As a registered nurse who works in a JCAHO compliant facility, I appreciate the importance of regulatory standards in maintaining and promoting patient safety and well being. The abortion industry claims to exist to promote women's health - it seems logical that its centers would strive to meet and/or exceed all safety standards and proudly display such achievements in its centers. After reading the entire chapter there seems to be no undue standard or burden, simply a requirement that these facilities meet standards for outpatient surgical centers. CDC guidelines for infection control and prevention; medication safety; patient education and informed consent; physical structure conducive to preserving life safety during emergent events; ability to administer varying levels of conscious sedation, monitor patients, and rescue those that progress on the continuum of conscious sedation or have an adverse reaction; and having capability to manage life threatening complications of procedures performed are all necessary to provide safe care to patients. Sex trafficking is a real issue and those concerned for women's health need to ensure all possible measures are taken to not unintentionally enable those engaged in this odious practice. Reporting suspected abuse is vital, confidential targeted patient history aids in identifying at risk patients.

The citizens of our Commonwealth are relying on the Board of Health to promulgate and maintain standards that protect and promote their health and well being. These standards necessarily need to be evidenced based.

Thank you