two wide- services which allow for immediate response to awake youth supervision staff members are emergencies; and, always on duty. 7293 Marin County JH PRO 20-22 - 6 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS (D) at least one youth supervision staff member on duty Policy 200 Staffing, Section (D) who is the same gender as youth housed in the According to shift schedules, housing unit facility. ☒ ☐ ☐ logs visual observations, and interviews with staff and youth, there is always a male and female youth supervision staff assigned to each shift. (E) personnel with primary responsibility for other Policy 200 Staffing, Section (E) duties such as administration, supervision of ☒ ☐ ☐ personnel, academic or trade instruction, clerical, kitchen or maintenance shall not be classified as youth supervision staff positions. (2) Special Purpose Juvenile Halls (minimum youth- MCJH is not a Special Purpose Juvenile staff ratio) Hall. Therefore, this Section of the Title 15 ☐ ☐ ☒ (A) during hours that youth are awake, one wide-awake Regulation is not applicable to this youth supervision staff member is on duty for each inspection report. 10 youth in detention; (B) during the hours that youth are confined to their room for the purpose of sleeping, one wide-awake youth ☐ ☐ ☒ supervision staff member on duty for each 30 youth in detention; (C) at least two wide-awake youth supervision staff members on duty at all times, regardless of the ☐ ☐ ☒ number of youth in detention, unless an arrangement has been made for backup support services which allow for immediate response to emergencies; and, (D) at least one youth supervision staff member on duty ☐ ☐ ☒ who is the same gender as youth housed in the facility. (E) personnel with primary responsibility for other duties such as administration, supervision of ☐ ☐ ☒ personnel, academic or trade instruction, clerical, kitchen or maintenance shall not be classified as youth supervision staff positions. (3) Camps (minimum youth -staff ratio) MCJH is not a Camp. Therefore, this section (A) during the hours that youth are awake, one wide- ☐ ☐ ☒ of the Title 15 Regulation is not applicable to awake youth supervision staff member on duty for this inspection report. each 15 youth in the camp population; (B) during the hours that youth are confined to their room for the purpose of sleeping, one wide-awake ☐ ☐ ☒ youth supervision staff member on duty for each 30 youth present in the facility; (C) at least two wide-awake youth supervision staff members on duty at all times, regardless of the ☐ ☐ ☒ number of youth in residence, unless arrangements have been made for backup support services which allow for immediate response to emergencies; 7293 Marin County JH PRO 20-22 - 7 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS (D) at least one youth supervision staff member on duty ☐ ☐ ☒ who is the same gender as youth housed in the facility; (E) in addition to the minimum staff to youth ratio required in (h)(3)(A)-(B), consideration shall be given to the size, design, and location of the camp; types of youth committed to the camp; and the ☐ ☐ ☒ function of the camp in determining the level of supervision necessary to maintain the safety and welfare of youth and staff; (F) personnel with primary responsibility for other duties such as administration, supervision of personnel, academic or trade instruction, clerical, ☐ ☐ ☒ farm, forestry, kitchen or maintenance shall not be classified as youth supervision staff positions. 1322 YOUTH SUPERVISION STAFF Policy 219 Youth Supervision Staff ORIENTATION AND TRAINING Orientation and Training (a) Prior to assuming any responsibilities each youth The elements of this regulation are supervision staff member shall be properly oriented confirmed in the CPO letter dated May 3, to their duties, including: 2022 ☒ ☐ ☐ According to the Board of State and Community Corrections’ Standard and Training for Corrections Division (STC), MCJH is up to date and in compliance with Title 15 minimum standards regarding staff training. (1) youth supervision duties; Policy 219 Youth Supervision Staff ☒ ☐ ☐ Orientation and Training, Section (a) (1) (2) scope of decisions they shall make; Policy 219 Youth Supervision Staff ☒ ☐ ☐ Orientation and Training, Section (a) (2) (3) the identity of their supervisor; ☒ ☐ ☐ (4) the identity of persons who are responsible to Policy 219 Youth Supervision Staff ☒ ☐ ☐ them; Orientation and Training, Section (a) (4) (5) persons to contact for decisions that are beyond Policy 219 Youth Supervision Staff ☒ ☐ ☐ their responsibility; and Orientation and Training, Section (a) (5) (6) ethical responsibilities. ☒ ☐ ☐ Policy 219 Section (a) (6) (b) Prior to assuming any responsibility for the Policy 219 Youth Supervision Staff supervision of youth, each youth supervision staff Orientation and Training Section B (b) (1 member shall receive a minimum of 40 hours of thru 11). facility-specific orientation, including: According to the Board of State and ☒ ☐ ☐ Community Corrections’ Standard and Training for Corrections Division (STC), MCJH ensures each youth supervision staff member shall receive a minimum of 40 hours of facility-specific orientation training. 7293 Marin County JH PRO 20-22 - 8 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS (1) individual and group supervision techniques; Policy 219 Youth Supervision Staff ☒ ☐ ☐ Orientation and Training, Section (b) (1) (2) regulations and policies relating to discipline and Policy 219 Youth Supervision Staff rights of youth pursuant to law and the ☒ ☐ ☐ Orientation and Training, Section (b) (2) provisions of this chapter; (3) basic health, sanitation and safety measures; Policy 219 Youth Supervision Staff ☒ ☐ ☐ Orientation and Training, Section (b) (3) (4) suicide prevention and response to suicide Policy 219 Youth Supervision Staff attempts Orientation and Training, Section (b) (4). ☒ ☐ ☐ MCJH conducts annual Suicide Prevention Training updates for its Supervisors and JCO staff. (5) policies regarding use of force, de-escalation Policy Youth Supervision Staff Orientation techniques, chemical agents, mechanical and ☒ ☐ ☐ and Training, Section (b) (5) physical restraints; (6) review of policies and procedures referencing Policy 219 Youth Supervision Staff ☒ ☐ ☐ trauma and trauma-informed approaches; Orientation and Training, Section (b) (6) (7) procedures to follow in the event of Policy 219 Youth Supervision Staff ☒ ☐ ☐ emergencies; Orientation and Training, Section (b) (7) (8) routine security measures, including facility Policy 219 Youth Supervision Staff ☒ ☐ ☐ perimeter and grounds; Orientation and Training, Section (b) (8) (9) crisis intervention and mental health referrals to Policy 219 Youth Supervision Staff ☒ ☐ ☐ mental health services; Orientation and Training, Section (b) ((9) (10) documentation; and Policy 219 Youth Supervision Staff ☒ ☐ ☐ Orientation and Training, Section (b) (10) (11) fire/life safety training Policy 219 Youth Supervision Staff ☒ ☐ ☐ Orientation and Training, Section (b) (11) (c) Prior to assuming sole supervision of youth, each Policy 219 Youth Supervision Staff youth supervision staff member shall successfully Orientation and Training, Section (c) complete the requirements of the Juvenile ☒ ☐ ☐ Corrections Officer Core Course pursuant to Penal The elements of this regulation are Code Section 6035. confirmed in the CPO letter dated May 3, 2022. (d) Prior to exercising the powers of a peace officer Policy 219 Youth Supervision Staff youth supervision staff shall successfully complete Orientation and Training, Section (d) training pursuant to Section 830 et seq. of the Penal ☒ ☐ ☐ Code. The elements of this regulation are confirmed in the CPO letter dated May 3, 2022. 1323 FIRE AND LIFE SAFETY Policy 219 Whenever there is a youth in a juvenile facility, there The elements of this regulation are shall be at least one wide awake person on duty at all ☒ ☐ ☐ confirmed in the CPO letter dated May 3, times who meets the training standards established by the 2022. Board for general fire and life safety which relate specifically to the facility. 7293 Marin County JH PRO 20-22 - 9 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS 1324 POLICY AND PROCEDURES MANUAL Policy 105 Policy and Procedure Manual All facility administrators shall develop, publish, and Memo completed on May 19, 2022, by implement a manual of written policies and procedures Superintendent, Tori Creighton, confirms that address, at a minimum, all regulations that are that the Policy and Procedure Manual was applicable to the facility. Such a manual shall be made administratively reviewed per Title 15 available to all employees, reviewed by all employees, ☒ ☐ ☐ Regulations Minimum Standards. and shall be administratively reviewed at a minimum every two years, and updated, as necessary. Those records relating to the standards and requirements set forth in these regulations shall be accessible to the Board on request. The manual shall include: (a) table of organization, including channels of Policy 105 Section (a) communications and a description of job classifications; ☒ ☐ ☐ In review of visually inspecting the Policy and Procedures Manual, MCJH follows minimum standards for this regulation. (b) responsibility of the probation department, purpose Policy 105 Section (b) 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; Policy 105 Section (c) ☒ ☐ ☐ In review of visually inspecting the Policy and Procedures Manual, MCJH follows minimum standards for this regulation. (d) initial orientation and training program for Policy 105 Section (d) employees; ☒ ☐ ☐ The elements of this regulation are confirmed in the CPO letter dated May 3, 2022.MCJH (e) initial orientation, including safety and security Policy 105 Section (e) issues and anti-discrimination policies, for support staff, contract employees, school, mental/behavioral ☒ ☐ ☐ The elements of this regulation are confirmed in the CPO letter dated May 3, health and medical staff, program providers and 2022. volunteers; (f) maintenance of record-keeping, statistics and Policy 105 Section (f) ☒ ☐ ☐ communication system to ensure: (1) efficient operation of the juvenile facility; ☒ ☐ ☐ Policy 105 Section (f) (1) (2) legal and proper care of youth; ☒ ☐ ☐ Policy 105 Section (f) (2) (3) maintenance of individual youth's records; ☒ ☐ ☐ Policy 105 Section (f) (3) (4) supply of information to the juvenile court and Policy 105 Section (f) (4) ☒ ☐ ☐ those authorized by the court or by the law; and, (5) release of information regarding youth. ☒ ☐ ☐ Policy 105 Section (f) (5) (g) ethical responsibilities; ☒ ☐ ☐ Policy 105 Section (g) 7293 Marin County JH PRO 20-22 - 10 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS (h) trauma-informed approaches; ☒ ☐ ☐ Policy 105 Section (h) (i) culturally responsive approaches; ☒ ☐ ☐ Policy 105 Section (i) (j) gender responsive approaches; Policy 105 Section (j) ☒ ☐ ☐ If appropriate, MCJH provides youth with a Transgender/Intersex Youth Preference Form at intake. (k) a non-discrimination provision that provides that all Policy Section 105 (k) youth within the facility shall have fair and equal access to all available services, placement, care, In review of the MCJH Policy and treatment, and benefits, and provides that no person Procedures Manual, MCJH follows shall be subject to discrimination or harassment on minimum standards for this regulation. 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 Policy 105 Section (l) chemical agents related security devices, and ☒ ☐ ☐ weapons and ammunition, where applicable; (m) establishment of procedures for collection of Medi- Policy 105 Section (m) Cal eligibility information and enrollment of eligible ☒ ☐ ☐ youth; and, (n) establishment of a policy that prohibits all forms of Policy 105 Section (n) 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 Policy 615 Fire Safety Plan The facility administrator shall consult with the local 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 Policy 615 Section (a) ☒ ☐ ☐ manual of policy and procedures; 7293 Marin County JH PRO 20-22 - 11 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS b) monthly fire and life safety inspections by facility On January 4, 2022, we conducted a Pre- staff with two- year retention of the inspection Inspection Briefing (PIB) with MCJH. We record; discovered that the MCJH facility did not complete a Fire and Life Safety Inspection from July 2020 to December 2021. We provided technical assistance to ensure monthly Fire and Life Safety inspections occurred monthly per regulation. At the time of this comprehensive inspection, MCJH has shown to be in compliance with ☒ ☐ ☐ the Title 15 minimum standards for this regulation. Technical Assistance was provided by recommending that MCJH provide supervisory oversight for monthly drills and develop a detailed Fire and Life Safety monthly inspection form. We also provided Technical Assistance in recommending that that MCJH update inspection forms to reflect distinguished differences between Fire life and Safety inspections, and Fire Drills. c) fire prevention inspections as required by Health 2020: and Safety Code Section 13146.1(a) and (b); Completed on November 23, 2020, by Engineer Paramedic, Jamal Cook. ☒ ☐ ☐ 2022: Completed on February 23, 2022, by Marin County Fire Department, Captain, Jake Rosebrock. d) an evacuation plan; ☒ ☐ ☐ Policy 615 Policy Evacuation plan. e) documented fire drills not less than quarterly; The fire drills are compliant with minimum standards for this regulation; however, the facility did have a 6-month gap between fire drills from October 15, 2020, through April 15, 2022. The Fire Drill documentation show alarm and “maintenance” checks but did not detail ☒ ☐ ☐ any other information such as a recorded count of youth, JCO staff, or other persons within the facility. Technical Assistance was provided to assist MCJH with guidance to develop a detailed Fire Drill inspection form. We also suggest that supervisory oversight ensures continued compliance with timely quarterly inspections per Title 15 Regulations minimum standards. 7293 Marin County JH PRO 20-22 - 12 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS f) a written plan for the emergency housing of youth in In review of the Policy and Procedure the case of fire; and, Manual, there is no mention of a specific location or language referencing a neighboring county agreement for emergency housing of youth in the case of fire evacuation. ☒ ☐ ☐ We provided Technical Assistance by recommending MCJH add to their Policy and Procedural Manual location specifics or language referencing a neighboring county agreement for the emergency housing of youth in the case of fire evacuation. g) development of a fire suppression pre-plan in Policy 615 Section (g) ☒ ☐ ☐ cooperation with the local fire department. 