BANT want permission to impersonate genetic counsellors

The British Association for Applied Nutrition and Nutritional Therapy (BANT) have recently expressed concern in their newsletter that moves by the Health Professionals Council (HPC) and Association of Genetic Counsellors and Nurses (AGCN) to support the statutory regulation of Genetic Counsellors may impact on their freedom to practice quackery.

We live in the age of the genome. Jeffrey Bland presented in his yearly seminar event in the UK on the subject of the genetic blueprint. BANT practitioners speak of ‘biochemical individuality’ and it is of this that we speak as being the major factor in how we approach individual help for clients. We are aware that a growing number of practitioners are using genetic testing, either the single gene or combined tests.
•     The first nutrigenetic tests appeared on the market in 2001 and have been used by nutrition counsellors since then.
•     In 2002 BANT representatives gave evidence to the Human Genetics Commission in its Genes Direct inquiry on genetic testing supplied direct to the consumer (defined as outside a medical consultation).
•     In 2008 BANT submitted evidence to the House of Lords inquiry into Genomic Medicine about nutrigenetic practice.

BANT is now aware that the Association of Genetic Counsellors and Nurses (AGCN) have applied for statutory protection of the title ‘Genetic Counsellor’ (GC). We are concerned that BANT members who already work in nutrigenetic counselling may be unable to continue to practise their profession without hindrance if the AGCN succeed in getting statutory regulation. In view of this fact BANT has written to the Health Professions Council to ask several questions relating to this topic. Namely;

•     can the HPC assure us that statutory protection will NOT impact on the use of ‘Nutrigenetic Counsellor’ as a title;
•     should BANT be making an immediate application to HPC to be considered alongside that of GCs;
•     should BANT representatives, as Nutrigenetic Counsellors, give a presentation to HPC at the same time as the AGCN present their case?

As mentioned earlier, BANT practitioners  work with biochemical individuality. Most students are now having modules on genetic testing in their studies and even more practitioners attend seminars on the subject. More practitioners are using these tests and it is right that BANT protects our rights to the use of these tests .  Please continue to check the BANT website for the latest information on this subject.

The ethics of genetic counselling are complex and the AGCN have an admirable code of conduct that takes this into account.  Genetic testing is a form of medical diagnostics looking at mutations in particular genes that can have profound and devastating implications for the patient and their family that may fundamentally change their life, such as Cystic Fibrosis, Sickle Cell Anaemia, and Phenylketonuria.  The role of the Genetic Counsellor is to inform the patient about the test and the implications throughout the process.

Genetic counselling is defined as ‘a communication process which deals with human problems associated with the occurrence, or the risk of occurrence, of a genetic disorder in a family

(American Society of Human Genetics, 1975)

A Genetic Counsellor is a highly skilled individual with either a primary qualification in nursing or midwifery or has completed a Masters degree in Genetic Counselling after obtaining a Bachelors in a relevant subject, in addition to this they must undertake at least 120 hours of specific counselling training as well as more general training for a period of around 2 years.  A nutrigenetic counsellor does not.  A nutrigenetic counsellor must hold a qualification, most likely not accredited, from an instituition approved by BANT and then must pay BANT a membership fee.  After this they may call themselves a nutrigenetic counsellor.
A Genetic Counsellor is expected to have a scientific understanding of genetic illness and testing, a firm commitment to evidence based practice and a commitment to a proper regulated professional relationship with a patient.  A BANT nutrigenetic counsellor undergoes dubious training, lacks effective regulation, belongs to an organisation that altered its code of ethics to allow commision to be recieved by members for products sold to customers and whose former ethics committe head pretended to be on a nursing register when she was not, a criminal offence.

The tests a Genetic Counsellor will advise on are of proven accuracy and are conducted in a carefully controlled environment.  The tests involved in nutrigenetics prompted this statement from the Human Genetics Commission (HGC):

Genetic tests that claim to be able to give nutritional health information, but have not been robustly and independently evaluated, are a concern for the HGC.

The HGC believes that test providers need to be able to provide evidence that the genetic tests they offer can reliably and accurately, predict what they claim to be able to predict. The link between a gene and a condition or trait should be proven for all genetic tests, including nutrigenetic tests, before they are sold to the public and proof of this link should be made available to consumers. The sale of genetic tests without this proven level of clinical validity can give rise to unnecessary anxieties about health or give an individual a false level of reassurance. With nutrigenetic tests in particular, this could lead to an over-consumption or avoidance of certain food groups, which could cause potential harm to the individual and lead to further costs to the NHS.

