Predictably, the pharma blogosphere is abuzz today with anticipation for the FDA public hearings set to kick off tomorrow.  The public hearing is being hailed in some circles as a shining moment that will herald in the dawn of a new era in pharmaceutical marketing.

Sorry to burst your bubble, but the FDA meeting to discuss social media as it applies to pharmaceutical companies will not singlehandedly change the face of marketing.  It is an important stepping stone for the industry that will surely drive increased attention to the need for social media policies and plans—but don’t expect a tidal wave of social media activity once guidance is issued.  We are more likely to see a ripple effect following these hearings and the resulting official FDA guidance.  And that is how it should be.

As I discussed recently in taking the safe route for social media, it is not in the best interest of any company to tackle the world of social media in one fell swoop.  Pharmaceutical companies have been reticent to engage in social media for multiple reasons—not just a lack of FDA guidance.  If the FDA was to issue clear guidance on how pharmaceutical companies are permitted to leverage social media it would lessen one of the many challenges facing the industry.

The FDA has the ability to ease some of the tension that surrounds social media for pharmaceutical companies by clearly outlining when fines will be levied and based on what parameters they will be doled out.  But hurdles will still exist.   In fact, if we are not careful, FDA guidance could have an adverse (pun intended) effect on the use of social media.  Because the industry has been so dormant in this area, it may be tempted to treat it like any other marketing discipline.  The FDA may very well facilitate this process by establishing an environment where pharma companies are forced to treat social media like advertising.  The impact of this would be incredibly detrimental and would only serve to build on the ill will that has befallen the industry.

I know this sounds like a pessimistic rant, but it is actually intended to be a realistic take on the public hearings.  I am excited about the fact that the FDA is finally holding a hearing on social media and the potential impact it will have on this industry.  It is an important step and one that will cause more than one pharma executive to stand up and take notice of the potential that social media holds.  Already there has been an uptick in awareness and meaningful conversations taking place on the topic.  These are the types of discussions that we need to continue to have in order to help solve not only the regulatory issues being addressed by the FDA, but other challenges as well. This is the immediate benefit of these hearings.

The lesson?  Social media requires a thought-out, strategic plan that takes into account various factors along the marketing spectrum.  One hearing by the FDA is not a silver bullet but it sure advances the conversation.

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