APPENDIX Dnr O 7-2018 Page 20 (21) my opinion it is insufficient that a more detailed meaning is only stated in the Prison and Probation Service's own regulations, which is currently the case for inmates in prisons. Additionally, it is unacceptable that there are no such provisions at all for remand prisons. As such, this has led to inmates, in some cases, being denied this right altogether or receiving significantly less access to periods of association compared to inmates in other remand prisons or in a prison. In addition, I would like to emphasise that the Remand Prison and Restriction Government Inquiry has also submitted proposals for changes to the Remand Prisons Act with regard to the use of isolation-breaking measures. In short, the proposal means that a provision is added to the Remand Prisons Act that states that an adult who is held on remand with restrictions must always have the right to at least two hours' association with another person every day. Young people are to have a corresponding right of four hours per day.44 The purpose of the provision is to guarantee inmates a certain amount of isolation-breaking measures per day in order to prevent them from becoming isolated. I share the inquiry's assessment that there is a need for such regulation. However, as the inquiry's proposal is formulated, this right will only include inmates who have had restrictions imposed upon them. Even inmates who are kept in segregation risk being isolated. For this reason, this group of inmates should also be entitled to isolation-breaking measures. I am also hesitant regarding a minimum time of only two hours. Based on the UN Standard Minimum Rules for the Treatment of Prisoners, two hours of isolation-breaking efforts constitute precisely the limit where an inmate is considered as being isolated in conditions amounting to solitary confinement. In order to reduce such risks for inmates, in my opinion the minimum requirements in the Swedish Prison and Probation Service should be set higher. I would also like to highlight that the objective, in the opinion of the CPT, should be that all inmates should be given the opportunity to spend at least eight hours a day outside their cells and be provided with the opportunity to participate in meaningful activities of various kinds.45 In my opinion, these opinions should be taken into account in future legislative preparation. Finally, there is reason to reiterate the representation on amending legislation I made to the Government in June 2018, which concerns the need for statutory regulation setting out specific times for reviewing decisions on the placement of inmates in remand prisons. Such specific times are found in the Prisons Act. As far as I understand, there are not any compelling reasons for applying different principles in the prison and remand prison systems in this respect. In the 44 45 See SOU 2016:52 p. 41. See CPT/Inf (2016) 1 para 53. – 101 – C