prisoners housed in them to wear anti-tear gowns ('strip gowns') and use special bedding, or housing vulnerable individuals in glass-fronted cells with nothing in them. Key decisions were undertaken by custodial staff with limited clinical input into the identification of a prisoner as being at risk of self harm, and their management thereafter (for example, setting the frequency of their observation by staff). The key focus in At Risk units appeared to be on having as little as possible inside the cell so to minimise prisoners' access to materials which they could use to harm themselves with. These 'situational controls' were not accompanied by the necessary accompanying work with the individual on addressing the underlying issues which led to their placement there. Furthermore, in a number of the At Risk units, some of the few in-cell fixtures were not ligature resistant or tamper proof, meaning that they could be used for self-harm, making these cells unsafe. This was extremely concerning and defeats the sole stated purpose of At Risk units- to provide a safe environment for individuals who were at high risk of self-harm. In short, the appearance, conditions and regime in most of the At Risk units we visited were as impoverished and stark as those in punitive segregation units and units for the management of difficult prisoners. Since segregation is a known risk factor for self harm and suicide,35 it follows that the people at risk of such behaviour should not be segregated. This practice also goes against international human rights law standards which call on states to altogether exclude people who are mentally unwell from segregation (see for example the Istanbul Statement, the Mandela Rules and UN Special Rapporteur on Torture reports), and with current trends to ban altogether the use of solitary confinement for people with mental illness (for example in the US). Units and cells not always used for their intended purpose Some people were housed in At Risk or Management units because cells there were accessible to people with disabilities , or because they were newly imprisoned and very anxious, because they needed medical supervision following a medical procedure, or because of other purposes which may be legitimate, but are not stipulated in the prison rules and do not warrant the strict conditions in these units. This was particularly prevalent in the female estate. To illustrate, at the time of our visit, occupants in one At Risk unit included the following: two cells were used for women in wheelchairs simply 35 See for example: Kaba, F., Lewis, A., Glowa-Kollisch, S., Hadler, J., Lee, D., Alper, H., Venters, H. (2014). Solitary Confinement and Risk of Self-Harm Among Jail Inmates. American Journal of Public Health, 104(3), 442–447. http://doi.org/10.2105/AJPH.2013.301742; Shalev 2008. 34

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