Psychopractice Regulation: SCoPEd – Generating Psychotherapathy?

by Denis Postle

Sometimes there are projects that in their obtuseness, their folly, and their slippery language, do harm to the human condition. The Scope of Practice and Education framework (SCoPEd)¹, the creation of three of the dominant UK psychopractioner organisations, is one of them.

SCoPEd shines a bright light on the activities and supposed validity of the British Psychoanalytic Council (BPC), the United Kingdom Council for Psychotherapy (UKCP) and the British Association for Counselling and Psychotherapy (BACP), and claims to have synthesized a catalogue of standards for the practice of counselling, psychotherapy and psychoanalysis. But spotlighting casts a shadow and SCoPEd, with its recent formal adoption, is no exception – it excludes and demeans countless other viable forms of working with the human condition in the UK.

After two books ^2,3 and many articles on therapy regulation ^{4, 5, 6, 7} and 28 years as a continuing participant in the Independent Practitioners Network (IPN) ⁸ – an antidote to earlier attempts to regulate UK psychopractice – and publishing the eipnosis website ⁹, I had given up speaking from the regulationist shadow. Except, if direct government control or legalised titles were to emerge. SCoPEd isn’t that, but it points in that direction.

And this is why SCoPEd is a problem. No, worse than a problem, offensive. Younger practitioners may not be aware that SCoPEd is only the latest in close to a quarter of a century of attempts to professionalize their delivery of working with the human condition in the UK, with the barely hidden aspiration of seeking state endorsement of this status.

It was offensive, two decades ago, to sit opposite Anne Casement, the then chair of the UKCP, in a BBC Radio 4 studio,¹⁰ declaiming that:

“At the moment, we’re a voluntary register but we are now in the process of moving to registration by law, to statutory registration, we’re actually in the process of doing that… We’re seeking to protect the title of ‘psychotherapist’, so after that, once we’ve registered by law, anyone who calls themselves a ‘psychotherapist’ will have us to deal with”. (Casement 1999)

Other senior therapy practitioners claimed that there was a need ‘to rid the psychotherapy garden of its weeds’ ¹¹. At a Parliamentary hearing about Health Professions Council regulation, I heard someone behind me describe non-compliants such as myself as ‘charlatans’.

Numerous authors and activists pursued opposition to the ambitions of professionalized counselling and psychotherapy. ^12,13,14 See also my 2007 book Regulating the Psychological Therapies: From Taxonomy to Taxidermy (mapped, measured, captured and stuffed?)² , the title of which continues to encapsulate 16 years of the antecedents (and likely result) of SCoPEd.

If you are as yet unfamiliar with SCoPEd, three previously warring factions ¹⁵ in the UK psychological demographic – BACP, UKCP, and BCP – got together to enable them to become a closed shop in the provision of psychotherapeutic services in the UK. SCoPEd developed three areas of ‘expertise’ and ‘competence’, to represent the claimed capacities of – respectively – counsellors, psychotherapists and psychoanalysts.

In the latest iteration, the three columns have been neatly scrambled to blur this exclusivity, an arrangement that also softens the ascension of BPC psychoanalysis to the heights of psychopractice insight and expertise, leaving BACP members to occupy the prairies of mere counselling.

So what is wrong, mistaken, or harmful about SCoPEd?

Let’s start with it as a taxonomy – describing and circumscribing instances of life and organising them into hierarchical categories.

The SCoPEd taxonomists looked at the practice of the three distinct, and to some extent, antithetical professional organisations, and came up with a hierarchical array of ‘standards’ and ‘competences’. This does two kinds of harm: it does violence to the need for sufficient varieties of caring response to the miasmic diversity of the human condition; and its exclusivity invalidates the many other ways of working with people, as though Co-counselling, Reiki, Sacral cranial, The Alexander Technique, hypnotherapy, Lacanian analysis, massage, breathwork, birthwork, yoga, meditation, dance therapy, EMDR, animal-assisted therapy, horticultural counselling, aroma therapy, sand tray therapy, mindfulness, acupuncture, reflexology, didn’t exist.