1326 SECURITY REVIEW 2021: An Annual Security Review was conducted on March 23, 2021 Each facility administrator shall develop policies and procedures to annually review, evaluate, and document We provided Technical Assistance security of the facility. The review and evaluation shall ☒ ☐ ☐ recommending MCJH ensure that, through include internal and external security, including, but not the entire inspection cycle, a Security limited to, key control, equipment, and staff training. Review occurs annually and is documented accordingly. 1327 EMERGENCY PROCEDURES Policy 619 Major Episode Control Management The facility administrator shall develop facility-specific ☒ ☐ ☐ policies and procedures for emergencies that shall Policy 615 Fire Safety Plan include, but not be limited to: (a) escape, disturbances, and the taking of hostages; ☒ ☐ ☐ Policy 619 Section (a) (b) civil disturbance, active shooter and terrorist attack; ☒ ☐ ☐ Policy 619 Section (b) (c) fire and natural disasters; ☒ ☐ ☐ Policy 619 Section (c) (d) periodic testing of emergency equipment; ☒ ☐ ☐ Policy 619 Section (d) (e) emergency evacuation of the facility; and ☒ ☐ ☐ Policy 619 Section (e) (f) a program to provide all youth supervision staff 2022: MCJH Superintendent Tori Creighton with an annual review of emergency procedures. provided a memo and acknowledged distributing an Annual Emergency Procedures Review to all staff. ☒ ☐ ☐ We provided Technical Assistance to ensure that MCJH provide BSCC with a memo indicating staff, through the entire inspection cycle, have annually reviewed Emergency Procedures and/ or completed a STC 2-hour block of Fire and Life Safety Training. 7293 Marin County JH PRO 20-22 - 13 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS 1328 SAFETY CHECKS Policy 477 Room Check Procedures/Documentation The facility administrator shall develop and implement policy and procedures that provide for direct visual During our Pre- Inspection Briefing on observation of youth at a minimum of every 15 minutes, January 4, 2022, we provided Technical at random or varied intervals during hours when youth Assistance to ensure Safety Checks were are asleep or when youth are in their rooms, confined in performed at randomly and varied intervals holding cells or confined to their bed in a dormitory. and to ensure that per MCJH policy, the shift Supervision is not replaced, but may be supplemented supervisor reviewed Safety Checks daily. ☒ ☐ ☐ by, an audio/visual electronic surveillance system During this inspection, we reviewed Safety designed to detect overt, aggressive or assaultive Checks for December and April of 2021 and behavior and to summon aid in emergencies. All safety February and March of 2022. We were checks shall be documented with the actual time the impressed with the changes implemented to check is completed. ensure Safety Checks were completed per Title 15 minimum standards and with the oversight taken by the supervisors to ensure quality assurance. 1329 SUICIDE PREVENTION PLAN Policy 471 Suicide Risk and Observation Program The facility administrator, in collaboration with the We reviewed one (1) suicide ideation healthcare and behavioral/mental health administrators, Incident Report from this inspection cycle. shall plan and implement written policies and Review of the report show MCJH follows procedures which delineate a Suicide Prevention Plan. compliance with this regulation and with The plan shall consider the needs of youth experiencing MCJH Policy and Procedure Manual. past or current trauma. Suicide prevention responses ☒ ☐ ☐ shall be respectful and in the least invasive manner We did, however, provide Technical consistent with the level of suicide risk. The plan shall Assistance regarding the timeframes in include the following elements: which youth placed on Observation Program (OBS) are observed in their room. We recommend removing “more frequently” and changing the time frame from every 15 minutes to every five or ten minutes as every 15 minutes is a normal Safety Check. (a) Suicide prevention training as required in Section The elements of this regulation are 1322, Youth Supervision Staff Orientation, and ☒ ☐ ☐ confirmed in the CPO letter dated May 3, Training and the Juvenile Corrections Officer Core 2022.MCJH Course. (b) Screening, Identification Assessment and Policy 471 Suicide Risk and Observation Precautionary Protocols Program #3 (1) All youth shall be screened for risk of suicide at intake and as needed during ☒ ☐ ☐ Policy 401 Intake/Initial Screening detention. We were impressed with the safety protocols taken by staff during the intake process. (2) All youth supervision staff who perform Policy 219 Section (4) intake processes shall be trained in ☒ ☐ ☐ Policy 471 Suicide Risk and Observation screening youth for risk of suicide. Program 7293 Marin County JH PRO 20-22 - 14 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS (3) All youth who have been identified during Policy 471 Suicide Risk and Observation the intake screening process to be at risk of Program #4 ☒ ☐ ☐ suicide shall be referred to behavioral/mental health staff for a suicide risk assessment. (4) Precautionary protocols shall be developed Policy 471 Section (4) ☒ ☐ ☐ to ensure the youth’s safety pending the behavioral/mental health assessment. (c) Referral process to behavioral/mental health staff ☒ ☐ ☐ Policy 471 Section (c) for assessment and/or services. (d) Procedures for monitoring of youth identified at ☒ ☐ ☐ Policy 471 Section (d) risk for suicide. (e) Safety Interventions Policy 471 Section (e) (1) Procedures to address intervention Policy 471 Section (e) (1) protocols for youth identified at risk for suicide which may include, but are not We reviewed 1 Incident report involving limited to: suicide safety interventions during the 2020/2022 inspection cycle. ☒ ☐ ☐ In review, the 15 minute “Observation Watch” status is the same time frame as 15 minute “Safety Checks”. Thus, there is no increase in safety precautions. Our Technical Assistance recommends MCJH increase its “Observation Watch” Safety check intervals. A. Housing consideration ☒ ☐ ☐ Policy 471 Section (1) (A) B. Treatment strategies including Policy 471 Section (1)(B) ☒ ☐ ☐ trauma-informed approaches (2) Procedures to instruct youth supervision Policy 471 Section (2) staff how to respond to youth who exhibit ☒ ☐ ☐ suicidal behaviors. (f) Communication Policy 471 Section (f) (1) (1) The intake process shall include communication with the arresting officer ☒ ☐ ☐ and family guardians regarding the youth’s past or present suicidal ideations, behaviors or attempts. (2) Procedures for clear and current Policy 471 Section (f) (2) information sharing about youth at risk for ☒ ☐ ☐ suicide with youth supervision, healthcare, and behavioral/mental health staff. (g) Debriefing of Critical Incidents Related to Suicides Policy 471 Section (g) (1) or Attempts ☒ ☐ ☐ (1) Process for administrative review of the circumstances and responses proceeding, during and after the critical incident. (2) Process for a debriefing event with affected Policy 471 (Section (g) (2) ☒ ☐ ☐ staff. (3) Process for a debriefing event with affected Policy 471 Section (g) (3) ☒ ☐ ☐ youth. 7293 Marin County JH PRO 20-22 - 15 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS (h) Documentation Policy 471 Section (h) (1) (1) Documentation processes shall be ☒ ☐ ☐ developed to ensure compliance with this regulation Youth identified at risk for suicide shall not be denied Policy 471 Section (I) the opportunity to participate in facility programs, services and activities which are available to other non- suicidal youth, unless deemed necessary for the safety ☒ ☐ ☐ of the youth or security of the facility. Any deprivation of programs, services or activities for youth at risk of suicide shall be documented and approved by the facility manager. 1340 REPORTING OF LEGAL ACTIONS Policy 106 Reporting to the Board of State and Community Corrections Each facility shall submit to the Board a letter of notification on each legal action, pertaining to conditions ☒ ☐ ☐ There were no reports of legal action having of confinement, filed against persons or legal entities occurred during this inspection cycle (2020 responsible for juvenile facility operation. thru 2022) 1341 DEATH AND SERIOUS ILLNESS OR Policy 610 Death of a Minor in Custody INJURY OF A YOUTH WHILE DETAINED No death or serious illness or injury reported having occurred during this inspection cycle (1) Death of a Youth. 2020 thru 2022. (a) The facility administrator, in cooperation with the health administrator and the behavioral/mental ☒ ☐ ☐ health director, shall develop written policies and procedures in the event of the death of a youth while detained, which include notifications to necessary parties, which may include the Juvenile Court, the parent, guardian or person standing in loco parentis and the youth’s attorney of record. (b) The health administrator, in cooperation with the Policy 610 Death of a Minor in Custody facility administrator, shall develop written policies Policy statement and procedures to assure there is a medical and operational review of every in-custody death of a ☒ ☐ ☐ youth. The review team shall include the facility administrator and/or facility manager, the health administrator, the responsible physician and other health care and supervision staff who are relevant to the incident. (c) The administrator of the facility shall provide to the Policy 610 Death of a Minor in Custody Board a copy of the report submitted to the Attorney Policy statement General under Government Code Section 12525. A ☒ ☐ ☐ copy of the report shall be submitted to the Board within 10 calendar days after the death. 7293 Marin County JH PRO 20-22 - 16 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS (d) Upon receipt of a report of the death of a youth from Policy 610 Death of a Minor in Custody the administrator, the Board may within 30 calendar Policy statement days inspect and evaluate the juvenile facility, jail, lockup or court holding facility pursuant to the ☒ ☐ ☐ provisions of this subchapter. Any inquiry made by the Board shall be limited to the standards and requirements set forth in these regulations. (2) Serious Illness or Injury of Youth Policy 611 life Threating Injury or Illness of (a) The facility administrator, in cooperation with the a Minor in Custody. health administrator, shall develop written policies There were no reported incidents of life- and procedures for the notification to necessary ☒ ☐ ☐ threatening injury or illness of a minor in parties, which may include the Juvenile Court, the custody during this inspection cycle. parent, guardian or person standing in loco parentis and the youth’s attorney of record in the case of a serious illness or injury of a youth. 1342 POPULATION ACCOUNTING Policy 106 Reporting to the Board of State and Community Corrections Each juvenile facility shall submit required population and profile survey reports to the Board within 10 ☒ ☐ ☐ II. Population Accounting working days after the end of each reporting period, in a format to be provided by the Board. According to BSCC records, MCJH follows this regulation. 1343 JUVENILE FACILITY CAPACITY Policy 106 Reporting to the Board of State and Community Corrections When the number of youth detained in a living unit of a juvenile facility exceeds its rated capacity for more than ☒ ☐ ☐ MCJH Rated Capacity is currently for 40 fifteen (15) calendar days in a month, the facility youth. administrator shall provide a crowding report to the Board in a format provided by the Board. 1350 ADMITTANCE PROCEDURES Policy 401 Intake/Initial Screening Policy 409 Booking Protocol The facility administrator shall develop and implement written policies and procedures for admittance of youth We reviewed (8) MCJH Intake Packet forms. that emphasize respectful and humane engagement with In review of the documentation, MCJH youth, and reflect that the admission process may be ☒ ☐ ☐ follows minimum standards for this traumatic to youth who may have already experienced regulation. We also interviewed several trauma. Policies shall be trauma-informed, culturally youths in custody. Overall, we were relevant, and responsive to the language and literacy impressed with the trauma informed needs of youth. In addition to the requirements of approach that MCJH intake staff utilize with Sections 1324 and 1430 of these regulations: youth during the intake process. (a) the admittance process shall include: Policy 409 Booking Protocol (1) Access to two free phone calls within one hour of admittance in accordance with the provisions ☒ ☐ ☐ Interviews with youth in custody and staff of Welfare and Institution Code Section 627; show that MCJH follow compliance with minimum standards of this regulation. (2) Offer of a shower; Policy 409 Booking Protocol ☒ ☐ ☐ Technical Assistance was provided to ensure that the offering of shower shall be added to the Intake Packet Form. 7293 Marin County JH PRO 20-22 - 17 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS (3) Documented secure storage of personal Policy 409 Booking Protocol belongings; ☒ ☐ ☐ (4) Offer of food upon arrival; Policy 409 Booking protocol #6 ☒ ☐ ☐ Technical Assistance was provided to ensure that the offering of “Food” shall be added to the Intake Packet Form. (5) Screening for physical and behavioral health Policy 401 Intake/Initial Screening and safety issues, intellectual or developmental ☒ ☐ ☐ disabilities; (6) Screening for physical and developmental Policy 401 Intake/Initial Screening disabilities in accordance with Sections 1329, ☒ ☐ ☐ 1413, and 1430 of these regulations; (7) Contact with Regional Center for the Policy 401 Intake/Initial Screening Developmentally Disabled for youth that are ☒ ☐ ☐ suspected of or identified as having a developmental disability, pursuant to Section 1413; and, (8) Procedures consistent with Section 1352.5. ☒ ☐ ☐ Policy 401 #8 (b) juvenile hall administrators shall establish written Policy 498 Classification criteria for detention that considers the least ☒ ☐ ☐ Statement #4 restrictive environment. (c) juvenile camps and post-dispositional programs in Juvenile Hall is not a camp, nor does it have juvenile halls shall develop policies and procedures post dispositional programs. that advise the youth of the estimated length of ☒ ☐ ☐ stay, inform them of program guidelines and provide written screening criteria for inclusion and exclusion from the program. (d) juvenile halls shall develop policies and procedures Policy 498 Classification Statement #5 that advise any committed youth of the estimated ☒ ☐ ☐ length of his/her stay. 1350.5. SCREENING FOR THE RISK OF SEXUAL Policy 598 Screening for the Risk of Sexual ABUSE Abuse The facility administrator shall develop and implement We reviewed (8) Screening for Vulnerability written policies and procedures to reduce the risk of to Victimization and Sexually Aggressive sexual abuse by or upon youth. The policy shall require Behavior (VSAB) forms. We were ☒ ☐ ☐ facility staff to assess