First, THANK YOU LIZ for posting this exhaustive critique of the IBLCE
Disciplinary Procedures sprung on us with no announcement, opportunity
for comment, or clue about why it was revised.  Liz's post should be
required reading along with the new procedure itself.
Who wrote this thing, some throwback to Sen. Joseph McCarthy?  Or
maybe further back, to the Salem witch-hunts?  It is unbelievable.
The idea that they can go fishing to find more evidence to incriminate
an IBCLC under investigation is just astonishing.
 'The Review Subcmte or staff "may at its discretion contact such
other individuals who may have knowledge of the facts ....".
LIz's comment on this: 'Wow.  It is unheard of, at least in USA
judicial proceedings, for judges and their courthouse clerical staff
to go out in search of evidence.  Rather, they ask the parties and
their lawyers to proffer evidence, under oath and rules of evidence
designed to promote the veracity of the facts.'

Me again:  Hear, hear!  It's unheard of in Norwegian judicial
proceedings too, as well as in intraprofessional disciplinary
proceedings, and hiring processes.  A prospective employer may only
contact those references provided by the applicant to find out about
the applicant.

This makes me very curious about the background of the IBLCE board
members, and even more curious about IBLCE's legal counsel.  Since
IBLCE seem to feel the need to ensure that they can make use of legal
counsel at every step of the way, it's not unreasonable to think that
said counsel were involved in the drafting of this procedure.  That
makes it even more bizarre, and much less reassuring.  What parallel
universe must they inhabit, to think that this is a Good Idea?

For me this is of little or no consequence, other than making me look
like a fool for having a credential awarded by this body, as I live
and work in Norway and my practice and employment are tied to my
licensure as a midwife only.  But for those whose IBCLC certification
is the minimum requirement for their employment, this is disastrous.

Rachel Myr
Kristiansand, Norway

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