Yes, I'm finding quite a few issues so far. To pick one out as an example:
"Gender" is a belief, not a fact. The wording in the policy documents fails to acknowledge this. For example, quoting:
"Gender variant behaviours may start between ages 3 and 5 years, the same age at which most typically developing children begin showing gendered behaviours and interests (Fast et al, 2018)."
"Gender refers to the roles, behaviours, activities, attributes and opportunities that any society considers appropriate for girls and boys, and women and men" source: WHO website.
It should be clearly stated that this means people are being treated to change their physical bodies to address the psychological distress associated with not matching sex-based stereotypes. A wider review should consider whether this is a mental health issue and should go through the mental health treatment pathway.