Forum Update: Supporting Community-Led Discussion
The forum was created as a space for shared learning and peer support, and as the community grows, we want to lean more fully into that purpose.
Going forward, PAAB will be taking a more listening-first role in forum discussions. Rather than responding immediately to every question, we’ll be encouraging members to engage with one another, share experiences, and help build collective understanding. PAAB will continue to monitor conversations and will step in to:
- Correct any misunderstandings
- Provide guidance when questions remain unanswered after a few days
- Support discussions where official clarification is needed
Our goal is to foster a collaborative, trusted community where knowledge is shared and strengthened by everyone’s contributions.
Thank you for being part of the conversation.
760 - What type of gating is required for a HCP website for a schedule 1 product (narcotic)? is de-indexing considered a form of gating? What type of information can be available pre-gate? can information around a patient support program be made available pre-gate for a schedule 1 (narcotic) product?
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Yes, de-indexing is considered a form of gating. Note that the de-indexed URL should also be something that is not easily guessable (controlled distribution). For example, “BrandX.ca” would not be acceptable. Neither would “BrandXHCP.ca” or “BrandXresources.ca”. There should be some aspect of the URL which is not easily guessed. We suggest a set of random characters/numbers.
Note that advertising of narcotics falls under the Narcotic Control Regulations and the Controlled Drugs and Substances Act. Advertising of narcotics is prohibited to the general public (this includes reminder ads that would be limited to only the product name, price and/or quantity). As such, it would not be acceptable to have a landing page which makes mention of the narcotic. In addition, the inclusion of promotions for a patient support program in a public space, would not be acceptable.
Please also be advised that Health Canada has provided additional guidance on the promotions of opioids. Please see: https://www.canada.ca/en/health-canada/services/drugs-health-products/reports-publications/medeffect-canada/submission-targeted-rm-plans-commitments-prescription-opioid-containing-products-guidance-industry/document.html#a3.2.3.3 and https://www.canada.ca/en/health-canada/services/drugs-health-products/drug-products/announcements/additional-restrictions-advertising-opioids.html
