(b) The issuance of instruction No. I-167 of the Minster of the Interior of 23 July 2003 establishing procedures to be followed by the police upon detention of persons at the structural units of the Ministry of the Interior; (c) The setting up of a specialized Human Rights Commission within the National Police Service in August 2000, with a network of regional coordinators; (d) The transfer of the investigation detention facilities to the Ministry of Justice in January 2000; (e) The access given to non-governmental organizations, such as the Bulgarian Helsinki Committee, to visit prisons on a regular basis; (f) The information provided by the representative of the State party during the dialogue that 13 underground investigative detention (pre-trial) facilities were closed in April 2004 and that the State party is seeking urgent solutions for the remaining 5 underground facilities; (g) The cooperation with the European Committee for the Prevention of Torture and Inhuman or Degrading Treatment or Punishment (CPT) and information offered by the representative of the State party that it has authorized the publication of the report on the visit by the CPT in 2002. C. Subjects of concern 32. The Committee expresses concern about the following: (a) The absence in domestic law of a comprehensive definition of torture as set out in article 1 of the Convention; (b) Numerous allegations of ill-treatment of persons in custody, in particular during police interviews, which may amount to torture and which disproportionately affect the Roma; (c) The lack of an independent system to investigate complaints, and that allegations of ill-treatment are not always investigated promptly and impartially, resulting in an apparent situation of impunity for those responsible; (d) The reported lack of prompt and adequate access by persons in custody to legal and medical assistance and to family members, and that access to free legal aid is quite limited and ineffective in practice. Furthermore, the reported inconsistencies in providing the required medical records to detainees hinder their ability to lodge complaints and seek redress; (e) Poor conditions in homes for persons with mental disabilities and the insufficient steps taken thus far by the authorities to address this situation, including the failure to amend the legislation relating to involuntary placement in such an institution for purposes of evaluation and the lack of judicial appeal and review procedures; 20