FREQUENTLY ASKED CONSTRUCTION QUESTIONS (FAQs)
October 2005

1.     IS CORRECTIONS STANDARDS AUTHORITY (CSA) PLAN REVIEW REQUIRED IF MY CITY OR COUNTY WILL BE BUILDING, EXPANDING OR REMODELING A LOCAL JAIL, JUVENILE HALL, OR CAMP?

2.     WHAT MUST BE SUBMITTED FOR CSA REVIEW?

3.     IN ORDER TO MINIMIZE MISTAKES AND PERHAPS SAVE COSTS, CAN THE CSA PROVIDE TECHNICAL ASSISTANCE TO HELP WITH DESIGN AND PLANNING?

4.     WHAT IS THE CSA ROLE IN LOCAL BIDDING AND CONSTRUCTION?

5.     IF MY CITY OR COUNTY PROCEEDS UNDER A "DESIGN/BUILD" MODEL, CAN WE START CONSTRUCTION BEFORE PLANS ARE FULLY DEVELOPED?

6.     WHEN IS STATE GRANT FUNDING RELEASED BY THE CSA FOR CONSTRUCTION PROJECTS?

7.     WHO CAN PROVIDE LEGAL ADVICE OR ANSWER QUESTIONS?

8.     ARE AUTOMATIC DOORS REQUIRED FOR CELLS/SLEEPING ROOMS?

9.     IS THERE A PREFERENCE ON WHICH WAY THE CELL/SLEEPING ROOM DOORS OPEN?

10.  ARE SKYLIGHTS AN ACCEPTABLE LIGHT SOURCE?

11.  WE ARE CONSIDERING PLACING TOILETS AT THE FAR SIDE OF THE CELL/SLEEPING ROOM TO ALLOW EASY ACCESS TO THE PLUMBING CHASE.  DOES THIS CONFIGURATION MEET REGULATIONS?

12.  ARE FLOOR DRAINS NECESSARY NEAR THE SLEEPING ROOM/CELL AREA?

13.  MAY OCCUPANTS GET DRINKING WATER FROM THEIR SINK, RATHER THAN INSTALLING A DRINKING WATER BUBBLER?

14.  IS IT POSSIBLE TO ELIMINATE THE TOILETS IN THE DAYROOM AREAS?

15.  IF OCCUPANTS HAVE ACCESS TO WARM WATER IN THE DAY ROOM, CAN THE SLEEPING ROOMS/CELLS HAVE COLD WATER ONLY?

16.  WHAT SUGGESTIONS DO YOU HAVE FOR BUILDING DESIGNS THAT MAXIMIZE SIGHT LINES AND STAFF EFFICIENCY?

17.  ARE THERE ANY ADDITIONAL RECOMMENDATIONS ON HOW TO REDUCE SUICIDE HAZARDS?

18.  WHAT TYPES OF VIEW PANELS ARE RECOMMENDED ON THE SLEEPING ROOM/CELL DOORS?

19.  CAN GLASS BLOCK BE USED TO PROVIDE NATURAL LIGHT WHILE LIMITING OBSERVATION FROM THE OUTSIDE?

20.  WHAT SPECIAL CONSIDERATIONS SHOULD BE KEPT IN MIND WHEN BUILDING PADDED ROOMS/CELLS?

21.  MUST ALL MEDICAL EXAM ROOMS BE AT LEAST 144 SQUARE FEET IN JUVENILE FACILITIES AND 100 SQUARE FEET IN ADULT FACILITIES?  

22.  WHAT EQUIPMENT/SUPPLIES SHOULD BE IN MEDICAL EXAM ROOMS?

23.  IS PERIMETER LIGHTING REQUIRED?

24.  SHOULD SHOWERS BE LOCATED ON TIER LEVELS OF HOUSING UNITS?

25.  ARE CLASSROOMS REQUIRED IN JUVENILE FACILITY EXPANSION PROJECTS?

26.  ARE SEGREGATED OUTDOOR EXERCISE SPACES THAT ARE SMALLER THAN THE PRESCRIBED PHYSICAL ACTIVITY AND RECREATION AREAS ALLOWED IN JUVENILE FACILITIES?

