Our submission to WHO extended consultation


Transgender Trend responded to the original World Health Organisation consultation on development of a WHO guideline on the health of trans and gender diverse people here. WHO subsequently extended the deadline for the public consultation. This is our submission to the extended consultation.

WHO extended consultation on the development of a WHO guideline on the health of trans and gender diverse people

The WHO guideline is extensive, covering treatment, healthcare and legal rights. The resulting guideline will therefore be a health guideline but also a political document. In some human rights areas, rights are in conflict, so it is concerning that WHO will develop guidelines based on the view of only trans people who will benefit from those rights, without considering those who will be disadvantaged by them. Legal recognition of gender self-ID for example has significant and serious implications for the female sex (women and girls) whose existing rights to dignity, privacy and safety will be eroded by members of the male sex who are able to identify into single-sex spaces.

It also has implications for safety in healthcare for all people; from the issue of data collection on the basis of ‘gender identity’ in place of sex, for women who need or want intimate healthcare to be delivered by females, and for women’s privacy, dignity and safety on single-sex hospital wards.

WHO guidelines will be used worldwide. WHO therefore has a duty to consider regional variations. For example, particularly in some developing countries, girls would be put at serious risk by opening up toilets to men who can ‘identify as’ women. Globally, women’s rights will be eroded by men identifying into positions of political power reserved for women. Freedom of association will also be negatively impacted for women who need to meet in women-only groups. Toilets, changing-rooms, refuges, rape-crisis services, prisons, hospital wards and sports are some of the areas that must be female-only, for the protection, fairness and equality of women and girls.

WHO must not further erode women’s equality or increase the risk of violence against women and girls by taking away safeguards that currently protect women and girls, through advocacy for self-ID in public policies and legislation.

The language used in the current development proposal does not inspire confidence that WHO has considered these issues from the perspective of any other group, particularly women and girls who would be the most severely affected, but also gays and lesbians whose status and legal protection is based on same-sex orientation, not ‘gender orientation.’  Lesbian-only groups must retain the right to exclude men, no matter how they identify, including men who identify as lesbians.

In the Q&A document WHO states that “representatives of people affected by the guidelines” are included in the GDG members. Which of the members represent the rights of women and girls, lesbian and gay people and detransitioners?

‘Gender-inclusive’ healthcare has already led to the word ‘woman’ being erased from medical literature in the UK on issues that affect only women, such as pregnancy, menstruation and menopause, putting women at risk, especially women for whom English is not their first language. For the safety of everyone, including those who identify as transgender, healthcare must be based on biological sex.

The Q&A document states:

“The scope will cover adults only and not address the needs of children and adolescents, because on review, the evidence base for children and adolescents is limited and variable regarding the longer-term outcomes of gender affirming care for children and adolescents.”

The statement is misleading in itself. The evidence for the benefits of ‘gender affirming’ care is weak. The evidence for the safety of gender affirming medical treatment is non-existent, but evidence of risks is increasing.

Despite this statement WHO does not question the benefits/risks of ‘gender-affirming’ care for adults. On what evidence basis has WHO made the decision to promote the gender-affirmation model in guidelines, above a therapeutic and exploratory approach? A WHO guideline on ‘gender-affirming’ care will inevitably be influential in the treatment of children and adolescents. WHO must adopt a politically neutral approach in developing these guidelines, with no presumption that one model of care is superior to another. To state a position at the outset suggests bias and this will influence choices made about research subjects and assessment of the evidence.

Research must consider the proportion of adults who drop out of a course of hormone treatment, and their reasons, along with those who embarked on medical treatment as adults who later regret hormones and surgery (detransitioners) and the rates of surgical complications and negative side-effects.  

Despite restricting the guidelines to adults, there will be a significant effect on the 17-25 year-old demographic. Recent findings in neuro science show that the brain does not stop developing until the mid-twenties, with executive functions such as the ability to weigh up evidence and long-term goals being the last to be completed.

Gender affirming care for this group risks putting more young people on an irreversible path to being a life-long medical patient.

