The regulations as forced on us by Cuccinelli are offensive, unnecessary and harmful. They should be repealed. There is no scientific evidence to support requiring these facilities to meet hospital standards, and the result and intent of the regulations are to interfere with the provision of constitutionally protected medical services to women. Even worse, the result of the regulations will interfere with non-abortion services to women, having a significant harmful effect on public health, safety and welfare.

Virginia has been dragged to the 19th century with the regulations as forced on us by Cuccinelli and his right-wing agenda non-scientist cohorts.  There is no need for such standards.  The sole reason for instituting them is not to protect women but to deny medical services to them.  I worked with ob-gyn physicians for years and know how important it is to provide such services.  These regulations are not only harmful to public health but also make Virginia look stupidly backward.

These regulations were put in place as another means to restrict a citizen's right to lawful medical procedures.  There is no medical necessity to have these clinic share the same requiirements as a hospital.  I continue to hope that these onerous restritions be repealed.

These common-sense standards were enacted to protect women from exploitation by abortionists that would profit by cutting corners on women's heallth.  Those who can't or won't comply with the law should rightfully be shut down.  These regulations provide a service to women by weeding out abortionists who operate using substandard practices.  It is just wrong to ask women to suck it up and tolerate shoddy facilities where conditions and providers are little better than what was found in the Back Alley prior to Roe.  The regulations add a necessary layer of accountability to a previously unaccountable and out-of-control industry that is rife with abuses.  Please retain and enforce the regulations that apply to abortion facilities for the sake of public safety!

As many people know the TRAP regulations were Cuccineli's way of resticting access to abortions.If he was so concerned about women's health why are these regulations not put upon plastic surgeons and oral surgeons,who actually do surgical procedures in their offices under general anesthesia.General anesthesia is rarely used for an abortion. As a member of the healthcare system I have a hard time understanding why it's acceptable to restrict women's access to healthcare by burdensome regulations.If a woman wants an abortion she will find a way to have one whether its legal or not,there by compromising her health and welfare. Grandfather clause in all existing abortion clinics.Don't deny the right of Virginian women to legal abortions and healthcare.

"If the regulations are not repealed and rewritten, tens of thousands of Virginia women and families will lose access to critical medical care, and Virginia's women deserve better." 

As  Kathy Greenier, director of the ACLU of Virginia Reproductive Freedom Project, said: “It’s time for the Board of Health to heed the advice of medical experts and give these politicized regulations the unbiased review that they deserve. We call on the Board and the Commissioner of Health to repeal and rewrite the regulations in order to protect women’s health and preserve access to comprehensive reproductive health care".

I couldn't agree more.  This is a travesty...  former Attorney General Kenneth Cuccinelli, with his vendetta against womens' rights, was defeated last November.  Let the voice of the people continue to be heard.

"If the regulations are not repealed and rewritten, tens of thousands of Virginia women and families will lose access to critical medical care, and Virginia's women deserve better." 

As  Kathy Greenier, director of the ACLU of Virginia Reproductive Freedom Project, said: “It’s time for the Board of Health to heed the advice of medical experts and give these politicized regulations the unbiased review that they deserve. We call on the Board and the Commissioner of Health to repeal and rewrite the regulations in order to protect women’s health and preserve access to comprehensive reproductive health care".

I couldn't agree more.  This is a travesty...  former Attorney General Kenneth Cuccinelli, with his vendetta against womens' rights, was defeated last November.  Let the voice of the people continue to be heard.

Please keep the abortion clinic regulations that have been put in place.  They are there to protect women and help keep them safe.  We can't keep the baby safe, even under these regulations a life is taken, but we can have regualtions to at least keep the Mother safe.  I hope and pray one day we will have regulations to keep both Mother and Child safe.  There is no reason why we should abject to the safeguards for the life of the Mother.

"If the regulations are not repealed and rewritten, tens of thousands of Virginia women and families will lose access to critical medical care, and Virginia's women deserve better." states Jill Abbey, administrator of the Richmond Medical Center for Women and the Peninsula Medical Center for Women in Newport News. “Any health center that can’t comply with these medically unnecessary regulations must close, restricting access to critical health care services centers like mine provide, such as cancer screenings and birth control.”

As  Kathy Greenier, director of the ACLU of Virginia Reproductive Freedom Project, said: “It’s time for the Board of Health to heed the advice of medical experts and give these politicized regulations the unbiased review that they deserve. We call on the Board and the Commissioner of Health to repeal and rewrite the regulations in order to protect women’s health and preserve access to comprehensive reproductive health care".

