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 Proposed
Comment Period Ended on 7/1/2016
spacer
Previous Comment     Next Comment     Back to List of Comments
5/26/16  9:01 pm
Commenter: Greg Letiecq

Regulatory need is clearly evident
 

The health and safety of all Virginians is expressly a foundational goal for this agency.  Facility inspections have frequently, if not nearly consistently identified issues where health and safety improvements can and should be made, hopefully improving the safety record at abortion facilities over the long term.

Given the record of incidents where people have died or seriously been injuried, it is pretty clear that there is a need for regulation and inspections.  Until the record demonstrates that these incidents have fallen to a level below that of other medical facilities the existing regulations should at least be maintaned.  That has not happened yet, and consideration should be given to strengthening these regulations instead of reducing them.

I would suggest that a target level of safety be established and the regulatory activity be tailored to meeting those goals, being made more or less stringent as the objective need would demonstrate.  In this fashion we would remove the details of regulatory rulemaking from the political realm and make discussions such as these simply a decision about what actions we could take to meet a specified metric.  What the ultimate goals would be would understandably involve political considerations, but the regulatory methods that would achieve these goals might be subjected to far less political activism, make them more about actual safety, and streamline the rulemaking process.

CommentID: 50029