This is the Our Duty Submission in response to the NHS England Consultation on the Prescription of Puberty Blockers.
NHS England consulted on its new policy for the prescription of Puberty Suppressing Hormones (also known as puberty blockers).
This public consultation ran for 90 days from 3 August to 1 November 2023.
The Consultation Website:
https://www.engage.england.nhs.uk/consultation/puberty-suppressing-hormones/
1. In what capacity are you responding?
Our Duty
2. Are you responding on behalf of an organisation?
Yes
Our Duty represents nearly 3,000 families in over 30 countries which have children with transgender ideation.
3 Has all the relevant evidence been taken into account?
No
We leave it to other organisations such as Transgender Trend and CAN-SG to identify the pertinent scholarly evidence that has been omitted. We commend their submissions in this consultation. We are concerned with three other types of evidence which have been largely overlooked:
1) The evidence of no evidence.
2) The evidence of trite facts.
3) The evidence as yet unpublished (whether due to the oppressive academic climate, or the novelty of the research realm).
The Evidence of No Evidence
If the ground is dry, we can deduce that there has been no recent rain.
We know there is no longitudinal study into the medicalisation of the adolescent cohort. Moreover, all the other research is either irrelevant – because the cohort differentiation is germane and important – or as confirmed by NICE, of low quality. Studies that do exist tend to look at patients who have been medicalised. Where are the studies of patients who have not been medicalised? Their absence as a studied patient cohort would seem to indicate that their condition has resolved. These sorts of deductions deserve validity and recognition.
We cannot look at the prescription of puberty blockers in isolation, because we know their use almost always leads to the administering of incompatible sex hormones . So that body of evidence, where it is of adequate quality and applicable to the adolescent cohort does require consideration in the context of any debate around the prescription of its precursor..
It is a fact that not enough is known about the administration of drugs that inhibit normal pubertal development. i.e. there is an absence of relevant research. This will lead some to demand more research. However, the ethics of experimenting on children must be weighed carefully. Such experimentation might be justified when there is a genuine physical condition which if left untreated would be life threatening, or severely life limiting. However, transgender ideation is not in that category. Indeed, the evidence is that non-treatment has far better outcomes than medicalisation. The published research evidence looks at mental health, where the outcomes are inconclusive, there is no longitudinal study into physical outcomes. However we know that victims of gender medicalisation are at high risk of a list of ailments from scar pain through sterility and osteoporosis to premature death. The absence of published research does not obviate these facts.
Another reaction to the lack of robust evidence would be to adopt the precautionary principle. When it comes to children’s bodies “if it ain’t broke, don’t fix it” is the most ethical and morally right position to take. The evidence is that this important consideration has not been given the weight and importance which it merits. If it had, the NHS would not be proposing to administer puberty blockers at all.
While the aetiology of so-called gender incongruence is missing from the published evidence base, it cannot be assumed that its manifestation demands medicalisation.
The evidence of trite facts
Some evidence is so trite that it does not appear in scholarly research. This is the evidence of incontrovertible facts. The primary fact with which we are concerned is that those who seek to medicalise the feelings of dysphoria resulting from rumination in conjunction with transgender ideation have healthy bodies. Medicalising these healthy bodies without any clinical justification is deeply unethical, and not proper medicine. It is a known fact that adolescents will claim to have the feelings described as ‘gender dysphoria’ in order to have their delusion of being the opposite sex ‘validated’. It is also a fact that while the medicalisation of ‘gender’ is claimed to be a treatment for ‘clinically significant distress’ associated with this list of feelings, we know that a great many patients do not exhibit levels of distress that are proportionate to the levels of harm that will result from the treatment they seek. It is also a trite fact that such feelings are almost always transitory, whilst the effects of medicalisation are permanent (particularly when one notes that the administration of puberty blockers almost invariably leads to further medicalisation with incompatible sex hormones).
It is accepted medical practice that tubal ligations and vasectomies are not given to adolescents, why should there be an exception for their chemical equivalents?
