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.
213 - Dear PAAB, I am curious about creating unbranded educational material around Subsequent Entry Biologics. We know that there are potentially a lot of issues that SEBs can have considering the nature of the manufacturing process. Is it acceptable to educate physicians on the challenges, risks, and non-identical nature of SEBs vs. orignial product, using review and 'expert opinion' articles in an unbranded piece? Alternatively, if we had a study that was done that showed these issues would we be able to use that? Or is it, if Health Canada has approved it then we can't say anything to infer challenges and risks? Many thanks.
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The piece you have described would be reviewed as an editorial (i.e. "unbranded" piece) under PAAB code s7.6. As a general principle, advertising should promote the sponsor's product by its own merits rather than by calling attention to the limitations of competitors (whether perceived or factual). The hypothetical piece you are describing risks being disparaging. Clients are sometimes surprised to learn that "Factual" and "misleading" are not necessarily mutually exclusive.Also note that class/category claims are generally not accepted. Given the variability within any given product classes and categories, it is misleading to make sweeping class/category statements.Finally, drug claims should not be based on review papers or expert opinion. The opinions of an individual are not necessarily consistent with broader current medical opinion. Comparative efficacy and safety claims require double blinded head-to-head RCTs.
