Bodies reviewing DTC materials
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It's my understanding that both ASC and PAAB offer services for the review of materials directed at consumers (i.e. disease state brochure, disease state website, etc.). Are we mandated to put this through PAAB or do we have the option to decided on the regulatory body. Also, if a piece is approved by ASC does it have to be re-reviewed by PAAB?
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Happy Friday @tmcd
Health Canada recognizes both ASC and PAAB as bodies who can provide advisory opinions on information directed to consumers (DTC) on educational material discussing a medical condition/disease (see HC link).
Should the context of the piece change through distribution or additional linkages, the audience may no longer be restricted to just consumers. If this is the case, we must assess the new context and audience. As an example, pieces which will be provided to HCPs (e.g., for distribution to their patients), now requires review for adherence to the standards of the PAAB code as per section 1.3 (The scope of the Code of Advertising Acceptance applies to all Advertising/Promotion Systems in both official languages of Canada (English and French) distributed via all media to healthcare professionals and patients) even if they have been reviewed by another preclearance agency.
When HCPs are simply informed of DTC campaigns, the PAAB asks to see (not review) the DTC piece to ensure the linkage between the two assets (e.g. DTC and APS) is permissible.
