Submission from Comment on Reproductive
1.1 This submission is written on behalf
of Comment on Reproductive Ethics (CORE), a non-profit organisation
which addresses ethical issues associated with human reproduction.
As well as directing CORE I also bring to this consultation the
experience of 20 years of crisis pregnancy counselling in Central
London. I have been involved personally in assisting some 8,000
women (and sometimes other family members) facing difficulties
in pregnancy or after abortion.
1.2 CORE believes the right to life begins
at fertilisation and is therefore opposed to abortion in all cases
where it is performed deliberately. This does not apply in those
cases where abortion has either occurred naturally or as the non-intentional
consequence of medical intervention aimed at providing life-saving
treatment for the mother.
1.3 The Committee has asked for submissions
addressing scientific developments associated with abortion, and
has deliberately excluded discussion of ethical or moral issues.
The focus on the need for two doctors and the possibility of other
medical staff performing abortions, as well as home abortion,
follows very much the proposals of the Abortion Law Reform lobby.
We are disappointed that the Committee did not hold to its broader
recommendation, as specified in their Fifth Report of Session
2004-05, where the proposal was to have representatives from the
Science and Technology Committees of both Houses as well as the
Commons' Health Select Committee in order "to consider scientific,
medical and social changes in relation to abortion since 1967,
with a view to presenting options for new legislation."
1.4 Whilst CORE finds it unsustainable that
ethical issues can be successfully removed from any discussion
of abortion, we will nevertheless aim to contain our response
as far as possible within the Committee's proscribed remit. We
have highlighted in bold some main points in our response.
2. COMMON GROUND
2.1 CORE would like in the first instance
to establish some sense of a common ground from which to initiate
this response, which will inform considerations we intend to raise
2.2 The agreement we sincerely hope exists
between organizations such as our own and your Committee, and
indeed with the public at large, is the concern that abortion
figures in the United Kingdom are increasing at a rate which cannot
be seen as desirable no matter what one's ethical position on
the acceptability or not of abortion. Whatever the level of support
for abortion or the enthusiasm of pro-choice lobbies, it should
be agreed that no woman would have an abortion if she could possibly
avoid it, and that the escalation of abortion figures is a problem
which needs addressing at its roots.
2.3 The National Health Service is based
on the principle of prevention. The aim of any modern healthcare
system is surely to make abortion as rare as possible. In order
to achieve such a goal we believe it is necessary to analyse the
provision of abortion in this country with much greater transparency
than is currently the case.
2.4 At this stage we would like to recount
briefly two particularly poignant, but not unique, stories of
abortion in the United Kingdom which we hope will remind the Committee
of the need to move our focus far beyond a simple assessment of
fetal viability and current medical developments, let alone the
facile rhetoric of choice.
2.5 The first is the story of teenager known
personally who was in care and had her 3rd abortion on her 16th
birthday. The other case concerns a young girl of 14 who had such
serious complications after an abortion, with fetal remains left
in her womb, that she had to have a hysterectomy to save her life.
Her parents had not been told about the abortion and were only
contacted at the time of the hysterectomy, which took place in
a London hospital this year. The medical and psychological impact
on the individuals personally involved and society at large are
unquantifiable. Such cases as these simply disappear within the
bland tables and figures which constitute our yearly abortion
2.6 The argument CORE will make later is
that we need to collect much more accurate information on the
reasons for which abortions are being performed and we also need
a far better mechanism in place for collating short and long term
effects of abortion.
3. FETAL VIABILITY
3.1 If it is the intention of the committee
to argue that the upper limit for abortion (24 weeks) does not
correspond to current understanding of fetal viability, then we
would certainly agree.
3.2 You will be receiving extensive evidence
on this issue from organisations more specialised than CORE, and
our only comment is that we feel the benefit of doubt should always
be on the side of the unborn baby. It is notoriously difficult
to estimate gestational age when the mother seeks medical care
for the first time at the later stages of pregnancy, and estimates
can be in error up to two weeks either way. This is reflected
in obstetrics generally, where the average gestation is deemed
to last 40 weeks but 38-42 week pregnancies are considered absolutely
3.3 Intensive care baby units analysing
the survival rates of premature babies are those who normally
provide evidence in this field but parallels with abortion must
be drawn very carefully. Often abortion is performed on a perfectly
healthy baby (when reasons other than fetal health are involved).
In such circumstances the aborted unborn child is likely to be
far more robust than one born prematurely as a consequence of
existing medical reasons.
3.4 Whatever the decisions about fetal viability,
we urge the committee to address the question of pain relief for
the baby undergoing abortion. The Royal College of Obstetricians
and Gynaecologists recommends feticide before late abortion, but
this is not always provided, and sometimes it does not work, and
can itself be painful.
4. SERIOUS ABNORMALITY
4.1 Outside the confines of abortion, definitions
of abnormality are usually discussed with a view to determining
the level of societal assistance required to ensure equality of
disabled people with so-called "normal" human beings.
Such definitions are very difficult to reach without denigrating
those with physical or intellectual impairment, who become more
often than not subsumed by the definition.
4.2 In the abortion arena the purpose of
the definition is even more equivocal and sinister. We are being
asked for a yardstick to determine who should live and who should
die. CORE argues that it is impossible to make any contribution
in this regard without entering into the moral debate that such
comments would demand. We are not prepared to make lists of which
disabled baby should live and which should die.
