Public Safety (PS) and Correctional Service Canada (CSC) Responses to Recommendations in the Structured Intervention Unit Implementation Advisory Panel 2022 to 2023 Annual Report

Responses to Panel Recommendations

1. CSC must be directed immediately to examine the relationship of the operation of the SIUs to its overall operations.

CSC staff have frequently suggested that the SIU model has had negative impacts on core correctional operations and have also suggested that SIUs are responsible for an erosion of the conditions of confinement for general population prisoners. An examination of these issues must start immediately. It must be supported by systematic data on the operation of the SIUs and CSC institutions more generally. And it must be completed before the end of 2024, be made public, and contribute to the pending 5-year review of Bill C-83.


The government is committed to ensuring that SIUs contribute to inmate rehabilitation while ensuring institutional safety and security. PS and CSC recognize that SIUs do not function in isolation from the broader institution.

To delve in to the Panel’s concerns, CSC will conduct a thorough analysis to explore the perception that SIUs detract from the conditions of confinement in the mainstream population and to examine why some inmates prefer to remain in SIUs, and why many inmates in SIUs do not avail themselves of offers for time out of cell and interpersonal interaction. CSC will report back to the Minister with the results of this analysis, and propose targeted, time-bound solutions to address these concerns, by December 31, 2024.

Whether in an SIU or in the mainstream population, the principles of the Corrections and Conditional Release Act (CCRA) clearly indicate that conditions of confinement should only be as restrictive as necessary to carry out an inmate’s sentence while maintaining the safety of inmates, staff, and the public. The CCRA is also clear that the purpose of the correctional system is to assist in the rehabilitation of offenders and their reintegration into the community as law-abiding citizens through the provision of programs.

In both SIUs and mainstream correctional environments, all efforts are taken to ensure inmates have access to correctional planning and interventions that are tailored to address their individual risks and needs. Each inmate receives a unique Correctional Plan that identifies their specific criminogenic needs and risks, and establishes corresponding correctional programming and objectives.

Correctional interventions are developed and evaluated to ensure they are effective, evidence-based and are responsive to the ethnic, cultural, and linguistic needs of a diverse inmate population. They are designed to ensure inmates are able to address the factors contributing to their offences, and ensure they are able to safely reintegrate into Canadian society as productive, law-abiding citizens upon their release. This approach applies to all inmates who are in the care and custody of CSC.

To provide additional context, it is helpful to note that CSC is managing evolving risks as it works to achieve its mission and fulfill its mandate. Elements such as the increase in drone drops leading to the introduction of contraband, as well as inmate affiliations to criminal networks and security threat groups (STGs), create significant operational security and population management challenges. This dynamic, complex and high-risk environment is part of CSC’s operating reality.

CSC is responding to some these challenges by enhancing its layered approach of best practices, such as dynamic security, technological supports, intelligence activities, enhanced searching and inmate monitoring, police partnerships, infrastructure amendments, and STG disaffiliation initiatives.

2. CSC must be directed immediately to develop and implement a plan to reduce the high number of Black prisoners, Indigenous prisoners, and prisoners with mental health problems who are being transferred into SIUs, as well as reducing their lengths of stay while in the SIUs.

The action plan needs to be developed and made public within 90 days of the release of this report. Updates should be made public every 60 days thereafter documenting both the changes that have been made and the impact of these changes. The actions taken must also prevent the prolonged isolation of these prisoners in any other forms of restrictive custody.


The overrepresentation of Indigenous and Black Canadians is a broader issue affecting the entire Criminal Justice System, including corrections. PS and CSC are committed to ongoing analysis and improvements that ensure equitable outcomes for overrepresented and vulnerable groups in SIUs and in the general correctional population. Both organizations will continue to analyze the trends and causes of overrepresentation in SIUs and other underlying factors, related to SIU transfers.

To address the concerns outlined by the Panel, CSC will report to the Minister within 90 days with an action plan geared towards identifying and addressing factors contributing to overrepresentation and extended stays of inmates who are Black, Indigenous, or who have mental health needs in SIUs; and will provide the Minister with updates on the implementation of these solutions every 120 days thereafter.

While there is always room for improvement, it is important to note that there are a number of substantial initiatives underway throughout the Government of Canada, including at PS and CSC, which contribute to addressing these issues. Indeed, addressing the overrepresentation and marginalization of Indigenous Peoples, Black and racialized Canadians, and Canadians with mental health issues remains a top priority. While these are complex and multifaceted problems, the Government has implemented a number of initiatives to reduce systemic inequities and, importantly, to address root causes of overrepresentation. 

Addressing the overrepresentation/marginalization of Black and Indigenous Canadians

For example, PS is supporting Canada’s Black Justice Strategy, which aims to address anti-Black racism and systemic discrimination that has led to the overrepresentation of Black people in the criminal justice system. The Strategy will aim to help ensure that Black people have access to equal treatment before and under the law in Canada. It is being developed in collaboration with an external Steering Group of Black experts and leaders and in consultation with Black communities across Canada.