SCoPEd diligently explored the professional walled gardens of BACP, UKCP and BPC, and sought and claim to have discovered a legitimate catalogue of psychopractice ‘standardisation’. Apart from making public and underlining the value of the three psycho-professional institutions, what is this for? Isn’t it primarily trying to make them ‘plug and play’ compatible with the NHS and other institutions that hire psychopractitioners? Not least an increasingly privatized NHS. And let’s not forget the 19+ UK universities and the many higher education institutions that run psychopractice courses; for them and the core group of therapy and counselling trainings, SCoPEd’s standardization of psychopractice is happily resonant with the examination/audit culture that infects too much of education.

In The Administration of Fear ¹⁶ Paul Virilio speaks of his WW2 childhood experience in Nantes of living under German rule. There were three ways of coping with it, he says: Occupation, being compliant, making the best of it; Cooperation, actively supporting the occupation; and Resistance, acting to derail or stop it.

I see the gilded credentials of the 75,000 practitioners that support the SCoPEd enterprise as a form of ‘occupation’ of the UK psychopractice demographic. It demeans and excludes. And there seems little doubt this patronizing of the ‘inferior’ is what is intended. While there has been significant disquiet about the ‘occupation’, there does seem to have been too much ‘making the best of it’ and not enough ‘resistance’.

Is it tolerable that the nuances of love, of flourishing, of rapport and presence seem absent from the standards? Will they also be absent from future generations of work with clients?

Is this too strong? I think not. SCoPEd is coercive and prescriptive, the best that could be distilled from warring tribes, built via conversations that we might suspect were conducted in Russian ‘vranjo’ mode: “We know that SCoPEd is ethically dubious”; “you know that we know”; “we know that you know but we all keep pretending it is OK”. But is it tolerable that the nuances of love, of flourishing, of rapport and presence seem absent from the standards? Will they also be absent from future generations of practitioner work with clients?

Some psychopractice organisations have voiced opposition to SCoPEd ^17,18 but there doesn’t appear to have been a coalition of the excluded. SCoPEd partners commissioned an Impact Assessment, ¹⁹ it acknowledged that there was scepticism of the value of the framework but insufficient to derail adoption by the three principal partners, or to deter the National Counselling Society, Human Givens, and the Association of Christian Counsellors joining it for the ride.

The fundamental flaw of SCoPEd, as a protocol promoting a service industry, is that it does nothing to mitigate or even address, practitioner abuse of clients. It leaves clients as the default quality controller; defective practice is identified when someone complains. It doesn’t include what clients need to feel safe – active practitioner engagement with civic accountability. Do other practitioners who know us well personally, stand by our practice? Would they send us clients? And not least, is there ongoing peer assessment of our ‘presence’ and our reputation, that comes with sustained contact?

Sadly, once qualified, a SCoPEd practitioner can keep up a subscription to their regulation club, occasionally dip into CPD, and discuss clients with a supervisor but otherwise avoid reciprocal exposure of their vulnerability with peers. So far as we avoid sharing with peers where we are in our lives, changes in the quality of our ‘presence’ and ‘rapport’ that would merit support, and perhaps challenge, are likely to remain out of sight. These are qualities that appear to contribute more to beneficial outcomes than MA’s, degrees or diplomas ²⁰. The high price of the ‘qualifications’ that entry to SCoPEd requires may justify a paywall for access to psychopractice but for clients looking for a practitioner who can be trusted with their concerns, or their distress, they can often be an inadequate long-term quality guide to practitioners.

The SCoPEd collection of psychopractitioners are people who we might suppose are aware of the social implications of how power and privilege is distributed, of how it can become fossilized, and who are supposedly sensitive to the infinite varieties of grief, fear and anger we may feel. And while mortgages, as a colleague reminds me, may have a significant influence in these matters, how can they submit to their occupation by the SCoPEd catalogue of ‘standards’?

Beyond its politeness, there is something gross about SCoPEd.

Off the page but successfully expressed in the SCoPEd protocol, is the long-standing determination of psychoanalysis to dominate the psychopractice field; how can this illustration of competencies below not be seen as showing ‘C’ (psychoanalysis) as being on top?

