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Psychotherapy Professionalisation 
and 
Statutory Regulation

Denis Postle May 1999

This is a compilation of two talks I gave in June 1999 to the Bath Psychotherapy Association and to the British Confederation of Psychotherapists conference on Statutory Regulation

The invitation to give this talk was based on an article of mine published last year in the International 
The Alchemist’s Nighmare: Gold in Lead – the annexation of psychotherapy in the UK Journal of Psychotherapy Vol. 3 No.1 1998 30pp 

It contains the fruits of ten years of researching and enquiring into psychotherapy professionalisation and statutory regulation in the UK.

To give you a sense of where I'm coming from.... here is the second paragraph of the abstract....
'....Is the attempted professionalisation of psychotherapy in the UK a rational, aware process - one that supports the needs of clients? Or is it an incoming tide of collective collusion in which a trade association consisting primarily of training schools and accrediting bodies seeks to colonise and dominate the field of psycho-practice?'

The paragraph sets the scene for this talk 

What I've done is look at the whole article and extract some of the essential ingredients and bake them afresh

There are two sections....
Professionalisation of Psychotherapy
Statutory Regulation of Psychotherapy 

As I was looking through Gold into Lead for a theme for this evening I was surprised by how of it was expressed in terms of imagery. 

So I've organised this first section around various images of professionalisation.... I hope you find them evocative.

Two of the UKCP presidents have favoured horticultural images when talking about professionalisation. I found this very revealing and I gave them a lot of space in the Gold Into Lead article. I'm going to quote them at some length.

In the conclusion of a talk about professionalisation given to a counselling conference, Professor Emmy van Deurzen argued, and I quote, that.... 
'when a garden has been very fertile and has been left to itself for a long period of time it is overgrown. Sprawling plants obscure each other's light and deprive each other of nutrients. It is then necessary to cut the plants back, quite drastically and carefully select the ones that one wishes to encourage and make room for, at the same time as uprooting those plants considered to be weeds'.

She is undoubtedly aware of the dangers in what she's suggesting.... such pruning....

 'If it is done haphazardly and too aggressively the result can be a sparse, unattractive environment in which little growth can be observed for a long time to come'. 

However in these times of rapid growth....

'the pruning of registration and standard setting is a welcome and entirely necessary phenomenon. ...as far as I am concerned: it was high time that we began to disentangle this overgrown field, for it had turned into a jungle, where some weird and wonderful creatures were sometimes doing untold damage'. 

There are two things I want to say about this.... 

....one the presumption of a Gardener or Gardeners who have the right to control the garden. But I want to ask who gardens the Gardeners? Who qualifies the Qualifiers?
Secondly.... here is a professor of psychotherapy and counselling, a former president of the UKCP [link] and still a leading figure in it, in using the word 'jungle' to represent a state of appalling and threatening disorder populated with damaging creatures. How come she hasn't noticed that jungle also means rainforest, far and away the richest ecological structure on this planet? 

Digby Tantam another past Chair of the UKCP when talking about the differences and similarities between psychotherapy schools  also favours horticultural metaphors—again I quote....'I have a metaphor...-the garden...To my mind no garden is quite satisfactory if it is confined to a single variety or even genus and I like a garden that is mixed. However I know that the roses I have in my garden have benefited from the attention of rose fanciers who have concentrated on them and on some cases in them alone...'
'Unfortunately everything in a garden is not lovely. Some plants are poisonous. Other become vectors for pests and viruses. Trees are not ideal for every situation, but neither are ground cover plants. Bulbs will mature and flower in a year, but shrubs take much longer. Some nurseries under-cut by producing poor stock cheaply... and so on'.
'Ensuring genetic diversity for plants presents many practical problems, but relatively few moral ones. This is because-that is, I think that it is because-few people would want to maintain that some species are superior by nature, and others inferior'. 

....I guess this is a side-swipe at the analysts who do indeed argue the instrinsic superiority of the analytic approach.......more on that later....to return to Digby Tantam....

'True there is the important category of weeds, against which we wage unceasing war. But weeds are simply plants in the wrong place'.

However, elsewhere Digby Tantam is on record as hoping that psychotherapy.... 

