About Us

We are a grassroots task force who approached APA about the need for a consolidated anti-torture and pro-human rights policy in relation to psychologists' involvement in national security settings. We reflect a broad range of interests and expertise, including peace, social justice, human rights, trauma, military, law, and corrections.

Linda M. Woolf, Ph.D., Task Force Chair

Linda M. Woolf is a Professor of Psychology and International Human Rights at Webster University and Fellow with the Institute for Human Rights & Humanitarian Studies. She has researched and written extensively on topics such as the Holocaust, genocide, human rights, hate groups, terrorism, torture, ethics, and peace psychology. Dr. Woolf is Past-President of the Society for the Study of Peace, Conflict, and Violence (Peace Psychology--Division 48 of the APA), an Institute for the Study of Genocide Board Member, and Editorial Board Member for H-Genocide. She is one of the primary drafters of the 2006 American Psychological Association Resolution Against Torture and Other Cruel, Inhuman, or Degrading Treatment or Punishment.

Laura Brown, Ph.D.

Laura S Brown, Ph.D. ABPP, is a feminist psychologist in private practice, and founder and director of the Fremont Community Therapy Project, a training clinic offering feminist, culturally competent, queer-friendly, trauma-focused services to low-income individuals in a social justice framework. She has been involved as an activist for various progressive causes since the mid 1960's, with her focus in the past decades on LGBT civil rights, women's rights, and anti-racism alliance work. She has written extensively on the topics of cultural competence, trauma treatment, feminist therapy, and ethics. Her service to psychology has included membership on APA's Committees on Women and LGBT Issues, and in the presidency of Divisions 35 (Women), 44 (LGBT Issues), and 56 (Trauma Psychology). She is a student of aikido, a martial art dedicated to the harmonious resolution of conflict.

Kathleen Dockett, Ed.D

Kathleen H. Dockett is professor of psychology at the University of the District of Columbia, with specialization in community psychology. A Fellow in Peace Psychology, her pioneering research integrates the paradigms of peace and community psychology with that of engaged Buddhism, in framing solutions for societal problems and promoting peace. Dr. Dockett serves on the American Psychological Association Council of Representatives for Division 48 Society for the Study of Peace, Conflict, and Violence (Peace Psychology). She co-chairs 48's Ethnicity and Peace Work Group, is convener of the Division's Task Force on Humanitarian and Psychological Issues in the Israeli-Palestinian Conflict, and has served as two-term secretary. She is a member of Divisions 27 and 45, and a member of the Advisory Board of Psychologists for Social Responsibility.

Julie Meranze Levitt, Ph.D.

Julie Meranze Levitt, Ph.D., is a clinical psychologist in the Philadelphia area and a Peace Psychologist who has been active, since the 1960's, working on local policies and projects to increase understanding cross-culturally and develop dialogue practices when there is conflict within the community and in/between non-profit organizations. Within her practice, she focuses on trauma and its impact on survivors and their families. She co-developed and convened a conference series within Psychologists for Social Responsibility to examine humanitarian practices abroad, with focus on ethics and asymmetrical power distributions among individuals and groups. She is the immediate Past-President of the Society for the Study of Peace, Conflict & Violence: Peace Psychology Division of the American Psychological Association and presently is studying community-based peace psychologists, their work, other service within the communities in which they live, their views on public policy and their activism. She has been one of the developers of a longitudinal study on resilience in Holocaust survivors and succeeding generations. In addition, she is an oral historian who focuses on ethics and interviewer/narrator interactions and impact on each other. Among her board affiliations is CeaseFire PA, an organization concerned with the proliferation of illegal guns and violence.

William Strickland, Ph.D.

William J. (Bill) Strickland represents the Society for Military Psychology (Division 19) on the American Psychological Association (APA) Council of Representatives. Bill also serves on APA's Policy and Planning Board and is the immediate past Chair of APA's Committee on the Structure and Function of Council. In his 5 years on Council, Bill has been very active in ensuring that APA policies unequivocally prohibit psychologists' participation in torture. Specifically, he helped author the 2007 and 2008 Council Resolutions regarding torture and other cruel, inhuman, or degrading treatment or punishment, and he moved their passage by Council; he introduced the revisions to Standards 1.02 and 1.03 of the Ethics Code to Council and he moved for their passage; and he was a member of the APA Presidential Advisory Group on the Implementation of the Petition Resolution. Bill is an industrial-organizational psychologist by training, and has never worked in an interrogation setting.

Consultants and Comments

In mid-June, the Task Force sent out a Call for Consultants to a broad range of constituencies for individuals to review a draft consolidated policy. Our call went to APA Divisions; State, Provincial, and Territorial Psychological Associations (SPTAs); four Ethnic Minority Psychological Associations (EMPAs); PsySR; the Coalition for an Ethical Psychology; Psychologists for an Ethical APA; some international psychological organizations; and to psychologists involved in the national security sector. Our goal is to draw on the expertise of a broad range of constituencies and perspectives to develop a coherent and useful consolidated APA policy going forward. Below are the individuals who have volunteered or been appointed by their association to serve as consultants. Note that organizational identification does not signify organizational endorsement of the policy, at this time.

Consultants were asked to provide biographical information and comments on the first draft. Each person's biographical information is included, as provided--not all consultants elected to provide a brief bio. Consultant comments are included below directly as written. Note some individuals also elected to provide comments on the draft document. These documents with comments are provided in PDF format for download.

Division 9:
  • Allan Omoto, PhD
    Biographical Information: Dr. Allen M. Omoto has been actively involved in APA governance in a number of different capacities. He represented Division 9, the Society for the Psychological Study of Social Issues (SPSSI), on the APA Council of Representatives for six years (2006-2011). While on COR, he worked on several issues related to social justice and human rights, and was a member of the 2008 APA Presidential Advisory Group for the Implementation of the Petition Resolution. He also served as Secretary and later Chair of the Public Interest Caucus. Currently, Dr. Omoto is the President of SPSSI and also serves on the APA Board for the Advancement of Psychology in the Public Interest. His comments reflect his own independent reading of the draft document and do not reflect the positions or opinions of any board, organization, or professional society.

    Comments on Draft One: I appreciate the Task Force's hard work on this document, but more than anything, the intent to try to update and consolidate APA policies on psychologist involvement in national security settings. It is clear that the APA has adopted a number of policies and position statements that directly bear on the involvement of psychologists in national security settings, and also that the APA's position and the explicitness of that position has evolved over time. I have a number of comments about the document that I will note below, most of them focused on the presentation of the document.

    To begin, though, I have a content question. Specifically, I am curious about the exclusion of the statement from the 2006 Resolution, "Be it resolved that psychologists shall not knowingly participate in any procedure in which torture or other forms of cruel, inhuman, or degrading treatment or cruel, inhuman, or degrading punishment is used or threatened." Because this statement addresses procedures, and not just discrete acts, I think that it warrants inclusion in this summary document.

    In terms of presentation, I do not think the form of the document is as effective as it could be, and especially considering how it is likely to be used. The front end introductory material currently in the Executive Summary is much too brief and provides little guidance or clarity about the use of this document or how it differs from previous documents and reports. It would help to have information like this in the document itself, or failing that, to expand on the material currently in the Executive Summary. A related issue is that the current title is imprecise. I don't think that there is any reconciliation of policies attempted, and to include this in the title suggests to me that new, reconciled or compromise policies are being proposed. I think that this implication might raise red flags for some reviewers and COR members. Furthermore, the policies that are drawn from are mostly not focused on psychologists in national security settings or work; they are much broader. "Policies Related to Psychologists' Involvement in National Security Settings" can be read as policies written about this involvement rather than as simply relevant to work in these settings.

