‘Safe zone’ consultation response

This is a response letter to the public consultation on legislation for ‘safe zones’ surrounding abortion clinics in Northern Ireland, brought forward by Claire Bailey MLA

http://www.niassembly.gov.uk/assembly-business/committees/2017-2022/health/primary-legislation/abortion-services-safe-access-zones-bill/call-for-evidence/

The Christian Medical Fellowship in Northern Ireland continues to uphold the Biblical understanding that all human life is created by God, and starts at the moment of conception. From that point on until the moment of death, all life is of equal value in the eyes of God, and all life bears the image of God in a profound and mysterious way, no matter how tiny, flawed or damaged. As Christians we are bound by the 6th Commandment to prevent unjust death by all legal means, and to uphold life where it must be found. As healthcare workers we recognise the holistic nature of human existence – in addition to the physical nature we recognise the spiritual and transcendent nature of human existence, and recognise that each human being has an eternal soul, and will be judged by God. We seek to support Christian healthcare workers in Northern Ireland to practice to the very best of their ability in light of the revealed Word of God, to be like the Great Physician, the Lord Jesus Christ, in love, service and holiness, and to grow in their walk with God.

Please find below my submission on behalf of the Christian Medical Fellowship in Northern Ireland relating to the Abortion Services (Safe Access Zones) Bill.

