Sales representative contact information in a branded context; is this considered person to person communication?
If a branded piece is created, (with no product claims, only the product logo) and contains space to include a sales representative business card and invite to connect virtually, would this be considered a person-to-person communication and not subject to PAAB review?
Jennifer Carroll last edited by
As per the response to PAAB Q&A 308, the PAAB code section 1.5 defines "personal correspondence as" single letters carrying a personal response or message. BUT it goes on to explain that this exemption does not apply to multiple personal letters initiated by the company. The above mentioned activity would not be considered a person-to-person communication. It is possible that the message is exempt from PAAB review even though it is not considered a person-to-person communication. However, it is also possible that some aspect of the activity discloses a therapeutic message, such as the content of the representatives business card or product logo. For this reason, we suggest an opinion to exemption review.
PAAB Q&A: Mention of new indications in 1X1 email to HCP may also provide additional learnings.