    I understood one purpose of the APA member-initiated task force was to scrutinize existing policies so as to be able to identify the policies or reports that could and should be rescinded. In particular, many more recently adopted policies duplicate portions of or render the PENS Report obsolete. I believe that a clear and unambiguous statement is needed in this document that makes this point, including specifically referencing the PENS Report. I don't think it is enough to simply say that here are the most recent policy statements collected up. The Executive Summary currently notes that some policies are outdated, redundant, and/or confusing, but not which ones. If this document is supposed to be the current and definitive statement on APA policies related to psychologist involvement in national security settings, then this should be noted and explicitly stated. This important purpose of the document is lost in the current presentation.

    The Executive Summary states three principles, although these really seem to be three of the policy statements contained in the document. I am unclear what, if any, distinction is being made between principles and policy statements. It seems to me that the foundational principles that need to be articulated are contained in the Ethics Code but also the (mostly UN) documents that speak to principles of human rights and the treatment of prisoners. The policy statements that have been adopted are APA attempts to enshrine certain principles and to make clear their applicability for the work of psychologists, including in national security settings. Thus, I would suggest a presentation and organization that sets out the principles and relevant documents and then lists the relevant policy statements that flow from the set of principles, much like the Ethics Code explicates principles and then sets out standards that derive from the principles. Regardless of whether the task force opts to modify the presentation in this way, the current interchangeable use of principle and policy statement is confusing.

    Given that all of the policy statements come from some other adopted document, I would find this document much easier to digest and more user friendly if the appropriate reference for each statement was provided along with the statement. So, for example, Policy Statement 1 is simply the Be It Resolved paragraph from the original petition resolution, whereas Policy Statement 2 comes from the Introduction to the Ethics Code. The current presentation of these policy statements have the effect of making them appear newly written or condensed rather than a cataloging of already adopted policies. The commentary provides some of this information, but also a good deal of other information, so the direct and simple source for each policy statement is difficult to discern.

    I also do not understand the logic used in ordering the policy statements in this document. Many of the statements come from the 2006 Resolution Against Torture and Other Cruel, Inhuman and Degrading Treatment or Punishment, but they are in a different and more sensible order in that resolution. In particular, Policy Statement 7 is broad and applies well beyond national security settings. Similarly, Policy Statement 8 is a broad statement of the applicability of the Ethics Code, not restricted to psychologists working in certain roles or settings. I would suggest not only a clarification between guiding principles and policy statements, but also a reordering of the policy statements from broader in scope to more narrow and specific.

    Policy Statement 8 makes clear that psychologists are bound by the Ethics Code and then has bullets for a number of individual ethical standards. I think that there may be additional standards that are relevant and could be listed; are these simply the most relevant or obvious ones? I think that overall familiarity with and adherence to the Ethics Code should be stressed rather than to suggest that only certain standards are relevant to working in national security settings, as I think the current bulleted list implicitly implies. After stressing adherence to the Code, specific standards could be listed but with a statement that they are being highlighted because they are especially relevant to work in national security settings. If standards are bulleted, though, I would encourage explicit referencing for each one (i.e., provide the number of the specific standard being restated), else this appears to be an interpretation or application of the Ethics Code and Standards.

    I understand that the Directives for Association Action come from other documents and reports. However, I do not understand their inclusion in this document. I may misunderstand the main thrust of this document, but I had interpreted it as the new "one stop shop" for guidance about psychologist involvement in national security settings. Including information about action for APA to pursue seems out of place in this context. These are all actions that should be being pursued based on adopted policies and it may be that some monitoring or continuing accountability is needed. It just does not seem to me that a reference document about individual psychologist involvement in national security work is the best place to restate these directives. Furthermore, some of the information from the directives should be easy to obtain (e.g., the number and content of letters written to the DOD, the status of the casebook), although it may require an explicit request or perhaps a legislative item that stipulates regular reporting of specific actions to certain governance bodies.

    Regarding the Expanded Policy Statements and Brief Commentary section, I found many of the commentaries of be of limited usefulness, and moreover, many were not brief. Again, I would suggest that the specific documents that serve as source material for the individual policy statements simply be referenced. They are limited in number and simply could be included in an appendix to the document. For many of the commentaries, verbatim material from different documents has been copied so it is unclear what has been gained by their inclusion or calling them a commentary (and indeed, some seem redundant with the material presented in the policy statement section). Other commentaries draw attention to new material or offer an interpretation of supporting material (e.g., that the specific policy statement is "in keeping with" some other document). These could be helpful for some purposes, but I am unsure they help in articulating the understanding and applicability of the policy statement. In short, the intent of the current commentaries is unclear to me; collectively, they seem serve a variety of purposes that also are not consistent across commentaries. I would find the commentaries more useful if they were more concise and did two things: 1) identified the source of the policy statement, and 2) provided references for additional relevant information and material. Moreover, I think that they should have a consistent format and that each and every policy statement should have a commentary (currently, there is no commentary for policy statement 5).

    Finally, regardless of what the task force opts to do with the commentaries, I do not think that material from Pro/Con statements that went out with ballot measures (see commentary for Policy Statement 1) should be included or referred to in this document. Unlike most of the other source material that is referenced, pro/con statements are not directly or indirectly adopted by COR or a governance body. Also, they are written with persuasive intent in mind.

  • Wendy Williams, PhD
    Comments on Draft One: I appreciate the opportunity to be on this taskforce. As a current member of APA Council and as a representative of Division 9 (SPSSI), I am invested in this being an open and inclusive process that goes through all of the proper channels to make sure that it is all "above board" (e.g., going through the New Business Item process on council once a final version is completed). As such, although I have appreciated seeing this draft, I do not have anything substantive to add to the discussion above and beyond what the other reviews have stated in their public comments. I think they raise a number of issues in the language that need to be addressed in the next round of revision before it gets to a new business item on the floor of Council. I especially think that an acknowledgment of the past that led us to this moment (a "preamble" that does address the problematic nature of the point in time we are now at, should be included). Beyond echoing what others have eloquently stated as concerns, I would like to stay informed of the process, but I do not have any further edits of my own. Thank you again for your willingness to take this feedback and for making the process inclusive and handled through legitimate procedures.

Division 13:

  • Melvin A. Gravitz, PhD
    Comments on Draft One: I strongly support those colleagues who have expressed their views as follows on this pending matter.

    Plainly speaking, a few APA members have been advocating that our national American Psychological Association take a position that would--in effect--make it inappropriate and even unethical for psychologists to participate in a number of ways in the defense of our country. As behavioral specialists, psychologists have much to contribute to the national defense in these important times. APA should be supporting the security of our country, rather than taking steps that would do the opposite.

    As example, APA members who serve in the military services are obligated to follow the policies and orders of their commands. Were they to refuse to do so, then they would be subject to legitimate penalties. Similarly, civilian psychologists have for many decades worked in national defense positions, and if they refused to adhere to their obligations, then they would no longer be able to perform their duties. APA should be supporting these colleagues and the nation they serve.

    This is an important matter that should be given the careful scrutiny it merits before it goes any further.

  • Cathleen Caviello, PhD
    Comments on Draft One: Thank you for the opportunity to comment. Please accept the following caveats: Because I was nominated to review this document by the Society of Consulting Psychologists (Division 13), I will focus my comments on psychologists in consulting roles. It is important to realize that similar concerns and questions could easily be raised by those in many other Divisions such as 12, 14, 15, 18, 19, 21, 22, 28, 29, 28, 40, 41, 45, 55, and 56. I also understand that my affiliation will be included as Division 13 but that the affiliation is included is for identification purposes only and that my comments are my personal thoughts/input. Please let me know whether any additional information is included prior to including it because my employer has pre-publication requirements with significant enforcement penalties.

