One step forward, two steps back: CBS adds trans women to MSM deferral

As part of an ongoing series investigating the research CBS claims to have in support of their new policy, you can follow the progress of my communications with related parties here (list updates with every new related post):

  1. One Step Forward, Two Steps Back
  2. That’s Not The Question I Asked
  3. You’re Like, Halfway There

Canadian Blood Services has announced a new policy that will defer trans women from donating blood if they’re pre-op and sexually active with men:

But many activists are upset with the policy because it focuses on whether or not a trans person has undergone gender confirming surgery.

Goldman says the criteria will create a countrywide, streamlined mandate for all trans blood donors.

According to Canadian Blood Services, there has been an increase in potential trans donors and this prompted the organization to implement criteria for those individuals.

The policy specifically targets trans women and is similar to Canadian Blood Services’ updated guidelines for gay blood donors. On June 20, Health Canada announced that gay men would be allowed to donate blood if they had abstained from sex for at least one year.

Trans women who undergo gender confirming surgery will have to wait one year before they can donate blood. After the wait period, Canadian Blood services will also identify them by their reconfirmed gender. “If a trans woman has not had [gender confirming surgery], that person would be considered as a male having sex with a male,” Goldman said.

Canadian Blood Services says there are regulations specific to trans women because that demographic is at high risk for HIV.

According to the Interagency Coalition on AIDS and Development, an estimated 27.7 per cent of trans women in Canada are living with HIV.

“There is a very high HIV prevalence rate in trans women,” Goldman said. “So we are obliged to treat (them) as a high risk group.”

There seems to be a taken assumption made by Dr. Goldman that post-operative trans women are less likely to contract HIV than pre-operative. Now as a demographic the stats hint that we do experience higher rates of HIV, but the exact extent to which this is a problem is difficult to pin down with existing data for reasons I’ll get to in a minute. And I suspect the elevated rates of HIV in our community have far more to do with socioeconomic discrimination than our genitals. So what does the Interagency Coalition on AIDS and Development even say?

Let’s find out: (emphasis mine, plus I’ve added paragraph breaks to make it more readable)

As noted above, epidemiological studies have not yet captured the full extent of HIV prevalence in trans communities. This said, some trends have started to appear. Prevalence rates tend to be high (27% in the United States, 3‐31% in Asia and 25% in Latin America)12.

Still, these numbers hide a few omissions. Firstly, we have almost no data on prevalence rates within trans men communities.13 Furthermore, most of the data collected has been of trans sex workers. It is important that such data be made available as often trans women from North America, Latin America and Asia are involved in the sex industry and they do have higher rates of HIV than the general trans population.

It does mean, however, that less is known about HIV rates among trans people that are not sex workers.

A last point to mention is that there is some data that suggests that HIV prevalence is higher in some racialized trans populations than in others,14 an example of how the impact of different kinds of discrimination can greatly increase vulnerability and risk of HIV infection.

Importantly, the way epidemiological data is collected often renders trans people invisible. For example, new HIV cases involving trans women are sometimes coded as ‘male’. Beyond the fact that this coding is extremely disrespectful of trans women’s personhood, it makes it difficult to find the data needed to ascertain levels of HIV in these communities. One might also note that because epidemiological surveillance is organized around the categories of ‘male’ and ‘female,’ that transgender persons that identify as both male and female or that identify as neither male nor female are made invisible.

We’re off to a rough start. The Interagency Coalition on AIDS and Development says, “don’t code trans women as male.” What does CBS do?

“If a trans woman has not had [gender confirming surgery], that person would be considered as a male having sex with a male,” Goldman said.

Code us as male. Subsuming us into cis male and female populations is the exact incorrect way to measure transgender stats, not to mention the alienation inherent in being viewed that way likely reducing the number of willing participants.

What’s more, our sexual history is only relevant in who our partners are under this CBS policy: If we have sex with other women, CBS gives us a pass. But if we have sex with men, even STI-negative men with whom we are in monogamous relationships, we’re an “escalated risk factor”–but again, this is directly contradicted by the Interagency’s findings.

The rest of the paper addresses the numerous discrimination problems trans people face, especially in Latin America. It discusses the intersection of race and gender variance, and how the lion’s share of violence is towards TWOC. It presents four case studies that demonstrate barriers to equitable healthcare that impact our overall security.

