I am a nurse practitioner with a Master of Science in Nursing.  I have been practicing in the Commonwealth for over 40 yrs.  For several years I worked as a nurse in the operating room department.  

I am actually confused as to why these regulations are needed.  Abortion in an outpatient facility has been proven to be safer than any other outpatient surgical procedure.  And it is safer than abortions performed in hospitals.  The physical plant requirements are nothing more than a way of attempting to close outpatient facilities.  Most first trimester abortions are performed under local anesthesia with no "sedation" whatso ever.  These regulations demand an 8 ft hall way to transport patients on gurneys.  Patients receiving local anesthesia are not transported on gurneys.  Also the regualtions require the type of air filtration needed for abdominal and thoracic surgery.  As I am sure everyone on the Board of Health is aware, this procedure is done through the vagina which is not a sterile cavity.

Also these regulations do not differentiate between medical and surgical abortions.  Physical plant requirements are the same for both types of procedure.  Medical abortions require no sedation nor surgical intervention.

If the Board of Health wants to endorse regulations which are centered on evidence based medicine, they should at the very least have input from the professionals who are providing this service.  By  demanding outpatient facilities meet the physical plant requirements of hospitals, you are not protecting the health and welfare of women in the Commonwealth; but, rather limiting access to the procedure and inflicting even more pain and suffering on a woman and her family.

I ask that you re-examine these regulations and re-write them with medical and scientific input.Type over this text and enter your comments here.

approximately 3000 words.