Special Report to the Storting Document 4:3 (2018–2019) 60 9 Solitary confinement in ­security cells or restraint beds Human rights standards on the use of special security regimes When considering whether Article 3 on torture and other cruel, inhuman or degrading treatment or punishment has been violated, the European Court of Human Rights stresses, among other things, the extent of human contact and sensory deprivation, the physical conditions, the duration of solitary confinement and how the inmate responds to being held in isolation.193 The use of security cells is a particularly intrusive form of solitary confinement entailing a very high degree of sensory deprivation. This increases the risk of violation of the prohibition against torture and inhuman treatment. The CPT has developed standards specifically aimed at the material conditions in such cells and the right to health care.194 Following its visit to Norway in 2018, the committee also issued specific recommendations relating to the size of the cells, distribution of meals to security cell inmates, clothing and daily follow-up by the health service.195 Under Section 38 second paragraph of the Execution of Sentences Act, coercive measures shall only be used ‘if the circumstances make this strictly necessary, and less forceful measures have been attempted in vain or will obviously be inadequate’. According to figures from the Directorate of the ­Norwegian Correctional Service, 334 administrative decisions were made on the use of security cells in 2018. In several prisons visited by the Parliamentary Ombudsman, the supervision protocols showed that some inmates had been placed in security cells without an ­administrative decision.196 The actual figure must therefore be assumed to be somewhat higher. According to the figures, there were four administrative decisions for placement in security cells for periods of more than six days in 2018, the longest of which was for 16 days. During our visits, we have also seen cases of prolonged isolation in security cells. In one prison, the longest stay lasted as much as 12 days. In several other prisons, we have found inmates confined to a security cell for four to six days. In the case of minors, the requirements are even stricter: A security cell may only be used if absolutely necessary, for the shortest possible period and subject to continuous monitoring. 193 ECtHR 10 April 2012 Babar Ahmad v. the United Kingdom, paragraphs 205–209; and 21 June 2005 Rohde v. Denmark, paragraph 93. 194 Council of Europe: Committee for the Prevention of Torture (CPT), 21st General Report, 10 November 2011, CPT/Inf (2011) 28, paragraphs 56 and 60. 195 Council of Europe: Committee for the Prevention of Torture (CPT), Report to the Norwegian Government on the visit to Norway 2018, CPT/Inf (2019) 1, paragraphs 107–110. 196 The Parliamentary Ombudsman’s reports after its visits to Bergen Prison 4–6 November 2014, p. 9; to Telemark Prison, Skien branch 2–4 June 2015, pp. 9–10; to Ullersmo Prison 29–31 August 2017, p. 20 ff. 61 ‹ 9