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.

Go Viral Without Making Everyone Sick

I’m sitting four rows up at Hill Holliday’s TVnext and Discovery is talking about live multi-platform programming. The man presenting makes the mistake of saying the “k” word. The word that guarantees your entire audience will zone out. The word that  is the enemy of productivity everywhere. The word that induces images of fluffy cute little critters.


It’s no secret, if you want something to go viral, add kittens. We, as humans, love kittens. Just ask this developer, he outsourced his work to China so he could watch cat videos all day. Or take Work It Kitty for example, which racked up more than 400,000 views in under two weeks without any additional marketing efforts.

But there’s better, on-brand ways to go viral. Draftfcb‘s Ship My Pants for Kmart  uses a clever pun to announce a new service. It’s a joke that everyone can get in on, requiring few cultural cues. Best of all, the joke doesn’t run the risk of offending many people.

Ship My Pants makes great use of social currency to spread a message via word of mouth. Humans have a natural need to belong– to feel like they’re insiders. Talking about Ship My Pants shows that you’re in on the joke. You’re smart, funny, and relevant.

Though, sellers need beware. Not everything you spread turns into delicious buttery goodness. People on the internet have the unfortunate tendency to focus on the negative. Sometimes you run the risk of spreading some bad, moldy dairy.

Draftfcb’s other viral effort, #Iatethebones, has gone viral to a certain degree, but the response has been mixed at best. Some have posted how hilarious the video is, while others have completely derailed the brand, saying the commercial makes KFC consumers look like idiots.

Yesterday, KFC started a U.S.-based promotion that asks consumers to come to KFC and say that they ate the bone in exchange for free chicken. This counters some of the negative WOM marketing KFC is receiving, but the ship has already hit the fan.

These campaigns are prime examples of why advertising professionals need to think beyond going viral. They need to ask themselves some basic questions before green-lighting a campaign: How would the average person react? Will social media reaction be positive or negative? Is there any potential for backlash? How will consumers view the brand once the campaign runs? After it runs?

When it comes to viral campaigns, its always best to prepare for the worst. But it’s still worth pursuing these type of campaigns, because WOM is invaluable–the positive potential far outweighs the risk. A great viral campaign, like Ship My Pants,  creates invaluable, lasting brand equity.

Tragedy Strikes, Humanity Reigns

The tragedy yesterday was shocking for all Boston area natives. But for people who are also ad mavens in the making, like me, it was  depressing  how insensitive some national brands were on social media.

How hard would it be to have a human being monitoring a brand’s social media? It’s not like most of these brands can’t afford a social media expert or two. Besides, this tragedy happened when work was still in session across most of the USA, so someone should have been around to stop these promotional tweets from getting out in the first place.

Unfortunately, many brands had their Twitter set to automatically post and no one was able to stop their release. Other brands were able to pull their promotional tweets in time or delete them soon after.

It’s really sad when people are losing life and limb  and all you get from Burger King is a promotion for coffee.

In contrast to Burger King, fast food giants like Wendy’s and Taco Bell quickly deleted their  tweets.  But they weren’t able to stop them from going up in the first place. McDonald’s was one of the only major fast food chains to directly respond to the tragedy.

It isn’t all bad in ad land, though. Some New England based companies did more than respond– they acted with heart.  Local restaurant chains Fire+Ice and Joe’s American Bar & Grill passed out food to officers and emergency crew.

On the national level, Southwest Airlines was quick to accommodate people, giving homage to the age-old saying that actions speak louder than words.

This type of response shows the importance of the human element in branding. It’s a reminder that the best brands are driven by interaction and an emotional core–they aren’t mindless robots.

Taco Bell Knows How to Put the Social in Media

Brands have long underutilized Twitter, using it as a glorified press release platform, but some are finally getting how to leverage the Twittersphere.

In the past, social media marketing frequently looked like this:

Thankfully, branded tweets increasingly focus on creating a conversation, rather than a linear narrative. Instead of pushing a product line, brands are now wise enough to introduce a topic that consumers might want to discuss. Take this Mcdonald’s tweet for example:

Other brands have recently found success by tapping into events that are culturally relevant. During the Super Bowl black out, Oreo set the marketing world ablaze with a rapidly produced ad that reminded viewers that they can “still dunk in the dark.”

But few brands are as successful at social media as Taco Bell.  The fast food chain proves it  knows how to tell a good, interactive story that uses social media to the fullest.

Taco Bell recently announced  its new  Cool Ranch Doritos Locos Taco, a follow-up to its most successful product ever.  Rather than typing up a tweet saying, “Hey, please come buy our Taco on March 7th. Our bonuses depend on it.” Taco Bell produced it’s first Vine video for the announcement.  Taco Bell then re-tweeted people’s comments about the launch. Taco Bell started conversations with a few, asking them if they wanted to try a Cool Ranch Taco.

Not stopping there, Taco Bell decided to capitalize on Valentine’s Day. They sent, Elijah Daniel (@aguywithnolife), an influential social media user, to a flower shop in New York City, where he found more than a nice bouquet. After giving a secret password to the clerk, he was handed a Cool Ranch Taco. Elijah tweeted the secret password and location of the flower shop to his followers. Droves of people appeared soon after, ready for some taco goodness.

Other brands should take note, because this is how you do a successful product launch via social media.