Topics FY2020 Meeting of Code Administration Managers and Practitioners" held
The Pharmaceutical Manufacturers Association of Japan (PMAJ) Code Compliance Promotion Committee held the "FY2020 Meeting of Code Administration Managers and Practitioners" on September 29, 2020. The meeting was attended by code management managers and code practice managers from 72 member companies, and was conducted according to the program shown in Table 1, making it a meaningful meeting. The following is a summary of the meeting.
Table 1 Program of the "FY2020 Meeting of Code Administration Managers and Practitioners
Opening remarks
Prior to the meeting, Makoto Hatano, Chairperson of the JPCPA Code Compliance Promotion Committee, stated the basic policy of the Committee for FY2020: "The Code Compliance Promotion Committee is committed to ensuring that member companies comply not only with relevant laws and regulations but also with voluntary codes, including the JPCPA Code of Practice, and that they conduct themselves in a socially responsible manner as members of the life-related industry with high ethical standards. Supporting the fulfillment of social responsibility with high ethical standards as a member」 and Priority Tasks「 Support member companies in promoting compliance」「 Promotion of appropriate information disclosure based on transparency guidelines」「 Compliance with guidelines on activities to provide sales information on ethical drugs」「 Government and JFPA、 JFTC、 The presentation outlined "cooperation, collection and dissemination of information, and feedback with the government and related domestic and international organizations such as JFMA, JFTC, IFPMA, etc.".
He also stated that the committee will participate in international compliance promotion activities such as the APEC Business Ethics Forum 2020 to be held in October to gather global trends and disseminate information on the efforts of the Pharmaceutical Manufacturers Association of Japan (PMAJ).
The Pharmaceutical Manufacturers Association of Japan (PMAJ) Code Compliance
Promotion Committee
Makoto Hatano, Practice Committee Chairman
Cases of Pharmaceutical Association Code of Practice Violation Actions
Mr. Hiroaki Mizoguchi, Deputy Practice Chair of the Code Compliance Promotion Committee, stated that he hopes that the Code Compliance Promotion Committee fully understands that the concept of "measures" is to require violating companies to make voluntary improvements. He then explained the viewpoints of the measures and other aspects of the measures for the two new cases of measures added after September 2019: "Provision of Taxi Tickets to Deemed Government Employees" and "Catch Phrase Competition".
He pointed out that the violations were long-standing and widespread, that governance weaknesses were taken particularly seriously, and that although the violations had already been stopped, the measures to prevent recurrence lacked specificity and could not be said to have been fully implemented. He explained in detail the criteria for determining whether the violation was "minor or not minor," and whether "the conduct was stopped and appropriate measures to prevent recurrence were taken. He concluded by explaining past cases in which weak governance was pointed out, especially "cases in which senior management was involved," "cases in which the product information overview review department was not functioning," and "cases in which there were deficiencies in the internal management system," hoping that the presentation would serve as a reference for promoting Code compliance at each company.
Pharmaceutical Association of Japan Code Compliance
Promotion Committee
Hiroaki Mizoguchi Deputy Practice Committee Chair
(5) Measures for the Month to Promote Understanding of the Code
Kenta Suzuki, a member of the Code Compliance Promotion Committee, reviewed the Code Understanding Promotion Month in FY 2019 and explained the measures to be taken in FY 2020.
First, he reported on the results of the questionnaire survey of member companies regarding the 2019 Month for Promoting Understanding of the Code: "Trust - To meet society's expectations," which is the theme for fiscal 2019, "It was an opportunity to rethink what is required by society as the pharmaceutical industry," "It is an important theme for the company," and "It is an important theme for the company as well. With regard to the "Inspection Items for Our Workplaces," 93% of the respondents answered that the theme setting was appropriate, such as "It was an important theme for the company, and we took prompt and appropriate actions at the head office and branches," and "We tried to remind the employees by describing and posting items to be inspected with emphasis," and "Specific items were set according to the nature of work. The "Inspection Items for Our Workplaces" were also set up, with 96% of the respondents saying that they were meaningful, for example, "We were able to set up specific items according to the nature of our work, which made the items more realistic.
Next, regarding the theme for FY2020, he explained that "Trust," which was highly evaluated by the member companies in the survey, would continue as the theme for FY2020, and that the subtitle would be "What is required of you now? ~He explained that the subtitle of the theme was "What is required of you now?
As background to the theme, he explained that in October 2019, the Guidelines for Provision of Marketing Information on Ethical Drugs will be fully applied, and in December 2019, the revised Pharmaceuticals and Medical Devices Act will be promulgated, which requires pharmaceutical companies to further improve their legal compliance systems. In addition, in December, the revised Pharmaceuticals and Medical Devices Law was promulgated, which requires pharmaceutical companies to further improve their legal compliance systems. He also requested that, as a life-related company, each department and workplace, based on the Pharmaceutical Manufacturers Association Code of Practice, establish its own specific items for proper corporate activities and conduct inspections to ensure thoroughness, in order to continue to earn the trust of society.
