On Tuesday, September 26, 2023, USA Climbing released its Transgender Athlete Participation policy. The policy centers around testosterone restrictions for transgender females, wherein eligibility is contingent upon the athlete maintaining lower testosterone levels for at least 12 months preceding competition.
The impetus for the new policy, in part, came two years ago when a trans woman made finals at a USA Climbing event. There was serious backlash from parents and other competitors, who argued that the athlete should be ineligible.
The new policy is a stark departure from its predecessor, which allowed transgender athletes to participate in the gender category with which they identified, so long as they provided basic documentation that affirmed their identity—such as a letter from a health care provider or counselor—and acknowledged that to qualify for the National Team and compete internationally, they must adhere to International Federation of Sport Climbing (IFSC) rules.
The change drew harsh criticism from climbers who believe the new policy is discriminatory. In response to this criticism, USA Climbing has paused the policy and is in the process of revising it. A public comment period is open and ongoing through Sunday, January 14. (You can weigh in here.)
The policy had been in the works for two years before approval, undergoing multiple drafts before finalization. “The guiding principle across the process was to try and find this very difficult balance between equity and inclusion and fairness on the field of play,” Marc Norman, the CEO of USA Climbing since 2018, told Climbing.
“In hindsight, parts of the policy went too far,” acknowledges Norman.
Kristen Fiore (she/they) published a letter to USA Climbing’s Board of Directors, writing, “Disappointed is an understatement. Furious would be putting it mildly.” Fiore is one of the few publicly affiliated members of Trans Climbers Belong, a group that formed in response to USA Climbing’s updated policy. Their change.org petition “Oppose USA Climbing’s new restrictions on transgender athletes” currently has over 10,000 signatures.
USA Climbing’s testosterone restrictions do not apply to competitors who are on the non-international track, which includes Youth C (children aged 12 to 13) and D (children 11 and under) athletes, nor do they impact recreational series participants. However, transgender females who wish to compete in international track competitions, a category which includes all qualifying and national level athletes age 14 and older, must maintain their testosterone levels below 5 nmol/L* for 12 months preceding competition (with tests conducted 12 months, six months, and six weeks prior to competition) and throughout the season (with tests conducted every six months). All tests must be conducted via liquid chromatography and mass spectrometry.
*Many studies have investigated normal and healthy testosterone ranges for men and women. Generally, the range for men from 18 to 40 years old is between 7.7 and 29.4 nmol/L, while it is 1.12 to 1.79 nmol/L for healthy menstruating women under 40.
“There’s so many hoops that trans athletes would need to go through that, at the end of the day, there will effectively be zero trans climbers in USA Climbing competitions,” says Vera May (she/they), a coach and staffer for MetroRock in Brooklyn. May is in the process of interviewing other transgender climbers and making a mini documentary about their experiences. “So it’s an effective ban. It’s essentially hopeless at this point if this policy is enacted.”
Norman suggested that USA Climbing’s Board is considering removing the testing requirements from qualifying events, but keeping them in place for National Championships. “So competitors could compete as they identify through divisionals,” he says. “But if they want to compete at the National Championship level, they must then meet the standard.”
Trans Climbers Belong, which did not wish to speak directly with Climbing, hasn’t offered specific details on what a new policy should look like. Still, their website calls out USA Climbing for excluding trans people from the decision-making process. “No trans voices were considered or listened to in the creation of these policies,” states the site. “USA Climbing did not gain the approval of any of their committees. No broad ask of the community of athletes, parents, or coaches were made.”
USA Climbing did, however, task one transgender individual, who was already a member of a USA Climbing committee (their name was not released for privacy reasons), to create the policy alongside a cis-gender individual, a medical representative, and USA Climbing’s DEI committee. All involved were asked to seek out input from the greater community. Although the trans individual was present throughout the entirety of the process—including research, recommendations to the board, and the first and final drafts of the policy—they chose to resign once the policy was approved.
Presently, Trans Climbers Belong is calling for a boycott of all USA Climbing-sanctioned competitions until the policy can be re-written with the inclusion of trans, nonbinary, and intersex voices.
A widely cited problem with USA Climbing’s policy is that it will effectively force trans female athletes as young as 13 years old to begin and continue hormone replacement therapy—a decision some teens may not be ready or willing to make. Even if they are, it may be out of their hands since dozens of states have passed bills restricting gender-affirming care. North Dakota, Idaho, Oklahoma, Alabama, and Florida have made providing this type of care a felony offense.
Transgender athletes also have cause to worry about data privacy. USA Climbing is not HIPAA compliant, meaning there are reasonable questions regarding their ability to keep medical and personal data safe, particularly if they were sued by a state that deems youth gender transition unlawful. Seattle Children’s Hospital, for example, is currently suing the Texas Attorney General’s Office after the office requested the medical data of trans patients from Texas—and it’s unclear whether USA Climbing would have the legal power to withstand such a request. Norman admits that, taking that lawsuit into consideration, USA Climbing is now focused on obtaining the least amount of personal information while also ensuring a fair field of play.
