Credit: D Storan /

Submissions to the abortion review are not as straightforward as might be expected

As a statistician interested in pro-life issues, I was naturally interested in making a submission to the current abortion review. Having analysed data from the first two years of our new abortion regime, I gathered the findings (plus commentary) into a Word document, and attached this Word document to an email, which I then sent to the address provided by the Department of Health: [email protected]

The full Word document is too long for posting as a blog here on this site, and in parts duplicates material which has been posted on this and other sites in the past. In summary, these are the points I had made, and supported as appropriate with statistical evidence, in the full document:

  • The effect of the 2018 abortion legislation was to increase abortion numbers here
  • Abortion rates here were rising sharply pre-Covid, 30% higher in Q1 2020 than in Q1 2019
  • Financial supports from the State for pre-abortion counselling, and for continuing  with crisis pregnancies, are non-existent
  • The State pays abortion providers much more generously than medics managing pregnancies to term
  • The three-day reflection period clearly allowed women, in large numbers, to change their minds about abortion
  • There has been very considerable inter-county variation in abortion rates, possibly explainable by variation in quality of pre-abortion counselling from individual abortion providers
  • Post-abortion women’s mental and physical health are issues that need addressing
  • About 8% of women (about 500 women a year) are hospitalised here after taking abortion pills. Is there a relationship between gestational age and hospitalisation e.g. are there relatively more hospitalisations after abortions at 9 weeks gestation than at 6 weeks?


It would be hard to find anything in this list that does not constitute a valid contribution to the abortion review.

But here’s the thing. After some interaction, via email, with the Bioethics Unit, I came to the conclusion that, submitting this document in this way, I ran the risk of having the document, its entire contents, rejected by the review body. There is an ominous statement on the Submission website, echoed in the email reply that I received, as follows:

Submissions responding to the questions set out in the consultation document below  are welcome. Submissions outside the scope of the review of the operation of the Health (Regulation of Termination of Pregnancy) Act cannot be addressed in this forum.


The problem here is that the consultation document has pre-determined headings, which allow little or no scope to submit any material other than what fits under these headings.  Moreover, the headings themselves seem rather vague, and subject to misinterpretation:

  • Q3 (a) To what extent do you agree that the Health (Regulation of Termination  of Pregnancy) Act 2018 has achieved what it set out to do?
  • Q4 (a) Are there parts of the Act which, in your opinion, have not operated well?
  • Q5 (a) Are there parts of the Act which, in your opinion, have operated well?
  • Q6 Are there any further comments you would like to make on the operation  of the legislation?
  • Q7 Do you have any comments about services provided under the Act?


As to Q3(a), there were conflicting claims in 2018 about what this Act was meant to achieve. Remember the mantra “safe, legal and rare”, used by at least three members of government in the referendum campaign? By that measure, the Act is an abysmal failure, whereas if the Act’s purpose was to reduce the number of Irish abortions abroad, then it was a success. Q3(a) assumes that everyone is agreed on the purpose of the Act, but that is not the case.

The other questions on the abortion review form distinguish between the operation of the legislation and the services provided under the Act, but are these not two sides of the same coin? I found this confusing.

In the end, when copying and pasting material from my Word document into the review form, I pasted material on the three-day reflection period under Q5(a), because I could relate this material specifically to a section of the Act. I pasted other material – on pre-abortion counselling, regional variation in abortion rates, payments to medical practitioners, and lack of State support for continuing with a crisis pregnancy – under Q7.

A large chunk of material in my original Word document – on changes in abortion rates here and in Portugal, post-legalisation, for example – I had to omit entirely from the abortion review form, because I could not see where it logically belonged. But this is important information, surely, and it is somewhat troubling that I felt unable to include it. I could have put this material somewhere on the form supplied, logical or not, but that ran the risk of my whole Submission being excluded as being “outside the scope of the review”.

In fact, I am a little worried that this will happen to me anyway, and to others who are pro-life.

By approaching the review in the way he has, the Minister for Health has given himself plenty of room here for burying contributions which he does not like.

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