Ms Amy O'Keefe:

We are here for the same reason, with a united goal: to ensure that the rights and freedoms of all disabled individuals are legally enforceable in all contexts. We are a group of behavioural scientists, practitioners and researchers who are actively working to promote a rights-based and values-driven approach to behaviour analysis in Ireland through awareness raising and education and by seeking the regulation of behavioural practitioners and services. We fully support the complete implementation of the UN Convention on the Rights of Persons with Disabilities, CRPD, and are grateful for the opportunity to discuss how behaviour analysis can be utilised in line with that.

Behavioural science is not inherently bad, and behaviour analysis is not a therapeutic intervention for autism; it is a neutral science with the potential for both ethical and unethical applications. Behavioural analytic strategies and principles are utilised across a wide and varied range of settings, including mainstream education, early childhood care, speech and language therapy, occupational therapy, physiotherapy, sports coaching, dance training, human resources and personnel management, the treatment of eating disorders, alcoholism and substance addiction, and typical "quit smoking" plans. Behavioural principles guide everything we do, from going to work to get paid, to going for an extra walk to reach your target steps on your Fitbit. Behavioural principles and behaviour analysis can explain why we do the things we do and are already a part of our everyday lives. Behavioural principles are a fact of life.

That said, significant concerns have been raised by the autistic community and others about behaviour analysis within disability services, and rightly so. Behaviour analysis has a troubled history, and although the application of the science has changed dramatically over the past 50 to 60 years, the behavioural community recognises and strongly opposes the fact that there are still examples of unethical practice within the field. Behaviour analysis should never be used with the goal of normalising or making a person "less autistic" and should always consider a person's values to create supportive and adaptive environments. For me, as an autistic person, the problems with behavioural science and the application of behavioural principles arise when they are used to teach blanket compliance for the sake of compliance or unwanted masking strategies and to encourage the appearance of normativity or neurotypicality. Fortunately, the notion of being "indistinguishable from peers", once espoused by practitioners in the field, has been long since dismissed as inappropriate and harmful.

Many neurodivergent and autistic individuals believe that behaviour analytic services and supports are important and can be offered within a framework that values and respects neurodiversity. Neurodivergent individuals may shy away from speaking positively about behaviour analysis because, at times, "those who express unpopular opinions ... are often attacked and excluded from neurodivergent communities". We want to support a society where every person has the freedom to access information and express their opinions. We wish to engage with those who have concerns about behavioural interventions via open and respectful dialogue. For example, ISBA is establishing an experts by experience panel, which will have a decision-making role in the organisation, a defined role in our feedback and complaints policy and a role in developing mandatory continuing professional development, CPD, for our members. We hope that actions such as these can contribute to mutual understanding and truly neurodiversity-affirmative practices.

Behaviour analysis and the neurodiversity paradigm are not mutually exclusive, nor are they incompatible with each other. As the neurodiversity paradigm has become more widely disseminated and understood, an international movement of behaviour analysts, among many other clinical fields, has shifted practice to become respectful and affirming of neurodivergences. Behaviour analysis should always take a values-based and learner-centred approach that values neurodiversity and prioritises the well-being of those with disabilities, in line with Article 26 of the UNCRPD. The goal of neuro-affirmative behaviour analysis is not to encourage normativity or neurotypicality but to support learners in developing the skills they themselves need to access the environments, activities and communities they themselves want to access.

There are numerous examples of behaviour analysis valuing neurodiversity and prioritising the well-being of those with disabilities. For example, incorporating meaningful choice making; training in the use of augmentative and alternative communication, AAC, devices; using task analysis to empower people in completing activities of daily living, for example, to teach menstrual hygiene; using virtual reality to prepare autistic people for interviews; employing video modelling to teach job skills; supporting self-advocacy and self-determination; using acceptance and commitment therapy and relational frame theory models to identify values and work towards valued goals; informing ethical decision making for practitioners; and promoting trauma-informed approaches. Behaviour analysis has the potential to significantly improve the lives of those who need it most when offered in a neuro-affirming manner. We see this as being particularly important in reducing restraint and exclusion.

Unfortunately, some people with disabilities can experience significant behavioural support needs that can cause a risk to their physical safety and the safety of their families and those who support them. These behaviours can include self-injurious behaviours, physical behaviours towards others and other responses that severely impact their quality of life. Today in Ireland people experiencing these behavioural health concerns are subject to arbitrary restrictions on their fundamental human rights, including physical restraint, seclusion and polypharmacy. It is clear that these people suffer the greatest limitations on their human rights and fundamental freedoms. The behavioural science community is at the forefront of supporting these people, their families and those who support them to reduce these risks and safely remove these restrictions. What is critical is to ensure that those experiencing significant behavioural support needs have access to qualified, trained and regulated multidisciplinary teams.

Behaviour analysts in Ireland want regulation and to ensure that practitioners in the field are operating within a human rights framework, professionally and without causing harm. The regulation of behaviour analysis in Ireland will allow for the creation and enforcement of strict ethics and professional conduct codes that will be created with the neurodiversity paradigm, human rights, disability rights and autistic values at their heart. We have the opportunity in Ireland to create the first fully neuro-affirming culture of behaviour analysis, not just pockets of ethical and respectful neuro-affirmative practitioners but entire systemic reform.

I presented a symposium on neurodiversity and ABA in Ireland at the 16th annual division of behaviour analysis, DBA, conference two weeks ago. I also took part in a keynote panel discussion entitled, "Neuroaffirmative voices reflected in behaviour analysis", along with two other neurodivergent and autistic behaviour analysts. If attendance and feedback from colleagues is indicative of anything, it is that there is a huge appetite for change within our field, a stark willingness to listen to autistic voices on the risks and harms that behaviour analysis can pose when not applied with respect to and understanding of neurological differences and neurodivergences, and a drive to address and eradicate harmful practices.

In the interim, we are committed to developing mandatory continuing professional development for our members, in consultation with divergent communities, where we aim to directly address Article 8 of the UNCRPD. Both the ISBA and the DBA have registers of behaviour analysts and behavioural psychologists, who have met a defined standard of education and training. In addition, the Psychological Society of Ireland, PSI, has accredited masters courses in ABA in Trinity College Dublin, TCD, and the University of Galway. Graduates from those courses who meet the PSI’s education and experience criteria can register as chartered behavioural psychologists. We will develop practice standards for behaviour analysts and psychologists in Ireland that ensure alignment with the UNCRPD and any legislation designed to support its implementation.

Ultimately, banning ABA will not protect anyone from harm as the application of behavioural principles occurs within every walk of life. Instead, a ban will result in further risk of harm to vulnerable populations by exposing them to people who are untrained and unaware of the full impact of behavioural principles. Instead, we propose that behaviour analysis is regulated in Ireland so that those of us who already practise ethically, safely and neuroaffirmatively can continue to do so, while those who fail to engage in the relative neuroaffirmative learning and practice cannot continue.