655 - We would like to do a table comparing non-clinical aspects (indication, route of admin, dosing, monitoring, etc.) of various products indicated for a specific disease. There are more than 10 drugs with this indication, so it will contain a lot of information, all of which will be based on the respective product monographs. It is our intention to give each brand equal prominence (i.e., it will not be specifically branded to one drug). What are the balance requirements for a piece like this? Normally, we understand that dosing warrants high-level balance. However, we can't possibly fit high-level balance for all of the product that will be mentioned in this piece. What do you suggest? Thank you!


  • Please note that dosing messaging in and of itself does not prompt requirements for the highest level fair balance. Dosing messages limited to optimal administration of the product(s) would generally be subject to lowest level fair balance. However, we note that your question mentions a comparison of indications and monitoring warnings. In HCP advertising, comparison of indications, contraindications, warnings and precautions, drug interactions or overdose would trigger the need for highest level fair balance. The piece would require review to determine the appropriate level of fair balance. We’ll need to consider more than simply the type of content in the piece. For example, we’d need to consider whether the piece qualifies for editorial provisions outlined in code section 7.5. You may consider submitting the piece for an opinion (see the fee schedule on our website).