The Adelaide Hospital Society has written to the Minister for Health, Mr Martin, expressing grave concern that the Government's proposed anti-abortion amendment poses "major threats to women's healthcare".
The AHS is a charitable society that supports the provision of health services to the public, irrespective of religious affiliation, through a public voluntary teaching hospital, specifically Tallaght Hospital since the Adelaide was merged into it.
The letter says the society has taken professional advice about the Protection of Human Life in Pregnancy Bill, which will be protected by the Constitution if the amendment is passed, and it lists six areas of concern.
These are: the implications of the Bill for the healthcare of women who have had abortions; the exclusion of the threat of suicide, of incest and rape, and of a seriously malformed foetus as grounds for abortion; problems for the emergency medical treatment of pregnant women and concerns for existing contraceptive and assisted human reproductive services.
The letter says that reducing crisis pregnancies, and providing comprehensive healthcare for all Irish women, particularly those who have had or will have terminations, must take precedence.
"The new Act does quite the opposite: it reinforces the stigmatisation of thousands and thousands of Irish women who have terminations outside Ireland," it says. They would be led to believe that they faced imprisonment for 12 years if they had such abortions in Ireland, and this would mean that their reluctance to access necessary advice and healthcare would be reinforced.
It is also critical of the prohibition in the Bill on the threat of suicide as a ground for abortion. It says that, while it is rare for pregnant women to be suicidal, this does occur, and such women should be provided for.
"The thinking behind this appears to imply that women would feign this condition in order to obtain an abortion and that the profession of psychiatry would collude with this," the letter says. "The Adelaide Hospital Society believes that this is a shocking implication in relation to Irish women and the profession of psychiatry."
Referring to the exclusion of rape and incest as a ground for abortion, it says it enforces such pregnancy on young girls or women unless they travel to another more compassionate jurisdiction, for which they need resources and support, which might not always be available.
It also says that the new Act will force women with a foetus suffering from very serious defects incompatible with life, such as anencephaly, to carry on with the pregnancy, even when they do not want to.
"The mental and physical health of such women should be paramount," it says.
The letter also refers to the provision for terminations in the new Act, where it is necessary "to prevent a real and substantial risk of the loss of the woman's life".
It says there is no provision here for dealing with emergencies that occur in pregnancy, involving such a threat, if such a woman is not close to an "approved place" for such a termination as outlined in the Act. This could place women's lives at risk.
It warns of "an appalling healthcare vista" relating to contraception and infertility treatment that could result from the unknown consequences of judicial interpretation of the existing Article 40.3.3, combined with the new Act.
The Attorney General, Mr Michael McDowell, said on RTÉ that the amendment was based on a large consensus. "The middle 80 per cent of Irish people, I believe, are the potential market for this particular proposal," he said.