April 19, 2023

A New Challenge to the FDA to Cease “Incredibly Lawless” Neglect of the Environment in its Chemical Abortion Pill Policy in Third Citizen Petition


On Earth Day 2023, SFLA & more than 150 Student Groups Demand Environmental Justice for Preborn Aquatic, Animal, Plant, & Human Life 

“The FDA has shown itself to be an incredibly lawless agency in disregarding the Endangered Species Act (ESA) and recklessly approving Chemical Abortion Pills in 2000,” said SFLA’s Kristan Hawkins. “FDA officials never checked whether government-sanctioned, corporate dumping of medical waste was hurting our environment. The Pro-Life Generation demands environmental justice for the aquatic, animal, plant, and human lives put at risk by the FDA’s neglect.” 


WASHINGTON D.C. (04-19-2023) – On the eve of Earth Day 2023, Students for Life of America President Kristan Hawkins announced that today a THIRD Citizen Petition had been filed by SFLA at the FDA, addressing the on-going dangers from the reckless approval of Chemical Abortion Pills. National Institute of Health (NIH) published studies noted in the petition indicate that the active components in the life-ending drugs have an impact on nature at large, which means that the more than 20 years of government-sanctioned, corporate dumping of medical waste into our water supply is a hazard that must be addressed. “Brick and mortar abortion vendors are not permitted to flush away human remains, and hospitals treat placenta tissue and human remains with utmost care,” noted Hawkins. “Yet Presidents Clinton, Obama, and now Biden are making cemeteries of our sewers, exposing us all to the chemically tainted blood, tissue, and human remains from Chemical Abortions.”

CLICK HERE to read Hawkins’ Newsweek op-ed, along with two state legislators, titled Stop Dumping Medical Waste, detailing some legislative solutions underway.



Corporate Counsel Zac Kester noted that the potential problem is ongoing. First, the FDA slapped a cover memo accepting the 1996 Environmental Assessment submitted by the Population Council, which would profit from the drugs, without further research. They accepted the general opinion that the littering of the package was the main environmental concern. But with each change in the health and safety standards, that error was compounded, meaning that the FDA failed FIVE TIMES to examine the risks to the environment in 2000, 2016, 2019, 2021, and 2023. 

“Each time the FDA removed or altered the 2000 health and safety standards, they permitted the polluting of the environment,” said Kester. “Officials should have made sure that those changes did not harm aquatic, animal, and plant life – our food supply.

“This citizen petition addresses mifepristone differently than the Alliance Defending Freedom (ADF) case that brilliantly details the reckless approval process that’s impacting women, especially minors. We share those concerns about a negligent approval process, adding the failure to protect the environment to the FDA’s legal issues. However, harms to the environment can be addressed with some of the toughest laws on the books, and we are examining all potential remedies.”

In the petition submitted by SFLA and more than 150 student groups across the country, SFLA asked that the approval of the pills be revoked  in “light of the FDA’s failure to comply with the requirements of the Endangered Species Act (ESA) when taking these actions.”  

The petition continues: “This Petition makes one request. We request that the FDA revoke its actions to approve Mifepristone and modify the associated regimen (including the REMS) until the agency conducts the required consultation with the United States Fish and Wildlife Service (“FWS”) and National Marine Fisheries Service (“NMFS”) (collectively, “the Services”) as compelled by the ESA. Before allowing Mifepristone for human consumption, use outside of a medical setting, and disposal into the environment, the FDA must first consult with the Services to determine the extent and the effects that its Mifepristone actions have on listed endangered or threatened species or designated critical habitats in the FDA’s action area (i.e., the entire United States and its territories) …  



“When the FDA made significant changes to the Mifepristone regimen and REMS in 2016, 2019, 2021, and 2023, the agency simply failed to conduct any ESA consultation or environmental assessment. This failure flies in the face of the ESA and must be corrected immediately— especially in light of the FDA’s removal of the in-person dispensing requirement, which opened up the floodgates to do-it-yourself abortions at home and disposal of Mifepristone directly into our nation’s water supply.”

With nearly 1,500 endangered species at risk in the U.S., SFLA highlighted several from key states including the Red Wolf, Kemp’s ridley sea turtle, leopard darter, California condor, and sockeye salmon.

“The FDA did not conduct sufficient advanced studies on the impact Mifepristone could have on the nation’s water supply when the Mifepristone regimen was approved for women and girls in 2000. In the lead up to 2000 approval, the FDA reported that there would be high standards for disposal related to Mifepristone. This has not been the case. …  Mifepristone and fetal remains in wastewater have impacts beyond humans and onto animals and plants. The EPA acknowledges that pharmaceuticals and human remains can impact the fertility of animals and fish. Mifepristone in wastewater is distinct from a natural spontaneous miscarriage, as the products of Mifepristone are chemically tainted with this drug.”

In SFLA’s Citizen Petition, a number of studies noting harms are reported. To read the THIRD petition as well as SFLA’s earlier petitions, click here.



