Factory Construction and Activation Manual, FPI – BOP Program Statement 8041.03

U.S. Department of Justice

Federal Bureau of Prisons

Program Statement

OPI: FPI

NUMBER: 8041.03

DATE: 12/11/97

SUBJECT: Factory Construction and Activation Manual – FPI

1. PURPOSE AND SCOPE

To provide guidelines for the design, construction, activation, modification, and deactivation of Federal Prison Industries (FPI) facilities at Federal Bureau of Prisons institutions. The Bureau’s primary correctional program is its industrial work program operated by FPI (trade name UNICOR). To keep pace with projected increases in the inmate population, FPI must prudently expand its operations by activating factories at new facilities, according to procedures outlined by Congress and developed in conjunction with the private sector.

2. PROGRAM OBJECTIVES

The expected results of this program are:

1. A factory at a new institution will be activated in a timely, cost-efficient manner.
2. The Planning, Research and Activation Branch (PRA) will coordinate design and construction activities with other Bureau components.
3. Factory designs will comply with accessibility standards outlined in the Uniform Federal Accessibility Standards (UFAS) and with requirements of the most current edition of the Life Safety Code requirements for Industrial Occupancies. In addition, the designs will comply with Bureau policy on locked doors in a means of egress and property protection.
4. Modifications to FPI standard designs will be identified and made as early as possible.
5. Each contractor will maintain separate cost and billing schedules for FPI construction.
6. An activation plan for each location will be developed, implemented, tracked, and revised as necessary.
7. A Business Plan will be developed whenever a significant operational change is recommended.
8. Each activation will be evaluated six to nine months after the new factory is operational.
9. A deactivation plan will be created to ensure the cost effective deactivation of a FPI plant.

3. DIRECTIVES AFFECTED

Directive Rescinded

PS 8041.02 – FPI Factory Construction and Activation (9/27/95)

Directives Referenced

PS 1237.11 – Information Security Programs (10/24/97)

PS 1600.07 – Occupational Safety and Environmental Health Manual (5/30/96)

PS 4200.09 – Facilities Operations Manual (4/3/96)

PS 5500.09 – Correctional Services Manual (10/27/97)

PS 8000.01 – UNICOR Corporate Policies and Procedures (5/13/81)

PS 8520.02 – Capital Expenditures, Authorization for (Budgeting/Planning) (2/9/96)

TRM 4201.01 – Facilities Development (4/1/96)

4. STANDARDS REFERENCED

American Correctional Association 3rd Edition Standards for Adult Correctional Institutions: 3-4401

American Correctional Association 2nd Edition Standards for Administration of Correctional Agencies: 2-CO-2A-01

The most current editions of the following National Fire Protection Association’s (NFPA) National Fire Codes (NFC’s):

• NFPA 101, the Life Safety Code
• NFPA 13, Standard for the Installation of Sprinkler Systems
• NFPA 231C, Standard for Rack Storage of Materials (for Warehouses)

5. PROCEDURES

The Bureau and FPI shall comply with the guidelines set forth in the Factory Construction and Activation Manual, and any subsequent revisions, when designing, constructing, activating, deactivating, and modifying FPI facilities.

/s/

Kathleen M. Hawk, Director

CHAPTER I – LIAISON WITH BUREAU OF PRISONS FACILITIES COMPONENTS

Planning, Research and Activation (PRA) is the Federal Prison Industries (FPI) branch that communicates with other Bureau components regarding FPI construction, activation, facilities, and deactivation issues. The PRA Manager is the primary FPI contact and coordinator for Bureau facilities programs and initiatives such as Architectural Barriers and Federal Accessibility Standards, Seismic Safety, and Facility Physical Plant Review Program (PPRP), formerly known as Facility Space Utilization Study.

The Facilities Program Coordinator for each of these initiatives shall notify the PRA Manager when any of these programs are implemented at locations with FPI facilities. Additionally, the PRA Manager, in association with the Product Support Center (PSC), shall review any plans developed under these programs that require FPI funding or modifications to FPI buildings or facilities.

Bureau Design and Construction Branch

In order to insure that FPI’s design requirements are included in the overall design, PRA shall work closely with the Bureau’s Design and Construction Branch Project Managers during the design and construction of a new institution and activation. This close association is recommended from the onset of the project. The Bureau Project Manager will act on behalf of FPI and coordinate FPI-related construction issues with project contractors (Architect Engineer and General Contractor) including FPI design changes, contract modifications and monthly progress payments. They will also evaluate contractor proposals and claims. PRA and the Product Support Center shall meet with the contract Architect and Engineering Firm, along with Bureau Project Managers, during the design and development phase to ensure the design criteria for FPI is being followed.

Design Phase

FPI design criteria shall be requested by the Project Manager when the process begins to solicit an architectural and engineering (A&E) firm. The Bureau Project Manager shall notify PRA of the announcement to solicit an A&E firm.

Once completed and reviewed by the Product Support Center, PRA shall forward the FPI design package to the Project Manager to include in the initial project design. FPI design criteria must be submitted to the Bureau Project Manager prior to A&E fee negotiations. Specific factory design procedures are located in Chapter 2 of this Manual.

PRA staff shall meet with the Bureau Project Manager and representatives from the A&E firm during the Conceptual Design Phase and the Design Development Phase to discuss FPI-related design issues and ensure all parties involved in the design are clear on FPI’s construction requirements. Typically, the reviews with the A&E and Bureau Project Manager involving FPI personnel, shall occur at the 10%, 50%, and 90% stages of Design Development/drawing completion.

The Bureau Project Manager shall provide PRA with two complete sets of design drawings at the completion of the Conceptual Phase and at the 50% Design Development stage and at the 90% Design Development stage. During the Design Development Phase, PRA shall work with the PSC to identify product-specific design requirements. Early identification of design changes may eliminate expensive modifications at a later date.

The Bureau Project Manager shall provide PRA with construction cost estimates for FPI’s segment of the project as soon as they become available. These will be used to develop funding projections for presentation to the FPI Board of Directors. As estimates become available throughout the project, the Project Manager shall ensure that FPI-related estimates are provided to PRA.