 

FREQUENTLY ASKED CONSTRUCTION QUESTIONS (FAQs)

1.     IS CORRECTIONS STANDARDS AUTHORITY (CSA) PLAN REVIEW REQUIRED IF MY CITY OR COUNTY WILL BE BUILDING, EXPANDING OR REMODELING A LOCAL JAIL, JUVENILE HALL, OR CAMP?

Yes.  Penal Code Section 6029 requires cities and counties to submit plans and specifications to the CSA for review and recommendations/approvals before undertaking any local detention facility and camp construction, remodeling or repairs that cost in excess of $15,000 (i.e., jails, juvenile halls, juvenile camps, correctional treatment centers, etc.).  This includes projects funded by the CSA and from other sources.  The goal is to build safe and secure detention facilities that meet local needs and operate efficiently, cost-effectively, and are in compliance with code and standards.

Submittals are not required for projects under $15,000, however, cities and counties are encouraged to contact CSA staff to discuss projects that are less than that amount to evaluate potential advantages of submitting plans for review and availability of technical assistance.   Although a project may initially cost under $15,000, there may be regulation implications that, if not addressed, may have larger cost implications (e.g., fire and life safety regulations).

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2.     WHAT MUST BE SUBMITTED FOR CSA REVIEW?

Titles 15 and 24, CCR, set forth minimum operations and construction standards for local adult and juvenile facilities.  Title 24 CCR requires plans and specifications to be submitted to the CSA (at least 1/8" scale architectural drawings) at three separate and sequential stages for formal review and response: 1) Schematic Design (30 percent complete, with operational program statement); 2) Design Development (50 percent complete); and 3) Construction Document (100 percent complete).  Submitting plans at all three stages is to the jurisdiction’s advantage because it allows issues to be addressed sequentially and early in the process, when project modifications can be made most economically.  CSA staff conduct reviews for compliance with regulations and respond in writing after each stage of review. 

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3.     IN ORDER TO MINIMIZE MISTAKES AND PERHAPS SAVE COSTS, CAN THE CSA PROVIDE TECHNICAL ASSISTANCE TO HELP WITH DESIGN AND PLANNING?

Yes.  The CSA encourages "pre-design" conferences after a design firm is hired but before beginning schematic design.  These meetings typically involve key city or county staff and the architect, and CSA staff including the architectural plan reviewer, facility inspector, and (if state funded) the grant manager.  In this way, standards issues/questions and design options can be discussed early in the process.  Additional conferences can be held throughout the plan review process before construction begins.

Units of local government (i.e., cities and counties) must perform careful and complete planning in order to build and operate safe and secure local detention facilities that meet applicable codes, standards and local needs.  In addition, planning and design decisions have major operational cost implications (e.g., staffing and life cycle costs).  Facility operational costs are generally 14 to 19 times the construction costs over a 30-year life cycle.  Design decisions that optimize staffing patterns and minimize life cycle costs can result in big savings to cities and counties for decades to come.

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4.     WHAT IS THE CSA ROLE IN LOCAL BIDDING AND CONSTRUCTION?

Bidding and construction are local responsibilities.  Cities and counties, as the owners and operators of jails, juvenile halls, and camps, are responsible for construction, and compliance with the Public Contract Code, which generally requires competitive bidding in the award of construction contracts.  Prequalification of bidders is also useful for major construction projects to help ensure that the potential contractor is the best fit for the job.  Resolution of bid disputes, or subsequent contract disputes, is the sole responsibility of cities and counties that manage the bid process and enter into construction contracts.

Most construction projects are bid based on complete plans and specifications ("design-bid-build" basis).  However, under certain circumstances, bidding can be done on a "design/build" basis whereby design and construction is procured from a single source before the development of complete plans and specifications (See Public Contract Code Section 20133).

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5.     IF MY CITY OR COUNTY PROCEEDS UNDER A "DESIGN/BUILD" MODEL, CAN WE START CONSTRUCTION BEFORE PLANS ARE FULLY DEVELOPED?

