Agencies | Governor
Virginia Regulatory Town Hall
Virginia Department of Health
State Board of Health
Regulations for Licensure of Abortion Facilities [REPEALED] [12 VAC 5 ‑ 412]
Action Amend the Regulation after Assessment and Receipt of Public Comment
Comment Period Ends 10/31/2018
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10/25/18  8:05 pm
Commenter: Stephen D Piscitelli, St Lawrence Catholic Parishioner, Alexandria, VA

Lessons Learned.from Gosnell in Philadelphia, PA - Women's Rights

We don't want another "Gosnell" fiasco like what happened in Philadelphia to happen here in our Commonwealth. Abortion center regulations and dutiful inspections are essential for the health and safety of Virginia women and must be enhanced, not weakened.  The abortion industry has fought regulation for years, yet repeatedly independent inspectors find serious deficiencies, even during announced inspections. Abortion centers are not able to self-regulate. Abortion procedures are fraught with health problems for women and thus are not healthcare because it puts the women's health at risk and discriminatorily ends the lives of potentially productive citizens of our Commonwealth. However, since abortion operates under the guise of healthcare, abortion centers must adhere to the regulatory standards of other healthcare facilities. Simply, Virginia women deserve nothing less.First do no harm.

Here are some changes I strongly urge the Board to adopt:

  1. Reinstate all of the health and safety measures the Board watered down during its last amendment process. We don't want to be caught as negligent as in Pennsylvania where Gosnell operated his butchery with impunity.
  2. Require all Office of Licensure and Certification (OLC) inspections to verify that ultrasounds have been performed at least 24 hours prior to every abortion performed. Women have a right to know.
  3. Require monthly inspections of abortion facilities instead of biennial. 
  4. Remove the ability of the Commissioner to grant permanent variances which is aggregious and dangerous.
  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." Life begins at conception as a matter of science..
  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." Otherwise the department would be complicit in criminal activity like infanticide versus promoting abortion operations such as found in Philadelphia under Gosnell.
  7. Reinstate the requirement that the abortion facility ensures that it has removed all of the fetal body parts from inside of the female patient upon the performance of an abortion because woman have basic health rights during any surgical procedure.
  8. Reinstate the requirement that abortion facilities report to OLC any incidents reported to the malpractice insurance carrier as the OLC could become complicit in negligence of a woman's rights to safety by ignoring blatient violaltions at abortion clinics.
  9. 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 which was a major factor in the death of women patients at the Gosnell clinic in Philadelphia.

 Thank you for your consideration.  Please ensure the health and safety of all women and make sure what happened in Philadelphia, PA doesn't happen here in the Commonwealth of Virginia. 


CommentID: 68343