IBLCE has withdrawn Continuing Professional Development points (CERPs) from evidence-based breastfeeding and lactation education
Please consider signing the petition available here.
For three decades, my life work and passion as a GP, researcher, International Board Certified Lactation Consultant (IBCLC), and breastfeeding medicine physician has been foundationally driven by my commitment to improved outcomes for breastfeeding women and their babies. Moreover, as an Australian GP, I have a responsibility according to my profession's Code of Conduct to "protect and promote the health of individuals and the community".
In an email sent 23 November 2023, the International Board of Lactation Consultant Examiners (IBLCE's) office manager for Australia, Asia Pacific and Africa did not specify why IBLCE had rejected The NDC Institute's application to attribute Continuing Education Recognition Points, L CERPs and R CERPs to my breastfeeding and lactation related courses, which are known as the NDC or Possums programs. But in earlier communications, both the Lactation Consultants of Australia and New Zealand (LCANZ), in a 2019 email to all its members, and the IBLCE, in response to my 2022 application, falsely accused my work of violating the World Health Organisation's (WHO) Code for the International Code of Marketing of Breast-Milk Substitutes. The WHO Code, here, is summarised by the Australian Breastfeeding Association here. The deplorably exploitative marketing practices of formula companies have been recently detailed in major reports by the WHO, here. But the NDC or Possums courses are free of conflicts of interest as defined by the WHO Code and WHA resolutions.
LCANZ and IBLCE claim that I am in violation of the WHO Code because Professor Donna Geddes and Dr Sharon Perrella from the world-leading Geddes Hartmann Human Lactation Research Group (GHHLRG), The University of Western Australia, have been second or third authors on two of my 30 research publications. Research from the GHHLRG has fundamentally changed international understandings of lactation science, and fundamentally changed information taught around the world by educators in the field of breastfeeding and lactation. These two publications, of which I remain proud, are here and here.
Targeting the NDC or Possums programs compromises IBLCE's credibility as a science-based organisation
On 29 October 2022, in response to my email raising concerns about IBLCE's weaponising of the WHO Code, Dr Laurence Grummer-Strawn, Unit Head of Food and Nutrition Action in Health Systems, WHO, wrote
[Concerning] interpretation of the Code ... There are many ambiguities regarding the prevention and management of conflicts of interest and there is no specific policy from WHO ... The issue of how to treat receipt of research funding is particularly problematic. WHO has not taken a specific position on this.
IBLCE's credibility as a peak professional body is further undermined by lack of transparency and due process. For example,
I've received no professional communication from IBLCE explaining how my two publications with Professor Geddes and Dr Perrella impact negatively upon breastfeeding women and their babies, or how these publications actually violate the WHO Code
I've received no professional communication explaining
The date from which the sanction became effective
Pathway for repair
The date upon which the sanction ceases.
How does this ban impact upon the NDC or Possums programs and The NDC Institute's capacity to survive commercially as a lactation education organisation?
IBLCE's decision to label me a WHO Code violator inflicts financial and reputational damage upon my professional life and The NDC Institute. This damage includes
Withdrawal of three invitations formally extended to me in the past 18 months to be a guest speaker at national conferences for IBCLCs (Quebec, Taiwan, and Denmark). Each invitation was withdrawn after the organisers learnt that IBLCE would not allow them to attribute CERPS to my presentations. Conference organisers need to provide CERPs in order to attract the attendance of IBCLCs and remain financially viable. Each withdrawal significally impacts not only upon my reputation but upon the growth and uptake of the NDC or Possums research and programs internationally.
Decreased opportunity for local or international lactation-related speaking engagements, because word spreads so that invitations are no longer extended.
Disincentivising IBCLCs to participate in The NDC Institute's courses, because
IBCLCs need to receive CERPs (in order to support their ongoing professional certification) when they invest time and money into professional upskilling
There is stigma attached to IBLCE's decision that the NDC or Possums programs can no longer attribute CERPs. Most IBCLCs place trust in their peak international professional organisation and are likely to believe in the veracity of the false accusation made against me.
Rejection of a paper submitted to the Journal of Human Lactation, not due to academic merit or lack thereof, but because the Editor concluded that my team were WHO Code violators.
Are there reasons why IBLCE has taken steps to harm the commercial viability of the NDC or Possums lactation-related education courses?
It's clear that IBLCE's decision to withdraw my rights to attribute CERPs is not based upon a concern to protect breastfeeding women and their babies, because
Other breastfeeding and lactation businesses, who continue to receive CERPS from IBLCE, use educational materials which rely upon research papers published by GHHLRG, without sanction. Because of the ground-breaking research published by the GHHLRG over many years, any failure to use their research findings renders education courses outdated, and not evidence-based
My right to work with breastfeeding women and their babies as an IBCLC (qualification first achieved in 1994, most recently renewed in 2022) has not been withdrawn by IBLCE, suggesting that IBLCE does not genuinely believe that my work poses a threat to breastfeeding women and their babies
The co-authors of my two offending publications receive their research funding through usual university mechanisms, which protect independence of research. The various contributors to their research funds are always appropriately declared. Moreover, my co-authors had no involvement in the development of my studies (one of which was entirely theoretical, the other a small case series evaluating implementation of the gestalt method, developed years prior).