each youth within 72 hours of impressed with the intake process in admission based on the following information: identifying youths’ potential vulnerabilities, in particular the attention to detail and interactions with youth. Review of the documentation show compliance with minimum standards for this regulation. (a) Prior sexual victimization or abusiveness; Policy 598 screening for the Risk of Sexual ☒ ☐ ☐ Abuse A. 7293 Marin County JH PRO 20-22 - 18 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS (b) Gender nonconforming appearance or manner; or Policy 598 screening for the Risk of Sexual identification as lesbian, gay or bisexual, Abuse B. ☒ ☐ ☐ transgender, queer or intersex, and whether the youth may, therefore, be vulnerable to sexual abuse; (c) Current charges and offense history; Policy 598 screening for the Risk of Sexual ☒ ☐ ☐ Abuse C. (d) Age; Policy 598 screening for the Risk of Sexual ☒ ☐ ☐ Abuse D. (e) Level of emotional and cognitive development; Policy 598 screening for the Risk of Sexual ☒ ☐ ☐ Abuse E. (f) Physical size and stature; Policy 598 screening for the Risk of Sexual ☒ ☐ ☐ Abuse F. (g) Mental illness or mental disabilities; Policy 598 screening for the Risk of Sexual ☒ ☐ ☐ Abuse G. (h) Intellectual or developmental disabilities; Policy 598 screening for the Risk of Sexual ☒ ☐ ☐ Abuse G. (i) Physical disabilities; Policy 598 screening for the Risk of Sexual ☒ ☐ ☐ Abuse H. (j) The youth’s perception of vulnerability; and, Policy 598 screening for the Risk of Sexual ☒ ☐ ☐ Abuse (I) (k) Any other specific information about the individual Policy 598 screening for the Risk of Sexual youth that may indicate heightened needs for ☒ ☐ ☐ Abuse (J) supervision, additional safety precautions, or separation from certain other youth. Staff shall ascertain this information through Policy 598 Screening for Risk of Sexual conversations with the youth during the admittance Abuse introduction process, medical and behavioral health screenings; ☒ ☐ ☐ during classification assessments; and by reviewing court records, case files, facility behavioral records, and other relevant documentation from the youth’s files. The facility administrator shall implement appropriate Policy 598 screening for the Risk of Sexual controls on the dissemination of information within the Abuse (K) facility relative to responses received pursuant to this ☒ ☐ ☐ assessment in order to ensure that sensitive information is not exploited to the youth’s detriment by staff or other youth. 1351 RELEASE PROCEDURES Policy 413 Release Procedure The facility administrator shall develop and implement We review 5 youths release packets as well written policies and procedures for release of youth ☒ ☐ ☐ as education booking referral packets. The from custody which provide for: documentation provided show MCJH to follow minimum standards for this regulation. (a) verification of identity/release papers; Policy 413 Release Procedure ☒ ☐ ☐ 1. Authorization for release: a. (b) return of personal clothing and valuables; Policy 413 Release Procedure ☒ ☐ ☐ 2. Procedure: a. (c) notification to the youth's parents or guardian; ☒ ☐ ☐ Policy 413 Release Procedure 2 Section (b) 7293 Marin County JH PRO 20-22 - 19 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS (d) notification to the facility health care provider in Policy 413 Release Procedure accordance with Sections 1408 and 1437 of these 2. Procedure: c. ☒ ☐ ☐ regulations, for coordination with outside agencies; and, (e) notification of school staff; Policy 413 Release Procedure ☒ ☐ ☐ 2. Procedure: (d) (f) notification of facility mental health personnel. ☒ ☐ ☐ Policy 413 Release Procedure # 2 Section (c) The facility administrator shall develop and implement Policy 413 Release Procedure #3 Section (a) policies and procedures for post-disposition youth to coordinate the provision of transitional and reentry ☒ ☐ ☐ services including, but not limited to, medical and behavioral health, education, probation supervision and community-based services. The facility administrator shall develop and implement Policy 413 Procedure #3 Section (b) written policies and procedures for the furlough of ☒ ☐ ☐ youth from custody. 1352 CLASSIFICATION Policy 498 Classification System The facility administrator shall develop and implement We reviewed seven (7) MCJH Classification written policies and procedures on classification of forms for youth. In review, MCJH follows youth for the purpose of determining housing placement compliance with the minimum standards for in the facility. ☒ ☐ ☐ this regulation. Such procedures shall: We provided Technical Assistance to recommend MCJH update the Intake Classification Policy to eliminate DJJ references. (a) provide for the safety of the youth, other youth, Policy 498 Classification System facility staff, and the public by placing youth in the Policy statement #1 appropriate, least restrictive housing and program ☒ ☐ ☐ settings. Housing assignments shall consider the need for single, double or dormitory assignment or location within the dormitory; (b) consider facility populations and physical design of Policy 498 Classification System ☒ ☐ ☐ the facility; Policy statement #2 (c) provide that a youth shall be classified upon Policy 498 Classification System admittance to the facility; classification factors Policy statement #3A. shall include, but not be limited to: age, maturity, sophistication, emotional stability, program needs, ☒ ☐ ☐ legal status, public safety considerations, medical/mental health considerations, gender and gender identity of the youth; (d) provide for periodic classification reviews, Policy 498 Classification System including provisions that consider the level of Policy statement #4 ☒ ☐ ☐ supervision and the youth's behavior while in custody; and, 7293 Marin County JH PRO 20-22 - 20 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS (e) provide that facility staff shall not separate youth Policy 498 Classification System from the general population or assign youth to a Policy statement #3B. single occupancy room based solely on the youth's actual or perceived race, ethnic group identification, ancestry, national origin, color, religion, gender, sexual orientation, gender identity, ☒ ☐ ☐ gender expression, mental or physical disability, or HIV status. This section does not prohibit staff from placing youth in a single occupancy room at the youth's specific request or in accordance with Title 15 regulations regarding separation. (f) facility staff shall not consider lesbian, gay, Policy 498 Classification System bisexual, transgender, questioning or intersex Policy statement #3D. ☒ ☐ ☐ identification or status as an indicator of likelihood of being sexually abusive. 1352.5 TRANSGENDER AND INTERSEX YOUTH. Policy 498 Transgender and Intersex Youth The facility administrator shall develop written policies MCJH, if applicable, provides a ☒ ☐ ☐ and procedures ensuring respectful and equitable Transgender/Intersex Youth Preference treatment of transgender and intersex youth. The Form at intake. policies shall provide that: (a) Facility staff shall respect every youth’s gender Policy 498 Transgender and Intersex Youth identity and shall refer to the youth by the youth’s Procedures upon intake C. preferred name and gender pronoun, regardless of the youth’s legal name. Facilities may prohibit the ☒ ☐ ☐ use of gang or slang names or names that otherwise compromise facility operations as determined by the facility manager or designee, and shall document any decision made on this basis. (b) Facility staff shall permit youth to dress and present Policy 498 Transgender and Intersex Youth themselves in a manner consistent with their gender ☒ ☐ ☐ Procedures upon intake E. identity and shall provide youth with the institution’s clothing and undergarments consistent with their gender identity. (c) Facility staff shall house youth in the unit or room Policy 498 Transgender and Intersex Youth that best meets their individual needs and promotes Housing A and B. their safety and well-being. Staff may not automatically house youth according to their external anatomy and shall document the reasons ☒ ☐ ☐ for any decision to house youth in a unit that does not match their gender identity. In making a housing decision, staff shall consider the youth’s preferences, as well as any recommendations from the youth’s health or behavioral health provider. (d) Facility administrators shall ensure that transgender Policy 498 Transgender and Intersex Youth and intersex youth have access to medical and ☒ ☐ ☐ Behavioral Health statement behavioral health providers qualified to provide care and treatment to transgender and intersex youth. 7293 Marin County JH PRO 20-22 - 21 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS (e) Consistent with the facility’s reasonable and Policy 498 Transgender and Intersex Youth necessary security considerations and physical Housing C. plant, facility staff shall make every effort to ensure ☒ ☐ ☐ the safety and privacy of transgender and intersex youth when the youth are using the bathroom or shower, or dressing or undressing. Facility staff shall not conduct physical searches of any Policy 498 Transgender and Intersex Youth youth for the purpose of determining the youth’s ☒ ☐ ☐ Searches A. anatomical sex. Whenever feasible, the facility shall respect the youth’s preference regarding the gender of the staff member who conducts any search of the youth. 1353 ORIENTATION Policy 401 Intake/Initial Screening The facility administrator shall develop and implement We reviewed (8) MCJH Intake Packets. In written policies and procedures to orient a youth prior review, MCJH shows to follow the minimum to placement in a living area. Both written and verbal standards with this regulation. information shall be provided and supplemented with ☒ ☐ ☐ In providing Technical Assistance, we video orientation if feasible. Provision shall be made to recommend MCJH update language in the provide accessible orientation information to all Orientation Policy (The language in the detained youth including those with disabilities, limited intake packet under ‘Your Rights”) is literacy, or English language learners. Orientation shall outdated language. include information that addresses: (a) facility rules including contraband and searches and Policy 401 Intake/Initial Screening disciplinary procedures; MCJH provides youth with a well detailed ☒ ☐ ☐ orientation packets regarding facility rules including contraband and 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 ☒ ☐ ☐ MCJH provides youth with a well detailed with facility rules, and consequences that may orientation packets covering all the elements result when youth violate the rules of the facility; of this regulation. (c) age appropriate information that explains the Policy 401 Intake/Initial Screening facility’s policy prohibiting sexual abuse and sexual Policy 409 Booking Protocol ☒ ☐ ☐ 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; (g) access to routine and emergency health and mental Policy 401 Intake/Initial Screening health care; Policy 409 Booking Protocol ☒ ☐ ☐ 7293 Marin County JH PRO 20-22 - 22 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS (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 Policy 401 Intake/Initial Screening from 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 Policy 401 Intake/Initial Screening Title 15 Minimum Standards for Juvenile Facilities. During the intake process, the Intake Packet ☒ ☐ ☐ provides Title 15 accessibility guidance to youth. 7293 Marin County JH PRO 20-22 - 23 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS 1354 SEPARATION Policy 497 Administrative Separation The facility administrator shall develop and implement In Review of Policy 497 Administrative written policies and procedures that address: Separation, we determined that the policy needs to be updated. Specifically, we recommend changing language and the rationale for classifying youth as ☒ ☐ ☐ Administrative Separation status during the intake process. On July 21, 2022, MCH provided an updated Separation Policy. The updated Separation Policy deleted language to indicate Separation on intake solely for 707(b) offenses and out of county bookings. (a) separation of youth for reasons that include, but are Policy 497 Administrative Separation not be limited to, medical and mental health Section (a) ☒ ☐ ☐ conditions, assaultive behavior, disciplinary consequences and protective custody. (b) consideration of positive youth development and Policy 497 Section(b) ☒ ☐ ☐ trauma-informed care. 7293 Marin County JH PRO 20-22 - 24 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS (c) separated youth shall not be denied normal Policy 497 Section (c) privileges available at the facility, except when MCJH was not able to provide necessary to accomplish the objective of separation. documentation to show that youth on Administrative Separation received equal programing, recreation, and exercise opportunities as other youth. Further, interviews with facility staff and youth support the lack of equity given to youth on Administrative Separation. As a result, MCJH was out of compliance with this regulation due to, youth on Administrative Separation (AD/SEP) were not provided Title 15 minimum requirements of one hour of programming, recreation, and exercise per day. ☐ ☒ ☐ On July 21, 2022, MCJH provided documentation and steps taken to show that the necessary corrective actions have occurred to ensure compliance with the minimum standards for this regulation. MCJH made the following corrective actions: 1. Created an Ad/Sep Logbook ensuring daily Title 15 requirements are met. 2. Updated their Separation Policy to reflect changes in expectations. 3. Supervisor to review Ad/Sep Logbook daily. 4. Provided a training and Job Aide for staff. (d) when the objective of the separation is discipline, Policy 497 Section (d) ☒ ☐ ☐ Title 15 Section 1390 shall apply. (e) when separation results in room confinement, the Policy 497 Section (e) separation shall occur in accordance with Welfare ☒ ☐ ☐ and Institutions Code Section 208.3 and Section1354.5 of these regulations. (f) policies and procedures shall ensure a daily review Policy 497 Section (e) of separated youth to determine if separation ☒ ☐ ☐ remains necessary. 