Comments on IBLCE Code of Conduct

[Guest guest]

Dear IBCLCs and Breastfeeding Advocates,

The

Board of Directors of the International Board of Lactation Consultant

Examiners® (IBLCE) is providing the opportunity for public comment regarding

the " Code of Professional Conduct for IBCLCs "

(International Board Certified Lactation Consultants), which will replace the

" Code of Ethics for IBCLCs " .

This is an extremely important issue for IBCLCs. Please take time to read

about this and consider. Below I have pasted my comments to the IBLCE and

attached is the current Code of Ethics.

To

submit your own brief and concise comments, please click here to fill in a comment box.

All comments must be submitted by Wednesday, September 7, 2011. Please be

aware that while some comments may be included in the revised document,

providing commentary does not guarantee changes.

Read the Code of Professional Conduct

Submit your comments

Thank you,

IBLCE Board of Directors and Staff

Dear Colleagues in IBLCE:

Thank you for the opportunity to comment on the proposed

new Code of Professional Conduct for IBCLCs.

I am writing to you as an IBCLC working in private

practice, in a physician practice, and in public health. I am also Chair of the

USLCA Licensure and Reimbursement Committee.

Regarding USLCA's work in advocating for licensure and

reimbursement of IBCLCs, we rely heavily on the published Professional

Standards for IBCLCs. Changes in these standards, including this proposed

change to Code of Ethics will affect our work since these standards have been

shared widely with legislative and administrative authorities in government,

health and insurance fields as evidence of the solid foundation for IBCLC

certification. Changes must not be made in a cursory manner. Should the new

document be adopted, I would like some information regarding the rationale for

these changes that I could share with these authorities who are already

considering the former documents.

In general, I see the plain language in the new document

is an improvement in readability for anyone wishing to know about the IBCLC

required conduct; however I find some of the content changes troubling.

Preamble

I dislike the links to other documents in this paragraph. When we

distribute the current Code of Ethics to interested parties in advocating for

the IBCLC, they may only have a print copy and they would be unable to access

these other documents. Additionally, this would require those who do have

access to the embedded links to read four other documents in order to

understand our Code. If these documents are to be referenced, the relevant text

should be included within the Code of Conduct rather than links.

The following statement seems erroneous to me, “IBLCE was founded

to further broad principles of human rights

articulated in numerous international documents stating that all members of

society have the right to the highest attainable standard of health, including

the woman’s right to breastfeed and the child’s right to be

breastfed.” The statement is followed by links to four documents, two of

which did not exist when IBLCE was founded. Though the language doesn’t

technically say it was founded on these specific documents, it reads that way

and I think it is misleading.

Additionally, it is always my understanding that IBLCE was founded to

provide a means of establishing the standard for the “well-trained

lactation professional”, the “lactation consultant,” and a

means of identification of the IBCLC certification as the gold standard for the

profession. The “further broad

principles of human rights” reads to me like an attempt to

advertise or lobby for the profession using social media marketing tactics,

rather than to define our professional responsibilities.

“Encourages” as the verb used in this sentence “IBLCE

encourages IBCLCs to uphold the

highest standards of ethical conduct…” weakens the requirement to

maintain the “highest standards”. I think this sentence deserves a

stronger verb making adherence to these standards an obligation, not an option.

Of specific concern, is the removal of the following statements from

the Code of Ethics?

a.

" The purpose of the International Board of

Lactation Consultant Examiners (IBLCE) is to assist in the protection of the

health, safety, and welfare of the public by establishing and enforcing

qualifications of certification and for issuing voluntary credentials to

individuals who have attained those qualifications. IBLCE has adopted this Code

to apply to all individuals who hold the credential of International Board

Certified Lactation Consultant (IBCLC). "

b. And, “The

International Board Certified Lactation Consultant shall act in a manner that

safeguards the interests of individual clients, justifies public trust in her/his

competence, and enhances the reputation of the profession. The International

Board Certified Lactation Consultant is personally accountable for her/his

practice and, in the exercise of professional accountability, must…”

These statements seem to be replaced with,

" To guide their professional practice, it is in the

best interest of all IBCLCs and the public they serve that there is a Code of

Professional Conduct which:

• Informs both IBCLCs and

the public of the minimum standards of acceptable conduct;

• Exemplifies the commitment

expected of all holders of the IBCLC credential;

