Report from the 
United Kingdom Standing 
Conference for Psychotherapy

Emmy van Deurzen Smith

The Editors received a copy of the following report and decided to publish it as it con
tains useful information on the current situation regarding psychotherapy regulation in
 Europe, and while it is particularly pertinent to the United Kingdom situation, it is also
 valid for the Irish context.

Emmy van Deurzen Smith is the Director of the Antioch University Psychotherapy 
Training Programme at Regents College, London.

To put the issues that we are discussing in context it seems important to once more
 remind you of the situation on the European scene.

In the first place we need to remember that at the end of 1992 we will find ourselves 
in a European community that will gradually efface its frontiers. It is also good to keep
 in mind that English is going to be one of the official European languages which more
 and more Europeans will acquire. One of the effects of this is the likely increased interest 
on the part of our fellow Europeans to come to live and work in an English speaking

It is of course with these considerations of mobility of the labour force in mind that
 the commission in Brussels has been considering the setting of common standards for
 the professions. The professions in this context are loosely defined as occupations that
 are at least on graduate level.

Some professions now already have what are called sectoral directives, which are basi
cally European regulations on one particular profession that every EC country has to
 conform to. On this point it is vital to remember that EC legislation (although it isn’t 
yet called legislation) overrules national legislation when it comes to the crunch.

A good example of this is the general directive on the recognition of higher education
 diplomas or formal qualifications required for the pursuit of professions or other occu
pations. This directive was drafted by the commission to speed up the mutual recognition
 of diplomas in all those professions where sectoral directives had not yet been agreed in 
time for 1992 (some sectoral directives have taken years and years to agree, when a particular profession was set up rather differently in different European countries, with well 
established professional bodies fighting for their own corner. Whilst the general direc
tive is about mutual recognition of diplomas and equivalences, so that one does not have 
to requalify, sectoral directives are about harmonisation of professions and training standards across Europe).

The general directive was thus drafted and then sent through a long process of 
redrafting after consideration by the the different EC governments and representatives
 of the professional bodies concerned. Much of the important discussion on all of this 
took place within SEPLIS, the Brussels body for the Liberal Social and Independent 
professions, which functions as a watchdog and advisory body to the professions and rep
resents them at the commission.

The directive was agreed and accepted two years ago and we have now reached the stage where the British government has implemented it by having put through parlia
ment what is referred to as the “European Communities recognition of professional
 qualification regulations 1991”.

Since April 17, 1991 we find ourselves therefore in a position to have to recognise 
EC qualifications of a level comparable to ones’ own in a given profession. The power 
to set such a level of training is in the hands of what are now called designated authorities.
 These can check equivalences and decide whether a migrant needs an adaptation period 
or an aptitude test in order to practice a given profession in this country, but their deci
sions have to comply with the above mentioned regulations. Adult psychotherapy
 remains in the position of not being a regulated profession for the moment so that anyone 
can still work as a psychotherapist in this country.

Of course the general regulations are superseded in the case of a sectoral directive on 
a particular profession. There is now no doubt that the profession of psychotherapy, if 
it were to be regulated by the general directives would fall within the category of the 
first directive (not the second which is intended for vocational training of less than graduate level). It is also clear that a sectoral directive on psychotherapy could be negotiated 
at some point in the future. This would define psychotherapy as a profession with par
ticular competencies and training requirements and restrict its practice and title to those
 who fit the regulations.

There is little doubt that this is the route that the Dutch initiative on a European
 Association for Psychotherapy will have to take eventually (or in the very near future) if 
it is to have any significant impact at all. But before I go on to explain some of the advantages and disadvantages of the sectoral directive, there are a few more things to say about 
the general directive and its implementation.

As I mentioned before there is now a list of those bodies that have been assigned the 
status of designated authority in order to monitor and regulate the access to particular 
professions for migrants. It goes without saying that being given such authority amounts 
to being given the authority to regulate a profession full stop. In every case where there
 was a professional body incorporated by Royal Charter this body automatically became 
the designated authority. It is recognised by the DTI that further authorities will yet
 have to be designated for those professions not yet covered by existing ones.

It is important to note that with regards to employment in the National Health
 Service the following authorities have been assigned:

Art Therapists – Council for Professions Supplementary to Medicine
  • Dramatherapists – idem
  • Music Therapists – idem
  • Speech Therapists – The College of Speech Therapists
  • Clinical Psychologists – The British Psychological Society
  • Child Psychotherapists – Association of Child Psychotherapists

Also for state registered practice:

  • Occupational Therapists – The Occupational Therapists Board
Physiotherapists – The Physiotherapists Board

These are just some of the most relevant examples of professions that are now officially regulated. It is anybody’s guess where the adult psychotherapists will fit into the
 picture. But we will do well to remember that it is most likely that any request for the 
establishment of a competent authority in this area will be met by an exploration of the
 professional standards set with bodies already in place as designated authorities in adja
cent fields, such as the British Psychological Society, The Royal College of Psychiatry
 and the Association of Child Psychotherapists.

