27 Selected topics from 2019 This attests to a lack of understanding of the role of medical personnel, and a lack of knowledge about the adverse health effects of restraint beds. The supervision logs also showed examples of both prison officers and the prison’s health ­personnel attempting to get inmates placed in restraints transferred to a mental healthcare ­institution, but that this was rejected by the ­specialist health service. Restraint beds and the prohibition against inhuman treatment The requirement of strict necessity The ECtHR requires that the use of restraint belts must be necessary and proportional to prevent immediate harm.30 According to Norwegian ­legislation, the use of restraints must only be employed when strictly necessary to prevent the inmate from hurting him or herself. The straps must be removed immediately when the risk of harm ceases. Less intrusive measures must always be attempted, unless it is obvious that they will have no effect. We found a significant number of decisions regarding the use of restraint beds that lacked adequate reasons. Several decisions lacked an individual description of the specific situation that made the decision necessary. In some prisons, half of the decisions lacked reasons for the use of restraint beds. In total, around half of the eighteen prisons had one or several decisions that contained inadequate reasons. No ­administrative decision has been made in eight of the 82 cases concerning the use of restraint beds. The lack of administrative decisions prevents the ­possibility for the inmate to file a complaint and limits ­appropriate internal control and oversight by external supervisory bodies. A lack of reasons for a decision also constitutes a threat to the legal safeguards of inmates. The requirement of strict necessity applies to the entire restraint process. The ECtHR has established a violation of Article 3 in a case where an inmate, who was described as calm, was not released from the restraint bed.31 ­ This requirement has been violated in a significant number of cases where restraint beds have been used in Norwegian prisons during the past six years. In two of the prisons, inmates were described as calm for most of the time spent in the restraint bed, in all the decisions made. In one prison, this applied to half of the decisions, while in other prisons this applied to several of the decisions. During many of the incidents involving the use of a restraint bed, the inmates slept in the restraint bed. The Parliamentary Ombudsman has in several reports following visits to mental healthcare ­institutions criticised the fact that patients were asleep while in restraints, as patients who are asleep no longer constitute a situation where the requirement of ‘strict necessity’ is fulfilled.32 In some cases, the straps were loosened to let the inmate use the bathroom, make a call or ­shower, before being strapped back into the restraint bed. In these situations, an explanation was not provided for why the person should be placed in restraints again. 30 Bures v. the Czech Republic, application no. 37679/08, judgment of 18 October 2012. 31 Julin v. Estonia, application no. 16563/08, judgment of 29 May 2012. 32 See, inter alia, the Parliamentary Ombudsman's report after visits to Østfold Hospital, psychiatric unit on 9–11 October 2018, Stavanger University Hospital, 9–12 January 2017 and Akershus University Hospital, emergency psychiatry department, 2–4 May 2017.