The Pro-Life Action League is pleased to provide comments regarding the Rules governing abortion clinics. While best known for our vigorous defense of the lives of the unborn, we also have extensive experience with regard to the level of safety (or lack thereof) in abortion clinics with respect to the protection of the mother of the aborted child. 

For the past four years the Pro-Life Action League has been actively studying abortion regulation in various states with a view to the safety of the women who choose to use the services of an abortion clinic.  We have particularly studied the inspection reports and the plans of correction for all the Virginia abortion clinics and have made our concerns known to the OLC on a number of occasions where we thought the plan of correction was inadequate. 

Inspections make a difference.  Requiring licensure and inspections has made a large difference in the standard of care at the clinics, although there is great room for improvement.  While corridor and door width is important (as was seen in Philadelphia where a woman died partially, at least, due to the inability of rescue workers to get her out of the building) our concern is with the poor understanding by the clinics of proper aseptic technique, the use of unlicensed personnel to perform tasks for which they are neither trained or licensed to perform, and the poor record keeping by some  nurses and physicians which make reconstructing what occurred in an abortion difficult to impossible. 

We are concerned that the interval between inspections is too great.  When a plan of correction is accepted it is important to see that the plan is actually carried out.  This has not occured with many of the clinics.  Too often a clinic is later recited for the same violation that was cited on the initial inspection.  But this comment only applies to the clinics which are reinspected.  We have requested the inspections of all clinics and as of this date we still have not received a biennial inspection for almost half of the clinics, subsequent to the initial inspection.  Also, to date there has been only one (1) clinic that has passed a biennial inspection the first time.  There was also only one (1) inspection followup that found no violations.  The rest have had violations. 

We are very pleased that the clinics are being inspected.  We would hope more people would read those inspections and realize the need for further monitoring of these clinics. 

One suggestion we would make would be to require the closure of abortion clinics found to be unsafe until such time as they can show that the correction has been implemented.  This is particularly important for those clinics having difficulty with cleaning and sterilization.  Women deserve better.  While we deplore the fact that abortion is legal in America, we believe that women deserve a high standard of care in any medical facility they choose to use.  But, aparently, some clinics disagree.  If you would like particular instances, please contact us. 

Jean Crocco RN(IL), BSN

Pro-Life Action League

6160 N. Cicero Suite 600

Chicago, IL 60646