Public comment of The National Catholic Bioethics Center et al. on Proposal to clarify requirements for pronouncement of death by the Organ Procurement and Transplantation Network
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On December 23, 2022, the US Food and Drug Administration (FDA) changed its Drug Facts Label for Plan B One-Step (PBOS), removing language that, since 2006, had stated that PBOS “may inhibit implantation (by altering the endometrium).” The FDA’s action has created the impression that PBOS and similar, generic levonorgestrel-based drugs used for “emergency contraception” (LNG-EC) have no effect on the survival of a human being conceived following sexual assault.
Unfortunately, the FDA did not address all factors relevant to how LNG-EC can impact human life after fertilization. Specifically, the FDA did not fully address a well-known concern that LNG-EC can prevent pregnancy even after it fails to prevent ovulation. Since this important issue was not resolved and concerns about LNG-EC’s post-fertilization effects remain, the National Catholic Bioethics Center will maintain its longstanding position that Catholic health care institutions and professionals should ensure with moral certitude (that is, by excluding any reasonable doubts), at a minimum, that LNG-EC is not dispensed when it could not prevent ovulation but may well cause the death of an embryo. Catholics should resist legislation that requires dispensing of LNG-EC on the basis of a negative pregnancy test alone.
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