• Provides IBCLCs with a

framework for carrying out their essential duties;

• Serves as a basis for

decisions regarding alleged misconduct "

This change has serious implications for the future of

licensure for IBCLC because it drastically weakens the IBCLC certification as a

basis of ‘consumer protection’. The entire new document now seems

to have its focus on the IBCLC rather than the “protection of the health,

safety, and welfare of the public”. This is a serious problem as it

relates to proposed licensure legislation in several states where we have

language that joins licensure to the IBCLC certification for the purpose of

public protection. By writing licensure bills which require the IBCLC

credential as the basis for licensing, we can avoid the necessity of creating

and administering a separate exam and exam board for IBCLC licensing, thus

saving appreciably on costs of licensure fees which must cover the maintenance

of the governing board. Without this language, it would be cost-prohibitive for

the small number of IBCLCs in each state to support a licensing board. Therefore,

it is doubtful that licensure could be attained in any state.

Under Definitions and Interpretations statement 1, “For the

purposes of this Code of Professional Conduct for IBCLCs, this document will be

referred to as the ‘Code’.” could create confusion. The

“Code” in IBCLC language has always been used to refer to the

“WHO Code”. Could this be changed?? Perhaps change to “Code

of Conduct”.

Principle 1. Provide services that

promote, protect and support breastfeeding

1.2 I like inclusion of this statement, “Provide care to meet

clients’ individual needs that is culturally appropriate, evidence based,

comprehensive, and up to date.” Sadly, I have noted more than a

few IBCLCs practicing without staying current. I would like to see the word

“current” in place of “up-to-date”.

1.4 “Convey accurate, complete and objective information about

commercial products (see Principle 7.1).” Reference to 7.1 doesn’t

quite make sense to me, what does that mean specifically? How do we provide complete information about products we may

not have information about or personal experience with? Are we expected to have

detailed technical knowledge of every pump, pillow, galactagogue and gadget on

the market? I think the former statement was more practical, “Provide information about appropriate products in a manner

that is neither false nor misleading.”

1.5 I think there is a fine line between calling an action

“personal bias” and “an IBCLCs practical experience” as

noted with legitimacy in the definition of evidence-based. How would you

explain the difference?

Principle 2. Act with due diligence

Under this section, it seems that the obligation

to inform the client from the former Code of Ethics has been left

out.

“11. Provide sufficient

information to enable clients to make informed decisions.

18. Present substantiated information and

interpret controversial information without personal bias, recognizing that

legitimate differences of opinion exist.”

I think it is important to keep these items in the Code of Conduct as

protection for the public and the IBCLC. Some health care professionals have

bias against certain information or alternative health care practices that may

be helpful to clients and these statements protect the IBCLCs right, and

obligation, to give evidence-based information, within our scope of practice,

that another health professional might suggest or require the IBCLC withhold.

Examples of information that might be withheld might, existence of infant with

a tight frenulum, use of herbal products or acupuncture, use of test weights

for estimation of intake at the breast, etc.

Principle 4. Report accurately and

completely to other members of the healthcare team

The articles in this section are ambiguous do not clarify the

obligations to report.

c.

Is there an obligation to report to the mother and /

or baby’s PCP “every” encounter, initial and follow-up? For

example, an IBCLC in private practice may not always send a report of her

visit. Is that acceptable? What if a mother does not have any PCPs? Or does not

want her visit reported to a PCP?

d. Can the IBCLC report only when the plan

of care changes with an ongoing problem? Or periodically?

e. Can the IBCLC report only to the

mother’s PCP if it is primarily a maternal issue, for instance plugged

milk duct? Or only to the baby’s PCP if it is a sucking problem when

mother has no problems?

Principle 7. Uphold the professional

standards expected of an IBCLC

The requirement to report unethical practices has been removed. What is

the rationale for this?

“Accept the obligation to

protect society and the profession by upholding the Code of Ethics for

International Board Certified Lactation Consultants and by reporting alleged

violations of the Code through the defined review process of the IBLCE.”

I hope you will take these comments into serious consideration prior to

changing the current Code of Ethics.

Thank you for your time and attention to this matter.

Sincerely,

Judith L. Gutowski, BA, IBCLC, RLC

1 of 1 File(s)

IBLCE_Code_of_Ethics.pdf