I posted on this subject previously but perhaps my thoughts are worth repeating.
I dont understand the magic of the FAF. The CAA took the view that IMCr holders might struggle to fly to the required tolerances close to the ground. In consequence they recommended IMCr holders adopt a higher DH that IR holders. In that there is sense. The pilot has been restricted by a parameter which is directly related to the skiils he is required to excercise. On the other hand the FAF is not asscoiated with any parameter of which I am aware in the same way. It could be overhead the airfield at 1,600 feet or it could be ten miles from the airfield at 4,000 feet.
I assume that it was felt because the FAF defines the point at which the pilot enters the "arrival process" this is also the point at which the pilot starts to fly a more complicated procedure with the propensity to "screw" up.
In reality few arrivals will be procedural these days, and for most of us wanting an easy life we will routinely accept vectors. It also seems to be worrying that a pilot is aqualified to fly airways cant be trusted to accurately fly vectors in IMC to a reasonable tolerance.
For these reasons using the FAF as the point of defining where the pilot's skills dont correspond with the task in hand doesnt make a great deal of sense.
If the pilot is to be restricted, he should be restricted by his actual skill set.
My experience is that many pilots struggle to fly a complicated procedural approach. It is also my experience that many pilots struggle to fly the final part of an ILS accurately. However, pilots are pretty good at accepting vectors.
For all of these reasons it seems to me than an EIR holder should be allowed to accept vectors to the top of the glide slope. Whether he should be allowed to continue some way down the glide slop is debatable and would depend upon how much ILS training was included in the syllabus. If it was felt that he should not continue down the G/S unless visual at the top of the G/S I dont see this an issue. The pilot would fly the missed and AT would be well accustomed to pilots going missed albeit usually from a lower level.
It could be argued that if the pilot went missed at the top of the G/S he would now have to fly the missed procedure for which his skill set was lacking. Well that is where an approach ban could be useful. In other words if the METAR wasnt giving a cloudbase above the top of the G/S the pilot would be required to divert - simple and clear, and reliant on an accurate and current definition of the conditions, unlike deciding what the cloudbase might be at an FAF ten miles from the airports based on the airport METAR or the area forecast.
In short I think an EIR holder should be allowed to accept vectors to the top of the G/S unless the cloudbase was below the top of the G/S. If vectors are not available then the pilot should be allowed to descend to the top of the procedure within the ATZ, once again if the cloudbase is reported as being above, or else be required to divert.