Should Mermaids be permitted to influence UK public policy on ‘trans kids’?

by Artemisia

Mermaids is a UK charity. Its aims are ‘to relieve the mental and emotional stress of all persons aged 19 years and under who are in any manner affected by gender identity issues, and their families, and to advance public education in the same’.

The organisation began a number of years ago as a support group for parents, and it still maintains an online forum. It also undertakes casework, training, advocacy and political campaigning.

In interviews with the press, its Chief Executive Officer, Susie Green, has described her experiences as the perplexed mother of a small boy who was drawn to ‘girly dresses and dolls’ rather than ‘’trucks and football’. When Jackie was nine, permission was obtained for him to wear girls’ clothes to school.

At twelve, his mother took him to the United States for a consultation with Dr Norman Spack, an endocrinologist at Boston Children’s Hospital. Dr Spack prescribed a puberty-blocking hormone, a treatment that at that time was banned in Britain for any child younger than sixteen.

Later, when Jackie was thirteen, Spack put him on estrogen: again, a highly controversial approach. Current policy in the NHS prohibits the prescription of cross-sex hormones to children younger than about 16.

In recent years, under Susie Green’s leadership, Mermaids has pressed insistently, disregarding the concerns of clinicians, for cross-sex hormones to be prescribed to younger children.

For Jackie’s sixteenth birthday, he was flown to Thailand where he underwent a seven-hour operation to fashion a pseudo-vagina. This would not be legal nowadays; soon after Jackie’s operation new regulations were imposed by the Thai Medical Council, restricting ‘sex change operations’ to patients over the age of eighteen. Furthermore, since 2009, young adults aged 18-20 must now obtain parental permission to undergo sex change procedures in Thailand. As can also be seen in this excerpt from a 2009 Telegraph article discussing tightened restrictions, a Thai gay rights activist drew attention to the phenomenon of post-SRS regret experienced by some patients.

In England under the NHS, irreversible gender-related surgery is only available to patients eighteen and older. This is in accordance with international standards of care.

Mrs Green has promoted Mermaids energetically. As CEO, and before that, Chair, she has been regularly quoted and interviewed in the media. In recent years she has been an invited speaker at various forums and conferences. Convenors have included the Westminster Social Policy Forum and the Royal College of Paediatrics and Child Health.

In 2015, Mrs Green was selected to give evidence in person to the inquiry into Transgender Equality conducted by the Women and Equalities Committee of the House of Commons. Mermaids also submitted a written statement. Later in this post I shall have more to say about that.

In a previous post I discussed an episode in which local authority social workers handed over to Mermaids the effective management of a child welfare case. This did not end well. Ultimately the High Court ordered that the child be removed from his mother. The charity was excluded from further contact.

Mermaids also offers training to professionals:

With this in view, it is reasonable to enquire into Mrs Green’s qualifications for the kinds of activity she and her organisation undertake. Under ‘Education’ on her LinkedIn page there is only one institution listed: ‘prince2 academy’.

PRINCE2 is an acronym for PRojects IN Controlled Environment and as its name suggests, it is a project management system. The PRINCE2 Academy appears to be a set of courses delivering online training in the PRINCE2 method. It is not clear if Mrs Green is a registered PRINCE2 practitioner or whether she has simply taken the foundation course. But that is not particularly important.

Project delivery is about process. Training, advocacy, an advisory role with respect to public policy: these are primarily about content. Delivery of accurate information is key, accompanied with well-informed insight, perceptive analysis.

Let’s look at how Mermaids measures up.

Mermaids submitted erroneous evidence to the Women and Equalities Committee

 The following passage is taken from the written evidence submitted by Mermaids to the Transgender Equality Inquiry conducted by the Women and Equalities Committee in 2015.

Mermaids frequently quote the Equality Act, primarily to schools unwilling to accommodate trans children. Antithetically, a young person of 16 wanted their name changing at school but their parents did not consent to this. Although the Equality and Human Rights Committee found the schools refusal to comply was discriminatory, they could not proceed with action against the school as the young person was under 18.

