Ferring Pharmaceuticals: failure to fully withdraw Pentasa leavepiece with incorrect prescribing information (AUTH/3716/11/22)

📅 2022 | 🖉 Dr Anzal Qurbain
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Key facts

CaseAUTH/3716/11/22
ComplainantTillotts Pharma UK Ltd
RespondentFerring Pharmaceuticals Ltd
MaterialPentasa adult summary leavepiece (ref UK-PA-2100024)
Main issueFailure to fully withdraw a leavepiece containing incorrect prescribing information; continued accessibility via a remaining hyperlink
Incorrect vs SPC wording (as described)Material stated division “2–4” doses; SPC stated “two or three” divided doses (once daily also referenced in both)
Timeframe highlighted~11 weeks after confirming withdrawal during inter-company dialogue
Applicable Code2021
Breach clausesClause 5.1
SanctionsUndertaking received; additional sanctions not stated
Complaint received23 November 2022
Case completed24 January 2024
AppealNo appeal

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

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What happened

  • Tillotts and Ferring entered inter-company dialogue about Pentasa promotional material containing incorrect prescribing information for adult acute dosing (division of doses stated as “2–4” rather than “two or three”).
  • Ferring confirmed in a letter dated 2 September 2022 that “materials which include this Prescribing Information have been withdrawn”.
  • Tillotts later found the Pentasa adult summary leavepiece (UK-PA-2100024) still accessible on the Ferring UK Hub via a “view booklet” link.
  • The material remained accessible for around 11 weeks after Ferring’s confirmation of withdrawal.
  • Ferring said it removed the main hyperlinks but missed another (hidden) hyperlink due to website architecture complexity; it accepted responsibility for the error and the incomplete withdrawal.
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Outcome

  • Breach ruled: Clause 5.1 (2021 Code) for failing to maintain high standards due to inadequate control and failure to fully withdraw the material.
  • No appeal.
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