There is little doubt that not everybody agrees that UKSCP should be the designated
 authority in the case of adult psychotherapy. At the moment of course UKSCP is not 
even ready to register its national members, let alone take charge of the equivalences in
 terms of EC migrants. We will need at least a code of ethics and firmly established entry
 requirements and curriculum standards for training, before we are ready to claim author
ity. It would not be surprising to find that analytical adult psychotherapy is meanwhile
 rather closer to establishing a competent and to be designated authority in its own right.

It is therefore rather urgent for us to face these issues if we don’t want to let our 
authority as a broad professional body be gradually frittered away.

This brings me to the question of the EAP and the possibility of European standards
 and regulations on psychotherapy. I shall not speak of the issues around the selection of
 our own representatives on this body, but I want to say some words about the project 
itself and the speed with which it is taking shape.

In order to understand some of my concerns you will have to know a bit more about
 the implications of sectoral directives. So please bear with me as I relate to you the dif
ficulties some professions have experienced with sectoral directives. The example of the 
chartered surveyors is probably the most telling.

In spite of having a chartered body in this country the surveying profession did not
 exist anywhere else in Europe. When the sectoral directive on architecture was agreed
 the competencies of surveying were included in it, so that chartered surveyors cannot 
now legally practice in any other EC country whereas migrant architects can come over 
here and fill their jobs. You can imagine the impact something like this may have on the
 future of even chartered bodies as the community and mobility of the professions 
becomes a reality.

We must therefore be aware of the possible implications of a European Association 
for Psychotherapy as it makes moves to working out the requirements for a sectoral 
directive. The directive that would ensue could set standards that would in effect curtail
 the freedom of a British body to set its own standards in psychotherapy. Moreover it 
could overrule other, related, professions such as, for instance, counselling, if the specific 
competencies overlap. By the same token inaction on the part of psychotherapists in set
ting their own standards may result in another profession’s sectoral directive 
encompassing psychotherapy and superseding it as a separate profession.

When we remember that psychotherapy is in effect very much integrated with clinical 
psychology and psychiatry in European countries that do have regulation it becomes a
 real matter for concern that the EAP has selected only psychologists and psychiatrists 
on its steering committee.

The question that we need to ask is whether the profession of psychotherapy that the
 EAP aims to establish is the one we want. I have serious doubts about what is happening
 and I think you are entitled to know something about my own experiences and personal 
impressions, which I shall then leave you to judge by your own standards.

I made a point of checking back with the Dutch co-ordinator of the European
 Association for Psychotherapy about the progress of the EAP this week and I was told
 that things had gone very fast since December. When I asked why the next meeting was
 to take place in Brussels I was told that there was a logistic reason for this. When I prompted a little further I found that talks are not just planned with Brussels’
and with SEPLIS, but that they have already taken place.

When I asked why all of this had to be so secretive and claimed the right to know
 what exactly was happening, I was told that there was no question of co-operating with
 a democratic process at this stage. I was asked to remind you that this is a private initiative
 and that only those who have been selected onto the steering committee will be informed
 of the progress to date. Accountability will only be on the agenda after the steering committee has agreed statutes for the organisation and has defined the profession of 
psychotherapy and its standards.

When I suggested that such an attitude would giver a handful of psychotherapists in 
Europe the exclusive right to define and delimit the profession I was told that this was
 indeed the strategy opted for. When I enquired why only psychiatrists and psychologists 
were represented I was told that this was the standard aimed for and that, and here I 
quote, “the lay model of therapy has to disappear”. Apparently the Germans weren’t
 even willing to begin discussing a European standard until lay representatives were eliminated.

I was then reminded that the countries that already have regulations on psychotherapy are putting money and energy into this project so as to be able to guarantee a
 European outcome in line with the sort of standards in the countries in question. It was
 clear from my discussion that UKSCP has been extensively discredited in the process of
 selecting candidates for a European steering committee and that it had become a liability 
rather than an asset in terms of election onto the EAP steering committee.

Hearing these comments I was glad that we did have an EGM coming up to try and 
affirm some boundaries around UKSCP, so as to reaffirm a profession of psychotherapy 
that is broadly based. I have no doubt that if we want to have a voice, what is needed is 
for us to set clear standards and constitute ourselves into a British body for psychotherapy
 that can become a designated authority very soon indeed.

But it has also become increasingly evident that not all of us want this to happen
 through UKSCP. The setting up of EAP has made it abundantly clear that there are a 
number of organisations in the conference who have preferred to act under their own 
steam. I was sad that the letter that went out from these organisations to the Dutch was 
not made available for general circulation. What I object to is that this conference is not 
being used to discuss such matters and air the disagreements and tackle the conflicts. It 
defeats the purposes of the conference if people only come here as observers, whilst carrying out the real action elsewhere, behind the scenes.

Therefore, taking a leaf out of my own book, I need to say that, whilst I would have 
felt naively confident a year ago that the conference would speak for the profession, I
 now feel the need to ensure that I explore other contacts and different avenues. For it 
has become evident that not all of us have the same commitment to this organisation 
and it would be rather foolish to discover that the conference had just been a talking 
shop where some of us were kept occupied whilst others went out to bring home the 
bacon or the Brussels pate.

Emmy van Deurzen Smith, April 1991.