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16 - Can a pharmaceutical company distribute a third party piece (a textbook) via their representatives? It is a textbook that they are providing sponsorship for only and thus is exempt from PAAB rules. Does this book require a reference section with the product monograph in it as the product is discussed within the content of the textbook?
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Yes, pharmaceutical companies can distribute textbooks via their representatives. With respect to how it fits into the PAAB Code, it depends on what "sponsorship" means. If the book was published independently and not commissioned by the pharma company, it would be considered to be third party. According to Health Canada guidelines in the "Distinction Between Advertising and Other Activities" independently published textbooks would not be considered advertising when distributed by pharma companies. That means the company had no involvement in the production of the textbook. If the textbook content was balanced and objective and did not appear to promote the sale of a product, it would not be considered 'advertising'. If the textbook content focused mainly on the sponsor's products, it could be considered 'advertising' when distributed. If the pharma company was involved in the production or selection of the writers and it mentioned healthcare products, it could be considered 'editorial advertising'.
It is a good idea to show the references for any scientific publication. Whether the book is not 'advertising' or if it is 'editorial advertising' subject to PAAB review, the product monographs of the products mentioned in it does not have to be shown as part of it. If the book was focused on the sponsor's products it could be considered to be 'product advertising'.
