Kirsti Miller Profile picture
Jan 28 68 tweets 19 min read
@BritishCycling trying to reach out to you to talk about you recycling failed policy. Your new trans guidelines is a breach of human rights and harms the health of affected women.
In 2017, the Human Rights Tribunal of Ontario recognised that policies originating from the IOC had infringed the human rights of cyclist Kristen Worley.
@ukantidoping
sportsintegrityinitiative.com/worleys-case-o…
Due to IOC policies regarding gender, the international cycling union (UCI) denied her the testosterone her physiology needed in order to maintain normal health, causing her medical and psychological harm.
Both the UCI and IAAF harmed athletes by implementing IOC Policies. In the Dutee Chand case, it emerged that 30 cases had been dealt with under the IAAF’s Hyperandrogenism Regulations, which were in force from 2011 to July 2015. And that’s in just one sport over four years.
Worley’s case is hugely significant because it holds the IOC to account for such harmful Policies. Yet the IOC’s Framework Guidelines ‘replaces and updates previous IOC statements on this matter, including the 2015 Consensus Statement’.
This appears to be an attempt by the IOC to distance itself from previous policies found to be responsible for harm caused to athletes. @ukantidoping @GenderGP
When asked if the IOC acknowledged that the release of the Guidelines could be triggering for athletes who had suffered harm under international federation attempts to implement its previous policies, the IOC pointed to its existing mental health resources.
In so doing, it recognised that athletes have been harmed by its policies, but it hasn’t done anything specific or new to help them.
The Framework Guidelines also dictate that medical information collected for anti-doping purposes ‘should only be used for the purposes disclosed to the athlete at the time such information is collected’.
In addition, the Guidelines specify that ‘informed consent’ must be sought from athletes when data is collected that could be used to determine eligibility to compete in the male or female category.
The 2021 World Anti-Doping Code specifies that doping samples can be used for gender verification purposes. There are serious questions about how this change was introduced to the 2021 Code that have never been answered.

sportsintegrityinitiative.com/doping-samples…
The idea back then was that it would be to monitor people with their consent”, said Budgett, when questioned about this. As such, have all doping control officers (DCOs) been informing all athletes that their doping samples can be used for gender verification purposes?
Have they given informed consent for this, as the Framework Guidelines on Gender Identity require them to?
In 2007, the same IOC Medical Commission that approved the 2003 Stockholm Consensus adopted a Consensus Statement on Sexual Harassment and Abuse in Sport. It is worth noting how the language differs.

stillmed.olympic.org/Documents/THE%…
The 2007 Consensus Statement recognises that sexual harassment and abuse ‘are violations of human rights’ that ‘give rise to suffering for athletes and others’ and to ‘legal, financial and moral liabilities for sport organisations’.
They specify that sporting organisations are ‘gatekeepers’ in this area and that everybody in sport ‘shares the responsibility’ to identify and prevent abuse in this area.
Psychosomatic illnesses, anxiety, depression, substance abuse, self harm and suicide are some of the serious health consequences’, continues the Consensus Statement. ‘Passive attitudes/non-intervention, denial and/or silence by people in positions of power in sport (particularly
bystanders@increases the psychological harm of sexual harassment & abuse. Lack of bystander action also creates the impression for victims that sexually harassing & abusive behaviours are legally & socially acceptable &/or that those in sport are powerless to speak out against it
Compare this with the IOC’s attempts to distance itself from harms caused by its policies on gender. States have an obligation to protect citizens from organisations or policies that could cause them harm.
The Framework Guidelines on Gender Identity appear to be an attempt by the IOC to draw a line under a very dubious part of its history.
The IOC has no choice but to take this approach. Many athletes have been harmed, & any admission of guilt could result in an avalanche of legal claims. However no human rights organisation – which the IOC claims to be – should be allowed to escape its historical past in this way.
‘The success of this new Framework in ensuring respect for the rights of transgender and intersex athletes will depend heavily on how it is implemented by sports governing bodies’, as the Shift Project puts it,
sportsintegrityinitiative.com/statement-on-t…
which has been working with the IOC on developing the Guidelines for the past three years.
The IOC will need to play an active & ongoing role in this regard. Moreover, adoption of a forward-looking Framework does not, on its own, address harms that have occurred in the past,
which sports bodies will also need to consider.’ @BritishCycling you have failed to even consider this.
@ukantidoping hoping we can connect before more harm is done.
I would love to have the maximum amount of trans people competing in @BritishCycling of course, or any athlete .... but the @BritishCycling with the blanket T policy aren't prepared for it and that's the scary part of this and it's actually endangering the XY trans athletes.
In the last 3 years Worley & other affected athletes have been working with the IOC on better ways of supporting transgender athletes, backed by more rigorous science and research.
There will be serious health and wellbeing consequences for transitioned and XY transgender athletes in meeting the anti-doping requirements in this new @BritishCycling policy @ukantidoping .
The release of this policy clearly shows @BritishCycling are not ready for transgender & XY transitioned female athletes with this policy. The system is still failing us, due to the strict testosterone limits which puts our health at risk.
It’s like taking the gas out of the car. When you lose testosterone in your physiology it’s like the car starts to shake when you take the petrol out of it. Certain functions of the body decrease or even stop functioning altogether.
Like the IOC did in 2003 & 2015 and now @BritishCycling is now
been caught up with the social side of the debate over transgender athletes.
Everybody needs hormones, it’s just that we need different types of hormones depending on what chromosome type you are. And that's the problem, like the IOC did in 2015 and now @BritishCycling they’ve tried to homogenise gender and they have compared apples with oranges.
The IOC thinking in 2015 and @BritishCycling today was & is that "if you lower an athlete's testosterone levels (of someone) who was XY chromosome that somehow that is going to match somebody who is XX.
No, you're making that XY chromosome person completely unwell, long term in sport and to end of life, thinking that's going to somehow assimilate to somebody who is XX chromosome (who doesn't need testosterone to stay well).
Remarkably, Worley the first transitioned woman to be sex verified under the original Stockholm consensus guidelines was able to have her case heard outside of CAS and, in a fillip for athlete self-determination, via a tribunal independent of sport.
In a resounding victory for evidence-based policy, the UCI accepted Worley’s critique and announced it would now:

