Supplementary memorandum by Pfizer Ltd
RESPONSE TO THE INSTITUTE FOR SOCIAL MARKETING'S
REPORT "DEALING IN DRUGS: AN ANALYSIS OF THE PHARMACEUTICAL
INDUSTRY'S MARKETING DOCUMENTS"
1. Pfizer is responding to the committee's
request for comments on the Institute for Social Marketing's report,
Dealing in Drugs: An Analysis of the Pharmaceutical Industry's
2. The inclusion of the words in the title
of the report "Dealing in Drugs", is in our view gratuitous,
and undermines the serious nature of the research, development
and discovery process that produces medicines.
3. Our overall impression of the report
is that it is based on a poor understanding of the ABPI Code of
Practice for the Pharmaceutical Industry, and fails to recognise
the role of pharmaceutical marketing in assisting patients with
gaining access to medicines.
4. The report complains that "three of
the five companies produced a very limited set of papers".
Pfizer complied with the request for two years' worth of promotional
and product support materials for three of our medicines. The
committee's request arrived by email after 5.00 pm on Friday 10
December with a deadline of Friday 17 December, which is five
working days. Pfizer provided 21 boxes of materials and did not
receive any further requests for information from the committee
or the Institute for Social Marketing.
5. The report alleges in an aggregated and
anonymised format that there were instances where the materials
reviewed appear to have contravened the ABPI's Code of Practice.
It is not clear from the document whether the Institute for Social
Marketing understood that the Code focuses on the external activities
of the industry that are directed towards health professionals
and the general public. The Institute for Social Marketing had
access to internal company documents that were never intended
for use with either health professionals or the general public,
and it appears to have included these documents in the report,
even though they would not normally be subject to the Code.
6. Marketing activities, such as disease
awareness campaigns, inform patients about their diseases and
encourage them to speak to their doctor. The report seems to object
to the pharmaceutical industry encouraging patients to present
to the medical services but Pfizer is proud to have run disease
awareness campaigns encouraging patients to seek treatment for
life threatening asymptomatic conditions, for example, high cholesterol
and blood pressure. In doing so, we believe we are helping the
NHS to achieve its objectives as set out in the cardiovascular
National Service Framework, and helping GPs to achieve the targets
outlined in the GMS contract. These initiatives should be welcomed
rather than criticised.
7. Communication with the general public
through disease awareness campaigns is regulated by the criminal
law and policed by the Medicines and Healthcare products Regulatory
Agency (MHRA) as well as by the ABPI. The MHRA issued guidelines
on disease awareness campaigns to the pharmaceutical industry
in June 2003 that defines ethical and appropriate communication
with the general public. For example, the guidelines state that
disease awareness campaigns must increase awareness of a disease
or diseases and provide health educational information on that
disease. The guidelines state that disease awareness campaigns
must not encourage patients to request a specific medicine. So
far as we could tell, none of the examples of "breaches"
quoted in the report breached the Code of Practice, the MHRA guidance
or the law.
8. Pfizer has been able to identify that
one of its documents is referred to in the report in the section
entitled "Market Research" where the industry is criticized
for "identifying populations who are not currently presenting
to the medical services for diagnosis and prescription of medicines.
This population dubbed the `missing millions' are estimated to
include almost two million people within the UK". The report
fails to recognise that the research that it objects to was undertaken
as part of an assessment of the potential to convert a particular
medicine from a Prescription-Only Medicine (POM) to a Pharmacy
medicine (P) ie to change the regulatory status of the medicine
so that it can be advertised directly to patients. It is worthy
of note that the Medicines & Healthcare Products Regulatory
Authority is generally supportive of companies seeking to convert
appropriate POM medicines to P status. Clearly, in this context,
the conduct of market research is entirely justified. The wording
quoted from the market research document is that of the market
research agency, not Pfizer. The market research referred to in
the report has not been used for any purpose in relation to the
promotion of a prescription medicine or raising awareness of a
particular disease and is therefore a legitimate piece of work.
We are gravely concerned that this research has been quoted out
of context and judged against the standards applicable to the
advertising of POMs rather than those applying to pharmacy medicines.
This shows a lack of understanding of the Code.
9. The report criticises pharmaceutical
companies' use of public relations to counteract negative publicity.
Pfizer believes that it has a right to defend its medicines and
to respond to media coverage, particularly when it is misinformed,
and may involve product safety issues. Public relations is a perfectly
legitimate activity for pharmaceutical companies and can help
to educate and inform health professionals and patients about
scientific advances and promote understanding of certain diseases.
This activity is also regulated by the Code of Practice and the
10. The report seems to object to the advertising
of branded Prescription-Only Medicines to health professionals
but it is important to recognise that this is expressly permitted
by the law and the ABPI Code of Practice.
11. The report portrays a lack of understanding
of the ABPI Code of Practice and the legal framework applying
to the pharmaceutical industry. We recognised one example cited
in the report and are deeply concerned that it appears to have
been taken wholly out of context and criticised for failing to
comply with standards that do not apply to it. Similarly, from
what we can tell, the examples used to demonstrate non-compliance
with the Code appear to have been taken from companies' internal
documents that are not subject to the Code. This undermines our
confidence in the entire report.
12. The pharmaceutical industry is one of
the most extensively regulated industries in the world. Our communications
about medicines with doctors and patients are constrained by the
criminal law and policed by the MHRA, as well as by the ABPI.
Pfizer believes that self-regulation is effective in regulating
the pharmaceutical industry's external communication and marketing
activities. The ABPI Code of Practice is currently the subject
of public consultation and review.