I couldn't agree more.  The restrictions that these laws would impose are a travesty...  former Attorney General Kenneth Cuccinelli, with his vendetta against womens' rights, was defeated last November.  Let the voice of the people continue to be heard, and protect women's access  to critical healthcare services.

"If the regulations are not repealed and rewritten, tens of thousands of Virginia women and families will lose access to critical medical care, and Virginia's women deserve better." states Jill Abbey, administrator of the Richmond Medical Center for Women and the Peninsula Medical Center for Women in Newport News. “Any health center that can’t comply with these medically unnecessary regulations must close, restricting access to critical health care services centers like mine provide, such as cancer screenings and birth control.”

As  Kathy Greenier, director of the ACLU of Virginia Reproductive Freedom Project, said: “It’s time for the Board of Health to heed the advice of medical experts and give these politicized regulations the unbiased review that they deserve. We call on the Board and the Commissioner of Health to repeal and rewrite the regulations in order to protect women’s health and preserve access to comprehensive reproductive health care".

I couldn't agree more.  The restrictions that these laws would impose are a travesty...  former Attorney General Kenneth Cuccinelli, with his vendetta against womens' rights, was defeated last November.  Let the voice of the people continue to be heard, and protect women's access  to critical healthcare services.

I look forward to a thorough review of the current TRAP laws by people looking for real evidence for what best serves women's healthcare needs. Trust Women, Respect Choice.

Women's health, and protecting women, should not be a partisan issue.  They should be confident that whatever medical facility they enter is clean and capable of providiing whatever medical care they require.

This law has been long overdue and is vital to protect the citizens of this Commonwealth.  There is no reason that these centers should be treated as if they are not supplying medical services!  Please keep the law in tact.

Recent information that has come to light about Virginia abortion center owner, Dr. Steven Brigham, exemplifies the need for regulations. Brigham's license to practice medicine has been revoked in five states because of his complete disregard for the safety of women. The New Jersey State Board of Medical Examiners revoked Brigham's license declaring, "Dr. Brigham's continued practice would present clear and imminent danger to the public health, safety, and welfare." Virginia inspections found gaping holes in the ceiling of his abortion center, unsterilized needles, outrageously high complication rates, and incomplete lifesaving equipment.  If an abortion doctor like Steven Brigham can continue to operate two abortion centers here in Virginia, it is clear that the regulations must remain in place to protect the women of Virginia from Brigham's harmful practices.i

Please keep this legistation intact and do not modify it.  Women deserve to know that the medical facitiles they use meet true medical standards and the medical personnel are properly licensed and accredited.  

How can we allow a doctor that has been banned from 5  states to practice abortion in VA    Butchers and restaurants have more rules and regulations than abortion clinics.   This is criminal  

OS

There is no logical reason to change or remove the current regulations over abortion clinics.  None of us would want to go to any physician's services which were not regulated carefully.  To question these current regulations is not logical.  If anything, we need more regulation, not less.

Let's have strict enforcement of abortion clinic regulations. 

The abortions clinics need to be held to stiff medical regulations for the safety of others.  Pregnancy centers are accountable, so abortion clinics should be also.  The regulations passed are fair and need to stay in place.

It seems obvious that since abortion is a medical procedure, it should have the same safety regulations as other medical practices.  I guess it has been "politically correct" to overlook these standards so that no women's rights groups are offended.  The time for political correctness suffocating truth in Virginia needs to end.  When practices need regulations, our officials need to have the courage to stand up and say it.  Have the courage to protect women's health by demanding safety regulations in abortion clinics.

Because the U..S. Supreme Court has prevented any restriction on the right of a woman to choose an abortion it is self-evident that the common sense regulations that were put into place regarding abortion facilities could have no purpose but to promote the health and safety of women making that choice.  The history of abortion providers in the U.S. and in Virginia is replete with instances of bad medical facilities and practices. Why, uniquely among medical procedures, should abortion be excused from the  professionalism and hygeine that is normal to medicine?  It seems to me that abortion providers who wish to overturn the existing regulations need to make the case that what they do does not require the professionalism and hygeine normal to medicine. 

Please keep strict regulations of abortion clinics like any other health clinic.

