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Police Commission adopts Early Intervention System policy after tense debate with POA
Summary
The San Francisco Police Commission voted to adopt Department General Order 3.19, establishing an Early Intervention System (EIS) designed to identify at-risk officer behavior and provide supervisory intervention. The vote passed 6-1 after debate over indicators, data access and a POA letter preserving the union's right to challenge future changes.
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The San Francisco Police Commission voted to adopt Department General Order 3.19, an Early Intervention System intended to flag patterns of officer conduct that may require counseling, training or supervisory review. The motion to adopt the order passed in a roll-call vote, 6-1.
The order, presented by Chief Kehane, would create an EIS tailored to local needs and modeled on literature and examples from other cities. Kehane said the system aims to provide supervisors a way to "identify at-risk behaviors when they may become problematic" and to improve accountability while giving officers access to support and training.
Commissioners and outside stakeholders pressed for specific protections and operational details. Commissioner De Jesus cited Professor Sam Walker's work to note that EIS is "officially separate from the formal disciplinary system," intended as counseling, training or coaching, and to request that the commission ensure records are treated accordingly.
Commissioner David Campos asked whether the EIS would withhold data that the department otherwise could access, and pushed for clarity on which events should be classified as indicators (which trigger review) versus associated factors (which are tracked but do not automatically trigger action). Chief Kehane said the department is mapping existing data sources and expects to explain where indicators will be stored and how they will be retrieved without limiting legitimate access.
The Police Officers Association (POA) signaled strong reservations but negotiated a letter-agreement explained by POA general counsel John Tennant. Tennant said the POA would not object to implementation of the specific EIS now before the commission but would preserve the right to contest any future attempts to change the system. "We have the right only to challenge changes," Tennant told the commission, adding the agreement preserves the POA's legal posture under the Government Code.
Advocacy groups, including a representative from the ACLU, said the DGO represents an improvement over the current status quo but urged stronger language on indicators and transparency and asked that the commission hold the department accountable for full implementation and budgeting of the system's technology.
The commission adopted the order after discussion and public comment. President Louise Rennie voted Aye; Vice President David Campos voted No; Commissioners De Jesus, Lee, Marshall, Sparks and Veronese voted Aye. The commission directed staff and the department to provide implementation details and to return with follow-up reporting.
The next procedural step is for department staff to finalize operational guidance and infrastructure plans and provide the commission with a timeline for full implementation and metrics the commission can use to review EIS performance.
