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education with CPD points, and many of the banner groups support their members with content that has been internally screened. Of course, there are also regulatory consultants like me who can guide you through the complexities of advertising health products and services, with timely, expert and truly independent advice. In your experience, what are the common issues most pharmacies face with their advertising? It often starts with what constitutes advertising. There’s a bit of a blur sometimes between what is information and when that becomes advertising. The definition of advertising is deliberately broad when it comes to therapeutic goods, and encompasses more than posters, pictures in a catalogue or an ad on a screen. As retailers, it’s difficult to disentangle your business from the supply of medicines, thus much of the communication delivered falls into the realm of advertising because it promotes supply from your business. In terms of advertising, what’s the difference when it comes to offering a service for example? When promoting health services that inheritably involve a therapeutic good, pharmacies must be careful to ensure that a particular good is not singled out. An example could be for flu vaccination services: you cannot detail the brand of vaccine you have available. Or if you’re offering respiratory function assessments, don’t use an image where it’s clear which peak flow meter you use. Since food and cosmetics have different rules regarding advertising, what would you say are the most common issues when promoting products that fall under those categories? This is a really complex area, and one that many advertisers find difficult to work in. As you said, foods and cosmetics products are not bound by the same regulations as therapeutic goods and, importantly, cannot make those types of claims. They cannot be promoted as having an impact on ‘normal physiological processes’. Sports supplements and protein powders cannot ‘boost muscle development’, rather they contain nutrients that support healthy muscle growth. Cosmetics don’t ‘reduce wrinkle formation’, they minimise the visible signs of ageing. Tricky, I know, and in a competitive market everyone’s pushing those boundaries to get an edge – you just need to know where the edge is! In today’s environment, you simply cannot ignore social media as a business, but as pharmacists, is advertising in this space worth the effort? There isn’t a one-size-fits-all when it comes to social media so, if it’s worth the effort, it’ll be up to the individual business. My advice would be to give it a good chance by allocating space in your business plan and setting up a marketing plan, then you have a budget and a direction. And before you start, have your moderation policy, and again, remember the rules that apply! I only recently found out that one in three people use social media and the fastest growing demographic for Facebook is the 45-54-year-olds. With more and more going digital, I really don’t think you can afford not to have a presence. Get help if you need it or it’s not your thing. Pharmacists will often come across products that they see and know they work for a certain purpose. Why can’t they simply share their opinion publicly? Registered medicines available for sale in Australia must provide the TGA with evidence that the product works, that it’s safe for use for this purpose and that it meets quality standards. It’s illegal to advertise the product for uses other than what this registration document states. That said, as health professionals, pharmacists can advise their patient on the most appropriate treatment for their condition. In some cases, this could be different from what the registered use is, but that’s the professional’s decision and it cannot be advertised to a wider population. If you or a doctor are recommending a product for a purpose that’s not included on the ARTG for that medicine, it’s generally called an ‘off-label’ recommendation. So, although healthcare professionals may be aware of research and make their own clinical decisions based on that information, the sponsor of that product and anyone promoting the supply of it (eg, retail NEWS IN FOCUS 13 pharmacies) must not advertise or encourage it for any off-label purpose to a healthcare professional. I know from my own experience that there are so many of those statements, and sometimes you’re unsure which one you need to use. Do you need them all in the one advertisement? Oh yes, I have people ask me, too: ‘Why do we need all that extra stuff on our ads?’ That ‘stuff’ is also known as a health warning, and they help consumers to make better informed decisions as to whether the product is going to suit them. You don’t need to use everything, and the information is set out in the TGAC. You just need to know how to read it. Or get some help translating the code. What’s the deal with testimonials, reviews, endorsements and influencers? That’s a huge question. Give me an example and I’ll let you know if it complies with the code, and how we can manage the situation. If you’re going to go down that avenue, and it’s particularly common on social media, be sure you educate any influencer or agency you use, run some pharmacovigilance sessions with your comment reviewers, and be sure to have any content you have control over frequently assessed against the rules. Remember I said before to have a moderation policy. That helps here too. Earlier you mentioned fines and penalties for publishing and broadcasting non-compliant materials. Who takes that responsibility, the publisher or the person who designed and gave them the ad? The TGA investigates advertising complaints. They consider an advertiser’s ‘attitude towards compliance’ when determining the appropriate action and have said on numerous occasions that the preferred path for minor or accidental breaches is to educate the advertiser. In some situations, the TGA may visit the advertiser to provide educational information. Yes, there are some big fines hitting headlines as the TGA takes down dangerous advertising, and in the meantime they aim to support the new self-regulatory process by assisting advertisers to understand their obligations and achieve behavioural change. RETAIL PHARMACY • JUL 2020