visiting arrangements remains unimplemented. Unfortunately amendments to the Implementing Rules introduced contactless meetings. The Sliven Prison for Women has introduced a good practice and even lifers meet their relatives without bars during visitations. We have not been able to conduct any reasonable dialogue for six years now with the Ministry of Justice and DG Execution of Punishments as regards the problem with the “extended visiting hours” granted as a bonus that has to take place in family environment but is practiced instead in the detention facility, in the presence of guards and under video surveillance. As regards labour in the places for deprivation of liberty, in 2017 the NPM established discontent in the prison in Sofia due to unenforceable standards in the production of envelopes. The problem appeared following an act of the deputy minister of justice as regards section 1 of Order No. ЛС-04-89 of 25 January 2011, which prescribes that labour standards be determined not according to the production possibilities but the minimum wage instead. The Director General of DG Execution of Punishments, relying on provisions of the Labour Code and the fact that pursuant to Article 250 Labour Code labour standards shall be determined with a view to establishing a normal labour intensity, rightly pointed out that the labour standards were to be determined by the employer. It is expressly specified that “[T]he price of labour shall not be affected by the products’ cost price but by the fluctuations of the minimum wage“. Thus a certain demotivation that was to be expected followed and many inmates refused to produce items with a cost price from BGN 0.04 to 0.09 each and a labour standard of 440 to 500 envelopes. The prison administration tried to handle the situation by imposing unlawful disciplinary sanctions for inmates’ refusing to work. Together with threats that they would not be able to work anywhere else, these sanctions led to a sort of a forced labour. Therefore there has been a grave violation of the right to labour and equitable remuneration, which in combination with the imposed disciplinary sanctions have impaired human dignity or caused fear, insecurity and inferiority. This is why, pursuant to Article 19, para 1, item 4 of the Ombudsman Act, the NPM recommends to the Minister of Justice, including in his capacity of owner of the capital of Prison Production State-Owned Enterprise, to restore the infringed inmates’ labour rights. The NPM established a significant progress in rendering the guards’ instructions in line with the statutory regulation. However, some extremes were also established such as section VI Other Specificities and Activities in the instruction issued by guard no. 1, requires the guard prior to using handcuffs to judge the age, sex, physical and health condition and make an individual risk assessment. The provision of Article 144 EPRCA is completely clear and allows for handcuffs to be used “in case this is strictly necessary because the result would not be achieved otherwise by applying physical force”; specific hypotheses are also mentioned. The law does not require that these directions be regulated in an individual Instruction, all the more so as the officer has no access to the inmate’s risk assessment. The problems established in the Instruction for guard no. 27 persist: a decision as to the use of handcuffs may only be taken by the head of the prison for a certain period of time, and after an assessment of the age, sex, physical and health condition and an individual risk assessment. Article 118 EPRCA provides for the possibility that the commander of the unit on duty issues the orders outside working hours. In the event of a sudden attack or unexpected circumstances, the decision shall be taken by the officer. In any ways, a report shall be drawn for every instance of applied physical force, use of handcuffs or weapon and the respective prosecutor shall be immediately notified. By an order of the deputy minister of justice any such instance should also be put down in a Register of instances of applied physical force or use of handcuffs. 14