369 - Hi Patrick. Accreditation for a CHE program has expired and the company wants to turn it into an OLA. The role of the reps is restricted to logistics only and the content is all on label. The program has been developed by HCPs and is presented by trained HCP speakers. Does the OLA content need to be reviewed by PAAB? Thank you.
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Drug advertising directed to HCPs should be submitted for PAAB pre-clearance unless the exemption criteria listed in s1.5 are met. The fact that something is an OLA does not, in and of itself, exempt it from the advertising regulations nor does it render it subject to the advertising regulations. There are many factors to consider (e.g. the content, linkages, and the means/context of dissemination). PAAB has created a decision tree tool to help you work through these factors. The tool is based on the 7 questions in the Health Canada policy document "The Distinction Between Advertising and Other Activities". The tool can be accessed through the following link: http://www.paab.ca/resources/pdfs/Guidance-on-which-HCP-materials-require-PAAB-review.pdf. You may choose to use the PAAB opinion service if you need an independent set of eyes to make this assessment (see the fee schedule on the website).