[Recommendation]: Lower or remove the age the Commission could pursue a young person’s complaint without parental consent.

This passage was quoted in the Committee’s report, which duly recommended:

The Equality and Human Rights Commission must be able to investigate complaints of discrimination raised by children and adolescents without the requirement to have their parents’ consent. [See pp. 27, 74, 81]

Following which the Government Equalities Office looked into the matter. Here is the Government response:

No such restriction exists on the Equality and Human Rights Commission’s (EHRC’s) power to investigate complaints of discrimination, and we are not aware of any legal basis for the statement in Mermaids’ written evidence to the Committee that “a young person of 16 wanted their name changing at school but their parents did not consent to this. Although the Equality and Human Rights Committee [sic] found the schools [sic] refusal to comply was discriminatory, they could not proceed with action against the school as the young person was under 18.” The Committee may wish to note that, in order to comply with the Data Protection Act 1998, the Equality Advisory and Support Service may pass an individual’s details to the EHRC only with the explicit consent of the individual. The case referred to in Mermaids’ written evidence was not referred to the EHRC. EHRC staff have met with Mermaids recently to clarify how the referrals process operates. [p. 13]

Rather snarky, it seems to me, but civil servants don’t like having their time wasted.

So: for whatever reason, Mermaids included a claim without foundation in its submission to the Transgender Equality Inquiry. The Committee trusted the organisation to know what it was talking about — and found itself with egg on its face.

Does Mermaids understand how much this matters?

It matters because public policy should be founded on sound evidence — on facts. No one who peddles made-up claims should be advising government committees.  Nor should they be involved in training professional people with direct responsibility for children, sick people or families in crisis.

Susie Green refused to acknowledge on the BBC that cross-sex hormones cause sterility

susie green bbc newsnight

Susie Green

 The evidence is there on YouTube for everyone to see. On 1 November 2016 there was a short debate on BBC Newsnight between Susie Green of Mermaids and Stephanie Davies-Arai of Transgender Trend.

Here is a transcript of the key exchange, which begins at around 4:20. Important passages bolded:

 Stephanie Davies-Arai: The treatment pathway is the same as transsexual, it’s cross-sex hormones (not cross-gender hormones). It leads to children being sterilised and on medication for life in order to be ‘their authentic selves’.

Evan Davis (interviewer) to Susie Green: Is that correct or …

Susie Green: Well no. I think that in terms of the way that these young people are assessed, they go through very careful assessments before any medical intervention is offered, that’s never before puberty has at least begun and got through to a certain stage …

Susie Green’s denial—’Well no’—and avoidance of the key issues raised by Ms Davies-Arai–are remarkable. Note the following points:

  1. ‘The treatment pathway is … cross-sex hormones’

At the Tavistock and Portman Gender Identity Development Service (GIDS) the treatment pathway is cross-sex hormones from the age of 16.

Less than four months before she appeared on Newsnight Susie Green gave a statement to the Guardian in which she called for the age limit for prescribing cross-sex hormones to be lowered.

  1. ‘It leads to children being sterilised’

This is a well-recognised effect of administering cross-sex hormones. Here is a concise and comprehensive statement from a medical authority, which also covers the effects of so-called ‘puberty blockers’ and gonadectomy:

Medical treatments—effects on fertility

Pubertal suppression with gonadotropin releasing agonists (GnRH-a) not only prevents development of potentially distressing secondary sex characteristics but also suspends germ cell maturation. Puberty appears to progress normally after discontinuation. However, many transgender individuals initiate gender-affirming hormone therapy concurrently with pubertal suppression, and thus, germ cells never fully mature. …

Gender-affirming hormones produce impairments in gonadal histology that can cause infertility. Estrogen use by transgender women results in impaired spermatogenesis and an absence of Leydig cells in the testis. Testosterone use by transgender men causes ovarian stromal hyperplasia and follicular atresia.

