"Charming spot." (He turns, advances to front, halts facing auditorium.) "Inspiring prospects." (He turns to Vladimir.) "Let's go."I was reminded of this play while listening to a panel discussion yesterday at the 9th Annual ePharma Summit in Philadelphia. At least one panel member -- Dennis Urbaniak, VP, Customer Channels and Innovation, sanofi-aventis -- advised attendees not to wait for the FDA to publish its much anticipated guidelines regarding regulation of pharmaceutical marketing on the Internet and social media sites.
Vladimir says: "We can't."
Estragon: "Why not?"
Vladimir: "We're waiting for Godot."
"If you are expecting clarity in any kind of guidance," said Urbaniak, "I would encourage you to go back and read current guidance about any other advertising channel that exists today. My fear is that there is a bunch of people out there hoping to get the answer and once it comes it's still going to be vague because it has to be -- you have to take your own risk position. And it's going to take another year for you to figure out what to do. So I'd like to shift the dialogue away from 'Is it coming?' and 'When is it coming?' because it implies that the answer IS coming."
But like Godot, the "answer" will never come.
Urbaniak suggested that the dialogue be shifted to "How can we take what we know today and responsibly put forward guideposts now?"
Personally, I do not think that FDA guidance is particularly vague. Guidelines for broadcast DTC, for example, clearly state what has to be included in TV drug ads; namely, information where consumers can get more complete information. The guidance specified using a 1-800 number or referring to a publication where the complete prescribing information can be found. That's pretty clear to me.
But I think the main point Urbaniak was trying to make was that no matter what the FDA guidance may specify, each company will have to interpret it according to its own tolerance for risk. Some pharmaceutical marketers like to take risks and push the envelope. They are willing to get FDA warning letters and push back when necessary. Others are more risk-adverse and do not want to receive any letters from the FDA.
At the end of Beckett's play, Vladimir says:
"We'll hang ourselves tomorrow. Unless Godot comes."
Estragon says: "And if he comes?"
Vladimir: "We'll be saved."
Save yourself! Understand your risk tolerance and put up your social media marketing guideposts. If you need help, take my Social Media Pharma Marketing Readiness Self-Assessment. Good luck!