The HGC advises any individual who is thinking about taking a nutrigenetic tests to obtain the following information first:
• general information on genetic testing and specific information on the nutrigenetic test including the evidence of the link between the gene and the condition/trait and whether this link has been published in a peer-reviewed academic journal
• the measures the test provider will take to ensure the confidentiality of their biological samples and personal records
• how they will be provided with the genetic test results and who they will be able to contact if they don’t understand the results
• information on the limitations of the test so that they are aware of the level of significance that they can attribute to the results of the test
• whether their biological sample will be used for any secondary purposes or if their personal details will be passed on to any third parties

The Commission believes that individuals taking a test should be aware that the interaction between genes and environment factors, such as food, is complex and constantly changing which makes interpretation of nutrigenetic tests very difficult and in some cases impossible without knowing these environmental factors. Consumers should also understand that some nutrigenetic tests are less predictive than the results they might receive for other genetic tests.

These are not issues that BANT appear to have considered.  The following letter is the HPC’s response to BANT’s concerns about their use of the term nutrigenetic counsellor.

Thank you for your recent letter regarding the continued use of the title ‘Nutrigenetic counsellor’ by your members. Marc has passed your letter to me for a response.
As you note in your letter, the Association of Genetic Counsellors and Nurses have applied for statutory regulation and have proposed that the title ‘genetic counsellor’ should become a protected title. The Association is due to present at the HPC Council meeting in December 2009. If the Council decides that the new professions criteria have been met, they can make a recommendation to the Secretary of State for Health. However, any decision about whether that group becomes regulated in the future is one for government.
The 2007 White Paper Trust, Assurance and Safety – The Regulation of Health Professionals in the 21st Century’ identified the priority groups for future statutory regulation including psychologists (regulated by the HPC from 1 July 2009), healthcare scientists, psychotherapists and counsellors, and other psychological therapists. We consider that it is unlikely that Government will proceed to consider whether to regulate further groups until at least 2011/2012 at the very earliest.
You may be aware that we have been undertaking a piece of work looking at the regulation of psychotherapists and counsellors. As part of this we have been considering with stakeholders in the field which titles should be protected and have considered whether it would be possible to protect the title ‘counsellor’ given it is widely used by practitioners undertaking therapeutic work with clients, and readily recognised by members of the public. However we have also acknowledged that the term is sometimes used, often as part of an adjectival title, by individuals practising in fields outside of ‘therapeutic counselling’. Examples include debt counsellors and financial counsellors.

In protecting a professional title the government has to be sure that that title is in wide usage by those it intends to regulate, and that protecting that title would not effectively bring into regulation others that it is not sought to regulate. With respect to protecting the title ‘counsellor’ as described on the previous page, we think that this title might be protected given its wide usage by ‘therapeutic counsellors’ but with provisions in legislation to ensure that this does not prevent its continued use by others outside of the ‘therapeutic counselling’ field. So the intention is that any future protection of the title ‘counsellor1 for the psychotherapists and counsellors part of the Register would not prevent the continued use of titles such as ‘debt counsellor’, ‘genetic counsellor’ and ‘nutrigenetic counsellor’.
With regards any potential future regulation of genetic counsellors and protection of the title ‘genetic counsellor’ it is very unlikely this would impact upon the continued usage of the title ‘nutrigenetic counsellor’ by your members. We apply out protection of title powers pragmatically and only take action where someone uses a protected title or implies their use of a protected title with the intention to deceive members of the public.
You do not need to make an immediate application to us. However, it is certainly very helpful to be aware of the use of this title in any subsequent discussions about regulation and we will highlight this to the HPC Council in their discussion about the genetic counsellors’ application. If government was to decide to regulate genetic counsellors at a future point, the decision to do so would be subject to a full public consultation at which point issues such as these could also be further considered.
Should you require any further information, please let me know.
Yours sincerely,

It is clear that BANT are not concerned with the need for proper regulation of genetic testing and those who advise on these tests but are simply seeking to protect their members business interests.  If they recognised the stark differences between Genetic Counselling and what they term nutrigenetic counselling they should feel obliged to come up with a description that more accurately reflected their members abilities and did not have the potential for confusing the public over the differences between highly qualified and capable Genetic Counsellors and those with dubious qualifications in nutrition.  The abbreviation ‘nutri’ does not translate into ‘unethical pseudoscientific nonsense, exploiting the uninformed and the gullible for personal gain’ in any dictionary I possess.

This is yet another sad illustration of how alternative therapists crave the respectability that comes with conventional medical practices but want nothing to do with the ethics, professionalism or evidence based practice.