Consultation on Commissioner's Directive 711 – Structured Intervention Units CBA

In my view, this outrages standards of decency and amounts to cruel and unusual treatment.”8 The CBA Section is concerned about the 2021-2022 Annual Report of the Structured Intervention Unit Implementation Advisory Panel (Panel Report), which indicates that 8.4% of people in CSC’s custody were held in SIU during the first 21 months of SIU implementation, and that 57% of SIU stays exceeded 15 days. [...] Instead of focusing on the failure of people held in SIU to participate in programs and services, the policy should address the root causes of refusal to comply. [...] 37.2 of the CCRA states that a health care professional “may, for health reasons, recommend to the institutional head that the conditions of confinement of the inmate in a structured intervention unit be altered or that the inmate not remain in the unit.” It is not mandatory. [...] Right to counsel The CBA Section argues that policy references to the right to counsel should state that people have a right to retain and instruct counsel when they are the subject of an authorization to transfer to SIU under Corrections and Conditional Release Regulation s 97(2)23. [...] The hurdles people in SIU experience to identify the relevant documents and request that those documents be shared with their legal representatives also Submission of the Criminal Justice Section Page 13 and the Imprisonment and Release Committee of the CBA impacts their right to counsel for IEDM reviews.