Delivered to the Portland Police Bureau on April 27, 2015.

This letter includes the Mental Health Association of Portland on changes to PPB policies 850.20, 850.21, 850.22, and 850.25.

In general these policies are excellent and our changes are largely aesthetic, but important nonetheless – especially to the persons our organization tends to represent, persons with mental illness.  We hope you can put this message into the right hands for consideration.

One idea struck us while reading the policy changes. Has the PPB thought of training and deputizing an individual to simply temporarily hold a person in custody just in hospital waiting rooms so that the officer can exchange custody and get back out on the road?

We suggest this does not need to be an officer (it could be a retired officer) but someone who can work with hospital clinical staff and hospital security, keep track of the individual in custody and keep them safe, and get help if needed. It could be an on-call position managed by the hospital or by an agency providing a lower-cost service to the police.

Also, absent from the policies is any mention or remedy for a problem that arose when Jose Mejia Poot was shot and killed: officers carrying lethal arms into a hospital setting. You explained to me that it is not PPB policy for officers to secure their weapons prior to entering a hospital. We think they should – unless there are exigent circumstances.

One more point before our comments.  It concerns language.

PPB policies should differentiate between “mental health” and “mental illness.”  Mental health refers to goals attainable by all individuals.  Mental illness is a medical condition that affects a small number of persons.  Police are not concerned with mental health of others, but rather mental illness, and the troubles that often result.

Facilities that provide secure, 24/7 crisis treatment may call themselves “mental health facilities,” but actually they serve persons who are acutely ill, and not all persons. This naming convention is confusing  – but typical for the industry.  We suggest it be continued by the PPB.

The fairly new term “mental health crisis” indicates a non-specific problem; mental illness, alcohol, drugs – both legal and illegal — dementia, autism, other causes, which may or may not manifest to need for intervention.  Most, not all, crisis do not require intervention. Abrupt action or confrontation of a person in a mental health crisis may cause the person in crisis to harm themselves or others.

We very much appreciate that PPB policy and other PPB language does not include the usage “the mentally ill.” The term “person with mental illness” is more accurate, person-centered, and thoughtful.

Here are our comments on the policies listed above.

850.20, Police Response to Mental Health Crisis

Strike the text below as irrelevant.

Mental health includes our emotional, psychological, and social well-being. It affects how we think, feel, and act. It also helps determine how we handle stress, relate to others, and make choices. Mental health is important at every stage of life, from childhood and adolescence through adulthood.

Mental health complications are medical conditions that change how a person thinks, feels, and acts, and are associated with distress or impaired functioning. When a condition(s) becomes severe, it may be diagnosed as mental illness by mental health providers.

Consider including the most common causes of “mental health crisis” in addition to mental illness in the following statement. These common causes include alcohol, drugs – both legal and illegal – dementia, and autism.

Mental health crisis is an incident in which someone with an actual or perceived mental illness is experiencing intense feelings of personal distress (e.g., anxiety, depression, anger, fear, panic, hopelessness), obvious changes in functioning (e.g., neglect of personal hygiene, unusual behavior) and/or catastrophic life events (e.g., disruptions in personal relationships, support systems or living arrangements; loss of autonomy or parental rights; victimization or natural disasters), which may, but not necessarily, result in an upward trajectory of intensity culminating in thoughts or acts that are dangerous to self and/or others.

Strike the text below as irrelevant and inaccurate.  It would be more relevant and accurate if stated like this, “Due to limited services, members are increasingly required to respond to and intervene on behalf of persons who are in mental health crisis.

Due to limited services, members are increasingly required to respond to and intervene on behalf of persons who are in mental health crisis.

850.21, Peace Officer Custody (Civil)

No comment.

850.22, Police Response to Requests for Mental Health Custody

Delete the word “primarily” from the sentence below. Police have no responsibility for evaluation, diagnosis, and treatment of persons who are in mental health crisis.

In the context of mental health services, mental health providers, not law enforcement, are primarily responsible for the evaluation, diagnosis, and treatment of persons who are in mental health crisis. There are times however, when mental health providers need police services.

Delete the word “primary” from the sentence below. Police have no responsibility to transport persons in mental health crisis to and from health care facilities.

Assisting Facilities (Including Hospitals) with Patients with Mental Illness: It is the primary responsibility of mental health facilities to have the proper resources to manage people in mental health crisis and to transport persons under their supervision to other care facilities.

850.25, Police Response to Mental Health Facilities

Delete the word “primary” from the sentence below. Police have no responsibility for evaluation, diagnosis, and treatment of persons who are in mental health crisis.

It is the primary responsibility of mental health facilities to have the proper resources to manage people in mental health crisis and to transport persons under their supervision to other care facilities.

Include the sentence in BOLD below.

Response to emergencies (Priority 1-3) at designated non-secure residential mental health treatment facilities will include a supervisor and a minimum of two (2) officers, one of which is an ECIT officer, if available.

Unless extreme exigent circumstances exist, members may not enter a non-secure mental health facility or residential mental health facility without notifying their supervisor of the request and coordinating a proper response together.

Unless extreme exigent circumstances exist, members may not enter a secure or non-secure mental health facility or residential mental health facility with lethal weapons.

Thanks for the opportunity to comment on these policies and changes to them. The policies are clearly the result of evolved thinking and consideration for the rights and safety of persons with mental illness.