At first glance, the Facebook fan page for Epilepsy Advocate is like many others, with regular updates, shared links and a small base of supporters.
But the page, launched in October, is different from most in two crucial respects: it doesn't allow comments or even the ability to "like" an item.
Welcome to the world of social media for regulated industries like pharmaceuticals. The Epilepsy Advocate is a so-called unbranded community run by pharma company UCB, maker of epilepsy treatments. As a drugmaker, UCB has to take a cautious line with its social Web efforts for fear of running afoul of rules set for all pharmaceutical advertising by the Food and Drug Administration that often make what's allowed or not rather murky.
While UCB isn't mentioned on the site, the company still has obligations under the FDA regulations. For instance, if a user reported an adverse reaction to its treatment there, UCB would need to report it to the FDA. What's more, pharma companies can be held liable by regulators for people discussing off-label use of their products on their sites. That means the dynamic back and-forth of social media ends up getting replaced by a particularly static experience.
"The concept and value of the social medium as this unconstrained exchange is not consistent with the regulatory constraints," said Chris Kuenne, CEO of Rosetta, which built the Epilepsy Facebook page for UCB.
It is a common feature of many pharma-related Web sites that the key social features, like commenting, are turned off. Nexium, a drug from AstraZeneca, has a Facebook page that won't let visitors post to its wall, comment on its posts or share them. Yet the drugmaker does take a step towards social with a heavily monitored social area. All posts are moderated before they're posted to the site. The restrictions make the page a mostly one-way communications channel with only a handful of posts from consumers, and several discussion topics without any consumer input at all.
"One mistake can mean the FDA forcing the pharma company to take the drug off the market," said Shiv Singh, social media lead at Razorfish. "They're justifiably extra-cautious in this realm."
The gray areas that exist have led some pharma companies to shy away from the first tenet of social media marketing: listening. Some choose to use online monitoring data at an aggregate level since they are required to report any adverse conditions they come across. Jeremiah Owyang, partner at social media consultancy Altimeter Group, said that's even led to drug companies blocking employees from visiting social sites out of fear they'll come across a report of an adverse reaction.
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