    Here are my comments:

    The document, as currently written, mixes policy with procedures/guidance. Most other APA documents distinguish between policy and guidance. I suggest doing the same with this document. The first five pages appear to be the actual policy statements. I suggest clarifying that distinction, more clearly separating the two, and titling the second part something like "Expanded Guidance and Commentary". If they remain together and what appears to be guidance actually becomes policy, then I suggest asking the consultants to again review the material with that in mind.

    The title of the document is very confusing. This document is narrowly focused on assuring that psychologists are not involved in torture. The document does not, as the title implies, apply to the broad range of activities of psychologists in national security settings. To reduce the confusion, the document could be re-named: Consolidated APA Policy Concerning the Prohibition of Psychologists Involvement in Torture. An alternative would be to add a simple caveat at the beginning that clarifies that the policy is not intended to summarize or address the broad range of roles that psychologists play in National Security settings because those roles are addressed by a multitude of APA policies and guidance documents relating to the specific specialty of the psychologists relevant to their roles, duties, and expertise.

    A picky but important comment about Policy Statement 7: I recommend eliminating the examples or, if examples are necessary, then just include the first two documents which are clearly relevant for many roles.

    In policy statement 8, the language is more stringent than in the actual APA Ethical Principles (2002 version with 2010 updates). In many settings, to include rural settings and many corporate settings in addition to a wide variety of government settings, it is impossible to avoid multiple relationships. For example, in traditional Employee AssistancePrograms,psychologists provide health care and also typically provide training and managerial consultation. The APA ethical code provides clear direction about these situations. Policy Statement 8 is fine but explanatory comment that starts, "Based on the Principles and Standards" should either be eliminated or more accurately reflect/quote what the code says. The APA Ethical Principles say, "A psychologist refrains from entering into a multiple relationship if the multiple relationship could reasonably be expected to impair the psychologist's objectivity, competence or effectiveness in performing his or her functions as a psychologist, or otherwise risks exploitation or harm to the person with whom the professional relationship exists."

Division 18:

  • Walter Penk, PhD
    Comments on Draft One:
    1. Unified Policy reads well to me. Principles are well-written and in keeping with APA standards of ethics and conduct.

    2. I have personal preferences with regard to sequencing points as they ae presented. But, to repeat, these are my personal preferences, and I am not typing them as recommendations that any changes must be made. I will simply list my personal reactions.

    3. I have two preferences: one, that APA and US Codes of Ethics appear first, before International Laws are mentioned. My mind goes from County of Comal, to State of Texas, to USA, to United Nations, not the other way around, like it appears in Principle 1..

      Like, for Principle 1, I prefer that our national laws, like the US Constitution (not the Canadian, for APA?) be mentioned before referencing International Laws.

      Further, I would like to see Principle 7 and 8 reversed, the US national laws (Canadian ?) presented before the list of International laws and organizations.

    4. For Principle 2, I would like to see an Appendix listing times when versions of APA Code of Ethics were passed and approved. Principle 2 lists only the version for 2010. Since, on occasion, discussions are held about actions or considerations that may have taken place, using earlier versions, before 2010, it might be helpful to list dates, by times, when various versions were passed as well as citations for availability.

    5. I would like to see listed other national (US, Canadian?) Codes of Conduct and Ethics that guide the practice of psychology in the USA (Canada?) with which APA Code of Ethics interacts...like US Federal Civilian Employee Code of Ethics, US Army Code of Conduct, US Military Code of Conduct, etc. Like, Principle 7 lists many International organization with which APA Code of Ethics interact. But, few organizations, with national (USA, Canada?) code of ethics are listed (Note: a couple are mentioned at the end of the Unified Policy but these could be listed earlier, like, in Principle 8 (national)--which I still think should appear in front of Principle 7 (International).

      This is an excellent document. Congratulations to the team who wrote the Unified Policy.Thanks for affording me an opportunity to read it.

Division 19:

  • L. Morgan Banks, PhD
    Biographical Information: Morgan Banks recently retired from the Army after 37 years of service, with over 27 of those years as a Clinical Psychologist. While on active duty, he served in a variety of positions, to include as a company commander, Special Staff Officer for a variety of military organizations at the Brigade and Major Command levels, and as both a clinical and operational psychologist. He was a member of the PENS task force, and he is a member of t the American Psychological Association (Division 13, Society of Consulting Psychology, and Division 19, Military Psychology) He is the author or co-author of several book chapters on Operational Psychology.

    Comments on Draft One:

    1. National Security Settings is not defined. A common sense reading of this term would include all settings that support the US National Security, to include all federal employees who work to support our national security. This would obviously include all VA and DoD psychologists, regardless of their role, along with many, if not most, other psychologists employed by the federal government. This document should include a definition of National Security settings, and be edited to make sure that the document makes sense in regard to that definition. If that is not the intent of the document, then the actual scope and purpose of the document should be articulated.The document appears to have been written without reference to the only detailed guidance on this type of work, the PENS report. In particular, the following PENS statements appear to be completely excluded: 3, 4, 5, 6, 7, 8, 9, 10, 11, and 12. Although some of the guidance contained in the PENS report's critical statements was briefly discussed, the draft document does not contain the clear, useful guidance that is contained in the PENS report. The PENS report must be included in this document for it to have any utility in providing ethical guidance to psychologists beyond not supporting any cruel, inhuman, or degrading treatment (something that is already against current US law, and therefore redundant.) The twelve statements from the PENS report and their explanations must be included. This would be pages 4 through 9 of the PENS report. As this is current APA policy, and the stated intent of this document is not to change APA policy, it would be disingenuous not to include all of current APA policy. By default, if the PENS report is not included, this would represent a major change in APA policy. Here is the source pointing out that the PENS report is APA policy:

      http://www.apa.org/about/governance/board/05aug-bdminutes.aspx

      It states, "Affirming the determination by the American Psychological Association (APA) Ethics Committee that the twelve statements included in the Report of the Presidential Task Force on Psychological Ethics and National Security are appropriate interpretations and applications of the APA Ethics Code, the APA Board of Directors adopts the task force report as APA policy." This is the only specific ethical guidance that APA has produced to assist psychologists working in these settings. It would be a dramatic step backwards to reduce the guidance and standards for these psychologists. The Ethical Principles of Psychologists and Code of Conduct have changed since the writing of the PENS report. Because of that change, it is reasonable to remove the sentence, "If the conflict cannot be resolved in this manner, psychologists may adhere to the requirement of the law. (Ethical Standard 1.02)," since the statement in the Code of Conduct that supported this statement has been changed.

    2. At numerous points in the Expanded Policy Statements and Brief Commentary portion of the document, it gives clear guidance to APA members to break the law or to follow guidance and rules that are not compatible with federal service. All federal employees are required to follow the US Constitution. This includes any international instruments to which the US is a signatory. If the US is not a signatory to a particular instrument, then it may not be legal for a federal employee to follow that international instrument.

      This is the Federal employee (civilian) Oath of Office:

      I, [name], do solemnly swear (or affirm) that I will support and defend the Constitution of the United States against all enemies, foreign and domestic; that I will bear true faith and allegiance to the same; that I take this obligation freely, without any mental reservation or purpose of evasion; and that I will well and faithfully discharge the duties of the office on which I am about to enter. So help me God.
      This is the Commissioned Officer (military) Oath of Office:
      I, (state your name), having been appointed a (rank) in the United States (branch of service), do solemnly swear (or affirm) that I will support and defend the Constitution of the United States against all enemies, foreign and domestic; that I will bear true faith and allegiance to the same; that I take this obligation freely, without any mental reservation or purpose of evasion; and that I will well and faithfully discharge the office upon which I am about to enter. So help me God.