In the now-paused policy, all climbers, regardless of age and track, would be required to apply for a Therapeutic Use Exemption (TUE) if taking banned substances, including testosterone and spironolactone. TUEs are set by the United States Anti-Doping Agency in compliance with the World Anti-Doping Agency International Standard. Questions regarding USA Climbing’s application of TUEs have been raised; in a letter published by Trans Climbers Belong, parents of trans climbers state, “Transgender athletes are required to obtain a TUE at every level of competition, whereas other athletes who might need a TUE for international events are not held to the same standard at every level of competition. This inconsistency within the rules is not only discriminatory but also highlights a lack of fairness and equity in the current policy.”
Norman admits that “the TUE requirement hasn’t always been clear, nor has it been clear where in the qualification process it would apply. The paused policy attempted to clarify that. To be fair, our first attempt at clarifying that went too far, specifically for the youth, and we have apologized for any harm that may have caused.” He says the board will likely continue to revise and clarify the policy surrounding TUEs.
Another critique of the policy is the cost of the required testing. The Endocrine Society’s Clinical Practice Guideline 1 recommends that trans women measure their serum testosterone concentrations every three months to ensure their health and safety. Most insurance companies will cover this testosterone testing. Still, some do not, and though tests are not particularly expensive (they start at $40), the cost of accessing a test (driving, hotels, time investment, etc.) can be far more.
Parents of trans climbers are also demanding that, if their children are to be subjected to testosterone testing, then all competitors should be held to that standard. However, it should be noted that USA Climbing’s 5 nmol/L testosterone limit is high enough that most women with hyperandrogenism would still meet the requirement.
The IFSC’s policy requires that trans women maintain their total testosterone levels below 10 nmol/L for at least 12 months leading up to competition. While it’s unusual for a national federation to set restrictions more rigorous than that of the international body (USA Climbing’s paused policy, remember, holds competitors to a 5 nmol/L standard), Norman expects the IFSC to adopt a more stringent policy soon. To understand why, we have to look back to 2015.
The International Olympic Committee’s (IOC) 2003 transgender athlete policy, which required transgender athletes to undergo genital surgery, stood for 12 years. Then, in 2015, the IOC invited athletes, scientists, and medical and health experts worldwide to convene in Lausanne, Switzerland, to review and re-write the organization’s policy on transgender participation.
The policy that they crafted would ultimately serve as a model for many other international federations, and to understand it best, you may need a brief scientific primer: Liquid chromatography coupled with mass spectrometry (LC-MS) is considered the gold standard for measuring circulating testosterone, which is why anti-doping organizations have long used it. With this method, studies have determined testosterone ranges for men and women with a high degree of confidence. Studies using LC-MS have shown that women generally have less than 2 nmol/L of blood serum testosterone, with those diagnosed with polycystic ovary syndrome (PCOS) exhibiting higher levels ranging from 3.1 to 4.8 nmol/L. Recognizing the variation in testosterone levels, sports federations often set a limit at 5 nmol/L to include women with PCOS or other causes of elevated testosterone.
In 2015, the IOC implemented a policy requiring trans women to maintain testosterone levels below 10 nmol/L for at least 12 months before competition and throughout the season. This policy was based on a 2011 study that utilized immunoassays, a common testing method at the time. However, there are limitations of using immunoassays, such as cross-reactivity with other steroidal substances and reduced accuracy at lower testosterone levels. There has since been a shift towards LC-MS as a more reliable testing method and as one that clarifies the challenges associated with accurately measuring testosterone in women and children.
In spring 2016, it became evident that using a testosterone level of 10 nmol/L was not the appropriate approach. Joanna Harper, a transgender athlete and scholar who was the first to address the International Olympic Committee (IOC), conducted the first peer-reviewed study on transgender athlete performance. She has collaborated with various international sports federations in crafting transgender eligibility policies. Following a meeting with the Olympic Committee in May, a subcommittee established a more suitable standard than 10 nmol/L. Eventually, the subcommittee settled on 5 nmol/L. According to Harper, the use of 10 nmol/L is an unfortunate historical remnant from a time when testosterone measurement methods were different and is now viewed as outdated.
Harper added that 2.5 nmol/L is a fair choice for sports federations as well, but it should be acknowledged that some trans women are on short-acting medication. For those women, they may fail a single test if taken at the wrong time. To accommodate this, Harper suggests requiring a minimum of three measurements before eligibility is revoked.
What came next is important too: In 2021, the IOC set a new policy, which essentially abolished the requirements they had in place in 2015, and instead left decisions to individual sports federations. The new policy placed no restrictions on transgender athletes, stating instead that “athletes should not be deemed to have an unfair or disproportionate competitive advantage due to their sex variations, physical appearance, and/or transgender status.” The policy was applauded for its focus on inclusivity, but many scientists—including Harper—said that its lack of scientific backing was misleading. What’s more, the policy arguably backfired. Without real guidelines in place, many federations, including the IFSC, continued with the policies they’d had in place since 2015, which perpetuated the out-of-date testosterone-based limits.
