FDA Questions Big Pharma's Online Presence

Just for a bit of behind the scenes, I used to work at the NLM (National Library of Medicine) and I also ran a retail pharmacy in a former life.  Pharmaceutical companies are put through the wringer by FDA regulations.  There may be a cure for the common cold out there but you won't hear about it for six years until it is fully vetted and then approved.  (I'm exaggerating, obviously.  Not about the time frame but about the "cure".)

About 15 years ago, the FDA regulations on drug/side-effect disclosure got drastically tighter.  Just to rip the fodder away from poor stand-up comics, the drug companies were required to reveal ALL side effects experienced by any member of a test study.  So therefore, out of 1,500 people, if two of them got a nosebleed, that has to go into the list of "potential" side effects.  If you've got a drunk signing up for test studies and shows up hung over for his $50, takes the trial, and has a headache afterwards, it gets documented.  That's why those television commericals seem so long on the list of "potential side effects" as compared to what the drug actually does for you.

Not contributing to the article particularly, just thought I'd pull back the curtain for a second.

But then again, how many warnings can you write in 140 characters or less? "Buy Aspirin from Bayer, for your headaches, etc, etc... oh and if you have this or that, or that, or that, or that... (re)... go to your doctor"

that was not my point. Social Media portals like FaceBook are not the ideal places to throw up healthcare billboards. the lights are already too blinding...

What Social Media does for us however, and this was the heart of my post, is show us who people are, what they do, and what they like.  We can learn as much as we need to know if we track social media statistics back using forensic social anthropology. 

What I find so interesting is that the Engagement Layers placed ontop of common-denominator social science are often so blindingly effective, we think that the magnetism of the new site is "dark magic". 

People don't change really change their social behaviors.  this message is lost because so many high velocity enablers are placed just a mouse-click away.  But, Social Mean Reversion is a stronger force. and when FaceBook is gathering dust on the Pop Phenomona archives shelf next to the Spice Girls and Saved by the Bell, we will all scratch our heads, and someone will write a book, and the book reviews will get debated on "NewSocialMediaFrenzy.com". and I will ask you to be my "NSMF Pal"

While it goes without saying that pharmaceutical companies should be as forthcoming as possible in regards to FDA regulations, it seems to me that you shouldn't automatically trust something you saw a banner for on your way back to the farmvile page. 
 
In short, if you have a question about some kind of medication, consult a physician. 

lets combine Universal Healthcare with Outcomes based Reimbursements.  Then to make it more fun, lets completely restrict one of the most cost effective forms of patient communication.  and if thats not fun enough, lets whip up a frenzy of Health2.0 Tech initiatives and not let Pharma play. 

Its really, really easy to criticize health reform. it is really, really hard to make meaningful changes.

I work with big pharma on these challenges daily. I also work with patient groups, payers, and HCP's.  I drive my computer into the eye of the storm on a daily basis.  what do I think?  the most impactful, best performing solutions to solve some of these problems are going to be the ones that are modeled after the people who define the system that we are trying to change: the patient. and because we are all patients of some form or another, and because we are all different, and because many of us are a litlle "funny in the head", the solutions taht will work will be so different from anything that has been seen before that these solutions, when unveiled, will be prodded, poked, scorned, criticized, and otherwise trashed by the same people who, if they took a really good honost look inside themselves, would realize that these new solutions were not created in the Pharma Lab, they were created by modern day Cultural/Social Anthroplogists with advanced degrees in Facebook, and Mafia Wars. the next generation of effective, impactful healthcare tools will be a mirror into our collective souls, and will look as funny as we do. but guess what, the solutions will fit like a fuzzy network of friends on Ning, and offer so little resistance that in between photo tagging and mafia hit jobs, we won't even notice that we are adhering to sublte, but important behavior modifications.....

I formally worked very closely with labeling in OTC pharmaceuticals. I can say that there are MANY regulations regarding print that are watched and adhered to very diligently. However, from a marketing perspective, there is also a close eye kept on any available loopholes. After all, there is a bottom line being watched.

That being said, if there is a way to avoid using 100% of the required warnings, it will happen. If it is mandated that the disclosures be available, I'm sure that a link of some sort to the company site would be simple enough.

As you point out though, the trouble is in the policing of the situation. With labels and ads, there are required submissions to the FDA with every change and companies dare not break that rule. In cyber-space, that is certainly more difficult to keep up with.

You can be certain though that each marketing department is tracking and searching for every comment, post, etc. related to their products. Therefore, it is not impossible for them to look at it from a regulatory perspective as well; providing the proper incentive to do so exists. The fact is that many folks consult the web for pharmaceutical information and the danger of misinformation leading to dire consequences is real and should therefore be addressed.

There's a fundamental question here concerning the nature and function of social networks, and that is: What's the difference between interaction with constituency and potential customers, and marketing and advertising copy? If the pharma companies want to create dialogues with their customer base, do they have to incorporate regulatory language into every blog, tweet, or social network posting? Does the word "casual" ever apply to what pharma companies, or their representatives, have to say about their products?

The kinds of extensive qualifications required by the FDA for TV and magazine drug ads might make it tough to adapt pharma messages to social sites. Where's the room on Twitter for things like "may cause involuntary throat closure that can in rare instances prove fatal"?

Still, the pharma firms found a way to work other media and they'll no doubt find a way onto social sites as well.