Select Committee on Health Written Evidence


Supplementary memorandum by Pfizer Ltd (PI 130)



  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 Marketing Documents.

  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 law.

  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.

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Prepared 26 April 2005