      Obviously, it would potentially violate both oaths of office to follow international law to which the US is not a signatory. This would require federal employees to either resign their commissions (Military psychologists) or leave their civilian jobs (civilian federal psychologists), or to leave APA. Being a member of an organization that encourages its members to violate US law is not compatible with Military or civilian service. Any reference that requires support of international law that is contrary to US law must be removed. The document may certainly suggest consideration of international law to which the US is not a signatory, but it may not be a requirement. If it is, then the guidance will not be in compliance with the employment requirements of federal employees. My strong recommendation is that the Expanded Policy Statements and Brief Commentary be removed to prevent this result. Otherwise, this portion must be completely re-written or the APA must resign itself to the departure of federal employees and all that that will entail. Finally, in addition to the potential violation of the oaths of office for federal employees, if it becomes a requirement to follow UN guidance when functioning in a national security setting, membership in APA may be a reportable incident for security clearance purposes for those members with clearances. This may mean that membership in APA will limit the ability of an individual to obtain or maintain a security clearance, since that membership would imply violating US law.

    See also Policy Draft Edits: BanksPolicyDraftEdits.pdf

  • Larry James, PhD
    Comments on Draft One: Thank you and the task force for taking on such an important topic and your leadership role in the process.

    I see this document as a start in a process. But as written I do believe that this document has many fundamental flaws.

    1. The title of the document is inconsistent with the charge of this task force. The title has in it "Psychologists Involved In National Security Settings." The problem with this is that all federal and government employed psychologists work in a "National Security Setting." The scope of the Task Force was to be limited to Psychologists working in military Detention facilities around the world. As written this document by title includes V.A. psychologists, CDC and NIH psychologists. All of these federal employees are involved in a national security setting.

    2. I believe that the document has a directive tone (you must or will do) rather than how all APA policies are crafted with a guidance tone (one should consider). This document in many places is more directive than the APA ethical code itself. Given that human behavior is very complex, this document like all APA policies, should provide psychologists with sound guidance and not list directive.

    3. I should point out that under the Uniform Code of Military Justice (UCMJ), all military members must follow the orders of the Commander In Chief (the President). For any military psychologist to follow another set of rules or policy would be a violation of federal law. Thus, all members of the military MUST follow all lawful orders of the President, the Secretary of Defense and his or her military chain of command. Therefore, This document as written would create more problems for military psychologist rather than solving problems. Simply stated, Military Psychologists cannot follow the United Nations nor any other document in lieu of the UCMJ.

    4. It was said that the PENS task Force report would continue to be policy and there was never a goal of your task force to replace the PENS Task Force report. The PENS Task Force Report was never mentioned in your document. This begs the question, what happens to the PENS report? I strongly suggest that the PENS report continue to serve as the document for the psychologists in detention facilities around the world. Your document offers little practical guidance to a young psychologist in a detention facility. The PENS report on the other hand serves as THE document and offers a great deal of guidance.

    I believe that this document is a very good starting point but it needs to address these issues. It should be a document that compliments the PENS report and the Ethics code.

Division 32

  • David N. Elkins, PhD
    Comments on Draft One: Since others are posting their comments, I will also do this. I believe the member-initiated task force is well-intentioned and I appreciate being a consultant. However, as I have expressed to Dr. Woolf and Julie previously, I have three major concerns about the proposed document which are detailed in the attached (my comments are in yellow). To summarize my concerns:

    First: the document does not mention APA's past mistakes regarding psychologists' participation in "enhanced interrogation" settings. A preface, at least, should acknowledge these mistakes which allowed psychologists to participate in torture during the Bush-Cheney administration with impunity. It was this which caused many to resign from APA in protest, including Ken Pope who had served as Chair of the APA Ethics Committee, was a Fellow in 12 Divisions, and had been a member of APA for 29 years. If the final version of the document does not at least acknowledge that mistakes were made in the past, I predict the document will be viewed as yet another "cover up" of APA's past mistakes in this area and will not convince those who left APA in protest, as well as thousands of us who stayed but had major concerns about APA's policies that allowed psychologists to place government demands over professional ethics. (See my comments in the attached about how 1.02 of the ethics code was changed during the Bush-Cheney period to allow psychologists to follow military/government orders over professional ethics and how 1.02 has now been changed again so that it no longer reflects its horrible history, which some in psychology called the "Nuremberg Defense" (i.e., "My military superiors told me to do it, so I'm not responsible." Without at least some kind of acknowledgement that past mistakes were made by our national organization and that it produced policies that allowed psychologists to participate in torture with impunit, the document is likely to be viewed as yet another "cover up" in this long saga, I fear. In fact, many psychologists are already making this charge, as most of you probably know.

    Second: not only does the proposed document fail to acknowledge APA's past mistakes, the document actually praises APA in several places for its longstanding commitment against torture (see the attached and my comments). This implies that APA's actions have always been honorable relative to torture which, unfortunately, is not true. All one has to do is look at the "old" 1.02 in the ethics code that was operational during the Bush-Cheney administration which permitted psychologists to engage in torture with impunity and the more recent "new" 1.02 that represents a radical change and no longer reflects what many called the "Nuremberg Defense."

    Third: there is a paragraph in the proposed document that seems to say psychologists currently working in certain settings can place job requirements about professional ethics if there is a conflict. (See the attached document and my comments about this). If I have understood the paragraph correctly, this would be a continuation of the very policies that many of us hoped would be superseded by the proposed document.

    Central to everything we do and say is this: The welfare of human beings is at stake here. It is critical that we finally "get it right." Unless the final version of the integrated policies document addresses the above issues, it's difficult for me to believe that psychologists who know the history of APA in regard to PENS and 1.02 of the ethics code will be able to support the document -- and thus the valiant effort of the member-initiated task force could go down in history as yet another effort, even though well-intended, that tends to cover up our national organization's sordid history regarding torture during the Bush-Cheney administration. I am acutely aware that my words here are very straightforward but this is no time to pussy foot around. After several years of this continuing sage, we finally have a chance to do the right thing -- and we need to do it.

    Although I am immediate past president of Div. 32, I speak only for myself in these comments.

    See also Policy Draft Edits ElkinsPolicyDraftEdits.pdf

Division 34:

  • Joseph B. Juhasz, PhD
    Comments on Draft One: I have given this matter a great deal of thought. It appears to me that every version of the APA's policies attempts to provide a craftily worded cover for psychologists who in fact are in some way or another involved in inhumane behavior. As an example witnessing an act of torture without reporting this to the proper authorities as an "advocate" of a person being tortured hardly seems like ethical behavior to me.

    I wonder how you or others would feel if we substituted "child abuse" or "rape" for "torture" Would anyone be in favored of tortured excuses for involvement in such behavior which is neither more nor less reprehensible than torture.

    I am still of the opinion that it is in the best interests of the profession to have non-tortured language that simply prohibits any involvement in torture.

Division 41:

  • Chris Meissner, PhD
    Comments on Draft One: I've had the opportunity to review both the document and others comments on the draft. I'll keep my comments simple here, as several of them are covered by others. Specifically, I want to echo the sentiments of several consultants (Thompson and Banks).

    First, the U.S. Constitution and U.S. laws should be primary in any consideration of legality by USG psychologists. They are bound by such laws and must act in accordance. Certainly conscience and conviction can be relied upon to refuse orders or duties that are immoral, and the APA ethics code should further advise their actions and considerations. I believe placing primacy on foreign treaties and international laws will be quite problematic and will result in the loss of such members from the APA. Matters related to security clearances as outlined by Morgan are also important consideration here.

    Second, others have said this better than I, but I don't believe the policies here encompass the range of considerations afforded by the PENS report - see Morgan Banks comments on this.

