AUTH/3386/9/20: Health professional v GlaxoSmithKline (low carbon inhalers website) – No breach | PMCPA Case

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Key facts

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Case number	AUTH/3386/9/20
Complainant	Anonymous health professional
Company	GlaxoSmithKline UK Limited
Material	Public website page on low carbon inhalers (https://lowcarboninhalers.co.uk/public), ref NP-GB-RS-WCNT-190008 (November 2019)
Main allegations	Indirect promotion to the public; lack of balance/disparagement of pMDIs; product-claim style statements; missing AE reporting statement; disguised promotion via NICE decision aid link; unclear third-party linking; high standards
Clauses considered	2, 9.1, 12.1, 26.1, 26.2, 26.3, 28.6
Panel decision	No breach of the Code
Complaint received	14 September 2020
Case completed	19 February 2021
Applicable Code year	2019
Appeal	No appeal

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

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An anonymous health professional complained about GSK’s public website page: https://lowcarboninhalers.co.uk/public (ref NP-GB-RS-WCNT-190008, November 2019).
The complainant alleged the page encouraged patients to ask HCPs to change treatment by stating: “Discuss with your nurse, doctor or pharmacist whether a low carbon inhaler is appropriate for you”.
They alleged the page was not fair/balanced and disparaged pMDIs, citing prominent wording such as: “A high carbon MDI inhaler has a carbon footprint that is 18x higher than a low carbon DPI inhaler”.
They alleged statements were effectively product claims (eg “Do you think about your inhaler’s carbon impact?”) rather than factual information.
They alleged the page lacked an adverse event reporting statement/box.
They alleged disguised promotion because the page linked to a NICE patient decision aid (“Use this decision aid with your doctor or nurse to choose the right inhaler for you”) which included an image of a GSK Ellipta device among other inhalers.
They alleged the page did not make it clear users were leaving the GSK site when clicking reference links (no pop-up).

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No breach of the Code was ruled.
The Panel found the page did not promote a prescription-only medicine to the public and did not encourage readers to ask for a specific prescription-only medicine.
The Panel found the material was non-promotional, so it could not be disguised promotion.
The Panel found it was sufficiently clear from the descriptions and URLs that reference links took users to third-party sites/documents.
The Panel found an adverse event reporting statement was not required because the material was not intended specifically for patients taking a specific prescription-only medicine (noting GSK nevertheless included a “Report an adverse event” link).
The Panel found no evidence that high standards had not been maintained.

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