And aren’t dominion and its counterpart, subordination, very common client agendas? So how come the flag of psychoanalytic dominion that SCoPEd waves over the enormous UK psychopractice demographic, is acceptable and even cherished by its exponents? Related to this psychoanalytic dominance, is the extent to which SCoPEd, in its apparent drive to open access for psychopractice to the NHS, mirrors/mimics the pyramidal medical establishment, of which psychiatry, a key product distribution arm of Big Pharma, is the dominant, scandalous ²¹ partner.

Off the page even further, alongside all these reasons for rejecting SCoPEd, there is a perhaps an even more fundamental reason for scepticism. Chasing the wraiths of regulation, and reflection on my own practice, led me to see that, along with other aspects of our threatened civilisation, psychopractice has the form of an extractive industry.²² People meet with psychopractitioners to have their distress or concerns attended to, and across generations of these encounters, from what we have learned with clients, practitioners have extracted a theory and practice base. Clients and trainee practitioners buy this accumulated knowledge and practice as a service but it could and perhaps should be more freely shared. So, in as much as the SCoPEd iteration of this knowledge base becomes a commodity, designed as it appears, for privileged access to the NHS, it may need to be seen as a form of psychotherapathy, potentially delivering an impoverished version of psychopractice.

Taxonomy as a basis for regulation can seem to be a societal disease, the grasping and compressing of the ineffables of desire and anxiety and disappointment into categories and hierarchies. My recent engagement with the climate crisis revealed that there was a hidden dynamic in all this. I had hinted at it a long time ago as ‘glaciation’²² but it merits a bigger role. I came to see that civilizations and their institutions such as psychopractice can be helpfully seen as an accumulation of ‘crystallization’ ²³: feeling and perception crystallize as speech; words crystalize as writing, writing crystalizes as books; risk crystallizes as insurance; client behaviour crystallizes as diagnosis; SCoPEd crystallizes psychopractice as ‘standards’.

Today, with crystallisation proceeding at the speed of light via digitisation, taxonomy may be reaching its ultimate limit, with SCoPEd as an example of its paralysing grasp. At our crisis-ridden time, if we want to sustain a fruitful approach to working with the human condition, might not inventing/building/creating ways of contradicting this crystallization be more relevant than reinforcing it as SCoPEd does?

What would that alternative look like?

A very long way off the page of SCoPEd, is self-directed learning. There used to be a university, East London, that ran self-directed education. I taught there, my son did a very good degree by self-directed learning there; it seemed very successful but it disappeared.

I learned my core psychopractice capacity from the self-directed culture of co-counselling ²⁴, and from cooperative experiential work with John Heron ²⁵ and Anne Dickson ²⁶. Building on 25 years as a film director, I learned to facilitate groups as an apprentice, and with Mary Corr and a dozen others generated thriving ‘cooperative enquiries’ ^27,28. Around 2000 hours of this self-directed learning, plus self and peer assessment, became enough to begin to work as an independent psychopractitioner, and 28 years of participation in IPN has supported decades of my practice and civic accountability.

I would like to be mistaken but my guess is that this route to psychopractice – where personal development and self-direction sometimes mutate into a vocation as a psychopractitioner – is now closed. SCoPEd lays the foundations for a day job.

From a long-term client perspective, SCoPEd is bad news. Take it down.

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Notes/references

1 The Scope of Practice and Education framework (2022) https://www.bacp.co.uk/about-us/advancing-the-profession/scoped/

2 Postle, D. (2007) Regulating the Psychological Therapies – From Taxonomy to Taxidermy, Ross-on Wye: PCCS Books

3 Postle, D. (2012) Therapy Futures: Obstacles and Opportunities (Introducing the PsyCommons), London: Wentworth Learning Resources (available from Lulu.com)4 Postle, D. (2000) Statutory Regulation: Shrink-Wrapping Psychotherapy British Journal of Psychotherapy https://www.academia.edu/26110963/Statutory_Regulation_Shrink_Wrapping_Psychotherapy

5 Postle, D. (1998) The Alchemist’s Nightmare: Gold into Lead – The Annexation of Psychotherapy in the UK International Journal of Psychotherapy 3: 53-83.