Construction Phase

Once the design process has been completed, PRA shall maintain contact with the Bureau Project Manager throughout construction. The Project Manager shall provide PRA with two complete sets of final construction drawings and specifications.

Informal progress meetings shall be held to provide an opportunity to exchange information concerning construction. Details regarding progress, delays, and design issues require regular updating. All site questions that emerge during the construction phase shall be forwarded to FPI (PRA) from the Project Manager, for review and decision.

Bureau Activation Coordinators

PRA staff shall periodically exchange updated construction and activation information with Regional and Central Office Bureau Activation Coordinators both telephonically and via the bi-monthly Corporate Factory Activation/Deactivation Update. PRA shall use information obtained from Bureau Project Managers and Activation Coordinators to update the Factory Activation Plan, the Activation Team, and Corporate Management.

CHAPTER II – FACTORY DESIGN PROCEDURES

FPI construction presents situations not common to other areas of project development, which have significant influence on a specific facility design. Market forecasts, the number of inmate jobs needed, and the space required by the manufacturing process ultimately affect factory design.

Ideally, product selection would be made early enough to be considered during the design of the new institution, permitting the design and construction of a product-specific factory. Factors influencing product selection, however, often prevent FPI from committing to a specific product in advance. Thus, the design of new facilities must maintain flexibility.

Factory Design Assessment

Following approval of a new or expanded product, PRA shall forward an industrial design assessment to the PSC and appropriate staff. The design assessment shall be used to develop any special design requirements the specific manufacturing process may have, and to provide accurate information during the design process.

PRA shall use the assessment as a guide when assembling a recommended factory design package. Criteria identified in the assessment shall be included in the design package submitted to the Bureau Project Manager and shall include at a minimum:

• Main factory area square footage.
• FPI warehouse square footage.
• Factory HVAC requirements.
• Modifications (if any) to the standard design program.
• Basic computer/MIS requirements.
• Basic utility requirements.
• Program and Architectural Accessibility Requirements.

Square footage requirements for the main factory floor shall be determined by the PRA based on projected inmate employment and the product proposed for the new institution.

Standard FPI Design Program

For accreditation purposes, all institutional work, industry, and vocational education programs shall meet minimum applicable federal, state, or local work, health, and safety standards. In addition, documentation is required that the programs are inspected by federal, state, or local health and safety officials at least annually. The programs also shall be inspected weekly by qualified departmental staff and monthly by a safety officer.

General Requirements

The FPI factory shall be designed as a pre-engineered metal building. Factory designs shall comply with Bureau policy regarding Seismic Safety, accessibility standards outlined in the Uniform Accessibility Standards (UFAS), and with requirements of the most current edition of the Life Safety Code (NFPA 101) requirements for Industrial Occupancies. The basic factory size shall be no less than 47,500 square feet, with the option to expand the factory to 60,000 square feet, and maintain the specified 100 feet to the perimeter fence. The facility shall be designed as a generic factory.

All FPI utilities, air compressors, etc. shall be configured to use as minimal amount of floor space as possible so as to maximize the remaining floor space for factory usage.

The factory must have the capability of securing inmates in the factory during non-traditional working hours and during periods of fog or inclement weather. The design shall comply with Bureau policy on locked doors as a means of egress and property protection. This requires pressure release locking devices in lieu of panic hardware on all exit doors. Doors and door frames must meet all specifications as defined by the Bureau Correctional Services Manual.

Inmate restrooms shall be provided on the main factory floor and designed to accommodate the number of inmates to be employed at that facility (information to be provided by PRA). Approximately three percent of these facilities shall be handicap accessible. The inmate restroom area shall emphasize privacy without a closable door. Inmate restrooms shall include 1/2 height individual stalls with 1/2 height closable doors. If possible the inmate restroom is to be equipped with a Bradley type hand washing station. Staff restroom facilities shall be provided in these areas as well. Staff restrooms shall have closable, locking doors and must be handicap accessible.

Note: Staff restrooms shall be located in the business office area and the inmate restrooms shall be located off the production floor.

The inmate entrance to the factory shall include adequate space to process inmates through a metal detector and perform searches as inmates enter and leave. A small private area of about 45 square feet shall be accessible from the entrance area for strip searches.

Close attention shall be given to using energy efficient equipment and materials. Significant savings can be realized if energy efficient cooling/heating systems, lighting, etc., are installed during the construction phase. Separate utility meters for each utility shall be included in the design. Whenever possible, all utilities, air compressors, etc., shall be in a configuration that minimizes use of production floor space.

Factory Production Area

Square Footage Requirements

Square footage for the factory shall be approximately 47,500 square feet, with the option to expand to 60,000 square feet, should FPI decide that additional space is required for that specific factory. Building design shall maximize free space between support columns. Support column spacing shall provide minimum spacing of 20′ in one direction and 30′ in the other direction.

Electrical Power Requirements

Service to the factory shall provide a minimum 1,000 amp, 480/277 volts, three-phase service for manufacturing purposes. Electrical boxes shall have the capacity for expansion and the capability to support overhead bus ducts. A 208/120 volt overhead bus duct shall be installed throughout the production floor. All electrical access panels, boxes, and system equipment must be located within secure closets or areas. These items shall be secured in a caged mechanical area other than on the production floor.

Production Area Lighting Requirements

Lighting for the production area shall be designed to support a generic manufacturing environment. An average of 100 foot candles when metered three feet from the factory floor is recommended. Emphasis shall be placed on the use of natural lighting, using skylights and windows around the upper level of the exterior wall when possible. The lighting system should be designed to maximize light dispersion to eliminate shadow casting. Energy conservation measures should be considered during design. Metal halide lighting fixtures are preferred.

Telephone/Data Line Requirements

Telephone receptacles shall be placed on two support columns in each support column row throughout the main factory production area. Placement shall provide uniform spacing between receptacle locations throughout the factory. RJ-45 duplex receptacles shall be installed adjacent to telephone receptacles for data line accessibility. The factory telephone system shall include an intercom and public address/paging system.