The most detailed evidence of patient profiles for this group comes from an outcome study from the Exeter adult gender clinic.

Service specifications governing treatment at adult gender clinics in England are gender affirming. Psychological support is offered but is not a prerequisite. The support is weighted towards helping patients adjust to their cross-sex identity, not to investigate what may lie behind the desire to transition.

The authors of the Exeter study concluded that:

“Service users may have unmet needs. Neurodevelopmental disorders or ACEs suggest complexity requiring consideration during the assessment process. Managing mental ill health and substance misuse during treatment needs optimising. Detransitioning might be more frequent than previously reported.” 

Their research showed that the trend showing a sudden increase in the last ten years in adolescent girls identifying as boys is replicated in adult gender clinics.

The report contains some revealing statistical data; of the natal women under 25 who were treated at the clinic, 89.4% had an adverse childhood experience, 23.4% had a neurodevelopment disorder, 77.1% had a previously diagnosed mental health disorder, 72% had a history of self-harming.

The authors found a detransitioning rate of 6.9% which they considered an underestimate.

This is the first clinical audit of a UK adult gender clinic. Without more studies of this nature from adult clinics, how is it possible for WHO to confidently announce a guideline on ‘gender-affirming care’ with the presumption that this is the right model to follow?

The Q&A point 7 defines ‘gender-affirming healthcare’ as “interventions designed to support and affirm an individual’s gender identity” without evidence to show that this approach is safe and effective. The interim report of the Cass Review of the Tavistock clinic for children and adolescents reported that clinicians felt pressured to affirm a child’s gender identity and that this led to diagnostic overshadowing, where co-morbidities were ignored or dismissed. There is no evidence to suggest that this would not also be true for adults.

WHO has taken an ideological standpoint with language such as ‘sex assigned at birth.’ This is a fundamental mistake about biological sex, which is observed at birth and cannot change. Also of concern is WHO’s wide definition of ‘trans and gender diverse’ people in point 6 of the Q&A. Many people do not conform to the ‘norms and expectations’ for their sex. ‘Male’ and ‘female’ are words describing biological sex, they are not ‘gender nonconforming identities.’

WHO must include definitions of subjective terms such as gender, gender identity and gender-affirming care. As it stands, the proposed guideline will promote a care model that is already highly contested in the field of child and adolescent health. Adults also are entitled to normal standards of evidence-based healthcare, and the ideological basis of the WHO documents suggests that the resulting guidelines will not meet that standard.

This Post Has 7 Comments

  1. charles lewis

    The WHO, like so many of these global or international bodies, should be treated with contempt, as should virtually all of their pronouncements. They are a hopelessly biased bunch, long since given over to the dangerous, absurd and unscientific ‘gender identity doctrines of the trans activists such as the disgraced Stonewall and Mermaids groups, doctrines which seem to have as their basic aim the destabilization and destruction of our children.

  2. Lyndsey Snow

    It’s such a sad state of affairs that an organisation that wields such power can be so utterly careless. Not fit for purpose.

  3. E Morrison

    An excellent response.

  4. Alicia Sufit

    This news is devastating, the WHO proposals are nothing short of a worldwide attack on the female sex, women and girls. I am horrified, saddened and angry!!

  5. Rebecca

    Very well put and a view a majority of people have but are too scared to express. Thank you for fighting this cause.

  6. Tony Turner

    I agree completely with the following comment from your response:

    WHO has taken an ideological standpoint with language such as ‘sex assigned at birth.’ This is a fundamental mistake about biological sex, which is observed at birth and cannot change.

    That sex is biological, and cannot be changed, is a fundamental fact, which some organisations seek to challenge for their own benefits, with no regard to the harm it may cause to others. This cannot be allowed to prevail.

  7. Joseph Thomas King

    I have never seen any medical condition or psychological condition politicized. Some people feel that removing gays and lesbians from mental disorders is the same but I disagree. The very Woke gay community which is about half on the trans side is very involved in this. They keep saying that if this was recognized when they were kids, things would be better. I disagree. Things would have been worse for me as a gay child. I would have been very confused which I think many of these kids and self identity is absurd.

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