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VULNERABLE374 on account of the pandemic.31 In fact, there has been only one sick person released due to COVID-19 and that release was secured under threat of legal action.32 Hundreds of people listed by CSC as having a low risk of reoffending, who are weeks or months away from their release date, who are old and sick, or who have already been granted a form of release, are still in prison.33 At the same time, overcrowding (known as double-bunking, or placing two people in a cell made for one) remains prevalent in penitentiaries,34 in shocking disregard for the most basic physical distancing rules. The institutional preventive measures made public by CSC include expanding urgent health care while suspending other kinds of health care; providing relevant health information to medical per- sonnel; implementing their “well-established” existing prevention protocols; enhancing cleaning practices; securing more medication and other health supplies; distributing additional soap and hand sani- tizer; and prisoner testing.35 However, emerging evidence shows that these have been poorly implemented.36 The Correctional Investigator noted that PPE and hand sanitizer are only available to staff and not to incarcerated people.37 Physical dis- tancing has generally not been possible. Communal eating, food serv- ing, and group activities have not been suspended in all institutions.38 While CSC has worked towards hiring more health care personnel, 31. Kathleen Harris, “Prisons Watchdog in the Dark on Inmate Early Release Plan to Limit Spread of COVID-19”, CBC News (22 April 2020), online: <perma.cc/ VN6W-UXFD>. 32. Samantha Beattie, “Inmate With Cancer Wins Prison Release During Pandemic. This Is His Story”, Huffington  Post (24 April 2020), online: <perma.cc/2J5W-BEND>. 33. Anthony Doob, Understanding  Imprisonment  in  the  Time  of  COVID-19,  Report [unpublished], (Toronto: University of Toronto, 11 May 2020) at 11–17; Justin Ling, “The Government Said It’s Releasing Many Inmates to Combat COVID-19. It’s Not”, Vice News (1 May 2020), online: <perma.cc/9GTC-A4J5>. 34. Correctional Service Canada, Double-Bunking  in  Canadian  Federal  Corrections, Research in Brief, RIB-18-12 (Ottawa: Correctional Service Canada, October 2018), online: Correctional Service Canada <perma.cc/F6UN-KWYB>. 35. Correctional Service Canada, COVID-19  Preparedness  and  Plans, (Ottawa: Correctional Service Canada, 30 March 2020), online: Correctional Service Canada <perma.cc/2P82-2HQN>. 36. Canada, Office of the Correctional Investigator, COVID-19  Status  Update, (Ottawa: Office of the Correctional Investigator, 23 April 2020) at 3, online: Office  of  the  Correctional  Investigator <perma.cc/DT46-PADV>. 37. Ibid. 38. Snow v Canada, [2020] FC file number T-464-20 (Affidavit, Paul Robert Quick) at 23–37, online: <documentcloud.adobe.com/link/review/?uri=urn%3Aaaid%3Asc ds%3AUS%3Aa0dfe49f-3668-42bb-9e54-88efa9f1bdc1&pageNum=1>.