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Written Testimony of Jill L. Stanek Concerning the Morning-After Pill 12/16/2003 Joint Meeting of the FDA Nonprescription Drugs Advisory Committee and the FDA Advisory Committee for Reproductive Health Drugs Hearing on Women's Capitol Corporation ~ Docket number 01P-0075 December 16, 2003 by Jill L. Stanek, R.N. for Concerned Women for America of Illinois 11664 Sundance Trail ~ Mokena, Illinois 60448 815-464-0984 (home) ~ 815-274-2744 (cell) jillstanek@comcast.net
The physical and social dangers to prepubescent and pubescent girls
The purpose to make specific medications available by prescription only is to keep the American public from harm as well as to allow medical professionals the opportunity to assess, diagnose, and educate patients before planning and implementing their care.
Medical professionals treat patients holistically, concerned not only with their physical health but also their emotional, psychological and social well-being.
I am a registered nurse with 10 years experience, six of which were in hospital obstetrics and gynecology, who is alarmed about the potential dangers in all the aforementioned areas to prepubescent and pubescent girls if emergency contraceptives are made available without prescription.
One emergency contraceptive pill contains amounts of estrogen and/or progesterone 10 to 15 times higher than a single day's dose of the birth control pill, with instructions to take this pill twice in 12 hours.
This in itself is of concern, particularly because of the potential for emergency contraceptives to wreak havoc on a developing girl's body. There has never been a randomized controlled study on the long-term and/or multiple use effects of emergency contraceptives.
Culture & Cosmos reported just last month that the blood clot causing the death of 16-year-old Stacey Bindle of New Zealand might have been due to the use of contraceptives, according to a coroner's report (Attachment 1). Bindle's parents are considering joining "what is a growing trend of lawsuits against contraceptive manufacturers" because their daughter probably was not told of health risks associated with taking the drug.
Thus, endorsements of over-the counter emergency contraceptives by the AMA, ACOG, and family planning clinics might be self-serving and designed to thwart getting sued for not providing informed consent.
Making emergency contraceptives readily available would be a welcome tool for sexual predators who molest family members, children of friends, or students; or adult "boyfriends" who commit statutory rape.
Rapists and incestuous predators could stock up on emergency contraceptives, keeping a stash in their bedroom drawers or pockets to give to their victims after committing each sexual crime.
The Bangkok Post reported last year, "Several random studies have shown that men are the most frequent buyers of the morning-after pills and that many learn about it from adverts in men's magazines" (Attachment 2). Emergency contraceptives have been available over-the-counter in Thailand for 16 years.
The Post quotes Dr. Nattaya Boonpakdee, program assistant at the Population Council: "They buy pills for their girlfriends or wives so that they don't have to wear condoms…. Some women I've spoken to said they that they didn't even now what they were taking; that the guy just said it was a health supplement."
The availability of emergency contraceptives over-the-counter would only increase the likelihood of rape and incest of young girls by adult men.
The research arm of Planned Parenthood, the Alan Guttmacher Institute, reported, "The younger women are when they first have intercourse the more likely they are to have had unwanted or nonvoluntary first sex, 7 in 10 of those who had sex before age 13, for example." (Attachment 3)
Planned Parenthood reported, "Teenage girls with older partners are more likely to become pregnant than those with partners closer in age." (Attachment 4)
Planned Parenthood reported, "teenagers who have been raped or abused also experience higher rates of pregnancy - in a sample of 500 teen mothers, two-thirds had histories of sexual and physical abuse, primarily by adult men averaging age 27." (Attachment 5)
Planned Parenthood reported, "Among women younger than 18, the pregnancy rate among those with a partner who is six or more years older is 3.7 times as high as the rate among those whose partner is no more than two years older." (Attachment 5)
Clearly, sexually active young girls are likely to be the victims of sexual abuse, and interaction with medical professionals is an important defense.
NARAL Pro-Choice America identified the vital link that health care professionals provide girls who want emergency contraceptives in December 2001 when it stated, "The need for emergency contraception can bring women, and young women in particular, into family planning centers, where they can receive other health care services and counseling. For those who remain sexually active, emergency contraception provides a bridge to ongoing contraception and disease prevention." (Emphasis added.)(Attachment 6)
Dr. Joycelyn Elders coauthored a commentary published in the Journal of the American Medical Association in 1998 on adolescent pregnancy and sexual abuse. She expressed concern that even in the clinical setting, the rush to choose "pregnancy outcome options" may preempt a workup to rule out sexual abuse (Attachment 7).
Without the medical professional link to contraceptive services, the likelihood is much greater that a sexual predator will continue committing his crime under the radar and at greater frequency if he can find a way to keep his victim from going to a clinic or doctor to seek contraception or have pregnancy diagnosed.
Girls who are questionably pregnant are clearly potential victims of sexual abuse, as Dr. Elders and her coauthor Alexa Albert stated: "Sexual abuse is a common antecedent of adolescent pregnancy, with up to 66% of pregnant teens reporting histories of abuse…. Pregnancy may also be a sign of ongoing sexual abuse…. Boyer and Fine found that of 535 young women who were pregnant, 44% had been raped, of whom 11% became pregnant as a result of the rape. One half of these young women with rape histories were raped more than once."
Dr. Elders and Albert stated, "The incidence of nonvoluntary sexual experiences that occur in adolescence, and thus, could lead to teen pregnancy, appears greater than previously assumed."
Dr. Elders and Albert stated, "Coercive sex acts against adolescent girls are frequently perpetrated by their boyfriend…. Boyfriends who are considerably older than their adolescent girlfriends have been found to be responsible for a majority of teen pregnancies."
Dr. Elders and Albert concur with Planned Parenthood and the Guttmacher Institute, that "the younger the mother, the greater the partner age gap." They reported "that fathers are on average 9.8 years older than mothers 11 to 12 years of age."
Dr. Elders and Albert concluded, "Health care professionals need to improve their abilities to identify and support adolescent girls who are experiencing nonvoluntary sex and are subsequently at risk for unplanned pregnancies. The possibility of sexual abuse should be considered routinely in every adolescent female patient who has initiated sexual activity, premenarcheal or postmenarcheal, pregnant or not. A thorough sexual history must be obtained in a caring and nonthreatening way, including asking the teen patient if anyone has ever touched her sexually or forced her to have sex when she did not want to. Pregnant teens should be asked if they wanted to have intercourse at the time they became pregnant. Breaking the code of silence can be the first step to halt ongoing abuse and begin the healing process." (Emphasis added.)
Dr. Elders' recommendations would be preempted if emergency contraceptives are made available over-the-counter.
The Bangkok Post continues, "Although many feminists believe that the morning-after pill gives them more control over their own bodies, it would seem, judging from the few studies conducted so far, that it is actually being used by men to exploit women."
How much more would minor girls be exploited if emergency contraceptives are available over-the-counter?
Over-the-counter access to emergency contraception will increase the likelihood that sexual perpetrators who are molesting young girls will prolong their rapes undetected and will also increase the likelihood of increased sexual abuse of girls.
Respectfully submitted,
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