The intent of Penal Code Section 6029 and Title 24 CCR is that state-level reviews occur before beginning construction or remodeling of local detention facilities.  Cities and counties proceed at their own risk if construction or remodeling begins before CSA review and/or approval of complete plans and specifications.  Construction changes might have to be made later in order for the project to conform to code and standards. 

A risk of "design/build" models (with or without guaranteed cost caps) on complex and unique projects, including major new local detention facility construction, is that critical design details (and cost implications) are not fully known at the time of single source procurement (e.g., security electronics and other major features needed for safe and secure confinement).  If complete plans and specifications are developed before awarding major detention facility construction contracts, critical design decisions affecting public safety can be made, costs can be better estimated, and city/county design leverage is increased.  This can help minimize the risk of an unsuccessful project or major unanticipated costs that could force a reduction in the desired scope of work.

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6.     WHEN IS STATE GRANT FUNDING RELEASED BY THE CSA FOR CONSTRUCTION PROJECTS?

For CSA funded construction projects, a formal state/county grant contract is entered into and grant funds are released only after completing all precontractual submittals and when plans and specifications are reviewed and accepted by the CSA and construction has begun.  (For precontractual submittals and funding requirements, please reference CSA Construction Grants Program, Grant Contract Administration and Audit Guide and applicable Request for Proposals.)  Units of local government are solely responsible for higher than expected costs or cost overruns that may occur.  For CSA funded projects, the approved scope of work (e.g., number of beds added) cannot be reduced due to higher than expected costs or cost overruns.

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7.     WHO CAN PROVIDE LEGAL ADVICE OR ANSWER QUESTIONS?

Cities and counties are responsible for projects and should seek the advice of their legal counsel on bidding questions or if considering the application of "design/build" approaches for detention facility construction projects.  There should be a thorough analysis of potential benefits and risks to the city or county if construction is begun before plans are complete.

Contact the CSA if you have questions about the construction plan review process or operational and physical plant standards for local detention facilities (Titles 15 and 24, CCR).  Visit the CSA web site at www.bdcorr.ca.gov for more information on facility standards and resource information on design and construction.

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8.     ARE AUTOMATIC DOORS REQUIRED FOR CELLS/SLEEPING ROOMS?

Although not required, automatic doors are both a convenience and an enhanced safety feature in facilities, especially those with a tier housing level.  In addition, they may present a substantial staff cost savings for counties by not requiring staff to open all doors manually.  Electronically controlled door locks are difficult and costly to add after construction and should be carefully considered during the design phase.

State Fire Marshal regulations require that all electrically controlled or other powered doors must be capable of release by a manual device located at a height on the door that is easily operable by staff.  It must be possible to open the door with a key.  A special tool must not be required to open the door.  Ladders, stools, or similar equipment cannot be required to reach the locking device.  Manual “gang releases,” which release multiple doors at the same time, are acceptable if they are accessible as noted above.

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9.     IS THERE A PREFERENCE ON WHICH WAY THE CELL/SLEEPING ROOM DOORS OPEN?

Outward swinging doors are recommended on individual cell/sleeping room doors for the following security, fire, and life safety reasons:

  1. A door should swing in the direction of control; an outward swing gives staff greater control of the door and decreases the potential of staff being pulled into the room.
  2. Doors that open inward are easily blocked by occupants, thereby creating a fire or safety hazard if staff is unable to enter the room.
  3. If a staff member enters or is pulled into a room and becomes involved in a physical altercation, additional staff may be unable to enter the room to assist due to the door swing being blocked.
  4. When securing the doors, staff must reach into the room to pull an inward-swinging door closed, automatically placing staff off balance.  This leaves staff more vulnerable to attack and/or injury.
  5. Outward swinging doors maximize the doorway opening and space available in the cell/room in the event staff has to respond to an emergency or forcibly remove an occupant.
  6. It is more difficult to determine if an inward swinging door is securely closed.
  7. Several crowded facilities have been unable to provide a portable bunk for a second occupant to sleep in a single occupancy room, since the portable beds can be used as a wedge between a built in bunk or cement slab and the door.
  8. Visual observation is limited if an occupant is behind the door when a staff member enters.  Even with backup staff in the hallway, staff can be ambushed.
  9. An occupant suffering from a seizure or other medical emergency may collapse in front of the door, hindering rescue efforts.
  10. Problems with inward swinging doors are compounded in rooms with two occupants.  One occupant could be leaning against the door, holding a second occupant hostage or choking him/her, with staff unable to open the door.
  11. Staff should be able to open the door and have the occupant enter without passing behind staff.

