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Exploring APS categories Exploring APS categories

Exploring APS categories - PowerPoint Presentation

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Exploring APS categories - PPT Presentation

Malika Ladha malikalpaabca PAAB Reviewer Exploring product branded advertising vs editorial advertising vs corporate advertising s6164 74 75 2 What is Drug Advertising Definition in section 2 of the Food amp Drugs Act ID: 748675

product advertising consumer paab advertising product paab consumer drug schedule health therapeutic claims drugs canada editorial corporate prescription information company public acute

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Slide1

Exploring APS categories

Malika Ladhamalikal@paab.caPAAB Reviewer

Exploring product branded advertising vs. editorial advertising vs. corporate advertising

(s6.1-6.4, 7.4, 7.5)Slide2

2

What is Drug Advertising?

Definition in section 2 of the Food & Drugs Act:

“Any representation by any means whatever for the purpose of promoting directly or indirectly the sale or disposal of any food, drug, cosmetic or device”Slide3

3

Still unsure?

See

Distinction Between Advertising and Other Activities

on the Health Canada websiteSlide4

If it is product advertising…

…and it is directed to HCPs, PAAB review is required.

Exceptions are listed in PAAB code 6.6(d):

Company price lists containing no other product/company claimsOnly message is “now on formulary”Only message is “Available at company X”APS only comprised of packshot with no therapeutic claims are visibleSlide5

Targeting patients:

PAAB s6.4.3Can:Create linkage

between the product and it’s therapeutic use

irrespective of the federal schedule. Can’t:Be promotional.Note:All product content must be derived from part III.Slide6

Editorial (s7.5)

What is an editorial?

Used to present information relative to a therapeutic area the sponsor has a vested interest in

Does NOT focus on a specific productDoes NOT contain identifiable branding elements for the sponsor’s productSlide7

Editorial (s7.5)Slide8

Corporate (s7.4)

What is a corporate APS?

Used to create and maintain a favourable image of a company, its products and its services

CAN contain product names along with their therapeutic or pharmacologic classificationCan NOT contain therapeutic claims or other claims of product merit or statusSlide9

Corporate (s7.4)Slide10

PAAB preclearance services:

PAAB code covers

HCP Advertising (whether product branded, editorial, or corporate ad with product mention or relating to a product)

Patient Information provided through HCPs PAAB advisory service (using Health Canada policy documents):Consumer Information

Consumer AdvertisingHealth Canada and Advertising Preclearance Agencies’ Roles Related to Health Product Advertising:

http://www.hc-sc.gc.ca/dhp-mps/advert-publicit/pol/role_apa-pca-eng.phpSlide11

Targeting consumers

For non-advertising information:

Need to consider the relevant provisions from the “Distinction” Document

Examples:Help-Seeking AnnouncementsConsumer BrochuresFor advertising:

Need to consider product’s federal schedule & whether disease/condition treated is on schedule A. Slide12

Consumer InformationSlide13

Consumer BrochureSlide14

Consumer AdvertisingSlide15

Federal Drug Schedules

Narcotic

Schedule G – controlled drugs

Prescription drugsSchedule D – biological products (e.g. vaccines, insulins). Caution: Some are dual scheduled products.Non-scheduled (including NHPs, EN-NHPs, homeopathic, OTC)

Note that an ethical drug is a product that does not require an Rx but that is generally prescribed (e.g. MRI contrast agent, hemodialysis solutions, nitroglycerine, emergency adrenergic agonists).

Adapted from Health Canada document “Terminology - Drug Product Database (DPD)”Slide16

Disease Consideration - Schedule A

Acute alcoholism

Acute anxiety state

Acute infectious respiratory syndromes Acute psychotic conditionsAcute, inflammatory and debilitating arthritis

Addiction, except nicotine addictionAppendicitisArteriosclerosis

Asthma

Cancer

Congestive heart failure

Convulsions

Dementia

Depression

Diabetes

Gangrene

Glaucoma

Haematologic bleeding disorders

Hepatitis

Hypertension

Nausea and vomiting of pregnancy

Obesity

Rheumatic fever

Septicaemia

Sexually transmitted diseases

Strangulated hernia

Thrombotic and embolic disorders

Thyroid disease

Ulcer of the gastro-intestinal tract

http://laws-lois.justice.gc.ca/eng/acts/f-27/page-14.htmlSlide17

Consumer Product

Advertising Key Considerations

Non gated → accessible to the general public

2. Food and Drugs Act and Regulations:Advertising of a prescription drug to the general public is limited to name, price and quantity c01.044a drug (prescription or nonprescription) or medical device may not be advertised to the general public for the treatment or cure for a Schedule A disease (3.1)

Section A.01.067 of the Food and Drug Regulations provides exemptions for certain non-prescription drugs and NHPs; Schedule A preventative claims may be made if these claims have been authorized by Health CanadaSchedule D products may make therapeutic claims to public except for schedule A prohibition (fair balance required)Slide18

Consumer Product

Advertising Key Considerations

The law

prohibits any direct to consumer “Advertising” of narcotic drugs (Section 70 of the Narcotic Control Regulations) and controlled drugs (FDR: G.01.007).Slide19

Consumer advertising/info:

What PAAB does for you.

Provides advisory service

Turnaround 4 daysReview based on Health Canada policy documents:Distinction Between Advertising and Other ActivitiesConsumer Advertising Guidelines for Marketed Health

ProductsPrinciples for Claims Relating to Comparison of Non-therapeutic Aspects of Non-prescription Drug ProductsTherapeutic Comparative Advertising: Directive and Guidance Document

PAAB has been doing DTC reviews since 1990Slide20

Questions?