Transgender people and the FDA’s new blood donation guidelinesBottom Highlights, Trans Progressive Thursday, December 24th, 2015
Commentary: Trans Progressive
Dec. 21, the Food and Drug Administration (FDA) issued final blood donation guidelines. The policy updated blood donor deferral recommendations, which they stated would reflect “the most current scientific evidence and to help ensure continued safety of the blood supply by reducing the risk of human immunodeficiency virus (HIV) transmission by blood and blood products.”
The Health Professionals Advancing LGBT Equality (GLMA) disagreed. “The FDA’s removal of the lifetime ban on blood donation for [men having sex with men (MSM)] is an important first step toward an optimal blood donation deferral policy addressing individual behaviors, including specific at-risk sexual behavior regardless of sexual orientation or gender, that would justify a deferral period based on the science,” President Henry Ng, MD, MPH, and Executive Director Hector Vargas, Esq., wrote in a joint statement. “GLMA supports nothing less than a paradigm shift away from any categorical restriction on MSM donating blood to a blood donation deferral policy based on individual behaviors. While the removal of the lifetime ban is a step in the right direction, GLMA remains concerned about the one-year deferral period for MSM being proposed by the FDA today because it continues to perpetuate stigma among gay and bisexual men.
“GLMA calls on the FDA to commit to a reasonable timeline to develop a blood donation policy that addresses individual behaviors, including specific at-risk sexual behavior regardless of sexual orientation or gender,” Ng and Vargas added.
The FDA’s blood donation guidelines impact transgender people. Under the previous policy, transgender people were considered the sex they were assigned at birth for their entire lives. So, for example, I transitioned to female over a dozen years ago, but for blood donation purposes the FDA recommended I always be considered a male, and guidance that applied to men should always be applied to me.
In a section entitled Nonbinding Recommendations, the new policy guidelines state “In the context of the donor history questionnaire, FDA recommends that male or female gender be taken to be self-identified and self-reported.” A trans man then would be able to go to a blood donation facility and give blood as a male, and a trans woman then would be able to go to a blood donation facility and give blood as a female. FDA policies would then apply based on gender identity, not gender assigned at birth.
But it’s not that clear since it’s listed in Nonbinding Recommendations.
Seeking clarification, I contacted Tara Goodin, the FDA’s media point of contact for the press release, and asked what should happen when a transgender person shows up for the first time to donate blood.
“Regarding your question about how the FDA’s final guidance is applicable to transgender individuals, the FDA’s recommendation to blood establishments is that the gender of a donor should be self-identified and self-reported in the context of the donor history questionnaire,” she replied. “Blood establishments typically revise their existing standard operating procedures regarding donor deferral following issuance of final FDA guidance on donor deferral.”
As a follow-up question I asked what would happen if you were someone like me who’s donated under the previous policy and are listed as male. Would, or should, the blood establishment change my gender marker in their database?
“To answer your question about how the new recommendations impact people who were previously deferred – Under these new recommendations, blood establishments will be able to requalify individuals deferred under old criteria provided that they meet current donor eligibility criteria,” Goodin replied. “Previously deferred donors will continue to be deferred if they meet any of the current criteria for donor deferral.”
I don’t read a direct yes or no in that answer.
When Goodin replied to me, she emphasized that “these are only recommendations by the FDA,” and “we recommend reaching out to your local blood donation center to determine how they will update their procedures based on the FDA’s new recommendations.” In other words, a direct yes or no in Goodin’s answer wouldn’t have mattered anyway.
As a transgender person looking at these fuzzy nonbinding recommendations, I can see a system structured to avoid taking a position on the gender of transgender people. That dodge of responsibility will subject transgender people to face-to-face harassment from blood collection agents who will transphobically misgender those transgender people who just want to give something back to their broader community. How awful.
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