When the door swings out, the lock bears the entire weight of pressure against the door.  Outward-swinging doors require correctional-grade locks that can provide appropriate security.  Additionally, while the possibility exists for a youth/inmate to rush the outward swinging door as it is unlocked, staff training and facility procedures in how to safely position themselves prior to unlocking the door can be provided.

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10.  ARE SKYLIGHTS AN ACCEPTABLE LIGHT SOURCE?

Skylights are an appropriate light source for detention facilities; however, the location, size, and security rating of the skylights are important.

Placing the skylight over the toilet, bunk, table or seat in a security cell with an eight-foot ceiling is not appropriate.  Such placement requires an internal security screening or glazing.  A more appropriate solution may be a smaller skylight that is placed in the center of the room and is not easily accessed by standing on any furniture or fixtures.

Security caging for the outside of a skylight should be considered, as well as the ability for staff to clean the skylight.  Some facilities report the need for regular maintenance due to a complex assembly.

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11.  WE ARE CONSIDERING PLACING TOILETS AT THE FAR SIDE OF THE CELL/SLEEPING ROOM TO ALLOW EASY ACCESS TO THE PLUMBING CHASE.  DOES THIS CONFIGURATION MEET REGULATIONS?

This approach is consistent with regulation.  However, when installing an outside plumbing chase corridor rather than individual plumbing chases or chases designed for access to two rooms/cells, additional security for the plumbing chase area must be addressed.  Access to the plumbing area should not be available from the sleeping room.  For example, one should not have access to the chase corridor by removing the toilet.  When the plumbing chase corridor is located on an outer wall of the facility, it should also be secure enough to prevent attempts from outsiders to penetrate security.  Additionally, staff needs access to the plumbing chase to turn water off in emergency situations.  Safe access to the upper level fixtures must be considered for facilities with two levels of sleeping rooms/cells.

Use of external plumbing chase corridors usually results in the toilet being on the "back" wall of the sleeping room/cell, creating a modesty issue if staff can directly view the individual using the toilet.  If modesty cannot be incorporated into the design of the room/cell, consideration must then be given to installing a partition to provide basic modesty, without creating blind spots that prevent the visual observation of the inmate to ensure safety and security.  “Modesty” is not synonymous with “privacy.”  The modesty partition cannot completely obscure the inmate/minor.  The primary purpose of a modesty partition is to facilitate cross-gender supervision, not modesty among individuals housed in the cell/room or dorm.

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12.  ARE FLOOR DRAINS NECESSARY NEAR THE SLEEPING ROOM/CELL AREA?

It is recommended that floor drains be included at regular intervals near the cells/sleeping rooms.  All floor drains should be located outside of the cells/sleeping rooms to prevent clogging, vandalism, and use to conceal contraband by residents.  Exceptions to this include some special purpose cells such as detoxification/sobering cells or safety rooms/cells.

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13.  MAY OCCUPANTS GET DRINKING WATER FROM THEIR SINK, RATHER THAN INSTALLING A DRINKING WATER BUBBLER?

No.  Regulations require drinking water bubblers that are mechanically activated, rather than requiring the use of a finger or hand directly on the drinking surface to create a drinking fountain.  The "finger" bubbler does not comply with regulations.

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14.  IS IT POSSIBLE TO ELIMINATE THE TOILETS IN THE DAYROOM AREAS?

