Fay, I would encourage you to contact IBLCE, as a certificant, and share
your views about this document.  This is very much a fait acccompli.  These
documents apply to and are effective NOW against all IBCLCs.

The only power we have as certificants, over any policy making at IBLCE, is
to communicate:  call, e-mail, write, fax  IBLCE.  It rather begs the
question of how we can offer suggestions and guidance, as practitioners in
the field, about the practice-guiding documents which are "our law," if we
don't even know that the materials are under review and revision.

 IBLCE opened a 2-week public comment period for review of the
[then-proposed] IBLCE CPC.  C'mon -- how hard would it have been to say,
"Oh -- by the way -- we are also totally rewriting the enforcement
mechanism for the IBLCE CPC.  Tell us what you think of that, too."

IBCLC certificants have exerted pressure on IBLCE "from the ground up" on
many matters in recent years: scope of practice, second credential, revised
education requirements, revised CERPs approval guidelines, etc.  I find it
exhausting trying to keep track of what is going on at IBLCE, and then
having to react on a "done deal."

Another option is to review the Standards issued by the NCCA - National
Commission for Certifying Agencies -- which accredits IBLCE's exam-testing
authority.  NCCA operates under the auspices of tthe Institute for
Credentialing Excellence.  Every five years IBLCE must file an application
to renew its rights to give the IBCLC certification exam.   In order to be
granted the continuing certification-exam authority, IBLCE must show it
meets the Standards established by NCCA,
http://www.credentialingexcellence.org/portals/0/STANDARDS%20-%20Updated%20January%202010.pdf
.

At Standard 6.D., we are told that, for any entity offering a certification
exam:   "Disciplinary policies must include procedures to address
complaints that may concern conduct that is harmful to the public or
inappropriate to the discipline (e.g., incompetence, unethical behavior, or
physical/mental impairment affecting performance). These policies must
ensure appropriate treatment of sensitive information and ****fair decision
making****." (emphasis added).

You tell me: Are the 24 Sept 2011 Discipline Procedures an example of fair
decision making?

Better yet -- tell them.
-- 
Liz Brooks JD IBCLC FILCA
Wyndmoor, PA, USA

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