'....registration will weed out unpromising, ineffective, or downright harmful innovations at a much earlier stage'.(Tantam 1996)

Notice the phrase 'weed out'. But psychotherapy professionalisation  is not some informal evolutionary process, a professional register creates weeds. Indeed for it to make sense, it has to create weeds to justify the high cost of the education of cultivars. 

What do we make of all this horticulture? I see it as indicative of an attitude to power that presumes privileged psychotherapy gardeners of who know the difference between weeds and cultivars. 
Who decides what are weeds? by what criteria?

This is a cultural and political decision, the conscious creation of privilege. I believe that it damages the interests, both of the psychotherapy client population, and of psychotherapists in general. The former are likely to be denied sufficient choice to find a good match for their issues. And the latter, due to becoming locked into a culture where hierarchical bureaucratic control dominates quality assurance, will gradually drift towards a 'play safe', 'low risk', 'defensive' style of practice. 

The notion that.... because I reject the UKCP project as mistaken....I am supposed to be a weed in this psycho-practice universe doesn't sit well with me personally. It seems to reflect a highly unaware view of power, one that presumes the intrinsic right of a handful of Gardeners to determine to dominate the psychotherapy garden. I will come back to in the last section of this evenings talk.

I end the horticulture imagery with one of the earliest contributions to the debate and one with which I broadly agree. In the Case against ....Richard Mowbray quotes his partner.
'Juliana Brown has remarked that as in an organic garden, it is perhaps better to put up with a few 'pests' for the sake of well-being of the whole system rather than resort to 'chemicals and pesticides' with the prospect of developing long-term side effects, not least that of  reducing the 'fertility' of the 'soil'. It is better to put energy into encouraging the health of the garden as a whole. A flourishing garden can cope with pests'. (p214) the Case Against.... 

So let's leave horticulture and return to the title of this evenings talk and touch briefly on Alchemy....

The Alchemist's nightmare: Gold into Lead-the annexation of psychotherapy in the UK --
Alchemy is one of those all purpose images for transformation which is a helpful way of looking at what we do in psychotherapy

Alchemists sought the transformation of base materials lead or tin into something more valuable such as gold or silver and also I understand it alchemy was also a tradition of personal transformation. 

Why I settled on it to reflect the research I'd done for this article is that the image carries my overall view of the state of play in the psycho-practice universe

Professionalisation transforms psychotherapy into what....?
....the gold of an open, organic, creative psychotherapy is turned by professionalisation  into the lead of a bureaucratic, fear-ridden state-regulated 'profession'.... 
....the transformation runs in the reverse direction to that intended-a dis-improvement....an alchemists nightmare....
....I regard professionalisation as 'stealing the flame' [link] a kind of theft of a body of knowledge that belongs to all of us....
....professionalisation is a process of glaciation, [link] the freezing of what was previously vibrant and alive.... 
....I also have a strong sense of loss.....I feel upset that a relatively small number of people could engineer the damage being done to something so precious to me....

Let's move on to the annexation part of the title. Annexation is a strong word but it feels accurate.

....from my perspective of a human potential practitioner.... the field of psycho-practice has tended to look like a prairie.... 

 ....by the late 80's the prairie was well-populated. Not over-crowded  but with lots of practitioners offering clients a wide range of services.... 

....scattered across it were/are assertiveness trainers, career counsellors, group work trainers, co-counselling and re-evaluation counselling teachers, facilitators, massage counsellors, stress management consultants, psychotherapists personal development coaches, psychoanalysts etc etc 
....Innovation was welcomed.... 
....some parts of the prairie flourished for a while and then faded or died or mutated into new forms....

....both clients and practitioners could move around in this prairie taking what they needed....

....there were one or two institutions dating form an earlier period —the Royal colleges and the British psychological Society for instance but then they seemed peripheral....

Viewed from this perspective, the professionalisation of psychotherapy looks like the annexation of a sector of this psycho-practice prairie by a one group of practitioners.... 
....psychotherapists

They fenced off a sector of the prairie and declared ownership of it. 

....so not surprisingly the nomads such as myself who used to range freely across this prairie were not well pleased....

....despite protests, the settlers claimed the territory as their own and moved to strictly control access.... ....the first level of fences are quickly raised and made more secure by the addition of 'registration' to keep outsiders out (and some of us might think, to keep insiders in) 

Before long.... inside this fenced off sector of the psycho-practice prairie registration enthusiasts built an institution. 

