Help us secure safe and accessible abortion in Northern Ireland

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Question 1: Should the gestational limit for early terminations of pregnancy be: 
A. Up to 12 weeks gestation (11 weeks + 6 days) Answer: No B. Up to 14 weeks gestation (13 weeks + 6 days) Answer: No C. If neither, what alternative approach would you suggest? Answer: The gestational limit should be set at 24 weeks. The overwhelming majority of abortions are performed before the end of the third trimester (12 weeks) by taking two types of pill, however, some women may not realise they are pregnant before the proposed restricted gestation limits of 12 and 14 weeks. Delayed recognition/presentation of pregnancy is more common amongst vulnerable women such as younger women or victims of domestic abuse, therefore a shorter time limit has the capacity to harm those who need the services most and would not meet the requirements set out in the CEDAW report. 
Question 2: Should a limited form of certification by a healthcare professional be required for early terminations of pregnancy? Answer: No B. If no, what alternative approach would you suggest? Answer: As abortion in Northern Ireland is no longer a criminal matter, as the 1861 Offences Against the Person Act has been repealed, there is no need for there to be a certification process in place. This process is not medically necessary nor used for statistical purposes, but was previously used to certify that the abortion could legally take place. Without criminal legislation in place, this process has become redundant and therefore should be removed.
Question 3: Should the gestational time limit in circumstances where the continuance of the pregnancy would cause risk of injury to the physical or mental health of the pregnant woman or girl, or any existing children or her family, greater than the risk of terminating the pregnancy, be: A. 21 weeks + 6 days gestation Answer: No
 B. 23 weeks + 6 days gestation Answer: Yes
 C. If neither, what alternative approach would you suggest?  Answer: N/A
Question 4: Should abortion without time limit be available for fetal abnormality where there is a substantial risk that: 
A. The fetus would die in utero (in the womb) or shortly after birth Answer: Yes B. The fetus if born would suffer a severe impairment, including a mental or physical disability which is likely to significantly limit either the length or quality of the child’s life  Answer: Yes
C. If you answered ‘no’, what alternative approach would you suggest? Answer: N/A
Question 5: Do you agree that provision should be made for abortion without gestational time limit where:
A. There is a risk to the life of the woman or girl greater than if the pregnancy were terminated? Answer: Yes B. Termination is necessary to prevent grave permanent injury to the physical or mental health of the pregnant woman or girl? Answer: Yes C. If you answered ‘no’, what alternative provision do you suggest? Answer: N/A 
Question 6: Do you agree that a medical practitioner or any other registered healthcare professional should be able to provide terminations provided they are appropriately trained and competent to provide the treatment in accordance with their professional body’s requirements and guidelines? Answer: Yes 
B. If you answered ‘no’, what alternative approach do you suggest? Answer: N/A
Question 7: Do you agree that the model of service delivery for Northern Ireland should provide for flexibility on where abortion procedures can take place and be able to be developed within Northern Ireland? Answer: Yes B. If you answered ‘no’, what alternative approach do you suggest? Answer: N/A
Question 8: Do you agree that terminations after 22/24 weeks should only be undertaken by health and social care providers within acute sector hospitals? Answer: No B. If you answered ‘no’, what alternative approach do you suggest? Answer: There is no clinical reason why abortions post 24 weeks need to carried out in acute hospitals. This is a historical feature from the Abortion Act 1967, which is still in operation in the rest of the UK but is out of step with modern medical practice. There is no medical reasons why most of these procedures could not take place in licensed clinics. 
Question 9: Do you think that a process of certification by two healthcare professionals should be put in place for abortions after 12/14 weeks gestation in Northern Ireland? Answer: No B. Alternatively, do you think that a process of certification by only one healthcare professional is suitable in Northern Ireland for abortions after 12/14 weeks gestation?  Answer: No
C. If you answered ‘no’ to either or both of the above, what alternative provision do you suggest? Answer: A certification requirement isn’t necessary at all. While this requirement remains in the rest of the UK, it is used to certify that the abortion can be carried out with regards to a law which criminalises abortion and is not medically necessary. As this law no longer applies in Northern Ireland, this process is redundant. It is also not necessary for the collection of medical data as information such as gestation, method of abortion, and age of the pregnant woman can be obtained through other means, like all other medical procedures. To impose a separate legal notification system for abortion exceptionalises and stigmatises abortion.
Question 10: Do you consider a notification process should be put in place in Northern Ireland to provide scrutiny of the services provided, as well as ensuring data is available to provide transparency around access to services? Answer: No B. If you answered ‘no’, what alternative approach do you suggest? Answer:  We do not think that a notification requirement is necessary at all. This requirement in the rest of the UK is not medically necessary but used to certify that the abortion can be carried out within exceptional grounds with regards to a law which criminalises abortion. As this law no longer applies in Northern Ireland, this process is redundant. It is also not necessary for the collection of medical data as information such as gestation, method of abortion, and age of the pregnant woman can be obtained through other means, like all other medical procedures. To impose a separate legal notification system for abortion exceptionalises and stigmatises abortion.
Question 11: Do you agree that the proposed conscientious objection provision should reflect practice in the rest of the United Kingdom, covering participation in the whole course of treatment for the abortion, but not associated ancillary, administrative or managerial tasks? Answer: Yes B. If you answered ‘no’, what alternative approach do you suggest? Answer: N/A
 
Question 12: Do you think any further protections or clarification regarding conscientious objection is required in the regulations? Answer: No B. If you answered ‘yes’, please suggest additional measures that would improve the regulations:  Answer: N/A
Question 13: Do you agree that there should be provision for powers which allow for exclusion or safe zone to be put in place? Answer: Yes B. If you answered ‘no’, what alternative approach do you suggest? Answer: N/A 
Question 14: Do you consider there should also be a power to designate a separate zone where protest can take place under certain conditions? Answer: No
B. If you answered ‘no’, what alternative approach do you suggest? Answer: A safe zone only covers a specific area outside the clinic. A ‘separate zone’ where anti-abortion protest activity is allowed is everywhere else outside this zone. A separate zone will not placate anti-abortion activists who have made repeatedly clear that they want direct access to women as they enter clinics. Given the history of attempts to police anti-abortion protests in Northern Ireland, a separate zone is likely to need constant enforcement to force protesters to abide by the rules – taking up policing time and causing distress to women who may still have to pass this zone. 
Question 15: Have you any other comments you wish to make about the proposed new legal framework for abortion services in Northern Ireland? Answer: No

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