564 - Based on advisory board recommendations for supportive tools, a company would like to create an unbranded "reference tool" which documents the metabolic pathways for drugs in a particular therapeutic area. This would be a service item distributed by the representatives. Information would be taken primarily from Product monographs and in a few cases, the literature. Is there any reason this would not be allowed? what would be the constraints?
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It is feasible to create a piece which includes a side-by-side comparison of product properties such as metabolic pathways. These comparisons are reviewed based on section 5.10.2 of the PAAB code which specifies that the information must be from the individual Product Monographs, we would question the use of other sources for this type of comparison. We caution that the presentation should not imply comparative clinical significance, and must be complete, in that other data relevant to the presentation also contained in the Product Monographs must not be omitted. This is also critical when creating an unbranded (i.e. editorial) tool as the piece must contain objective and balanced information with no emphasis on information about the sponsor’s product. We caution that selectively choosing a product property/feature (e.g. metabolic pathways), which may create a comparison that is beneficial to the sponsor’s product will not be acceptable in an unbranded context. A good rule of thumb is, if you can identify the sponsors product based on the information presented, then it is not an editorial (s. 7.5).
