ΑΛΛΗΛΕΓΓΥΗ ΣΤΗΝ ΕΕ: ΕΞΕΛΙΞΕΙΣ ΣΤΟ ΠΕΔΙΟ ΤΗΣ ΠΡΟΣΦΥΓΙΚΗΣ ΠΡΟΣΤΑΣΙΑΣ ΚΑΙ ΠΡΟΚΛΗΣΕΙΣ ΣΤΗΝ ΕΕ ΚΑΙ ΣΤΗΝ ΕΛΛΑΔΑ

Maria Dimitrakopoulou 165 ing water, poor hygiene and safety conditions, with a very high -risk for fire and contagious diseases spread in and outside the site, and the presence of rats and insects inside tents and containers. 59 Hotspots in Lesvos and Chios are also characterized by similarly hazardous condi- tions, with thousands in tents 60 , with already vulnerable people exposed to condi- tions and risks that are dangerous to their physical integrity and well-being, in- cluding sexual and gender based violence (SGBV). Additionally, as of 20 July 2017, almost 8,500 officially recognized vulnerable people were waiting on the islands for their transfer to the mainland. 61 Alternative accommodation and shelter ca- pacity on the islands is extremely limited. For months, the government has taken steps to gradually transfer those who were eligible and wished to be transferred from facilities on the islands to the mainland; however, delays in this process have meant that the authorities are unable to transfer people before the island facili- ties surpass capacity. 62 V. The legal and regulatory framework There is no stand-alone EU legislative instrument regulating hotspots. Nonethe- less, in Greece, Law 4357/2016 63 , which entered into force on 3 April 2016, gov- erns implementation of the EU-Turkey statement, new asylum procedures and op- eration of the hotspots. Under this new law, people can in principle be detained in hotspots for up to three days for identification purposes, though this may be extended up to 25 days if the process is not complete. Appeals against the deten- tion decision must be lodged with the administrative court in the region where the hotspot is located. 59. Save the Children, Children living in abysmal conditions as number of refugees arriving on Greek islands spikes, 22 September 2017, https://www.savethechildren.net/article/ children-living-abysmal-conditions-number-refugees-arriving-greek-islands-spikes, and Joint Letter to Prime Minister Tsipras re Deteriorating Conditions for Asylum Seekers Trapped on theAegean islands, October 2017, https://www.hrw.org/news/2017/10/23/ joint-letter-prime-minister-tsipras-re-deteriorating-conditions-asylum-seekers. 60. UNHCR, Greece Aegean Islands factsheet, October 2017, https://data2.unhcr.org/en/ documents/details/60770. 61. Minutes of the Session of the Special Permanent Committee of Equality, Youth and Human Rights of the 27th of July 2017 focusing on the rights of refugees and asylum seekers. 62. Joint NGO roadmap for more fair and humane policies: Transitioning to a Govern- ment - run refygee and migrant response in Greece (Dec 2017), https://drc.ngo/me- dia/4154531/joint-ngo-roadmap-12122017.pdf. 63. L 4375/2016, Gov. Gazette 51/A/3-4-2016, available at: http://www.refworld.org/ docid/573ad4cb4.html.