CALLING FOR URGENT FEDERAL INVESTIGATION INTO WPATH
A thoroughly researched paper by E. Jensen examines whether the World Professional Association for Transgender Health (WPATH), the organization whose guidelines shape gender medicine practice worldwide, is experiencing what safety science calls an "organizational failure," meaning it is unable to recognize or fix ongoing safety problems. Initially submitted for review in February 2024, the paper has been expanded to a book, soon to be published by Paradox Press
@pdxinstitute. We summarize with some key points in hopes that it sheds more light on the operations of WPATH.
WHAT IS AN ORGANIZATIONAL SAFETY FAILURE?
In workplace safety, when something goes wrong, investigators look for "root causes" or root cause analysis of the deeper organizational problems that allowed the incident to happen, not just the immediate event (OSHA, 2016). An organization in failure mode is one where root causes are either never identified or never fixed. This paper identifies six warning signs of this, illustrated with well-known examples:
- Ignoring science: Decisions are made that go against available evidence, often due to biases like confirmation bias (only seeing what supports existing beliefs) or the "halo effect" (trusting information from favored people regardless of its quality) (NSF, 2023).
- Blocking investigation: When problems are identified, the organization either prevents investigation or conducts a flawed one. The Rotherham child exploitation scandal is cited: approximately 1,400 children were sexually exploited over 16 years while a researcher who documented the problem had her funding cut for "implementation problems" (Alexis Jay OBE, 2014).
- Punishing those who speak up: Disagreement is silenced rather than addressed. The Boeing 737 MAX is cited: rather than fixing a known dangerous system (MCAS), Boeing and FAA personnel punished whistleblowers and obstructed investigations (Commerce Committee Majority Staff, 2020). The 1900 Galveston hurricane is another example: Cuba's weather service warned the US, but their communications were cut off because officials found the information unclear (Larson, 1999).
- Conflicts of interest: Leaders cannot objectively evaluate situations because of personal stakes: financial, relational, or otherwise (Emory A. Rounds, III, 2022).
- Training only from within: When leaders learn only from their own organization, they develop blind spots. Safety protocols fail to adapt to change, and a false sense of security develops.
- Dismissing or mistreating those affected: People harmed by the failure are ignored, mocked, or treated with condescension, preventing the problem from being recognized (John L. Bryan, 2008; Yates, 2015).
HOW DOES THIS APPLY TO "GENDER MEDICINE"?
This paper then examines WPATH's Standards of Care version 8 (SoC8, Coleman et al., 2022) through each of these warning signs.
Who Actually Needs These Treatments?
The paper points out that there is no objective test, no blood test, scan, or measurable characteristic, to determine who has a "gender identity" that will benefit from medical treatment. Diagnosis is based entirely on what the patient reports. More importantly, there is no way to predict whether someone's gender identity will remain the same after treatment. "Gender fluid" is a consideration, as well as "non binary". This matters because many of these treatments cause permanent changes to the body, including potential effects on fertility, bone health, cardiovascular health, brain structure, and sexual function (Wierckx et al., 2012; Bjørnebekk et al., 2021; Cheng et al., 2019; Levine, 2018; Dreher et al., 2018; Nassiri et al., 2020).
The paper also notes that WPATH's SoC8 contains no guidance on caring for people who detransition, individuals who underwent these treatments, and later regretted or reversed course (Cohn, 2023; Jorgensen, 2023; Clayton, 2023). Without studying these patients, the paper argues, the evidence base is fundamentally incomplete because only favorable outcomes are being captured.
How Many People Are Affected?
Estimating the number of people receiving "gender medicine" in the US is surprisingly difficult. Some patients are "correctly" coded through insurance with a "gender dysphoria" diagnosis. Others receive treatments coded under different diagnoses, a practice called "creative coding" (Grinberg et al., 2018; Santoro, 2022). Still others pay out of pocket entirely. A "gender dysphoria" diagnosis is also not always required (Olson, 2022; Wahlberg, 2023), and the formality of diagnosis varies widely (Plume, 2022; Chiang et al., 2023). Insurance-based estimates (such as Respaut and Terhune, 2022, reporting about 5,600 children treated from 2017–2021; Canner et al., 2018) only capture a fraction.
The paper takes a practical approach, using published referral data from a single pediatric gender clinic and the known exponential growth in the number of referrals, consistent with data from multiple countries. The extrapolated single-clinic treated population was 378 (2019), 671 (2020), and 1,193 (2021). There were 33 of these clinics in 2014, meaning just two clinics with similar populations would exceed the entire Respaut and Terhune national estimate. A calculation was then undertaken that when a patient population reached a certain annual size, a new clinic needed to open. If the average among various clinics is around 121, then approximately 326 would be treating patients by 2021. This compared well with the 300-400 estimated by SEGM and Gender Mapper. Note that the medical group associated with the pediatric clinic is being sued by a detransitioner
@CholeCole (Brockman v Kaiser, 2023).
