Q（Question）

A physician or pharmacist at a hospital department or pharmacy has requested information on unapproved drugs, off-label drugs, or unapproved dosage regimens. When that person is out and unavailable, and the company is asked to provide the information instead to another physician or pharmacist in the same department or pharmacy, may it do so?

A（MHLW answer）

Providing information in accordance with the conditions of this guideline is permissible.

However, in such cases, it is necessary to take care to confirm that the requesting physician or pharmacist and the alternative recipient are coordinating with each other regarding receipt of the information.

Items requiring particular attention: (2), (3)

So what (meaning): Delivering the information to a colleague of the absent requester is allowed, but only after confirming that the two parties have coordinated so that the substitute's receipt reflects the original request.

So why (rationale): Without coordination, the alternative recipient may not have made a genuine request in their own right, which would undermine the request principle (item 3) and the fairness requirement (item 2).

Commentary — background, application, practical notes

This question covers proxy receipt—the situation in which the person who originally requested information is unavailable, and the company is asked to deliver the information instead to a colleague in the same department or pharmacy. The answer permits this, but conditions it on confirming that the original requester and the substitute recipient are coordinating with each other regarding receipt of the information.

Typical scenarios include a physician in a hospital department saying in advance, 'If the materials arrive while I am out, please give them to my colleague,' or a head pharmacist requesting that a junior pharmacist receive information on their behalf. In both cases, the permissibility rests on the pre-existing coordination between the requester and the substitute.

The common error is when a medical representative independently decides to extend delivery to another member of the same department without being asked to do so by the original requester. If the representative selects the substitute on their own initiative, there is neither a direct request from the substitute nor confirmed coordination with the original requester, making the provision non-compliant. Coordination need not be documented in writing, but it must be confirmed in advance—after-the-fact confirmation is insufficient.