7293 Marin County JH PRO 20-22 - 25 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS 1354.5 ROOM CONFINEMENT Policy 468 Room Confinement (a) The facility administrator shall develop and implement written policies and procedures addressing the confinement of youth in their room ☒ ☐ ☐ that are consistent with Welfare and Institutions Code Section 208.3. The placement of a youth in room confinement shall be accomplished in accordance with the following guidelines: 7293 Marin County JH PRO 20-22 - 26 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS (1) Room confinement shall not be used before Policy 468 Room Confinement other, less restrictive, options have been attempted and exhausted, unless attempting Room Reflection Time (room confinement) those options poses a threat to the safety or was often given to youth with pre- security of any youth or staff. determined time periods of up to one hour for disciplinary reasons. This is a “room restriction” which is no longer compliant with Title 15 Regulations. We reviewed 3 incident reports in which a youth was given Room Reflection time. All three-incident resulted in a youth being placed in his/her room for less than an hour. However, none of the incidents reach the justifiable level of safety and security to place a youth in a confined room. As a result, MCJH is not in compliance with this regulation. Through our Technical Assistance we informed the facility that if a youth is placed in a locked room for any reason other than for medical precautions, it is considered ☐ ☒ ☐ room confinement. Further, that room confinement shall only be utilized when a youth presents a safety security threat to himself/ herself. On July 21, 2022, MCJH provided documentation and steps taken to show that the necessary corrective actions have occurred to ensure compliance with the minimum standards for this regulation. MCJH made the following corrective actions: 1. Updated the Separation Policy to clearly define Temporary and Voluntary Separation. 2. Developed a new Temporary/Voluntary Separation form. 3. Behavior Management guidelines updated to discontinue the practice of “Room Reflection Time” 4. Provided a training to staff. 7293 Marin County JH PRO 20-22 - 27 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS (2) Room confinement shall not be used for the Policy 468 Room Confinement purposes of punishment, coercion, Guidelines for Room Confinement B. convenience, or retaliation by staff. Guidelines for Room Confinement A. The facility utilizes a program titled “Room Reflection Time” which often requires a youth to be placed in a temporarily locked room for violating facility’s rules. As a result, MCJH is not in compliance ☐ ☒ ☐ with this regulation. Through Technical Assistance, we informed MCJH that room confinement shall only be used if a youth is a safety and security to himself or others. As indicated in section (1), comments above, of this regulation, On July 21, 2022, MCJH provided documentation and steps taken to ensure compliance with the minimum standards for this regulation. (3) Room confinement shall not be used to the Policy 468 Room Confinement extent 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 Use of Room Confinement A. do one or more of the following: (1) Return the youth to general population. Policy 468 Room Confinement ☒ ☐ ☐ Use of Room Confinement B1. (2) Consult with mental health or medical staff. Policy 468 Room Confinement ☒ ☐ ☐ Use of Room Confinement B2. (3) Develop an individualized plan that includes Policy 468 Room Confinement the goals and objectives to be met in order to ☒ ☐ ☐ reintegrate the youth to general population. Use of Room Confinement B3. (4) If room confinement must be extended beyond Policy 468 Room Confinement four hours, staff shall do each of the following: ☒ ☐ ☐ Use of Room Confinement C.1-4 (A) Document the reasons for room Policy 468 Room Confinement confinement and the basis for the extension, the date and time the youth was Use of Room Confinement C.1 ☒ ☐ ☐ first placed in room confinement, and when he or she is eventually released from room confinement. 7293 Marin County JH PRO 20-22 - 28 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS (B) Develop an individualized plan that Policy 468 Room Confinement includes the goals and objectives to be met ☒ ☐ ☐ in order to integrate the youth to general Use of Room Confinement C.2 population. (C) Obtain documented authorization by the Policy 468 Room Confinement facility superintendent or his or her ☒ ☐ ☐ designee every four hours thereafter. Use of Room Confinement C.3 (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 Policy 468 Section (6) ☒ ☐ ☐ in 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. 1355 INSTITUTIONAL ASSESSMENT AND Policy 412 Assessment and Case Plan PLAN Policy statement ☒ ☐ ☐ The facility administrator shall develop and implement written policies and procedures for assessment and case planning. 7293 Marin County JH PRO 20-22 - 29 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS (a) Assessment: Policy 412 Assessment and Case Plan The assessment is based on information collected Policy statement during the admission process with periodic review, which includes the youth's risk factors, needs and The Policy 412 Assessment and Case Plans, ☒ ☐ ☐ strengths including, but not limited to, contains the elements for the minimum identification of substance abuse history, standards for this regulation. educational, vocational, counseling, behavioral health, consideration of known history of trauma, and family strengths and needs. (b) Institutional Case Plan: Policy 412 Assessment and Case Plan (1) A case plan shall be developed for each youth Policy statement ☒ ☐ ☐ held for at least 30 days or more and created within 40 days of admission. (2) The institutional plan shall include, but not be Policy 412 Assessment and Case Plan limited to, written documentation that provides: ☒ ☐ ☐ Policy statement (A) objectives and time frame for the resolution Policy 412 Assessment and Case Plan ☒ ☐ ☐ of problems identified in the assessment; Policy statement (B) a plan for meeting the objectives that Policy 412 Assessment and Case Plan includes a description of program resources ☒ ☐ ☐ Policy statement needed and individuals responsible for assuring that the plan is implemented; 7293 Marin County JH PRO 20-22 - 30 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS (3) periodic evaluation of progress towards meeting Policy 412 Assessment and Case Plan the objectives, including periodic review and Policy statement discussion of the plan with the youth; We reviewed 6 “Assessment/Case Plans” that MCJH also referenced as being Institutional Case Plans. In review, there were no periodic evaluation of progress towards meeting the objectives, including periodic review and discussion of the plan with the youth. Further, the information within the documents provided were more consistent with youth behavior notations rather than the elements specified in Title 15 for Institutional Case Plans. As a result, MCJH is non-Compliant with this regulation. We provided Technical Assistance that recommend MCJH formulate an Institutional Case Plan document that will guide the staff and that contain the elements for minimum standards of this regulation. We also ☐ ☒ ☐ provided an understanding of distinguishing the differences in expectations between Assessment and Case Plan vs Institutional Case Plans. On July 21, 2022, MCJH provided documentation and steps taken to show that the necessary corrective actions have occurred to ensure compliance with the minimum standards for this regulation. MCJH made the following corrective actions: 1. Updated Institutional Case Plan Policy to reflect that youth will now be assigned to JCO’s to have monthly reviews with youth regarding their respective Case Plans. 2. Updated procedures to include supervisory oversight through Case Plan audits every 15 days. 3. Provided a training and job aide to staff. 7293 Marin County JH PRO 20-22 - 31 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS (4) a transition plan, the contents of which shall be Policy 412 Assessment and Case Plan subject to existing resources, shall be developed ☒ ☐ ☐ Policy statement for post dispositional youth in accordance with Section 1351; and, (5) in as much as possible and if appropriate, the Policy 401 Intake/Initial Screening plan, including the transition plan, shall be ☒ ☐ ☐ developed with input from the family, supportive adults, youth, and Regional Center for the Developmentally Disabled. 1356 COUNSELING AND CASEWORK Policy 304 Counseling and Other SERVICES Therapeutic programs The facility administrator shall develop and implement ☒ ☐ ☐ Policy 304 Counseling and Other written policies and procedures ensuring the availability Therapeutic programs contains the elements of appropriate counseling and casework services for all for the minimum standards of this regulation. youth. Policies and procedures shall ensure: (a) youth will receive assistance with needs or concerns Policy 304 Counseling and Other ☒ ☐ ☐ that may arise; Therapeutic programs (b) youth will receive assistance in requesting contact Policy 304 Counseling and Other with parents, other supportive adults, attorney, ☒ ☐ ☐ Therapeutic programs clergy, probation officer, or other public official; and, (c) youth will be provided access to available resources Policy 304 Counseling and Other to meet the youth’s needs. ☒ ☐ ☐ Therapeutic programs 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 treatment. (a) At a minimum, each facility shall develop policies and procedures which: (1) restricts the use of force to that which is deemed Policy 448: Use of Force reasonable and necessary, as defined in Section ☒ ☐ ☐ Section (a) (1) 1302 to ensure the safety and security of youth, staff, others and the facility. (2) outline the force options available to staff Policy 448: Use of Force including both physical and non-physical ☒ ☐ ☐ Section (a) (2) options and define when those force options are appropriate. (3) describe force options or techniques that are Policy 448 expressly prohibited by the facility. ☒ ☐ ☐ Section (a) (3) 7293 Marin County JH PRO 20-22 - 32 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS (4) describe the requirements of staff to report any Policy 448 inappropriate use of force, and to take ☒ ☐ ☐ Section (a) (4) affirmative action to immediately stop it. (5) define a standardized reporting format that Policy 448 includes time period and procedure for Section (a) (5) 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 Policy 448 for investigating unreasonable use of force. ☒ ☐ ☐ Section (a) (6) 7293 Marin County JH PRO 20-22 - 33 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS (7) define the role, notification, and follow-up Policy 448 procedures required after use of force incidents Section VIII (C) for medical, mental health staff and parents or legal guardians. The policy contains the minimum standards for this regulation. However, in reviewing Use of Force Incident Reports, the facility is not consistently contacting the parental/legal guardian with a follow up notification for youth involved with Use of Force Incidents. Further, through interviews with staff and supervisors, parents are only notified if a youth is transported to the hospital for injuries. As a result, MCJH is non-compliant with this regulation. We recommend MCJH update their incident reports to provide an area that shows parental/legal guardian notification made ☐ ☒ ☐ when Use of Force incidents occur. Or provide a system of documentation to ensure parental/legal guardian notifications have been made following Use of Force incidents. On July 21, 2022, MCJH provided documentation and steps taken to show that the necessary corrective actions have occurred to ensure compliance with the minimum standards for this regulation. MCJH made the following corrective actions: 1. Made changes to the Incident Report to indicate parental notification. 2. Change the procedure to ensure the parent or guardian are notified on every Use of Force Incident. 3. Added parent notification to be noted in the housing unit logbook. (8) describe the limitations of use of force on Policy 448 pregnant youth in accordance with Penal Code ☒ ☐ ☐ Section (a) (8) Section 6030(f) and Welfare and Institutions Code Section 222. (b) Facilities that authorize chemical agents as a force ☐ ☐ ☒ option shall include policies and procedures that: (1) identify who is approved to carry and/or utilize chemical agents in the facility and the type, size ☐ ☐ ☒ and the approved method of deployment for those chemical agents. 7293 Marin County JH PRO 20-22 - 34 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS (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 Policy 448 which require that agencies provide initial and ☒ ☐ ☐ Section C regular training in use of force and chemical agents when appropriate that address: (1) known medical and behavioral health Policy 448 ☒ ☐ ☐ conditions that would contraindicate certain Section (c) (1) types of force; (2) acceptable chemical agents and the methods of ☒ ☐ ☐ application. (3) signs or symptoms that should result in Policy 448 ☒ ☐ ☐ immediate referral to medical or behavioral Section (c) (3) health. (4) instruction on the Constitutional Limitations of Policy 448 ☒ ☐ ☐ Use of Force. Section (c) (4) (5) physical training force options that may require Policy 448 ☒ ☐ ☐ the use of perishable skills. Section (c) (5) (6) timelines the facility uses to define regular Policy 448 ☒ ☐ ☐ training. Section (c) (6) 7293 Marin County JH PRO 20-22 - 35 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS 1358 USE OF PHYSICAL RESTRAINTS Policy 614 Use of Physical Restraints The facility administrator, in cooperation with the responsible physician and mental health director, shall develop and implement written policies and procedures ☒ ☐ ☐ for the use of restraint devices. Restraint devices include any devices which immobilize a youth's extremities and/or prevent the youth from being ambulatory. Physical restraints may be used only for those youth Policy 614 Use of Physical Restraints who present an immediate danger to themselves or Policy statement others, who exhibit behavior which results in the destruction of property, or reveals the intent to cause ☒ ☐ ☐ The Policy 614 Use of Physical Restraints, self-inflicted physical harm. Physical restraints should contains the elements for the minimum standards for this regulation. 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 Policy 614 Use of Physical Restraints discipline, or as a substitute for treatment. The use of Policy statement 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. The provisions of this section do not apply to the use of Policy 614 Use of Physical Restraints handcuffs, shackles or other restraint devices when used Policy statement 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 Policy 614 Use of Physical Restraints of the facility manager or designee. The facility manager Policy statement 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 Policy 614 Use of Physical Restraints retention shall be secured as soon as possible, but no later ☒ ☐ ☐ Procedure #3 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 soon as Policy 614 Use of Physical Restraints possible, but in no case longer than four hours from the ☒ ☐ ☐ Procedure #4 time of placement, to assess the need for mental health treatment. 