Action | Amend the Regulation after Assessment and Receipt of Public Comment |
Stage | NOIRA |
Comment Period | Ended on 10/31/2018 |
1118 comments
I write to oppose the proposed regulations that would require surgical-center style construction and fitting out for abortion facilities. The rather transparent aim of this regulation is to put abortion providers out of business when they can't renovate their facilities to achieve compliance. In so doing, the creators of this regulation believe they will thwart the performance of abortions in Virginia. This is under the guise of 'protecting women' or 'safety' for women.
As a midwife for over 35 years, I can tell you with confidence that the goal of thwarting abortions will not be realized in this manner. Here are some facts:
1. Women have ALWAYS - throughout history - had abortions when they couldn't cope with having a baby.
2. Abortion, when carried out by providers with the knowledge and skills needed for safety, are orders of magnitude safer than carrying a pregnancy to term and giving birth. The major complication rate is extremely small, less than 0.5%. So there is no need to carry out extraordinary renovations for the slight chance of complications, nor is the rationale that tougher physical facility requirements will improve outcomes in any way believable.
3. Making it difficult for women to procure abortion, as the inevitable closure of clinics in the face of the propsed regulation will do, will only drive them to desperate measues such as self-inducing abortion or resorting to unskilled and dangerous practitioners. These are the abortions with high complication rates, including death.
I don't believe that what our state legislators and officials want is more women dying of pregnancy-related causes. So I would urge you to REJECT these absurd regulations
Thank you.
Maryann Long
Please keep abortion safe. I oppose any unncessary restrictions on abortion. It's a woman's right to make decisions about her own healthcare.
Women making this critical decision should not need to travel within the state to get the procedure simply because the State Board of Health wanted to reduce the number of clinics or providers and, most likely, eliminate them all eventually because your requirements are so burdensome.
TRAP Restrictions are used to control women and their bodies. There really is no other purpose but a disquise to curtain abortions which is a women's right.
Roll back burdensome restrictions in TRAP
Do not place medically unnecessary restrictions on abortion clinics. Clinics need to remain in service at low cost to service Virginia's population at all income levels.
Please vote to end TRAP regulations, which are medically unfounded and only work to limit women's access to basic healthcare. Abortions are proven to be safer than giving birth. Abortion is legal and should be accessible, especially in low income communities.
Burdonsome restrictions on the construction/maintenance of facilities dedicated to the health and well being of all women is unnecessary. The existing regulations and rules more than adequately provide for safe procedures for women seeking to terminate a pregnancy. There is no reason other than a political one to add an additional layer of regulations on these faciliities. It is the right of any woman to control her own body and access to facilities is part of that right.
Abortions should be a private matter between a woman and her physician.
Undo the TRAP restrictions on abortion clinics. These are unneccessary and a farce.
TRAP restrictions on Virginia abortion providers are burdensome and medically unnecessary. They encourage all parts of American society to treat women like second class citizens. All health care should follow evidenced-based medicine.
The TRAP laws were enacted for only one reason, to make it more difficult for facilities that perform abortions to exist. There has never been concern by our General Assembly majority for the health and safety of women. This is not about safe and proper medical procedures. This is strickly another impediment to a woman's right to choose and have autonomy over her own body. I strongly urge you to rescind all TRAP regulations. No other legal medical procedure has to face these ridiculous restrictions.
I am writing to urge the Virginia Board of Health to rely on evidence-based medicine and amend the dangerous restrictions on Virginia women's health centers. Thank you.
Rely on evidence-based medicine and amend the sham restrictions on Virginia women's health centers.
Stop funding faith based pregnancy center!
There are many things the Department of Health can focus on to ensure/protect patient health and safety, but this isn't one of them. Regulations and restrictions should match patient care and safety needs. If the focus is on the health and safety of patients, regulations and guidelines should be evidence-based and consistent across the board. Any restrictions for abortion facilities should be comparable to the restrictions on other facilities providing similar non/minimally-invasive outpatient medical procedures that carry a similar level of risk or potential for complications. Women don't want special treatment, they just want the same treatment as everyone else. Additional arbitrary restrictions and bureaucratic red tape targeting abortion providers seems--at most--like an excellent way to waste taxpayer money.
TRAP regulations serve only one agenda, and that’s to restrict abortion. Any Board of Health worth their salt would use only evidence based criteria for healthcare safety across the board. All women in Virginia have a right to have access to a safe abortion in a clinic. Scrap TRAP now.
Please undo unnecessary regulations on abortion clinics. Women will have abortions, and as a nurse, I want them to be safe.
Please amend or withdraw the unnecessary physical restricitons placed on clinics that provide abortion and family planning services for Virginians.
thank you
Regulation of healthare facilities should be based on evidence-based medicine, not political or ideological agendas. Restrictive hospital-style regulations are inappropriate and unnecessary for the low-risk procedures and services provided by outpatient women's health centers. The regulatory process should not be used to resrict women's access to safe abortions, the right to which is protected by the U.S. constitution.
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."
As demonstrated by the horrifying movei Gosnell, and the evidence presented at his trial, Virginia’s abortion facilities need more oversight, not less.
