You have read the rules. You have memorized the guidelines. But if the sense that the material in front of you feeds directly into someone's prescribing decision — and behind that decision, a patient's body — never quite lands, review stays at the level of formal verification. Perspective-taking is not a feeling of sympathy. It is a cognitive habit of asking, "Who receives this material?" It builds a bridge between knowledge and judgment, grounding abstract rules in someone's concrete situation.

So What / So Why — The Core of This Lens

So what (what changes)  Perspective-taking converts the text of a rule into something a person experiences. In promotional material review, that means replacing the question “Does this safety information comply with the guideline?” with: “A physician reads this material and makes a prescribing decision. A patient then takes that drug. Is the information in the physician’s hands at that moment sufficient?” Compliance with rules and what actually reaches the reader are not the same thing. The gap matters most in gray zones — where formal requirements are technically met but whether an abbreviated disclosure actually functions is impossible to judge by text-matching alone.

So why (why review needs it)  When review stops at formal checking, the reviewer has not traced the downstream impact of the material they approved. Safety information placed in a single line at the bottom gets logged as “present.” Whether a physician actually reads that line, whether it enters the prescribing decision at all — those questions go unasked. The absence of perspective-taking is not a precision problem. It changes what review is for. The MHLW guidelines on promotional activity for prescription drugs require that “negative information also be provided” because those on the receiving end need protection for their judgment. If the reviewer has never once stood in that recipient’s position, the rule stays abstract, a line to check off rather than a purpose to serve.

This is why perspective-taking pairs with the rule-based lens. The rule-based eye asks what must be written. The perspective-taking eye asks what actually gets through. Only when both are active does review function in substance, not just form.

Inside the Lens — What / Where / Why / How

What (what this lens looks at)  It internalizes the subjective situation of the material’s recipients — patients, family members, prescribing physicians, pharmacists. The exercise is to imagine being in a position where this information is all you have, then read the material from there. Concretely: does the volume, order, and emphasis of safety information function in the recipient’s actual cognitive context?

Where (when to apply it)  When judging whether safety information is adequately disclosed. When checking the information balance between patient-facing and healthcare-provider-facing materials. The lens is most useful in the gray zone — where formal requirements are met but substantive function is in doubt. A material where RMP key risks appear only as a single closing sentence; a slide deck that substitutes “please refer to the package insert” for naming any adverse event — those are the judgment calls where this lens earns its place.

Why (why this lens is necessary)  Rules define what must be written; they do not define how much writing is enough for the information to land. Answering that requires imagination about the recipient’s situation. The gap between a formally present disclosure and information that actually functions is invisible without standing in the recipient’s position. “If I were this physician, could I make a prescribing decision on this information alone?” — that question turns text-matching into meaning-checking.

How (the concrete practice)  After a first read, ask again: “Has the patient prescribed this drug been given enough information to choose to take it knowing the risks?” “Could the physician who attended this session learn that this product’s negative data exists?” Carrying these questions into a second read is how perspective-taking enters the review process as a step, not just a disposition. No emotional disturbance is required. Temporarily borrowing a position — a cognitive operation — is enough.

Entering the Perspective — Standing in That Position

What follows reconstructs the situation from multiple parties’ standpoints, based on documented deviation cases. Read it not as assertion but as an illustration of how to borrow a viewpoint — “from this position, here is what you see.”

The patient’s position

Your hay fever worsened that spring, and your doctor prescribed a new antiallergic drug. “It works well,” the doctor said. You have no way of knowing whether you have any contraindications. You also have no way of knowing that in the 20-minute web seminar the prescribing physician attended, information on the drug’s contraindications and precautions for careful use was handled by displaying the package insert on screen for about 10 seconds at the final slide. If the physician later realizes that the contraindication check was insufficient, that process never reaches you. You take the drug as “the one the doctor chose.”

The question to hold: if you were this patient, would you accept a review record that reads “safety information: present”?

