How Can The Life Sciences Industry Best Use The Internet And Social Media?

Do you remember the first time you used the Internet?  I do – and I’m not sure how I survived before that glorious day.  Needless to say, the Internet is now an integral part of our personal and professional lives.  Social media is a large part of why that has occurred.  It has increased the usefulness of the Internet and our dependence on it by connecting people in an efficient and effective way. Businesses have long used this connective force to reach consumers.  Companies utilize blogs, Facebook pages, Twitter, Google search optimization, YouTube and many other mediums to connect electronically with current and potential buyers and to market their products. The Life Sciences Industry, however, has been hesitant to dive fully into these waters without clear guidance from the FDA.

The FDA delayed issuing draft guidance on the use of the Internet and social media until sometime during the first quarter of 2011.  This delay leaves the waters murky, as it is difficult for companies to predict how the FDA might apply the law.  In the context of the Internet, the FDA’s marketing and promotional standards become anachronistic and ill-fitting.  They are not suited to the quick, compact and catchy formats provided by the Internet and popular social media. For example, how can a company attach a full PI or boxed warning to a typical Internet advertisement that’s smaller than a business card and flashes on the screen for seconds at a time? Furthermore, when people use the Internet, they rarely stay in one place for very long and have the power to navigate away from anything in which they are not interested. Getting users to skim their eyes over your brand name or product name while reading analysis of their favorite football team (Go Bears!) is about as much as you can expect.  If the FDA takes a conservative approach, they will likely ban or severely limit marketing that cannot display a fair balance of safety and risk information.

This will probably push Life Sciences companies to utilize social media sites that capture an audience for an extended period of time  and provide connections to other people, organizations, activities, and events, such as Facebook. To me, that’s where the value in using social media lies – getting people to spend time at your site, learning about them, and connecting with them and their network of contacts. The challenge seems to be creating a page or site that people want to visit often and for extended periods of time. While several companies have Facebook pages already, it will be interesting to see how companies use and develop their Internet strategy once the FDA begins to issue guidance on the Life Science industry’s use of social media.

Interestingly, according to the FDA’s website, when the draft guidance is finally released, it will touch on one of the following six areas:  responding to unsolicited requests; fulfilling regulatory requirements when using tools associated with space limitations; fulfilling post-marketing submission requirements; online communications for which manufacturers, packers, or distributors are accountable; use of links on the Internet; and correcting misinformation. While all of these areas are relevant, timely and important, they only begin to touch on the universe of issues that FDA will ultimately have to address as the Internet and social media become more important marketing tools for Life Sciences companies.

Given Facebook’s utility, popularity, and high profile (“The Social Network” was great, by the way), I anticipate that the draft guidance will attempt to address Facebook.  How will the FDA adapt its regulatory approach to the increasingly important role of the Internet and social media?  In the meantime, the industry must wait and wonder how it can best utilize these fantastic tools for connecting with consumers.