The Imprisonment (Temporary Provisions) Act of 1980 was the first statute that allows remanded and sentenced prisoners to be held in police cells, although this confirmed a previous common law power. The pressure of overcrowding on the prison system, at times combined with strikes by prison officers and the destruction of prison cells in riots, has caused police and court cells to be used extensively for most of the last decade. This practice has been a source of continuing concern to policymakers. Police and court cells are not designed to hold prisoners for extended periods. Despite the efforts of police officers to make conditions tolerable in difficult circumstances, facilities for exercise, washing, bathing, and visits are inadequate. In his report on the 1990 prison disturbance, Lord Justice Woolf described conditions in police cells in Manchester as being overcrowded, without natural light, small, overheated, and without sanitation. Exercise for the prisoners was limited to 20 minutes each day. The prisoners spent the major part of the day locked in their cells. Not only are police cells inhumane, they are also costly. The total cost of holding prisoners in police cells during fiscal year 1990-91 was 53.5 million pounds, which is equivalent to the annual cost of running five prisons the size of Dartmoor.