Dear State Board of Health,

As you consider regulations for abortion clinics I'd like to encourage you to make them as safe as the hospitals that take care of us.  As I considered where to have my surgery in 2013 I was pleased to find a clinic who's rate of infection was less than that of the average hospital.  This gave me confidence that I'd not have to deal with the added complication of infection while trying to recover.  I wonder why we would allow our women to have a surgerical procedure that offered anything less than what is mandated for hospitals.  Are we going to value their protection from infection less than that of what happens at the average hospital? 

I realize that this mandate will be costly, however, is the main concern over cost going to subject these women to lesser standards than the average person receives at our local hospitals and surgical centers?  These clincs made a profit or they would not be in business, why are they not willing to give up some of their profit to protect the women of our communities.  Will you, the State Board of Health, allow a woman's safety to be given away for a few dollars of profit, I think not. 

Your role is to protect the public, allowing clinics to operate with lesser standards than a hospital is a travesty for public health.  I realize that some may say it's not like having an operation at a hospital, I would say that's completely false, it is.  We have a surgical center here in Central VA and they do lesser surgical procedures than the hosptial, would you allow them to operate under less stricter rules than the hospital, would we allow the public to be put at risk for things like Sars, staff infections and more simply because they do less complicated procedures than the hospital, I think not.

I encourage you to not listen to those supporting abortion or those opposing abortion.  As you make your decision do so to protect the safety of the women of Virginia.  If you lower the standards for these clinics you are saying to women that you are not concerned with their safety, which I do not believe you would agree with.

Thank you for reading this and for acting in a manner that will save lives across the Commonwealth of VA.

Respectfully submitted,

Carl Weiser

Abortion clinics as well as all Planned Parenthood clinic and offices should have the same sanitary and medical supervision  (Licensed Medical Doctors, LIcensed Registered Nurses and/or Licesed Practical Nurses ) as hospitals where abortions are completed for the safety of the women involved.  I am against post 1st term abortions except in the case of risk to the life of the woman involved. All of these clinics should be inspected frequently (at least four times a year) and routinely without prior notice, by State Health Department where that clinic resides. 

As a Licensed Registered Nurse I have seen the results of abortions gone wrong. 

Because the U..S. Supreme Court has prevented any restriction on the right of a woman to choose an abortion it is self-evident that the common sense regulations that were put into place regarding abortion facilities could have no purpose but to promote the health and safety of women making that choice.  The history of abortion providers in the U.S. and in Virginia is replete with instances of bad medical facilities and practices. Why, uniquely among medical procedures, should abortion be excused from the  professionalism and hygeine that is normal to medicine?  It seems to me that abortion providers who wish to overturn the existing regulations need to make the case that what they do does not require the professionalism and hygeine normal to medicine. 

Abortion centers need the same health regulations as any other surgical center to protect women during a medical procedure.

Very important to have safety regulations at abortion clinics or any other clinics. As a nurse I understand regulations. We need to protect and educate all involved including patients. Without regulations patients/clients are not protected and should an emergency situation occur, client could be injured or even die. Staff members of clinic should be educated so they know risks and dangers.  Should the birth of fetus be such that it is a live birth, that too should be addressed. Not only physical  but mental and emotional damage can occur.

E. Scott RN

You know the same old comparisons....tattoo parlors, satellite emergency clinics, dentistry, chiropractors...they all conform to state regulations (thankfully!)..so why should it be different for abortion providers?

They want to run (play?) by their own rules. They need to be inspected regularly and thoroughly, since what they do is far more serious and dangerous than the aforementioned business's. Please protect women from possible  faulty, shady,  and unsafe abortion providers.

Thank you,

Russ Whitesell

I am a resident of Waynesboro, Viriginia.

I urge you to retain the current regulations to protect the health of surgical patients.

Surgical regulations are designed to protect patients, all patients. They should not individually crafted based on the needs of those doing the surgery.

If surgical regulations are appropriate for surgical facilities, then they should apply to all surgical facilities.

The current review of surgical facility regulations is all about politics and money, and not about medicine.

If you care about medicine, the answer is obvious.

Ken Adams

I appreciate your time in considering my thoughts. Common sense and wisdom would dictate any facility that deals with humans in the area of physical healthcare should have extensive rules and guidelines. For instance, we have rules for housing people (landlords), we have rules for feeding people (restaurants), we have rules for beauty (nail salons/beauty or barber shops), we have rules for massage therapy and chiropractors. If we have rules governing housing, food, and outside the body care, how much more should we have regulations for inside the body care?!