Given that the IFSC’s current policy dates back to 2015 and considering the organization’s recent emphasis on addressing issues related to REDs (relative energy deficiency syndrome), Norman says he anticipates the federation will modify the testosterone threshold soon. He expects a shift from the existing level of 10 nmol/L to a lower value, potentially 5 nmol/L or even 2.5 nmol/L based on the recognition that the current threshold of 10 nmol/L is considered exceptionally high.
It’s worth noting that, in part because of the open-door nature of the 2021 IOC policy, there are a wide array of restrictions set by Olympic-affiliated federations. In 2020, World Aquatics (and the non-Olympic World Swimming) voted to ban transgender women from competing in the women’s category if they’d gone through male puberty. In spring 2023, World Athletics made the same decision, as did The Union Cycliste Internationale. World Rugby outright banned transgender women, regardless of time of transition or medical intervention. Some federations, including the International Tennis Federation, have opted to tighten testosterone requirements down from 10 nmol/L to 5. Others, including World Triathlon and World Archery, tightened requirements to 2.5 nmol/L. Many Olympic-affiliated federations have no policy in place, which means the policy is up to individual national federations.
There are certainly many drivers of athletic performance, including external factors such as environment and culture, and science has established that men and women have different athletic capacities. In rowing, swimming, and running events, the average gap between males and females is relatively modest—11 to 13 percent. In jumping events, that gap increases to 18 percent. In sports that necessitate significant upper body strength, the gap is above 20 percent. The greater gap for sports dependent on upper body strength can be explained by the fact that males have a disproportionately strong upper body compared to their lower body, whereas, for females, the opposite is true.
Climbing performance, as we know, is based on a nexus of strength and skill-based systems. The gap between men and women is modest but noticeable, with men climbing two grades harder than women in both bouldering and sport climbing (V17 as compared to V15, and 5.15d compared to 5.15b).
Testosterone is currently the only established physiological driver of men’s athletic advantage over women, which is why athletic federations are now asking to what degree can hormone therapy close the gap.
After beginning hormone therapy, trans female athletes experience a number of changes, including decreases in cross-sectional muscle mass, higher fat mass, and a decline in hemoglobin. Current research quantifying these physiological changes, particularly as they apply to athletes, is incredibly limited, although some general and preliminary conclusions may be drawn.
Additionally, there’s a psychological element at play. The importance of psychological health is well established when it comes to sports performance, and as Vera May, the climbing coach in Brooklyn, noted: “Even when it feels like it’s really not necessary to gender me in a particular way, I still get misgendered. It’s extremely uncomfortable being a trans woman in the broader climbing community.”
No longitudinal studies have been conducted on trans women engaging in endurance sports. However, Harper’s first study, published in 2015, analyzed run race times from eight transgender female runners across roughly seven years. When adjusted for age, the runners ranked the same place as (but not better than) when they competed as men. Many factors within the study were uncontrolled, but it suggested that when it comes to endurance-based events, hormone therapy may remove previously-held advantages.
While it seems that cardiovascular fitness is quickly lost, this does not seem to be the case for strength. A systematic review led by Harper, analyzing 24 studies on trans women, found that, despite hormone therapy leading to a decrease in strength, lean body mass, and muscle area, these values still remained higher than those seen in cisgender women, even after 36 months.
“I can suggest that it’s probably true that trans women lose strength in a linear fashion for some period of time before it levels off,” explains Harper “Trans men will gain strength for some period of time before that strength gain will level off—and it’s a much larger time frame than the fast changes that occur in an aerobic competition.”
It’s worth considering that as trans women lose strength and gain fat mass, they are not seeing changes in bone density or structure. They are, as Harper points out, effectively powering a larger frame with less muscle. To date, no studies have evaluated strength-to-weight ratios in trans athletes undergoing hormone therapy.
An important distinction of the studies included in the systematic review is that they involved untrained transgender women—not athletes. If athletes were to undergo hormone therapy at the same time as they engage in training programs meant to counteract muscle and strength loss, it’s unknown how much athletic capacity they may be able to retain.
Trans Climbers Belong wants to see the policy completely overhauled, noting that, “Policy resting on a foundation of misinformation cannot be updated.” In her letter, Fiore adds, “The process you’ve chosen in creating and announcing these changes to our sport is wholly incompatible to the community I love. Instead of seizing the opportunity to bring our community together you have destroyed any hope I had that trans climbers will feel included at USA Climbing’s table.”
The public comment period remains open through Jan. 14. As USA Climbing evaluates revisions to the policy, Norman says the board is closely considering questions of data privacy, TUE requirements, and the level of competition at which testosterone requirements ought to be enforced. “We continue to encourage and have dialogue with the community,” he added. “When the board feels the engagement, process, and information gathering has achieved what they need to make a decision, then we will move forward.”
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