PS is also supporting the whole-of-government initiative to develop the Indigenous Justice Strategy to address systemic discrimination and overrepresentation of Indigenous peoples in the justice system. PS has contributed to a variety of community programming, such as the Indigenous Community Corrections Initiative (ICCI) and the Aboriginal Community Safety Planning Initiative, which aim to respond to corrections and community safety issues in a holistic and culturally relevant manner including by developing community safety plans, strategies for incarceration alternatives, and reintegration projects for Indigenous offenders. To support the ICCI, Canada has confirmed a strategic investment of $5.21 million in 2023/2024 and $12M ongoing thereafter.

The Federal Framework to Reduce Recidivism was tabled in Parliament in 2022, and aims to increase public safety by reducing recidivism; preventing victimization; addressing the overrepresentation of Indigenous Peoples, Black Canadians and other marginalized groups in the criminal justice system; and ultimately, create safer communities. Following the tabling of the Framework, Public Safety Canada continued engaging with partners and stakeholders to help inform the development of the implementation plan, which was published in November 2023. A Report back on the Framework will be tabled in Parliament in 2025 to update on challenges, make recommendations, and identify new actions and areas of focus under the plan.

Public Safety Canada’s National Crime Prevention Strategy (NCPS) provides funding to projects that contribute to preventing and reducing crime in Canada and to increasing knowledge about what works in crime prevention. From 2008 to 2019, the NCPS provided funding to 650 projects in communities across Canada, representing multi-year investments of approximately $500 million. The Crime Prevention Action Fund (CPAF), one of the NCPS’s four funding programs, provides grant and contribution funding that supports evidence-based crime prevention initiatives in communities that address known risk and protective factors associated with crime among vulnerable groups of the population, including high risk offenders. In fiscal year 2022-23, the government made approximately $12 million available to community-based programs through the CPAF.

Addressing overrepresentation in federal corrections

PS and CSC share the public’s concern about overrepresentation of Indigenous peoples and Black Canadians in federal corrections overall, and in SIUs more specifically. CSC is actively engaged in addressing overrepresentation within the context of federal correctional institutions – including in SIUs – and will explore means to make further progress in this area.

CSC hired a Deputy Commissioner of Indigenous Corrections, created Indigenous Intervention Centres, developed culturally relevant correctional programming for Indigenous men, as well as training for staff, and strengthened partnerships with Indigenous communities. Work is ongoing to develop culturally appropriate security classification for Indigenous Offenders.

Culturally appropriate approaches to corrections extend to both SIU and mainstream inmate populations. Before authorizing an Indigenous inmate transfer to the SIU, CSC considers their social history and attempts to identify any culturally appropriate alternatives to the transfer. When a transfer to an SIU is necessary, CSC continues to offer culturally appropriate interventions and support through access to Elders, Indigenous Liaison Officers, and Spiritual Advisors; and offers programs and interventions adapted to meet the needs of incarcerated Indigenous people.

CSC has also created an Anti-Racism Framework and Actions, with a focus on three pillars: employees, offenders, and stakeholders. CSC also has training in place to support staff, covering topics such as anti-racism, unconscious bias, Indigenous culture, and cultural competency.

An Ethnocultural Action Framework has been created to better support ethnocultural offenders, including those who are Black and other racialized groups. Over 60 staff members have been identified as Ethnocultural Site Coordinators, tasked with providing support to offenders of racialized groups, including those who are Black. These coordinators provide Black offenders with interventions and services aimed at supporting reintegration. Some areas of focus include providing mentorship and culturally relevant materials for personal development purposes, as well as engaging community partners to support Black offenders.

The development of a Black Offender Strategy to identify new opportunities to address the unique lived experiences and barriers faced by federally sentenced Black individuals is underway. This strategy will initially identify and determine ways to incorporate expand successful practices across the country and, where possible, anchor them in policies, procedures, and practice nationally.

In 2023, CSC held Open Houses in all institutions with an SIU to increase engagement between community partners, the institutions and the SIU. In addition, CSC created and disseminated a poster to all SIUs that includes information for inmates about the type of community supports available to them, including the Regional Ethnocultural Advisory Committees. This information was also added to the insert for the SIU Inmate Handbook, which was disseminated in all SIUs.

In early 2023, CSC created a National List of Stakeholders that was shared with the regions. This list is comprised of community partners that have expressed interest in providing support within the SIUs. CSC also launched an Expression of Interest, specifically encouraging Black, racialized and ethnocultural organizations, experts, and groups to signal their interest in working with CSC moving forward.

Addressing Mental Health in SIUs

In 2017 and 2018, federal budgets included $78.2M to better address the mental health needs of individuals. In the 2018 Fall Economic Statement, the Government of Canada announced $448M over six years for transforming federal corrections. Of this funding, more than $150M over six years is being used to enhance mental health support in the federal correctional system. Investments in mental health include enhanced assessment and early diagnosis of individuals, enhanced primary and acute mental health care, support for patient advocacy services and 24/7 health care at designated institutions. 

CSC has specific mental health assessment processes for individuals in SIUs. Health Services conducts daily wellness visits to each inmate in the SIU; a safeguard to ensure inmates in the SIU are not displaying the emergence of physical and mental health symptoms. Health assessments, including mental health evaluations, are required within 24 hours of transfer to the SIU and every 14 days thereafter. A more in-depth mental health assessment is completed no later than 28 days from the inmate’s transfer to the SIU.