7293 Marin County JH PRO 20-22 - 36 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS Continuous direct visual supervision shall be conducted Policy 614 Use of Physical Restraints to ensure that the restraints are properly employed, and Procedure #5 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 Policy 614 Use of Physical Restraints procedures shall address: (a) documentation of the circumstances leading to an Policy 614 Use of Physical Restraints ☒ ☐ ☐ application of restraints. Policy statement (b) known medical conditions that would Policy 614 Use of Physical Restraints ☒ ☐ ☐ contraindicate certain restraint devices and/or Policy statement techniques. (c) acceptable restraint devices. Policy 614 Use of Physical Restraints ☒ ☐ ☐ Policy statement (d) signs or symptoms which should result in Policy 614 Use of Physical Restraints ☒ ☐ ☐ immediate medical/mental health referral. Policy statement (e) availability of cardiopulmonary resuscitation Policy 614 Use of Physical Restraints ☒ ☐ ☐ equipment. Procedure #3 (f) protective housing of restrained youth. While in Policy 614 Use of Physical Restraints restraint devices, all youth shall be housed alone or ☒ ☐ ☐ Procedure #5 in a specified housing area for restrained youth which makes provision to protect the youth from abuse. (g) provision for hydration and sanitation needs. Policy 614 Use of Physical Restraints ☒ ☐ ☐ Policy statement (h) exercising of extremities. Policy 614 Use of physical restraints ☒ ☐ ☐ Policy statement 7293 Marin County JH PRO 20-22 - 37 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS 1358.5 USE OF RESTRAINT DEVICES FOR Policy 502 Transportation Policy MOVEMENT AND TRANSPORTATION WITHIN Policy 502 Transportation Policy contains THE FACILITY. the elements for the minimum standards for this regulation ☒ ☐ ☐ 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 Policy 502 Transportation Policy approved to utilize restraint devices and the ☒ ☐ ☐ Procedure for movement within facility required training. Section (a) (b) the circumstances leading to the application of Policy 502 Transportation Policy: Procedure restraints must be documented. ☒ ☐ ☐ for movement with the facility Section (b) (c) an individual assessment of the need to apply Policy 502 Transportation Policy: Procedure restraints for movement or transportation that for movement within the facility includes consideration of less restrictive ☒ ☐ ☐ Section (c) alternatives, consideration of a youth’s known medical or mental health conditions, trauma informed approaches, and a process for documentation and supervisor review and approval. (d) consideration of safety and security of the facility, Policy 502: Transportation Policy: Procedure with a clearly defined expectation that restraint ☒ ☐ ☐ for movement within the facility. devices shall not be used for the purposes of Section (d) discipline or retaliation. (e) the use of restraints on pregnant youth is limited in Policy 502: Transportation Policy: Procedure accordance with Penal Code Section6030(f) and ☒ ☐ ☐ for movement within the facility Welfare and Institutions Code Section 222. Section (e) 1359 SAFETY ROOM PROCEDURES Policy 613 Use of Safety Room (a) The facility administrator, and where applicable, in Policy 613 Policy Section cooperation with the responsible physician, shall Policy 613 Use of Safety Room contains the develop and implement written policies and elements for the minimum standards for this procedures governing the use of safety rooms, as regulation. described in Title 24, Part 2, Section 1230.1.13. The room shall be used to hold only those youth who ☒ ☐ ☐ According to MCJH, there were no incidents present an immediate danger to themselves or that resulted in the use of a Safety Room. others, who exhibit behavior which results in the destruction of property, or reveals the intent to cause self-inflicted physical harm. A safety room shall not be used for punishment or discipline, or as a substitute for treatment. Policies and procedures shall: 7293 Marin County JH PRO 20-22 - 38 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS (1) include provisions for administration of Policy 613 Policy Section ☒ ☐ ☐ necessary nutrition and fluids, access to a toilet, and suitable clothing to provide for privacy; (2) provide for approval of the facility manager, or Policy 613 Policy Section ☒ ☐ ☐ designee, before a youth is placed into a safety room; (3) provide for continuous direct visual supervision Policy 613 Use of Safety Room and documentation of the youth's behavior and ☒ ☐ ☐ Procedure #3-4 any staff interventions every 15 minutes, with actual time recorded; (4) provide that the youth shall be evaluated by the Policy 613 Use of Safety Room facility manager, or designee, every four hours; ☒ ☐ ☐ Procedure #6 (5) provide for immediate medical assessment, Policy 613 Use of Safety Room where appropriate, or an assessment at the next ☒ ☐ ☐ Procedure #8b. daily sick call; and, (6) provide a process for documenting the reason for Policy 613: Use of safety room placement, including attempts to use less ☒ ☐ ☐ Procedure 6 restrictive means of control, and decisions to continue and end placement. (b) The placement of a youth in the safety room shall be Policy 613 Use of Safety Room accomplished in accordance with the following: ☒ ☐ ☐ Procedure #1-8 (1) safety room shall not be used before other less Policy 613 Use of Safety Room restrictive options have been attempted and ☒ ☐ ☐ Definition exhausted, unless attempting those options poses a threat to the safety or security of any youth or staff. (2) safety room shall not be used for the purposes of Policy 613 Use of Safety Room punishment, coercion, convenience, or ☒ ☐ ☐ Definition retaliation by staff. (3) safety room shall not be used to the extent that it Policy 613 Use of Safety Room compromises the mental and physical health of ☒ ☐ ☐ Definition the youth. (c) A youth may be held up to four hours in the safety Policy 613 Use of Safety Room room. After the youth has been held in the safety ☒ ☐ ☐ Procedure #5 bullets room for a period of four hours, staff shall do one or more of the following: (1) return the youth to general population. Policy 613 Use of Safety Room ☒ ☐ ☐ Procedure #5 bullets (2) consult with mental health or medical staff, Policy 613 Use of Safety Room ☒ ☐ ☐ Procedure #5 bullets (3) develop an individualized plan that includes the Policy 613 Use of Safety Room goals and objectives to be met in order to ☒ ☐ ☐ Procedure #5 bullets reintegrate the youth to general population. 7293 Marin County JH PRO 20-22 - 39 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS (d) If confinement in the safety room must be extended Policy 613 Use of Safety Room beyond four hours, staff shall develop an Procedure #5 bullets individualized plan that includes the requirements ☒ ☐ ☐ of Section 1354.5 and the goals and objectives to be met in order to integrate the youth to general population. 1360 SEARCHES Policy 408 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 safety and Policy 408 Searches security of the facility, public, visitors, youth, and ☒ ☐ ☐ Policy statement staff. (b) Searches shall be conducted in a manner that Policy 408 Searches preserves the privacy and dignity of the person ☒ ☐ ☐ Strip Search Procedure #1-11 being searched and shall not be conducted for harassment or as a form of discipline or punishment. (c) Strip searches and visual or physical body cavity Policy 408 Searches searches shall comply with Penal Code Section Strip Search Procedure #1-11 and Body 4030. Cavity Search statement. During this inspection cycle (2020/ 2022), ☒ ☐ ☐ (2) strip searches occurred. We reviewed the Incident Reports involving those strip searches. In review, the procedures taken show MCJH follows the minimum standards of this regulation. (d) Physical body cavity searches shall only be Policy 408 Searches conducted by a medical professional. ☒ ☐ ☐ Body Cavity Search policy statement (e) Any youth held after a detention hearing shall only Policy 408 Searches be strip searched with prior approval of a supervisor Policy statement when there is reasonable suspicion based on ☒ ☐ ☐ specific and articulable facts to believe that youth is concealing contraband. The reasonable suspicion shall be documented. (f) Searches of transgender and intersex youth shall Policy 408 Searches comply with Section 1352.5. ☒ ☐ ☐ Policy statement (g) Cross-gender pat-down searches and strip searches Policy 408 Searches are prohibited except in exigent circumstances or ☒ ☐ ☐ Policy statement when conducted by a medical professional. Such searches must be justified and documented in writing. 7293 Marin County JH PRO 20-22 - 40 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS 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 Policy statement #1 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 a Policy 431: Minor’s Information on grievance, which includes provisions for the youth ☒ ☐ ☐ Grievances to have free access to the form; Policy statement #1 (b) the youth shall have the option to confidentially file Policy 431 Minor’s Information on the grievance or to deliver the form to any youth ☒ ☐ ☐ Grievances supervision staff working in the facility; Policy statement #1 (c) resolution of the grievance at the lowest appropriate Policy 431 Minor’s Information on staff level; Grievances Policy statement #2 To ensure resolution of the grievance at the ☒ ☐ ☐ lowest level, we provided Technical Assistance recommending that MCJH update their grievance form to include a staff response section for the staff person being grieved against. (d) provision for a prompt review and initial response Policy 431 Minor’s Information on to grievances within three (3) business days, ☒ ☐ ☐ Grievances grievances that relate to health and safety issues Policy statement #1 must be addressed immediately; (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 procedure #1 directly involved in the circumstances which led to the grievance. (2) Provision for a staff representative approved by Policy 431: Minor’s Information Procedure ☒ ☐ ☐ the facility administrator to assist the youth. #1 (e) provision for a written response to the grievance ☒ ☐ ☐ Policy 431: Procedure #3 which includes the reasons for the decisions; (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 County JH PRO 20-22 - 41 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS (g) resolution of the grievance must occur within ten Policy 431 Minor’s Information on (10) business days unless circumstances dictate a ☒ ☐ ☐ Grievances longer time frame. The youth shall be notified of Policy statement #1 any delay; and, (h) the policy shall provide multiple internal and Policy 431 Minor’s Information on external methods to report sexual abuse and sexual ☒ ☐ ☐ Grievances 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. 1362 REPORTING OF INCIDENTS Policy 425 Incident Reports A written report of all incidents which result in physical In review of multiple Incident Reports, harm, use of force, serious threat of physical harm, or including but not limited to, Use of Force death of an employee, youth or other person(s) shall be ☒ ☐ ☐ and Use of Physical Restraints, MCJH staff maintained. Such written record shall be prepared by the report incidents according to regulation and staff and submitted to the facility manager by the end of meets minimum standards. the shift, unless additional time is necessary and authorized by the facility manager or designee. 1363 USE OF REASONABLE FORCE TO Policy 473 Use of Force to Collect DNA COLLECT DNA SPECIMENS, SAMPLES, Specimens, Samples or Impressions IMPRESSIONS Use of force to gather specimens is (a) Pursuant to Penal Code Section 298.1 authorized prohibited. law enforcement, custodial, or corrections personnel including peace officers, may employ ☐ ☐ ☒ reasonable force to collect blood specimens, saliva samples, and thumb or palm print impressions from individuals who are required to provide such samples, specimens or impressions pursuant to Penal Code Section 296 and who refuse following written or oral request. (1) For the purpose of this section, the “use of reasonable force” shall be defined as the force that an objective, trained and competent ☐ ☐ ☒ correctional employee, faced with similar facts and circumstances, would consider necessary and reasonable to gain compliance with this section. (2) The use of reasonable force shall be preceded by efforts to secure voluntary compliance. Efforts to secure voluntary compliance shall be ☐ ☐ ☒ documented and include an advisement of the legal obligation to provide the requisite specimen, sample or impression and the consequences of refusal. 7293 Marin County JH PRO 20-22 - 42 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS (b) The force shall not be used without the prior written authorization of the supervising officer on duty. The authorization shall include information that ☐ ☐ ☒ reflects the fact that the offender was asked to provide the requisite specimen, sample, or impression and refused. (1) If the use of reasonable force includes a cell extraction, the extraction shall be videotaped. Video shall be directed at the cell extraction event. The videotape shall be retained by the ☐ ☐ ☒ agency for the length of time required by statute. Notwithstanding the use of the video as evidence in a court proceeding, the tape shall be retained administratively. 1370 EDUCATION PROGRAM Policy 436: School Program (a) School Programs Section (a) The County Board of Education shall provide for the 2020: No inspection occurred. administration and operation of juvenile court schools in conjunction with the Chief Probation Officer, or designee 2021: Completed in November 2021 by, Alternative Education Consultant, Lisa pursuant to applicable State laws. The school and facility Schwartz. administrators shall develop and implement written Mrs. Schwartz completed the Juvenile policy and procedures to ensure communication and Facility Education Program Review and coordination between educators and probation staff. Evaluation form. Schwartz indicated Culturally responsive and trauma-informed approaches minimum standards were met. should be applied when providing instruction. Education staff should collaborate with the facility administrator to We provided Technical Assistance to suggest use technology to facilitate learning and ensure safe that if a physical inspection cannot occur, at ☒ ☐ ☐ technology practices. The facility administrator shall a minimum, have the local agency perform a request an annual review of each required element of the virtual and or a desk audit in lieu of the program by the Superintendent of Schools, and a report inspection. or review checklist on compliance, deficiencies, and corrective action needed to achieve compliance with this section. Such a review, when conducted, cannot be delegated to the principal or any other staff of any juvenile court school site. The Superintendent of Schools shall conduct this review in conjunction with a qualified outside agency or individual. Upon receipt of the review, the facility administrator or designee shall review each item with the Superintendent of Schools and shall take whatever corrective action is necessary to address each deficiency and to fully protect the educational interests of all youth in the facility. 