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Shop Talk: Pharma CCOs on "Vicarious Liability"

Compliance challenges in the life sciences sector


On March 25, 2010 Compliance Week and Deloitte co-hosted an executive roundtable focusing on the topic of compliance challenges facing the life sciences sector. The forum was attended by a dozen compliance officers from the pharmaceutical and life sciences sectors, including David Hodgson and Mark Stehr, both partners with Deloitte & Touche LLP, each with a focus on life sciences companies.

According to executives at the roundtable, the threat of strict vicarious liability - also known as “Park liability” to the legal cognescenti, named after a court case affirming the principle - has created great uncertainty for pharmaceutical executives, due to the Food, Drug, and Cosmetic Act. The question now is whether the case could set a broader precedent across other industries.

“Most companies want to do the right thing. They want to be responsible corporate citizens ... [But] it can be difficult for companies and individuals to have a clear understanding of what the government wants them to do.”
- David Hodgson, Partner, Deloitte & Touche LLP

To read more from the roundtable discussion, download the attached article, which was originally featured in Compliance Week's May 2010 edition.

As used in this document, “Deloitte” means Deloitte & Touche LLP, a subsidiary of Deloitte LLP. Please see for a detailed description of the legal structure of Deloitte LLP and its subsidiaries. Certain services may not be available to attest clients under the rules and regulations of public accounting.

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