  1.  
    1. It is not, and should not be, the responsibility of the Department of Health to advise on the policing of the environs of hospitals and clinics, especially those areas that are public land, or public rights of way.
    1. “Preventing or impeding access to the premises” – this is excessive. The vast majority of witness and work done outside abortion clinics is respectful and quiet, and neither prevents nor impedes access. “Influencing, harassing, alarming or distressing” – to influence someone may be a very positive thing, and it is not clear why this should be banned. Many women are in two minds about having an abortion, and a recent study (DP Sullins. Affective and Substance Abuse Disorders Following Abortion by Pregnancy Intention in the United States: A Longitudinal Cohort Study. Medicina (Kaunas). 2019 Nov 15;55(11).) found that up to 25% of women had an unwanted abortion. There are considerable concerns about the standards of consent being used when women are being counselled for abortions, and it seems highly unlikely the current standards of Montgomery compliant consent (Montgomery and informed consent – The MDU are being adhered to, lacking such things as a ‘cooling off period’ (untitled (rcog.org.uk)), and a full description of the potential severe risks that can be associated with medical abortion. When people are concerned that other members of society are putting themselves at risk, in the short term and in the much longer term, given the increased risk of psychological pathology following abortion (Sullins 2019), then to silence their voices is to deny a small window where a woman can consider a fuller range of viewpoints. It also gives a small window where women who are being coerced into having an abortion against their will may avail of help, with very clear material and practical support which the Sexual and Reproductive Health Services, and the NHS and Social Care as a whole are unable, or unwilling to provide. Many women to date have availed of this help, to their benefit and relief. To call the work that is done outside abortion clinics “harassing” is perjorative. The vast majority of work is silent, respectful, indeed sombre and humane. The picture painted in the media of noisy aggressive protests is flawed, and does not represent the vast majority of work done in this area. This is a straw man, designed to silence protesting voices and to push an ideological and authoritarian agenda at the expense of liberty. It is interesting to note that the words “alarming or distressing” are used. The very nature of medical abortion is both alarming and distressing – the nature of the process, the act in itself, and the outcome have both of these qualities. But perhaps it is appropriate for a certain amount of alarm to be generated – alarms are there to signal danger ahead, risks to oneself and others, to cause people to stay away from something dangerous – all of these things are valid in the work done outside abortion centres. Any distress noted amongst users of these services is mirrored in the distress felt by those present at the witnesses, who feel genuine sadness and distress, both for the women involved, the fathers and families of the children, and the unborn children themselves.
  2. This is a very broad brush. Supposing GP surgeries and pharmacies start to offer abortions – will there be ‘safe zones’ at every street corner and health centre? Indeed, to call these places ‘safe zones’, where the unnecessary death of an unborn child is commenced, is perverse.
  3. Again, the broad brush approach applied to such a wide variety of premises from the largest hospital to the smallest library, health clinic, pharmacy or hole in the wall. And all to be decided by the Department of Health whether it be valid to prevent ministry of the most profound and important type, dealing with the very nature of what it means to be human, what it means to be seen as precious in the eyes of the Almighty God. I am deeply concerned about the effect of such stipulations may mean for healthcare workers in these places – very many healthcare workers, Christian and not, are utterly opposed to abortion in Northern Ireland (An open letter against abortion in Northern Ireland – Simple GP). For our employer to then pass a judgement that our deeply held religious beliefs, our consciences, our perfectly valid and legitimate views are debarred from the entirety of our workplace is surely one of the most pernicious forms of discrimination. Many healthcare workers are driven and motivated by their faith, and in keeping with GMC and other guidelines (Personal beliefs and medical practice – GMC (gmc-uk.org)) are allowed, and indeed encouraged(Faith at end of life: public health approach resource for professionals – GOV.UK (www.gov.uk)), to discuss these things with patients. To apply ‘safe zone’ legislation to a health clinic, a hospital or other environment would be to effectively gag any discussion of faith – this would be unacceptable, in fact potentially harmful to many health care workers. It would leave them at risk of criminal charges for doing something for which their professional bodies actively encourage – would prayer meetings in hospital be banned or restricted? How about the hospital carol service? Would we even be allowed to celebrate the birth of Jesus Christ or read Psalm 139 where the psalmist describes how we were “knit together in [our] mother’s womb”? What are hospital chaplains to do whenever prayer is policed, one of the chief pillars of their work? To designate a hospital, for example, as a ‘safe zone’ would be potentially to ban Christianity, and any other religion, apart from humanistic secularism, from its corridors. So much for holistic care.
  4. Why is it that the same message when spoken to someone who is not a ‘protected person’ is allowable, but to a ‘protected person’ it is then forbidden? It is clear that there is a complete lack of objectivity – what might constitute offence one day may be allowed another day. This is a both a nightmare for anyone who would try and enforce it, but also an encouragement for those who would seek to ban other opinions, not just pertaining to abortion per se, but perhaps those expressing certain political opinions, for example. How about if I was to attend a hospital appointment, and there was an awareness raising event or stand promoting medical abortion – I would find this distressing; do I then get to have a say in banning this, purely because I am offended?
  5. It is concerning to think that potentially a handful, maybe even one or two members of staff in the Department of Health, unelected and not held to account, could have the final say on things like prayer, Bible reading, public preaching and talking to someone about their faith, not just within a hospital or clinic, but even extending out to the undefined area of the public realm, roads, footpaths, shop premises or even households nearby! Such powers to gag and restrict are too much for a liberal society, never mind fit to be held by unelected members of management within a healthcare setting.
  6. 2(a) as noted previously, influence may be very positive. I would point you towards those women who, after speaking to people involved in witness outside abortion centres, have changed their minds and carried their babies to term; I would also point you towards those women who, having taken the first abortion pill, have expressed regrets and availed of Abortion Pill Reversal services and have thankfully gone on to give birth to a healthy child – these women have had very positive influences and will attest to that. 2(b) there is already sufficient leeway for the PSNI to deal with those obstructing private or public ways. 2(c) see my note above – the greatest distress and alarm is caused during the process of abortion. 3 The use of video recording facilities in the public is not currently illegal unless it is for terrorist or criminal activities (Q717: I want to take some photos / video footage in public, is it now illegal? (askthe.police.uk)) Video recording at witness events is exclusively used for the protection of those at the witness – sadly, there have been a number of assaults against those engaged in quiet witness at abortion centres, video footage of which has been helpful in liaising with PSNI in pressing charges. Video facilities are not used to intimidate or trace workers or patients at facilities, because this would already be within the realms of existing legislation. It is not clear how intent could be proven, relating to the use of video, given its current use. 4 The assumption is that the presence of a ‘safe zone’ will not be publicised or signposted, then? This seems like an underhand way of limiting many things such as free speech and gospel proclamation in a widespread way, while pretending that no such thing is happening.
  7. It is deeply distressing to consider the prospect of people being removed by the PSNI, potentially forcefully, and fined for such dangerous acts as praying silently, reading a Bible in a public place, singing religious songs, preaching, or displaying Bible verses on placards. Christians who are involved in this ministry are motivated by love for their neighbour and obedience to God’s commands. The Bible teaches that Christians should obey the state when it comes to matters of the state, but when it comes to matters of faith, then the state has no say in these things. For the state to intrude into matters of faith is a gross overstep. In addition, if we consider non violent protests over the years, police involvement does not usually result in positive media coverage. It is especially troubling to note 7(2), requiring recording media to be turned off. The PSNI are also subject to scrutiny in their handling of protests and people judged to be breaking the law, and video evidence of police brutality and abuse of power has been vital across the world over the last few years, yet the suggestion is that this should not be allowed for this particular exception? 7(5) it is troubling that the simple act of quiet prayer could cost a faithful Christian £2500, for an act motivated by compassion and a quiet commitment to our compassionate Father in Heaven.
  8. 8 weeks from start to finish to bar the exercise of the Christian faith from a wide selection of areas including the public highway? With no consultation with local faith groups, churches, politicians, prior announcement, right of appeal, idea of duration or plan to review this dictat?
  9. It is right and proper to consider these conflicting rights. It is my view that the current legislation is sufficient to deal with anyone who exceeds the current law with this issue. To make a new law forbidding certain expressions of the Christian faith, or potentially the Jewish or Muslim faith, in a particular area, due to arbitrary and ill defined notions of offence, harassment and distress is unnecessary, and a worrying precedent to set at this time when freedom of expression is under attack in many areas. It is all to easy to foresee a situation where dissent from the majority view of the day in area could be criminalised. What is best is for all viewpoints to be in the public arena to allow them to be examined, rather than some to be excluded for flawed reasons. This is especially important when it comes to human life – when it starts, when it ends, what our duties are as healthcare workers, and specifically as Christian healthcare workers. It is no secret that very many people in Northern Ireland disagree profoundly with abortion, it is also no secret that the legislation which brought about abortion provision was forced upon Stormont in a non-democratic way. Protest against abortion is also protest against unrighteous and incompetent government and politicians, as it is a witness and a caring ministry to women and children in great need and at great risk.
  10. It is not clear how a government department would be able to measure, qualitatively or quantitively, the effectiveness of ‘safe zones’ – perhaps through fines levied? Increased rates of abortion? More and more widespread restrictions on witness and faith activity?

Yours sincerely

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