Just as the government has spot checks for other businesses around cleanliness, compliance, safety, and general health safety, the abortion industry must have safe, clean, and well documented rules with extremely stringent disciplinary actions when they are violated. I would think you could follow the same rules placed on surgeons and hospitals since abortion is an outpatient procedure. It might be easier to restrict abortion centers from offering any medical assistance and limit them to counseling only. Send all patients to a certified/regulated hospital for regular outpatient surgery where safety, cleanliness, transparency, and rules protecting both the hospital and the patient are in place. Please place patient safety and care above business that is only concerned about the dollar. Thank you for the opportunity to comment.

Thanks, C Sullenger, for comments above that make good sense.  We have historically acted to protect the vulnerable from those who would take advantage of them, whether pimp, employer, bank, or doctor.  Someone with an unwanted pregnancy can be a runaway trapped by a sex trafficker, a victim of incest, or a professional woman fully able to take care of herself.  These regulations are not in place to protect the wealthy, because they are able to find and afford a facility that meets their standards.  These regulations are for the vulnerable, who need someone who is "weeding out abortionists who operate using substandard practices,"  as C Sullenger stated.

I remember first hearing that abortion clinics were not regulated and being very surprised that they were not subject to the same standards of practice we have come to expect at the dental office and outpatient surgery centers.  It just makes sense that Virginia would act to protect its citizens who enter an abortion clinic, in need of its services, to the same extent we protect those going to the dentist or to have a simple surgery.

As clinic inspections have demonstrated since these regulations were made official, there are plenty of intolerable conditions encountered in Virginia's abortion clinics.  This need not be so.  I urge you to retain these regulations and make the abortion industry in Virginia as humane and professional as is possible.

The Virginia regulations for abortion providers/clinics need to remain in place.  Given the recent information concerning one abortion provider(Dr. Stephen Birgham) in the state, the regulations not only need to remain in effect but also be consistently enforced. A doctor who has had his license revoked in five states should not think that he can practice in VA without regulations in place to assure the health and safety of his patients.  Abortion is a surgical procedure and women need the assurance that it is being performed safely according to the standard medical practices for other surgical procedures concerning sterilization and access to emergency care should the need arise.

As a civilized society, we should have at least the common decency to protect the health of expectant mothers and ensure that fetuses are properly handled.  Otherwise, we fall further into the abyss of a disposable society.

Abortion facilities need to be regulated to protect women from unsafe, unclean and dangerous abortion practicing facilities.

It is no secret that in recent years some abortion facilities have been exposed for deplorable and unsafe conditions.

This should be enough to grant abortion facilities the same oversight that is given to other businesses that do medical

practices.  Some of those businesses are far less invasive than that of the abortion procedure.  It smacks in the face of

reason that these facilites have gotten away with this for as long as they have.  With all of the hype about Women's

Rights why do they not have the right to have state oversight for ALL medical facilities? Do the RIGHT thing Virginia and

grant women safe medical care.

Keep the regulations we have now. Do not alter them.  See that they are enforced.  Save lives.

It is fairly obvious that abortion providers in our state need to be regulated for the safety and well-being of the people who use their services. I make no pretense -personally, I think abortion is a very poor, even harmful, choice for women. Nevertheless, when a woman is deperate and scared and goes to an abortionist to end her pregnancy, the state has the duty to insure her that she is not being taken advantage of by a business that operates without proper oversight. Our hair and nail salons, our restaurants, our pet shops have had way more oversight and inspections than abortion facilities in the past decades. This must stop. Because I disagree with the choice, does not mean I care less about what happens when a woman goes into an abortion facility in our neighborhoods. I have seen a woman in severe medical distress leave a local abortion facility, not by stretcher to an ambulance, but in the back seat of a pick up truck, too hurt to get into a car or even walk. She was carried out of the building in a narrow, upright gurney because that was the only thing that could fit through the door. The doctor did not accompany her. Back alley abortionists will try to continue their business with the least protection for women and the most profit for themselves. When these businesses set up shop in Virginia, the state should be there to inspect and insist on corrections to shoddy practices. It just makes sense to keep a keen oversight on these businesses.

I am writing to express my concern and ask you to keep the regulations in place for the safety of abortion clinics in Virginia.

The issue of killing living child aside, abortion IS a medical procedure and the clinics engaged in this practice absolutely needs to follow the same medical facility requirements that a hospital or outpatient clinic is required to follow. The question of why that has been the case in for years in Virginia is answered by following the campaign donation trail to elected officials and other organizations in Virginia.   