Ceiling Height

The main factory area ceiling shall provide an 18-foot minimum clearance from the lighting, HVAC units, and utilities. The ceiling shall be designed to accommodate compressed air lines, electrical busbars/feedrails, any special ventilation required, and the mezzanine office configuration.

Plumbing Requirements

Factory plumbing shall be based upon the needs of a generic manufacturing environment. Drinking fountains shall be designed along the perimeter of the factory floor and shall utilize wall-mounted equipment. Eyewash stations shall be installed in conjunction with drinking fountains. An emergency shower with a floor drain shall be located in the main factory area outside the inmate toilet area. Provisions for adequate floor drains shall be included in the basic factory plumbing package, including placement in toilet facilities and throughout the main factory production area. FPI shall be guided by the A&E firm regarding spacing of floor drains for a light manufacturing environment.

HVAC Systems

HVAC systems shall be designed to maintain a light manufacturing environment, while remaining compatible with the institution’s systems. Air conditioning, and/or evaporative cooling (depending on local environmental conditions), shall be included in the design for the main production floor. All factory support and administrative areas shall be air-conditioned. The temperature range shall be similar to other areas within the institution. The factory shall be provided with its own air handling unit to allow for localized temperature control and ventilation. Heating shall be provided through this air handling unit.

Pneumatic Systems

The factory design shall include an air compressor system. There shall be two, 30 horsepower, screw-type industrial air compressor units. Each shall be capable of maintaining 250 scfm and 125 psi throughout the main factory area. This system shall include cooling apparatus for the compressor and dehumidifying capabilities for compressed air. The compressors shall be located in a secure mechanical room to minimize noise levels. Air lines shall be run overhead between each support column row. Hardware to accommodate drop lines shall be installed at 10-foot intervals along the overhead air lines. Air lines shall be extended down about 50 percent of factory area support columns. Access hardware and shut-off valves shall be installed on all support column air lines.

Fire Protection

A fire protection system shall be hydraulically designed to comply with all the requirements of NFPA 13, 1994 edition. Fire protection coverage shall be placed on the following:

• Main Factory Floor: Extra Hazard
• Load Dock Area: Ordinary Hazard Group 2
• Office Areas: Light Hazard
• M/E Rooms: Ordinary Hazard Group 1

Loading Docks

The loading dock shall support trailer loading/unloading at the factory floor. The width of the dock shall be a minimum of 18 feet. The length of the loading dock shall accommodate all the roll-doors with the exception of the door offering “weather seal” protection. A minimum of two automatic dock levelers shall be included. A minimum of two overhead roll-up doors shall be included. One door should measure a minimum of 12 feet wide and 16 feet high, the second door should be located just past the end of the loading dock and be equipped with “weather seal” protection and sized to accommodate a trailer backed up to the door. A ramp providing forklift access from ground level to the loading dock shall be provided.

A roof covering the loading dock area shall be included in the design. Emphasis shall be placed in lighting the entire loading dock area. The loading dock area shall be equipped to accommodate a minimum of three trailers backed up to the dock at any given time. Additionally, a staging area for approximately two trailers shall also be included. The total space shall be adequate for five trailers to be parked at any given time.

Requirements for the MCS Computer Room

Computer Room

Physical

A separate secured 10′ x 10′ computer room (per Bureau policy) shall be provided in the factory administrative area. The computer room walls shall be of masonry (B walls) or other non-penetrable materials. The door shall be a security metal door without a window and equipped with lock and key. The floor shall be constructed of tiles for anti-static protection. The room will be separated from water storage areas, electrical generators or transformers, telephone services, janitorial areas or other high traffic areas. No windows shall be included in the design for this room.

Environment

The temperature in the computer room must be maintained between 60 and 80 degrees Fahrenheit at all times (24 hours per day). The humidity level will be between 20 – 40 noncondensing. Most central air conditioning systems provide this, however with the heat generated by the computer equipment in a closed room, this temperature is harder to maintain. To offset the extra heat, additional vents from the central air conditioning duct shall be provided in the computer room. The computer room must also have an intake for exhausting warm air.

Electrical

Six dedicated 110 volt grounded receptacles (duplex receptacles) on 30 amp circuits. One dedicated 220 volt single phase, 30 amp circuit terminating in the computer room on a female L14-30R receptacle.

Telephone

The computer room shall be equipped with four telephone connections: a standard office telephone for voice, and three direct four-wire voice and data lines (a.k.a. measured business line) from the institution’s main communication room/De-marc area to the FPI computer room, bypassing any PBX system. All circuits are to terminate on an RJ11 wall plate jack.

Inter-Communication (Work stations within Administrative and Production areas)

Run a three inch conduit from the computer room to a centrally located support pillar in the factory. Leave a “pull-string” in the conduit; FPI will pull the necessary cable at a later date.

Note: All cable must be in conduit.

Wiring Termination: All wiring into the computer room shall terminate on a RJ45/66 punch block.

1. Three cables of shielded, plenum, Cat. 5, eight conductors (twisted pair – four pairs) shall be installed and terminated on a RJ45 triplex jack directly from the FPI computer room to each staff office. Pinning for the RJ45 connector is a standard asynchronous DTE-DCE using IEEE RS-232 electrical interface.
2. Two cables of shielded, plenum, Cat. 5, eight conductors (twisted pair – four pairs) shall be installed and terminated on a RJ45 flush jack directly from the FPI computer room to each inmate desk and/or work area in the administrative area of the factory. Pinning for a RJ45 connector is a standard asynchronous DTE-DCE using IEEE RS-232 electrical interface.

Intra-Communication

Access to the FTS2000 data network, factory, warehouse, camp, and other FPI buildings.

Note: All cables (fiber) must be in conduit.

1. Install six (3 pair) fiber optic cable strands and six pairs of copper wires (data rated, cat. 5) from the main communications room to the FPI computer room. See specifications below.
2. Install six (three pair) fiber optic cable strands and four pairs of copper wires (data rated, cat. 5) from FPI’s computer room to FPI’s warehouse, office area. See specifications below.