    Third, I thought there was some redundancy in the policies. Specifically, policies 5 and 6 could be combined, as could policies 2 and 8. I can't quite understand why they were separated and can't foresee any issues caused by combining them.

    Finally, I believe this is an important effort, though it seems pointed at clinical psychologists. I would be remiss if I didn't note that as a research psychologist I regularly interface with the intelligence and military communities, both operational and training entities. There are important considerations for me and my colleagues in this context that simply aren't addressed in this effort ... including the conduct of research in operational and training settings, treatment of individuals as participants in this research, reporting of concerns, etc. It might be useful to consider how research psychologists might (or might not) be impacted by these policies.

Division 48

  • George Hough, PhD
    Biographical Information: Dr. Hough is a Clinical Psychologist and licensed to practice independently in the states of Kansas and Missouri. He has been board certified in Clinical Psychology by the American Board of Professional Psychology since 1995. He has been in independent practice for 21 years in Topeka, Kansas. He provides forensic psychological evaluations for private attorneys- both plaintiff and defense- as well as for local, state, federal and international courts.

    Dr. Hough obtained his bachelor’s degree from the University of Michigan in 1978, and Ph.D. in Clinical Psychology from the California School of Professional Psychology at Berkeley in 1988.He completed a two year post-doctoral fellowship in Clinical Psychology at the Menninger Clinic (1987-89) in Topeka, KS. He graduated from the Topeka Institute for Psychoanalysis in adult psychoanalysis in 1999. He has taught courses in psychoanalytic theory and technique at the Greater Kansas City Institute for Psychoanalysis, and has given presentations on various forensic topics. He has been a member of the Physicians for Human Rights Asylum Network for nearly two years and has undergone PHR’s training in the use of psychological evaluations for the documentation and treatment of asylum seekers.

    Comments on Draft One: Comments for Separate Document

    1. Members of the Task-Force have clearly put a lot of effort and thinking into this document and you efforts should be commended. Though I have tried to review the document very carefully, line by line as it were, in the end there is little I have to add. The comments I provided on the other document that reviewed the work product by the Task Force are primarily questions asking for some clarification or distinction. The Task-Force has already done the hard work or "heavy lifting" for this document. I thank all of you on the Task-Force for initiating this project. I would very much like to see the project continue to move forward to the next steps.

    2. This document seems to me to succeed in its efforts to supersede the PENS document and assert human rights and international law at the forefront of APA policy regarding psychologists work in national security. From what I have read about the process used to develop PENS, and that it has been used by DOD and other national security agencies to justify continued acts of torture and unethical/illegal behavior, those issues do implicate the need for this document.

    3. The argument this document will somehow further "enshrine" PENS and embolden those who would misuse it to subvert the rule of international law and standards seems to fail in light of the content of this document. If PENS is ultimately annulled (and it might be), then this document (still in process) would be well situated to be the most viable one that could be considered at present.

    4. This document reasserts international definitions of torture codified in UN documents and helps clarify standards and applicable international law. In other words, it makes clear that more "permissive" and politically expedient definitions of torture are not acceptable for APA ethics. International standards are reaffirmed and are consistent with APA's position as an accredited NGO with the United Nations.

    5. This document reasserts that psychologist's do not hold themselves to standards less stringent than other helping professions such as the American Medical Association, the American Psychoanalytic Association, or other professional associations throughout the world. This will help APA reassert itself as a standard bearer for psychology ethics throughout the world and that it has not capitulated to the urgency and "ends justify the means" thinking under the banner of national security. This is a positive assertion.

    6. There is still need for the authoritative Casebook from the APA Ethics Committee as indicated in this document. Standard recommendations that apply to clinical or academic settings within the United States will here require more nuanced and carefully thought through solutions.

    7. Some suggestions to "seek consultation", as a basis for ethical action and decision-making in national security settings, while helpful in the abstract as a guiding principle, are quite impractical in practice. In the national security settings, psychologists will sometimes be immersed into settings where making rational and moral decisions, where there is organizational transparency and accountability, and where the psychologist has full power to confront, challenge and expose unethical practices- all of this may be more aspirational than not. Psychologists working in standard organizations and institutions as well as in private practice take this requirement for granted and can do so with little risk or conflict within the setting. For psychologists in national security settings, we cannot underestimate the difficulties this simple maxim may convey. Powerful situational forces are at play and these require further study.

    8. There is a need for APA members in national security settings to be able to access consultation outside the chain of command/organizational structure. To my knowledge the APA Ethics Committee does not have institutional procedures in place for such consultations for APA members who are at the security settings. Establishing any such procedures will obviously be complicated but the process needs to be started, in coordination with the DOD as well as intelligence agencies and civilian contractor organizations. Ultimately, the psychologist be need to be part of a separate chain of command while serving in national security sites that are outside the tactical command responsible for the operation. To my knowledge APA has not yet addressed such institutional structures, regulations, procedures and supports.

    9. I assume that psychologists will continue to be working at national security settings. Military psychologists may not have an option otherwise. It is recognized that the psychologist working in a national security environment may be confronted by challenges that are far beyond their traditional training and experience. A heavy burden will be incurred by these individuals, as the onus falls upon the individual psychologist to: be mindful of ethical breaches, aware of the applications of both US Constitutional law as well as International Law, clarify roles and boundaries, seek consultation, maintain confidentiality, be knowledgeable of various specific techniques regarding torture and other cruel and unusual punishments, and even more. The situational demands are no doubt well near impossible to navigate well. Given the uniqueness and the stakes at play with these situations, I would encourage APA to continue to provide ongoing Ethics training for individuals who may be working in these settings or contemplating doing so. For private contractors such training could become a condition of employment that must be satisfied before an offer of employment.

    10. There and many other complex issues will need to be worked out and APA is only in the beginning stages of this process. This document will ultimately be a valuable contribution to that process.

    See also Policy Draft Edits: HoughPolicyDraftEdits.pdf

  • Arthur Kendall, PhD
    Comments on Draft One: Comments on draft report.

    Principle 1: Psychologists may not work for an organization or agency responsible for operating settings where persons are held outside of, or in violation of, either International Law (e.g., the UN Convention Against Torture and the Geneva Conventions) or the US Constitution (where appropriate). They may provide mental health services directly to the persons being detained or for personnel of the facility and their dependents. They may work for an organization or agency external to that operating the facility in oversight, investigating, auditing, or evaluating the organizational, physical, social, operational, or psychological environment of that facility. They may work on behalf of detainees as a class without reference to any individual detainee.

    "Detained" should be broadly interpreted. It should all apply right from the moment of capture, arrest, or taking into custody.

    These principles apply when people are detained by any military, intelligence, law enforcement, or other governmental agency whether or not war has actually been declared. It is always unethical to obey any illegal order. It is always unethical to comply with contracts complicit in illegal acts.

    Information gathered from detainees while investigating, auditing, or evaluating a facility should be strongly protected from the organization or agency directly operating the facility. If necessary, the information should be destroyed if it puts detainees at risk from the operating agency.

    Psychologists participating in oversight, investigating, auditing, or evaluating facilities for detainees have an obligation to promptly notify organizations or agencies responsible for the prosecution of non-compliance with human rights laws and regulations.

Division 55:

  • Robert Younger, PhD
    Comments on Draft One: With Gill Sanders I'm representing Division 55. Given the detailed comments from several of the task force members, I would like to concentrate my remarks on a few issues.

    First, the document is quite broad, covering principles, policy, and procedure and unfortunately mixing these elements. If policy is the primary thrust of the document then I would suggest that be the focus. If the effort is to mimic the APA ethical standards then the paper can be placed in that form, i.e., principle followed by standard, etc. Again, as mentioned by others, I would separate principle, policy and procedures.