Gonadal effects of gender-affirming hormones are thought to be at least partially reversible. For example, pregnancy has been reported in transgender men who have previously used testosterone. Thresholds have not been established for the amount and duration of exogenous testosterone or estrogen exposure necessary to have a permanent negative effect on fertility.

For patients who elect surgical transition, gonadectomy will render them permanently sterile.

Source: Johnson EK, Finlayson C (2016) ‘Preservation of fertility potential for gender and sex diverse individuals’, Transgender Health 1:1, 41–44

  1. ‘It leads to children being … on medication for life’

Here are a couple of relevant statements by medical authorities:

  1. a) ‘Cross-sex hormone treatment has an important role in acquiring the secondary sex characteristics of the desired sex. Transsexuals often start taking sex hormones at young to middle age and in higher than recommended dosages. Fearing loss of secondary characteristics of the reassigned sex, transsexual subjects usually continue hormones lifelong.’

Source: Asscheman, Henk, Giltay, Erik J et al, ‘A long-term follow-up study of mortality in transsexuals receiving treatment with cross-sex hormones’, Eur J Endocrinol April 1, 2011 164, 635-642

  1. b) ‘After reassignment surgery, which includes gonadectomy, hormone therapy must be continued.’

Source: Gooren, Louis J., Giltay, Erik J, Bunck, Mathijs C. ‘Long-Term Treatment of Transsexuals with Cross-Sex Hormones: Extensive Personal Experience’ The Journal of Clinical Endocrinology & Metabolism, Volume 93, Issue 1, 1 January 2008, Pages 19–25


Considering her position as the CEO of an organisation that claims to speak with authority on the transition of children and young people, it is shocking that Susie Green should go on television and mislead the public on these crucial matters.

To say the very least: this is not professional behaviour.

Immediately after saying ‘Well no’, Mrs Green changed the subject with very noticeable promptness. Let’s look at what she said next: ‘in terms of the way that these young people are assessed, they go through very careful assessments before any medical intervention is offered’.

We might find this just a little bit glib, coming as it does from a woman who ignored the settled opinion of experienced clinicians and arranged for her son to have a gonadectomy when he had barely turned sixteen–in a country (Thailand) which now bans such surgeries to people under the age of 18.

Mermaids has falsely stated the survey population when purporting to cite statistics for suicidality among ‘trans youth’

In presentations aimed at concerned professionals, Mermaids has exhibited a PowerPoint slide with the heading ‘Statistics’. It displays a set of figures designed to chill. But let me quickly say: these are not what they seem. They have been fiddled to support an agenda. They are, in fact, completely worthless.

Mermaids-suicide-stats-compressor

Here are the phony statistics in question:

  • ‘59% trans youth considered suicide
  • 48% attempted suicide
  • 57% actively self-harm’

A subheading claims that the figures come from a survey of ‘more than 2000 trans people in the UK’. The survey, cited at the foot, was conducted by academics from three universities in collaboration with PACE, a now-defunct LGBT+ mental health charity. The report was published in 2014.

There is no mention of the report’s title: LGB&T Mental Health — Risk and Resilience Explored. The foreword records that ‘Over 2000 people completed our survey…’

Spot the obvious mistake. The trans participants in the survey were only a subset of the total number of people who took part. The statement that ‘more than 2000 trans people’ were surveyed is not true.

And this matters enormously, because unless the survey population is of adequate size, the results of the survey have very little meaning. It is not possible to use those results to make useful generalisations about the target population, the group about which the survey is intended to provide information.

In the case of the survey into ‘LGBT&T Mental Health’, the overwhelming majority of respondents were lesbian, gay or bisexual. Only a minority, just over 17%, identified themselves as trans.

And here’s the clincher: Only 27 of the trans respondents were under 26. This is the total size of the survey population on which the claim is based that 48% of ‘trans youth’ have attempted suicide.

