Possibility of a secondary audience
Hi there, it is my understanding that manufacturers can provide HCPs with branded patient brochures that the HCP can then choose to share with a patient once they have been prescribed. In this case, the primary audience of the brochure is the HCP and the patient. However, if we were to provide a brochure holder (very simple with just product and company logos) with this branded patient brochure, would there now be a secondary audience for this brochure (i.e., healthcare consumers)?
Jennifer Carroll last edited by Jennifer Carroll
In the scenario described above, the HCP is the secondary audience. Why do we say that? We say that because a brochure intended to be shared with a patient should be written in patient friendly language (content is based off part III of the TMA). A HCP should not be detailed to off a patient brochure. They are the secondary audience as they will see the brochure before handing it to the patient, but they’ll be viewing it with the understanding that it is patient information.
Depending on where the holder is intended to be placed, you may also need to consider the consumer regulations. For example, if the holder is intended to be placed in a context that is visible to anyone who enters the examination room, then any openly visible element on the holder (and any exposed section of the brochure) must not exceed the consumer regulations (see Q&A 240 for additional guidance).