AUTH/2036/8/07: Procter & Gamble—Intrinsa ad placed in public-facing journal (POM promoted to the public)

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Key facts

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Case number	AUTH/2036/8/07
Company	Procter & Gamble Pharmaceuticals UK Limited
Product	Intrinsa (testosterone transdermal patch) (POM)
Issue	Advertisement placed in journal accessible to patients; POM promoted to the public
Channel/material	Print advertisement in Wellbeing / “Wellbeing for Women, Mothers & Babies 2007” (June 2007 edition); ad ref INT-UK3063
How identified	Voluntary admission by the company (treated as a complaint under Constitution & Procedure)
Complaint received	20 August 2007
Case completed	19 September 2007
Applicable Code year	2006
Breach clauses	2, 9.1, 20.1
Panel notes	Company did not establish intended audience; ad not certified (Clause 14 requirement referenced by Panel); seriousness reduced confidence in the industry
Corrective action described	Overstickering materials sent to recipients; no further distribution until overstickering; charity confirmed no further distribution in current form; MHRA and PMCPA informed
Appeal	No appeal
Sanctions	Undertaking received; Additional sanctions: Advertisement

Reviewed by Dr Anzal Qurbain (FFPM) — ABPI Final Signatory

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Procter & Gamble (P&G) voluntarily admitted that an Intrinsa (testosterone transdermal patch) advertisement appeared in the June 2007 edition of the journal Wellbeing (ref INT-UK3063).
P&G believed the journal was intended solely for health professionals because it was distributed to members of the Royal College of Obstetricians and Gynaecologists (RCOG) and the publisher said content was under editorial control of a senior RCOG fellow.
In practice, recipients (health professionals) made copies available to patients, typically by placing the journal in waiting rooms.
The Panel noted the full title was “Wellbeing for Women, Mothers & Babies 2007” and considered it should not have been a surprise that it was intended for the public.
The Panel was extremely concerned P&G had not established the intended audience and that the advertisement had not been certified (as required by Clause 14, although Clause 14 was not listed as a breach in this case record).
P&G worked with the publisher to send materials to oversticker the Intrinsa advertisement so patients could no longer see it; the charity confirmed it would not distribute further copies in the current form.
Although 100,000 copies were produced, P&G stated approximately 3,500 recipients actually received the journal; each received enough materials to oversticker 30 copies, plus a freephone number for queries.
P&G informed the MHRA and the PMCPA and monitored for consumer contacts (none were reported).

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Breach ruled of Clause 20.1 (promotion of a POM to the public) (acknowledged by P&G).
Breach ruled of Clause 9.1 (high standards not maintained).
Breach ruled of Clause 2 (seriousness reduced confidence in the pharmaceutical industry; particular censure).
No appeal.

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