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  2. PAAB Q&A
  3. Disclosure requirements: PI & Safety Information, Federal schedule, study parameters, reference lists

Disclosure requirements: PI & Safety Information, Federal schedule, study parameters, reference lists

60 Topics 72 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

    519 - We are sending an announcement to HCPs informing them that a product is now covered on the provincial formulary and providing the the reimbursement criteria. My questions are: Are we required to include the reimbursement criteria? What level of fair balance is required?

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  • Jennifer CarrollJ

    505 - Dear PAAB - would a branded APS comprised of only a provincial listing (with clinical criteria/notes), require high-level balance or low-level balance? Note this assumes that all listing criteria is on-label.

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  • Jennifer CarrollJ

    495 - If the safety information for 2 products is almost identical (the molecule being the same in both products), can we merge the two fair balances and indicate which safety information is for both products and which safety information is for only one of the products?

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  • Jennifer CarrollJ

    489 - Where can I get the detail guidance around layouts (ie, font size, specific/mandatory placement of info etc)? Thanks.

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  • Jennifer CarrollJ

    485 - If there are updates to safety information, is there a grace period that PAAB allows before pieces have to be updated with the new label?

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  • Jennifer CarrollJ

    484 - What happens when a piece which contains information on multiple drugs is already approved by PAAB but then a product monograph update comes out for one or more of the drugs. Does this require revision and re-submission or is the piece still valid for the duration of the approval period?

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  • Jennifer CarrollJ

    454 - For an HCP-directed piece relating to a patient program, where brand name and indication are given in addition to the monitoring schedule from warnings & precautions, what level of balance would be required?

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  • Jennifer CarrollJ

    446 - Can you confirm whether Code sections 2.10.1 and 2.10.2 are mutually exclusive? For example, could an abbreviated indication appear with the first marketing claim in an APS, with the verbatim indication appearing elsewhere in the APS?

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  • Jennifer CarrollJ

    434 - For traditional online banner ads, how can one be expected to fit the verbatim indication on the first 'frame' also containing a claim? Traditional banners are only a few pixels in size, which seems to prohibit effective advertising for products with larger indications.

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  • Jennifer CarrollJ

    420 - What are the requirements for display signs at a conference? The display sign contains pictures of drug products and contains general information about the product. Would fair balance need to be applied to this display? Are we required to include the indications on the display? This sign would only be used at conferences along with brochures which contain the indications and fair balance information.

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  • Jennifer CarrollJ

    368 - We have an existing product with a new indication. We would like to announce the 'new' indication like "Now indicated in...". What level of fair balance would be required?

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  • Jennifer CarrollJ

    351 - Hi PAAB, could you please advise what is required in terms of balancing copy for NHP products?

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  • Jennifer CarrollJ

    346 - Hello. Could you please clarify if the indication statement is considered a claim?

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  • Jennifer CarrollJ

    345 - In light of the new Fair Balance requirements (high level), are we required to include all the laboratory monitoring as part of the warnings and precautions section? It seems like a lot of info given that they are monitoring guidance but not warnings per se (e.g. monitor leucocytes very 4 weeks ...). Please advise.

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  • Jennifer CarrollJ

    344 - Hi Patrick, Lately PAAB has been requesting that the indication for a product be placed on the front page of every piece. If we are not making any clinical claims on a front page of a piece, why can we not include the indication on the second page of a piece? Your PAAB code clearly says: 2.10.2 - PAAB code, The TMA content, "Drug X is indicated for" (or equivalent) must be presented verbatim at least once within the advertising message of the APS. Nowhere does it say it has to be on the front page.....thanks!

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  • Jennifer CarrollJ

    342 - In the development of booth promotional materials intended to reprise indications, contraindications, warning and precautions which are part of the Product Monograph, are there any restrictions on how these sections can be excerpted. Is is permissible to exclude text from the indications section, for example?

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  • Jennifer CarrollJ

    332 - Would the discussion of the bioequivalence of a particular product be considered to be a non-pharmacologic claim? If the piece included bioequivalence data (and no other claims) would the lowest level of fair balance suffice?

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  • Jennifer CarrollJ

    313 - Does an indication statement constitute a therapeutic benefit/claim or efficacy statement in and of itself? If so, can you confirm that any APS with the indication statement on it would require highest level fair balance?

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  • Jennifer CarrollJ

    286 - After putting the NOC/c boxed statement on the front cover, can additional related statements go on the inside of the APS - or does it all have to appear on the front cover?

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  • Jennifer CarrollJ

    272 - We are developing a patient-directed instructional guide on how to use an injectable medication. The format is a flip chart, with visual instructions on one side (for the patient), and more detailed instructions on the reverse side (for the nurse's eyes only). Given the new PAAB code, and the fact that this is a HCP-delivered patient APS based on Section III of the product monograph, would the lowest level of fair balance suffice?

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