re: Preproposal Statement of Inquiry to amend Chapter 246-490 WAC, Vital Statistics (USA)

The Women’s Liberation Front, Hands Across the Aisle Coalition, Safe Spaces for Women, and the Just Want Privacy Campaign, along with a list of individual signatories, submitted a letter in response to the Washington State Department of Health’s proposal to “creat[e] a new rule regarding changes to sex designation on birth certificates.”  The state’s website with information regarding the proposal can be found here.

According to the letter, “The Department is proposing to allow people born in Washington to change their vital birth information for any reason or no reason at all, a move that would render the state’s vital statistics inaccurate and unreliable, and raise a raft of complicated questions the Department does not appear to have considered. We urge you to scrap this proposed rulemaking as it is unnecessary, outside of the Department’s statutory authority, and harmful to women and girls.”

The letter points out that “a person’s sex is innate and immutable, and it is one of the most important vital statistics about them. In contrast, a person’s subjective ‘identity’ is not mentioned in RCW 43.70.150, nor is it a ‘vital statistic,’ and therefore it has no relevance to the Department’s statutory mandate to ‘insure faithful registration thereof.'”  It further points out that “[t]he text of the draft rule conflates sex and “gender” and has additional problems due to the absence of clear objective definitions for key terms.”  Finally, the letter expresses concern for how this proposed rule change would impact women and girls.  It states, “[w]e are also especially concerned that the draft rule would skew or even make unusable crime statistics that are crucial in the fight to stop violence against women and girls, or would help individual violent men to evade law enforcement efforts at apprehending them. These concerns are well-supported by the facts.”

The full letter can be found here and as a PDF here.

 

 

 

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