The family member’s position

Your father was prescribed a new cardiovascular drug. The physician told him: “International trial data confirm reduced risk of cardiovascular events.” You were relieved. But your father is Japanese. The possibility that the drug’s effect on slowing progression to renal failure may be weaker in Japanese patients, and the fact that initial regulatory approval was withheld, were never mentioned — because the company representative did not raise those points in the online hearing for the hospital formulary committee. The physician might say, “I didn’t know that data existed.” You still don’t know what was missing from that decision.

The question to hold: if you were this family member, would you accept the explanation that “information was disclosed (and questions would have been answered)”?

The prescribing physician’s position

You scheduled an online hearing for the formulary committee. You set aside the time. The company representative explained efficacy data. International trials showed statistically significant risk reduction — that was the message. After the hearing ended, you opened the electronic package insert yourself and found: “In Japanese patients, the effect on slowing progression to renal failure may be weaker.” If the representative’s logic is that it was not mentioned because no one asked, what basis do you have to report to the formulary committee? What do you use to anchor the next prescribing decision?

Standing in the position of this physician — making a decision while uninformed — the omission of safety information is visible not as a technical violation but as an act that corrupts someone’s judgment. That is how the perspective-taking eye works.

Reading Past Deviations Through This Lens

The deviations recorded by the monitoring program, re-read through perspective-taking — not as descriptions of rule violations but as answers to the question “whose judgment was distorted?”

Case 1 — Safety information reduced to the “last 10 seconds” of a 20-minute web seminar (2020 published report)

Format / product area: Web seminar hosted on company site (approximately 20 minutes) / antiallergic drug

What happened: Throughout the seminar there was no mention of indicated patients or important basic precautions listed in the interview form. Safety information — contraindications and precautions for careful use — was provided only by displaying the package insert on screen for approximately 10 seconds at the final slide. The report’s assessment: “Information on safety including contraindications and precautions for careful use was provided only by displaying the package insert on screen for approximately 10 seconds at the final slide” (2020 MHLW Promotional Activity Monitoring Program Report).

Re-read through perspective-taking: The creator likely held an internal record of “the safety slide was included.” As a formal log, “provided” holds. But what the physician who watched this seminar has in hand is the image of a package insert that appeared for 10 seconds. If a contraindicated patient existed, could that physician have used that information in a prescribing decision? Could the patient choose to take the drug knowing the risk? That is what the perspective-taking eye asks. The gap between “present” and “delivered” cannot be seen without standing in this patient’s position. On the structure by which a formally present disclosure conceals a substantive gap, see also Inside the Creator vol.02 “Structures That Outsource Blame — Externalizing Responsibility”. Behind the externalized responsibility, the recipient is left with no one accountable to them.

→ Detailed case in Anatomy of a Failure vol.06 “Overemphasis on Efficacy / Downplaying Safety Information”.

Case 2 — Japanese patient data left unspoken in a formulary committee hearing (2023 published report)

Format / product area: Online briefing by company representative / cardiovascular drug

What happened: In an online hearing for the hospital formulary committee, the representative focused the presentation on efficacy. The electronic package insert explicitly stated: “In Japanese patients, the effect on slowing progression to renal failure may be weaker.” The representative did not raise this point. Japanese patient population data was shown on a separate slide only after a healthcare professional asked a question. The report’s assessment: “Despite the hospital having secured sufficient time for the briefing, this was a case where it is suspected that negative information was deliberately withheld” (2023 MHLW Promotional Activity Monitoring Program Report, Suspicious Report Case 5-1).

Re-read through perspective-taking: The representative’s internal record is “I would have answered if asked.” But from the physician’s position, information that is available only if you ask means making a prescribing decision while uninformed. The only physician who searches for Japanese patient data on their own is one who already knows that data exists. Without knowing it exists, there is no question to ask. Tracing from the physician’s position what happened after the Japanese cohort hazard ratio never came up in the hearing — the perspective-taking eye receives the weight of the report’s phrase “deliberately withheld” not as a regulatory finding but as a gap in someone’s judgment.