6 Postle, D. (1997) How does your garden grow? Counselling News, June: 29-30.

7 Postle, D. (2005) Psychopractice Accountability: A practitioner ‘full-disclosure list’ in Bates, Y. and House, R (eds) Ethically Challenged Professions: Enabling Innovation and Diversity in Psychtherapy and Counselling 172-8, Ross-on-Wye: PCCS Books

8 Independent Practitioners Network, https://ipnetwork.org.uk/

9 Postle, D. (2008) eipnosis: A Journal for the Independent Practitioners Network: Contents http://ipnosis.postle.net/pages/IpnosisContents.htm

10 Casement, A. (1999) Straw poll talkback. BBC Radio 4, 4 September.

11 Postle, D. (1997) How does your garden grow? Counselling News, June: 29-30.

12 Mowbray, R. (1995) The Case Against Psychotherapy Regulation: A Conservation Issue for the Human Potential Movement, London: Transmarginal Press

13 House, R and Totton, N. (eds) (2011) Implausible Professions: Arguments for Pluralism and Autonomy in Psychotherapy and Counselling. 2^nd Edn, Ross-on-Wye: PCCS Books

14 Postle, D. (2021) Calling All (UK) Therapists Video London: WLR

15 The Final HPC Professional Liaison Group Meeting (2011) pp 289-294. In Postle, D. (2012) Therapy Futures: Obstacles and Opportunities (Introducing the PsyCommons), London: Wentworth Learning Resources (available from Lulu.com)

16 Virilio, P. (2012) The Administration of Fear semiotext(e): Cambridge Mass. MIT Press

17 Partners for Counselling and Psychotherapy (2023): response to January 22 iteration of the ScoEd framework https://www.partnersforcounsellingandpsychotherapy.co.uk/pcp-response-to-january-2022-iteration-of-the-scoped-framework/

18 The Person Centred Association (2023) Welcome and ScopEd updates and info-where next? https://www.the-pca.org.uk/blog/welcomeandscoped.html

19 ScopEd Impact Assessment (2022) https://www.bpc.org.uk/download/8155/Final-Report-on-the-Impact-Assessment-of-the-SCoPEd-Framework-December-2022.pdf

20 Wampold, B., E. (2001) The Great Psychotherapy Debate, Ch. 8: 2020, London: Lawrence Erlbaum Associates

21 A judge sentences unqualified psychiatrist Zholia Alemi to 7 years in jail but for 22 years the psychiatrists she worked alongside apparently failed to notice that she was as effective, or ineffective, as they were. https://www.theguardian.com/uk-news/2023/feb/28/judge-jails-fake-nhs-psychiatrist-and-criticises-abject-failure-of-scrutiny

22. Postle D. (2014) The PsyCommons: Professional wisdom and the Abuse of Power p16-17 Asylum Spring

22 Postle, D. (1994) The Glacier Reaches Edge of Town. Self and Society 23(6): 7-11.

23 Postle, D. (2021) The End of Progress Self & Society Vol 49 No1 Spring, Podcast version: https://soundcloud.com/denis-postle/the-end-of-progress

24 Co-counselling International (UK) http://www.co-counselling.org.uk/

25 Heron, J. (1996) Cooperative Inquiry: Research into the Human Condition, London: Sage

26 Dickson, A. (1985) The Mirror Within: A New Look at Sexuality London: Quartet

27Postle, D. The Nuclear State (1982) Video Crucible: Science and Society, ATV https://vimeo.com/576904068

28 Spencer A. Postle, D. (1998) From Survival and Recovery to Flourishing: a residential co-operative inquiry, London:  Counselling News

SCoPEd: Butchering Psychopractice

Denis Postle (ARCA; Independent Practitioners Network) interrogates the power relations of the SCoPEd project.