Unpublished Evidence
The phenomenon of adolescent transgender ideation became apparent in 2015. Since then, there has been much activist-led research of very low-quality published (e.g. Turban et al), while at the same time more serious research has been suppressed (e.g. Diaz and Bailey). This is presumed to be because of the cognitive capture of academia by the so-called progressive forces promoting transgenderism.
Desistance from transgender ideation, and detransition from medicalised transgender ideation, are more commonplace than the published research would suggest. This is because the published research lags events by many months. Papers that document the efficacy and positive outcomes of non-medical interventions that lead to desistance exist, but have not been published. The two factors inhibiting the free and rapid flow of information, then, are academic lag and ideological suppression. Both of these need addressing in a fast-moving field.
Adolescent transgender ideation is a cultural phenomenon. Children are succumbing to transgender ideation because it is fashionable, because they are susceptible, and because they have been indoctrinated. The most up-to-date thinking on the nature of this contagion is ‘The Lifecycle of Transgender Ideation’ published at https://ourduty.group/education/lifecycle-of-transgender-ideation/
The concept of puberty as a human right has entered the discourse. Again, this is an emergent hypothesis, but one that bears careful consideration. In human rights law, the right to life and the right to health are well established. Puberty is an essential part of healthy human development. Blocking puberty is, therefore, an abuse of a young person’s fundamental human rights.
Conclusion
An holistic approach to determining the circumstances under which puberty blockers can be administered to patients with transgender ideation needs to take a broader view of what constitutes relevant evidence. When the academic blinkers are so removed, it should become clear to all that pubertal suppression for reasons of gender identity is never clinically indicated.
4 Does the equality and health inequalities impact assessment reflect the potential impact that might arise as a result of the proposed changes?
No
The impact of prescribing puberty blockers is understated. These impacts are clearly discriminatory to patients who are unable to provide truly informed consent (which is all of them by the definition provided in Montgomery v Lanarkshire), but the discrimination weighs particularly heavily on the following protected characteristics:
- Disability, in that autistic children and those with other neurodiversities, are at increased risk of susceptibility to transgender ideation, and at increased risk of making poor decisions.
- Age, in that younger children are less able to comprehend that which is being done to them.
- Sexual Orientation, in that it is known that a majority of children with transgender ideation will, if not medicalised, grow up to be same-sex attracted or attracted to both sexes.
Consequently, these groups are at a disproportionate risk of the known harms of medicalising a specious identity. These risks cannot be mitigated, only eliminated by the removal of improper medicine as a treatment option.
5 Are there any changes or additions you think need to be made to this policy?
We recommend that puberty blockers are not used in the treatment of adolescent transgender ideation.
The previous stakeholder mini-consultation showed three circumstances in which puberty blockers would be prescribed:
- Under a clinical research setting
- Under exceptional circumstances, and
- “The use of PSH as a precursor to a moving onto gender affirming hormones is covered by a separate clinical policy”
While we are opposed to all three prescribing scenarios due to the diverse principles, facts and evidence previously described, we have a particular concern regarding point (3) which seemed to be absent from the version published in this consultation, and the absence is unexplained. It is presumed this use-case is to smooth the transition from a natural endogenous endocrine system to the unnatural and exogenous incompatible sex hormones. Since we also oppose the prescription of incompatible sex hormones for much the same reasons as we oppose the prescription of puberty blockers, we would like to see an explanation for this omission.
We are primarily concerned with the health and wellbeing of our children. Any ‘official’ legitimisation of the articles of faith in gender identity ideology, e.g. any suggestion ‘gender identity’ is a recognised trait, undermines the ability of parents to ground their children in reality. Children in the ruminative phase of transgender ideation will look for opportunities to appeal to authority to validate their delusion. The NHS has a duty of care to avoid using language that suggests transgenderism is in any way valid.
The experience of parents affected by having a child with transgender ideation can inform the gathering of evidence around aetiology, and inform the development of effective, non-medical, interventions. We would encourage the NHS to work with us to exploit our evidence base and help professionalise our practice. We are currently achieving better results yet with zero funding.
