A trans woman believes NHS England has imposed a ‘stealth ban’ on trans women donating blood in the UK, as they won’t meet ‘male requirements.’
Jessica Smith (she/her) from Reading, Berkshire, has been on a stable HRT (Hormone Replacement Therapy) regime since 2018. Her hormone levels are in the standard female range, and she has reported no medical issues.
After registering to give blood as a first time donor, she received a phone call to answer questions on her medical and travel history. Jessica mentioned that she was transgender.
At her first appointment, she was tested as a man
A week later she attendended an appointment. Before she was given a haemoglobin test, the nurse explained that they would be testing against male ranges because she was assigned male at birth (AMAB). To perform the test the nurse said she was using the ‘male’ copper sulfate solution, which is a different concentration from the one used for female blood. Jessica failed the drop test they performed and was given a fingerprick blood test (Hemocue).
Jessica measured 124g/L on the Hemocue test and was told it was below the minimum limit for men (135g/L). As a result her donation was deferred for 12 months, and she was advised to speak to her GP about being anaemic. Using the male reference for the sulfate solution test means trans women are likely to be deemed to have haemoglobin levels too low for giving blood.
If the female range had been used for the deferment, the deferment time likely would have been three months, not 12. But Jessica’s ranges were checked against male ranges, which means she now is not allowed to try again for a year. So the NHS potentially loses out on two units of blood.
JPAC advice is to consider hormone status
Jessica later discovered that the UK advisory committee for blood donations, JPAC guidelines state that consideration should be given to hormone therapy in trans people, and to using the correct reference ranges for them.
People with male testosterone levels, (either a replacement hormone or produced in their body), have higher haemoglobin levels as that is one of the effects of testosterone.
When Jessica had learned about JPAC recommendations for trans people, she reported “I contacted my GP who arranged a blood test, and my levels came back the next day as 132 g/L. The female reference range for haemoglobin levels is 115 – 165g/L.” This meant her blood was within a healthy range, as the cut off level for blood donation for women is 125 g/L. Jessica should have been allowed to donate, and the Hemocue test likely was wrong.
An apology but no resolution
Jessica submitted both a complaint and a freedom of information (FOI) request to NHS Blood and Transplant (NHSBT). A week later a nurse got in touch with her. The nurse explained that as a way of ensuring they screen blood from assigned female at birth (AFAB) people for particular antibodies, they switched to recording sex assigned at birth. And this is what they use for reference ranges, estimated blood volumes, and how often they can donate. The nurse apologized, and said it was still a work in progress and not complete; but was for the safety of donors and recipients.
Jessica pointed out to the nurse that most trans women will struggle to meet the limits (being tested in the male range). The nurse continued to apologize, and mentioned NHSBT are working on updating their guidance but had no timescale to offer.
Jennifer worries that the current guidelines are putting people at risk of being rejected and giving up trying to donate blood, as well as worrying about trans men being accepted with female haemoglobin levels.
Jessica believes the position of NHSBT/JPAC is not one of outright transphobia. She says:
I think they’ve tried to cover off one issue (antibodies from AFAB donors) and they inadvertently created this mess. However, they’ve definitely failed to consider the effect it can have on NHS blood stocks, by pushing away people who would be perfectly safe to donate.
Wrong reference levels could put people at risk
Jessica feels a lot less sure of using NHS services as a result of her experience.
I have no confidence in NHS Blood and Transplant for one. They have made decisions that put people at risk. They have nurses giving out inaccurate advice that may cause donors to worry. I’m reluctant to attempt to donate again.
A particular worry would be if a trans man walks in to give blood, who, according to their hormone levels, should not be accepted if the haemoglobin tests under 135g/L, but is accepted at just over 125g/L, because female reference values are applied, even if the donor has high enough blood testosterone levels that their haemoblogin value should be over 135g/L. That would leave the person at risk of anemia after the blood is taken according to NHS’s own rules.
NHS track record is not the best anyway
This is not the first time Jessica has encountered an issue accessing healthcare through the NHS.
I was already disillusioned with the NHS after my previous GP decided they weren’t going to continue prescribing my HRT, again putting me at medical risk from osteoporosis. We are being failed by the NHS, and their insistence on Sex at Birth being used where it isn’t medically relevant is putting us (trans people) at risk of being excluded unnecessarily. So yes, I’m less sure about using NHS services.
When questioned on their policy for treating trans patients, NHSBT responded with:
Trans people can donate, though blood donation can vary around sex/gender for a mix of medical reasons – for example how often people can donate, what their blood volume is, which blood components can be used due to the development of some antibodies in females, and whether specific hormones are being taken at a specific time. All these variations are in place for practical health reasons – to protect the donor and to protect recipients. We follow the guidelines set by JPAC, the independent body which advises the UK’s four blood services.

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