Note: If the installation is being made at a complex, or if there are any other FPI buildings, the object is to ensure that all of the different FPI locations within a complex are tied together by fiber optic cable, for computer access. Consequently, the fiber optic cable requirement, described above, must be installed among all FPI facilities at the complex.

Specifications

• Fiber strands shall be multi-mode;
• Operating wavelength is 850nm;
• Fiber strands will be water resistant, gel filled, non-metallic underground, “D” type 62.5/125 micron;
• Operating temperature at -40 degrees Celsius;
• End-to-end fiber loss of no greater than -1db (after interface unit);
• Fiber strands shall be terminated on secure wall interface cabinet (WIC) with connectors and jumper cables;
• Fiber strands shall be terminated on ST connectors;
• Bit Error Rate of 1 in 10⁹ or better;
• Fiber to electrical interfaces for RS-232 using DB25 and V.35 using Winchester DB34;
• Attenuation of electrical interface to fiber is to be no greater than 2db;
• Optical output level from electrical interface is to be no greater than +/- 6db;
• Data rate clocking mechanism is to be bi-directional and controlling.

SENTRY Communication

Per Bureau specifications and policy, the institution LAN system and SENTRY computer access shall be located in the AW(I&E)/SOI’s office and the Business Manager’s office in the administrative area.

Security

All requirements shall comply with Bureau computer security policy. Any computer which has access to BOPNet should be connected to BOPNet with a distinct and separate connection for the FPI network.

Factory Administrative Areas

The administrative area shall consist of approximately 3,000 square feet, located in a mezzanine area above the production floor. The design of this area shall include one office for the Superintendent of Industry (approximately 200 square feet) and may have up to six private offices of approximately 150 square feet, a computer room measuring approximately 100 square feet, and an open office area of approximately 1,000 square feet for inmate clerks and file storage.

A staff conference/break room shall also be included in this design. If possible these rooms should be adjacent, with an accordion wall dividing the rooms. Windows and/or glass storefront shall be included in the offices and the conference room. Placement of the glass should allow for observation of the factory floor while providing modesty panels for staff. Two staff rest rooms (handicapped accessible) shall be provided. In addition, a “janitor” closet with a mop sink shall be provided on the mezzanine level. Two stairways shall be included in the design. One of the stairways shall include an electric chair lift, to meet UFAS requirements. The stair well shall lead directly to the factory floor. The doors leading to the mezzanine office area shall include locks.

Offices located in the administrative area shall be equipped with telephone and computer data line capabilities. RJ-45 duplex receptacles shall be installed adjacent to telephone receptacles for data line accessibility. Offices shall be designed to facilitate supervision of the factory floor and open office area. Window configurations shall maximize visibility of factory operations.

An additional office for the Factory Manager shall be located on the factory floor consisting of approximately 150 square feet and equipped with telephone and computer data line capabilities. RJ-45 duplex receptacles shall be installed adjacent to telephone receptacles for data line accessibility. Offices shall be designed to facilitate supervision of the factory floor. Window configurations shall maximize visibility of factory operations.

There will be two tool rooms located on the factory floor. The rooms will be adjoined by a high security steel door. One room will be a Class A tool room and the other room will be a Class B tool room. To gain access to the Class A tool room, the staff member must first enter the Class B tool room and then unlock the separating high security steel door within the Class B tool room interior wall. The Class B tool room shall be equipped with two pass-through windows sized 12 inches high by 18 inches wide, including service counters. These windows shall be located side by side and equipped with roll-up doors.

Note: Toolroom construction must comply with the Correctional Services Manual.

FPI Warehouse Area

On a case-by-case basis, the decision shall be made whether the FPI warehouse shall be designed as a stand-alone building free from common walls with other buildings, or shall be shared with the institution warehouse. Where the FPI warehouse is a stand-alone unit, it shall be near the institution warehouse. Construction shall generally be similar to a pre-engineered structure (steel frame and shell) on a suitable concrete pad. The warehouse area shall be constructed to be approximately 13,500 square feet of floor space, unless otherwise specified in the addendum. The warehouse should be designed to allow FPI the option to expand the building up to 10,000 sq. ft., should a larger warehouse be required.

Utilities shall be compatible with general institution systems. The utility equipment rooms should be configured to use the minimal amount of floor space possible so as to maximize the floor space for warehouse usage. Air conditioning shall be included in the warehouse office area. The warehouse office shall be approximately 300 square feet, with a glass walled office-within-an-office of approximately 10′ x 10′, included in one corner of the warehouse. The office will require the same telephone and computer requirements as the offices in the factory.

Metal halide or similar lighting shall be installed in this area. Approximately one quarter of the fixtures shall include an instant strike feature. There shall be a minimum ceiling clearance of 20 feet, after installation of lighting, HVAC units, and utilities. Building design shall maximize free space between support columns.

A chain link fenced-in storage area of approximately 300 square feet for “hot” storage shall be included in the design. Access to this area shall be wide enough to accommodate a forklift and loaded shipping pallets.

A drinking fountain, eyewash station, and emergency shower meeting UFAS requirements shall be installed in the FPI warehouse, near the inmate restrooms. Approximately five inmates will be working in this area. A separate unisex staff restroom, meeting UFAS requirements, and a janitor’s mop closet, with mop sink, will also be included in the FPI warehouse.

Loading Docks

Three loading dock doors shall be provided in the warehouse design. When possible, two overhead roll-up doors shall be positioned across the front of the warehouse, near the office area. The doors shall measure a minimum of 12 feet wide and 16 feet high. One of these doors shall be equipped with a “weather seal.” The loading dock shall include a minimum of two automatic dock levelers. The third overhead roll-up door shall be located at the opposite end of the warehouse to facilitate simultaneous shipping and receiving. A ramp shall be included to provide forklift access from ground level to the loading dock.

A roof covering the loading dock area shall be included in the design. Emphasis shall be placed in lighting the entire loading dock area. A concrete turnaround area shall be included in the design to allow for tractor trailers to maneuver easily.

