Rather than further water down existing health and safety measures, I urge the Board of Health to heed the following recommendations. Women deserve to know that centers performing surgical procedures in our state meet basic health and safety standards The Board owes it to women to ensure compliance with basic sterlization procedures, periodic inspections, and reasonable oversight measures. 

1. Reinstate all of the health and safety measures the Board unlawfully watered down during its last amendment process. 

2. Require all OLC inspections to verify that ultrasounds have been performed at least 24 hours prior to every abortion performed. 

3. Require annual inspections on abortion facilities instead of biennial. 

4. Remove the ability of the Commissioner to grant permanent variances.

5. Reinstate the definition of "first trimester" as being the first twelve weeks from conception, not "13 weeks and 6 days after last menstrual period." 

6. Reinstate the ability of the department to deny, suspend, or revoke the license to operate an abortion facility for violating "any provision of Article 1 (§ 32.1-123 et seq.) of Chapter 5 of Title 32.1."

7. Reinstate the requirement that abortion facilities provide information on post-abortion counseling to its patients.

8. Reinstate the requirement that the abortion facility ensure that it has removed all of the fetal body parts from inside of the female patient upon the performance of an abortion. 

9. Reinstate the requirement that abortion facilities report to OLC any incidents reported to the malpractice insurance carrier.

10. Reinstate the reasonable design and construction standards that provided for things such as hallways wide enough to carry patients out on stretchers in cases of emergency.