When cells/sleeping rooms are provided with toilets, it is recommended that a toilet be accessible from the dayroom for use during recreation, school and other unit activities.  Especially in juvenile facilities, this reduces the need to transport occupants to their individual cells/rooms to use the toilet, either for emergencies or for scheduled restroom breaks.  If meals are served in the dayroom, regulations require a visual barrier that prevents the toilet(s) from being in direct view of dayroom occupants.

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15.  IF OCCUPANTS HAVE ACCESS TO WARM WATER IN THE DAY ROOM, CAN THE SLEEPING ROOMS/CELLS HAVE COLD WATER ONLY?

No.  Hot and cold or tempered water is required in the sleeping rooms/cells.  When facilities are constructed or expanded, it is important to confirm that the required hot/cold or tempered water is provided in these locations.

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16.  WHAT SUGGESTIONS DO YOU HAVE FOR BUILDING DESIGNS THAT MAXIMIZE SIGHT LINES AND STAFF EFFICIENCY?

Consideration of sight lines throughout a facility will maximize staff effectiveness and impact operating costs.  It is critical that a county representative consult with the assigned CSA Field Representative to review staffing implications of new designs.  While each county or city needs to calculate its own costs based on local salary and benefits, it is estimated that the cost of one post staff position (including shift relief factors) over the 30-year life cycle of a facility is $8.5 million. 

There are a number of options that can be considered to maximize sight lines and staffing.  For example, when two units are co-located, it may be possible to share a common outdoor recreation area, rather than constructing two separate recreation yards.  The type of lighting, window angles and placement, window materials and camera angles also impact sight lines.  Careful thought should be given to these issues at the very earliest design stages.

A maximum of 30 minors is allowed in a juvenile housing unit, with a child staff supervision ratio of 1:10 during the day and 1:30 at night.  Some designs incorporate staff stations/control areas that have responsibility for supervising more than one housing unit.  These designs may achieve staff savings by staff being able to visually observe both living areas; however, in juvenile facilities, if the position is considered a fixed post, that individual may not be counted in the child supervision staff ratio. 

Juvenile facility designs have also been proposed for 30-bed units with a continuous wall that divides it into two 15-bed units during the daytime programming.  The design incorporates a “shared” control/staff station, with the intent that one child supervision staff member would provide supervision from that station at night.  When the continuous wall prevents direct staff access throughout the entire 30-bed unit, that staffing proposal has not been accepted as meeting the staffing requirements.  All juvenile facilities (and some higher classification adult housing units) must be designed so that the housing unit is never left unattended.  This is especially true at night.  Supervision staff must have direct access to their housing unit, without walls or other obstructions that prevent prompt response to emergencies.

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17.  ARE THERE ANY ADDITIONAL RECOMMENDATIONS ON HOW TO REDUCE SUICIDE HAZARDS?

All facility designs must consider the potential for suicide hazards.  In addition to the provisions of Title 24 CCR, the following considerations are suggested:

1.     Place sprinkler heads, smoke detectors, lights or other protrusions out of reach of the occupants.  Consideration may be given to placing smoke detectors in air ducts.  If there will be two or more occupants in a room, additional protections may be needed.

2.     Place pay phones in fully supervised areas.  The shortest cord possible is recommended on all pay phones, with provision made for handicapped access.

3.     Emergency call buttons in sleeping rooms/cells should be of heavy construction and tamper proof in design.

4.     Beds, desks, and other similar items should be attached flush with the wall, rather than leaving a space between the wall and the object where a hanging attachment could be made.

5.     Pan bottom type beds should be a solid pan, without holes.

6.     All bolts should be welded in place and cut to eliminate sharp edges.

7.     Security bars should never be installed on the inside of a sleeping room.

 

Title 24, CCR, requires that "supply and return grilles shall have openings no greater than 3/16 inch or have 16-mesh per square inch."  Some manufacturers have products labeled "maximum security return grilles" that have ¼", 5/16" or greater openings.  Check with the manufacturer before ordering to ensure 3/16" grille openings.

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18.  WHAT TYPES OF VIEW PANELS ARE RECOMMENDED ON THE SLEEPING ROOM/CELL DOORS?

