Board of Health,

Specific recommendations:-Require ultrasound before abortion. Accurate dating of the gestational age of the fetus is related to the risks for women choosing between methods of abortion.-Failure on safety regulations during repeated inspections at an abortion clinic, should lead to consequences otherwise inspections are not accomplishing the purpose of protecting public safety. The Virginia Board of Health has the responsibility to protect Public Health. Abortion clinics are doing surgery on thousands of young Virginia women of childbearing age, surgery that can lead to emergency situations. Yet the first 14 inspection reports that I have reviewed, made avaiilable months ago, show multiple safety violations, and those, in front of the watchful eyes of the inspectors. One can only imagine the unsafe practices that continue in their absence. Indeed, many of the inspection reports of subsequent inspections of the same abortion clinic, begin with a large list of repeat violations that have gone uncorrected since the last visit. In one case, the emergency crash cart had a critical medicine expired about the time of the last inspection. One clinic, put on notice that the doctor was not using sterile gloves for a procedure had staffers who replied that they did not expect their physician to use sterile gloves. Allowing an abortion clinic administrator write a plan of correction does nothing if that plan is mailed in, but not implemented or enforced. Some of the reports show this lack of follow through. The abortion clinics of Virginia need to be held to the same standards as other surgical centers, and to have those standards rigorously enforced. Medical abortions are increasing as a percentage of abortions. The failure rate of medical abortions beyond the FDA guidelines of 49 days post last menstrual make it critical that an accurate measurement of the gestational age is known to the woman, so that she can be aware of the greater risk of incomplete or failed abortion past 7 weeks gestation. The ultrasound is critical in assessing accurately, is this medical abortion more likely to fail" Is there no heartbeat and no abortion is needed" Virginia abortion clinics who offer medical, home-alone abortions to Nine Weeks to women after Mifepristone (RU-486) are putting her at increased risk. An accurate ultrasound would at least provide an idea of the expected failure rate of her abortion. The abortion clinics in Virginia ned to be held to the same standards as other surgical centers, and have those standards rigorously enforced. I submit that the Board of Health has the duty to protect women from foreseeable, predictable harm, by enforcing consequences on clinics that violate, sometimes repeatedly, the safety regulations. Why are there no consequences to those clinics who do not follow safety protocols" There certainly will be consequences to their patients.Respectfully, Mrs. Kathy ClowesExec. Dir. Front Royal Pregnancy Center 2/11/15 Kathy Clowes