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SCoPEd seems to be yet another instance of ethical sleep on the part of its authors, BPC, UKCP and BACP, institutions that aspire to the high ground of human sensibility and civic accountability. One of the long-standing deficiencies of the psy trainings that they validate, and thus the crust of institutions that represent them, notably for 1:1 work, is the lack of explicit attention to the ubiquity of power-relations. If this were not so, how else can the current SCoPEd initiative – and its likely tame acceptance by the psy demographic it refers to – be understood?

The shenanigans of UK therapy training schools’ efforts to secure their economic status via state regulation, has a long history. Isn’t SCoPEd, a remarkable pro-active coming together of entities previously laden with toxic animosity, yet another precursor for state regulation? Or as time may tell, a defensive response to whispers from government that it is minded to take the psy world in-house?

Let’s back off from this to a reprise of what, to a long-term watcher of power relations in the psy demographic, appears to be a continuing ethical contradiction. This can be outlined as follows: the overwhelming source of complaints from clients (leaving aside mistakes) is the result of practitioner behaviour that drifts from facilitation to coercion, manipulation, exploitation or bullying, i.e. dominance behaviours. But if we look at the organisations whose work has given us the SCoPEd taxonomy, they are top-down structures in which dominance behaviour has for decades been intrinsic to their ethos and operation.

People who have trained since say, 2010, may not be aware of this but it was blatantly evident in the previous decades in conflicts over market share, modal validity/invalidity, and here it is again in SCoPEd. Yet another definition of what psychopractice is, yet another taxonomy, with no sense – as I pointed out in 2007 – that such taxonomies are forms of violence and lead to taxidermy of the organism they engage with. What were then relatively open, rich multitude of modes of therapeutic relations are now in SCoPEd reduced to three levels of competency, free of any sense of the coercive forcing of the ecologies of psy practice that this entails.

“overwhelmingly likely to distort or corrupt the wildernesses of nuance in client practitioner relations”

As too often with such intentionally seductive interventions by power-brokers, the context is hidden. Why might this be so? What benefits are intended to accrue for clients and practitioners from SCoPEd? The context that is obscured seems potentially to come in two parts: preparations as I have mentioned, to embrace/field state regulation of the psy demographic; and secondly to provide succour for training schools that not only have the UKCP, BPC, BACP etc. on their backs but also the commodification of their courses via universities selling authority/validation/status. Universities that increasingly are being run as businesses, with ‘products’ and ‘services’.

In this relegation of context to invisibility, the SCoPEd initiative is also a notable example of what I have come to understand as a ‘trance-induction’. Trance induction captures attention via cogent images, sounds, phrases and naming which make the background context go missing. Current examples include ‘take back control’, ‘project fear’, ‘Make America Great Again’. Trance inductions are ubiquitous and through their temporary exclusion of the street, the venue, or the rest of the audience, in cinema, theatre, sport and literature, they can be beneficially entrancing. However when ‘trance inductions’ such as SCoPEd become embedded in our psy culture as agents of dominance, or claims of entitlement, they seem overwhelmingly likely to distort or corrupt the wildernesses of nuance in client practitioner relations.

The claim implicit in the SCoPEd initiative is that it is ‘evidence-based’, currently a very potent trance induction that typically excludes the context of how the evidence for their taxonomy was derived, how the choices were made. SCoPEd doesn’t appear to have been generated via research with people, more likely it has emerged from research on people (or even research without people); the point being that the ownership of the research rests with the researchers, which as in SCoPEd, emerges yet again as institutions presenting entrancing power-over assertions of psychopractice entitlement.

That said, the psy ecology has many inter-related strands, embracing cooperation, challenge and support – some form of civic accountability is essential. SCoPEd demonstrates only too clearly that if its layers of competencies are intended to enhance client safety – i.e. freedom from coercion, exploitation and abuse (why else would the initiative be undertaken) – the way they celebrate top-down power relations in both form and intention means they unawarely subscribe to its opposite, an ethos of entitlement, that is likely to result in client harm. This may support the economic dynamics of training institutions and their validity networking, but it is hard to see how it would be other than harmful to clients.

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Regulation, professionalism and cultures of dominance

The government has published a consultation document, Promoting Professionalism, Reforming Regulation. Although the paper does not mention counselling and psychotherapy directly, it does ask questions of, and propose changes to, the current system under which registers of counsellors and psychotherapists are accredited by the Professional Standards Authority (PSA).

