In general, we may consider review articles for disease state claims when the reference is published, peer-reviewed and independent of influence from the manufacturer. This however, should not be extrapolated out to health product content (e.g. if the “practice defining documents” or “clinical practice for managing the patient population” directly/indirectly refers to health products; “treatment algorithms”; “treatment recommendations”, etc.). These should come from Canadian consensus guidelines (see Code section 3.2). It would not be acceptable to distribute these types of papers in the context of drug advertising. A complete consensus guideline could be distributed.
The activity of sales rep discussion does not fall under the scope of the PAAB code. As a courtesy, we invite the client to consider the following when deciding whether to move forward:Although the activity does not fall under the scope of the PAAB code, it does fall in the realm of advertising and is thus subject to the provisions of the Food and Drugs Act. If the activity is deemed to be misleading, it could be found to be in contravention of the Food and Drugs Act.