....over at the back there (in the image) you see the British Medical Council.... the British Psychological Society.... the Royal College of Psychiatry....

....The organisational style of the new institution....United Kingdom Standing Conference on Psychotherapy [UKSCP] mimicked that of the professional bodies of medicine, they being held as something psychotherapy should aspire to....

There was a point while I was researching Gold into Lead when all the key officials at the UKCP were all doctors. That's since changed but I invite you to consider what that meant in terms of UKSCP's style and organisational preferences.

What was beginning to emerge was a top down bureaucratic form of organisation. Layers of registration and disciplinary boards. 

I appreciate that UKCP.... successor to UKSCP.... is internally federal via the sections but the lines of authority are layered in a hierarchical ways.

'UKCP is a dominator hierarchy seeking to borrow power from another dominator hierarchy (the government) in order to impose its dominance....' (Kalisch 1996)

However.... there was a lot of disagreement between the psychoanalytic trainings (who had been driving the formation of this institution for decades) and the humanistic trainings.

The psychoanalysts tended to see themselves....and I quote from Bob Young [link] Professor of Psychoanalytic Studies...'as the 'the gold standard' the therapists are alloys and baser metals - copper, as I recall one saying.'

This is within the psychoanalytic framework. When the analytic organisations found that they had only one vote each and no veto within the UKSCP they put together another competing institution.... the British Confederation of Psychotherapists [BCP]

Now we have two organisations BCP.... and UKCP

By the end of the 90's there had been a couple of adjustments to these institutions.... 
....separate entrances and fortifications to stop movement between the two.

What conclusions might we draw from this image?  
....it carries the sense that professionalisation institutionalises and sets in concrete what was previously organic and self-regulating.... in the sense that a prairie is self regulating....

....professionalisation is defensive.... this view from outside is one thing.... imagine the view from inside.... There is a wall between you and the rest of the population. 

....As Kalisch has suggested, at the heart of the bureaucratisation that UKCP represents is a desire that the wildness, iconoclasm and potential dangerousness of creative thought and imagination be tamed, anaesthetised and rendered anaemic in order to be safe for human consumption (Kalisch 1990).

Who will pay for this....? Guess who? clients.... 

....where previously psycho-practice traditions might emerge and die-now through this annexation....psychotherapy seems to be making preparations for life after death....

Practitioners like myself whose work comprehensively overlaps with those psychotherapists who have built these institutions look on incredulous and appalled.... but what can we do....? 

1.  confront professionalisation where we can.... 
2.  try to prevent statutory regulation from being achieved.... 
lastly.... because this has all been critique....which tends to install a victim position....
3.   we can make the thing we want to have.

Five years ago Em Edmondson and her partner Nick Totton made a proposal that attracted a lot of support and led to the formation of the Independent Practitioners Network [IPN].... 

it has developed into an alternative way of holding accountability to clients in the field of psycho-practice 
IPN has three components....
....the practitioner group 
....mandatory links between groups 
....gatherings of the network every few months that are open to the whole network

How does the Independent Practitioners Network function?
The basic unit is a practitioner group of a minimum of five and a maximum of practitioners.
The members of this practitioner group get to know each other well enough to be able to stand by each other's work.
They do this through....
....self disclosure....
....talking through client work....
....co-supervision....
....visiting each other's work rooms etc.

This turns out to be an onerous task, it is definitely not a soft option....
....how the 'standing by each other' is reached is done is the groups business....
....Our group used a process of self and peer assessment that took best part of 12 months....
....IPN provides a solid way of holding both the personal and occupational strands of accountability for clients.... 
....each person has 5 or six other who know us and hold us....
In addition.... Membership of the IPN (which is only open to groups) requires two other ingredients....

1)....links....
 finding two other groups which are prepared to endorse the process through which the group came to stand by its members....
2)....and the development and publishing to the network, of a code of practice and a statement of the ethical commitments of the group....

No one runs IPN. It belongs to everyone and no one. Currently there are groups in various stages of evolution all over the UK with around 300 participants.

