Virginia Regulatory Town Hall
Agency
Virginia Department of Health
 
Board
State Board of Health
 
chapter
Regulations for Licensure of Abortion Facilities [12 VAC 5 ‑ 412]
Action Amend Regulations Following Periodic Review
Stage NOIRA
Comment Period Ended on 2/11/2015
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2/9/15  8:19 pm
Commenter: William Nelson, MD

The regulations must be amended
 

The current regulations governing the conduct of abortions in Virgina must be amended. They are onerous, restrictive, and not based on fact or science.   They impose a burden on women seeking abortion by closing clinics and limiting access, when no such burden is placed on women for any other outpatient medical procedure.  They address neither safety nor accesibility.   Numerous commenters refer to the deaths and damage to women caused by abortion clinics,  but this claim is simply not true.  Out patien abortion remains one of the safest medical procedures of all times-  even safer than many other outpatient procedures carried out in less regulated environments. This is well documented in published reports from the Virginia Department of Health and from the Office of the Medical Examiner.   Numerous commenters refer to "violations" such as blood spattter, poor handwashing, and abortions without appropriate consent.   As bad as these "violations" sound, they are not addressable by the onerous regulations govering building construction and EMS requirements.   Addressing them, if they indeed existed, would have been entirely possible under the regulations at any point prior to the current ones.  Finally, the requirement to apply new building standards to existing structures is a thinly veiled strategy to close clinics.  There are no other instances where such new construction standards have been applied to existing structures..     The end result will only be less cancer screening, less treatment of disease, more unintended pregnancies, and an increasing number of women damaged from illegal street abortions carried out outside of the law.  Please, let Virginia once again stand for common sense, tolerance for the choices of others, and a balanced sense of fairness.

CommentID: 38224