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
spacer
Previous Comment     Next Comment     Back to List of Comments
1/16/15  4:09 pm
Commenter: Margaret Walsh

Respect Women, Require Safety
 

Board of Health,

Dear Members of the Virginia Board of Health:I recently temporarily retired from the practice of Ob/Gyn after 26 years to provide full time care for my 95 year old mother. I am Board certified in General Ob/Gyn and in Maternal/Fetal Medicine (High Risk Obstetrics) and in Diagnostic Radiology.While in practice, I did not do elective pregnancy terminations, but I did many D&C procedures for patients with incomplete miscarriages and embryonic and early fetal deaths. All of these procedures were done in a hospital setting and I wouldnt have ever considered doing them in my office for safety and patient pain management issues.My patients were given general anesthesia with IV medications so they didnt have pain. When patients dont get such pain relief, as in abortion clinics, they may involuntarily move, increasing the risk of uterine perforation. I cared for patients after elective abortions from other physicians, and some had vivid memories of terrible pain. If uterine perforation occurs, bowel/bladder/and/or vascular damage can occur.An anesthesia specialist was always present at my D&C procedures to monitor vital signs. Sometimes, unexpectedly, heavy bleeding would occur. Blood flow is markedly increased in the pregnant uterus, even in early pregnancy. Patients with previous Cesarean sections may have abnormal attachment of the placenta which can result in severe bleeding. Sometimes, special medications need to be given to decrease uterine bleeding. Sometimes blood transfusions are necessary.Virginia is blessed with may Ob/Gyn residency training programs that can provide abortion services in a safe hospital setting. They have immediate access to emergency personnel, medications and bloodproducts. Its not necessary in Virginia to have abortions performed in free standing abortion facilities, which are not willing to adhere to the same safety standards.Our patients deserve the safest and most humane treatment available. The first rule in medicine is to do no harm. Margaret D. Walsh, MD, FACOG

CommentID: 37404