Here are the changes I recommend the Board make:
Inspections of abortion facilities have produced evidence of hundreds of safety violations, one center was even closed after Gov. McAuuliffe's commissioner of Health suspended its license after a 70 pg. report of violations. We must prevent crimes like Dr. Gosnell committed, from happening in Va. by having health and safety standards in place. Reinstate all of the health & safety measures the Board unlawfully watered down during it last amendment process. Reinstate the requirement that the abortion facility ensure that it has removed all of the fetal body parts from inside the female patient upon performance of an abortion. Reinstate the reasonable design & construction standards that provided for hallways wide enough to carry patients out on stretchers in case of emergency. Reinstate the ability of the dept. 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 Ch. 5 of Ttitle 32.1. thank you.
Im the matter at hand both God and I DEMAND YOU TAKE THE FOLOWING ACTION:
Reinstate all of the health and safety measures the Board unlawfully watered down during its last amendment process.
Require all OLC inspections to verify that ultrasounds have been performed at least 24 hours prior to every abortion performed.
Require annual inspections on abortion facilities instead of biennial.
Remove the ability of the Commissioner to grant permanent variances.
Reinstate the definition of "first trimester" as being the first twelve weeks from conception, not "13 weeks and 6 days after last menstrual period."
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."
Reinstate the requirement that abortion facilities provide information on post-abortion counseling to its patients.
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.
Reinstate the requirement that abortion facilities report to OLC any incidents reported to the malpractice insurance carrier.
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.
Sincerely,
Richard W. Firth
With respect the majority of Americans do not agree with these pro abortion policies. If anything the majority approve of placing limits and stricter conditions on abortion policies.
Type ovGod hates hands that shed innocent blood. BAN ABORTION NOW.
It is very callous to disregard the health of women by removing common sense regulations that provide even minimum standards of care and hygiene at abortion clinics. Only the abortionist doctors and their colleagues in the legislature and the executive branch would be clamoring to remove the very meager protections that had been in place under previous abortion clinic regulations. It is hard to believe that any entity that claims to care about women would not want an abortion clinic to meet standards of cleanliness and physical safety and be inspected at a minimum of once a year! Shocking! Read the inspection reports from abortion clinics to find out more about the unsanitary, back alley conditions at many clinics which threaten women’s health. Abortion is not like pulling a tooth. It is a very invasive procedure that brings serious risks to women. If you truly care about women you will want more, not fewer safeguards. It is ironic that there is an effort to weaken protections as the Gosnell movie opens in theaters!
Reinstate all of the health and safety measures the Board unlawfully watered down during its last amendment process.
Dear Board of Health,
Require that Abortion centers make every efforto have strong health and safety rules in place.
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Dear Board of Health,
Please make these changes in our Commonwealth:
I am a life-long resident of Virginia. I have lived over 6 decades in rural Virginia. I am well educated in issues of health and public health ethics; health, public health, mental health, and sexual health policy; and concerns of vulnerable populations with threatened autonomy, threatened access, and threatened dignity in health care services. I am primarly an independent voter - and of course ALL Virginians register 'independently' and not 'by political party'. I listen to all sides on difficult issues and assess validity of evidence, logical strength of arguments, and meaningfulness of the each speaker's engagement with the difficult issues, including their sincere effort to listen to all sides. Regarding 'abortion rights', 'women rights', 'rights of unborn infant', etc there is - as you know - more shouting then listening, more bias and prejudice than consideration of evidence, logic, and respect for the dignity of all persons joining the discussion. So, first: I support the Constitutional protections for women's decisional autonomy regarding each woman's own reproductive health. Just as I support the Constitutional protections for gun owners, Constitutional protections for gay and lesbian married couples and their families under the marriage, etc. 'Anti-abortion' screamers often condemn gay and lesbian people, and others that they don't like, almost in the same breath, when discussing abortion. 'Abortion rights' screamers, in my experience, often condemn faith communities, gun owners, and others, when discussing what they call their 'abortion rights'. I have found that SCREAMERS on BOTH THESE SIDES are often ignorant of important facts, that they intentionally obscure data and other facts, that they are disrespectful of other cultural and moral beliefs that are not their own (but that are nonetheless authentic, important, and valuable) and that they are destructive of helpful engagement in policy discussions, to ensure public policy that reflect the highest ethical values, and conveys the best outcomes for our complex Commonwealth. Please, oh please, think, listen, and speak with respect for all of our human dignity: the dignity of the unborn (who are human beings, no cabbages, or lumps of coal) and the dignity of born children, the dignity of women (who are more than half the human population, and essentlal to the continuing of human life, human families, and human society), the dignity of health care providers (who sacrifice much in service to our human health, family health, and social health), the dignity of voters in the Commonwealth who, are, after all the reason that we have law, policy, and society, and so, you who make law and policy, are not their bosses, but rather we are your bosses. Respectfully, edward, rural resident, public health advocate, human rights advocate
Roll back your "War on Women" by:
If this was veterinary clinic regulations, there would be no comments against them. Don't women deserve better?
Particularly at locations such as the bottom floor of an apartment complex in Alexandria Va. it really is not a medical facility. I do not support abortion in va.