→ Detailed case in Anatomy of a Failure vol.06 “Overemphasis on Efficacy / Downplaying Safety Information”.

What both cases share is that the deviation functioned as information that never reached anyone. The rule-based eye ends at “safety information was not provided.” The perspective-taking eye sees a chain: “that physician made a prescribing decision without knowing,” “that patient had no opportunity to learn the risk.” A reviewer who can imagine that chain asks of any formally present disclosure: is this enough?

The Compound Eye of Review ── Map of 10 chapters

  1. Part 1: Two Ways of Seeing — Why Reviewers Need Both the Rule-Eye and the Recipient-Eye
  2. Part 2: Micro-Level Reading — Knowing the Rules, and Why They Exist
  3. Part 3 (this chapter): Perspective-Taking as Method — Making Knowledge Personal
  4. Part 4: The Patient's Eye — I Am the One Who Takes This Drug
  5. Part 5: The Family's Eye — Spouse, Parent, Adult Child at the Bedside
  6. Part 6: The Lawyer's Eye — Can This Material Survive Cross-Examination?
  7. Part 7: The Regulator's Eye — Reading Your Own Materials from the Inspection Standpoint
  8. Part 8: Media & Public Scrutiny — Imagining the Front-Page Headline
  9. Part 9: Integrating Lenses — Switching, Holding, and Merging Perspectives
  10. Part 10: Making the bird's-eye view a habit — reading past failures as a mirror
Key Points
  1. "Present" and "delivered" are two different questions. Safety information existing in formal terms and a prescribing physician actually receiving it as a basis for judgment are not the same thing. As the 2020 antiallergic drug case shows, displaying a package insert for 10 seconds in a 20-minute seminar counts as "provided" in the record. What remains in the physician's hands is 10 seconds of screen image.
  2. Perspective-taking asks who made a decision while uninformed. In the 2023 cardiovascular drug formulary hearing case, negative Japanese patient data surfaced only after a question was asked. A physician who does not know the data exists cannot ask about it. The perspective-taking eye builds that asymmetry — "you cannot ask about what you do not know exists" — into the reviewer's judgment.
  3. Making rules personal is a habit of temporarily borrowing the recipient's position. "If I were this physician, could I make a prescribing decision on this information alone?" "If I were this patient, could I choose to take this drug knowing the risk?" Carrying those questions into a second read is what turns formal checking into substantive review. No emotional reaction is required — borrowing the position as a cognitive operation is sufficient.
References
  1. Ministry of Health, Labour and Welfare. Guidelines on Promotional Activities for Prescription Drugs (September 25, 2018).
  2. Ministry of Health, Labour and Welfare. FY2020 Report on the Promotional Activity Monitoring Program (Document No. 000652563).
  3. Ministry of Health, Labour and Welfare. FY2023 Report on the Promotional Activity Monitoring Program (Document No. 001272191).
  4. Japan Pharmaceutical Manufacturers Association. Promotion Code for Prescription Drugs.
  5. Standards for Appropriate Advertising of Drugs and Other Products (Ministry of Health, Labour and Welfare).
  6. Davis, M. H. (1983). Measuring individual differences in empathy: Evidence for a multidimensional approach. Journal of Personality and Social Psychology, 44(1), 113–126.
  7. Batson, C. D., Early, S., & Salvarani, G. (1997). Perspective taking: Imagining how another feels versus imagining how you would feel. Personality and Social Psychology Bulletin, 23(7), 751–758.
  8. Galinsky, A. D., & Moskowitz, G. B. (2000). Perspective-taking: Decreasing stereotype expression, stereotype accessibility, and in-group favoritism. Journal of Personality and Social Psychology, 78(4), 708–724.