PP ANNUAL REPORT ON THE PERFORMANCE OF ACTIVITIES OF THE NPM N PM the entire prison system. It is encouraging to note that the Ombudswoman was informed by the Government of the Republic of Croatia (in its Report on the Activities Taken upon the Ombudsman’s Recommendations and the Report on the Ombudsman’s Work for 2011 of April 2013) about the establishment and first activities carried out within this supervision. Furthermore, based on data obtained during the visits of the NPM, we believe that an organisational separation of healthcare provision from the prison system and its integration into the healthcare protection system would significantly contribute to upgrading the quality of healthcare protection. There are fewer healthcare workers employed in prisons and penitentiaries than is envisaged in the valid systematisation which does not take into account the real overcrowding of prisons and penitentiaries but, as a rule, corresponds to their optimal capacities. Therefore, it is not possible to ensure 24-hour coverage of on-duty healthcare workers, which may also result in the violation of the rights of persons deprived of their liberty. In addition, a lack of the necessary number of physicians of particular specialisations (such as psychiatrists, for example) was detected. 3. Normative framework deficiencies A possible cause of torture and other cruel, inhuman or degrading treatment or punishment is deficient of regulations. Although the legislative framework, regardless of the category of persons deprived of their liberty, may generally be assessed as a highly qualitative one, some areas are not sufficiently or precisely regulated, such as the application of special measures of maintaining order and security, or areas related to accommodation conditions in detention units and the like. In practice, such legal loopholes or vague wordings lead to different interpretations which result in unequal treatment of persons deprived of their liberty and this consequently leads to arbitrariness. In such situations, the existing practices and patterns of action, which are not always correct and acceptable, are adopted and they become a rule which may constitute torture or other cruel, inhuman or degrading treatment or punishment. It is justified to believe that in the course of the announced development of a new Enforcement of Prison Sentences Act, as well as other regulations concerning persons deprived of their liberty, special attention will be paid to eliminating such legal gaps. A positive example is the actions taken by the Ministry of the Interior which, at the end of 2012, initiated amendments to the Ordinance on the Admission and Treatment of Arrested and Detained Persons and the Register of Detainees in Detention Units. The aim of the Register was to harmonise the technical conditions of the facilities for the accommodation of persons deprived of their liberty with the CPT recommendations and the actions of the Ministry of Health which, taking into consideration the Ombudsman’s recommendations, started drawing up an integral regulation on the implementation of security measures of obligatory psychiatric and addiction treatment, regardless of where 31