NHMRC Consultation

We submitted a response to the National Health and Medical Research Council/Medical Research Future Fund's Statement on Sex, Gender, Variations of Sex Characteristics, and Sexual Orientation in Health and Medical Research during their public consultation phase.

We are deeply dismayed by the apparent lack of understanding demonstrated by a government department involved in medical and scientific research, as evident in the content of their Statement.


What benefits should the Statement achieve?

Thanks for the opportunity to contribute to the NHMRC public consultation. This is an important initiative which has implications for all Australians.

We are a major advocacy group exclusively for Lesbian, Gay and Bisexual people. One of our major objectives is protecting the sex-based rights of Australian LGB people.

LGB Alliance Australia want to emphasise the importance of sex-based research when doing scientific or medical research. We acknowledge that some people, but certainly only a small proportion of people, believe they have a gender identity or no gender or are "non-binary" or trans and we respect their right to believe whatever they want to believe.

In the 2021 Census, 43,220 respondents or 0.17% of the Australian population identified as non binary.1.

Source: https://www.abs.gov.au/articles/analysis-non-binary-sex-responses

However, non binary was not effectively defined in the 2021 Census "which show the concept of non-binary sex was not consistently understood and was perceived in different ways by different people. Results cannot be used as a measure of gender diversity, non-binary genders or trans populations." 2. Ibid

This brings up serious issues in terms of doing solid scientific or medical research. If something cannot be adequately defined, as shown by the Australian Bureau of Statistics census, how can it be studied?

And indeed if the 0.17% is even a vague approximation of the number of trans and gender diverse people in Australia, what of the 99.83% of Australians who acknowledge that biological sex is still an important indicator?


Do the Vision and Purpose of the Statement align with the benefits you identified in the previous question? If not, how can this alignment be improved?

We do not believe that the classifications of the Australian Bureau of Statistics 2020 Standard is accurate in light of the 2021 census measuring "non binary" people. Why would you use this when it is clearly ambiguous and open to interpretation?

Solid, reliable definitions must be employed particularly in the healthcare and medical fields. Medicine and medical research should be informed by good science and scientific classifications not by a belief system that approximately 99.83% of the population either don't believe in or don't understand.

The concept of sex must be retained in all research and health initiatives.

Every person has a sex, whether they identify with the sex they are born with or not.

There are only two biological sexes; males and females. Males produce or have the potential to produce small gametes (sperm). Females produce or have the potential to produce large gametes (ova).

People with DSDs (also known as Intersex) still have a biological sex of either male or female. There is no third sex in mammals or humans. There is not a mammal on this planet that produces a cross between sperm and eggs which is presumably what a third sex would look like.

Potential issues will arise in research if a third sex, trans or people with a gender identity are put in the sex category in to which they do not belong. Data and research will be inaccurate and results will be skewed. This has potential to be misinforming at best and dangerous in the worst case scenarios.

So a way of including trans and gender diverse people would be to retain their original sex marker in questionnaires:

The sex you were born as [Male] [Female]

And then add under that:

Your Gender Identity: [Trans] [Non Binary] [Gender Diverse] [Other] [Intersex] [None]

This way there will be no skewing of biological data but it also includes the option for gender identity and intersex variations to be included and recorded.


Is the guidance provided in the ‘What better practice looks like’ section (pages 8-12) suitable? If not, what could be added or removed to strengthen the section?

We don't have enough characters to include all that we have found in the 'What better practice looks like' section that can be improved on.

Please email us and we will email you what we have come up with.

A small sample here includes:

In the second paragraph of Pg 5/12, the language is biased by genderist beliefs. The term "cisgender" is used to describe the average male or female who do not ascribe to being defined in this way. The majority people in Australia do not follow genderist activist beliefs that categorises people into "cisgender" or "transgender" categories. The vast majority of Australians do not have a gender identity, they have a sex and a personality.

The Australian Bureau of Statistics uses and defines terms like "cisgender", due to being influenced in consultations with activists to do so, and without consulting the majority of Australians. Why is the NHMRC Consultation using the term "cisgender" to describe the majority of males and females in Australia, when only a small minority of Australians would describe themselves this way? And how is the term "cisgender" , which is activist language, relevant to medical research, health and aged care? Medical research needs to be based on biological sex, not activist language. Only this section fits in the form. See below for full version to email them.


This is the part we could not fit into the form.

Better practice acknowledges there are only two sexes in the human species. We acknowledge that people don't always identify with their biological sex but that this is misleading when it comes to research and good science. Sex based research must be the gold standard particularly when it comes to health and medical research. Anything else will be inaccurate and misleading unless of course the research pertains specifically to non-binary/trans/gender diverse people.

This may not be "inclusive" in the broadest sense of the term, however, in order for research to be accurate for 99.83% of the population, sex based research must be accurate.

We have picked out salient points from the What Better Practice looks like as could be improved as follows:

Pg 4/12 and Pg 5/12 - "promoting effective, sensitive and safe involvement of people with lived experience in all stages of research projects". Whose "lived experience" gets to have a prioritised say in all stages of research projects?

In the second paragraph of Pg 5/12, the language is biased by genderist beliefs. The term "cisgender" is used to describe the average male or female who do not ascribe to being defined in this way. The majority people in Australia do not follow genderist activist beliefs that categorises people into "cisgender" or "transgender" categories. The majority of Australians do not have a gender identity, they have a sex and a personality.

