Until the time that all abortion facilities are closed, these facitilies must be required to follow the health and safety measures for their clients that are required for all outpatient/surgery facilites.  Therefore I strongly urge the Board of Health be required to implement and enforce the following :

1  Reinstatement all health and safety measures diluted unlawfully by the Board during its last amendment process.

2.Removal of  the Commissioner's ablility to grant permanent variances.

3.Reinstatement of the ability of the department to deny, suspend, or revoke the license to operate an abortiion facility for violations of any provision of Article 1 (32.1-123 et seq.) of Chapter 5 of Title 32.1.

4. Requiremnent for annual inspections of abortions facities, not biennial.

5. Reinstatement of requirement for all abortion facilites to report to OLC all incidents reported to their malpractice insurance carrier.

6. Reinstatement of design and construction requirements for hallways sufficiently wide enough for transportation of a patient on a stretcher during an emergency situation.

7. Requirement that all OLC inspections verify ultrasounds were performed at least 24 hours prior to every abortion procedure.

8. Reinstatement of the definition of "first trimester" as being the first twelve weeks from conception.

9. Reinstatement of  requirement for abortion facilities to verify all parts of the baby have been removed from the uterus during the aboriton procedure.

10. Reinstatement of requirment the abortion facilitity provide information for post-abortion counseling to each client.

Thank you for your attention to these serious matters.