When I checked the site today, I found a message sent to me regarding an attempt by multiple anti-trans organizations to get the FDA to create restrictive regulations on the prescription and use of estrogen for the treatment of transgender women. The request is of course based on pseudoscience, and when reviewing the petition it becomes readily apparent that many of the justifications for their petition are being twisted to reflect a viewpoint not originally cited within the referenced materials.

As an example, the petition cites studies that show that Analysis of the United States Transgender Survey 2015 (USTS 2015) data showed that males who took cross-sex estrogen for gender affirmation were more likely to plan suicide, attempt suicide, and require hospitalization for a suicide attempt. This uses a well known fact - that those suffering from gender dysphoria are more prone to suicide and suicidal ideations than the general population, to justify stopping treatment for gender dysphoria. This is circular logic; those of us suffering from gender dysphoria don’t have a higher rate of suicide because of the treatment, but rather because of the underlying issue - gender dysphoria. The number would more than likely be higher if hormone therapy was not available, but having said this, HRT is not a cure all. Although it helps, it cannot take the patient back in time and erase the underlying history contributing to the emotional issues we suffer from, just like any childhood trauma.

They also state the growth in clinics specifically set up to treat transgender patients as a cause of their petition. And I quote, The number of clinics providing hormonal interventions for gender affirmation based solely on informed consent has surged. A 2022 Reuters investigation documented the growth of specialized pediatric gender clinics from zero to over 100 in just 15 years, while a 2021 analysis estimated that there were more than 300 clinics and offices providing such interventions to minors nationally. More than 1500 cancer treatment centers have opened up in the United States in the past three decades; should we be asking the FDA to look into the increase in cancer patients as a result of the existence of more treatment centers? Is the increase in cases of cancer due to the increase in treatment centers? Based on the logic used in this petition, that would be the case.

The underlying fact which those submitting this petition are choosing to ignore is that over the past several decades, because of changes in our society, more transgender people are willing to come forward. The number of acknowledged transgender Americans has increased, and the medical profession has responded accordingly by the creation of specific centers within which those who specialize in the field can practice. Not the other way around. Just as is the case with cancer treatment centers.

They also use the increase in transgender patients to justify their petition. They found that the current rate of medicalization based on formal diagnoses of gender dysphoria (0.1%) is 13 to 22 times higher than the established historical clinical baseline for gender dysphoria (0.0046%–0.0075%). The authors conclude that this discrepancy suggests a “systematic over-prescription of medical interventions to an overwhelmingly non-clinical population.” Apparently, any increase in the level of treatment for gender dysphoria cannot possibly be due to the fact that we know more about it now than we did twenty years ago, or that because of the internet, that knowledge is more readily available to the general public. Or perhaps that people are simply more open about where they fall on the spectrum, and the medical profession more knowledgeable?

Additionally, the proposal includes the creation of a registry to include any and all transgender patients being prescribed estrogen. Anyone want to guess why this would be needed?

It should also be noted that roughly two-thirds of the signatories to the petition are not medical professionals, and also that not a single major medical organization signed on in support of the petition.

The links to the article and the petition are included below:

https://www.transvitae.com/groups-petition-fda-to-restrict-e...

https://s3.documentcloud.org/documents/27871234/fda-2025-p-7...

With my thanks to Lisa Charlene for bringing this to my attention.