Please take a break & really sit back and take an honest look at the situation.
The whole premise of sexual intent being some kind of high bar to pass is a red herring, as Wendy points out.
With some honest reflection you would find that the behavior speaks for itself.
If you still struggle, try this experiment: just go down to you local police station and tell the duty officer that later that evening, you plan to take a 12 year old boy from your neighborhood to a deserted fitness center & take a nude shower with him. Be sure to add that you will be blowing raspberries below his belly button and will also grab him from behind & lift him up to show the boy how to rinse his hair. Emphasize that this is going to be just an experiment, and that there's no sexual intent.
When you get out of the mental institution where you will have been committed, report back to the board on what you've learned.
It's simply not possible for reasonable citizens to believe that there is any way that the behavior does not include sexual intent. It is incomprehensible.