Erik Bodin, Director

Virginia Department of Health, Office of Licensure and Certification

9960 Mayland Drive, Suite401

Richmond, VA 23233

Dear Mr. Bodin,

I am writing in response to the periodic review and small business impact review of 12VAC5-412, Regulations for the Licensure of Abortion Facilities.  I ask that you do not modify, repeal or weaken these regulations.

These regulations are not for the purpose of limiting or restricting women's rights or for political reasons, but are for the protection of women's lives and health, and as such are clearly needed.

Over 80 violations were discovered at abortion centers even though they had received notification of upcoming inspections.

Inspectors found an abortion center splattered with blood and improperly storing fetal remains.  Several failed to comply with even basic sterilization procedures.  Other inspections revealed problems with storage of and dispensing of drugs at abortion centers including several with expired drugs and others with improperly labeled drugs.  In addition, personnel were not properly trained and procedures were not maintained.

Also, several abortion centers were cited for local and state building code violations, the abortion centers claiming that requiring them to meet certain building standards puts an undue burden on their business.  It may.not appear at first to be related to women's health issues, however, in repeated instances, paramedics have been unable to assist women who suffered complications from botched abortions.  Kamamaya Mongar, the woman who died from her abortion in the Gosnell case, died in part because paramedics were unable to negotiate hallways at Gosnell's abortion center.

Women's safety and health should be a top priority in any surgical procedure, including an abortion.  These standards were implemented as a result of an arduous two-year process, amply reviewed by the Virginia Board of Health.  To repeal or weaken these standards places women in harm's way.  This Board's most important consideration is the safety of Virginians.

Sincerely,

Linda P. Riddell

203 Lodge Road,

Callao, VA 22435

trufflesam@yahoo.com