Fire Protection

A fire protection system shall be hydraulically designed to comply with all requirements of NFPA 13, 1996 edition; NFPA 231, 1995 edition (General Storage); and NFPA 231C, 1995 edition (Rack Storage). Fire protection coverage shall be based on the following:

• Warehouse: Extra Hazard
• Distribution Center: Extra Hazard
• Office Area: Light Hazard

CHAPTER III – POST-DESIGN MODIFICATIONS (RETROFITTING FACTORIES)

Bureau construction projects use a standard design program when developing FPI facilities. Ordinarily, this design accommodates most product lines without major modifications. Significant modifications are generally identified during the design review process. This chapter outlines procedures to initiate specific product-related modifications, as required by FPI to accommodate specific product needs.

Design Modifications During Project Construction

PRA shall provide FPI-related design drawings to the PSC and the Associate Warden/Superintendent of Industries (AW/SOI) as soon as they become available. The PSC shall develop a factory layout, with assistance from the AW/SOI, based on these drawings. Required modifications shall be identified as early as possible during this process.

If significant modifications are identified prior to construction completion, the PSC shall submit recommendations to PRA for approval. PRA shall forward the modifications to the Project Manager with a request for cost estimates, which will be used to determine whether it is in FPI’s best interest to pursue the modifications with project contractors.

A decision to proceed with the modifications and to use project contractors requires issuance of an amended Request for Special Authorization (RSA) and Statement of Work as provided by the PSC, that incorporates the additional costs. The RSA, prepared by the PSC, is authorization for the Bureau Project Manager to initiate a contract change order.

The PSC representative will be required to travel to each site to be activated along with a specialist from that particular field. The issues to be addressed while reviewing the site are varying. Examples of items to be reviewed are square footage and factory layout requirements, lighting, accessibility in and out of the production area, air handling systems, electrical provisions, warehouse capacity, pneumatic systems, factory support areas, administrative design, and any other building modifications which are required.

Post-Construction Modifications

Minor retrofitting of new factories to accommodate a specific manufacturing process is to be anticipated. Most modifications should be identified by the PSC and the AW/SOI well in advance of construction completion. If modifications are required, the PSC shall develop a Factory Modification Plan, which shall include:

• An outline of construction modification requirements.
• A scope of work assessment.
• Construction drawings.
• Cost estimates.
• A project timetable.

The PSC shall oversee post-construction modifications. This shall include an assessment to complete modifications in-house. If the PSC is unable to perform such work, they shall initiate the paperwork to procure services and forward to PRA for processing.

If A&E services are required to design the necessary modifications, they shall be solicited by FPI. When necessary, the PSC shall serve as the Contracting Officer’s Technical Representative (COTR). Construction contracting, other than with project contractors, shall be administered by the SOI, with assistance from PSC as necessary.

Alterations to Existing FPI Facilities

The following approval procedures shall be implemented whenever modifications are proposed that will alter or affect any FPI buildings or facilities – including modifications to doors and doorways; walls, floors, or ceilings; or alterations that may change the performance of a utility or mechanical system. Routine maintenance and component replacements are exempt.

Any plan to alter FPI buildings and facilities shall be submitted for review to PRA and the Product Support Center, then forwarded to the Facility Manager for action. The approval process shall include the PSC’s assessment of the effects on current or future manufacturing capabilities. Following the approval process, the plan, with comments and recommendations, shall be submitted to Corporate Management for consideration.

If building or utility system alterations are required, the AW/SOI, with the PSC’s assistance and approval, shall develop an “Alteration Proposal” that complies with UFAS requirements and provisions in the Facilities Operation Manual, Chapters 2 and 3. The proposal shall include:

• A complete written description of all building alterations, number of square feet involved, type of construction, fixed equipment needed, relationship of existing utilities, or addition of new utilities. It shall indicate whether the proposal is an addition, modification, or new structure and whether unusual conditions might complicate the construction process, such as drainage, rock, accessibility, seismic, or life safety.
• A complete written justification indicating why the alteration is necessary. It will have references to Program Review findings, policy deficiencies, space study requirements, additional product development requirements, or management objectives.
• Drawings illustrating the proposed modifications in relation to the existing facility. Enough details shall be provided to give a complete understanding of the project location, scope, and complexity.
• Total estimated funding requirements for design, construction, and project supervision, based on the current construction cost estimating guidelines.
• A project timetable showing estimated start and completion dates and the length of time needed to complete the entire project, allowing time for A&E services, procurement, and special conditions.
• Documentation of Work Programming Committee action.
• A recommended method of compensation to FPI for any diversion of space to non-FPI functions.
• Source of funding for construction costs associated with executing the proposal.

Space Diverted for Non-FPI Purposes

Compensation to FPI for space diverted to non-FPI purposes shall depend on the value of the space diverted, determined on a cost per square foot basis. To obtain this figure, the total cost of construction shall be applied to the total square footage of the building affected. This cost per square foot shall then be applied to the total square footage diverted by the proposal.

If a proposal to divert FPI space is submitted and approved during initial construction of the facility, FPI’s proportionate cost of construction shall be reduced by an amount established by the cost per square foot formula. The Bureau shall assume costs associated with architectural redesign or construction modifications resulting from the diversion proposal.

Compensation for FPI space diverted following initial construction shall be developed through an interagency agreement. The value of the diverted FPI space shall be determined by the cost per square foot formula. This value shall serve as the basis for agreement. The interagency agreement shall focus upon partial or total (depending on the total value of diverted space) relief from FPI’s portion of the institution’s utility expenses. The institution shall assume all costs associated with implementing approved FPI alterations.

A qualified Fire Protection Engineer shall review all design drawings and mission change specifications for renovating existing structures and factories or constructing new structures and factories. The design review shall verify that the design meets all current life safety and fire protection requirements for the building(s) and the operations within.

CHAPTER IV – FPI CONSTRUCTION CONTRACTING AND BILLING

The Construction Contract

The construction contract shall require the contractor to maintain a separate cost and billing schedule for FPI-related construction. Requests by the contractor for payment shall be independent from requests regarding the overall project. This procedure also requires separate documentation to support the invoice. Generally, applications for payments are prepared on AIA (American Institute of Architects) form G-702. A separate form G-702 shall be prepared for FPI construction. Ordinarily, FPI facilities are bid as add/deduct alternates. Bidding as an alternate facilitates an independent FPI construction ledger from the beginning of the project.