7293 Marin County JH PRO 20-22 - 43 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS (b) Required Elements Policy 436 School Program: Section (b) The facility school program shall comply with the State Education Code and County Board of Education policies, all applicable federal education statutes and regulations and provide for an annual evaluation of the educational program offerings. As stated in the 2009 California ☒ ☐ ☐ Standards for the Teaching Profession, teachers shall establish and maintain learning environments that are physically, emotionally, and intellectually safe. Youth shall be provided a rigorous, quality educational program that responds to the different learning styles and abilities of students and prepares them for high school graduation, career entry, and post-secondary education. All youth shall be treated equally, and the education Policy 436 School Program Section (b) program shall be free from discriminatory action. Staff ☒ ☐ ☐ shall refer to transgender, intersex and gender- nonconforming youth by their preferred name and gender. (1) The course of study shall comply with the State Policy 436: School Program Section (b) (1) ☒ ☐ ☐ Education Code and include, but not be limited to, courses required for high school graduation. (2) Information and preparation for the High School Policy 436: School Program Section (b) (2) Equivalency Test as approved by the California ☒ ☐ ☐ Department of Education shall be made available to eligible youth. (3) Youth shall be informed of post-secondary ☒ ☐ ☐ Policy 436: School Program Section (b) (3) education and vocational opportunities. (4) Administration of the High School Equivalency Policy 436: School Program Section (b) (4) Tests as approved by the California Department ☒ ☐ ☐ of Education, shall be made available when possible. (5) Supplemental instruction shall be afforded to Policy 436: School Program Section (b) (5) ☒ ☐ ☐ youth who do not demonstrate sufficient progress towards grade level standards. (6) The minimum school day shall be consistent with Policy 436: School Program Section (b) (6) State Education Code Requirements for juvenile court schools. The facility administrator, in conjunction with education staff, must ensure ☒ ☐ ☐ that operational procedures do not interfere with the time afforded for the minimum instructional day. Absences, time out of class or educational instruction, both excused and unexcused, shall be documented. 7293 Marin County JH PRO 20-22 - 44 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS (7) Education shall be provided to all youth Policy 436: School Program Section (b) (7) regardless of classification, housing, security status, disciplinary or separation status, including room confinement, except when ☒ ☐ ☐ providing education poses an immediate threat to the safety of self or others. Education includes, but is not limited to, related services as provided in a youth’s Section 504 Plan or Individualized Education Program (IEP). (c) School Discipline Policy 436: School Program Section (c) (1) (1) Positive behavior management will be implemented to reduce the need for disciplinary ☒ ☐ ☐ action in the school setting and be integrated into the facility's overall behavioral management plan and security system. (2) School staff shall be advised of administrative Policy 436: School Program Section (c) (2) ☒ ☐ ☐ decisions made by probation staff that may affect the educational programming of students. (3) Except as otherwise provided by the State Policy 436: School Program Section (c) (3) Education Code, expulsion/suspension from school shall be imposed only when other means of correction fails to bring about proper conduct. School staff shall follow the appropriate due ☒ ☐ ☐ process safeguards as set forth in the State Education Code including the rights of students with special needs. School staff shall document the other means of correction used prior to imposing expulsion/ suspension if an expulsion/suspension is ultimately imposed. (4) The facility administrator, in conjunction with Policy 436: School Program Section (c) (4) education staff will develop policies and ☒ ☐ ☐ procedures that address the rights of any student who has continuing difficulty completing a school day. (d) Provisions for Special Populations Policy 436: School Program Section (d) (1) (1) State and federal laws and regulations shall be observed for all individuals with disabilities or suspected disabilities. This includes but is not ☒ ☐ ☐ limited to child find, assessment, continuum of alternative placements, manifestation determination reviews, and implementation of Section 504 Plans and Individualized Education Programs. (2) Youth identified as English Learners (EL) shall Policy 436: School Program Section (d) (2) be afforded an educational program that ☒ ☐ ☐ addresses their language needs pursuant to all applicable state and federal laws and regulations governing programs for EL students. 7293 Marin County JH PRO 20-22 - 45 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS (e) Educational Screening and Admission Policy 436: School Program Section (e) (1) ☒ ☐ ☐ (1) Youth shall be interviewed after admittance and a record maintained that documents a youth's educational history, including but not limited to: (A) School progress/school history; ☒ ☐ ☐ Policy 436: School Program Section (A) (B) Home Language Survey and the results of Policy 436: School Program Section (B) ☒ ☐ ☐ the State Test used for English language proficiency; (C) Needs and services of special populations as Policy 436: School Program Section (C) defined by the State Education Code, ☒ ☐ ☐ including but not limited to, students with special needs. (D) Discipline problems. ☒ ☐ ☐ Policy 436: School Program Section (D) (2) Youth will be immediately enrolled in school. Policy 436: School Program Section (D)(2) Educational staff shall conduct an assessment to ☒ ☐ ☐ determine the youth's general academic functioning levels to enable placement in core curriculum courses. (3) After admission to the facility, a preliminary Policy 436: School Program Section (D) (3) ☒ ☐ ☐ education plan shall be developed for each youth within five school days. (4) Upon enrollment, education staff shall comply Policy 436: School Program Section (D) (4) with the State Education Code and request the youth's records from his/her prior school(s), including, but not limited to, transcripts, Individual Education Program (IEP), 504 Plan, ☒ ☐ ☐ state language assessment scores, immunization records, exit grades, and partial credits. Upon receipt of the transcripts, the youth's educational plan shall be reviewed with the youth and modified as needed. Youth should be informed of the credits they need to graduate. (f) Educational Reporting Policy 436: School Program: Section (f) (1) (1) The complete facility educational record of the ☒ ☐ ☐ youth shall be forwarded to the next educational placement in accordance with the State Education Code. (2) The County Superintendent of Schools shall Policy 436: School Program: Section (f) (2) provide appropriate credit (full or partial) for ☒ ☐ ☐ course work completed while in juvenile court school in accordance with the State Education Code. 7293 Marin County JH PRO 20-22 - 46 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS (g) Transition and Re-Entry Planning Policy 436: School Program: Section (g) (1) (1) The Superintendent of Schools and the Chief Probation Officer or designee, shall develop policies and procedures to meet the transition ☒ ☐ ☐ needs of youth, including the development of an education transition plan, in accordance with the State Education Code and in alignment with Title 15, Minimum Standards for Juvenile Facilities, Section 1355. (h) Post-Secondary Education Opportunities Policy 436: School Program: Section (h) (1) (1) The school and facility administrator should, whenever possible, collaborate with local post- ☒ ☐ ☐ secondary education providers to facilitate access to educational and vocational opportunities for youth that considers the use of technology to implement these programs. 1371 PROGRAMS, RECREATION, AND Policy 444 Recreation and Exercise Program EXERCISE. Through Technical Assistance, we recommended that MCJH develop a more detailed format for documentation of The facility administrator shall develop and implement programming, exercise, and recreation for written policies and procedures for programs, recreation, and exercise for all youth. The intent is to ☒ ☐ ☐ the youth. For example, “Open rec” does not indicate what programming may have minimize the amount of time youth are in their rooms occurred. In addition, documentation should or their bed area. include which youth Self Separated in his/her room and, as a result, did not participate in programming, recreation, or exercise. 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 ☒ ☐ ☐ Policy statement #1 Saturday, Sunday or other non-school days, of which 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 Policy statement #3 represents a threat to the safety and security of the facility. Such program, recreation, and exercise schedule shall Policy 444: Programs Recreation and be posted in the living units. ☒ ☐ ☐ Exercise Program Policy statement #4 7293 Marin County JH PRO 20-22 - 47 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS 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 On April 8, 2022, Superintendent Tori relevant to the population. ☒ ☐ ☐ Creighton 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 Exercise Program programming to include, but not be limited to, Section (a) trauma focused, cognitive, evidence-based, best practice interventions that are culturally relevant and linguistically appropriate, or pro-social interventions and activities designed to reduce recidivism. These programs should be based on the youth’s individual ☒ ☐ ☐ needs as required by Sections 1355 and 1356. Such programs may be provided under the direction of the Chief Probation Officer or the County Office of Education and can be administered by county partners such as mental health agencies, community based organizations, faith-based organizations or Probation staff. Programs may include but are not limited to: (1) Cognitive Behavior Interventions; Policy 444: Programs Recreation and (2) Management of Stress and Trauma; Exercise Program (3) Anger Management; Section (a) (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. (b) Recreation. All youth shall be provided the Policy 444 Recreation and Exercise Program opportunity for at least one hour of daily access to Policy Guidelines unscheduled activities such as leisure reading, letter ☒ ☐ ☐ writing, and entertainment. Activities shall be supervised and include orientation and may include coaching of youth. 7293 Marin County JH PRO 20-22 - 48 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS (c) Exercise. All youth shall be provided with the Policy 444 Recreation and Exercise Program opportunity for at least one hour of large muscle ☒ ☐ ☐ Policy Guidelines activity each day. The administrator/manager may suspend, for a period not Policy 444: Recreation and Exercise to exceed 24 hours, access to recreation and programs. ☒ ☐ ☐ Program Policy Exception #4 The administrator/manager shall document the reasons why suspension of recreation and programs occurs. 1372 RELIGIOUS PROGRAM Policy 303 Religion The facility administrator shall provide access to Youth wishing not to participate in Religious religious services and/or religious counseling at least Services are allowed to participate in an once each week. Attendance shall be voluntary. A youth ☒ ☐ ☐ activity outside of their room. shall be allowed to participate in an activity outside of their room if he/she elects not to participate in religious programs. Religious programs shall provide for: (a) opportunity for religious services and practices; Policy 303 Religion ☒ ☐ ☐ Religious Services #1-4 (b) availability of clergy; and, Policy 303 Religion ☒ ☐ ☐ Religious Counseling #1-4 (c) availability of religious diets. Policy 303 Religion ☒ ☐ ☐ Religious Diets #1-2 1373 WORK PROGRAM Policy 464: Detainee Labor Conditions and Restrictions The facility administrator shall develop policies and procedures regarding the fair and consistent assignment MCJH does not currently have a Work of youth to work programs. Work assigned to a youth ☒ ☐ ☐ Program. shall be meaningful, constructive and related to vocational training or increasing a youth's sense of responsibility. Work programs shall not be imposed as a disciplinary measure 1374 VISITING Policy 456 Visiting Policy The facility administrator shall develop and implement We reviewed the visiting schedule, written policies and procedures for visiting, that include interviewed youth and staff to determine that provisions for special visits. Youth shall be allowed to MCJH follow compliance with the minimum receive visits by parents, guardians or persons standing standards for this regulation. ☒ ☐ ☐ in loco parentis, and children of youth. Other family members, such as grandparents and siblings, and supportive adults, may be allowed to visit with the approval of the facility administrator or designee, and in conjunction with the youth’s case plan or in the best interest of the youth. 7293 Marin County JH PRO 20-22 - 49 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS All visits shall occur at reasonable times, subject only to Policy 456 Visiting Policy the limitations necessary to maintain order and security. Authorization Process: Visitation shall not be denied solely based on the visitor’s criminal history. The staff shall determine in each case, ☒ ☐ ☐ whether the visitor’s criminal history represents a risk to the safety of 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 Policy 456 Visiting Policy hours per week. Visits may be supervised, but ☒ ☐ ☐ Policy statement conversations shall not be monitored unless there is a security or safety need. Provisions for special visits, in addition to the two-hour Policy 456 Visiting Policy minimum and/or outside of the regular visiting hours, Definition statement shall be accommodated as necessary and within the discretion of the facility administrator or designee. ☒ ☐ ☐ Family therapy and professional visits shall be accommodated outside the provisions of this regulation. Facilities may provide visitation opportunities outside of normal visiting hours to accommodate special visits. The facility may provide access to technology as an Policy 456 Visiting Policy alternative, but not as a replacement, to in-person ☒ ☐ ☐ Policy statement visiting. 