Any platform where a company can engage directly with potential customers is obviously a powerful tool to be harnessed; a healthy social media presence is important for the success of most businesses. When you work in regulated markets like pharmaceuticals or alcohol, engaging with a potential customer base can get a little tricky, especially where “tricky” means harmful and expensive. Let’s agree that this is also your working definition of “risk”.
It would be hard to argue that a company’s social media presence is anything besides a more dynamic outlet for advertising. For regulated markets, mitigating risk even when advertising in “traditional” platforms like print and TV gets a bit lumpy (e.g. the pretty ad with a lady enjoying a tire swing has to be that much more appealing to allay the turn-off of a full page of micro print describing risks and side effects), but the rules and implications around use of social media is fuzzier, so those risks can grow.
Enter Reg-SM, a new launch from the social-media marketing agency, Attention. Reg-SM specializes in helping businesses in those regulated markets use social and mobile media in ways that are legally compliant.
Just in time, it seems, as last week the FDA proposed new guidelines for companies who post about their drugs or medical devices on social media platforms. The guidelines would require that any tweet or post or unit of social media speech (air quotes optional) promoting a drug or medical device to include the product’s risks and adverse side effects. It’s hard for me to imagine a worthwhile tweet about a prescription drug anyway, but to jam anything but the risks of a drug into a tweet seems impossible.
Always helpful, the FDA has offered a sample tweet for a fictional drug that sounds kind of attractive to me.
NoFocus (rememberine HCl) for mild to moderate memory loss-May cause seizures in patients with a seizure disorder www.nofocus.com/risk
Sign me up, I guess. Quick aside, though: how odd for a drug to be named after not the affliction (still weird), but the cause of the affliction the drug is meant to address. When I have a headache I reach for my bottle of JawClenchesWhenSleepDeprived.
These new guidelines are going to make it very difficult for companies to tweet about their products. The FDA’s NoFocus conveniently has only one risk to list, but even relatively safe drugs often have a number of possible side effects and risks. While I’m not sad about maybe never seeing a tweet about Viagra, these guidelines don’t seem to demonstrate a working knowledge of the platform.
Possibly more quietly impactful, the guidelines also prohibit a company from curating discussions on it’s own website by adding positive reviews and taking down negative ones.
JamesWimberley says
Tweeting puffs for prescription pharmaceuticals - as Annie implies, if they work they are dangerous - is a reductio ad absurdum of allowing advertising to consumers in the first place. As a regulated European, the practice strikes me as crazy and demonstrably has no health benefits. Limited liability corporations are slaves and should speak when spoken to.
paul says
Alas, over here, limited liability corporations are immortal persons of immense wealth that somehow can have deeply held personal beliefs but no consciences.
My bet is that those guidelines get interpreted so that a single “there may be risks” and a link to the drug’s (or the company’s) web site are considered sufficient. Oh, and you can astroturf, you just can’t do it directly. Someone will have to be watching Mechanical Turk listings very carefully.
On the other side, once you start doing tweets and hashtags, pretty much anyone can use them, which is something for which most companies seem thoroughly unprepared.