I'm not a fan of unecessary regulations, but in the area of reproductive health, I believe it's critical to hold abortion centers to the same type of reasonable regulations that apply to any other health care faciilty. Abortion is an invasive procedure that destroys a life—it's not a simple, natural procedure that can be approached casually. Things can go wrong, and it would be even more tragic to end two lives or destroy a woman's reproductive ability because of a preventable complication. 

Although the abortion industry has fought regulation for years, independent inspectors have repeatedly found serious deficiencies, even during announced inspections. Abortion centers are not any better able to self-regulate than any other health-care facility, so it's important that a solid external oversight process be in place. 

Please consider the following suggestions:

1. Reinstate all of the health and safety measures the Board watered down during its last amendment process. 
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. 
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 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. 
8. Reinstate the requirement that abortion facilities report to OLC any incidents reported to the malpractice insurance carrier.
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.

To take the life of a human being is a terribly sad thing, and to endanger the life of a woman while doing so is unecessarily risky. I thank you for considering these reasonable recommendations.