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 Regulations for Licensure of Abortion Facilities
Stage Emergency/NOIRA
Comment Period Ended on 2/15/2012
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2/13/12  2:00 pm
Commenter: Mary A. Camarca, MD

Abortion Facility Regulations
 

As a fellowship trained Pediatric Emergency physician, I do not perform abortions.   As an ED physician, I have performed thousands of common and safe procedures.  Irregardless, my first and foremost  duty as a physician is an obligation to patient safety, NOT to  patient access, no matter how  many patients  want, need,  or require the procedure; no matter how common and safe the procedure.  That obligation includes meticulous patient documentation, adherence to infection control policies, ensuring the availability of resuscitation equipment and drugs, and  a physical enviornment that allows for patient safety.  I have read the proposed regulations. They are a strong, reasonable, and comprehensive move toward the primary goal of patient safety.  

The fact that abortion is common and safe is irrelevent. I have seen post abortive complcations in my ED.  They are not common, but these are life threatening complications with life long disabilities as a result. It only takes one patient complication or death to destroy a family, a  medical practice, or a physician and have negative consequences for the rest of  us in the medical profession. 

Abortion is a service sought out by a patient in order to fullfill a lifestyle choice.  It is provided for by our medical industry, as opposed to the service or retail industry. Abortion does not cure a disease. It does prevent an illness.  It does not promote the health of the patient.  Nevertheless, it falls under the difinition of a medical/surgical procedure and is currently legal.  The most common surgical abortion procedure in the first trimester is a painful, invasive, irreversible surgical procedure that terminates a human life in the fetal stage of development.  These are  statement of facts without political or religious bias.   It has both short term and long term complications, some of which are serious and life treatening, albeit rare, such as uterine perforation, bleeding, and sedation complications.  

The medical profession's FISRT and FOREMOST obligation is to protect the safety of every single patient, not to to provide access.  No regulation or policy can make a procedure "too" safe, no matter how common or safe the procedure is regarded.  When the medical profession chooses to acknowledge that the patient prior to birth should be afforded the same safety protections,  abortion procedures will then become "too" safe.  They will be obsolete.

CommentID: 22409