by Barry James from Wolf21.com
Emerging Problems for Big Business as they Tap into Social Media’s Marketing Potential
Online marketing through social media sites, although a powerful and growing advertising strategy, is relatively new and – as its stands now – overwhelmingly the purview of small business and tech companies. As big business inevitably enters the social media advertising market, an interesting bell weather of how big business will fare in the social marketplace, and what challenges they will face, is playing out at hearings of the Food and Drug Administration. The FDA is currently examining what cautionary measures and regulations, if any, they can impose on the highly-regulated pharmaceuticals industry as Big Pharma launches itself into the blogosphere.
Print media as diverse as the National Journal and the New England Journal of Medicine have weighed into the discussion of how the FDA – which has regulated pharmaceutical advertising since the days of snake-oil salesmen, or 1906, to be precise – will adapt its regulatory oversight to the largely unregulated domain of social media. (For my part, I have been monitoring how this issue is playing out on, PharmaGossip.blogspot.com, a Blogger micro-blog dedicated to tracking the pharmaceutical industry.
A recent post on PharmaGossip by multi-disciplinary medical researchers, Jeremy Greene and Aaron Kesselheim (both are medical doctors, while Greene holds a Ph.d. and Kesselheim has additional degrees in both law and public health), examines what policy options may be available to the FDA as advertising from large pharmaceutical companies inevitably makes its way – intentionally or unintentionally – onto powerful peer-to-peer social sites, such as Facebook and Twitter.
Greene and Kesselheim note that in 2008, when Facebook and Twitter were in their infancy with only 350,000,000 combined worldwide users, sixty percent of Americans already went online as their first step in looking for health related information. Yet, they note, “(t)he drug industry allocated less than 4% of the more than $4 billion it spent on direct-to-consumer advertising to Internet outlets in 2008, and only a tiny fraction of that was for social networking sites.” With social media participation booming, the FDA convened public hearings in November, 2009, to deal with how social marketing by Big Pharma companies should be regulated so that adequate information about promoted drugs (such as possible risks and side effects) is passed on to online consumers.
We are all accustomed to how TV ads for the plethora of drug products treating everything from osteoporosis to high blood pressure are concluded by a rapid-fire and almost incomprehensible recital of possible side effects and risks. The same applies to print ads that list out the possible perils of prescribed meds in fonts so small a magnifying glass is almost mandatory. These blurs of warning are not, as many would presume, the product of lawyers seeking to shield drug manufacturers from possible litigation (although I am sure they are cited as a defence in litigation); rather, they are product disclosures that have long been required by the FDA in traditional advertisements in order to protect public health.
How to enforce such consumer protection regulations has now become highly problematic. How is it possible to track third party blog postings, or even more problematic, anonymous or near-anonymous comments by apparent consumers, in order to ensure the public is made aware of information they probably need? Further, how in the heck would it even be possible to list all the possible side effects and risks of a drug in a Twitter post limited to 140 characters?
Greene and Kesselheim report that Big Pharma companies have been using a ‘one-click rule’ on their proprietary websites, “ensuring that risk information was no further away than a single tap of the finger.” However, they note, “this approach remains controversial; in April 2009, the FDA issued warning letters to 14 manufacturers who sponsored search-engine ads for prescription drugs in which there was no obvious connection to a statement of risks.” A further issue, they point out, is that once a promotion enters the social media ether-sphere, drug companies “may [and, almost assuredly, will] lose control of the promotional message.”
This is essentially the same problem faced by all big corporations who spend millions of dollars every year promoting and enhancing the “brand” that defines their operations and products: How do you protect and shape a brand once you’ve tapped into the peer-to-peer networking of social media?
It is not only Big Pharma facing such concerns. How do you effectively Tweet about the gas mileage of the latest hybrid car while qualifying the estimate of mileage without all the fine print of city versus highway mileage etc. required by government regulators and your legal department? How do you effectively protect your proprietary and intellectual property once you have purposively put it into the public domain?
The approaches taken and results of the FDA hearings into the use of social media advertising by the pharmaceutical industry is sure to shed light on many of the pitfalls and risks large business will have to face in the ever-burgeoning social media marketplace. Meanwhile, for the consumer, caveat emptor is as applicable as ever; and, perhaps more so, as we increasingly rely on our social networks for important information. Who do you really trust?