129 - Can sales representatives distribute Congress reports? The congress reports are commissioned by a pharma company to a third party ( ex medical communications company). Information is not focussed on company brands and is balanced and independently produced.Do these reports need to go to PAAB for reps to be able to distribute?
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Please see PAAB Code s11.1 for the definition of advertising subject to the Code and see PAAB Code s6.6(a) that states "Information materials that have been independently controlled and prepared, with industry involvement limited to purchase and/or sponsorship of the distribution (example: a textbook)." Meeting Reports of sections of accredited Health Professional Meetings or Continuing Education (CE) events/activities (see s11.10) organized independently of the sponsor of the materials and that are not focused on, or provide emphasis on, the sponsor's product(s) i.e. do not promote the sale of the sponsor's product(s). See Health Canada guideline "The Distinction Between Advertising and Other Activities" regarding section "Continuing Medical Education (CME) / Scientific Symposia/Exhibits" that states "Moreover, reports, edited scripts or recorded videos of the proceedings, in whole or in part, that concern a specific drug may be advertising if they are disseminated by the sponsor, or the sponsor's agent, to a wider audience after the meeting." Based on the above, if the content includes statements, claims or data relative to the drugs that the sales reps normally promote, the item would be considered "advertising" subject to PAAB review. See section 1 Scope. Sales reps are hired to promote the sale of a product. Therefore, just about anything they hand out would be considered to be advertising by the definition in the Food & Drugs Act. You can see the PAAB Code at www.paab.ca