I am sure you are aware, but just in case, the New Jersey State Board of Medical Examiners revoked Dr. Stephen Brigham's license, stating as public record that, "Dr. Brigham's continued practice would present clear and imminent danger to the public health, safety, and welfare." In addition Virginia inspections found gaping holes in the ceiling of his abortion center, unsterilized needles, outrageously high complication rates, and incomplete lifesaving equipment.  

Based on the evidence in those and other Virginia clinics, it is pretty clear that safety of women seeking these services is being ignored for political reason and pandering to Planned Parenthood and other organizations.

As elected officials, one of your responsibilities IS the safety of the folks who have elected you…and you need to insure that Abortion facilities follow the same medical facility requirements that a hospital or outpatient clinic must follow…and prosecute those that fail to do that. 

Maintain healthy medical facilities! Regardless of your opinion on abortion, if the facilities are to exist, they should be sanitary and clean and well maintained! Relaxing health standards will only endanger more lives.  Keep the regulations where they are (or improve them even more) !

TypePlease leave the abortion center regulations in place for the sake of women and their babies--and our nation! over this text and enter your comments here. You are limited to approximately 3000 words.

It's hard to imagine a more vulnerable group than women who are pregnant and facing difficult choices. The last thing they need is unregulated clinics that are anxious to sell a product that has the ability to severely injure these women.  The current regulations are necessary and appropriate for these facilities.  Any reduction or removal of these regulations would facilitate the operation of "abortion mills" that profit by moving the women through the facilities as quickly as possible, to maximize profit while the welfare of the woman goes disregarded.  In their rush to move women through the process basic medical hygiene and post surgical care are threatened.  We need regulation to ensure that proper methods of treatment are followed and enforced in a timely way so that more women do not suffer as they have in recent years at clinics across America (see Gosnell).

Thank you.

Please maintain the regulations for abortion clinics as they are. These facilities must operate with the highest regard for the safety of their patients. As freestanding surgery centers, they must be regulated as other surgery centers.

I am in total support for Abortion Center Regulations

Prior to the implementation of regulations in 2012, the Virginia abortion industry had gone unregulated for too long. Department of Health inspections revealed widespread health and safety violations, including blood splattered exam tables and equipment, unsterilized equipment, poorly or untrained staff, violations of state parental consent laws, and the lack of reporting of possible cases of child sexual abuse, along with over 300 other violations. These violations reveal a serious need for regulations of these facilities in order to protect women who seek out abortions. 

We need to care more about protecting patients and "life" than focusing on construction standards and the profits.  Without people, there is no one to pay for any of it.

We strongly urge you to maintain the regulations of abortion centers as they are.  This is vital to protect the women of Virginia.

We strongly urge the board to maintain the abortion center regulations as they are and to enforce them.  There is so much evidence of unsanitary and unsafe conditions in these centers.  Protect our women!

Life is precious and flippantly regarded when we cannot see this human eye to eye. heart to heart and mother to her own flesh. Women (and the fathers) deal with this loss in many ways; some are burdened later and some immediately. It is something you never forget no matter how hard you try to rationalize the fateful decision.

The least we can do is to make this death as humane as possible for the child and provide good medical care and grief counceling for the mother. We are all God's children and until we resolve to eliminate "convenient abortions" we can at least make the situations the easiest for the child and have the mothers health provided for in a clinically professional way.

Keep the 2012 Health & Safety regulations and required inspections for abortion clinics. These are basic regulations that any medical facility performing invasive procedures must follow. The health and safety of patients require these regulations, as was proven during the 2013 inspections.

Staph infection is a real possibility every time you go to the hospital.  You enter the hospital for something as minor as a cut on your finger, but if you are unfortunate enough to contract staph bacteria from a dirty waiting room, you could end up fighting for your life.  There is a reason why there are high cleansiness requirements for hospitals, especially in areas where blood and cuts are prevalent like the surgery or birth rooms.  Cuts and blood create a favorable environment for infections and all sorts of disease transmissions like hepatitis-C.  So, why abortion centers do not have the same sanitary requirements like hospital operating room?  Do you not have cuts and blood involved in an abortion procedure?

Abortion clinic regulations MUST be maintained. It's obvious from just seeing the news that death centers such as Planned Parenthood hold a total disregard for safety and proper health care for women, as well as the abortionists that work there. Maintain and ENFORCE the rules and regulations regarding these clinics/centers and shut them down when they are breaking the laws!