ASA Adjudication on GlaxoSmithKline UK Ltd

Ad

A magazine ad for Piriton Allergy Tablets claimed "Although pollen is Britain's most common allergen, you may not be aware that around 103,000 people are allergic to leather, 644,000 to house flies and 181,000 to squirrel fur. The fact is, people can develop an allergy to just about anything". A labelled photograph made claims for the number of Britons allergic to photocopier toner dust; tomatoes; squirrel fur; breath spray; acrylic glue; wasp stings; hair dye; moisturiser; ants; windscreen wiper fluid; gold; deodorant; paint dye; mosquito bites; rats; trees; detergents; avocados; dust; chilli; perfume; kiwi fruit; spices; sweat; artificial fingernails; leather and nylon. Text stated "Allergy figures extrapolated from a TNS survey of 16-64 yr olds".

Issue

The complainant, a doctor, challenged:

1.  whether the ad was misleading, because he believed not all the materials listed caused allergic reactions; some caused adverse reactions only and he believed those could not be treated with the product;

2.  the accuracy of the claimed number of people allergic to each substance, because the numbers had been derived from a survey in which respondents self-diagnosed their allergies, rather than from diagnoses made by medical professionals and

3.  whether 774,000 Britons were allergic to sweat, because he believed that sweat allergies were rare.

CAP Code (Edition 11)

Response

1.  GlaxoSmithKline (GSK) said Piriton, an antihistamine, contained chlorphenamine maleate, which was used to control all allergic conditions responsive to antihistamines.  GSK said they had included surprising and thought-provoking allergens in the ad.  They sent a copy of the Summary of Product Characteristics from the product licence issued by the Medicines and Healthcare products Regulatory Agency (MHRA) for Piriton, which stated " ... Piriton allergy tablets are indicated for symptomatic control of all allergic conditions responsive to antihistamines, including hay fever ... food allergy, drug and serum reactions, insect bites ...".  GSK said squirrel fur, rats, trees and dust caused allergic rhinitis, a condition of the nose caused by exposure to allergens; they sent information from the National Health Service (NHS) that explained that allergic rhinitis could be caused by tree pollen, dust mites and domestic pets.  They sent medical papers that stated that allergic contact dermatitis could be caused by: acrylic glue; artificial fingernails; breath spray; deodorant; detergents; gold; hair dye; leather; moisturiser; nylon; paint dye; perfume; photocopier toner dust and windscreen wiper fluid.  They sent two medical papers that showed that people could have histamine allergic reactions to their own sweat.  GSK said some of the substances listed in the ad could cause either irritance or an allergic reaction; they therefore understood why the complainant, albeit mistakenly in their view, believed some of the materials did not cause allergic reactions.

2.  GSK said they had surveyed 4,166 UK adults aged between 16 and 64 years.  They said the results had been weighted to make them representative of the UK population as a whole.

GSK said the ad made clear that the numbers of allergy sufferers had been derived from a survey and did not imply that all the diagnoses had been made by medical professionals, although they believed that some respondents would have been diagnosed by a medical professional.  They acknowledged that there was a risk that respondents could incorrectly categorise themselves as allergic to a substance when the basis of their reaction was in fact a result of irritation or intolerance, but said the survey had been designed to minimise the number of respondents who made that error by listing the common symptoms of an allergic response.  They gave an example of a typical question: "Which of the following foods do you suffer an allergic reaction to? By allergic reaction we mean symptoms such as itchiness, redness, swelling, tenderness and irritation.  You may also get itchy or runny eyes or nose" and said respondents who merely felt something "disagreed" with them or "were sensitive to" a substance would be unlikely to describe themselves as suffering from those symptoms.  They said itching was a typical symptom of an allergy.  They said they had not included symptoms such as pain or soreness, because those were likely to be the result of irritant contact dermatitis.

GSK said consumer surveys were frequently used to estimate the prevalence of diseases, particularly those that were mild and often not presented to a healthcare professional, and that those consumer surveys were often used to advertise healthcare products.

They said NHS guidance on allergic rhinitis stated that its prevalence and incidence were difficult to assess accurately, because many people self-diagnosed and treated themselves with over-the-counter allergy products.  It also stated that people with mild symptoms might not perceive them to be serious enough to seek advice from a healthcare professional.