… support an advocacy initiative to encourage sport’s governing bodies, at the highest level,
to adopt policies and guidelines that are based in objective scientific research and responsive to the individualised needs of XY female athletes.
The mediation parties agreed to promote this message to the IOC and WADA – the overarching global organisations in the Worley case.

uci.ch/pressreleases/…
Athletes caught up in the IAAF/IOC policy on hyperandrogenism were required – in order to partake in sport – to undergo surgical and/or hormonal interventions unrelated to their health status.
These procedures have been called into question as invasively counterproductive to the wellbeing of those women.
The IOC & @wada wrongly presumed like @BritishCycling have done today that, by comparison, transgender female athletes have no similar health concerns. Their overarching requirement is to keep serum testosterone levels below 10 let alone 5nmol/L!
However, a ten-year struggle by (now-retired) Canadian cyclist Kristen Worley proved this is not a simple journey.
In essence, Worley underwent gender reassignment via surgery in 2001 & attempted to re-enter the world of sport.
But when she applied for a Therapeutic Use Exemption (TUE) for testosterone (which is a vital hormone for women, as well as men), approval took ten months instead of days or weeks.
This put Worley into a “severe post-menopausal state”. It not only impacted on her health, but it prevented her from training as an elite cyclist.
Ultimately, when Worley was permitted a TUE under the World Anti-Doping Agency (WADA) code, the allowable:

… levels of synthetic testosterone 5nmol/L… were not enough to support her basic health.
This new @BritishCycling policy is in-fact 180 degrees of the medical and scientific truth.
@BritishCycling has assumed two things; one that transition in either direction is the same, secondly that XX females and XY females through transition are the same; they are not
and is like ‘comparing apples to oranges’. Of course, if the proper research had been done prior to policy by @BritishCycling this would have known this as a ‘starting point’.
@ukantidoping @GenderGP @shiftproject @wada_ama @iocmedia @proud2playinc @RogerPielkeJr
Testosterone belongs to a class of hormones called androgens. Whilst testosterone is the dominant sex hormone in males (oestrogen in females), it is produced in significant quantities by both males and females – especially by elite athletes, who need it to aid muscle growth
and recovery. Females produce it in the ovaries and the adrenal gland, whilst men produce it in the adrenal gland and testes.
Transitioned athletes need to take synthetic androgens, as they have no functioning ovaries or testes, and therefore cannot produce testosterone or oestrogen naturally, a situation known as ‘complete hormone deprivation’.

