596 - A disease-state piece includes mention of treatments in a balanced manner. It is distributed to consumers as a Consumer Brochure and technically exempt. Can this same piece be distributed to HCPs, or would it have to be revised to meet Editorial APS requirements? Does the content and/or level of detail dictate this?
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Distribution of a piece which discusses treatment options to healthcare professionals, would require review under the PAAB code. The copy would be reviewed to ensure that it meets editorial APS requirements (PAAB Code section 7.5). Please note that “Consumer Brochures” are not considered exempt from PAAB review as they do not fall under the PAAB code (they are outside of the scope of the PAAB code). The PAAB does offer an advisory opinion on consumer brochures based on Health Canada policy documents. The following link provides the roles of the various regulatory bodies within Canada: https://www.canada.ca/en/health-canada/services/drugs-health-products/regulatory-requirements-advertising/policies-guidance-documents/advertising-preclearance-agencies-health-product.html