I strongly urge the Board of Health to implement strong health and safety measures that will protect vulnerable women and hold the abortion industry accountable, including to:
I recommend the board make the following changes to increase protections for women and children:
Reinstate all of the health and safety measures the Board unlawfully watered down during its last amendment process. Require all OLC inspections to verify that ultrasounds have been performed at least 24 hours prior to every abortion performed. Require annual inspections on abortion facilities instead of biennial.
Remove the ability of the Commissioner to grant permanent variances. Reinstate the definition of "first trimester" as being the first twelve weeks from conception, not "13 weeks and 6 days after last menstrual period." 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."
Reinstate the requirement that abortion facilities provide information on post-abortion counseling to its patients.
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. Reinstate the requirement that abortion facilities report to OLC any incidents reported to the malpractice insurance carrier. 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.
Why de-regulate failities which are supposed to protect human beings? Without controls, excesses occur much to the detriment of the public health.
There was a time in Virginia when the Government sought to carry out the will of the people. But those of the Humanist religion have no respect for democracy or law as we saw in the Kavanaugh circus/protest/defamation..
Until we can stop this great scourge in our nation, please take common-sense steps to protect vulnerable women and their unborn children. Please do the following:
Medical facilities that perform abortions need clear, strong cleanliness and health standards.
For all pro-death women and men in Virginia, life begins at conception, not when you (mom) births you. Your mom gave you life and didn't kill you. Do you hate your life so much that you want to kill defenseless human beings? An unborn baby (fetus - little one) relies totally on its mother, for nutrition, growth and love while still in the womb and out of the womb.
Women & men - it's not your 'right' to kill another human being (person). It's dysfunctional how once a baby is born, they are a citizen and if one kills the citizen, one goes to prison. Until the baby is delivered from the womb of the mother, Planned Parenthood would have one believe it's a 'blob of tissue'. That's why it's so very important that the pregnant mom have the right to have an ultrasound and the right to see this so called 'blob of tissue', and you will certainly be amazed to discover, the 'blob of tissue' resembles a 'little one' aka development of a baby -- YOUR baby. We (creatures) are endowed by our Creator with a will - a will to be selfless or a will to be selfish. When one annihilates a fetus (Latin for 'little one'), it's because the pregnant mom believes they can't make it on their own, doesn't want to be saddled with a born 'little one', or has no one to turn to for assistance. Usually, they are unaware there are groups that specialize in providing love, support and the ability to carry the baby to term and to be born.
There are non-profit pregnancy centers who open their arms to you, and will provide assistance to get ready for the 'little one', homes for unwed mothers scattered throughout Virginia. There are non-profit homes in many counties in Virginia that provide a place for you and your baby, all the baby necessities that are supplied through generous donors. Most homes have a 2-year limit, but I know of one that doesn't have a restriction, both mom and baby can stay as long as the mom needs to stay. This home offers onsite vocational training or moms can apply for grants to attend community college or online courses. It's not an END -- it's a BEGINNING with your darling baby!
Anytime an instrument of torture is inserted up a woman's vagina and womb, and the unborn fetus (baby) limbs as in arms, legs, body are torned from the baby's body and pulled out of the woman, and then scissors are used to snip the spinal cord at the baby's neck to ensure the baby is dead, this is a surgery. So, why not enforce the same medical standards for any other medical procedure? Sounds logical and shows a deep concern for the women who believe they have no other recourse but to end (abort) their baby.
This weekend, the 'GOSNELL' movie is playing in theaters. Do you remember the newsflash of Dr Gosnell in Philadelphia slums performing abortions on women who had nowhere to turn. He had baby body parts in plastic bags, sewer system clogged, in jars in the refrigerator, and the most putrid and unsanitary business in recent years. Blood saturated the rooms. One woman had to be medevac from his facility and later died. This is how he came to light. Pennsylvania bureaucrats were pro-abortion and turned a blind eye to complaints. He made his choice (selfish) and now he's spending Pennsylvania tax dollars and all his time in a prison cell. All you pro-abortion hardness of heart folks should go see the movie. Maybe, just maybe, the movie will pull at your heart strings to return to as what God made you -- to love as to be loved.
In addition, there are many parents who are unable to conceive a child and would be most willing to adopt your baby. I know a young girl who was unmarried and became pregnant. She was too young to take on the responsbility of raising a child by herself. She made the most beautiful selflless decision in birthing her baby and allowed the baby to be adopted by a couple who had the resources and the love to give her baby. In addition, this family invited her into her baby's life in visiting the family. They didn't cut her off and that's very important for the baby for the baby's mother.
If pro-death (abortion) providers are really sincere and concerned regarding women's health, these 10 statements wouldn't be an issue. I concur with all 10 requirements below:
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
These are changes that I believe the Board should implement:
The lives of the unborn matter as much as any. All abortions should stop! GOD created man in his own image. Man should not destroy what GOD has made.
Please think about what happened with the abortion clinic run by Gosnell. Our state needs strong guidelines to protect vulnerable women who are seeking an abortion. We don’t need a repeat of what happened to women in Godnell’s clinic!