Tin - I cannot see any safety issues in that, but I guess the whole thing hangs on the 'clearance'? A procedural 'clear for ILS R22 via the BN' implies route TO the BN at which point the 'procedure' should begin - either the teardrop or the hold entry to the ILS. I would have thought that a simple call to ATC asking for 'selfposition' would have cracked the problem?
Incidentally, if the chart is accurate?? the BN is not 'on' the localiser.