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The Christian Medical and Dental Fellowship of Australia.

Submission to the NSW Department of Communities and Justice and the NSW Ministry of Health regarding Banning LGBTQ+ Conversion Practices: Consultation Paper dated 17/8/23.

In compassionate, evidence-based concern for the growing number of children and adolescents confused over gender identity, the Christian Medical and Dental Fellowship (CMDFA) endorses the declaration of the National Association of Practising Psychiatrists (NAPP) that, “Conversion practices legislation must also consider the evolving international standards of care for gender questioning or gender dysphoric young persons, including the important role of parents in supporting their child in the decision-making process (Vrouenraets et al 2022)’.

CMDFA concurs that “Psychological interventions that promote exploration of gender identity, while identifying and addressing any underlying conditions or family circumstances, have become the standard for first-line treatment internationally’ (see references 10, 29, 30, 31, 32, and 33 in the Guidelines of the National Association of Practising Psychiatrists (NAPP) published under the name ‘Management of Gender Dysphoria in Young People’ on that organisation’s website – napp.org.au). These non-directive interventions prioritise the well-being and self-discovery of young individuals, ensuring that they receive appropriate care and support during their gender identity journey (see reference 10 in the NAPP Guide) and include sharing of knowledge between the young person, their parents and clinicians.

We would, therefore, like to emphasise the anomalies that exist in such legislation as the Victorian “Change and Suppression Act”[i] in which it is a criminal act to employ psychotherapy (psychological interventions) in order to help orientate the feelings of a confused child or adolescent towards the biological reality of chromosomal identity. We are also concerned that the Victorian legislation has taken the liberty of reversing the democratic tradition in which a person is innocent until proven guilty.

Under penalties that may involve 10 years in gaol and crippling financial fines, the Victorian legislation obliges a practitioner to ‘affirm’ an identity incongruent with chromosomes which, essentially, means directing the child towards a pathway that begins with social affirmation and progresses to blocking of puberty, administration of cross-sex hormones and may end with surgical intervention, including castration, refiguration of genitalia and urinary output, and removal of breasts.

We would like to point out that the so-called ‘Australian Guidelines’[ii] for management of gender dysphoria as promulgated by the gender clinic at the Royal Children’s Hospital, Melbourne, has no age limitations for such interventions and from Family Court records, the youngest age for the blocking of puberty has been 9 years, and children 16 years and younger have had mastectomies.

We would like to emphasise the irony in that and similar legislation in which the term ‘conversion therapy’ is directed against traditional psychotherapy which would aim to make a child more comfortable with given chromosomes, while ignoring its appropriate use for the process of chemically and surgically ‘converting’ a child or adolescent towards an external appearance incongruent with chromosomes.

We would like to emphasise the experimental nature of such interventions: the growing number of ‘converted children’ who would like to ‘de-transition’ is alarming, as is the high rate of suicide in adults who have undergone the procedure.

But the process of ‘affirmation’ does not meet the usual standards for experimentation as declared by various ethical declarations since the Nuremburg trials at the end of World War 2. Basic to any valid experimentation is biological plausibility, consideration of side effects, intellectual and emotional capacity for the granting of consent, and the provision of adequate information upon which to grant such consent.

Biological implausibility… (Note that references are included in the attached ‘Life Altering Decisions and the Adolescent Brain’, which was published in Quadrant Magazine, April 2023[iii], from which the content of this submission is derived.

As the attached document will attest, with supporting references, the claim that the administration of ‘puberty blockers’ will grant time to consider gender identity is biologically implausible, because such identity is encouraged by the very hormonal processes that are now ‘blocked’. Sexualisation is not merely a product of ovarian and testicular output of hormones but is also influenced by central, cerebral centres.

The concept that a child, blocked from nature’s hormonal directions, may be able to maturely consider sexual identity, is challenged even more by consideration of the psychological forces that will have been exerted by authority figures who have acquiesced to an identity contrary to chromosomes.

Even more implausibility is granted by consideration of the natural process of maturation of the brain in which the limbic system is poorly controlled by the pre-frontal cortex until the early twenties. Thus, ‘feelings’ lack the discipline of mature consideration. To this natural dichotomy is added the effect of various psychological and psychiatric co-morbidities that are well known for association with gender confusion.

It is thus biologically implausible to claim that administration of ‘blockers’ will permit mature consideration of identity. Given the consequences of such administration it is unfair, if not unethical, if not abusive to encourage their use while legislating against psychotherapy.

Lack of informed consent

The neurons that produce the Gonadotropin Releasing Hormone (GNRH), whose effects are blocked by ‘blockers’ have broader roles than sexualisation: they are found throughout the brain and have been found to influence development, structure and function of non-reproductive cerebral function. ‘Blocking’ such function has been found to have inflicted sustained alteration in these cerebral centres.

Readers are here referred to the research which has emanated from the veterinary school in the University of Glasgow where ‘blocked’ sheep were revealed to have suffered hypertrophy in the limbic system which normally co-ordinates emotion, memory, cognition, leading to mature ‘executive function’. The functions of hundreds of genes were found to be altered by the blockers, leading to sustained emotional lability and interference with learning and preference for the ‘familiar’ over the novel.

