AFFIDAVIT I, the undersigned, VIVIENNE NOKUZOLA MATEBULA Hereby make oath and state: 1. I am a 44-year old woman resident in Vereeniging. I am a volunteer of the Treatment Action Campaign and a member of the TAC committee in the Vaal Triangle. 2. The facts herein fall within my personal knowledge unless is otherwise apparent or otherwise stated and are to the best of my knowledge true and correct. 3. I have been practicing as a qualified nurse since 1977 and have worked at hospitals and clinics in Johannesburg, Hillbrow and, since 1996 at Kopanong hospital in Vereeniging. 4. Kopanong hospital is a level 1 hospital that provides access to health care for people from Meyerton, Van Der Bijl Park, Rusterval, Roshnee, De Deur and Vereeniging. The hospital has ante-natal and maternity facilities and I estimate that there are approximately 100 births every month. 5. I am currently a senior nursing auxiliary and earn R3,500 a month. My duties include giving medication, referring patients to doctors, recording vital data. Presently I work in the Out Patients Unit (OPU). 6. I am also an HIV counselor, and often conduct pre-test counseling for patients. I keep a record of all people I counsel in my diary and sometimes counsel between ten and fifteen people every day. 7. Sometimes I am called to counsel women who are pregnant and I strongly believe that these women should be offered access to Nevirapine, because this would reduce the risk of HIV infection of their babies. I have been advised that the Department of Health's Survey of Women attending Public ante-natal clinics that was conducted in 2000 found an average HIV prevalence of 29.4% at clinics in Gauteng and that 30.6% of pregnant women between the ages of 25 and 29 had HIV. 8. HIV is a problem to me. I see it spreading and I see many patients with symptoms. Unfortunately at my hospital they are very good at testing for HIV, but not at treating. Many people test positive, but the testing is often done without their proper consent, and is requested by the staff, rather than by the people themselves. It is sad that we have to refer people with HIV and other ailments to clinics where there is often no medication. 9. Early in 2001 I learnt that Chris Hani Baragwanath was providing NVP for pregnant mothers who are HIV positive through the AIDS Care Counselling Training (ACCT) based at the Chris Hani Baragwanath Hospital in Soweto. I am aware of the existence of anti-retroviral drugs that can treat HIV infection and particularly of those drugs like NVP that reduce the risk of mother to child transmission. But we do not have these at Kopanong hospital. The result is that where a pregnant woman asks for these drugs I have to refer them to Chris Hani Baragwanath hospital (CHB) where I know they can get the medicine. Chris Hani Baragwanath hospital is 60 kms away, and because women who come to our hospital are poor, getting there causes great difficulty. 10. Let me relate one case to illustrate this point. In May of this year a woman named "S" was referred to me for counseling. She was pregnant and told me that she had tested HIV positive in 1999. I counseled her and referred her to Chris Hani Baragwanath hospital when she was seven months pregnant, to get Nevirapine. I wrote a referral letter for Dr Glenda Grey's attention at the ANC unit. She visited Baragwanath hospital where the people were helpful and friendly. They told her to come back when she went into labour because although they could give her a pill, she would need a dose of syrup for her child. She told me this. 11. In the last week of June she went into labour and came to Kopanong hospital. She told the nurses that she needed to go to Baragwanath hospital and asked them to get an ambulance. She was told to go there herself by taxi. I am told that even though she was already two centimeters dilated, she left the hospital to go to CHB. 12. To get to Baragwanath from Kopanong you have to take three taxis. You have to wait for each taxi to fill up. Eventually when you get to CHB you have to climb the bridge over the road. She did all of this when she was in labour. When I raised this case with the hospital I was told that it is not my department, because I am a nurse not a senior sister. 13. I can say that there are some doctors here who on my side. I have collected a petition of doctors, nurses and other health workers at clinics in Zone 11, 12 and 13 of Sedibeng and at Kopanong hospital. This petition is attached as annexure "VNM(1)". Most of them say that they want to be able to help pregnant women and provide Nevirapine. But the Provincial health department will not make the medicines available. 14. In the paediatrics ward we see a lot of HIV and mothers losing their children. For me this is very sad. I think our hospital could provide Nevirapine to women with HIV and offer HIV counseling and testing. ___________________________ DEPONENT THUS SIGNED AND SWORN TO ME AT ………………………………. On this day of ……………………………2001 by the Deponent who has declared that she has read this affidavit, understands the contents thereof and has no objection to taking the prescribed oath, and regards the same as binding on her conscience. __________________________________ COMMISSIONER OF OATHS 1