The Australian Bureau of Statistics uses and defines terms like "cisgender", due to being influenced in consultations with activists to do so, and without consulting the majority of Australians. Why is the NHMRC Consultation using the term "cisgender" to describe the majority of males and females in Australia, when only a small minority of Australians would describe themselves this way? And how is the term "cisgender" relevant to medical research, health and aged care? The terms Cisgender is not recognised either legally and in legislation or scientifically.

Terms like "pregnant people and women" are biased genderist language, as only the female sex can potentially become pregnant. To be inclusive the term "pregnant women" includes everyone with matured female reproductive sex potential, as it is physical biological female bodies that become pregnant, and not people's identities.

Pg 5/12 - "Individuals and population groups with lived experience are meaningfully and effectively involved in prioritisation, design and conduct of research that impacts them or has the potential to impact them". "Lived experience" is important in many aspects of research, but not when sex is conflated with gender identity.

For example, if transmen and activist supporters are given a prioritised say in language used for research or health for females (sex), then they might regard health advertising for PAP smears for "people with a cervix", to be more inclusive. However, for clarity in language this should refer to females or women, as 40% of women don't know what a cervix is. Also, women who speak English as a second language may not realise that PAP smears are for females, because the words female or women were not mentioned. By using the term "people with a cervix" you are denying/erasing 99% of women the benefit of accurate language and sex based definitions.

Using "people with a cervix" may help transmen to feel included, but the lack of clarity in this language is dangerous to the health and well-being of the majority of Australian females.

What would be more appropriate would be the term "females with a cervix" This includes women and also transgender and nonbinary people who are female, and is accurate terminology. Transgender men know they are biologically female. That is not offensive and it is inclusive of all people born female.

Similarly, if transwomen and activist supporters are given a prioritised say in language that they regard as inclusive for them, then the term "people with a prostate" may help transwomen to feel more included. However, when this term is used in health advertising to try to get men to get their prostates checked for cancer, it is dangerous because if the advertising doesn't mention "males" or "men" then men may not know to seek health checks for this. Inclusive and biologically correct language for this would be "Males with prostates".

Transmen are females, and therefore they and their activists supporters should have no prioritised say in language used for research or healthcare for the majority male (sex) population. And, transwomen are male (sex), and therefore they and their activist supporters should have no prioritised say in language used for research or healthcare for the majority female (sex) population.

Because the lived experience of trans-identifying people and activist supporters is representative of only a small minority of people, and therefore they don't have the lived experience to speak about what is best for inclusivity in research and health that impacts the vast majority of Australians.

Clear language, not activist language, should be prioritised for use in all research and healthcare settings.

Pg 7/12 - SEX

No one can change sex. They can only change their legal sex on birth certificates in some states, because these governments have permitted this. The Australian Bureau of Statistics should replace "reported sex can change" with "legal sex can change", in order to be more accurate in their glossary definitions.

Pg 8/12 - Sexual orientation should include "homosexual".

Data collection and analysis:

There is no third sex category in humans. So, "another term" or a third response in the sex category should not be used. The term "intersex" may be used by some who have DSD's, but some people who do not have DSD's identify as intersex. Those who have DSD's are either male or female.

Non-binary is a gender identity, not a sex. The Australian Bureau of Statistics is conflating sex with gender identity, and has included non-binary gender identity in the sex category of their census, in order to pacify genderist activists who believe that a person's sex is defined by their gendered expressions, and not by their biological birth sex. For clarity in research, data collection and analysis, non-binary should be in the gender identity category. Use solid scientific and biological definitions not ABS definitions which have already proven to be inaccurate.

What do researchers, research organisations, consumers, etc need to implement the Statement?

Evidence based research and medical care must be based on best practice and good science and not on gender ideology and political correctness.

Is there anything you would like to raise that is not otherwise captured by these questions?

The following may also be useful for you.

LGBTIQ+ is not an homogenous group. LGB pertains to the sex-based rights of lesbians, gay men and bisexual people, people who are same-sex attracted. We are same-sex attracted not same gender attracted. So sex based research is relevant and important for the LGB.

TQ+ as it pertains to trans and "queer" is a belief in a gendered soul rather than biological reality. The plus+ in the acronym has never been defined so could also include pedophiles, zoophiles, necrophiliacs and all manner of sexual perversions that the LGB have nothing in common with.

Imposing gendered belief on the majority of the population, including the LGB is unwise in terms of accuracy of research and data.

It must also be noted that mainstream LGBTIQ+ organisations are pushing gender identity ideology at the expense of sex-based rights and the LGB. For example, funding and research for lesbians is diabolically low compared to funding and research for TQ+. Healthcare research for lesbians is also diabolically low. Lesbians get lumped into the LGBTIQ+ umbrella but it must be noted that lesbians are a distinct and vulnerable cohort with unique needs and challenges and with very little in common with the TQ. This is also happening for gay men and bisexual people, although there has been more research and funding for them because of the AIDS epidemic in the 1980s and 1990s.

The key take away from this is be careful when lumping distinct cohorts under the one umbrella. We are not an homogenous group and we all have unique and differing needs.

We are happy to consult with you if you need any further information.

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