To paraphrase the late Dr. Martin Luther King, Jr., “There comes a time when people get tired … and we have no alternative but to protest.”
There has been a lot of moaning and groaning about the FDA’s continued delay in releasing social media guidance. As if it matters. Various DDMAC panjandrums have consistently said that what regulated industry marketers want most, predictable “how to” guidelines relative to specific platforms (FaceBook, YouTube, Twitter, etc.) is not on the docket nor is direction on adverse event discovery, reporting, or responsibility. Expecting a regulatory Holy Grail will only lead to disappointment and frustration. And blaming the FDA when that happens won’t make anything better or move the social media agenda ahead any further or faster.
Social media for regulated industry is a greenfield of opportunity. But to maximize the opportunity, we must accommodate the reality of a messier world. Social media, almost by definition, is messy – and the regulatory framework (or lack thereof) is equally so. And it’s not likely to get much better.
Embracing social media means embracing regulatory ambiguity. And that’s a paradigm shift for an industry that has (in a post-Vioxx world) been going in precisely the opposite direction. Social media (and its game-changing opportunities) demands a move away from the cautious tactics of the Vioxx Populi towards a better understanding of the digital Vox Populi.
Nobody said it was going to be easy. And marketers have to get used to it if regulated marketing is going to succeed and thrive in the 21st century. And that means more than sponsored Google links and branded FaceBook pages with the interactivity turned off. It means mixing it up with real people in real time. It’s not going to be easy, or risk-free, or inexpensive. And whatever social media “marketing models” companies build will have to be elastic – just like the media environment in which they are designed to operate.
The most constructive “podium policy” from the FDA (in this case from Jean-Ah King, special assistant to DDMAC Director Tom Abrams) has been, ““The bottom line is this is a regulated industry, and if you choose to do promotion in that area (social media) just make sure that at the end of the day what we’re looking at is in the best interest of public health.”
Obvious – but important to remember. And, in the words of Winston Churchill, “Ease is relative to the experience of the doer.”
