Early this week, Scrip published an article that notes that the FDA still considers social media a “high priority,” even though the agency’s working list of topics in need of additional guidance hasn’t included social media in a couple of years.
It’s tempting to say that the FDA’s continued commitment to more explicit rules really doesn’t matter. At WCG, we’ve been consistent for years in our belief that no company need wait for the FDA before wading into social media. There are well-established, safe ways into interact online, and the simple act of setting up a blog or responding on Twitter is no longer causes eyebrows to arch or tongues to wag. (For an excellent example of how one large pharma company — that happens to be a client — is plunge ahead, check out Fast Company’s examination of Sanofi’s efforts.)
That doesn’t mean that there haven’t been consequences, and I outlined some of them last December. But most of my concerns from last year have been allayed, in part, by the rising number of successful case studies and trial-and-error advancement made by the pharma industry in moving forward (cautiously), even without rules.
But one of the consequences I didn’t talk about then was the impact of the FDA’s inaction on smaller companies: organizations that don’t have the legal support or regulatory know-how to test undefined waters. Though pharma is sprinting ahead in its exploration of this space, biotech companies remain laggards, and the smaller the company, the more resistance there is to implementing social media platforms without some sort of solid direction from the FDA.
Increasingly, these are the groups that need guidance the most: more and more of the important conversations — among patients, among investors, among doctors — is taking place online. And while my colleagues at WCG can certainly present options and show how others have done it safely, there is no stack of case studies high enough to outweigh the positive impact of FDA action.
So this week’s news that the FDA still “committed to this area in terms of both time and human resources”, could mean good things around the corner. Especially for those who need it the most.