The memo's authors appeal to science, but referring to biological traits such as genitals and genes does not make their definition of sex scientific. This selective definition of sex deviates from scientific consensus about the nature of human sex and gender. 

The SWHR task force operationalizes ‘sex’ and ‘gender’ as research variables with sweeping explanatory potential in biomedicine. The manner in which they do so reveals a theoretical gulf between a widely practiced genre of bioscience knowledge production in women’s health research and critical feminist approaches to science, medicine, and the body.