The Pharmaceutical Advertising Advisory Board (PAAB) recently
released a revised version of its Code of Advertising Acceptance.
As of July 1, 2013, the PAAB will apply this revised Code to all
newly submitted advertising and promotion systems (APS). For all
marketing materials currently in circulation, there will be a
transition period ending July 1, 2014 for compliance with the new
version of the Code.
The PAAB is an independent review agency whose primary role is
to ensure that advertising directed to health-care professionals
for prescription, non-prescription, biological and natural health
products is accurate, balanced and evidence-based, and reflects
current and best practices.
Internet and Social Media
The most significant amendments to the Code reflect the
increased use of the Internet and social media platforms to
advertise to health-care professionals. First, the term
"social media" is now defined in section 11 of the Code
The broad term for internet
activities that engage or encourage engagement through online
discussions or interactions. E.g.: blogs (personal online
journal(s) comprised of entries/posts), microblogs (Twitter), chat
rooms, forums, video/photo sharing (YouTube, Flickr), social
networking (Facebook), podcasts, user forums/discussion groups,
wikis (website where content is added, modified or deleted by the
users), news aggregation (RSS), apps etc.
Section 6.5 of the Code specifically addresses the concerns of
using these technology platforms to advertise health-care products
to health-care professionals. For instance, section 6.5.2 of the
Code now states that the name of the pharmaceutical company that
sponsors any of the online media platforms covered by the
definition above should be stated on every page of the website
controlled by the sponsor, unless use of the company name is
prohibited by regulatory requirements. Furthermore, section 6.5.9
states that the sponsors of websites that allow user-generated
content must monitor these pages, provide terms and conditions to
users who engage in commentary, and describe the types of comments
that will be modified or removed from the site.
Another important amendment to the Code speaks to the current
practice of attaching a copy of the product's prescribing
information to any advertisement for that product. Section 7.3.1 of
the revised Code permits the advertising company to provide either
a URL or a direct link to the product's Terms of Market
Authorization (TMA) as approved by Health Canada, in place of the
prescribing information. It should be noted that the linked webpage
need not be reviewed under section 7.3.2b of the Code if no
additional advertising content, other than a corporate logo and
tagline, is displayed on the page. If there is additional
advertising content, then the PAAB must review the linked page.
Definitions and Interpretations
With respect to definitions contained in the Code, section 11
has been significantly amended to clarify a number of terms. The
revised definitions section includes new definitions for terms such
as "fair balance," "healthcare professional,"
"marketing benefit claim," "prescribing
information," and the aforementioned "social media."
Furthermore, section 2.10 has been amended to clarify
"authorized use" and what is required for an
advertisement to be misleading.
The PAAB has developed several guidance documents to assist
interpretation of the revised Code. These documents are all
available on its website, www.paab.ca. Additionally, in-person and online
training sessions are also offered. The in-person sessions are
currently scheduled to take place in Toronto and Montréal in
late-February. Various online webinars are currently scheduled for
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