1375 CORRESPONDENCE Policy 453 Correspondence- Mail Policy The facility administrator shall develop and implement ☒ ☐ ☐ Through interviews with youth and staff, it written policies and procedures for correspondence was determined that MCJH follow Title 15 which provide that: minimum standards for this regulation. (a) there is no limitation on the volume of mail that youth Policy 453 Correspondence- Mail Policy ☒ ☐ ☐ may send or receive; Guidelines #1 (b) youth may send two letters per week postage free; Policy 453 Correspondence- Mail Policy ☒ ☐ ☐ Guidelines #1 (c) youth may correspond confidentially with state and Policy 453 Correspondence- Mail Policy federal courts, any member of the State Bar or holder Guidelines #2 of public office, and the Board; however, authorized ☒ ☐ ☐ facility staff may open and inspect such mail only to search for contraband and in the presence of the youth; and, (d) incoming and outgoing mail, other than that described Policy 453 Correspondence- Mail Policy in (c), may be read by staff only when there is Guidelines #3 ☒ ☐ ☐ reasonable cause to believe facility safety and security, public safety, or youth safety is jeopardized. 1376 TELEPHONE ACCESS Policy 457 Phone call for Detainees The administrator of each juvenile facility shall develop ☒ ☐ ☐ Through interviews with youth and staff, it and implement written policies and procedures to was determined that MCJH follow Title 15 provide youth with access to telephone communications. minimum standards for this regulation. 7293 Marin County JH PRO 20-22 - 50 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS 1377 ACCESS TO LEGAL SERVICES Policy 453: Correspondence Policy statement The facility administrator shall develop written ☒ ☐ ☐ procedures to ensure the right of youth to have access to Through interviews with youth and staff, it the courts and legal services. Such access shall include: was determined that MCJH follow Title 15 minimum standards for this regulation. (a) access, upon request by the youth, to licensed Policy 453: Correspondence ☒ ☐ ☐ attorneys and their authorized representatives; Policy Statement (b) provision for confidential consultation with Policy 453: Correspondence ☒ ☐ ☐ attorneys; and, Policy Statement (c) unlimited postage free, legal correspondence and 453: Policy Correspondence ☒ ☐ ☐ cost-free telephone access as appropriate. Policy Statement 1390 DISCIPLINE Policy 445 Discipline Guidelines The facility administrator shall develop and implement In reviewing Incident Reports, and written policies and procedures for the discipline of interviews with youth in custody, MCJH is youth that shall promote acceptable behavior; including compliant with minimum standards for this the use of positive behavior interventions and supports. ☒ ☐ ☐ regulation. Discipline shall be imposed at the least restrictive level which promotes the desired behavior and shall not include corporal punishment, group punishment, physical or psychological degradation. Deprivation of the following is not permitted: (a) bed and bedding; ☒ ☐ ☐ Policy 445 Discipline Guidelines A. (b) daily shower, access to drinking fountain, toilet and Policy 445 Discipline Guidelines B. ☒ ☐ ☐ personal hygiene items, and clean clothing; (c) full nutrition; ☒ ☐ ☐ Policy 445 Discipline Guidelines C. (d) contact with parent or attorney; ☒ ☐ ☐ Policy 445 Discipline Guidelines D. (e) exercise; ☒ ☐ ☐ Policy 445 Discipline Guidelines E. (f) medical services and counseling; ☒ ☐ ☐ Policy 445 Discipline Guidelines F. (g) religious services; ☒ ☐ ☐ Policy 445 Discipline Guidelines G. (h) clean and sanitary living conditions; ☒ ☐ ☐ Policy 445 Discipline Guidelines H. (i) the right to send and receive mail; ☒ ☐ ☐ Policy 445 Discipline Guidelines I. (j) education; and, ☒ ☐ ☐ Policy 445 Discipline Guidelines J. (k) rehabilitative programming. ☒ ☐ ☐ Policy 445 Discipline Guidelines K The facility administrator shall establish rules of conduct Policy 445 Discipline Guidelines and disciplinary penalties to guide the conduct of youth. Such rules and penalties shall include both major violations and minor violations, be stated simply and ☒ ☐ ☐ affirmatively, and be made available to all youth. Provision shall be made to provide accessible information to youth with disabilities, limited English proficiency, or limited literacy. 1391 DISCIPLINE PROCESS Policy 445: Discipline Guidelines The facility administrator shall develop and implement ☒ ☐ ☐ written policies and procedures for the administration of discipline which shall include, but not be limited to: 7293 Marin County JH PRO 20-22 - 51 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS (a) designation of personnel authorized to impose Policy 445: Discipline Guidelines Section (a) ☒ ☐ ☐ discipline for violation of rules; (b) prohibiting discipline to be delegated to any youth; ☒ ☐ ☐ Policy 445: Discipline Guidelines Section (b) (c) definition of major and minor rule violations and Policy 445: Discipline Guidelines Section ☒ ☐ ☐ their consequences, and due process requirements; (C) (d) trauma-informed approaches and positive behavior Policy 445: Discipline Guidelines Section ☒ ☐ ☐ interventions; (d) (e) minor rule violations may be handled informally by Policy 445: Discipline Guidelines Section counseling, advising the youth of expected conduct (e) imposing a minor consequence. Discipline shall be ☒ ☐ ☐ accompanied by written documentation and a policy of review and appeal to a supervisor; and, (f) major rule violations and the discipline process Policy 445: Discipline Guidelines Section (f) shall be documented and require the following: Review of the facility’s incentive program and documentation showing the discipline ☒ ☐ ☐ for major rule violations by youth, MCJH is in compliance with the minimum standards for this regulation. (1) written notice of violation prior to a hearing; Policy 445: Discipline Guidelines Section e) (1) We reviewed (7) “Written Notice to the ☒ ☐ ☐ Minor” Due Process forms. In review of the documentation, MCJH show compliance with the minimum standards of the regulation. (2) accommodations provided to youth with Policy 445: Discipline Guidelines Section disabilities, limited literacy, and English ☒ ☐ ☐ (f) (2) language learners; (3) hearing by a person who is not a party to the Policy 445: Discipline Guidelines Section ☒ ☐ ☐ incident; (f)(3) (4) opportunity for the youth to be heard, present Policy 445: Discipline Guidelines Section ☒ ☐ ☐ evidence and testimony; (f) (4) (5) provision for youth to be assisted by staff in the Policy 445: Discipline Guidelines Section ☒ ☐ ☐ hearing process; (f) (5) (6) provision for administrative review. Policy 445: Discipline Guidelines Section ☒ ☐ ☐ (f) (6) (g) violations that result in a removal from camp or Policy 445: Discipline Guidelines Section commitment program, but not a return to court, will (f)(g) ☒ ☐ ☐ follow the due process provisions in subsection (e) above. 7293 Marin County JH PRO 20-22 - 52 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS 1410 MANAGEMENT OF COMMUNICABLE Policy 621: Notification of Contagious DISEASES. Diseases to Superintendent Policy Statement The health administrator/responsible physician, in cooperation with the facility administrator and the local ☒ ☐ ☐ health officer, shall develop written policies and procedures to address the identification, treatment, control and follow-up management of communicable diseases. The policies and procedures shall address, but not be limited to: (a) Intake health screening procedures; Policy 621: Notification of Contagious Diseases to Superintendent, (Intake ☒ ☐ ☐ Procedures Tied to COVID-19) (b) Identification of relevant symptoms; Policy 621: Notification of Contagious ☒ ☐ ☐ Diseases to Superintendent, (c) Referral for medical evaluation; Policy 621: Notification of Contagious ☒ ☐ ☐ Diseases to Superintendent, (d) Treatment responsibilities during detention; Policy 621: Notification of Contagious ☒ ☐ ☐ Diseases to Superintendent, (e) Coordination with public and private community- Policy 706.2, Communicable Diseases- ☒ ☐ ☐ based resources for follow-up treatment; Minors (f) Applicable reporting requirements; and, Policy 706.2, Communicable Diseases- ☒ ☐ ☐ Minors (g) Strategies for handling disease outbreaks. Policy 706.2, Communicable Diseases- ☒ ☐ ☐ Minors The policies and procedures shall be updated as Policy 706.2, Communicable Diseases- necessary to reflect communicable disease priorities Minors ☒ ☐ ☐ identified by the local health officer and currently recommended public health interventions. 1433 REQUESTS FOR HEALTH CARE Policy 435, Sick Call Policy/Removal from SERVICES (EXCERPT) School The health administrator, in cooperation with the In providing Technical Assistance, we facility administrator, shall develop policy and ☒ ☐ ☐ recommended that MCJH place a secured procedures to establish a daily routine for youth to lock box in the facility dayroom to allow convey requests for emergency and non-emergency youth to confidentially make medical and medical, dental and behavioral/mental health care mental health request. services. 1480 STANDARD FACILTY CLOTHING ISSUE Policy 459, Clothing Issue and Exchange 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: 7293 Marin County JH PRO 20-22 - 53 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS (a) Clothing is clean, reasonably fitted, durable, easily Policy 459, Clothing Issue and Exchange laundered, in good repair, and free of holes and ☒ ☐ ☐ tears. (b) The standard issue of climatically suitable clothing Policy 459, Clothing Issue and Exchange ☒ ☐ ☐ for youth shall consist of but not be limited to: (1) Socks and serviceable footwear; ☒ ☐ ☐ Policy 459, Clothing Issue and Exchange (2) Outer garments; ☒ ☐ ☐ Policy 459, Clothing Issue and Exchange (3) New non-disposable underwear which shall Policy 459, Clothing Issue and Exchange remain with the youth throughout their stay, ☒ ☐ ☐ and; (4) Undergarments, that are freshly laundered and Policy 459, Clothing Issue and Exchange ☒ ☐ ☐ free of stains, including tee shirts and bras. (c) Clothing is laundered at the temperature required by Policy 459, Clothing Issue and Exchange local ordinances for the commercial laundries and dried completely in a mechanical dryer or other ☒ ☐ ☐ laundry method approved by the local health officer. (d) Suitable clothing is issued to pregnant youth. ☒ ☐ ☐ 1482 CLOTHING EXCHANGE Policy 459, Clothing Issue and Exchange The facility administrator shall develop and implement written policies and site-specific procedures for the cleaning and scheduled exchange of clothing. Unless ☒ ☐ ☐ work, climatic conditions, or illness necessitates more frequent 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. 1484 CONTROL OF VERMIN IN YOUTH’S Policy 499, Control of Vermin in Minors’ PERSONAL CLOTHING Personal Clothing There shall be written policies and site-specific procedures developed and implemented by the facility ☒ ☐ ☐ administrator to control the contamination and/or spread of vermin and ecto-parasites in all youth’s personal clothing. Infested clothing shall be cleaned or stored in a closed container so as to eradicate or stop the spread of the vermin. 1485 ISSUE OF PERSONAL CARE ITEMS Policy 401, Issuing of Personal hygiene Items to Minors There shall be written policies and site-specific procedures developed and implemented by the facility administrator for the availability of personal 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; (a) Toothbrush; Policy 401, Issuing of Personal hygiene ☒ ☐ ☐ Items to Minors 7293 Marin County JH PRO 20-22 - 54 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS (b) Toothpaste; Policy 401, Issuing of Personal hygiene ☒ ☐ ☐ Items to Minors (c) Soap; Policy 401, Issuing of Personal hygiene ☒ ☐ ☐ Items to Minors (d) Comb; ☒ ☐ ☐ (e) Shaving implements; Policy 424 Hygiene/Showers, Shaving, and ☒ ☐ ☐ Razor Handling (f) Deodorant; Policy 401, Issuing of Personal hygiene ☒ ☐ ☐ Items to Minors (g) Lotion; Policy 401, Issuing of Personal hygiene ☒ ☐ ☐ Items to Minors (h) Shampoo; and, Policy 401, Issuing of Personal hygiene ☒ ☐ ☐ Items to Minors (i) Post-shower conditioning hair products. Policy 401, Issuing of Personal hygiene ☒ ☐ ☐ Items to Minors Youth shall not be required to share any personal care Policy 401, Issuing of Personal hygiene items listed in items (a) through (d). Liquid soap Items to Minors 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. 1486 PERSONAL HYGIENE Policy 401, Issuing of Personal hygiene Items to Minors There shall be written policies and site specific procedures developed and implemented by the facility administrator for showering/bathing and brushing of ☒ ☐ ☐ teeth. Youth shall be permitted to shower/bathe up on assignment to a housing unit and on a daily basis thereafter and given an opportunity to brush their teeth after each meal. 1487 SHAVING Policy 424 Hygiene/Showers, Shaving, and Razor Handling Youth shall have access to a razor daily, unless their appearance must be maintained for reasons of identification in Court. All youth shall have equal ☒ ☐ ☐ opportunity to shave face and body hair. The facility administrator may suspend this requirement in relation to youth who are considered to be a danger to themselves or others. 7293 Marin County JH PRO 20-22 - 55 - J453 JUV PRO-Eff. 01-01-2019 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS 1488 HAIR CARE SERVICES (Excerpt) Policy 424 Hygiene/Showers, Shaving, and Razor Handling Hair care services shall be available in all juvenile facilities. Youth shall receive hair care services ☒ ☐ ☐ monthly. Equipment shall be cleaned and disinfected after each haircut or procedure, by a method approved by the State Board of Barbering and Cosmetology. 1500 STANDARD BEDDING AND LINEN ISSUE Policy 459 Clothing Issue and Exchange Clean laundered, suitable bedding and linens, in good ☒ ☐ ☐ repair, shall be provided for each youth entering a living area who is expected to remain overnight, shall include, but not be limited to: (a) One mattress or mattress-pillow combination which Policy 459 Clothing Issue and Exchange meets the requirements of Section 1502 of these ☒ ☐ ☐ regulations; (b) One pillow and a pillow case unless provided for in ☒ ☐ ☐ (a) above; (c) One mattress cover and a sheet or two sheets; ☒ ☐ ☐ (d) One towel; and, ☒ ☐ ☐ (e) One blanket or more, up on request ☒ ☐ ☐ 1501 BEDDING LINEN EXCHANGE Policy 459 Clothing Issue and Exchange The facility administrator shall develop and implement site specific written policies and procedures for the scheduled exchange of laundered bedding and linen ☒ ☐ ☐ issued to each youth housed. Washable items such as sheets, mattress covers, pillow cases and towels shall be exchanged for clean replacement at least once each week. The covering blanket shall be cleaned or laundered once Policy 459 Clothing Issue and Exchange ☒ ☐ ☐ a month. 