By Don Elgie
For the pharmaceutical industry, especially makers of prescription medication, the prospect of posting or responding on social media can be a daunting one. The industry is highly regulated, the rules, stringent.
Many pharmaceutical companies choose to avoid social media altogether, rather than risk the prospect of posting something that contravenes the regulations. One has to wonder if this fear is holding back what could be a great opportunity to engage.
While it’s true that the makers of prescription (and even over the counter) medication need to be far more cautious in their use of social media than most brands, there are still ways for these brands to connect with, and engage, people on social media.
But it is important to stay on top of the regulations as they are constantly changing.
Regulation
The pharmaceutical industry has many regulatory bodies. There are global industry regulators, such as the United Nations Health Care Organisation, World Health Organisation and the World Trade Organisation.
UK regulators
The main regulator in the UK is the Medicines and Healthcare Products Regulatory Agency (MRHA). It published The Blue Guide in September 2014.
Advertising prescription only medicines is prohibited. Any mention of the prescription drug’s name on social networking sites, or even in the name of a url, will be seen as advertising. Advertising Standards Association rules must also be adhered to.
Other industry bodies include the Association of the British Pharmaceutical Industry, the Department of Health, the National Health Service and the National Institute for Biological Standards and Control.
US regulators
The main regulator in the United States is The Food and Drug Administration. Its most recent guidance outlines rules that the pharma industry must follow in social media. Including the fact that, regardless of any character constraints, pharmaceutical brands must always add the associated risk information.
“The firm should also provide a mechanism to allow direct access to a more complete discussion of the risks associated with its product.”
Other industry bodies include the Department of Health and Human Services and the Centers for Disease Control and Prevention.
Pharma brands need to keep things general
One easy thing for brands to do to remain within the rules is to keep posts generic. Not mentioning the product in any way, shape or form, instead trying to build a community through discussion of general topics.
The problem is, of course, that once there’s a Facebook page dedicated to a brand, people will use the space to ask questions – from “I think I need to be prescribed X, but my doctor won’t do it. What can I do?” to “Why am I questioned about my painkiller purchases at my local pharmacy?”.
Pharma brands may worry about the regulators when they post to social media, but the general public have no such qualms. Therefore, brands need to decide how they will manage these questions and comments before they set up a social media presence. Outlining a mini terms of engagement on a page, states upfront what will and won’t be responded to and means that the brand can refer back to it as needed.
Promoting awareness of issues
Another way that pharma brands can use social media is by starting awareness campaigns. They may not be able to tell people why they should buy and use their products, but they can engage in wider issues. For example, a vaccine manufacturer may promote proper sanitation as part of a flu prevention campaign, but they won’t post “tell your doctor to vaccinate you with X for best results.”
Pharma brands often choose, correctly, to be deliberately vague when answering questions about their own products, if they respond at all, but they have greater freedom when dealing with the wider issues. (A painkiller maker may choose to discuss the issue of pain management as a whole, rather than what its painkiller can do for the individual.)
There’s nothing stopping pharmaceutical brands from using social media, other than fear of making a mistake and paying considerably for it, but these brands need a full strategic review of their options before taking the social media plunge. There are tremendous rewards to be gained from social media, if it’s managed in the right way.
Need help navigating social media in a regulated industry? Get in touch.
Don Elgie, Non-executive chair, Emoderation
