Pharma: Don't Wait For the FDA

The phramaceutical industry has long felt itself "unique" due to regulations that hold it back from full frontal social media activity. Adverse events reporting, fair practice and DTC rules were in place before twitter, before facebook and even before or oblivious to blogs. Still most pharmas feel they are uniquely ill-suited to listen to patients and spark conversations. Some use social media platforms as a way to distribute content. Some are getting over their terminal uniqueness and seeing that there are lessons to learn in all directions. Also, everyone knows the FDA will not blaze new trails here and will only act to respond to the worst of missteps. So everyone looks to their pharma brothers and sisters to innovate first.

Media Post covered an interview between EyeonFDA and well, the FDA, this past month. As you might expect, they are not passing judgement on anything:

"The upshot is that the FDA doesn't categorically prohibit pharmaceutical companies from engaging in social media. "It's not the medium, it's the message," explained Dr. Jean Ah Kang, special assistant to Tom Abrams at the FDA's Division for Drug Marketing, Advertising and Communications, in charge of Web 2.0 policy development." 

"Even so, it's likely that big pharma will remain reticent about plunging into social media marketing, barring more explicit guidelines from the FDA."

Pharma Marketing Blog covered this interview and the keynote at the eMarketing Summit where Sanjay Koyani, Director of FDA Web Communications, gave a keynote.

"On both occasions pharma eMarketers had their ears perked up to hear what the agency had to say about regulation of pharmaceutical marketing on the Web and especially on social networking sites.

On both occasions, we were disappointed."

Don't Wait

Can pharma look to other markets for lessons? Is it all moot because of their unique situation? A few pharmaceutical companies have been experimenting with communities, corporate blogs, sponsored conversations around issues (not products), and content distribution via YouTube and Flickr. And considering some of the jam-ups in traditional marketing where a pharma here or there has taken it on the chin for mistakes, it would seem about time for some real trailblazing in social media. If there legal teams are allowing them to take risks with traditional advertising then surely they can push the envelope a bit in social media.

• Don't wait for the FDA

• Don't wait till your nearest competitor hits a homerun
• Don't wait until the economy recovers (long wait)
• Stop considering your situation unique
• Look to all sorts of businesses for lessons-learned and do the hard work of finding the application to your own situation
• Build the capacity to try pilot programs to accrue learning and data

Comments

[Jonathan Richman]

I wrote about this same thing earlier in the week (http://bit.ly/vqn5F) and agree with you, John.

Also, many companies aren't waiting. Here's a list of all the pharma related social media projects out there (http://bit.ly/B3PR7)

[John Mack]

Pharma doesn't have to wait for the FDA to get engaged in social media. However, it should not be left out of the process when FDA decides to issue guidance. Nor should the public!

Sooner or later FDA will issue guidance and it will affect what the industry is doing.

I am calling for a public hearing at FDA to bring in all stakeholders -- pharma companies, healthcare professionals, consumer advocates, publishers, ad agencies, legal/regulatory experts, technology companies, Web site owners, etc. -- to advise the FDA BEFORE it issues guidance.

I invite you and your readers to take my survey regrading their opinion on a public hearing. Take the survey here: http://tinyurl.com/d9kxmy

Thank you.