were, however, derived from its material shortcomings related to, for example, implementation of specific measures of maintaining order and security, implementation of disciplinary proceedings, definition of disciplinary violations and many other. Based on the information collected during the visits and actions taken on complaints of prisoners, our position is that the implementation of specific measures of maintaining order and security is insufficiently clearly prescribed, particularly when having in mind that the use and performance of those measures represents a further restriction of the rights of prisoners. For instance, implementation of the specific measure of maintaining order and security placement in a specially secured room devoid of dangerous objects, is prescribed in just one paragraph, which neither prescribes the purpose of implementing this measure nor makes it clear whether the measure is implemented for security or medical reasons and whether it is punitive or preventive in character. Therefore, it happens in practice that the measure of placement in a specially secured room devoid of dangerous objects is imposed on a prisoner who threatened to commit suicide, which is considered to be absolutely unacceptable. Additionally, despite the fact that the EPSA prescribes that placement in a specially secured room devoid of dangerous objects may not exceed 48 hours at a time, it is unclear in practice what should be the minimum time limit in which the measure could be re-imposed. Likewise, when unequal treatment and unclear legal definition of the types, purpose and reasons for imposing a specific measure of maintaining order and security are concerned, the data collected during our visits in 2013 points to significant differences in the implementation of measures between individual institutions in the prison system. This statement is best illustrated by comparing the data on the implementation of measures in Zagreb County Prison and Lepoglava State Prison, the two high security penal institutions with the largest number of prisoners. According to the data delivered by the Central Office, in 2013 a total of 363 specific measures of maintaining order and security were implemented in Lepoglava State Prison (which on 31 December 2013 had 735 prisoners), while in the same period not a single measure was implemented in Zagreb County Prison (which on 31 December 2013 had 881 persons deprived of liberty, i.e. 146 more than in Lepoglava State Prison). As much as we tried, it was really hard to find a logical reason for such a difference in the number of implemented specific measures between the two largest penal institutions in the Republic of Croatia, and we have to emphasize that it sounds quite unbelievable that during the entire 2013 not a single measure was implemented in Zagreb County Prison, that is, there was not a single case of, for example, imposing a measure of enhanced supervision or handcuffing. Moreover, according to the data collected by inspecting the Register of specific measures of maintaining order and security, in the course of 2012 a total of 68 measures were implemented in Zagreb County Prison. These data may be interpreted in more ways than one, but it would be surely detrimental if they pointed to arbitrariness. As a consequence, our position is that the improvement of the legal framework and clear legal definition of the criteria for imposing individual measures, particularly those that additionally restrict the rights of persons deprived of their liberty, would significantly contribute to a more equal treatment and thus to the strengthening of the rights of persons deprived of their liberty.