    With regard to "procedures" the document speaks of the techniques which are prohibited, but of course this only the negative side of intelligence gathering and assessment, presumably of individuals. More balance, including moral balance, might be achieved by mentioning policies and standards consistent with ethical information gathering as opposed to just "avoiding the bad." Similarly, detailing prohibiting techniques identified by "such as" "the United Nations Convention Against Torture and Other Cruel, Inhuman, or Degrading Treatment or Punishment; the Geneva Conventions" and others raises the implication that practitioners (the emphasis on which is overall lacking) need primarily to avoid torture or prohibited techniques to ethically practice in the national security arena. --

    And finally, one can argue that the document, with its admixture of principle, policy, and practice, strives to be all things to all people and perhaps master of none. As mentioned earlier, it's relevance to actual practice seems, to this practitioner, limited at best. Given this admittedly subjective view, this valiant and laudatory effort runs the risk of being condemned by partisans without being useful.

IOWA Psychological Association

  • Holly Sanger, PhD
    Comments on Draft One: My comments are as follows:

    I am confused and somewhat unsettled by the use of "national security settings" both in the title of the document and as used throughout. If the goal of the revised policy is to provide clear and accurate statements regarding principles of behavior with respect to psychologist involvement in torture, or other violations of human rights, then why not just say that directly.

    Policy Statement 1 is clear; however, it raises some questions about involvement in settings where the government of the United States may be operating independently of international law. I recognize that there is no way to address every eventuality and I do think the other policy statements provide adequate coverage of the issue.

    Policy Statement 5 and 6 address psychologist responsibility to intervene and/or report violations. I absolutely support those statements and yet wonder about the mechanisms available for military/government psychologists, especially those who may be operating in more isolated locations without the support of branch specific chains of command. But that is a matter of education and integrity, not policy.

Indian American Psychological Association

  • Wendy Peters, PhD
    Comments on Draft One: Please forgive the delay in my response and comments which are noted immediately following my brief introduction. Although nominated to consult on this matter by the Society of Indian Psychologists (SIP), my input and viewpoints are solely my own and not necessarily those of my fellow members or colleagues in SIP. That being said, as I have read and interpreted the policy draft I would summarize it as attempting to establish and clarify APA policy regarding 3 major aspects of professional conduct as follows: 1) Agency, being the business, function, and duties of the psychologist and their individual allegiance understood as the loyalty of a citizen to his or her government or of a subject to his or her sovereign; 2) the international definition and standard for human rights; and 3) the prohibition of psychologists engagement in or association with torturous acts.

    My comments:

    1. The intent of the document is unclear in that is combines both principles (guidelines/aspirations) with policy (directives/practice/procedures)

    2. The PENS policy, as it is currently written, is very clear and sufficient to address policy in relation to psychological practice in any National Security setting

    3. The draft is highly redundant in that it continually recapitulates the definition of torture to the point of contradicting a psychologists professional (not to mention personal) obligations to what is lawful and legal according to the US constitution.This draft is narrowly focused in that it predominantly addresses psychologists involvement in torture and says little or nothing about any other aspects of psychologists involvement in National Security settings.

    4. I recommend that instead of recapitulating the digressions of torture and advocating that psychologists potentially break the law to uphold APA ethical standards, that both policy document and task force work in collaboration with governmental and other authorities to see that the law is changed to meet and be more consistent with professional ethical standards.

    5. Last, I feel that the language used in the draft is so lofty and cumbersome that it impairs both readability and comprehension for one without a Juris Doctorate unlike the PENS policy which is very comprehensive yet unintimidating in its verbiage.

National Latina/o Psychological Association
  • Jesse Aros, PhD.
    Biographical Information: Dr Aros is the founding director and lead psychologist for the University Counseling Center at UHV. Before assuming this post, he served as director of the student counseling and disability service units at Texas A&M International University, as graduate program director of counseling and associate professor at St Mary’s College of California, and as a tenured associate professor of counseling at the University of Guam. Dr Aros is currently serving as 1) a consultant for the National Latino/a Psychological Association on the American Psychological Association Member Taskforce to Reconcile Policies Related to Psychologists’ Involvement in National Security Settings; 2) is on a second term on the Association of University & College Counseling Center Directors’ governing board; 3) is serving on the UoHouston Victoria Safety and Risk Committee; and, 4) is the National Latino/a Psychological Association liaison to Helping Hands, Helping Minds. The latter is a joint governmental and NGO coalition that focuses on improving racial/ethnocultural group safety, emergency response, and crisis preparedness through community consultation and planning based on cultural and linguistic factors and data driven needs.

    From 2008-2011, Dr Aros served on the American Psychological Association’s National Committee on Disability Issues in Psychology, as committee chair on diversity and governing board member for the Association of University & College Counseling Center Directors, and as a member of the Accreditation Review Board for the International Association Counseling Services. He has also served in sundry other capacities: Co-chair of the American Counseling Association/s Presidential task force on Best Practices in Counseling Immigrant Families and Individuals, President of the Guam Psychological Association, Guam’s Alternate to the American Psychological Association’s Council of Representatives, the American Counseling Association’s National Committee on Multicultural Concerns, and on other chair and/or committee capacities nationally, and internationally. Dr Aros has authored either partly or in whole some 47 publications, 8 Private Foundation Grants, 2 Federal Public Grants, 1 memorandum of understanding for shared student mental health services between two Texas universities from rival systems on the US:Mexico border, and; 1 mutual aid compact to provide a coordinated emergency support for system wide campus mental health service delivery, university consultation, and debriefing following a major crisis.

    Dr Aros is a licensed psychologist in Texas (#33492), nationally registered as Health Service Provider in Psychology (#52036); and listed on the National Provider Index (#1487973988). At present, he has approximately 9,780 hours of specific paid work experience directing and providing clinical services for college students and running university counseling centers, 3,130 hours of pro bono clinical or emergency response service related experience; and, 19,950 hours of faculty experience for 32,380* total postdoctoral hours. (*This does not include 6, 845 hours of predoctoral experience as a counselor, 1,630 hours teaching and supervision, 600 pro bono clinical hours, and 321 volunteer hours assisting as well as promoting mental health and wellness services).

    To date, overall, Dr Aros has logged approximately 41,956 hours providing mental health education and clinical service delivery in the United States and abroad, with approximately 38,946 hours of student and academic affairs relevant experience to date serving in four (4) university campuses on both the Eastern and Western hemispheres.

    Comments on Draft One: Comments from NLPA Consultant Dr J. Aros on the "Report of the APA Member Initiated Taskforce to Reconcile Policies Related to Psychologists' Involvement in National Security Settings Dated 9/11/12

    1. Task: To clarify existing statements, not create policy. This consultant approached this as an editing assignment, a peer review.

    2. All "Key Reference Documents" used/quoted, as noted on http://unifiedpolicytaskforce.org

    3. This consultant's review and comments.
    4. The accuracy and clarity of "translation" appears to be largely present, the use of "..." in places such as commentaries, eg: Expanded Policy Statement #8 (et alum) with Commentary infers that is much more to say including, but not limited to, the following matters
    5. Disproportionate racial and ethnic profiling is suggested in the key documents by inference. See the greater likelihood of detainment and torture of people of color thought to phenotypically resemble those who are or may be considered "threats to US National Security."
    6. For native speakers of "Language Other Than English" (LOTE) in the US mainland, its territories, language often can be a key covariant or variable that may be linked with "race" and "culture." This "confound" bears explicit mention, given on salience of its loading on who in National Security Settings on who is what kind of enemy, as defined globally in the Patriot Act, as well as key documents referenced.

    7. The above two points do appear to merit further mention as well as further discussion, emphasis, and would make a very small change enhancing this document.

