Comment on FR Doc # 2011-01905

Sections 115.13, 115.113, 115.213, and 115.313 (compare to the Commission’s PP–3 and PP–7 standards) Questions #4-14: I believe the standard as revised is much more manageable and allows for agency and facility flexibility based on actual design and population demographics. I do not believe the standards should mandate actual staffing ratios as this too could be very costly, but more importantly, may not address the actual needs that would effectively reduce victimization in some facilities. In some cases, the corrective actions that would be needed may not have anything to do with "staffing levels". in these cases, staffing resources can be more effectively used. This standard can be achieved through staffing pattern assessments, video technology, incident monitoring reviews, and, more importantly, through staff training, awareness and culture change. Many agencies/facilities have established mandatory and minimum post/staffing criteria. Agencies can easily modify these criteria based on facility effectiveness in reducing victimization incidents and/or by continuous incident monitoring. if a rise in victimization is detected in a particular area of a facility, then immediate steps can and should be taken to increase staffing levels and/or other technologies to increase monitoring and awareness in that area of the facility where resources are most needed. This will increase the responsiveness and effectiveness in reducing victimization and make those responses more immediate. Daily incident monitoring of PREA related incidents can be used as an effective tool to provide immediate response to problem areas within a facility. This would be much more effective than establishing mandatory staffing ratios.