Once the contract has been awarded, copies of FPI-related segments shall be forwarded to the FPI Controller. Subsequent change orders or modifications to the contract that apply to FPI shall also be forwarded to PRA.

FPI Construction Cost Estimates

The Bureau Project Manager shall provide PRA with estimates of FPI’s proportionate cost of construction as soon as they become available from the A&E firm. These estimates shall be used in preparing a FPI Board of Directors proposal for use of Bureau B&F funds or a resolution authorizing FPI B&I funding.

Use of Bureau B&F Funds

There are two types of funding for FPI construction projects: Bureau generic inmate work space B&F funds and FPI B&I Funds. In most instances, FPI activations will be funded via the Bureau B&F funds.

Upon bid opening, the Project Manager shall request PRA to submit a memorandum authorizing the use of B&F funds in the amount of FPI’s proportionate cost of construction, based on the construction bid. Signature authority for this memo rests with the PRA Manager.

Use of FPI B&I Funds

When the project is funded using FPI B&I funds, the Project Manager shall request that PRA submit a Request For Special Authorization (RSA) in the amount of FPI’s proportionate cost of construction, based on the construction bid. The RSA, approved by the PRA Manager, or for amounts exceeding $500,000, by the FPI Deputy Assistant Director, shall authorize the expenditure of FPI B&I funds. The Project Manager shall accept FPI-related alternates based upon the approved RSA.

Construction Modifications

Modifications that require additional funds must have prior approval by FPI via memorandum for generic inmate work space B&F funds or RSA for B&I funds. The Project Manager shall request a cost estimate regarding the proposed modification from the A&E firm or construction contractor. This estimate shall be submitted to PRA, which shall ensure the proper means for funding approval is submitted.

Contractor Requests For Payment

Contractor requests for payment regarding FPI-related construction shall be certified through established verification procedures. The Bureau shall make payments to the contractor regarding FPI-related construction through the project and by ordinary B&F project accounting procedures on FPI’s behalf.

If there is an indication that construction costs will exceed the amount FPI originally authorized, the Bureau Project Manager shall submit a request to PRA for additional funding in the amount required to complete construction. The request shall provide details outlining the need for additional funding.

Bureau Reimbursement for FPI B&I Funded Projects

For FPI funded projects, following the payment of an FPI-related construction claim by the Bureau, a request for reimbursement shall immediately be made to the FPI Controller. Copies of the contractor’s invoice, the AIA G-702, and supporting documentation (including project staff certification) shall be made through the On-Line Payment and Collection (OPAC) system.

Construction Settlement Claims

The Bureau Project Manager shall notify PRA whenever a post-construction claim involves FPI construction. At no time shall an agreement be made on behalf of FPI regarding a construction settlement without authorization. Any additional funds required by a construction settlement shall require FPI approval.

CHAPTER V – THE FACTORY ACTIVATION PROGRAM

The PRA Branch was created to activate and deactivate factories in the most cost-efficient manner. To achieve its mission, PRA developed a program to standardize and document guidelines for uniform, complete activations.

The Project Review Group

Prior to Corporate Management’s product approval for a new factory, and prior to any capital expenditure, a project review group, including representatives from the relevant components, such as the PSC; Planning, Research, and Activation (PRA) Branch; Financial Management Division; Quality and Engineering; and Program Management, shall conduct a thorough, critical review of proposed operations.

The Project Group shall conduct an objective review of the proposed product line(s) and factory(s) in areas such as:

• Factory/warehouse square footage requirements.
• Civilian/inmate staffing requirements.
• Cost of construction.
• Overhead calculations.
• Feasibility studies.

A final report of the group’s findings and recommendations shall include a projected Business Plan for the new factory. The project group shall ensure an objective review of proposed factory operations by people with backgrounds in relevant market, financial, and capital investment areas.

The Factory Activation Date

The factory activation date is defined as when FPI begins receiving inmates. This date is initially established by adding three months to the anticipated inmate arrival date to the facility. The activation team may refine it during the activation process, as it is dependent upon construction progress.

Factory Activation Plan

An individual activation plan shall be developed for each new location, outlining the several tasks needing to be accomplished for the successful activation of the factory. About 13 months before the anticipated activation date, PRA shall distribute the general factory activation plan to the managers identified as Factory Activation Team members. Team members shall review and modify the general plan template to create an accurate, factory-specific activation plan on a “best information” basis. Changes are to be anticipated as the project develops.

The initial review objective is to initiate activation planning and identify those responsible for completing each task. Each team member shall complete the following during initial review:

• Add additional tasks to the plan if they are essential to opening the new factory. Delete tasks that do not apply.
• Assign resources (generally the branch/institution manager or persons with primary responsibility for completing the task). Make appropriate recommendations or changes.
• Indicate an estimated time frame (number of work days required to complete each task).
• Develop an anticipated start date for each task.

Upon completing the review, team members return the schedule (with changes noted) to PRA, which incorporates the changes into an initial factory activation plan.

The Factory Activation Team

The activation team develops and administers the activation plan, and includes the following staff:

• Factory Activation Specialist (committee chair).
• Sr. Program Manager and Program Manager(s).
• Controller.
• Materials Management Branch Chief.
• Planning, Research, and Activation Branch Manager.
• FPI Personnel Management Specialist.
• Management Information Systems Branch Manager.
• Product Support Center Manager.
• Customer Services and Marketing Productions Branch Manager.
• Quality and Engineering Branch Chief.
• Associate Warden (I&E)/Superintendent of Industries. (To join Activation Team once selected.)

Following review of the activation plan by team members, PRA shall set a date for an initial meeting, generally 12 months before the anticipated activation date. During this meeting, the activation plan shall be further refined; the team shall also establish a new projected activation date based on construction progress.

Support branch managers shall participate in the initial meeting. Following the meeting, a staff member may be appointed to represent the branch manager at planning sessions and meetings. This appointee shall be the representative throughout the activation process; however, the branch manager shall remain the responsible resource.

