1.  INTRODUCTION

  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 later.

  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 statistics.

  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 normal.

  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 ABORTION—MEDICAL AND PSYCHOLOGICAL

  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 nature.

  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 MIDWIVES PARTICIPATION AND HOME ABORTIONS

  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.  REQUIREMENT FOR TWO DOCTORS' SIGNATURES

  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 NUMBERS OF ABORTIONS

  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 Act.

  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.

9.  EXECUTIVE SUMMARY

—  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 for all.

—  Abortion figures in the UK continue to rise, and our rates are much higher than most comparable European countries.

—  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.

August 2007