In 2011, the Alliance cautiously welcomed the PSA system as an alternative to an earlier proposal to regulate counsellors and psychotherapists under the Health & Care Professions Council (HCPC), a plan we – and thousands of other practitioners – strongly opposed.

As we start to make sense of the current discussions, in which some in our field are already pushing again for state regulation while seeking to further align therapeutic practice with healthcare, we share as food for thought one submission to the consultation from long-term regulation-watcher and Alliance participant, Denis Postle.

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Promoting Professionalism, Reforming Regulation: Consultation Submission from Denis Postle, ARCA

January 20, 2018

“How could the dominance cultures of the professional psychological organisations, however well intentioned, make reliable, just adjudications of the dominance misbehaviour of alleged errant members?”

I have been a practitioner of group facilitation, personal development training and therapy in the Humanistic Psychology and Human Potential traditions since 1985. In 1995 I was a founder participant of the Independent Practitioners Network (IPN) and for me this continues to be a dynamic way of sustaining practitioner civic accountability. This is not an Independent Practitioners Network response.

Over the last 20 years I have taken a detailed and sustained interest in the ongoing processes of regulation of the psychological therapies, publishing a considerable  amount of material on the internet via eipnosis: a journal for the Independent Practitioners Network  and two books, plus participation in several others.

As I will outline below, the more I saw of mainstream counselling and psychotherapy institutions in this time, the less I was inclined to be associated with them; this perspective is thus of an outlier. IPN emerged as a response to what was perceived as inadequate forms of civic accountability in the psychological therapies.

2.2  ………As the HCPC has traditionally been the regulatory body to assume regulatory oversight of new groups, it could be seen to have a vested interest in expanding its registrant base. We therefore believe that the PSA, working with relevant stakeholders, would be better placed to provide advice on the regulation of professions

During the abortive process of taking counselling and psychotherapy into regulation by the HCPC, then just HPC, I had extensive contact with its chief executive, Marc Seale, and attended and reported on a substantial number of events and meetings there. I became convinced that, then or now, for the HCPC to regulate psychotherapy and counselling would be as inappropriate as putting the Royal Ballet under the control of the Sandhurst military academy. The HCPC knew how to ‘grasp’ but had no capacity for ‘holding’ the nuances of the practice of counselling and psychotherapy. Happily the HCPC’s coercive, prescriptive approach to this task failed and should not be revived.

I attended many of the early foundation meetings of the PSA and its cultural grasp of regulatory tasks was notable for its more participative, cooperative stance.  I regard it as a least worst option.

Promoting professionalism, reforming regulation

The text of the departmental statement under this headline, as so often, appears to make a presumption that psychotherapy and counselling are some subsidiary of medicine, i.e. they consist of ‘assessment’, followed by ‘diagnosis’ and ‘treatment’ of ‘patients’. This hegemony of the medical paradigm and the assumption that how medicine is regulated can transfer to the psychological professions continues to defy constant challenge from critical practitioners. It is perhaps a key vehicle through which harm to people in need continues to be enacted.

There may be a small place in the diverse cornucopia of the psychological therapies for biomedical treatment using zero responsibility elixirs but the overwhelming basis of psychological work is relationship. This means that there is an intrinsic element of risk, and insofar as  regulation has sought to make this disappear, it has tended to make professional practice defensive. How can this be in the public interest?

Risk can and should be minimised, to do this successfully would seem to  mean there was comprehensive evidence of the actual amount of harm that was prevalent in the psychological therapies. I and colleagues I have consulted are not aware of any such evidence.

Witnessing the regulatory shenanigans over the last 20 years in the UK convinced me that ‘Professionalism’ in the psychological therapies is comprehensively compromised in ways that this consultation seems unaware of.