Updating and Tracking The Factory Activation Plan

The schedule developed at the initial team meeting shall be used to monitor progress. FPI shall use project management software, maintained by PRA staff, to create and track each activation. PRA staff shall update individual plans from information obtained from team members and information provided by Bureau Project Manager and Regional Activation Coordinators.

Periodically, the Activation Specialist shall distribute a current copy of the plan to each team member, who shall review it and update tasks for which he/she is responsible. These updates can be in the form of percent complete, start date, completion date, or duration. The updated schedule shall be returned to PRA to incorporate into the plan. PRA shall provide guidance in plan analysis and updating during team meetings.

Selection of the AW/SOI initiates several events in the activation process. PRA shall forward an activation package to the AW/SOI, including a FPI activation manual, the initial activation plan, and a set of construction drawings. The FPI Personnel Management Specialist shall include in this package an outline of general personnel guidelines to assist the new AW/SOI in hiring staff.

A team meeting shall include the new AW/SOI, once a selection has been made. Following this meeting, updates to the plan are required monthly. The Assistant Director, IE&VT, shall be apprised of progress based on the activation updates.

The team shall place particular emphasis on the personnel section of the activation plan. Staffing tasks require close monitoring, as they reflect actual dates when personnel actions, including reporting dates, occur. This section of the plan is directly affected by changes in anticipated activation date and is intended to minimize the factory’s initial overhead by maintaining staffing close to production start-up. Staff reporting dates should follow PRA-established general guidelines, with exceptions made on a case-by-case basis. The following time frames are to be used only as guidelines:

• AW/SOI – 9 months prior
• BUSINESS MANAGER/PLANT CONTROLLER – 8 months prior
• FACTORY MANAGER – 7 months prior
• CONTRACT SPECIALIST – 7 months prior
• SYSTEMS ADMINISTRATOR – 7 months prior
• WAREHOUSE FOREMAN – 7 months prior
• ACCOUNTANT – 6 months prior
• FACTORY FOREMAN – 5 months prior (2 per month)
• QUALITY ASSURANCE MANAGER – 5 months prior
• ASSISTANT FACTORY MANAGER – 2 months after activation
• SECOND WAREHOUSE FOREMAN – 2 months after activation

The Factory Business Plan

A new or revised Business Plan is required whenever a significant change in operations is recommended or occurs at an individual factory. Specific events that cause development or re-evaluation of the factory Business Plan include:

• Activation of a new factory.
• Relocation, or in some cases the closure of an existing factory.
• An expansion of current operations, necessitating significant new equipment.
• Introduction of a new product line, or a substantial change in the factory product mix.

The PRA Branch, in conjunction with the appropriate Program Manager(s), shall prepare a Business Plan as part of the new product development process. The PRA Branch, Financial Management Branch, PSC, Program Managers, and factory staff shall be used to prepare a Business Plan.

The PRA Branch has primary responsibility for developing the Business Plan, which includes the Five-Year and Break-Even Income Statements (with supporting documentation) when an existing factory operation is relocated or significantly modified. Development of a revised plan shall begin as soon as a product is selected, a location is approved, or another significant change is identified.

Both the Five-Year and Break-Even Income Statements follow the same format and include essentially the same support information. The Five-Year Income Statement presents information in annual increments, while the Break-Even Income Statement displays data in quarterly segments. Elements necessary to develop a Business Plan can be derived from financial reports from similar operations as well as from knowledgeable staff.

Business Plan/Activation Budget Elements

• General. Location, initialization date, and factory(s) involved.
• Sales. Information related to estimated sales levels, capacity utilization, and inflationary impact on the periods displayed.
• Capital Requirements. Factory and warehouse space requirements for each factory and support operation are to be identified by the Product Support Center and the costs involved indicated. Pertinent information and the cost of capital equipment shall be listed. Depreciation schedules indicating depreciation period lengths and monthly and annual depreciation amounts to be charged shall be established.
• Expense Data Source Report. Source and background support information to explain the derivation of overhead cost estimates and other factors affecting the financial performance of the operation.

Activation Budget

Once the AW/SOI is selected, the activation team shall consider and develop the actual costs associated with the activation. During the first meeting with the AW/SOI, general parameters shall be established, for which the AW/SOI shall develop specific line item figures. The PRA Business Plan shall be used as the baseline for the activation.

The FMB team representative shall provide PRA with a monthly financial status report. PRA shall investigate any departures from the budget and may seek justification from the AW/SOI.

Product Support Center Responsibilities

Upon publication of the factory business plan from the Central Office, the PSC representative will develop a production schedule which is to support the inmate employment requirements, sales, and profits. The schedule will include production output from week one, first article through full production. Additionally, a manpower analysis will be included for both staff and inmates.

The PSC representative will identify various training activities, either from existing factories or private industry, arrange expert visits, MISB, and PSC on-site training. If required, a visit to a factory producing similar products will be initiated. The PSC will identify these sites; however, it is the responsibility of the AW/SOI to schedule the visit.

Based upon the customer contract, the PSC’s Product Development Center will provide assistance with first article production and work instructions, inclusive of Quality Assurance requirements (i.e., appropriate Mil-Specs, Federal Standards, etc.).

Upon retrieval of construction drawings and notification of product from PRA, representatives from the Product Support Center will conduct a site visit for all planned facilities.

Deliverables required for a complete activation plan are as follows:

• PRA will supply the PSC an approved set of construction blueprints from the Design and Construction Branch of the Bureau.
• The Product Support Center will provide, upon notification of product and retrieval of construction drawings from PRA, an equipment listing and factory layout. This shall include make, model, quantity, power requirements, costs, number on hand, and a floor plan of the factory with equipment placement.
• The Product Support Center representative will provide a Request for Special Authorization (FPI Form 27) and Request for Contract Action (FPI Form 89b) for both the A&E firm and equipment. Included with the PSC’s submission will be a phase timetable (e.g. 3 months, 6 months, 12 months) for acquisition of equipment in a just-in-time basis, which shall facilitate minimizing factory start-up costs.
• The Product Support Center representative will develop a production plan upon publication of the factory business plan.
• Manpower analysis.

