Rather than create a new category of lactation assister (for want of a 
better term), I'd like to see the IBLCE focus its time and energy on a 
long-range strategic plan, including administrative re-organization.

(1)  Under the current bylaws, ethics complaints about IBCLCs are to be 
filed in writing with the Discipline Committee of the IBLCE Board, which has 
power to inviestigate and sanction the Code-of-Ethics violator.

But what if someone has a complaint against one of the members of the IBLCE 
Board?

It is an inherent conflict of interest to have the board investigate and 
possibly sanction "one of its own."  That model, currently used by the U.S. 
House of Representatives' Ethics Committee, doesn't work very well.  A 
better system is using an outsider -- an independent counsel or arbitrator 
-- with powers to investigate, report, and recommend sanctions.

(2)  Under the current bylaws, amendments to the Code of Ethics can be made 
by motion and vote at an IBLCE Board meeting.  But the Code of Ethics 
carries such weight and authority that amendments to it should come after 
the Board has solicited input from as many interested parties as possible.

The U.S. Congress does it well here:  bills are discussed and debated in 
hearings (on the record, no less) before they ever reach the floor for a 
vote.

The recent addition of Principle 25 (all IBCLCs must abide by patent and 
copyright laws) stirred tremendous debate and angst on Lactnet.  (Many 
object to the patenting of human milk components, and want to fight such 
commercial efforts without the risk of losing their IBCLC credential.  
Gerber was able to win on trademark grounds a challenge in Guatemala to its 
use of its WHO-Code-violating logo.)  I'd like to think the IBLCE Board 
would have benefitted from the vigorous debate *before* it took action (if 
at all) to use the Code of Ethics as a vehicle for supporting intellectual 
property rights.

I do recognize and applaud the effort that has been taken by IBLCE to 
generate comments on its proposal to add another certification program.


Liz Brooks, JD, IBCLC
Wyndmoor, PA, USA

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