We respectfully ask:

  1) That the Board reinstate ALL the original health & safety measures (altered during last amendment).

  2) All OLC inspections must that prove ultrasounds were taken at least 24 hrs. before every abortion.

  3) Inspect the facilities annually, not biennially.

  4) Deny the Commissioner authority to grant permanent variances.

  5) Reinstate "first trimester" definition as being 12 weeks from conception, NOT "13 weeks & 6 days after last mentrual period".

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

  7) Reinstate that mandatory information on post-abortion counseling be given to all patients.

  8) Reinstate that the facility MUST ensure that all fetal body parts were removed from the patient during all abortions.

  9) Reinstate that the facility MUST report to OLC any incidents reported to the malractice insurance carrier.

 10) Reinstate design & construction standards for egress; i.e. hallways wide enough to accomodate stretchers for emergency cases.

These are vital minimum requirements for safe abortion facilities. The State of Virginia must be a leader in enforcing safety standards for any and all health facilities within the state boundaries. Thank you very much.