    8. This document is wholly correct in its recurrent position that participation of psychologists in torture is indefensible. It is assumed by this reviewer that this document will be vetted to as many national associations of psychologists globally as possible in creating a unified meta American response and that the use of diplomatic channels and resources taken from (eg: the United Nations) is on our organizational radar to make this so. -
    9. At some point, Milman's work, the Zimbardo prison studies, and our related knowledge base on these topics should be integrated or find a way into this report. This can be done, largely via the commentaries, in some way--even if only in passing in the expanded principles and comments by citing in text, is the humble opinion of this reviewer. This is true especially as we share this report *outside* our field.

    10. See attached, use in whole/part as/if desired.

    11. Received materials and appointed on 9/4/12, submitted on 9/11/12, within the two days as Dr Levitt requested on 9/10/12.

National Security Sector
  • Robert Roland, PhD
    Comments on Draft One: I have been very fortunate to be in contact and discussions with several of the reviewers who have submitted thoughtful and detailed analyses of the draft APA Policy Paper. I particularly would like to point out the efforts of Morgan Banks and Tom Williams in this regard. I have learned over my 30+ year association with both of them that I ignore their advice at my own peril. When you hear from Mel Gravitz, Brad Johnson, Larry James, Bill Strickland and others you will have heard from the best and most experienced National Security and Clinical Psychologists in the world. They always demand the very highest and most ethical standards from everyone and are in positions of respect and authority to make that happen. I have nothing additional to offer except encouragement.

    Please continue this inclusive effort to establish a reasonable stance that will accommodate the genuine concerns expressed by every Psychologist. There is much more agreement than decent here. There are many things that are clearly within our professional lane as Psychologists and some well beyond those boundaries - for now. We will ultimately be more effective by identifying those within our purview and concentrating our efforts to achieve clarity there. If we do this with consensus as a first step then we can ultimately influence National and International policy, procedures etc.

    In so doing, we may actually engage the larger number of our almost 140,000 member constituents rather than the +/- 10% who registered a vote in past polls involving these issues. I believe that we all ultimately want all Psychologists to be informed and care about these issues. Right now they don't.

  • Thomas Williams, PhD
    Comments on Draft One:
    1. The proposed consolidation has served three very important purposes. First, the consolidation of the various policies has helped to make evident that American Psychological Association's policy as outlined within the "Report of the American Psychological Association Presidential Task Force on Psychological Ethics and National Security" (PENS) is actually well-crafted and better achieves the desired objective for an ethical practice in national security settings than do many of the other APA policy constructions that linked to international law. It is surprising that the current effort to consolidate existing policy makes no reference to that important document. Secondly, it has highlighted that the current Task Force seeks to extend and link the American Psychological Association?s Ethics Code and practice within National Security settings more closely with International Law. There are many more issues with that than there are solutions realized. Third, and perhaps this purpose is the most concerning and important, is that the proposed document presumes the practice of psychologists in support of national security needs to focus almost entirely on international prohibitions against torture. In summary, I do not believe the proposed policy document achieves clarity in consolidating existing policy. The proposed policy consolidation fails to address the PENS report (one of the most important and carefully crafted documents that more closely reflects the practice environment), and attempts to move and unify the existing policy and practice by more closely linking practice in national security settings to a closer alignment with international law at the expense of the provisions and protections of the protections afforded every citizen under the U.S. Constitution.

    2. Of all the sections, Policy 8 offers the most clarity and accuracy. Strongly recommend you re-construct the proposed policy around the foundation that Policy 8 provides. It is important to have a policy that is applicable to the "activities that are part of their scientific; educational, or professional roles" as psychologists who "practice" in "settings" in support of national security. We should avoid the mention of any specific type of psychologist (e.g., military clinical, as is done in the #1 endnote, etc.). Thus, it is the APA Ethics Code from which the proposed unified policy should derive its authority and standing as the authoritative source to guide the practice of psychologists. We must recognize and guard against various efforts to cloak activities of the American Psychological Association within an uncertain and ill-defined framework of international laws as happens within the current proposal by linking various international treaties into a proposed APA policy to guide the practice of a selected group of psychologists. As I have tried to highlight in the comments provided within my review of the Task Force report, doing so creates unforeseeable and unnecessary vulnerabilities. In addition, proposals such as these too often come across as motivated by a lack of trust that our own U.S. policies and judiciary will serve our stated interests.

    3. As noted above, the attached document contains my ?Comments? which are linked to and embedded within the various policy statements. My number one concern is that the effort to unify and clarify has perhaps inadvertently slipped into an expansion of international law and policy over the practice U.S. psychologists in support of U.S. National Security. As is noted throughout my review within the comments provided on that attached document, those psychologists who practice within National Security settings are sworn to protect and defend the U.S. Constitution. The proposed documents seem to create supremacy of international law over our Constitution. That is ill-advised, unacceptable, and has unforeseen consequences.

    4. Thank you for the opportunity to provide input. I commend the effort and think the consolidation serves as a start point while highlighting a path for the way ahead.

      See also Policy Draft Edits:WilliamsPolicyDraftEdits.pdf

Additional Volunteers

  • Brad Johnson, PhD
    Comments on Draft One: First, thank you very much for your willingness to provide crucial leadership in this important area of APA policy consolidation. This is not easy but certainly very important work. I have reviewed the draft document and have only a few minor comments and recommendations.

    1. I think that there should be a clearer delineation between the Policy document and the Commentary Document. Right now, they flow together, threatening to dilute the value of the former. It would be help of the Policy Document had a clear ending. At the outset of the Commentary, something should be added by way of introduction such as: "The following commentary on the APA Policy .... is offered as additional guidance to the extent that it might amplify or illuminate APA policy. Different psychologists may find different aspects of the commentary helpful."

    2. The current Policy document is framed almost entirely as a series of negative proscriptions. It lists the many behaviors that are outlawed but fails to communicate anything aspirational or positive about the work that psychologists do in the national security arena. I believe that the aspirational principles in the Ethics Code provide the basis for a more positive introduction to this policy document. Without this addition, the narrative fails to inspire national security psychologists to achieve professional and ethical excellence in their specialty areas. Here are just a few statements that seem appropriate, accurate, and rooted in current APA policy, especially the Ethics Code:

    • In light of their training and expertise, psychologists, including those serving in national security roles, make important contributions to society and to our national security.

    • All psychologists, including those in national security roles, are ultimately accountable for their behavior.

    • National security psychologists strive toward the very highest ethical ideals of the profession.

    • etc...

    3. I applaud the Task Force for avoiding any commentary about the PENS process and the wildly disparate views it tends to elicit. The focus of any APA Policy document addressing the Ethics of Practice should be affirmative, aspiration-based, and practically useful for psychologists working in that arena.

    Again, I thank the Task Force members for an excellent start.

  • Corann Okorodudu, EdD and Judith Van Hoorn, PhD
    Biographical Information: Corann Okorodudu is a Professor Emeritus of Lifespan Developmental Psychology and Africana Studies (Rowan University) where she has also served as Associate Vice President for Academic Affairs and coordinated programs on Africana Studies, Women Studies, and multicultural curriculum transformation. For more than 30 years, she has focused her professional performance in American higher education, at the United Nations, and in governance of the American Psychological Association, on promoting institutional policies and practices reflective of human rights, social justice, and democratic community.

    She served as Main (Head) United Nations/Non-Governmental Organization (UN/NGO) Representative for American Psychological Association (APA) from 1999 to 2004 and remained an APA UN/NGO Representative until 2008. In 1999, with Joan Buchanan, she drafted APA's applications for NGO accreditation at the United Nations, with accreditation to the UN Department of Public Information, the UN Economic and Social Council, and the United Nations Children's Fund (UNICEF). She is currently a UN/NGO Representative for the Society for the Psychological Study of Social Issues and has served as Main Representative of the SPSSI UN team.

