Pharmaceutical companies with Facebook pages were until today in the privileged position of being totally in control of their pages with users unable to post comments on their walls. Today, Facebook rescinded this privilege and turned comments on.
The previous policy gave the pharmaceutical industry a degree of protection not afforded to companies in other industries. The result has been mixed with some pharma giants simply turning off or closing their pages and others expected to implement new community management policies.
There was actually a logic to pharma companies enjoying this protection as the pharmaceutical industry is such a highly regulated and conservative industry that it is governed by rules that make it hard to do the same social media and social network engagement that other industries can. Just one of the practical problems they face are the rules that exist in various global markets (including the USA and UK) requiring companies to report all adverse events and adverse effects to the relevant regulators. If consumers are free to post allegations and claims about side effects then how does a company handle these claims with the regulators?
According to US Food and Drug Administration (FDA) guidelines there are four factors that must all be triggered in order to create an adverse event that must be reported:
- An identifiable patient
- An identifiable reporter
- A specific drug or biologic involved in the event
- An adverse event or fatal outcome
These guidelines have been in place since the 90s and despite requests by the pharma industry, the FDA still hasn’t provided any clear guidance on how these triggers apply to the new social media and social network connected world.
The ‘get out’ for pharma companies would appear to be that it is unlikely that many comments posted online or on Facebook pages would trigger all four of these criteria. A research paper published by Nielson Online in November 2009 found that in fact hardly any healthcare-related conversations contained sufficient information. Out of 500 healthcare-related messages analysed just one contained sufficient information to trigger the FDA’s four requirements.
The Washington Post has a good round-up of what steps some pharma companies have already taken. It appears that many, at least initially, are simply shutting down their pages. AstraZeneca has already shut down a page about depression (it sells the antidepressant Seroquel) and Johnson & Johnson is closing four pages today.
An alternative option for companies is to publish a clear social media editorial policy so consumers know exactly what is and isn’t allowed. They can then implement vigorous community management procedures to block and remove comments that violate the policy. Although it doesn’t sound very open and transparent or social media, consumers can be understanding and supportive if the rules seem fair and they understand the rules and why they are there. After all, it’s better to have some conversations in a managed environment than no conversation at all.
Disclosure: I’ve previously provided corporate communications consultancy to companies in the pharmaceutical and healthcare industries.