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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.
  • 0 Votes
    2 Posts
    348 Views
    Jennifer CarrollJ
    Hi @hollymed Please see this PAAB Forum Q&A
  • Promotion of NOC/C materials

    Claims & Support/References for Claims
    2
    0 Votes
    2 Posts
    328 Views
    Jennifer CarrollJ
    Hi @chagali-toney-0 Per the Guidance on Advertising for Drugs with Notice of Compliance with Conditions NOCc “3. For NOC/c product advertising, studies and/or data which are not presented in the Terms of Market Authorization will not be accepted.” Please note that this does not state “verbatim”. However, it should be interpreted to mean that no data from outside of the PM can be presented.
  • Placing PSP enrolment forms on patient websites

    PAAB Code
    3
    0 Votes
    3 Posts
    448 Views
    L
    @jennifer-carroll Great, thank you!
  • 0 Votes
    2 Posts
    337 Views
    Jennifer CarrollJ
    Hello @mimi77 Promotion of a patient support program through the presentation of the program name and logo does not fall under the exemption criteria and links the brand logo to promotion of a company service (PSP logo) (Code section 7.5). Additionally, program names often have implications for the brand such as alluding to therapeutic use. Exemption is limited to brand name and logo in a context not linked to therapeutic or promotional messages per Code section 1.5.
  • Welcome to your NodeBB!

    General Discussion
    1
    0 Votes
    1 Posts
    208 Views
    No one has replied
  • RWE Presentation

    PAAB Q&A
    2
    0 Votes
    2 Posts
    429 Views
    Jennifer CarrollJ
    Hello @lora_nolan This is a review question. Per the Community Guidelines (see top right corner), this does not meet the use conditions for the Forum. Please address review questions through the appropriate channels by submitting a ticket for a call with the Reviewer through eFiles.
  • Clinical trial cessation

    Claims & Support/References for Claims
    2
    0 Votes
    2 Posts
    343 Views
    Jennifer CarrollJ
    Hello @gmc Hard to say whether this is even acceptable without looking at the study, but as a general question, we can state that this would require highest level fair balance. It is an implied claim of efficacy which would likely require quantification from the study (i.e., presentation of data). If it was stopped due to safety concerns, that would also prompt inclusion of that information and render it subject to highest level fair balance. With respect to “what other data is required for it’s inclusion?”, this is a review specific question. Please submit for an opinion as there are a number of factors that would need to be considered.
  • 0 Votes
    2 Posts
    332 Views
    Jennifer CarrollJ
    Good Morning @ebailey All files do not need to come back together. You can update the parent file and then apply across all the children files. In general, the parent file should be the one being resubmitted; however we understand that there may be practical reasons to resubmit a child file to get it to approval prior to proceeding with the rest of the children and the parent. When this is the case, please outline this for the reviewer. You may also reach out with an email to admin to confirm that the reviewers agree prior to resubmission.
  • 0 Votes
    2 Posts
    450 Views
    Jennifer CarrollJ
    Hey @supriya We’re unclear about the request. We can provide an example of how to cross-reference: Insert an asterisk ( * ) at the point in the text where you want to reference the footnote. At the bottom of the page, add the corresponding footnote, also marked with an asterisk ( * ). Cross-references must appear on the same spread as the claim. Multiple claims can be linked to the same footnote if the footnote would be the same for each claim. If this is not the question, can you please provide additional context.
  • Imagery

    PAAB Code
    3
    2
    0 Votes
    3 Posts
    512 Views
    T
    @jennifer-carroll said in Imagery: which exceeds name, price, and quantity, this copy should be blurred to prevent advertising to the general public. Thank you!
  • 🍁“Product of Canada” and “Made in Canada"🍁

    Announcements fyi aps
    1
    1 Votes
    1 Posts
    313 Views
    No one has replied
  • The use of secondary endpoints with nominal p-values

    PAAB Code
    3
    0 Votes
    3 Posts
    533 Views
    L
    @jennifer-carroll Amazing, thank you so much!
  • 0 Votes
    3 Posts
    702 Views
    Jennifer CarrollJ
    Morning @constance If the product has not received NOC, a manufacturer cannot promote that a new indication is coming soon as this would be off-label promotion.
  • Separation of patient consent information on a PSP form

    PAAB Code
    3
    0 Votes
    3 Posts
    484 Views
    L
    @jennifer-carroll Thank you very much for the very comprehensive and helpful response!
  • 0 Votes
    3 Posts
    540 Views
    TFT
    @jennifer-carroll Thank you!
  • 0 Votes
    2 Posts
    404 Views
    Jennifer CarrollJ
    Hello @username Apologies for not seeing this sooner. Thanks for your question. To clarify, iterative submissions (i.e. different iterations within the same PAAB eFile) do not require light blue shading. Blue shading is requested for child files that are part of a series. The blue shading is used to identify the common copy between the child and the parent eFile. However, whether you’re renewing an iterative submission or a series parent or child submission, you would shade the copy yellow. Once the submission is a renewal, it is more helpful to reference the backfile to which the copy is 100% pickup rather than shading it in relation to a parent file where the copy may be as little as 60% common. When using the “express renewal” feature, we will not require that the shading be adjusted by virtue of the way in which the “express renewal” platform functions and the nature of the guarantee that nothing has changed.
  • Now Available HCP Email and Fair Balance

    Miscellaneous
    2
    0 Votes
    2 Posts
    433 Views
    Jennifer CarrollJ
    Good morning @caitlinbyrne While “now available” as a stand-alone message is exempt, when it is paired with another marketing claim (route of administration), the piece is no longer exempt. This piece appears to require lowest level fair balance if restricted to the copy noted above.
  • Current DTC Regulations

    Resources
    2
    0 Votes
    2 Posts
    482 Views
    Jennifer CarrollJ
    Hello @tbalzarini Thank you for bringing this to our attention. We will update shortly. In the meantime, the Health Canada “Guidance on Distinction Between Advertising and Other Activities for Health Products” resource should be consulted.
  • Use of descriptive statistics

    PAAB Code
    4
    0 Votes
    4 Posts
    763 Views
    Jennifer CarrollJ
    Hey @cchristopoulos Descriptive statistics in an RWE do not preclude the use of the publication in an APS as long as they are pre-specified.
  • 0 Votes
    2 Posts
    394 Views
    Jennifer CarrollJ
    Good Morning @au3010 Please see Q&A 520