It is important to maximize visibility into the room/cell while providing the greatest measure of safety and security when evaluating the size and placement of view panels.  Consideration should be given to the classification of the inmates/minors, whether or not the unit will house both males and females in a “co-ed” setting, and future use of the housing area.  Not all view panels need to be within the door.  Some facilities have successfully incorporated additional view panels into the room/cell wall, allowing staff to view areas of that space which would otherwise be less visible.  Placement and sizing of all windows should take into account staff of varying heights, so that all staff has a readily accessible view of rooms.

Use of diagonal windows is not recommended due to the limitations offered for viewing the room.  When walking past a diagonal window, staff is only able to view the portion of the room at eye level.  It becomes necessary to stop and scan the entire window length to get a fuller view.

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19.  CAN GLASS BLOCK BE USED TO PROVIDE NATURAL LIGHT WHILE LIMITING OBSERVATION FROM THE OUTSIDE?

Glass block is not security grade glazing and should not be used in secure detention areas.

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20.  WHAT SPECIAL CONSIDERATIONS SHOULD BE KEPT IN MIND WHEN BUILDING PADDED ROOMS/CELLS?

The size of the room must comply with regulations after the padding and backing is installed so the room should be constructed larger, and with a higher ceiling than the final dimensions.  Consult with your vendor to determine what space should be allowed for the padding and backing to insure that the final dimensions meet the requirements in the regulations.  (Sobering/detox cells in adult facilities also require a padded floor and the eight-foot ceiling height is measured after the floor padding is installed.)

Safety rooms/cells are intended for the short-term placement of individuals who are a danger to themselves or others.  While the ceiling height can be higher than eight feet without jeopardizing their safety, to guard against the inmate/minor being able to get a “running start” to ram their head against the opposite wall, the rooms should not be significantly larger than the square footages indicated in regulations.

Also to prevent injury, hard surfaces should be minimized in padded rooms/cells. To prevent inmates/minors from injuring themselves by beating their heads against the glazing, view panels must be no more than four inches wide.  Food passes are required in adult safety cells and cannot be more than four inches wide.  The audio monitoring devices should be padded so that not more than four inches of hard surface is accessible.  These devices should be located in the ceiling whenever possible.  Adult safety cells require a flushing ring toilet in the floor, while juvenile safety rooms require access to a standard toilet, wash basin and drinking fountain.  In juvenile safety rooms, these plumbing fixtures should not be placed inside the cell, as doing so would defeat the intent of providing the safety of a padded room.  “Access” means the plumbing fixtures can be available outside the padded room. 

Variable intensity lighting is required in adult safety cells.  Despite silence on lighting requirements in the juvenile regulations, the rooms must be lighted and variable intensity lighting is recommended there as well.

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21.  MUST ALL MEDICAL EXAM ROOMS BE AT LEAST 144 SQUARE FEET IN JUVENILE FACILITIES AND 100 SQUARE FEET IN ADULT FACILITIES? 

Yes.  The regulations require that each facility has at least one medical exam room and many facilities will require more exam rooms to adequately provide health care services to their population.  All medical exam rooms must meet the required dimensions.

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22.  WHAT EQUIPMENT/SUPPLIES SHOULD BE IN MEDICAL EXAM ROOMS?

The rooms must be designed in consultation with the responsible physician/health authority-administrator and should contain only the equipment and supplies that they identify as necessary to conduct examinations.  For security reasons, health care offices, related office supplies and medical storage should not be in the exam room, but located in areas that are reasonably accessible for staff.  The design and operation of the exam room should minimize opportunities for inmates/minors to access equipment that can be used to injure themselves or others or jeopardize facility security.

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23.  IS PERIMETER LIGHTING REQUIRED?

Maintaining the appropriate level of security is essential in adult and juvenile facilities.  Juvenile regulations specifically require that the outdoor exercise area be lighted to provide for nighttime programming “and to provide security.”  In facilities with a secure perimeter, lighting that area is an essential element in providing the security and observation necessary to prevent unauthorized access by the general public and to ensure that inmates/minors remain within the confines of the facility.  The location of the facility, community concerns and security requirements must all be considered when designing the type and intensity of perimeter lighting.

