Use IMCE as an admin UI for images?

I'm maintaining a module (User Badges) that needs to maintain an image library, but not as its main purpose.

Right now it uses the upload module and a rather primitive file listing. This has lots of problems and is not very scalable without a lot of development work.

I'm thinking that coding a lot of image library handling code is unnecessary and would end up inferior to the solutions offered by existing Drupal modules.

it might work better, for example, to dump all the existing code and use IMCE instead. It seems to have all the functions for managing an image library.

I want to get the best solution I can to this issue, so I'd be grateful to hear the opinions of others on this idea.