135 - I am developing a web site to host presentations of specialists to family physicians. The website will be gated to only allow physicians and the presentations will be accredited by the College of Family Physicians and produced independently by the speaker. There will be space for physicians' comments as well discussion forums focussed around the the topics being presented. I will seek pharma sponsorship of the presentations and will declare the sponsorship on the pages where members access the presentations. Will the slides require PAAB approval and do you see any hurdles that I may face in this endeavour?
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The answer to your question lies within whether this web site will fall within the "advertising" realm or not. If it falls within the advertising realm, then the drug advertising regulations will apply and the site should be submitted to PAAB. Otherwise the drug advertising regulations would not apply and the site would be exempt from PAAB review. Unfortunately, it is not possible to provide a specific answer your question as it is missing elements which must be considered in determining whether the scenario falls within the advertising realm. For example: who is setting up the site (i.e. who is "I"?), what relation do you have to the topics and sponsors, will branded advertising appear anywhere on the site? These questions in addition to a few more appear on the following link within the Health Canada policy document "The Distinction Between Advertising and Other Activities". See the link below: www.hc-sc.gc.ca/ Answer all 7 questions found within this link in a manner which is objective and remember that no one factor in itself will determine whether or not a particular message is advertising. The answers must be taken as a whole. Alternatively, we can provide an opinion as to whether your specific scenario falls within the advertising realm if you submit such request through our electronic submission system.
Please call the PAAB office if you have any further questions.