Readers are referred to research on rodents in which ‘blockers’ have also been found to result in preference for the ‘familiar’. Such preference is not esoteric: it provides some understanding of the observed phenomenon that children on ‘blockers’ almost inevitably progress to the next stage of transgendering, the administration of cross-sex hormones. In children who have undergone ‘social affirmation’ to a gender incongruent with chromosomes, the ‘familiar’ is the name, the clothing, the toilets, the recognition and encouragement of authority figures of the adopted identity. The ‘novel’ is the concept or reverting to an identity congruent with chromosomes. Thus, a physiological barrier (perhaps related to fearfulness through disruption of the limbic system) is added to the psychological barriers for change.

Research on the proclivity for neuronal degeneration in sufferers of Down Syndrome has revealed its association with the progressive reduction in availability of GnRH due to distortion in its manufacture imposed by the excessive genetic influence from the extra chromosome (in position number 21) which is basic to the syndrome. In both mouse and human models, replacement of the lacking GnRH ‘rescues cognition’. [iv]

This astonishing work by French, Swiss, German and Spanish researchers on the essential role of the blocked hormone (GnRH) in the structure and function of the brain appears ignored by leading gender clinics in children’s hospital, as has the succession of previous considerations of side-effects of blocking GnRH.  This work on GnRH, which appeared in the leading publication, Science, 2022,  should not be ignored by legislators in the making of decisions that will criminalise management of gender dysphoria in children and adolescents by alternative, psychotherapeutic means.

Nor should it be ignored such related work of other research institutions that was published a decade earlier in the similarly respected journal ‘Nature’[v]. In that work, performed in New York by Zhang et al., it was ‘discovered that GnRH induces adult neurogenesis broadly in the brain, and GnRH therapy can greatly amend ageing disorders. Thus, whereas the inhibition of GnRH ‘may lead to the end of reproductive length—which seems necessary for species’ quality—it initiates systemic ageing at the same time’. Zhang et al. maintain ‘questions remain’ and, certainly, their research was based on inhibition of GnRH by inflammation as opposed to the pharmaceuticals of gender clinics, but ‘proof of principles’ exist: that GnRH exerts a role throughout the brain by inspiring the production of new cells. ‘Blocking’ that role, according to Zhang et al., impedes that production and is associated with ageing.

It is reprehensible that gender clinics, substantiated by legislation, continue to mislead the general public and the gender confused, by assertions that ‘blockers are safe and entirely reversible’.

It is reprehensible that gender clinics, supported by health departments, should not also reveal noted complications of the administration of cross-sex hormones on the brain. For example, the adult male brain, administered oestrogen, shrinks at a rate ten times faster than ageing, after only four months administration. The effect on the growing brain has, thus far, not been investigated: in one notable case, funds for such basic research were denied by a government funding organisation.

The litigious risk

Thus, plausibility, side effects and informed consent are consistently ignored in the hormonal and surgical experimentation on gender confused children and adolescents. There should have been legal as well as ethical constraints for the practice contravenes the directive of the Australian High Court decision in which eye surgeon, Dr Rogers, was censured for not informing Mrs Whittaker about the remote possibility of side effects in her good eye, consequent upon operating on the defective one[vi].   Knowledge of the possibility of even a one in 14,000 chance of complication should, according to the Australian High Court, be imparted with such clarity that the patient may be able to make an informed decision of whether or not to go ahead with the procedure.

It is simply astonishing that gender clinics have been permitted to intervene, massively, in the bodies and brains of vulnerable children and adolescents, under assertions of safety, with no reference to contrary published literature. Surely they have submitted themselves and their institutions to condemnation from the Australian High Court and, thus, litigation.

Conclusion

CMDFA respectfully requests NSW legislators to fully inform themselves of the broad literature pertaining to care of gender-confused children and adolescents. We request that, as part of compassionate, ethical care, legislation enforces the obligation for truly informed consent. In accordance with the Conclusion of the NAPP Guide and, contrary to the restrictive Victorian legislation, we request that NSW legislation will promote ‘safe and respectful practices appreciating the rights and needs of individuals exploring their gender identity, while allowing health practitioners to provide necessary therapeutic interventions’.

We would emphasise that the definition of ‘necessary’ must be based on full appraisal of established research as directed by the considerations of ethics that emerged from the Nuremberg trials: there should be biological plausibility and not merely an ideological imperative; experimentation should be regulated and controlled; side effects should be acknowledged and not concealed, and permission should be sought after  the provision of fully informed consent accorded by competent (sufficiently mature) cerebral function in those concerned.

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[i] Victorian Change or Suppression (Conversion) Practices Prohibition Act 2021 https://content.legislation.vic.gov.au/sites/default/files/2021-02/21-003aa%20authorised.pdf

[ii] Telfer MM, Tolit MA, Pace CC, Pang KC. Australian Standards of Care and Treatment Guidelines for Trans and Gender Diverse Children and Adolescents. Version 1.3 Melbourne.: The Royal Children’s Hospital, 2020.

[iii] Whitehall J. “Life altering decisions and the adolescent brain’ Quadrant April 2023.  https://quadrant.org.au/magazine/2023/04/life-altering-decisions-and-the-adolescent-brain/

[iv] Manfredi-Lozano, Leysen V, Adamo M et al. GnRH replacement rescues cognition in Down Syndrome. Science (2022). 377,eabq4515. DOI:10.1126/science.abq4515.

[v] Zhang G, Li J, Purkayastha S et al. Hypothalamic programming of systemic ageing involving IKK-b, NF-kB and GnRH.  Nature (2013). 497:211-216.

[vi] Rogers vs Whitaker. (1992) HCA-175 CLR 479.

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Photo by Pavel Danilyuk.