Bifurcating abortion procedures to effect design standards

The May 2, 2016 issue of Virginia Register of Regulations purports to make a “technical change”  with the proposed addition of the terms "medication induced abortion" and "surgical abortion" in order to “tailor the facility design and construction guidelines more precisely to the requirements of each facility.” The limited public record of the actions taking place within many of these clinics is enough to show that this distinction between types of abortions, and therefore a need for different design standards, is unwarranted.

For example, according to an inspection report at the Virginia Women’s Wellness Center in Virginia Beach, it was discovered that for 36.6 percent of patients that had medication abortions in January 2014, a repeat medication dose or a surgical procedure was required to complete the abortion.  And these are just the ones we know about from that facility. Other inspection reports indicate similar issues. The women in these scenarios can often require additional surgical procedures to complete the abortion process. It only makes common and medical sense that the women would return to the same clinic in order to address the failed medication abortion.

Furthermore, according to the FDA, RU-486 is only to be used until 49 days gestation and if used according to FDA guidelines has an 8 percent failure rate.  The farther along in gestation a woman is, the more likely it is that RU-486 will fail.  According to the New England Journal of Medicine, statistics indicate that there is a 17 percent failure rate at 50-55 days, and a 23 percent failure rate at 57-63 days.  Virginia Women's Wellness' rate of 36.6 percent failure is over four times the average. 

Knowing these facts and realizing that this scenario is the case for many women undergoing abortions, it is disingenuous at best, and volatile to women’s health at worst, to change the regulations to create such a distinction in health and safety standards among clinics. I recommend keeping the current regulations.