Erik Bodin, Director

Virginia Department of Health, Office of Licensure and Certification

9960 Mayland Drive, Suite 401Richmond, VA 23233

Dear Mr. Bodin,

I am writing today in response to the periodic review and small business impact review of 12VAC5-412, Regulations for the Licensure of Abortion Facilities. I ask that you do not modify, repeal or weaken these regulations.

These regulations are clearly needed to protect women. Despite abortion centers receiving notice about upcoming inspections, over 80 violations were discovered.

Inspectors found an abortion center splattered with blood and improperly storing fetal remains. Several failed to comply with even basic sterilization procedures. Other inspections revealed problems at abortion centers with the storage and dispensing of drugs, including several with expired drugs in stock, and others with improper labeling of drugs. In addition, personnel were not properly trained and procedures were not maintained.

Finally, several abortion centers were cited for local and state building code violations. Abortion centers claim that requiring them to meet certain building standards puts an undue burden on their "business." And for many people concerned with abortion safety, regulating hallways, doorways and other building aspects does not appear at first blush to address women's health. However, in repeated instances paramedics have been unable to assist women who suffer complications of a botched abortion. In the Gosnell case, the woman who died from her abortion, Karnamaya Mongar, died in part because the paramedics were unable to negotiate hallways at Gosnell's abortion center.

The bottom line is that women's safety and health should be a top priority in any surgical procedure, including an abortion. The standards were not implemented on a whim or for political reasons. These standards were the result of an arduous two-year process that was amply reviewed by the Virginia Board of Health. To repeal or weaken these standards places women in harm's way. The safety of Virginian's is this Board's most important consideration.

Sincerely,

Deborah Hawley
9520 Tetotum Rd.

King George, VA 22485

debndanh@yahoo.com