Adding in Planned Parenthood's 41 gender medicine clinics, which treated over 74,000 patients across all ages in 2022 alone based on extrapolated data (Brock and Anderson, 2023; Sibarium, 2023), and using survey data on transgender identification rates (Herman et al., 2022; Jones, 2023) with US Census population figures (US Census Bureau, 2020) to estimate the pediatric-to-adult ratio, the paper estimates:
- Approximately 200,000 children have cumulatively received gender medicine treatments since 2015
- Approximately 650,000 adults in the same period
- A combined total of roughly 0.9 million people, with acknowledged uncertainty of ±50%
The paper predicts that the pediatric growth rate likely plateaued in 2022–2023 because the number of new clinics needed to sustain exponential growth became impractical. The author also notes that the Respaut and Terhune insurance database analysis captured roughly 6% of the estimated overall population, meaning 94% of pediatric "gender medicine" patients are either not using insurance or not receiving a "gender dysphoria" diagnosis before receiving treatments.
WPATH's Influence on Practice
The paper documents how WPATH's guidelines shape care broadly. The American Academy of Pediatrics' 2018 policy statement directly references WPATH (Rafferty, 2018) and this policy subject to a another detransitioner lawsuit (Ayala v. AAP, 2023, settled with Rafferty and dismissed against AAP). The Endocrine Society's guidelines were co-sponsored by WPATH (Hembree et al., 2017) and have been criticized by evidence-based medicine experts (Kaltiala et al., 2023; Block, 2023a). WPATH training is incorporated into physician education at universities (Kayode, 2023).
WHAT DOES THE EVIDENCE ACTUALLY SHOW?
Several countries have independently reviewed the evidence behind "gender medicine" for young people, and all reached similar conclusions:
- Finland (Council for Choices in Health Care, 2020): Found the evidence very low quality; required gender medicine to be delivered only through research clinics with experimental safeguards
- Sweden (Ludvigsson et al., 2023): Concluded gender medicine should be considered experimental and delivered only under strict research conditions
- United Kingdom (NICE, 2020): Found very low quality evidence for both puberty blockers and cross-sex hormones in children/adolescents
- Norway (Healthcare Investigation Board, 2023; Block, 2023b): Criticized the establishment of treatment guidelines without a systematic review first; classified treatment as experimental
- Denmark (Hansen et al., 2023): Changed its treatment policy based on safety concerns from insufficient evidence
The Cass Review interim report (2022) noted that an experiment is defined by a deliberate scientific framework, which is currently absent from "gender medicine" practice. Despite these findings, WPATH's SoC8 was developed using a consensus-based approach (Delphi method, where experts vote on recommendations) rather than strictly following the evidence. This distinction is acknowledged by WPATH leadership in their own communications. Note that this paper was submitted before the final Cass review, which also makes the same point.
ETHICAL CONCERNS
The paper raises several ethical issues:
The phrase "Do no harm" appeared in the ethics section of SoC version 7 (Coleman et al., 2012) but was removed from version 8.
Research spanning a decade has shown that most children with gender dysphoria naturally resolve their distress through puberty without medical intervention (Kaltiala-Heino et al., 2018). However, when children receive psychological affirmation that their cross-gender identity is correct, the vast majority continue to identify that way (Zucker, 2019), raising questions about whether the approach itself influences the outcome. A paper raising serious ethics concerns about current practices (Levine et al., 2022) preceded SoC8 but is not mentioned in it.
All medications used in gender medicine are prescribed "off-label", meaning they are not FDA-approved for this purpose (AMA, 2016). Pharmaceutical companies have repeatedly declined requests from doctors to seek FDA approval or conduct clinical trials for these uses (Terhune et al., 2022). The FDA may have been considering lowering its standards to encourage approval applications (Anonymous, 2023). Dresser and Frader (2009) have warned about the risks of off-label prescribing when substantial uncertainty exists. Meanwhile, some of these medications can cause permanent infertility, and animal models are rarely used to test outcomes first (Anacker et al., 2021; Guarraci et al., 2023; Hough et al., 2017).
WPATH's own evidence review, conducted before SoC8 was published, stated: "We could not draw any conclusions about death by suicide" (Baker et al., 2021). Yet claims about suicide risk are frequently used to justify urgent treatment (Jensen, 2022), and the SoC does not distinguish between suicide risk before versus after treatment, an important distinction given that some of the medications themselves are associated with increased depression risk. "Gender diversity" caused by factors not treatable with gender medicine, such as homosexuality (Steensma et al., 2013) or autism (Churcher Clarke and Spiliadis, 2019), would not be expected to show reduced suicide risk from these treatments. Jackson (2023) supports this finding. The best available analysis on suicide in the UK pediatric gender service population (Biggs, 2022) is not mentioned in SoC8.
