Actually I can. You know how drug advertisements look in magazines—it can be like 3 pages of text (aka “product disclosure”) that runs on and on and interrupts whatever you’re reading. Heaven help you if you’re reading Reader’s Digest where 3 pages suddenly becomes 5 due to the smaller format. And if you do take a moment to glance at the ad, you’ve got to be thinking that something that takes that much explaining maybe shouldn’t be taken at all. Be that as it may, enter the brave new world of online advertising…
Well, there’s just no room online to be putting all that junk. Those tightly designed banner ads would become full-page ads with all the disclosure notices included and I guarantee that after coming face to face with a few “impressions” of those, you’ll never click on that website again.
And don’t the drug companies know it. But they need to be pushing their wares online—that’s where all the “growth” is these days. So now, get this—the drug industry’s big guys like Eli Lilly and Pfizer are turning to the FDA for guidance on how to push their goods online. Why? The current FDA guidelines for advertising in traditional print media (magazines, newspapers) or t.v. require all that disclosure information is shown prominently. But there aren’t really any guidelines set for new media—so everyone’s playing by the rules of traditional media, and clearly that’s not good.
Not good for who? Big pharma, but also the bigger online media companies. See the online companies have a bit of a quandary here as well. They WANT big pharma ad dollars, but they just can’t give big pharma all the real estate they need. So they have to get clever—maybe a scrolling drop-down box for the disclosure info…or a click through to another page—? But is that good enough for the FDA? Would it meet the requirements that call for safety disclosure information to be prominent? Some companies, according to the Wall Street Journal (11/12/09), are testing such tactics right now:
For example, a search for “Yaz birth control” would reveal an ad with a link to the official site for the drug as well as a separate line that says “click to see full safety and prescribing information, including boxed warning.” Yahoo is testing a new format for display ads that would include a link inside the ad for safety information.
That sounds all well and good, but in the spirit of “you can bring a horse to water but you can’t make it drink”—is that really enough to guarantee consumers will click through to the warnings and read them thereby guaranteeing that the ads offer “prominent” safety warnings? Heck, a box of Tylenol has more warnings written on it than a fence outside a nuclear reactor, but it still comes under fire for potential acetaminophen overdose—so where do you draw the line?
We’ll have to see. An FDA hearing on disclosure rules for online media took place last week in Washington, DC, so more to come…though it’ll be a while…