The Pharmaceutical Manufacturers Association of Japan (PMAJ) Code Compliance
Promotion Committee
Kenta Suzuki Practice Committee Member
Special Lecture 1
Mr. Keita Nohara, Advertising Guidance Officer, Supervisory Guidance and Narcotics Control Division, Pharmaceuticals and Consumer Health Bureau, Ministry of Health, Labour and Welfare, gave a lecture titled "Monitoring Project for Sales Information Provision Activities".
Mr. Nohara gave an overview of the "Fiscal Year 2022 Sales Information Provision Activity Surveillance Project," and explained the main points of the project, highlighting the main cases of questionable reports. He stated that "inappropriate sales information provision activities are still being conducted in the "closed" environment where pharmaceutical company representatives visit medical institutions to explain products and provide information to on-site physicians and pharmacists," and that "pharmaceutical companies should take the following actions to ensure that medical professionals properly verify and ultimately use pharmaceutical products appropriately. Pharmaceutical companies need to provide information requested by healthcare professionals so that healthcare professionals can properly verify and consequently use pharmaceuticals appropriately.
He also called for "the appropriate and accurate provision of information, both positive and negative, for the safe and proper use of pharmaceuticals," and for "the inappropriate provision of information to be an opportunity to review the company's overall system and education, rather than a problem for MRs and other front-line workers.
He concluded by saying, "I hope that MRs and others will devise ways to provide balanced explanations of efficacy and safety even in the face of the new coronavirus disaster, reduced opportunities and time to visit medical institutions, and limited provision of information. He concluded by saying, "I would like to keep a close eye on the way information is provided through the Web and other means.
Ministry of Health, Labour and Welfare, Pharmaceutical and Consumer Health Bureau
Monitoring, Guidance and Narcotics Control Division
Mr. Shota Nohara, Advertising Guidance Officer
Special Lecture 2
Dr. Shinichi Watanabe, Professor of the Pharmaceutical Affairs and Informatics Unit, Teikyo Heisei University Faculty of Pharmaceutical Sciences, gave a lecture titled "Research and Study on Guidelines for Activities to Provide Information on the Sale of Ethical Drugs".
Mr. Watanabe gave an overview of the "Survey Research on the Actual Situation of Companies in Relation to the Enforcement of the Guidelines for Provision of Information on the Sale of Ethical Drugs," which has been conducted to date, and stated that "This research is scheduled to be conducted as a three-year MHLW Science Research project from FY 2005 to FY 2021," and that "The survey on the status of response to the establishment of in-house systems conducted in the previous fiscal year was conducted by each company. The purpose of this study is to promote the development of internal systems at each company, and is not intended to provide administrative guidance.
Then, from the results of the survey conducted in FY2019, he introduced the status of responses of the four surveyed organizations and pharmaceutical companies regarding "establishment and members of the supervisory department and the examination and supervision committee," "examination of materials for sales information provision activities," "evaluation and education," "implementation of monitoring and guidance such as monitoring," "response to inappropriate sales information provision activities," "complaint window," etc. The status of response by the four organizations surveyed and member companies of the Pharmaceutical Manufacturers Association of Japan (PMAJ) was presented.
In closing, he stated that he hoped that the results of this survey would be used as a reference to check their own systems and that the provision of information by manufacturers and distributors to healthcare professionals is essential for appropriate drug treatment, and that they should continue to provide appropriate information for patients who need pharmaceutical products.
Teikyo Heisei University Faculty of Pharmacy and Pharmaceutical Sciences
Pharmacy and Informatics Unit Professor
Mr. Shinichi Watanabe
Closing Remarks
Tokuo Tanaka, Executive Director of the Pharmaceutical Manufacturers Association of Japan (PMAJ), thanked special speakers Mr. Keita Nohara and Mr. Shinichi Watanabe, and expressed his appreciation for the participation of code administrators and code practitioners in this meeting.
He also stated that although the number of violations of the Pharmaceutical Association Code has not decreased, there is no doubt that the attitude of code administrators and code practitioners to show that they are paying close attention is a major deterrent, and requested that they continue their activities in the future.
Regarding the disclosure of information under the transparency guideline, which is the cornerstone of "trust," the meeting noted that although the disclosure has been voluntary since it started in 2013, not a single member company of the Pharmaceutical Manufacturers Association of Japan (PMAJ) has continued to disclose information for the past seven years without missing any items required by the Clinical Research Act (principle method, printable and searchable). These facts were reflected in the "Results of the Survey on the Enforcement Status of the Clinical Research Act in the Fiscal Year 2028" issued by the Economic Affairs Division, Medical Affairs Bureau, Ministry of Health, Labour and Welfare.
Regarding the monitoring of sales information provision activities, he requested that if the person to whom the information was provided felt that the information was inappropriate, we must improve our activities, and that we should take this opportunity to share the report with all employees and reflect on our own actions, rather than thinking that the fact that our company was not pointed out to us was someone else's problem.
He concluded by saying that "research and development of new drugs" and "compliance" are two wheels that go hand in hand, and that unless everyone involved in the pharmaceutical industry fully understands and practices compliance on a daily basis, they will not earn the trust of society.
Mr. Norio Tanaka, Executive Director, Pharmaceutical Manufacturers Association of Japan
(Code Compliance Promotion Committee, Practice Member Hiroyuki Yoshimine )
