With the long-awaited FDA public hearings on social media in pharmaceutical marketing set to kick off this week, the PhRMA has fired a warning shot.  Yesterday, the PhRMA released a statement suggesting the idea of an “FDA-approved Use of Universal Safety Symbol,” for branded/sponsored health information online.

For example, this symbol could be used if a pharma company was linking to branded content via a Tweet or through a paid search ad.  The intent is to distinguish legitimate, authorized content online from the content that is not sanctioned by the FDA.  This symbol would be used in much the same way as the safe-harbor for DTC advertising on television—as long as it points to a regulated site with all of the risk information presented than it would be in bounds.

Even as I write this post, I am not sure where I come down on the usefulness of this kind of symbol.  On the one hand, the intent is clearly in the right place.  By offering a solution (where few people have) the PhRMA is acknowledging that it recognizes the value in social media tools.  The PhRMA is attempting to present a solution that eases the trepidation most pharmaceutical marketers currently feel when approaching any type of online marketing effort.  Clearly, patients are congregating online and there needs to be a plan in place that allows pharmaceutical companies the ability, and freedom, to reach those patients.

On the flip side, an FDA-approved symbol seems to send the wrong message to pharmaceutical marketers about the way they should be communicating online.  In going this route, the FDA would essentially be treating social media tools just as they have handled TV and radio ads in the past.  In the case of social media, we are dealing with a very different platform with a new set of rules that govern the community.  Applying old methods of regulating the industry to this community could fall on its face.  When we discuss social media strategies with our clients, we always implore them to stay away from blatant product promotion.  Because social media is about adding as much value as you extract, it does not lend itself to overt product promotion.  The FDA-approved symbol may help with advertising models, but it doesn’t really address social media because it circumvents the community dynamic.  With this symbol, pharmaceutical marketers might be tempted to simply push branded content out through social media channels.  That’s not community engagement, that’s advertising.

Ultimately, if pharmaceutical marketers are to get engaged with social media it should not be as a means to only push advertising and branded Websites.  So while this proposal by the PhRMA does get the conversation started, I am not sure it sends the right message on proper community engagement.

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