Upon notification of deactivation of factory and identification of activation at a new site, the PSC representative and PRA specialist shall conduct a site visit to each location involved. An estimate for cost and time required will be provided by the PSC representative for transfer of equipment. Additionally, identification of equipment in idle status will be performed.

If, upon review of the existing equipment, it is understood the machinery is of no value, PRA will be notified and will also be notified of subsequent advisement of disbursement.

CHAPTER VI – EVALUATING THE ACTIVATION PROCESS

The FPI activation process is not unlike other strategic planning procedures the Bureau uses. Its success largely depends upon an ability to incorporate improvements learned from staff actually involved in activating new factories. The process is frequently subject to revision to remain abreast of industry standards and changing operational environments.

The process assumes the activation program can be improved with each new activation. Staff involved in developing the new factory to production and ultimately to a break-even point or point of profitability will have significant insights into areas that may improve activation. To capitalize on this experience, the FPI Post-Activation Survey has been developed.

Post-Activation Survey

About six months after the factory has reached significant operation, PRA shall forward a Post-Activation Survey to the Warden, AW/SOI, and factory Department Heads. The survey should be completed with absolute candor, as its sole purpose is to identify improvements to the activation process.

Post-Activation Review

Soon after receiving the completed surveys, PRA shall assemble a Post-Activation Review Team (ordinarily, the same as the Activation Team). Results of the survey shall be distributed to each team member to guide a final review of the activation process.

The objectives are to learn the experiences of staff and identify areas that may be improved. The process shall include discussions with line staff, Department Heads, the AW/SOI, and the Warden.

Through this process, recommendations and constructive criticism obtained from factory activations will be incorporated into the planning process, in order to improve the effectiveness of future activations.

CHAPTER VII – DEACTIVATING A FACTORY OPERATION

Periodically, FPI is faced with circumstances that require the closure or relocation of existing factory operations. When this occurs, the Deactivation Specialist works directly with the affected AW/SOI to develop a deactivation plan, which shall be used to monitor a factory closure or relocation. It shall encompass FPI staffing and personnel issues, disposition of FPI assets, and the transfer of customer orders.

In addition, a Deactivation Team, consisting of the Deactivation Specialist, AW/SOI, Chief of Quality and Engineering, and Program Manager, shall be created to facilitate the deactivation process. The sensitive nature of this activity requires complete integrity in communications. Thus, all communications regarding a deactivation must be coordinated through the Deactivation Specialist.

The Factory Deactivation Plan

These guidelines were developed to assist the AW/SOI and Deactivation Specialist during deactivation planning. The AW/SOI, with the assistance of the Product Support Center and Program Manager, shall draft a transition plan. This plan shall be submitted to the Deactivation Specialist, who shall incorporate it into the project schedule.

Scope of Deactivation

Corporate Management shall decide the nature of deactivation at the affected factory. This decision shall dictate personnel procedures to be followed and help set a date for factory closure/transfer. When the operation will be relocated, this date shall normally correspond with the new factory’s activation date. If the product line is to be phased out permanently, the AW/SOI and Program Manager shall estimate this date based on the factory’s remaining backlog.

Notification Process

Once Corporate Management determines the nature of deactivation and a date is established, the Deactivation Specialist shall ensure that proper officials are notified in writing: Labor Management Relations officials, Bureau Personnel Director, Regional Director, Warden, National and Local union officials, and Congressional representatives.

Staffing and Personnel Issues

The Deactivation Team shall review existing staffing and develop a revised staffing plan to meet the needs of the corporation. A number of steps shall be followed to minimize any negative impact on staff, including:

• Notifying institution FPI staff of plans to close/relocate the factory as early as possible. Ordinarily, the Deputy Assistant Director, Program Manager, and Deactivation Specialist make a personal visit to the affected institution shortly after the announcement to close/relocate the factory to give staff the opportunity to ask questions.
• Establishing a list of affected staff and developing a projected time frame over which individual positions will be abolished/relocated. The AW/SOI shall develop this list with the assistance of the Deactivation Team.
• Exploring potential opportunities, including those at other FPI locations, for affected staff. The Deactivation Team shall work closely with Corporate Management, the Warden, and affected staff to ensure all options are exhausted before any adverse personnel action is taken.

Transfer of Customer Orders

The AW/SOI shall identify any customer orders that cannot be completed prior to deactivation, ensuring their timely transfer to other FPI factories or providing a waiver to the customer. The highest priority shall be placed on satisfying customer needs while deactivating a factory.

Disposition of FPI Assets

The deactivation plan shall list all major equipment items in the affected factory and recommend a disposition for each.

Major equipment shall ordinarily be relocated to the institution receiving the product line. If a product is being phased out permanently, or the receiving institution does not need the equipment, the AW/SOI, with the assistance from the Program Manager, and Product Support Center (PSC) shall recommend a disposition in the deactivation plan.

The PSC representative in conjunction with the Program Manager, is required to perform various tasks with the deactivation of factories. These assignments include disposition of FPI assets, developing a transition schedule (including cost and timeliness for the transfer of inventory and equipment), and ensuring the equipment will be used for production purposes at another site to be activated or an existing FPI factory. If, upon review of the existing equipment, it is understood the machinery is of no value, PRA will be notified and will also be notified of subsequent advisement of disbursement.

Raw materials, supplies, and operational inventories shall be exhausted during the phase-down of production. Remaining inventories shall ordinarily be transferred to the new location with major equipment and the product line. The AW/SOI shall list significant inventory items and recommend a disposition in the deactivation plan.

Planning for the disposition of buildings and facilities shall begin immediately following a decision to deactivate. If no replacement operation is planned, negotiations shall begin with the institution regarding possible acquisition of FPI facilities, including transfer of FPI facilities-related overhead.

This format shall be used to guide the development of a deactivation plan. Each location presents unique issues that may require additional tasks. It is not the intent to limit a deactivation plan to only the issues addressed here.

Published Feb 8, 2025 by Christopher Zoukis, JD, MBA | Last Updated by Christopher Zoukis, JD, MBA on Feb 18, 2025 at 5:47 pm