4.3 In actual practice in the UK abortions
are performed for conditions such as cleft palate and clubfoot,
so "serious abnormality" has already become very broadly
interpreted. It is very unlikely that interpretation of the present
law will become more rigorous no matter how much time is spent
debating the meaning of "serious".
5. RISKS OF
5.1 CORE is a member of Alive & Kicking,
an alliance of groups campaigning to reduce the number of abortions
in the United Kingdom, and whose membership includes medical professionals.
CORE aligns itself with the position taken by the Christian Medical
Fellowship (CMF) in relationship to long-term or acute adverse
health outcomes from abortion, whether of a medical or psychological
5.2 Rather than burden the Committee with
identical lists of references, we suggest that the reference material
supplied by the CMF be given the most serious consideration. We
draw particular attention to the French EPIPAGE study, published
in BJOG 2005, focusing on "Previous induced abortions and
the risk of very preterm delivery", and research by Prof
D M Fergusson from Canterbury University in New Zealand, addressing
mental health problems associated with abortion.
6. NURSES OR
6.1 We are not in favour of allowing nurses
and midwives to perform abortions. The suggestion is dismissive
of the welfare of women and the proper care due to them. It is
simply an insensate proposal to solve the problem of the shortage
of properly qualified doctors prepared to carry out abortions.
It should be recognised openly that this shortage exists primarily
because the number of women seeking abortion is already very high
and continually rising, but we also believe that new generations
of doctors are more reluctant to dedicate their skills to this
operation than in the past. To work to reduce the number of abortions
is a far more rational solution than reducing the level of professional
care for the women involved.
6.2 Similar objections apply to home abortions.
Were any of these proposals to be implemented, we foresee an inevitable
increase both in the incidences of medical complications as well
as added psychological stress. It would be particularly harrowing
for women to experience the physical reality of abortion while
alone at home.
7.1 This requirement is currently not enforced
in any meaningful way. It should be both retained and respected.
Abortion is permitted in law as an exemption, not as a right,
and it is the duty of the doctors to ensure that the law is respected
as intended. The purpose of the law is not only for the benefit
of the mother but also to respect the right of the unborn child
not to be the victim of an illegal termination.
8. REDUCING THE
8.1 Moving forward from the premise that
fewer abortions would be a desirable objective, we suggest that
there is an immediate need for far greater transparency in relationship
to the provision of abortion in the first place. More precise
details should be collected on abortion referral forms, and the
resulting data be made readily available for analysis. We need
to collate and face the facts.
8.2 Currently 97% of all abortions are justified
under Ground C of the Abortion Act, (grouping together the medical
or psychological health of the mother). We have absolutely no
way of identifying what percentage is one or the other. Any reform
of the Abortion Act should address this inadequacy. Medical and
psychological health are important issues in the provision of
abortion, but represent two very different categories of health
care and should be separated under the conditions of the Abortion
8.3 We believe the Committee should also
be investigating why women are having abortions, beyond the generics
of medical or psychological reasons. Is the current increase the
result of financial, work-related, relationship, or other societal
pressures? This is essential information if we are to impact in
any way on escalating abortion figures. We need to identify the
problems and provide solutions.
8.4 We would like to see much greater transparency
applied to the collection of statistical data, when performed
on the grounds of fetal abnormality. The case in 2001 of a baby
aborted at seven months for cleft palate received huge media attention,
and in general the public reaction was of disquiet. Subsequently
the Abortion Statistics became considerably less specific in identifying
details of the abnormalities for which abortions have been performed.
We would like the Committee to question why this backwards step
has been taken. Discussion of what does or does not constitute
a serious abnormality becomes academic if disinformation and obfuscation
is all that is available to the concerned public.
8.5 Maternal complications relating to abortion
are currently only reported within the time-span of the immediate
abortion. If anything happens after the patient has left the clinic
it does not have to be included on the abortion form. We have
no information therefore regarding subsequent complications. The
hysterectomy of the 14-year-old girl, for instance, will not appear
in any data relating to abortion. If we are to have an accurate
account of the medical and psychological consequences of abortion
then we have to keep more accurate records and cross-reference
at a much later date than is the current practice.
8.6 Some 1% of abortions are currently performed
under Condition D of the Act which permits abortion to avoid "injury
to physical or mental health of any existing children or family".
CORE would urge the Committee to seek clarification as to what
is meant by this clause.
We reiterate our opposition to all
forms of abortion.
Neonatal medicine has made considerable
progress in the recent decade and premature babies are able to
survive at much younger gestational age than before. This progress
is likely to continue and may well influence decisions regarding
the upper limit for abortion.
Most abortions, however, take place
in the first trimester of pregnancy not at the limits of viability,
and this is the real problem we need to address.
Abortion on the grounds of any form
of disability is contrary to our commitment to disability rights
Abortion figures in the UK continue
to rise, and our rates are much higher than most comparable European
It is argued that abortion is necessary
but it can never be claimed that it is desirable. We should be
making significant efforts to reduce the numbers of abortions
in our country, by addressing the reasons that bring women to
the decision to abort their pregnancies. In the first instance
this will require extensive and honest analysis of the existing
situation. The collection of abortion data needs to be much more
focused and transparent so that we can identify what is causing
the alarming increase in overall numbers.
We must then invest seriously in
providing positive solutions to the problems revealed, solutions
which do not rely on the abortion of the unborn child.