They said NHS guidance for contact dermatitis (of which allergic contact dermatitis was a sub-group) stated that there were no good epidemiological studies on the prevalence of the condition in the UK.  GSK believed, in the absence of such evidence, consumer surveys were suitable to estimate the prevalence of allergies.

3.  GSK said 774,000 people represented 2% of 16 to 64 year olds in the UK.  They sent a medical paper which showed that 2-10% of adults had atopic dermatitis (eczema) and that sweat induced by heat or exercise could provoke an exacerbation of that condition.  They also sent a medical paper which showed that 84.4% of patients with atopic dermatitis were allergic to their own sweat.  Using those figures, they calculated that 1.69-8.44% of adults in the UK had atopic dermatitis aggravated by sweat.

GSK said another condition, urticaria caused by sweat, was a type of cholinergic urticaria. They sent a medical paper, which said 11.2% of young adults had cholinergic urticaria, and another which found that 64.7% of patients with cholinergic urticaria showed positive reactions to their own diluted sweat. Using those figures, they calculated that 7.24% of young adults were affected by urticaria caused by sweat.

GSK believed, therefore, the number of survey respondents who diagnosed themselves as allergic to sweat, when weighted to represent the whole UK population, was a reasonable representation of the likely number of people affected by those conditions in the UK.

Assessment

1.  Not upheld

The ASA considered that GSK had shown that Piriton could be used to treat the food allergies (tomatoes, avocados, chilli, kiwi fruit and spices) and insect bites (wasp stings, ants, mosquito bites) listed in the ad.  We noted from the NHS information that allergic rhinitis was an allergic condition responsive to antihistamines; we were satisfied that squirrel fur, rats, trees and dust allergies could cause allergic rhinitis and that Piriton could therefore be used to treat allergic reactions to those things.  We noted allergic contact dermatitis could be treated with antihistamines such as Piriton and considered that GSK had therefore substantiated that the product could be used to treat allergic reactions caused by the 14 substances listed in the ad that could cause that condition.  We noted sweat could cause allergic reactions, which could be treated with antihistamines including Piriton.

We considered that GSK had shown that all of the substances listed in the ad could cause allergic reactions, which could be treated with Piriton.  

On this point we investigated the ad under CAP Code clauses 3.1 (Substantiation) and 7.1 (Truthfulness) but did not find it in breach.

2.  Upheld

We noted text at the bottom of the ad stated that the figures had been extrapolated from a survey of 16-to-64 year olds and considered that that made clear to readers the source of the information. However, we considered that, although GSK said the questions in the survey listed the common symptoms of an allergic reaction, some respondents could mistake non-allergic adverse reactions for allergic reactions.  We considered that, because they were not supported by diagnoses from medical professionals, the results of the survey were not an appropriate basis on which to estimate the number of people nationwide suffering from allergic reactions to each listed substance.  We noted that good epidemiological studies did not exist for all of the advertised allergies but considered that that did not mean consumer surveys could be used to accurately measure numbers of allergy sufferers.  We concluded that GSK had not substantiated the accuracy of the claimed number of people allergic to each substance.  

On this point the ad breached CAP Code clauses 3.1 (Substantiation) and 7.1 (Truthfulness).

3.  Upheld

We noted that the figure of 774,000 people, which had been extrapolated from the survey responses, was within the estimates of the numbers of people with atopic dermatitis aggravated by sweat and urticaria caused by sweat which GSK had calculated from the figures given in the medical papers.  However, we considered that, because the 774,000 figure had been derived from a survey in which patients had self-diagnosed their allergies, rather than from diagnoses from medical professionals, the results of the survey were not an appropriate basis on which to estimate the number of people nationwide suffering from allergic reactions to sweat.  We concluded that GSK had not substantiated the claim.

On this point the ad breached CAP Code clauses 3.1 (Substantiation) and 7.1 (Truthfulness).

Action

We told GSK to ensure that they held suitable evidence to substantiate claims made in future ads.

Adjudication of the ASA Council (Non-broadcast)