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24.  SHOULD SHOWERS BE LOCATED ON TIER LEVELS OF HOUSING UNITS?

There are important differences between adult and juvenile facilities in this area.  It is generally accepted that adult facilities will incorporate showers on both the lower and the tier housing levels.  Typically adult inmates have open access to showers during times they are in the dayroom and there is less structured programming to interfere with this access. 

In juvenile facilities showers typically occur in a more controlled manner, under immediate staff supervision.  The daily schedule in juvenile facilities revolves around school and other program requirements that prevent open, unsupervised shower access.  There are no regulatory prohibitions against showers on the tier levels in juvenile facilities; however, managers should consider staffing requirements as well as access to towels, clothing and shower supplies if showers are located on upper levels of housing units.  If those showers are not used after the facility becomes operational, considerable resources have been wasted and there may not be enough showers on the lower level to meet the needs of the unit.

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25.  ARE CLASSROOMS REQUIRED IN JUVENILE FACILITY EXPANSION PROJECTS?

There needs to be sufficient, dedicated classroom space to accommodate the population that will be added as a result of the expansions.  If this cannot be done in existing classroom space, new classrooms are required.

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26.  ARE SEGREGATED OUTDOOR EXERCISE SPACES THAT ARE SMALLER THAN THE PRESCRIBED PHYSICAL ACTIVITY AND RECREATION AREAS ALLOWED IN JUVENILE FACILITIES?

All juvenile facilities must have exercise areas that meet the dimensions established in Title 24, CCR.  Some recent proposals for juvenile facilities incorporate additional segregated exercise areas adjacent to housing units.  Juvenile regulations do not expressly prohibit these additional areas; however, they raise operational questions.  To be considered in the calculation of required exercise areas, no single dimension can be less that 40 feet.

Juvenile regulations in both Title 15, CCR and Title 24, CCR, clearly establish the intent that programming include significant amounts of daily indoor and outdoor exercise.  It is also the intent of regulation, and the prevailing juvenile facility practice, that group interaction in supervised physical activities is a key component of physical activity programs.  This recognizes not only the importance of developing the skills and abilities to engage in cooperative team efforts, but also physiological needs for large muscle activity.  This operational intent is implemented within physical plant requirements for large group exercise areas, with specified dimensions.

Exercise has historically been a supervised juvenile “program” with goals that include establishing team interaction, physical strengthening and ensuring large muscle exercise.  Juveniles do not typically have open access to exercise areas that are adjacent to dayrooms.  Supervision is a major concern, especially as departments consider approaches that would allow more than one minor into the specialized areas at one time. 

Some proposals attach the areas to all housing units as a recreational option, while others look at them as a viable option for higher risk minors who must be segregated from the general population for reasons including, personal safety, discipline, health issues, etc.  Often the minors in the former categories would not have access to the larger recreational areas, either due to security concerns or the inability to schedule use within the general population facility program.  Regardless of the motivation, the smaller exercise areas represent a shift in thinking for juvenile facilities, especially when applied broadly to multiple classifications of minors.  There is little disagreement with establishing segregated exercise areas for minors whose classification or special needs prevent them from being incorporated into the general population exercise program.

The CSA plan review process requires departments to submit an “operational program statement” with their plans.  That program statement describes the overall approach to facility operation.  Departments seeking to incorporate smaller segregated exercise areas into their design must articulate how the use of those areas will be incorporated into the overall recreation and physical activity program.  They are still required to have the larger exercise area(s) as specified in regulation.  To adequately describe the intended use, the program statement should address:  purpose and goals of the segregated areas; how supervision will be provided; requirements for access to the areas; classification of minors having access and number of minors allowed in each area at one time; and, how programs offered in the segregated areas fit into the overall physical activity and exercise program for the facility.  The approach will be reviewed by staff and should be discussed during plan review and design conferences with the county.

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