Some perspectives that may be relevant:

The psychological therapies can be seen as an extractive industry. Practitioners work with clients, they accumulate in professional journals the insights that emerge; there is parallel input to trainings, supervision and professional conferences, where the extracted knowledge is refined  and fed back into practice. This tends to be a self-referential elite activity, the psychological knowledge does not diffuse significantly into society. One result of this elite grasp of work with the human condition amplified by the pathologising of instances of common human distress, has been the generation of stigma. As a result, and especially in the current climate of economic ‘austerity’, access to professional psychological knowledge typically requires a crisis.

For the industrialised psychological therapies, regulation has multiple benefits. It supports the creation of professional walled gardens of therapeutic practice membership of which is restricted in ways that generate unnecessary scarcity. The walled gardens are also professionally and economically in competition with each other and have often seemed more concerned with status and protection of the profession than of enriching and empowering the population at large.

Due perhaps to the medical paradigm that shaped early development but also because of an overly self-referential professional culture, access to these professional walled-gardens tends to be excessively expensive, unduly lengthy and with inappropriately complex academic content. Where is the evidence that, apart from the economic benefits to universities and training institutes, and enhanced professional status, a Masters or a PhD is a requisite education path for sitting alongside people who are struggling with human condition difficulties?

2.9  ……….In addition, the Law Commissions recommended that regulatory bodies be given powers to operate a form of negative register through the use of prohibition orders for those groups not subject to statutory regulation. Such a scheme allows individuals to be barred from practising a specified profession or from carrying out specific activities and would set the standards required of a certain occupation. Where these standards were not met in a way that places the public at risk of harm, the relevant regulatory body would issue a prohibition order that would prevent or restrict an individual from carrying out a certain role or providing certain services.

This is perhaps the most important issue of the consultation.

I see no problem with a person convicted by a court of abuse or fraud being included on a public register of such offenders. The key to this is ‘convicted by a court’.

Inclusion on such a list of people found guilty of abuse by the professional bodies that are presently under the wing of the PSA would be unacceptable.

Three reasons for this:

1. In my experience of the behaviour of some people in the psychological professions, there will likely be a witchhunt of practitioners like myself who are on, or just outside, the margins of the regulation regime. Or for instance, who belong as I do, to civic accountability bodies that are too small for the PSA’s attention.

2. My study of the UK psychological professional bodies, including the HCPC, constantly demonstrated a profound paradox. The bodies claim to be protecting the public from abuse. But what is the origin of abuse? It is the enactment of some form of physical, emotional or cognitive dominance behaviour, i.e. some form of coercion, bullying or sexual abuse, due, leaving aside mistakes, to an unworked thread of belief or behaviour in the practitioner that licences them to enact some form of domination.

Why does this matter? It matters because with no exception that I know of, the professional psychological bodies associated with the PSA are all structured as traditional top down dominance cultures in which executives make decisions on behalf of members.

How could such dominance cultures, however well intentioned, make reliable, just adjudications of the dominance misbehaviour of alleged errant members? Especially if they are licensed to enact extreme dominance behaviour such as legally enforceable negative prohibition orders.

3. A negative prohibition order is way too close to potential abrogation of human rights, i.e. the human right to have a conversation with a consenting Other, paid or unpaid. In the hundreds of modes of approach to working with the wildernesses of the human condition, there will always be people and institutions who find some other approaches to be anathema or alien, and worthy of being dismissed as charlatanism. If they are introduced at all, negative prohibition orders should only apply to convictions by the courts.

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Brief references

Books

Postle, D. (2007) Regulating the Psychological Therapies: From Taxonomy to Taxidermy. Ross-on-Wye: PCCS Books.

Postle, D. (2012) Therapy Futures: Obstacles and Opportunities. Lulu.com

Videos

The PsyCommons – Ordinary Wisdom and Shared Power

Around 75% of the UK population have no need of ‘mental health’ services. What is it they know and do that keeps them psysavvy? The psyCommons examines the ordinary wisdom and shared power hidden from us by the mental illness industries and the medicalization of ordinary human distress.

The psyCommons and its Enclosures: Professionalized Wisdom and the Abuse of Power

The second in a series of videos about the psyCommons looks at how the basic human capacity to resolve and survive the ordinary difficulties of daily life through family, friends and local communities, is undermined by the psychological professions, along with their pharma allies.