Agencies | Governor
Virginia Regulatory Town Hall
Virginia Department of Health
State Board of Health
Regulations for Licensure of Abortion Facilities [REPEALED] [12 VAC 5 ‑ 412]
Action Regulations for Licensure of Abortion Facilities
Stage Proposed
Comment Period Ends 3/29/2013
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1/28/13  4:12 pm
Commenter: Brandi Cummings, PharmD, individual

Opposition to TRAP regulations


Members of the Board of Health,
I urge you to make decisions based on evidence.  Evidence of why invasive procedures are needed or not needed to make a medically sound decision.  Onerous and unnecessary regulations would restrict access to essential health care services for the women of Virginia and further marginalize young, low-income, uninsured and minority women by decreasing their health care options. 
I also have concerns about the unintentional consequences to regulations that seem to have safety as a primary goals.  For example, for a medical center to meet the current standards, not even the proposed standards, a facility is required to keep certain medications readily available.  Dapsone is one medication required in case of malignant hyperthermia, a rare adverse effect from some paralytic agents used when patients are intubated.  Centers that provide abortions do not use paralytic agents for procedures.  However, they are required to have the paralytic agents available in case of anaphylaxis and sudden respiratory compromise.  The paralytic agent may be used for emergency intubation.  Because the paralytic agents must be available for life saving measures, the current regulations require Dapsone must be available. Dapsone is difficult to obtain; our nation has suffered from extensive drug shortages requiring hospitals to change medications in operating rooms and crash carts.  Supply of lesser used medications can lead to medication errors because prescribers are not as familiar with dosing and are selecting doses in an emergency situation.  We do not help the national drug shortage by requiring medications to be available at clinics when the need is almost nil.  The medications expire.  The shortages continue.  In the event of an emergency, staff at a center will initiate life saving measures. They will arrange emergency transport.  If a rare adverse effect occurs to a life saving treatment, it can be treated at a hospital that does appropriately stock rare rescue medications.
We need to look at the evidence and the safety records of women's health centers.  Abortion is one of the safest medical procedures. Overregulation will limit access to a wide range of preventive reproductive health care services provided by women's health clinics, including life-saving cancer screenings, family planning, and sexually transmitted infection testing and treatment. 
I appreciate your service to our commonwealth and ask you to make the best decision, based on facts and evidence.  Please do not neglect your duty because of outside pressures.  These are the lessons you learned in medical school and have served you and your patients well.
Brandi Cummings, PharmD
CommentID: 25016