A/HRC/15/47 ILO, OHCHR prepared comments based on the international standards regarding the rights of prisoners and good practices in prison management, which were submitted in June 2010. The Office also provided advice for the review of the Royal Decree on the Separate Status of Prison Staff, and recommendations for amendments to specific Prison Procedures, such as those pertaining to health and sanitation or labour in prison. 52. Wider criminal justice legislation also impacts on detention. The Office drew to the attention of the authorities provisions of the new Penal Code which are likely to increase the growth rate of the prison population. Over the past 15 years, the prison population has grown at an annual rate of 8 to 13 per cent. Prison overcrowding is one of the main challenges faced by the prison authorities in carrying out their mission, threatening to undermine reform progress, and by prisoners who live in congested cells, with often less than two square metres per person and too little time outside their cells. 53. Human resources determine any process of reform. While policies have been developed at a senior level, the General Department of Prisons (GDP) is faced with a gap at the operational level, where insufficiently trained or untrained personnel are required to translate these reforms into daily practice. In consultation with outside actors involved in the prison sector, in particular the Cambodia Criminal Justice Assistance Programme (CCJAP) of AusAID (the Australian Government’s overseas aid programme), OHCHR has been working with the Steering Committee on Prison Staff Training, set up by the Ministry in January 2010. The Office started developing a comprehensive training plan and curriculum for all categories of prison staff, both for new recruits and for existing staff promoted to new responsibilities, for implementation from 2011 onwards. In parallel, it has also sought to help address more immediate needs such as developing a pool of prison trainers, or designing a short training plan for around 650 prison guards who have not had any training since their recruitment up to three years ago. 54. The primary goal of the programme is to ensure that the human rights of prisoners are promoted and protected. Regular monitoring of prisons is an essential tool for achieving this goal. The programme seeks to critically assess conditions of detention and prisoners’ treatment, identify good practices developed in some prisons in order to promote them in others, understand the reasons behind specific problems or patterns of abuse in order to address them systemically, and draw the attention of prison authorities to these issues. The Office continued to enjoy the full cooperation of the prison authorities in accessing the prisons and holding confidential interviews with prisoners and staff. Between June 2009 and August 2010, it conducted five new assessment visits to provincial prisons in Prey Veng, Mondolkiri, and Kampong Speu, and to Correctional Centres No. 3 and 4, then accommodating a total of around 2,000 prisoners. During the same period, it also carried out over 35 follow-up visits to prisons in eight provinces and the four national Correctional Centres, accounting together for 70 per cent of the prison population. Prison authorities have welcomed OHCHR’s constructive approach. The quality of dialogue on difficult issues raised by the Office as part of its confidential reporting to the Government has been constant. 55. Solutions to several problems identified have progressed over the last year, thanks to the commitment of governmental and non-governmental actors involved in the sector. The revised sub-decree regulating prisoners’ rations and cell equipment, which almost doubled the daily food allocation per detainee (from the equivalent of US$ 0.37 to US$ 0.70), was issued in June 2009, and funds were disbursed from September onwards. The Ministries of Interior and Health also agreed in early 2010 that healthcare in prison fell under the Ministry of Health: prison dispensaries were officially considered as “health posts”, to be supported by the relevant public health structures in terms of supply of medicine and medical training for prison health-care staff. While expected improvements at prison level have been slow, in part due to the limited resources of the public health system, this 13