CAT/C/BGR/CO/4-5 Access to a fair procedure for asylum-seekers 14. The Committee is concerned that the State party has not taken measures to ensure the implementation of all rights of asylum-seekers and refugees, including issues such as detention and transfer of asylum-seekers, the lack of translation and legal assistance services and the expulsion of foreigners on the basis of national security considerations (arts. 3, 11 and 14). The Committee recommends that the State party: (a) Amend article 16 of the Ordinance for the Responsibilities and Coordination between the State Agency for Refugees, the Directorate of Migration and the Border Police – in order to formally remove the rule that allows for the detention of asylum-seekers on the basis of illegal entry and ensure that asylumseekers enjoy accommodation, documentation, access to health care, social assistance, education and language training, as provided in articles 29 and 30 (a) of the Law on Asylum and Refugees; (b) Ensure that the detention of asylum-seekers is only used as a last resort, when necessary, for as short a period as possible and that safeguards against refoulement are fully implemented; (c) Accelerate the long-awaited opening of the Pastrogor transit centre in order to correct the current practice of transferring asylum-seekers to detention centres because of inadequate reception facilities; (d) Ensure interpretation and translation services at all border crossings and centres dealing with asylum-seekers; (e) Ensure that the State Agency for Refugees reinstate its legal assistance programme and make sure that reports, descriptions of evidence presented by asylum-seekers, minutes and interviews are established in a professional manner. Definition of statelessness 15. The Committee is concerned that the legislation of the State party does not provide for a legal definition of a stateless person and that no legal framework or mechanisms exist to determine the status of such people (arts. 2 and 3). The Committee recommends that the State party consider introducing the definition of a stateless person in its legislation and establish a legal framework and mechanisms to determine statelessness. It encourages the State party to consider acceding to the 1954 Convention relating to the Status of Stateless Persons and the 1961 Convention on the Reduction of Statelessness. Non-refoulement 16. The Committee is concerned that the State party does not fully apply its obligation under article 3 of the Convention with regard to the respect the principle of nonrefoulement (art. 3). The Committee recommends that the State party: (a) Observe the safeguards ensuring respect for the principle of nonrefoulement, including consideration of whether there are substantial grounds indicating that the asylum-seeker might be in danger of torture or ill-treatment upon deportation; (b) Amend its legislation to guarantee a suspensive in-country right of appeal and respect for all safeguards and interim measures with regard to asylum and deportation procedures pending the outcome of the appeals; 5