Select Committee on Health Written Evidence


APPENDIX 34

Memorandum by the Association of the British Pharmaceutical Industry in response to the Institute for Social Marketing's Analysis of the Pharmaceutical Industry's Marketing Documents (PI 126)

  1.  Thank you for sending us a copy of the Institute for Social Marketing's Analysis of Pharmaceutical Industry Marketing Documents. The report is based on promotional and "product support" materials provided by five member companies of the Association of the British Pharmaceutical Industry to the Health Select Committee and raises many general points relating to the conduct of the industry.

  2.  Having received this report on Monday 14 March we understand that we and the companies concerned have only a matter of days to respond to its contents. It contains a number of serious allegations, many of which are based on a poor understanding of the ABPI Code of Practice for the Pharmaceutical Industry. In particular the report does not distinguish between internal strategy/market analysis (which is not covered by the Code) and external marketing actions (which are).

  3.  The ABPI has not seen the documents submitted by the companies but it appears that much of the criticism in the Analysis refers to internal company documents not for use with either health professionals or the general public.

  4.  The focus of the Code is on external activities of the industry and their appropriateness for professional and public audiences. To take an example prominent in the report: the use, in an internal market analysis, of language about "targeting" patient segments that could benefit from a medicine is not tantamount to directly advertising a prescription-only medicine to the patients themselves, the latter being both against the Code and against the law.

  Our other main points in response to the Analysis are as follows:

  5.  We find minimal reference in the Analysis citing any example of specific individual external activities contravening the Code. We have, nevertheless, asked the PMCPA to comment on the Analysis and its comments are attached. The ABPI invites the Select Committee to provide details of any specific complaints regarding external company activities or published material to the Prescription Medicines Code of Practice Authority (PMCPA) which will take up such matters immediately.

  6.  A number of the products under review in this Analysis have already been the subject of cases considered under the Code of Practice and action taken where breaches have been ruled. The Analysis does not appear to have taken that into account.

  7.  The Analysis gives the impression that all activities that increase the usage of medicines via the application of established marketing techniques are in breach of the Code and not in the public interest. This is quite wrong. The industry is fully entitled to promote medicines to health professionals (and to provide non-promotional information to the public about medicines so promoted) provided that the requirements of the Code are met.

  8.  Moreover, marketing techniques that recognise that decisions are made not by computers but by human beings with needs and emotions are also being adopted by Government on health matters. The Government's White Paper on Public Health issued in November 2004 states (Page 20): "A wide range of lifestyle choices are marketed to people but health itself has not been marketed. Promoting health on the principles that commercial markets use—making it something people aspire to and making healthy choices enjoyable and convenient—will create a stronger demand for health . . ."

  9.  The fact that targeted messages encourage patients to ask health professionals for advice about a disease and could lead to successful treatment of that disease should be welcomed rather than criticised. Government, through the MHRA, has endorsed the use of such disease awareness campaigns. That is quite different from advertising prescription-only medicines to the public, which the Code prohibits and which is not the subject of any of the criticisms made in the Analysis.

  10.  The use of public relations is questioned in the Analysis. This is a perfectly legitimate activity within the confines of the Code. Pharmaceutical companies are entitled to inform the media, particularly when this may involve issues relating to product safety. The support of third party medical/scientific experts in this work is also quite valid.

  11.  The ABPI remains of the view that the Code works well, as set out in the evidence submitted to the Health Select Committee by the ABPI and by the PMCPA. The publication of detailed reports of the outcomes of completed cases shows that the system is fair and transparent.

  12.  We recognise, however, that there is always room for improvement and have outlined to you in our evidence that the Code and its operation is currently the subject of public consultation and review. We will of course ensure that any legitimate issues emerging from this Analysis that are currently not covered by the Code are included in this review.

  13.  In the interest of fairness and balance I would hope that you will reflect the above in any publication of the Institute for Social Marketing's Analysis and accompany it with equal prominence and publication of both this commentary and any being provided by the five cited pharmaceutical companies.



 
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