improvements there should be some sort of consequence or sanction, financial or otherwise, issued by the CoE. Ordinary prisons should not hold migration detainees. The EU should establish an independent body of researchers to conduct studies and site visits to ensure compliance regarding detention facilities. Such studies and reports should not be handled by a State’s Ministry of Interior, since it lacks neutrality and could be biased. There needs to be a uniformed definition of “specialized facilities” alongside the prohibition on the use of ordinary prisons as detention facilities. Such definition may be broad, so as to leave it to the State to decide on an acceptable facility, but should include an exhaustive list of possibilities by looking at all the different facilities States have used and determining those that meet the definition. The EU should also amend the Directives in order to allow for easier access to the CJEU based on violations regarding the use of ordinary prisons instead of specialized facilities. The CJEU or some other EU institution should make advisory opinions on what it deems a specialized facility for detention. Recently, there has been criticism that certain camps in Greece subject detainees to ordinary prison-like conditions, including refusing asylum claims, sending people to Turkey without following proper procedures, and by violating the principle of non-refoulement.133 The EU must explicitly state that ordinary-prison like conditions are not sufficient living conditions for applicants, as they differ in procedural guarantees and standards. The EU must further ensure that State authorities are not responsible or negligent for the result of such conditions. The RD explicitly states that countries must respect the principle of non-refoulement and may not 133 Blanket detention in deplorable conditions on the Greek Islands, EUROPEAN COUNCIL ON REFUGEES AND EXILES (Apr. 15, 2016), http://www.ecre.org/blanket-detention-in-deplorable-conditions-on-the-greek-islands/ 39