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Friday, January 27, 2012

Taking the "Cool" Way Out of Having Rx Product Convos on Social Media

I have criticized pharma companies for mentioning Rx brand product names via social media. Mostly because they forget to include fair balance or don't educate the public (see, for example, "Novo Nordisk's Branded (Levemir) Tweet is Sleazy Twitter Spam!").

That doesn't mean, however, that I don't believe there is a way for pharma to engage in branded product discussions via social media such as Twitter and Facebook (see, for example, "Breaking the 140-character Limit of Twitter Opens the Door to FDA-Compliant Branded Tweets").

It appears that most pharma companies have decided not to engage in these kinds of discussions and are implying that FDA regulations prevent them from doing so.

Take for example a discussion about Paula Deen on the Novo Nordisk Facebook wall (here) . Amidst the criticisms and defenses of Novo was this statement by "Tanya", a representative of Novo Nordisk:

"Hi Darcy, I had to remove your post becuase (sic) you mention a product name, which we are not allowed to have on our page - even if you post it yourself. Can you repost without mentioning the product name? Sorry! -- Tanya"

Unfortunately, I can't see what product was mentioned because the post was deleted. Duh! However, it was probably Victoza -- the diabetes product that pays for the endorsement by Paula Deen.

I infer from Tanya's statement that there is some FDA law or regulation against mentioning product names on the Novo FB page. In fact, there is no such law or regulation. And in other "social media" contexts -- such as my BlogTalkRadio show -- Ambre Morley, Associate Director, Product Communications, Novo Nordisk, didn't seem to have any problem mentioning the product name. In fact, she didn't point out the possible side effects (fair balance). I'm not sure if she broke the law there or not (you can read a summary of that discussion here; use code '1111nvd' to get it free; or listen to the podcast here).

Are pharmaceutical companies missing an opportunity to educate people about their products by "handling" posts as Novo did in the above example?

Some people actually think this policy of removing posts that mention products is a good thing. Idil Cakim, for example, said "the Novo Nordisk community manager 'played it cool' by only reminding the fans of the FDA guidelines" (see "Novo Nordisk Handles Paula Deen Reactions on Facebook").

I should have put a "sic" next to "FDA guidelines" because there are NONE! Tanya only reminded people what Novo Nordisk's POLICY is. [To be more clear, Tanya SHOULD have said "it is our policy not to mention product names."] I guess Idil -- one of "the world's best social media thinkers" featured on socialmediatoday.com -- also inferred from Tanya's statement that there was a LAW or guidelines.

There are, in fact, some new FDA guidelines for dealing with certain branded communications on social media (see "Review of The Social Media Guidelines Nobody Expected!"). These guidelines only apply to "off-label" discussions on social media sites. I don't know if these guidelines were applicable in this case.

Tanya may have "played it cool," but she missed an opportunity to really inform her FB visitors about Victoza, assuming that was the product mentioned in the deleted post.

But without more encompassing FDA social media guidelines, every pharma company will just continue to take the easy "cool" way out and censor any mention of product names on its social media sites.

P.S. Dear Novo Nordisk: Sorry that I seem to be focusing on you these past couple of weeks! But you ARE in the news a lot these days. I'm not sure it's helping or hurting the sales of Victoza because you don't mention the drug much in public statements about Paula Deen or on your Facebook page. That's fine. Just so you know. I'm not picking on you exclusively. I've gone on posting binges against Pfizer, Boehringer-Ingelheim, and practically every other pharma company. So, please don't take it personally.

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