Scientists have found that when the body loses its ability to produce hormones, it loses its ability to maintain itself. If you remove the ovaries or testicles (as with the four London 2012 athletes).
then you are altering the body’s ability to naturally produce androgens, which has serious health implications.
As I said Kristen met the protocols outlined in the Stockholm consensus, and received a Therapeutic Use Exemption (TUE) to use synthetic androgens. However, the amount of androgens permitted by her TUE were set below the average range for females at 0.5nmol/L,
even though the normal androgen range for non-athletic females is 0.52nmol/L to 5.6nmol/L. This induced ‘complete hormone deprivation’ in Worley.
The impact of ‘complete hormone deprivation’ removes the body’s day to day ability to regulate itself, but especially in the amount of androgens needed to respond to exercise. As the body has no androgens, cell synthesis ceases, causing a number of serious health issues including
the induction of an immediate extreme post menopausal state; a non-natural and aggressive ageing process; complete muscle atrophy (i.e. failure of muscle development
& recovery, making sport impossible); anaemia; a large drop in haematocrit levels & more. “For @BritishCycling and @ukantidoping sport to suggest such a parallel with XX chromosome women in terms of hormones is false, unethical, as well as being medically & scientifically immoral
You are comparing apples to oranges. Women with an XY history produce no androgens, but XX women have androgens, which carry over 200 daily functions in the human body.
Outside of women’s sport androgen deprivation, which is unique to the XY karyotype and is known medically as hypogonadism, is treated with testosterone supplements and intervention to elevate blood levels to increase health and wellness.
But within the sporting structures governed by @wada_ama policy, access to testosterone is heavily regulated. XY individuals need their testosterone levels to be T>14nmol/L or higher to be healthy.
Yet the IOC previously and now @BritishCycling & @wada_ama requires that XY females competing without a therapeutic use exemption (TUE) – like me post operative– to maintain R levels at below 10nmol/L, where XY athletes who have undergone sex reassignment are at 0.5nmol/L,
as the only remaining source for their primary hormone, testosterone, is the adrenal glands.
From personal experience, I can tell you that it is next to impossible to continue competing at the international level in most sports, let alone safely, while abiding by blanket 5 or 10nmol rules @wada_ama Policy – which is also used to set the policies of sport-specific,
national and regional governing bodies as signatories to the Olympic Movement, worldwide. Beyond competing in sport, it is impossible to maintain your basic health as a transitioned XY female competitor without TUE support and the necessary infrastructure and understanding.
Multiple athletes have lost their careers to these policies. I am one of them, and I know of close to two dozen other voices.
Given my experience, what we are seeing here with this @BritishCycling policy represents déjà vu. Athletes are being impacted by this very same framework, and being put at risk through an insecure, unhealthy, and unsafe environment in which to ensure an athlete’s success.
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More from @KirstiMiller30

Jan 27
It has been argued by the likes of Tucker & Hilton et al without evidence that cisgender women athletes could be at greater risk of physical harm and injury if they compete in sports with larger and stronger transgender and intersex athletes.
This is the basis of World Rugby’s ban on trans women. According to the report prepared for World Rugby, trans women who transition after male puberty retain ‘significant’ physical advantages over cisgender women — even after they take steps to lower their testosterone levels.
The report claims advantages include being 30–40% stronger and more powerful and 10–15% faster.101 Importantly, the report concludes these advantages create at least a 20–30% greater risk of injury for cisgender female rugby players competing against transgender female players.
Read 17 tweets
Jan 26
All these clowns that have said Laurel Hubbard at 10nmol/L competed in Tokyo, with up to 10 times the amount of T than an XX women don't have a clue. Laurels T levels have been under .04nmol/L since 2012 impossible for her to have any higher. She met the rules of the 2003 policy.
At 3minutes 20 Laurel confirmed in 2017 that she competes under the rules of the 2003 IOC policy meaning she was more than two years post operative when she first competed in the women's category. Her injury in 2018 was a direct result of CAD.

I spoke about the serious consequences to health Laurel was forced to compete with in this interview. My prediction cane true Laurel competed with a massive disadvantage.

Read 5 tweets
Jan 25
Sports like #WorldRugby blanket banning #transgender women on safety grounds place themselves on a slippery slope. Safety has no gender!

austlii.edu.au/au/journals/Ad…
A separate trans policy is not necessary to address physical safety risks in sports. It is the disparity in size/strength that is relevant, not the source of the disparity.
Assessing any group of athletes as a monolithic group especially amongst trans athletes is flawed. Trans is an umbrella term many different body stages of transition & body types. ImageImage
Read 26 tweets
Jan 25
Believing and perpetuating myths and misconceptions about trans athletes is harmful. Denying trans people the right to participate is discrimination and it doesn’t just hurt trans people, it hurts all of us. ImageImageImageImage
There is a long legacy of sex discrimination in sport. Myths, such as the idea that physical exertion would harm women’s reproductive systems or that women were inherently inferior athletes, were historically used to “protect” women out of participation. Image
The marginalization of trans trans & intersex athletes is rooted in the same harmful history of gender discrimination and stereotyping that has impeded the achievement of gender equality in sports as a whole. ImageImageImageImage
Read 28 tweets
Jan 19
Pride Games is not just about celebrating Pride out on the sporting field!
Way before celebration of Pride there is an urgent need for all sports to develop programs & solutions to these problems to improve youth mental health, boost physical activity rates, & mitigate the negative influences of traditional gender norms.
Although there has been more progress on the issue of homophobia in sport, there was a LOT more work to be done on issues affecting trans people. Trans athletes in sport are being attacked by the likes of Trump even our PM @ScottMorrisonMP called us heavy handed in cricket.
Read 32 tweets
Jan 18
Academics and leading scholars in the fields of Kinesiology, Law and Policy, and Gender Studies agree that trans women DO NOT have an inherent advantage are not a threat to women's sports. ⁦@FallonFox⁩ ⁦@AlanaFeral
@DrRyanStorr
athleteally.org/future-womens-…
This document
athleteally.org/wp-content/upl…

utilizes a close reading of peer-reviewed, credible sources to better understand trans athletes, to dispel misinformation about trans athletes that has spread in recent media and political debates,
to outline critical legal and policy discussions about trans athletes, and to highlight why access to sport matters for everyone.
Read 6 tweets

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