Police detention centres Limited binding power of the Directive on Workplaces However, the Federal Ministry of the Interior also remarked that the working group, when defining those standards that require structural changes to the police detention centre buildings that are several decades old, had chosen the formulation “for new construction, extension and larger conversions”. The NPM emphasised that this restriction is inappropriate and the working group had not included such a condition in the jointly agreed standard. As the working group standard for the toilets in cells for multiple inmates does not contain such a restrictive formulation, the NPM recommended the Federal Ministry of the Interior not to include this formulation in the Directive on Workplaces. The Ministry held out the prospect that this condition would appear several times in the Directive on Workplaces. The reason for this is the clarification in the Directive on Workplaces that the obligation to implement the standards does not come into effect with the release of the Directive on Workplaces or for minor renovation measures. Measures such as the complete separation of all toilets can only be implemented during major, longer-term conversions, as in such cases the police detention centre would have to remain closed for several weeks. The Federal Ministry of the Interior assured that all Police Departments could implement individual working group guidelines or standards from the Directive on Workplaces on smaller construction measures (cell by cell or when repairing damage). The NPM will therefore continue to monitor the implementation of all standards and guidelines of the Ministry that require structural measures. Lockable lockers The Federal Ministry of the Interior reported, as presented in the NPM Report 2019 (p. 158), about the lack of interest on the part of the detainees in St. Pölten police detention centre in the pilot offer of locking the existing lockers in the cells with a padlock. The NPM addressed the Ministry with this topic once again and spoke out in favour of the provision of lockable containers for storing small personal belongings of the detainees in all police detention centres. Shelves planned in Directive on Workplaces The Federal Ministry of the Interior conceded that all of the detainees had been positive about the opportunity to store small personal belongings in the cells during the pilot phase in St. Pölten police detention centre. For this reason, in accordance with the new Directive on Workplaces, there should be the opportunity to place items on shelves in all cells in future provided there is enough space. Where this is not possible, shelves shall be included in new constructions, extensions or conversions. In view of what the Federal Ministry of the Interior has reported, the NPM is looking forward to the release of the new Directive on Workplaces. Realisation of table visits 139 As explained in the NPM Report 2019 (pp. 155 et seq.), the regulations for table visits in the decree on detention enforcement of the Federal Ministry of the Interior of May 2019 deviated greatly from the standards discussed and

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