Inspectors also noted the following illegal procedures in at least two institutions: decisions to use these practices made by the nursing staff without confirmation from physicians, or on the basis of prescriptions that had been written in advance, with the indication "when necessary", and implemented with no prior medical checkup. The visits also confirmed the findings of the thematic report in terms of treatment and care for patients detained in mental health institutions. So-called "therapeutic" solitary confinement, and sometimes restraint described in the same way, are used as safety measures, pure and simple, and detained patients are subjected to such practices systematically throughout their time in these institutions – regardless of their clinical condition. This situation is very common – found even in the most open institutions. And yet there are a few exceptions to this rule: in one of the institutions visited, as soon as their clinical condition allowed, the patients detained were allowed to benefit from a conventional hospitalisation regimen and activities in the same way as the other patients, without this ever having posed any problems. When consulted over the summer by the Minister of Health and Social Affairs about a draft circular for implementing the new Article L.3222-5-1 of the Public Health Code, the CGLPL did not hesitate, on the basis of these justifications, to bring up 7 all of the provisions that it felt should be included in such a text to ensure the law is fully applied in keeping with its founding principles. The CGLPL found the draft that it received from the Ministry to be overly technical, and asked that the legal provisions not be interpreted as exclusively applying to patients placed in seclusion rooms, but, on the contrary, also to patients confined in their own rooms. It also asked that the circular adopt measures aimed at proving that solitary confinement and restraint were only carried out as a last resort and at guaranteeing that these measures do not go on for longer than is considered strictly necessary. The CGLPL also recommended that, on the basis of the circular, a national body for assessing policies aimed at limiting the use of solitary confinement and restraint be set up, and reminded the Minister of all of the recommendations set out in the conclusion of the May 2016 report on solitary confinement and restraint in mental health institutions. Since the draft circular on which the CGLPL had been consulted was still being worked on when this annual report was being written, the CGLPL can do no more than stress the need to bring it properly to completion and the wish that this document not amount to a purely procedural text regulating the content of the record introduced by law, but represent a dynamic text underscoring the public authorities' commitment to reducing solitary confinement and restraint practices and promoting the application of the legislation that provides for such practices only as a last resort and for policies limiting them to be set up and assessed. Whenever necessary, the CGLPL is prepared to share its expertise with the Government in drafting this circular. It is imperative that an implementing circular for the new provisions of Article L.3222-5-1 of the Public Health Code be adopted with the utmost urgency, in order to enable traceability of any solitary confinement and restraint measure taken, in whatever form it may take, and to expedite the definition and assessment of policies aimed at limiting these practices with account taken of the recommendations set out in the CGLPL's report on solitary confinement and restraint in mental health institutions. 7 Letter dated 23 August 2016 to the Minister of Social Affairs and Health. 25