PAAB-exempt name-only communications

[ALee]

Hi Jennifer - We have some questions regarding PAAB-exempt name-only communications.

1. AskPAAB #137 on the original PMCQ site outlines that an HCP-directed exempt banner ad may link to the unedited PM. However the same question #137 on the PAAB Forum website has additional text, outlining that such a link would then render the banner ad no longer exempt. Can you provide clarification or advise which interpretation is correct?
2. AskPAAB #330 and #517 both deal with a 'Coming soon message', but give conflicting responses on whether this message is considered exempt. Can you provide clarification or advise which interpretation is correct?

[Jennifer Carroll]

Hello @andrewleeson

1. The added clarification copy “however, linking a name-only banner ad to the TMA renders it non-exempt from preclearance as this constitutes a link to therapeutic messages” was added so as to help avoid the misinterpretation that just because there “should not be an issue linking such banner” meant that the banner remained exempt. The activity of linking the banner to a therapeutic message renders it no longer exempt. We did not believe that was clear with the initial response.

2. We will remove 517 to help reduce confusion. Please consider the response in 330 to be accurate: “A piece containing only the message "Drug X is coming soon" with absolutely no other message (implied or stated) within the piece AND absolutely no link to therapeutic or promotional messages is exempt. Note that the manufacturer is responsible for ensuring that this message is employed only AFTER the product has been approved by Health Canada. It is prohibited to advertise a drug product prior to Health Canada approval.”