Forum Update: Supporting Community-Led Discussion
The forum was created as a space for shared learning and peer support, and as the community grows, we want to lean more fully into that purpose.
Going forward, PAAB will be taking a more listening-first role in forum discussions. Rather than responding immediately to every question, we’ll be encouraging members to engage with one another, share experiences, and help build collective understanding. PAAB will continue to monitor conversations and will step in to:
- Correct any misunderstandings
- Provide guidance when questions remain unanswered after a few days
- Support discussions where official clarification is needed
Our goal is to foster a collaborative, trusted community where knowledge is shared and strengthened by everyone’s contributions.
Thank you for being part of the conversation.
93 - As follow-up to question 91 and as referenced in question and answer 46, if the off-label content of the educational material (publication) is not the focus and will not be discussed by the rep, and that the reps are trained to use the material in a non-promotional manner, would this then comply to PAAB exemption?
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You appear to be trying to create a grey area. The issue that you have to address is "Are you 'advertising' your product by the use of this material?". The definition of advertising includes "promote the sale of a product". If you are using the "educational" (no such designation exists in the regulations) material to promote the sale of your product then you are advertising. Health Canada has a guidance that says that if you link advertising and non-advertising materials then all of it becomes advertising. I suggest to stay away from the perception of promoting off-label information. There must be a valid source of information regarding the on label stuff if it found its way into the "educational" material. Many companies are setting policies to not let their sales reps distribute materials that are not intended for promotional use for perception and control reasons.