The Corrections and Conditional Release Act (CCRA) also contains safeguards to ensure inmate health and wellbeing. For example, staff members may refer an inmate to Health Services if they have reason to believe that their mental health is deteriorating during their stay in the SIU. Additionally, a health professional may request the institutional head alter an inmate’s conditions of confinement in an SIU or recommend removal from the SIU for health and mental health reasons.

CSC recently held a roundtable with external health care providers across different professional disciplines to review CSC’s approach to interdisciplinary health assessment within SIUs to ensure CSC’s approach was consistent with community standards. To inform the roundtable discussions interviews were conducted with individuals with lived experience with the SIU to elicit individual’s experience. While they identified opportunities to support staff in working to their full scope of practice, the review confirmed that the approach to assessment was appropriate and in line with similar processes in the community.

3. CSC must be directed to immediately ensure that all prisoners held in an SIU for more than 15 days will have their case referred to an IEDM, regardless of whether or not the prisoner had been previously ordered released.

Enhanced reporting on the number of prisoners and their relevant characteristics (e.g., whether the prisoner is Indigenous or from a racialized group, the presence of mental health problems, length of stay) must be implemented. These reports will present data on prisoners in any SIU anywhere in Canada and who have been in an SIU for a total of 30 days or more. These reports must be released to the public monthly, starting immediately.


Independent external oversight of SIU transfers and conditions of confinement is one of the cornerstones of the SIU model. PS is committed to strengthening SIU oversight, and work is underway to develop and implement improvements to the governance, supports, and review capacity of the Independent External Decision Makers (IEDMs).

The 15 day timeframe for external oversight recommended by the Panel reflects Rule 44 of the United Nations Standard Minimum Rules For the Treatment of Prisoners (Mandela Rules). Rule 44 stipulates that solitary confinement refers to the confinement of prisoners for 22 hours or more a day without meaningful human contact, and that prolonged solitary confinement refers to solitary confinement for a time period in excess of 15 consecutive days.

As will be outlined in greater detail below, the legislative and regulatory framework for the SIU model contains a number of provisions to ensure that inmates in SIUs do not experience solitary confinement. This includes an IEDM review on conditions of confinement in an SIU with the authority to direct their removal from the SIU.

Accordingly, at this time it would be premature to implement the Panel’s recommendation with respect to IEDM referrals. However, PS and CSC will consider the Panel’s findings as part of both organizations’ ongoing efforts to review SIU implementation and identify potential enhancements to this specific process.

SIU conditions of confinement

As is noted by the Panel in their report, one of the primary objectives of the SIU model is to ensure that inmates who cannot be safely managed in a mainstream correctional environment receive targeted interventions and supports without experiencing prolonged isolation or solitary confinement.

The CCRA reflects this intent, and requires that CSC offer inmates in an SIU an opportunity to spend a minimum of four hours outside of their cell, including two hours interacting with others, every day. While there is always room for improvement, it is promising to note that, during the final quarter of 2023, CSC succeeded in ensuring inmates in an SIU had opportunities for 4 hours outside their cell and 2 hours of interaction over 94% of the time.

All efforts are taken to ensure inmates in SIUs have access to correctional planning and evidence-based, culturally relevant interventions that are tailored to address their individual risks and needs. Health assessments, including mental health evaluations, are required within 24 hours of transfer to the SIU and every 14 days thereafter. CSC Health Services conducts daily wellness visits to each inmate in the SIU to ensure inmates in the SIU are not displaying the emergence of physical and mental health symptoms.

Independent oversight of SIU conditions of confinement

The CCRA also contains safeguards to ensure that SIU inmates who may be experiencing conditions resembling isolation or solitary confinement receive an independent, external review of their case. These reviews are triggered well in advance of the 15 consecutive days outlined by Rule 44 of the Mandela Rules. IEDMs are legally bound to review all cases where an inmate in an SIU has not spent four hours a day outside their cell or interacted with others for two hours a day for a period of 5 consecutive days or 15 days in a 30-day period. This oversight applies to all SIU inmates, including those who have refused CSC offers for time out of cell and interpersonal interaction.

As part of their review, IEDMs are required to assess whether CSC has taken all reasonable steps to provide opportunities for time out of cell and interpersonal interaction and to encourage the inmate to avail themselves of said opportunities. Should they find that CSC has not taken all reasonable steps to provide these opportunities or encourage the inmate to avail themselves of these offers, IEDMs are entitled to make any recommendation they consider appropriate to remedy the situation.

Importantly, if CSC fails to satisfy the IEDM that it has taken all reasonable steps to remedy the situation within 7 days of receiving their recommendations, the IEDM is legally required to direct CSC to remove the inmate from the SIU and notify the Correctional Investigator.

Reporting on SIUs

With respect to the Panel’s recommendation on reporting, CSC will evaluate the recommendation closely with the goal of increasing transparency, taking into consideration the resource implications, while respecting the privacy rights of offenders.

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