Last week we wrote about the challenges of communicating about our products through new media channels. Two items from this week's news are illustrative of some of the unique issues with which we must contend when writing about our business.
An NPR story on the rise of pertussis cites doctors' anecdotal reports on "an increase in the number of parents refusing to vaccinate their children against childhood diseases." As a manufacturer of vaccines we have an obvious business interest in pediatric vaccines that we believe aligns with public health interests. The NPR story fairly addresses a significant public health issue so we'd like to highlight it on our blog. But not so fast... we must first ask ourselves whether doing so could be seen as promoting our products. If it is viewed that way, then we have an obligation to include additional information about the product in question.
So, it isn't straightforward when a vaccines manufacturer communicates about vaccines. There are times when even our disease-oriented communications might be interpreted as promoting our products, thereby requiring that additional information be included along with the mention of our products (approved indication statement, safety information, submission to FDA etc). Many factors, including a pharmaceutical company's position in a particular market (ie, if they are the largest or only manufacturer of a product for the disease under discussion) and the product's approved indication can inadvertently raise the perception that the communication is promotional.
When it comes to Twitter, there isn't much collective experience or precedent for any of us. So it isn't surprising that as one blog pointed out, Pharma hasn't nailed it yet. However, in our view, the FDA's recent communications on sponsored links raises questions about how Twitter can be used to communicate about prescription drug products. For example, FDA has made clear that the short 100 or so character ad copy used in sponsored links cannot be used for anything deemed to represent what the product is used for, without also including the safety information about the product in the sponsored link - a difficult challenge in such limited space. Including a direct link to the product's website where all the important information about the product is spelled out is not sufficient.
So before making claims that "Pharma doesn't know how to do this," we ask that you take into consideration that there may be much larger issues at stake governing the way we communicate.