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Special FeaturesLast update June 4, 2019

Ask PAAB

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We have enhanced the Ask PAAB section to make it more user-friendly due to the growing number of questions. You can now select a category of interest from the drop down menu above to view existing question and answers or you can also do a search for questions that have been submitted to Ask PAAB since the beginning.

Most Recent Questions and Answers
712

We have an online newsletter where we post healthcare-related information, as well as society news pertaining to our association. Our member and supporter base primarily consists of hospital pharmacists as well as a small number of architects, students, and pharmaceutical companies. We can set-up advertising on the site to require a login to limit access by the general public. My concern is with the students who are not yet healthcare professionals, the pharmaceutical organizations, and the small number of architect members. Would their exposure to pharmaceutical advertising go against PAAB standards, even if we include a disclaimer that the advertisements are meant for healthcare professionals only? When we used to have a print journal that contained advertising for pharmaceutical products, the same individuals would have received copies of it. To my knowledge, this was not an issue in the past. However, we would appreciate some guidance to ensure we are being PAAB compliant, as online advertising is new to our association. Thank you kindly. 

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711

Can patient survey data from CADTH be used for an unbranded tool on current patient experience and behaviour?

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710

For Help-Seeking Announcements, the Distinction Between Advertising and Other Activities states "there is no implication that a drug is the sole treatment available". Does this mean no implication for a single brand within the context of available drug treatments, or no implication for drug treatment over non-drug treatment?

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709

For a product with two different administration formats (eg. syringe and pen), is it permissible to only advertise one format in APS (with no mention of the other device)?

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708

If Product-A is a combination of Drug-B and Drug-C, can the mechanism of action information from the Drug-B and Drug-C Product Monographs be used in Product-A advertising? The Product Monographs for combination products usually contain less information regarding their components (for brevity), however mechanisms of action should be identical regardless of formulation.

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707

Hi, For the balance copy requiring a direct link to the Product Monograph - the guidelines state that a link to the Health Canada database along with DIN number would work in lieu of a corporate URL. If going this route, is it sufficient to say: "Search the Health Canada Drug Product Database and search DIN XXX for...." OR must the database URL be written out? It is quite long: (https://www.canada.ca/en/health-canada/services/drugs-health-products/drug-products/drug-product-database.html) Much thanks!

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706

Can sales representatives provide information on a drug's reimbursement criteria in response to a question from a HCP if the reimbursement criteria are not aligned with the TMA. For example, the approved Health Canada indication is for use as 2nd line therapy but the drug is only reimbursed for use in 3rd line. Could the sales representative respond to the question and provide information on reimbursement if not aligned with the TMA. Thank you.

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705

Can a non promotional website that is not subject to review and is only available to verified Canadian HCPs link to a post-gate landing page for a PAAB approved branded website?

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704

If a product has two possible dosing schedules, with no specific requirements/recommendations on which HCPs can choose, are we permitted to just focus on one dosing schedule in APS? If both dosing schedules are required, are we permitted to focus on one over the other in terms of prominence?

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703

Regarding the PAAB Guidance document "Tips relating to inclusion of expert commentary in drug advertising", would the same rationale and requirements apply to patient testimonials?

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Deputy Commissioner  

Jennifer Carroll
Senior Reviewer Communications

To view the PAAB
Code of Advertising Acceptance
click here
Pharmaceutical Advertising
Advisory Board
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Have a great summer and see you in September.