1510 FACILITY SANITATION, SAFETY AND Policy 499.3 Institution Sanitation, Safety MAINTENANCE and Maintenance Further evidence of compliance with this The facility administrator shall develop and implement regulation is supported with MCJH’s written policies and site-specific procedures for the compliance with the following Title 15 maintenance of an acceptable level of cleanliness, repair Regulations: and safety throughout the facility. The plan shall provide for a regular schedule of housekeeping tasks, ☒ ☐ ☐ • 131 County Inspection and equipment, including restraint devices, and physical Evaluation of Building and grounds plant maintenance and inspections to identify and • 1327 Emergency Procedures correct unsanitary or unsafe conditions or work • 1325 Fire Safety Plan practices in a timely manner. The use of chemicals shall be done in accordance to the product label and Safety Data Sheet which may include the use of Personal Protection Equipment (PPE). 7293 Marin County JH PRO 20-22 - 56 - J453 JUV PRO-Eff. 01-01-2019 REVIEW OF NON REGULATORY REQUIREMENTS GRANT FUNDING OR CODE REFERENCE YES NO N/A P/P REFERENCE - COMMENTS JUVENILE PROBATION AND CAMPS FUNDING (JPCF) (Camps Only) The programs/services identified on the JPCF – Camp Allocation Eligibility Form are being provided at the ☐ ☐ ☒ facility. (Refer to the JPCF Program Agreement, Attachment B) 208.5 WIC CONTACT BETWEEN PERSONS UNDER THE JUVENILE COURT AGES 19- 20 AND MINORS IN THE FACILITY The facility houses Juvenile Court Wards 19 years of ☐ ☒ ☐ age and older. The facility has been approved to hold persons under ☐ ☐ ☐ the juvenile court who are ages 19 through 21. The facility continues to comply with the requirements of 208.5 WIC (programming, capacity and security of ☒ ☐ ☐ the facility) as outlined in the county’s application. JUVENILE JUSTICE DELINQUENCY PREVENTION ACT MONITORING (JJDPA) WIC 206 SEPARATE FACILITIES FOR WIC 300 MINORS Dependent or neglected minors who are defined under ☐ ☐ ☒ Section 300 of the Welfare and Institutions Code Violation (WIC) are held only in non-secure, separate and segregated facilities. DETENTION OF STATUS OFFENDERS (WIC 601) AND FEDERAL MINORS ☐ ☒ ☐ Status Offenders (WIC 601) are held in the facility. Status Offenders (WIC 601) are kept separate from ☐ ☐ ☒ Juvenile Delinquents (WIC 602)? (WIC 207[d]). Violation Federal Minors (ICE Holds or ORR Contract) are held ☐ ☒ ☐ in the facility. If yes to the above, the Monthly Report on the Detention of Status Offenders/Federal Minors is ☒ ☐ ☐ submitted to the BSCC. WIC 208 SEPARATION OF MINORS AND ADULT INMATES (JJDPA 42 USC 5633, Sec 223, State Plans (a)[12]) Are adult inmates held in the facility? (When a person ☐ ☒ ☐ in detention is proceeding through the adult court, AND that person is 18 years of age or older that person is an adult inmate.) If adult inmates are held, they are appropriately ☒ ☐ ☐ separated from minors. Violation Adult inmates from an adult facility (e.g. inmate workers or “Scared Straight” programs) are not allowed ☐ ☐ ☒ in the facility in a manner that allows contact with Violation minors. 7293 Marin County JH PRO 20-22 - 57 - J453 JUV PRO-Eff. 01-01-2019 PHYSICAL PLANT EVALUATION STATE BOARD OF STATE & COMMUNITY CORRECTIONS - BIENNIAL INSPECTION JUVENILE HALLS, SPECIAL PURPOSE JUVENILE HALLS AND CAMPS APPLICABLE REGULATIONS: Pre-1998* California Code of Regulations (CCR) BSCC Code: 7293 FACILITY NAME: Marin County Juvenile Hall FACILITY TYPE: JH CONSTRUCTION/REMODEL DATE(S): Original construction in 1960's; remodel in 1996; 9 beds added 2002 IDENTIFY FACILITY PHYSICAL PLANT MODIFICATIONS SINCE 1992: Added new classroom, courtroom, and administration area in 1996; renovated outdoor exercise space and 9 beds added in 2002 under 1998 regulations FIELD REPRESENTATIVE: Craigus Thompson Sr. and Forrest Coleman DATE: June 8, 2022 Comments: No changes to the facility during the 2020/2022 inspection cycle. ARTICLE/SECTION YES NO N/A COMMENTS RECEPTION AREA (JH) Pre-98 regulations; court holding room in 1996 addition; a pre-booking area is also located in the  A. Holding Rooms: administrative area. 1. Contain 15 square feet per minor; 2. Have sufficient seating to accommodate the rated  capacity based on floor space; 3. Provide access to water closets and wash basins at  Access provided outside the holding room. a ratio of a 1:8; and 4. Provide access to drinking fountain.  Access provided outside the holding room. B. Provide access to telephone.  C. Provide access to private room(s) for interviews.  MEDICAL EXAM SPACE (JH & CAMP) The nurse’s office is also used for medical exams, locked pharmaceutical storage, and storage for  Space or room(s) afford privacy, are equipped to carry out other medical supplies. A separate, suitably routine examinations and emergency care and have equipped exam room should be considered in sufficient locked storage space for medical supplies. future for remodeling or construction. CAPACITY (CAMP)  The maximum number of minors does not exceed 100 unless there is a certificate of compliance to expand capacity up to 125 minors (WIC § 886 and 886.5). LIVING UNITS (JH AND SPJH) There are East, West, and North wings, each of  which hold 30 youth or less. A. Living units are designed to accommodate no more than 30 minors and contain: 1. Showers at a ratio of 1:6;  1998 regulations (applicable to the 9 beds that came online in 2002) require that a washbasin, 2. Washbasins at a ratio of 1:6;  toilet, and drinking fountain are available in each room. There are 4 additional pre-98 wet rooms. 3. Water closets at a ratio of 1:6 or water closet and  Central toilet area includes 8 showers, 7 one urinal for every 15 boys; and, * Issues on this checklist are from the Pre-1998 Title 15, Sections 4272 (Juvenile Halls and Special Purpose Juvenile Halls) and 4323 (camps and ranches). 7293 Marin County JH PHY 20-22 - 1 - J455 PHY Pre-98.dot (9/98) ARTICLE/SECTION YES NO N/A COMMENTS 4. Access to a drinking fountain by minors and staff. washbasins and 7 toilets.  BSCC recommended the removal of all towel holders within the facility shower areas. B. Doors of each sleeping room have a view panel 1998 regulations require that the view panels for (maximum of 144 square inches of shatter-proof glass  the 9 beds brought online in 2002 have a or plastic materials) that allows the visual supervision minimum of 144 square inches. of all parts of the room. C. Hallways in the detention living units are at least eight feet wide. If rooms are located on only one side, or if  room doors are staggered, hallways are at least six feet wide. SINGLE ROOMS (JH, SPJH & CAMP)  Contain a minimum of 500 cubic feet of air space and 63 cubic feet of floor space. DOUBLE ROOMS (JH, SPJH & CAMP)  Contain a minimum of 800 cubic feet of airspace and 100 square feet of floor space. DORMITORY SLEEPING AREAS (JH & CAMP)  Contain a minimum of 400 cubic feet of airspace and 50 square feet of floor space per minor. LOCKED SLEEPING ROOMS (JH, SPJH & CAMP) Contain an individual or combination drinking fountain,  wash basin and toilet, unless a communication system or procedure is in effect to give minor immediate access to these fixtures. PLUMBING FIXTURES (CAMP) The following plumbing fixtures are adjacent to each  sleeping area: A. Shower or bathtub at a ratio of 1:6; B. Washbasins at a ratio of 1:10;  C. Access to toilets at a ratio of 1:10 or toilet and one  urinal for every 15 boys; and, D. Access to a drinking fountain.  BEDS AND MATTRESSES (JH, SPJH & CAMP)  Beds and mattresses are: A. A least 30 inches wide and 76 inches long; B. Spaced at least 36 inches apart and at least 12 inches off  the floor; and, C. Mattresses are made of a fire-retardant material.  INTERVIEW ROOMS (JH, SPJH & CAMP)  A. There is one interview room for each detention unit in juvenile halls and special purpose juvenile halls. B. There is a private room suitably equipped for  conferences and interviews in each camp. 7293 Marin County JH PHY 20-22 - 2 - J455 PHY Pre-98.dot (9/98) ARTICLE/SECTION YES NO N/A COMMENTS LIGHTING (JH, SPJH & CAMP) There are at least 50 foot candles of illumination at desk  level and, at night, there is a maximum illumination of two foot candles at bed level in individual and multiple occupancy rooms. ACADEMIC CLASSROOM (JH & CAMP) Classroom space was measured by facility staff and reported to be 1415 square feet, with an Each classroom contains a minimum of 160 square feet with  additional classroom on the West (girls) Wing that a teacher's desk and work area, and a minimum of 28 square measures 310 feet and is used as needed for feet per student. Classrooms should be designed for no overflow. more than 15 students. DINING SPACE (JH & CAMP) The facility is designed to utilize a dining hall in a separate building on campus for low risk minors.  There is a minimum of 15 square feet of space for each However, at the time of the inspection, the person being fed at any given time. dayroom was being utilized for youth to complete all meals. PHYSICAL ACTIVITY SPACE (JH & CAMP) The outdoor recreation space was replaced with the 2002 addition and comes under the regulation A. There is indoor space consisting of at least 30 square  noted below (Section 460A.1.11). feet of clear space for each minor, which may be included in a day room, a recreational building, or a multipurpose space (gymnasium). B. There is outdoor and/or multipurpose (gymnasium) space consisting of:  1. No less than the equivalent of 90' X 100' outdoor and /or multipurpose space (gymnasium) for a facility with a capacity of 40 or less. 2. No less than the equivalent of 90' X 100' hardtop area and 260 X 260' field area and/or multipurpose  space (gymnasium) for a camp with a capacity of more than 40, and a juvenile hall with a capacity between 41 to 100 minors. 3. No less than the equivalent of two 90' X 100' hardtop area and 260 X 260' field area and/or  multipurpose space (gymnasium) for a camp with a capacity of more than 40 and a juvenile hall with a capacity in excess of 101 minors. B. Lighting is adequate for security and evening  recreational activities in camps. Physical Activity and Recreation Spaces (NA SPJH; There is a large paved exercise area that measures 1.11) approximately 110’ X 110’ plus an additional smaller paved exercise area that measures 68’ X 98: Facilities with a capacity of less than 41 minors have a  23’ for a total of 13,664 square feet of outdoor minimum of 9,000 square feet dedicated indoor- exercise area. outdoor space. 01: Facilities with a capacity of 40 minors or less have a Drinking fountain is in the outdoor exercise area minimum of 9000 square feet dedicated indoor-outdoor as required by Section 460A.2.3 space. 7293 Marin County JH PHY 20-22 - 3 - J455 PHY Pre-98.dot (9/98) ARTICLE/SECTION YES NO N/A COMMENTS 98: Facilities with a capacity of 41 to 100 minors have a minimum of 9,000 square feet dedicated indoor- outdoor space, plus a field area. The field area contains a minimum of one acre with a minimum dimension of  Facility capacity is less than 41 minors. 100 feet. 01: Facilities with a capacity of 41-274 minors have a minimum of 225 square feet of dedicated indoor- outdoor space per minor, up to 61,650 feet. 98: Facilities with a capacity over 100 minors have a minimum of 18,000 square feet dedicated indoor- outdoor space, plus a field area. The field area contains a minimum of one acre with a minimum dimension of  100 feet. 01: Facilities with a capacity of 275 or more minors have 61,650 square feet dedicated indoor-outdoor space, plus 145 square feet for each minor beyond 274 (up to a maximum of 87,120 square feet). 98: At least one half of the dedicated indoor-outdoor space  is a paved or "like" surface. 01: Changed from one-half to one-quarter of the space A portion of the dedicated physical activity and recreation  space is out-of-doors and is equipped and of a sufficient size to comply with Title 15, § 1371. 01: The required recreation area has no single dimension  less than 40 feet. Outdoor recreation area lighting allows for evening  activities and provides security. STORAGE SPACE (JH, SPJH & CAMP)  A. Each minor is provided 9 cubic feet of secure storage space for personal clothing and belongings. B. Camps shall have adequate space (12 square feet of  floor area is recommended) for bulk and activity storage equipment. MULTIPURPOSE SPACE OR ROOM (SPJH)  There is a multipurpose space or room that provides space for reception, dining, recreation, exercise and/or education. This room contains a minimum of: A. 30 square feet of clear floor space per minor in the  room; B. 10 feet by 20 feet floor dimensions; and,  C. 1600 cubic feet of air space with a minimum ceiling  height of eight feet. SPECIAL PURPOSE JH EXEMPTIONS Not a SPJH SPJHs are exempt from the following Pre-1998 Title 15 regulations:  a. Section 4272(b) Medical exam rooms b. Section 4272(m) Academic classrooms c. Section 4272(n) Dining space d. Section 4272(o) Physical activities space 7293 Marin County JH PHY 20-22 - 4 - J455 PHY Pre-98.dot (9/98) STATE BOARD OF STATE & COMMUNITY CORRECTIONS - BIENNIAL INSPECTION JUVENILE HALLS, SPECIAL PURPOSE HALLS AND CAMPS LIVING AREA SPACE EVALUATION BSCC Code: 7293 FACILITY: Marin County Juvenile Hall (MCJH) TYPE: JH RC: 40 FIELD REPRESENTATIVE: Craigus Thompson Sr. and Forrest Coleman DATE: June 8, 2022 Comments: No changes to the facility during the 2020/2022 inspection cycle. ROOMS EACH ROOM Unit Room Applicable # Each Room Total Size (L x W x H) or FIXTURES* COMMENTS Designation Type Standards Rooms # Beds RC RC Square/Cubic Feet T U W F S Court Holding Pre-1998 1 4 (4) 8.3' X 6.75' 6.5' bench; access to plumbing outside holding room; additional interview rooms also available; pre- booking space in administrative area. Room dimensions provided by facility staff, at the request of the BSCC, to update CYA data. Housing Single Pre-1998 17 1 1 17 11.25' X 7.5' North Wing - At the time of the inspection, the North wing housed COVID-19 protocol youth. All rooms North, East, Double Pre-1998 7 2 2 14 11.25' X 11.25' are dry rooms except for rooms D and E. and West wings West Wing – At the time of the inspection, the west wing housed female youth. All rooms are dry rooms except for rooms A and B. East Wing – At the time of the inspection, the east wing housed male youth. All rooms are dry rooms. South Wing Single 1998 8 1 1 8 6.6’ X 10’ 1 1 1 South Wing – At the time of the inspection, the South wing was unoccupied. All rooms are wet rooms. South Wing Single 1998 1 1 1 1 8.3’ X 10’ 1 1 1 Handicapped accessible room. Operational in 2002; under 1998 regulations. Safety Padded Pre-1998 1 1 (1) 11' x 9' Plumbing fixture access outside the room. Room Dayroom Pre-1998 1 37' X 38' Additional dayroom/multipurpose space in the west wing Recreation Outdoor 1998 110’ X 110’ + Total of 13,664 square feet of outdoor exercise area 68’ X 23’ *T = Toilets; U = Urinals; W = Wash Basins; F = Fountains; S = Showers in unit; If "Total RC" appears in brackets ( ), it is not part of the facility's rated capacity. 7293 Marin County JH LASE 20-22 - 1 - Juv LAS.dot;BSCC 460(1/6/97)