Safetypee,
QED! In so much as we are getting confused and we are not even flying...
I read the chart (and it is a while too since I flew in the US) as use the IRK initially for the arc and then the IIRK for distance when on the LOC. For a straight in, then yes it's straight to the IIRK. But if you were planning your descent from afar, I guess you may not be able to get the IIRK, so the IRK would give you a good TOD. Please feel free to correct me - I am regularly wrong! Much more likely to be the MCM/IIRK error though.
Good, safe, naming convention, don't you think?
Also, we must remember that 100 other things could cause this accident.