So what have we learned through IPN about accountability to clients....?
....it is 'good enough'
....it is flexible, organic, and able to grow into new forms as need arises
....it is intriguing, satisfying, fun, 
....it is congruent with the kind of values around power that I imagine many practitioners share

This brings us to the end of part one.... in conclusion I want to say that.... 
....the overall message of the Gold Into Lead article is to bring out into the open the two falsehoods that often mask what is happening when people push through major changes such as psychotherapy professionalisation against opposition....
....that the change is inevitable....
....that it is nothing to do with politics ie power.
Psychotherapy professionalisation and statutory regulation is not inevitable and it is about power

Before I go on to talk about Statutory Regulation I'd like to put in a few sentences on the current political developments.... 
....On MondayJune 14th,  the 'report stage' and 'third reading' of the 1999 Health Bill took place in the House of Commons, the committee stage, having been completed.
The Health Bill is long complicated and mostly about the NHS.... but tucked away at the end is something we need to know about....
Where previously the regulation of a profession required an act of parliament with all the difficulties  of finding time as you can see above, the Health Bill 1999 enables the health minister to regulate a profession via 'an order in council'
Anne Richardson, policy advisor at the ministry of Health told me....
....'she would shortly be briefing the UKCP about these provisions....' 
....'that there is no hit list  of professions' 
David O'Carrol who has been involved in drafting the bill said....
....'the minister is taking the power to break the backlog of professions who wished to be regulated'
....'priority will be professions supplementary to medicine....'
....if a professions is split?-'well perhaps there could be a free-standing Health Professions Council'....take a look at the detailed provisions

The Health Bill 1999 undoubtedly opens the legislative door to the Statutory Regulation of psychotherapy in the |UKlike.... next week....
....So now I'll move on to that. 

The Statutory Regulation of psychotherapy....
What does it mean...? 

The Statutory Regulation of psychotherapy means....
....engaging the power of the state.... 
....to endorse the values, practices and worldview.... 
....of the organisations that seek it

So this part of my talk about the statutory regulation of psychotherapy is a talk about institutional power....
....its deployment 
....its varieties or qualities
....and why it matters.

UK psychotherapy training schools have been accumulating positional power for a couple of decades....
....by forming trade associations....
....the BPS....then UKCP.....more recently the BCP.

These trade associations have consolidated their positional power 
....by introducing registers....
....making access to them dependent on completion of an 'approved training'
....and by attempting to convert their trade association status to that of a 'profession'

In relation to psycho-practice as a whole....
....trade associations such as the UKCP, BCP and BPS.... 
....amount to a formidable concentrations of un-elected, un-accountable.... 
....positional power. How these organisations deploy this positional power.... 
....and especially, how they deal with dissent 
....points to the ideology around power that they have adopted.

During (at least) the last ten years.... 
....psychotherapy professionalisation.... and statutory regulation....
....has stimulated considerable dissent.... 

Here are a brief selection of texts that give the flavour and extent of the published objections, criticism and resistance to professionalisation....

The Case Against Psychotherapy Registration: A Conservation Issue for the Human Potential Movement 
Richard Mowbray and Juliana Brown 305 pages Trans Marginal Press 1995bibliography 18pp
'Is psychotherapy a suitable case for statutory treatment? This book responds with a resounding No!'

Implausible Professions 
edited by Nick Totton and Richard House 24 authors, 348 pages PCCS Books 1997
....examines the dynamics of professionalisation....challenges the basis of professionalisation

LIMITS TO PROFESSIONAL THERAPY Richard House Free Association Books(in press) 248 pages
a scholarly critique of professionalisation  that de-constructs:
....The 'Professionalised Therapy Form'.... 
Professionalised Therapy's 'regimes of truth'

INTERNET SITES 
selfheal...[link].http://www.ourworld.compuserve.com/homepages/selfheal Non-mainstream psychotherapy resources
G.O.R.I.L.L.A. http://www.lpiper.demon.co.uk/....texts critical of psychotherapy professionalisation and statutory regulation
....currently dozens of articles 

Two conferences about professionalisation organised by the Norwich Collective.... were held in Cambridge in 1991 and 1992 ....
....they set the scene for the emergence in 1995....
....of the Independent Practitioners Network [IPN]
nb I don't speak for IPN

All this amounts to a formidable body of research.... inquiry into psychotherapy professionalisation.... statutory regulation. 