    Her APA governance and policy experience includes her two terms in the APA Council of Representatives with Judith Van Hoorn as representatives of the Society for the Study of Peace, Conflict and Violence. In COR, they worked collaboratively with a broad representation of divisional representatives and served as co-movers of the following APA resolutions: (1) Resolution Against Torture and Other Cruel, Inhuman, and Degrading Treatment or Punishment, 2006; (2) Reaffirmation of the American Psychological Association Position Against Torture and Other Cruel, Inhuman, or Degrading Treatment or Punishment and its Application to Individuals Defined as "Enemy Combatants", August 2007; (3) Amendment to the Reaffirmation of the American Psychological Association Position Against Torture and Other Cruel, Inhuman, or Degrading Treatment or Punishment and its Application to Individuals Defined as "Enemy Combatants", February 2008; and (4) Resolution that an Ad Hoc Committee of the APA Ethics Committee Review and Recommend Resolution of the Discrepancy between the Language of the Introduction and Applicability Section of the Ethics Code and Ethical Standards1.02 and 1.03, August 2008.

    She also served as member of the APA Presidential Advisory Group that produced the Report of the APA Presidential Advisory Group on the Implementation of the Petition Resolution to provide guidance to the APA Council of Representatives regarding involvement of psychologists in settings where persons are being detained unlawfully based on national security reasons (December 2008). She was a member of the team that supported Council action that made the petition resolution policy during the first Council meeting following the vote of approval of the membership (2009).

    She worked in collaboration with Judy Van Hoorn and other APA divisional representatives, the Ethics Committee, and the APA Ethics Office to offer language that contributed to the APA Ethics Code Amendment to Address Potential Conflicts among professional ethics, legal authority and organizational demands (that under no circumstances may standards be used to justify or defend violating human rights (2010).

    Comments on Draft One: We congratulate the Task Force for undertaking this important but complex and time-consuming initiative, which involves not only drafting a valid consolidation of existing policies, but reconciling the various, potentially contradictory comments and recommendations from so many consultants. As co-movers of several of the APA resolutions during our term on the APA Council of Representatives, we offer recommendations and comments in order to be helpful to the Task Force in achieving its mission. Our comments and recommendations are presented below and edits tracked separately in the proposed draft of the consolidated policy.The NBI: Reconciliation of Policies Related to Psychologists Involvement in National Security Settings proposes that APA Council of Representatives take several actions. The key recommendations we include below focus on the proposed consolidated statement of current policy, that is, the document the NBI asks be APPROVED by APA Council as the official 2012 statement of APA policy and publicized and cited as such. In addition to these recommendations, we include several comments regarding the expanded statement.

    I. NBI action item:
    Be it resolved that, Council APPROVES the attached "APA Consolidated Policy Concerning Psychologists Consultations in National Security Settings."

    Recommendations

    1. We recommend that this policy statement is presented as a complete, "stand alone" document, circulated in a separate file in order to make it very clear to readers that this is "the complete, accurate, and clear proposed statement of current policy." Since two similar documents are proposed, it is necessary to avoid confusion and misunderstandings now during the review process, in February on the floor of Council, and, if approved, later in the future when policy is being discussed or cited. (We recommend a "stand alone" file for each set of statements to clarify that their rationale and purpose differ.)

    2. We recommend that the following sections be included in the document to assure that the organization is clear and that readers can verify easily that the content of the consolidated policy is complete:
    3. Introduction that includes (1) a brief statement of purpose and rationale; (2) a list of policy documents cited; and (3) an explicit statement of the logic for the order of the policy statements, showing that subsequent policy statements follow clearly from earlier policy statements.
    4. Consolidated Policy text.
    5. For APA review process and submission to Council format so line numbers are shown.
    6. Appendix with APA resolutions, etc. that include the policy statements cited in the text of consolidated policy as well as the complete sections of Ethics Code that are included.
    7. For APA review process and submission to Council, we recommend that all documents or sections of documents be formatted to indicate line numbers.
    8. We recommend that an official and more complete title is needed for the Consolidated Policy.
    9. For clarity and consistency with policy, we recommend use of the phrase "psychologists involvement" (see NBI) or perhaps "psychologists' roles" (see Resolutions) because the phrase "psychologists consultations" has different meanings.
    10. Despite its length, we recommend a more comprehensive title that states explicitly that these policies relate to the APA position against torture and CIDTP. For example:
      APA Consolidated Policy Concerning Psychologists Involvement in National Security Settings and Reaffirmation of the APA Position Against Torture and Other Cruel, Inhuman, or Degrading Treatment and Punishment
    11. It is critical that this consolidated text not change policy.

      Your note to reviewers explains: "We are not creating new policy. We are unifying, consolidating, reconciling existing policy into a clear accurate statement of current policy."

    12. We think that the consolidated policy document is incomplete and thereby changes policy. If the consolidated policy document is not complete, it changes policy through omissions. We noted that a number of APA policy statements were omitted. We refer to ones that do not appear to be contradicted by more current statements nor restatements of other policy. In particular, please review the 2006 Resolution and the 2007 Resolution (amended 2008). As requested, we have attached a file that indicates most omitted statements of policy as well as suggestions for integrating them into the document.

    13. Rewording statements may change policy. Use exact quotes from the original source. Wording sometimes differs from the wording in the policy statements that Council approved. In our experience, there were often lengthy discussions of exact wording of the resolutions during the review process and on the floor of Council. We are concerned that Council, APA members, and the public may take any change in wording as reflecting a change in policy. We are also concerned that a change in wording will be seen as an invitation for further ?tweaking? and rewording that will result, de facto, in changes in policy.

    14. Show that the document is complete. To simplify the process of review and action by Council, show clearly that the consolidated policy document is complete and that all current policies statements are correctly quoted and are included without duplication. We found that reviewing a NBI a time consuming process for reviewers/readers. Council members will appreciate your clarity about what the consolidated policy contains and why a policy statement is omitted. and This will save considerable time prior to and during the COR meeting.
    15. Following each policy statement in the Consolidated document: Cite the original source and the specific line(s) quoted, e.g. 2006 APA Resolution Against Torture? (lines xx-xx)

    16. For each section of APA policy documents included in the current consolidated document, indicate where the section of the policy is included (quoted) e.g. Consolidated policy (lines xx-xx). If a section of APA policy is not included in the Consolidated document, give a rationale; e.g. "duplication of . . . "

    17. We recommend that the order of the ?Principles? be changed to clarify that all policy statements relate to APA human rights policies in keeping with the NBI statement, "whereas the human rights principles at the heart of the documents can become obscured."(See suggested Principle 1 in the attached document.)

      Note on the organization and length of document.

      We are aware that there are many distinct BE IT RESOLVED policy statements in the 2006 Resolution and the 2007 Resolution (amended 2008). We think that streamlining the consolidated policy document cannot be accomplished by omitting policy statements but through reorganization. We agree with the effort of the Task Force to streamline the document by identifying main policy statements as key principles and then organizing other policy statements as they relate to these principles.

    II. NBI action Item:
    Be it resolved that, "Council RECEIVES" the attached "Expanded Policy Statement and Brief Commentary for posting"

    We recommend that the title for this separate document should be changed from "Expanded Policy" to "A Commentary on the Consolidated Policy", so that it is clear that this document is not to be cited as APA policy.

    1. Policy Statement- See Recommendations above
    2. Brief Commentary
      Suggest that Task Force review "Whereas" statements that included in relevant resolutions. Many of these provide information and contextual information that, while not policy, relevant to the Commentaries.

    See also Policy Draft Edits: VanHoornOkoroduduPolicyDraftEdits.pdf