It’s Time to Get Social Without Fearing the FDA

This post originally appeared on PJA Bow + Arrow.

The FDA takes pharmaceutical social media regulation seriously. Zarbee’s Natural Children’s Cough Syrup recently found this out the hard way, when the FDA sent them a warning letter. Among Zarbee’s infractions Zarbees “liked” the following comment made on October 30, 2013: “Love Zarbee’s this is the only medicine we use for our 2 year old. Colds and congestion clear up in 2 days.” The FDA argues that liking this post is considered an endorsement.

It’s no wonder that fear of the repercussions for improperly handling social media communications has kept many pharmaceutical brands from actively engaging with patients.

Social media has historically felt off-limits to pharmaceutical companies.  Big Pharma did not want to touch the likes of Twitter and Facebook, where regulation from the FDA has been unclear and virtually non-existent. But now the FDA has cleared the way for social media usage with clear guidelines. These guidelines outline the proper use and behavior of pharma companies on the Internet.

What this means for your organization:


  • All information on your site must be monitored. Make sure you have a team to check the accuracy of information.
  • You’re not responsible for user-generated content, but you do have to pay close attention to third party sites. You’re responsible for anything on these sites over which you have influence or control.
  • If an employee acts on your behalf on a personal account, you’re responsible.Make sure that they know that they are a representative of the company and to act accordingly.
  • Thorough, accurate documentation is just as important as ever. You’re at fault if any inaccurate information comes out through your sponsored sites and communities.


Clearer guidelines ultimately mean it’s time to get engaged. The IMS Institute found that nearly half of the top 50 pharma companies are on social media, but few are interacting or engaging with patients. The companies that effectively engage early on will win huge kudos with their patients. With fewer regulatory hurdles, the first-mover advantage of interacting with patients far outweighs the risks associated with social media.

One of the problems that pharma companies face is that most pharma social media teams need training. Medtronic, a medical device company, made itself approachable by training their team to respond appropriately and establishing a presence on Twitter, LinkedIn, and YouTube. Their team continuously monitors social media and answers questions promptly and in a personal manner. The company now has 180,000 Facebook fans.

With the rising occurrence of patient complaints about pricing, dry drug pipelines, and demands for transparency, now is the time to (at the very least) become active on social media. According to Pew Research, seven out of ten adult Internet users search online for information about health. Social media allows you to remedy incorrect information and to become a part of the ongoing conversation about your brand. Participating in the conversation in the digital age will return some agency to the management of your brand.

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