What other reasons could there be then to explain why IBLCE, which represents 37,000 IBCLC-members globally, uses commercial levers to exert control over which lactation-education businesses succeed and which lactation-education businesses fail? Has IBLCE become subject to industry capture?
NDC or Possums programs are evidence-based and challenge widespread overdiagnosis and overtreatment of breastfeeding women and their babies. The programs and my research publications continue to critique popular approaches applied by many IBCLCs around the world, which are taught to IBCLCs with CERPs attribution even when there is an absence of corroborating research, or when the research directly shows lack of efficacy.
Could it be that the reason why IBLCE has refused to attribute my courses with L CERPS and R CERPS, after previously endorsing them, is that I was the first internationally to publish critiques of
The diagnosis of posterior tongue-tie
Frenotomy overuse?
Could it be that IBLCE refuses to attribute my courses with CERPs because I have spoken out about applications of chiropractic, orofacial myofunctional therapy, osteopathy and other bodywork therapies for breastfeeding infants, which unnecessarily pathologise, are not supported by credible evidence, and which create unnecessary expense and anxiety for parents? Bodywork therapists and tongue-tie professionals have become prominent industry groups within the fields of breastfeeding and lactation healthcare provision and education. LCANZ, for example, asks IBCLCs to tick their 'Areas of Expertise' as they promote their services on the LCANZ website. These areas of lactation consultant expertise, now normalised in the treatment of breastfeeding women and their babies despite absence of evidence of efficacy, include 'Post Tongue tie Rehabilitation', 'Breathing Therapy', 'Massage', and 'Fascia Release'.
In my view, attempts to silence dissenting interpretations of the research and to damage the NDC or Possums programs capacity to survive commercially in the field of breastfeeding and lactation support constitutes anti-science.
Why are senior professionals in breastfeeding advocacy networks silent on this issue?
There is silence by senior professionals in breastfeeding and lactation advocacy communities and breastfeeding medicine networks on this issue. This silence
Condones IBLCE's anti-science stance
May be driven by fear of being exposed to social media and other backlash in breastfeeding advocacy communities, with potential impact upon not only their own reputations, but upon the viability of their own conferences and upon their own small clinical and education businesses
Is unethical. By remaining silent, these professionals and their professional networks may find themselves either
Drawing upon and influenced by research from GHHLRG, and also research and education programs by myself, but unable to appropriately acknowledge the source of this work, or
Avoiding any reference to GHHLRG research and my own work, which means that they are selectively ignoring available evidence, which is unscientific.
When we as a professional community remain silent about unethical or unjust behaviours in our ranks, then our silence not only condones injustice or unethical behaviour, but perpetuates it.
IBLCE's weaponising of the WHO Code fails to protect, and impacts negatively upon, the wellbeing of breastfeeding women and their babies
The NDC or Possums programs, which directly contest overdiagnosis and overtreatment, have been shown to be effective in eight preliminary evaluations to date. IBLCE's attribution of CERPS to non-evidence-based lactation education, whilst actively silencing or 'cancelling' genuinely evidence-based and innovative lactation education, inevitably impacts negatively upon the wellbeing of breastfeeding women, their babies, and their families.
I work independently and my 30 research publications over the past two decades have been a labour of love. Weaponising the WHO Code against a single, small, self-funded researcher and educater with a view to stigmatising and excluding her breastfeeding-related work internationally does nothing to address the complex problems posed by formula companies, including deplorable marketing practices, nor does it do anything to address unethical promotion of breast milk pumps, bottles and teats.
Unrestrained corporate or industry self-interest is a major driver of the global trend to overdiagnosis and overtreatment in healthcare, including in the care of breastfeeding women and their babies. Unrestrained corporate self-interest is a complex and existential problem, which not only inflicts harm upon breastfeeding women and their babies globally, but also undermines democracy, ravages the natural environment and climate, and threatens our very survival upon this earth.
Intelligent, effective, and highly ethical responses to the excesses of corporate power are urgently required, from governments, governance structures, and from each of us as best we can.
IBLCE's decision to 'cancel' the NDC or Possums programs by withholding CERPs attribution has nothing to do with the wellbeing of breastfeeding women and their babies. As a response to corporate excess, IBLCE's decision is neither effective nor ethical.
I invite you to sign a petition which asks IBLCE to reconsider the ban of the NDC or Possums programs from L CERP and R CERP attribution rights, found here.
Kind regards
Pamela Douglas
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