The Eunuch Chapter: A Case Study in Weak Evidence
Chapter 9 of SoC8, which addresses "eunuch" identity, is examined in detail as an example of the quality of evidence underlying the guidelines. Nearly every non-pharmaceutical citation in the chapter comes from the Eunuch Archive, an online fetish database. The cited sources include:
- A single case report where the method of psychiatric evaluation was not described (Hermann and Thorstenson, 2015)
- An opinion piece (Wassersug and Lieberman, 2010)
- A popular press article that was not peer-reviewed (Hay, 2021)
- A book about writing fictional eunuch characters (Lieberman, 2018)
- A journal article where none of the reference links functioned (Wibowo et al., 2016)
- A journal article with only three references total — a census, a textbook, and a photo essay (Mukhopadhyay and Chowdhury, 2009)
No data is presented supporting the eunuch identity in children. The Eunuch Archive contains writings involving minors (Gluck, 2022a). The chapter's lead author (T.W. Johnson, listed as 12th author on Coleman et al., 2022) has been documented as having a personal sexual interest in the subject matter (Gluck, 2022b), raising conflict of interest concerns. The paper argues that a systematic review of this chapter would likely not retain any of these citations.
How WPATH Responds to Criticism
The paper reproduces a full April 2023 letter from WPATH President Dr. Marci Bowers (Bowers, 2023) and analyzes it against the six failure characteristics:
- Detransitioners are not mentioned anywhere in the letter. The SoC repeats that detransition is rare when the actual rate is unknown.
- The letter's content is predominantly political, discussing "anti-trans" legislation, conservative politics, gun control, book banning, and Harvey Milk, with very little addressing medical evidence or patient safety.
- The Finnish, Norwegian, and Danish evidence reviews and policy changes are not acknowledged. The Florida review of available evidence (Brignardello-Peterson and Wiercioch, 2022) is not directly addressed.
- European restrictions are characterized as having been "cherry-picked" by US conservatives, without engaging with the substance of those reviews' findings.
- The Missouri Attorney General's actions, which were triggered by whistleblower evidence from a pediatric gender clinic (Bailey, 2023) and sought to require gender medicine to follow experimental research safety rules, are characterized simply as political attacks.
- Dr. Eli Coleman's quoted defense of SoC8 explicitly acknowledges the consensus-based methodology. The unscientific approach of SoC8 development was also discussed by Dahlen et al. (2021).
- A recent publication claiming that withholding WPATH-recommended care constitutes "maltreatment" (Georges et al., 2024) is cited as an example of insular training's impact, with its citations suffering from selection bias.
Shortly after SoC8 was first published on September 6, 2022, a revised version appeared on September 15 with nearly all age recommendations removed. The explanation, provided by committee member Amy Tishelman, was that age recommendations needed to be removed to avoid exposing practitioners to lawsuits while enabling insurance coverage for treatments. One age recommendation remained: phalloplasty was not recommended for youth under 18 due to high complication rates.
What Happens to People Who Raise Concerns?
The paper documents professional consequences for those who question WPATH's approach, drawing parallels to FAA retaliation against Boeing whistleblowers and hostility toward the Rotherham researcher. Kenneth Zucker, a psychologist who specialized in "gender medicine" for decades, was fired by the Centre for Addiction and Mental Health for asserting there was insufficient evidence behind their "best practices" (aligned with WPATH SoC). He was later exonerated and received an apology and settlement (Hayes, 2018). The paper states that questioning the safety of WPATH SoC can be expected to negatively impact one's career, and notes that the medical content of the paper itself was edited by an anonymous researcher in the field for this reason.
CONCLUSION
The paper concludes that WPATH meets all six criteria for organizational failure: decisions contraindicated by science, blocked scientific inquiry, suppressed dissent, conflicts of interest, insular training, and hostility toward those affected. "Gender medicine" as currently practiced is characterized, rightfully so, as dangerous, with an estimated 0.9 million people at risk (vastly underestimated in our opinion), and the paper calls for a formal safety investigation into the WPATH Standards of Care.
We thank E. Jensen for this important analytical paper, and encourage you to read it in full, below. We, at Colorado Principled physicians, and E. Jensen, implore the federal government to seriously investigate WPATH for organizational failure, and the exponential harm to vulnerable adults and minors who have been experimented on due to their "guidelines".
Brilliant work,
@acsengsafety!
@zaelefty @ptelephant @ftc @potus @gop @GOPoversight @TheDemocrats @ConceptualJames @CollinRugg @swipewright @donoharm @govrondesantis @thejusticedept @hhsgov
#WPATH #WPATHFILES #USPATH #genderidentity #genderaffirmingcare #medicalethics #ethics #MedTwitter #MEDX #medicine