Sir, – As the doctor appointed by the minister for health in 2018 to advise the HSE on the implementation of the Termination of Pregnancy Act, I share the serious concerns about the forthcoming review of the legislation and its operation expressed by Orla O'Connor and the National Women's Council of Ireland ("Donnelly is dragging his heels on abortion review", Opinion & Analysis, December 15th).
I agree that an independent chair should be appointed without further delay, and critically that the review’s terms of reference must be framed to ensure that if the evidence suggests the need for legislative and policy changes, these can be brought forward.
I would highlight four areas in particular that require careful attention to ensure that unnecessary systemic barriers are not limiting access to legal abortion services.
The uneven provision of the service in only 10 of the State’s 19 maternity units needs to be addressed.
The three-day period waiting period is patronising and unnecessary and should be removed.
Parents’ concerns about access to termination in cases of foetal abnormality may mandate legislative review to eliminate the need for unnecessary or unreasonable travel abroad to access appropriate care.
Finally, a hitherto overlooked serious systemic barrier to access is the anomaly in the HSE guidelines which limits the definition of 12 weeks of pregnancy to 84 days from the first day of a woman’s last menstrual period. In universal medical practice, a woman is 12 weeks pregnant until she is 13 weeks pregnant. Twelve weeks of pregnancy is 90 days, not 84, and this is clear and correctly stated in all other HSE material relating to pregnancy.
My efforts in late 2018 to ensure that the correct medical definition of 12 weeks was included in the guidelines met with immovable resistance from within the Department of Health.
This novel definition of 12 weeks of pregnancy should be corrected without further delay. – Yours, etc,
Dr PETER
BOYLAN,
Dublin 6.