36 - In your answer to question 34, you state "If the information is created independently of the company it is usually not advertising." I can think of clear examples of "text or reference books" that are produced by an independent publisher, but which deal almost exclusively with a single pharmaceutical product. If such items are paid for and distributed by company representatives, even though produced independently, are they advertising?



  • I said "usually" for a reason and you found an exception. Refer to the Health Canada document "the Distinction between Advertising and other Activities". If the book is primarily about one drug, distribution by sales reps would probably be viewed as a promotional activity because that is what sales reps are paid for. Independently published text books are not required to be reviewed by the PAAB. The content of the book would have to be examined to see if there is a violation of the PAAB Code. This case is similar to distributing clinical reprints that were independently published.


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