There is absolutely no way that the results of such a tiny survey can be mapped onto the whole population of trans-identifying young people in the UK.

That twelve of the 27 reported such an attempt is very sad for them and their families. However, it tells us nothing about the prevalence of suicide attempts among ‘trans youth’ in general. This micro-survey is of no value whatsoever as a basis for determining social policy.

This is not an abstruse matter: it should be obvious to anyone with common sense.

Mermaids has used the supposedly high risk of suicide attempts by trans-identified young people to support its campaign to lower the age at which the NHS prescribes cross-sex hormones to children. It claims that medical transition reduces the likelihood that a gender dysphoric child will commit suicide. In reality, there is no persuasive evidence that this is true.

When Susie Green gave oral evidence to the Transgender Equality Inquiry she argued that the treatment protocols followed by the Gender Identity Development Service are too restrictive and should be relaxed. She claimed that children waiting to be put on cross-sex hormones become ‘self-harming and suicidal’ and referred to ‘a 48% suicide attempt risk’.

This claim was picked up and repeated in the report from the Committee: ‘Mermaids said there was a significant risk of self-harm or suicide where hormone treatment is not yet being given; they drew attention to evidence that the attempted suicide rate among young trans people is 48 per cent.’ [p. 52]

For the 48% figure a footnote refers to an article in the Guardian published in November 2014. The Guardian in turn cites ‘findings released by Pace’. Evidently the journalist had had an advance view of a press release from PACE dated 20 November. This press release predated the publication of the full report of the survey.

The press release gives an overall figure of 485 for ‘survey participants under the age of 26’. Rather strangely, however, it omits to give an overall number for the ‘young trans* participants’ while stating that ‘48.1% … have attempted suicide’. The use of percentages at this point conceals the very small number of respondents. The other figures in the Guardian post also come from PACE: the Guardian has simply rounded them down, so that 48.1% becomes a snappier 48% and the figure of ‘59.3%’ for suicidal thoughts becomes 59%.

It is, perhaps, not coincidental that these misleading and alarmist figures were initially presented by a charity that was forced to shut its doors for lack of funding just over one year later.

Meanwhile, the Guardian confused matters further by implying that all of the ‘more than 2,000 people’ surveyed were ‘trans’. Presumably this was due to a careless misreading of the statement from PACE.

Given that the Mermaids PowerPoint slide refers to a ‘survey of more than 2000 trans people’ it seems likely that the figures on the slide came by way of the Guardian report. Even assuming that this is the case, it does not let Mermaids off the hook.

It is simply not professional to quote statistics from a newspaper report without attempting to check them at source. In this case the survey report is easily found on the web. Although PACE has closed down, the report has been archived on several sites by interested parties.

Regardless of what it was intending to do, Mermaids deceived the audiences to whom it presented that PowerPoint slide. Even more important and worrying, it gave misleading information to the Women and Equalities Committee.

There is more. The problems with the figures on the PowerPoint slide have been pointed out in detail in at least two important blog posts:

So far as I am aware Mermaids has never acknowledged either of these critiques, nor has it qualified Susie Green’s statement to the Women and Equalities Committee.

The organisation does not seem to have cited the 48% figure recently. But last month Mrs Green was back beating the same old drum, this time in an article on Huffington Post UK. This time she kept things vague, asserting that there are ‘shockingly high statistics for suicide attempts by transgender young people’ without citing any source at all.

These serious misstatements of fact are not acceptable

Mermaids presents itself as a repository of wisdom on the subject of transgender children and youth and in many quarters it is accepted as such. The inaccurate statements detailed above are not minor matters. The UK, as a society, cannot afford such lapses in an organisation that trains professionals and advises on public policy.

Moreover, none of this is helpful to children who show symptoms of gender dysphoria or gender identity disorder (as currently defined), or their anxious and more or less bewildered parents. They deserve a more professional service than Mermaids is currently providing.

Meanwhile, it should, unfortunately, be recognised that it is never safe to take on trust any statement that comes from Mermaids.