239. Such practices contradict standards that forbid medical personnel from taking part in torture, directly or indirectly, by certifying detainees’ fitness for interrogations, assisting or even merely being present during abusive interrogations for the purpose of stepping in, if necessary, and providing knowledge to facilitate ill-treatment, such as information contained in detainees’ medical records.484 240. In this regard, ODIHR takes note of the independent review launched in November 2014 to determine whether American Psychological Association (APA) officials had colluded with the Department of Defense, the CIA and/or other government officials “to support torture” during the Bush administration. The report, published in July 2015, determined that “key APA officials” did in fact collude with “important DoD officials to have APA issue loose, high-level ethical guidelines that did not constrain DoD in any greater fashion than existing DoD interrogation guidelines” and “to defeat efforts (…) to introduce and pass resolutions that would have definitively prohibited psychologists from participating in interrogations at Guantanamo Bay and other U.S. detention centers abroad”. It also concluded that “current and former APA officials had very substantial interactions with the CIA in the 2001 to 2004 time period, including on topics relating to interrogations, and were motivated to curry favor with the CIA in a similar fashion to DoD.” 485 241. Following the publication of the report, the APA Board recommended, among other things, the adoption by its Council of Representative of a policy prohibiting psychologists from taking part in the interrogation of detainees held in custody by military and intelligence authorities, whether in the United States or elsewhere, but “allowing training of military personnel on recognizing and responding to persons with mental illnesses, on the possible effects of particular techniques and conditions of interrogation and other areas within their expertise”.486 INVOLVEMENT TREATMENT OF OTHER OSCE PARTICIPATING STATES IN ACTS OF TORTURE AND ILL- 242. While the CIA RDI programme was developed by the United States, its implementation was only possible through collaboration with other states. As many as 54 countries, 484 Istanbul Protocol, op. cit., note 313, paras. 52-53; UN Special Rapporteur on Torture, “General Recommendations of the Special Rapporteur on torture”, op. cit., note 313, para. n; UN Special Procedures, “Situation of detainees at Guantánamo Bay”, op. cit., note 23, paras. 73-75. See, also, “Principles of Medical Ethics”, op. cit., note 313; “Declaration of Tokyo”, World Medical Association, op. cit., note 313. 485 “Report to the Special Committee of the Board of Directors of the American Psychological Association, Independent Review Relating to APA Ethics Guidelines, National Security Interrogations, and Torture”, Sidley Austin LLP, 2 July 2015, pp. 1, 9-10, <https://assets.documentcloud.org/documents/2160985/report.pdf>. See, also, ibid., p. 70: “By explicitly declaring it ethical for psychologists to be involved in interrogations of detainees in DoD or CIA custody, while not setting strict and explicit limits on a psychologist’s involvement in the intentional infliction of psychological or physical pain in these situations, APA officials were intentionally setting up loose and porous constraints, not tight ones, on this particular use of a psychologist’s skill. This was especially true in the context of the time, which included (i) the government’s known legal contortions that sliced the definition of torture down to a fragment, (ii) the widespread and credible claims that this kind of abuse had occurred, and (iii) the existence of a large loophole in the Ethics Code that allowed CIA and DoD psychologists to follow explicitly unethical orders and still be considered ethical as long as they tried to “resolve” the conflict.” 486 “Press Release and Recommended Actions: Independent Review Cites Collusion Among APA Individuals and Defense Department Officials in Policy on Interrogation Techniques”, APA website, 10 July 2015, <http://www.apa.org/news/press/releases/2015/07/independent-review-release.aspx>. 104