The absence of regulations on the convicted Dr. Gosnell’s abortion facilities resulted in horrific and irresponsible treatments to women. I sincerely urge the Board of Health members to make the following changes to protect women who deserve better care:

1. Reinstate all of the health and safety measures the Board unlawfully watered down during its last amendment process.
2. Require all OLC inspections to verify that ultrasounds have been performed at least 24 hours prior to every abortion performed.
3. Require annual inspections on abortion facilities instead of biennial.
4. Remove the ability of the Commissioner to grant permanent variances.
5. Reinstate the definition of "first trimester" as being the first twelve weeks from conception, not "13 weeks and 6 days after last menstrual period."
6. Reinstate the ability of the department to deny, suspend, or revoke the license to operate an abortion facility for violating "any provision of Article 1 (§ 32.1-123 et seq.) of Chapter 5 of Title 32.1."
7. Reinstate the requirement that abortion facilities provide information on post-abortion counseling to its patients.
8. Reinstate the requirement that the abortion facility ensure that it has removed all of the fetal body parts from inside of the female patient upon the performance of an abortion.
9. Reinstate the requirement that abortion facilities report to OLC any incidents reported to the malpractice insurance carrier.
10. Reinstate the reasonable design and construction standards that provided for things such as hallways wide enough to carry patients out on stretchers in cases of emergency.

Thank you for your consideration.