It’s important to note that the tainted blood, tissue, and human remains from a deliberately caused Chemical Abortion is vastly different from a spontaneous abortion, in the following ways: 

  1. Dangerous Chemical Abortion Pills do not taint the remains of spontaneous miscarriages, which are also not planned events.
  2. Responsibility for protecting the environment from a business practice is with the person/business who began a chain of events leading to potential harms. The Chemical Abortion sales team and corporations, as the generators of medical waste, are responsible to clean it up.
  3. A Chemical Abortion Sales Team knows that they are starting a chain of events likely to ending with tainted tissue and blood and human remains in the wastewater system, and therefore are responsible to ensure protection of the environment.

As SFLA previously reported in earlier coverage of this case: Ironically, while the deadly pill pushers say they are advocating for women, SFLA’s YouGov poll indicates that Gen Z and Gen Y absolutely reject the policies of Biden’s FDA, which put them at risk.  


The Generation asked to buy Chemical Abortion Pills doesn’t buy the Biden Team’s willingness to risk their lives and future fertility, with 9 in 10 consistently expressing concern with the current No Test, Online Distribution of Chemical Abortion Pills.  



  • Support for an Ultrasound Screening to Protect Women facing ectopic or late-term pregnancies: 91% agree this is somewhat to extremely important, with 40% choosing extremely important. (Chemical Abortion Pills don’t work well later in pregnancy or end an ectopic pregnancy, once established outside the womb. An ultrasound is used to determine location and length of pregnancy to save women’s lives, something Biden’s FDA no longer requires.) 
  • Support for Blood Test Screening to preserve a woman’s fertility: 93% agree this is somewhat to extremely important, with 41% choosing extremely important. (In the U.S., 15% of the population has Rh-negative blood. In an exchange of blood during birth, abortion, or miscarriage with a preborn baby, antibodies can form in a woman’s body that unless quickly neutralized can essentially sterilize her, as future pregnancies are attacked. The treatment is a shot called Rhogam that Biden’s FDA does not require to be administered, nor do they even require a blood test, giving women information they need to seek help.) 
  • Support for requiring In-Person Care to prevent abusers from getting the drugs to use against women without their knowledge or consent: 60% supported with 40% opposing. (Chemical Abortion Pills are abusers’ dream drugs, giving them the power to end a mother’s pregnancy without her knowledge or consent. In-person dispensing ensures that women are not being coerced and that they have information on things like blood type.)  

Not only do Chemical Abortion Pills place women at risk of injury, infertility, death, and abusers, NIH-published studies such as this one indicate they pose a risk to the environment as well.

More information on the broader project can be found here, but short-term plans are underway, including:  

STEP ONE: Students for Life of America & Students for Life Action have been leading the call for an Environmental Assessment of the impact of Chemical Abortion Pills along with tainted blood, tissue, and human remains in America’s wastewater system. This resonates with environmentally conscious Gen Z & Gen Y voters. Fewer than 1 in 10 wanted to ignore the potential dangers, with 92% agreeing that this is somewhat to extremely important, with 30% choosing extremely important. 

STEP TWO: To prevent environmental contamination of America’s water, corporations and medical businesses – from hospitals to surgical abortion vendor locations – are required to handle medical waste carefully. Red Bag Medical Waste regulations require contaminated and dangerous materials be disposed of according to state laws. The youth vote was fully in favor of requiring Red Bag Medical Waste procedures to Chemical Abortion Pill regulations, with 90% agreeing this is somewhat to extremely important, with 30% choosing extremely important. 



HISTORIC LEGISLATION MOVING FORWARD: Students for Life Action is already getting traction on our calls for protecting the environment from Chemical Abortion Pill-tainted blood, tissue, and human remains. West Virginia is the first state in the nation to file a bill calling for Red Bag Medical Waste requirements, and as Politico reports, “The next abortion fight could be over wastewater regulation.”

ELECTED OFFICIALS TAKE NOTE: From the 2022 poll —  “Standing strong against reckless No Test, Online Chemical Abortion Pill sales and distribution is a winning issue. Almost 7 in 10 Millennials and Gen Z are more likely to support a candidate who supports laws that require in-person medical care and testing before and after the sale of dangerous Chemical Abortion Pills.”

For interviews, contact Kristi Hamrick at [email protected]


Students for Life Action (SFLAction), a 501c4, along with its 501c3 sister organization, Students for Life of America (SFLA), make up the nation’s largest pro-life youth organization and a political and policy operation engaging people of all ages. Together they work to end abortion — the human rights issue of our day — and provide political, legal, and community support for women and their children, born and preborn. Headquartered in Fredericksburg, VA, SFLA has more than 1,300 groups on middle, high school, college, university, medical, and law school campuses in all 50 states. SFLA creates strategy, policy, and programming to connect those most targeted for abortion with people ready to help and builds a framework for political engagement on their behalf. SFLA and SFLAction have more conversations with those most targeted by the abortion industry than any other pro-life outreach in the world, reaching more than 2 million people across social media platforms each week and engaging in approximately 100,000 digital conversations per month. Over more than 16 years, President Kristan Hawkins has grown SFLAction/SFLA into an $18 million organization preparing for a Post-Roe America.