At no point did it compare the rates of HIV between pre-op and post-op trans women. So to answer the original question, “Does the study cited by CBC corroborate CBS’ assumption that post-op women are less likely to be HIV-positive?” the answer is:

No. In fact, no such comparison has ever been made.

The study says its own numbers are questionable and casts doubt on even the 27% statistic. There is a higher rate of HIV among trans women, but that study alone cautions us from accepting its final number as a reasonable representation of just how much higher.

The biggest contributor to the correlation between trans folk and HIV is because there’s a correlation between trans folk and being a marginalized sex worker. The pre/non-op trans woman working an office job with a sexually monogamous relationship with her boyfriend is as much a risk as any other monogamous cis woman working the office with a boyfriend–yet only one of them is deferred. With the constant calls for donations, you’d think they’d focus on the actual risk factors instead of writing off entire demographics for being guilty by association. As a demographic we are a high risk, but that does not mean every individual is subject to the same oppression that leads to those risks. (To say nothing of how this feels like cis people blaming us for the discrimination they enact.)

Here is Canadian Blood Services’ contact page. I have a suggestion: Write to them. Ask for proof. Ask for the study that compares the rate of bloodborne illnesses between pre-op and post-op trans women. We ought to take them to task on whether their policy is corroborated by recent data.

This is the letter I wrote to them:

Dear CBS,

My name is [Siobhan], and I am a transgender woman affected by the policy you’ve recently announced.

I wanted to raise a concern with the proposed policy and how it contradicts the Interagency Coalition on AIDS and Development’s recommendations cited in this CBC article.

In the cited paper, “HIV and Trans Communities” by the Interagency Coalition on AIDS and Development, the authors advise that the very statistics they have devised have been confounded by the practice of coding trans women as “male.” They conclude not only that the cited “27%” is an unreasonable representation of HIV prevalence in trans women as it also includes some men who have sex with men (“MSM”), but that there are a number of causes for the increased rate–all of which are related to socioeconomic status, which is a highly variable element that not any given individual experiences uniformly.

Canadian Blood Services, as represented by Dr. Mindy Goldman, is blatantly disregarding the paper’s recommendation when she states “If a trans woman has not had [gender confirming surgery], that person would be considered as a male having sex with a male.” Yet Dr. Goldman states there is a “very high” prevalence of HIV in trans women–despite the confounding influence on stats by categorizing heterosexual pre-operative trans women as MSMs. It is specious to claim the rate is “very high” when it is bloated with the inclusion of MSMs.

I don’t doubt that the CBS will likely continue with their blanket abstinence requirements for Queer donors (a topic which I will happily write about another day), but if you insist on coding trans women as “male,” you are furthering the inaccuracy of health data affecting trans populations, not to mention propagating tremendous disrespect for trans women. You may find that your policy becomes unnecessary simply because we will not volunteer ourselves to abuse from your agency, even if we are eligible donors under the additional scrutiny.

If nothing else, please reconsider how you code trans women in your system and policy.


Thank you,


If I get anything but a form letter, I’ll keep y’all posted. In the mean time: Happy belated Canada Day, trans ladies.



  1. chigau (違う) says

    I thought that after the last fiasco, “CBS” was succeeding in getting its shit together.
    Why did I think that?

  2. says

    If I were back in Canada, I would be tempted to show up dressed like a “man” and lie. I would donate blood based on the rules and conditions for heterosexual cismen’s behaviour. Then a month or so later, tell what I did, both to CBS and the public (anonymously if necessary).

    If the sex life rules for het-cismen don’t threaten the blood supply, then why would a transwoman abiding by the same rules and lying about her gender identity threaten the supply? It wouldn’t. It would demonstrate that the policy is discriminatory.

  3. samihawkins says

    Ugh. Let’s be honest about the real reason for this policy, the more-trans-than-thou bullshit that’s always plagued our community. This awful belief that post-ops are ‘real’ women while non-ops like me are just men in dresses

  4. Siobhan says

    Ugh. Let’s be honest about the real reason for this policy, the more-trans-than-thou bullshit that’s always plagued our community. This awful belief that post-ops are ‘real’ women while non-ops like me are just men in dresses

    A good point. Dr. Goldman claims to have made the policy with consultation from “the trans community.” Assuming that’s true, they were either paved over by cissexist assumptions or they were in fact the source of cissexist assumptions. Garbage either way.