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Document Type: Consultation response

HMPPS Certified Prisoner Accommodation Framework consultation – IMB response

HMPPS Certified Prisoner Accommodation Framework Consultation

Comments from Independent Monitoring Boards (IMBs)

Temporary accommodation (paragraph 13, page 4)

This paragraph is vague and allows establishments to use temporary accommodation that does not meet the standards referenced in this framework. The language should be clearer about what it means by “the authority will make every effort to comply to the minimal standards”. Actual outcomes for prisoners need to be measured rather than relying on intent. There ought to be a time limit and escalation sign off, perhaps from the Prison Group Director.

Privacy screening (Annex A, paragraph 3, page 5)

In principle, we do not believe that prisoners can decently be held in double cells, often designed for a single prisoner, with a shared toilet. A number of IMBs across the prison estate, including Lancaster Farms, Bristol, Swinfen Hall and Peterborough women’s prison, have repeatedly raised concerns about the lack of adequate privacy screening when prisoners have to share a single cell, and in many cases where they have to eat meals. The partial privacy screening in instances of crowded accommodation is unacceptable. In-cell toilets and washing facilities should be screened in shared cells.

In light of the COVID-19 pandemic, it is concerning that there is no mention of handwashing facilities or alternatives being provided.