Almost all of it expresses disapproval.

This dissent has met with a very clear response from the register-builders and promoters of statutory regulation....

Silence..... 
....or rather.... as a colleague has pointed out.... a special form of silence that Germans call totschweigen....
....ignoring something to death.

What is it that the statutory regulationists don't want to hear....?

......here are some headlinesThat professionalisation/Statutory Regulation of psychotherapy is driven by....
....economics 
....status 
....and territory
notice....I don't include client's interests.  

 ECONOMICS
....the explosive growth in counselling training.... 
....from 76 training organisations in 1990 to 545 in 1997....(source: Independent 9 Dec 1997)
....means that increasingly, psychotherapy is part of a saturated psycho-practice market.

The whole project of professionalisation.... 
....raising the threshold of entry to psycho-therapy training
....promoting practitioner registration
....weed/charlatan creation
....is a trade association response to market saturation

STATUS
Psychotherapy professionalisation is about status....
....a desire for parity with psychiatry and clinical psychology in the NHS
....envy and jealousy of psychoanalytic patronage in the NHS

TERRITORY
battles within, and between, the trade associations for market dominance
....e.g. the BCP ultimatum on dual membership
....a desire to create/lead/manage/control a European 'psychotherapy profession'   What about clients?

Clients' interests as a way of justifying statutory regulation and professionalisation....
....have become separated from actual benefits to clients. 

 As a result of psychotherapy professionalisation and statutory regulation....clients will be faced with....
....increased costs 
....reduced choice 
....and due to undeliverable promises and guarantees... no improvement in safety

What does this silence in response to dissent tell us about the trade associations' approach to power? 
....isn't this way of deploying their considerable positional power....
....fundamentally incongruent with the values of psychotherapy practitioners?

Let's look at some other varieties of power....
....'power from within'
....'power with'
....'power over' Starhawk quote

'Power from within....'
When working with clients, most psychotherapists seek to evoke, enhance, or awaken, the 'power within' of the client.... 

....the 'power from within'-to survive, to recover, to flourish, to heal, to belong, to love and be loved, to become self-directing, or responsible etc 

 'Power with....'
In relations with colleagues, family, friends and clients many psychotherapists are likely to adopt 'power with'.... 
....'power with' -co-operation, negotiation, debate, parity, mutuality, consensus-building, power-sharing

'Power over'....
In pursuing professionalisation and statutory regulation....
UKCP, BCP and BPS have adopted a 'power over' approach........to each other....to their registrants ....to dissenting psycho-practitioners ....and ultimately....to clients. 

'Power over'....
....means bullying, coercion  or domination.... 
....the use, or threat, of exploitation/force/sanctions to install compliance, deference, obedience, discrimination, or subjugation....

Here is Starhawk...''Power-over' comes from the consciousness I have termed estrangement....It is the consciousness modelled on the God who stands outside the world, outside nature, who must be appeased, placated, feared and above all, obeyed'. 
'The language of power-over is the language of law, of rules, of abstract, generalised formulations enforced on the concrete realities of particular circumstances....'

Engaging the force of the state through Statutory Regulation....
....to consolidate the power of a psychotherapy 'profession'.... 
....is a 'power over' approach to social organisation....

Why is that a  problem?

It is a problem mainly because
'....power-over motivates through fear. Its systems instil fear and then offer a hope of relief in return for compliance and obedience'. Starhawk

To attempt to dominate psycho-practice in this way....
....embraces the 'power-over' domination that is threaded through the society around us. 

Three conclusions....
1.....domination....and its 'power over' correlates....
....subjection, subjugation, victimisation, discrimination, exploitation, deference, obedience, collusion...
....is the fundamental factor in most client abuse....

2.There is a massive incongruity between 'power from within'/'power with' practitioner/client relations.... 
....and 'power over' occupational politics.... 
....this generates a lot of fear in practitioners.... 
....that will inevitably contaminate work with clients....if it hasn't already done so.

3.Because it is intrinsically a 'power over' way of relating....Statutory Regulation would install in psychotherapy....
....the key element in the abuse of clients it claims to minimise or eliminate....
.... the societal norm....that dominance is OK....