Is it possible?
In a comment to the FDA on Regulation.gov, I described a Tweet that may pass muster with the FDA.
Here's my comment:
"The draft guidance does not mention Tweets accompanied by images, which is perhaps a way to present ISI along with benefit information in the tweet itself," I said. "I have created a mock-up using Lipitor as an example."
Here's a screen shot of how this tweet would look on Twitter:
|My mockup of an ad that may pass FDA muster re Branded Rx Tweets|
The shortened version of the URL makes it plain that the link is to a page devoted to risks -- a requirement mentioned in the guidance. That page also links to the coupon information, which is OK to do according to the FDA guidance document.
In addition, the tweet includes the total ISI (important safety information) as a JPG image, which is clearly readable on the Twitter page as shown in the screen shot above.
A caveat: An image takes 26 characters away from the tweet, so there is even less space to use for promotion. But as my example shows, it's possible.
My question: Do tweets such as this satisfy the requirements of the guidance document?
What's your opinion?