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  2. PAAB Q&A
  3. Claims & Support/References for Claims

Claims & Support/References for Claims

239 Topics 391 Posts
PAAB Notice
The responses, guidance, and advisories provided by the Pharmaceutical Advertising Advisory Board (PAAB), including but not limited to those available through the PAAB Forum, the PAAB website, and any PAAB correspondences, are specifically intended to assist individuals navigating the PAAB preclearance system. Repurposing or reproducing this content without written consent from the PAAB Commissioner is strictly prohibited. This prohibition includes, but is not limited to, use in machine learning or AI models.

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  • Jennifer CarrollJ

    430 - One of the pivotal trials for an advertised brand has a reference comparator (RC) arm (i.e., the trial has statistical analysis for the advertised brand vs placebo and the RC vs placebo, but no statistical analysis for the advertised brand vs RC). The Product Monograph mentions the RC as part of the design, but no RC data is included in the PM. Can the data for the RC vs placebo be shown in an APS?

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  • Jennifer CarrollJ

    427 - Recently we've seen an APS that have been submitted where p-values were requested for safety data, otherwise it would not be admissible as data. The problem is, virtually no clinical trials power their adverse events to generate p-values. When did this become a requirement?

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  • Jennifer CarrollJ

    425 - Can a pharmaceutical company publish the results of a clinical study that was supported by a scientific grant. Would this have to be identified as advertorial?

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  • Jennifer CarrollJ

    423 - Definitions Section 1.8 of the PAAB code states: Use of the word 'new' or statements implying "new" in advertising should be restricted to 1 year after initial marketing. Can you please clarify what is meant by "initial marketing"? Is this the NOC date or when "marketing" activity is initiated etc.?

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  • Jennifer CarrollJ

    422 - Dear PAAB. The PAAB codes states that superlatives or special status cannot be used unless substantiation can be provided. What is the substantiation you are looking for? Is the monograph a source that would suffice?

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  • Jennifer CarrollJ

    417 - Hi Patrick, Can a company position its brand (from both a creative and messaging standpoint) on secondary outcomes in its PM? If not, then what code number does this contravene?

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  • Jennifer CarrollJ

    404 - Hi Patrick, I am doing a slide kit for the reps based on our PM. In the PM it mentions a study with our drug against a non-approved drug, so I can use this info in my slide. New studies have come out on our drug vs the non-approved drug would I be able to use this new data in my slide deck for the reps.

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  • Jennifer CarrollJ

    387 - May we: Report the results of a patient satisfaction study to doctors?Ask doctors' opinions of key results from of that study?Then report back to all doctors a summary of responding doctors' aggregate opinions?

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  • Jennifer CarrollJ

    385 - Our client would like to produce a Canadian consensus statement in a disease area where there are currently no relevant guidelines. The publication would be peer-reviewed and cover all therapeutic options; we would ensure that any discussion of the sponsor's product was on-label. The intent would then be to distribute reprints through the sales force, and possibly also create an unbranded APS highlighting the availability of the consensus statement (no emphasis on a particular drug). Can you give us any guidance on how we should set up the consensus process and paper to be acceptable for these uses? Assuming the publication is peer-reviewed, would the fact that it has a single sponsor be an issue? Is endorsement by a medical association required or just recommended? Thanks in advance.

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  • Jennifer CarrollJ

    384 - What type of references are allowed in unbranded materials? I am interested in using studies which are based on patient surveys/questionnaires as well as some review papers (neither of which have a focus on the company's branded product). Would these type of references be allowed or are strictly limited to the same rules as branded communications? Thanks.

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  • Jennifer CarrollJ

    383 - We have 2 questions regarding inclusion of treatment guideline statements that address drug place in therapy (our product is sited by non-proprietary name) in HCP-directed APS: 1. a) Can treatment guideline statements be included anywhere among product claims? b) Similarly, can treatment guidelines be included on the other side (back or front) of a page containing product claims? 2) Can treatment guidelines be included on the other side of a page containing the main sections of the Product Monograph of product sited in the guidelines (Dosage, Indications, Warnings and Precautions, Contraindications and Adverse reactions)?

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  • Jennifer CarrollJ

    381 - Hi there, Is the full article needed for the references or is the abstract okay if the content of the reference is there. Thank you, Anne

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  • Jennifer CarrollJ

    364 - Hello, Can text from Part III/Consumer Information of a PM be used as a reference within and HCP directed piece? For example, if we were to define patient types that a product is indicated for and use the language defining such patients from Part III, would this be acceptable in HCP directed materials?

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  • Jennifer CarrollJ

    362 - Are poster presentations in medical conferences acceptable as a reference for promotional materials?

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  • Jennifer CarrollJ

    358 - Can you please advise what is required to substantiate a market share claim for a prescription product (i.e. will IMS data suffice)? How long must a market leadership position be maintained in order to make such a claim? How long is the claim valid?

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  • Jennifer CarrollJ

    347 - Is the message "Now Approved" acceptable in APS? It seemed that at one time, this was discouraged due to the perception of Health Canada endorsement

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  • Jennifer CarrollJ

    338 - Can you advise if published, qualitative studies are acceptable for patient preference claims under the new Code?

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  • Jennifer CarrollJ

    324 - Dear PAAB, what difference does it make when we combine data from duifferent sections of the TMA (PM). i.e can we put data from the clinical trial section and the adverse event section together since the adverse events are from the clinical trials?

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  • Jennifer CarrollJ

    316 - What are the limitations in terms of advertising for OTC pharmaceutical brands with a DIN?

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  • Jennifer CarrollJ

    314 - Hi Patrick. I would like to know if you would consider this tag line "Because every day is special" a claim that would require to be supported by data (our medication increases overall survival). Thanks a lot for your answer :)

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