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was faulty, but given the breadth of the cases and complexity of the problems, the EPD was limited in terms of resources devoted to the cases. An outside review would undoubtedly have the effect of increasing public confidence as well. Recommendation No. 55: The intake process and coding of complaints needs to be formally established and clarified. Discussion: The EPD has made great strides in establishing the requirement to number and track all inquiries along with complaints. This captures much needed information useful for policy review, future training, and public education. This is only a first step. The department should consider the creation of a formal early warning system (EWS). An EWS is a non- disciplinary system designed to track complaints made against officers. A well-designed EWS collects information about all allegations and complaints lodged with the department, regardless if sustained or not. Thresholds are established to alert managers to officers who may be at risk or who might benefit from outside assistance. For example, one system design might raise an alert when an officer has been the subject of four discourtesy complaints in a six-month period. Even if none of the cases were sustained, the system quietly alerts key managers that there may be a problem outside of realm of discipline. It may indicate a need for training or perhaps simply a discussion to see if the officer could benefit from an employee assistance referral. Again, strictly not disciplinary in any way, the intent is to intervene before a more significant problem develops. Recommendation No. 56: All personnel assigned to the IA function must receive comprehensive training on how to conduct internal investigations, 84