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So the kerfuffle over the U.S. FDA hearing on regulated industries use of the Internet and social media is dying down a bit. Its been a month, so I guess thats normal.

I got caught up in other stuff and didnt get a chance to do a wrap-up, but thats okay, because about 3,467 other people did. Just visit http://www.fdasm.com or search Twitter for hashtag #fdasm and youll have more reading, reports, and recaps than youll know what to do with.

The noise is dying down. But its not over. Not even close.

As youre securing budgets, reviewing your 2010 plans, and wondering if youll have to put any social media on hold, think again.

Dont be paralyzed. Theres still plenty U.S. pharma companies can do with social media in the current environment.

Frustrated that it may be a year or more before FDA issues guidelines? There are still some rules that have set precedent, still rules we can follow, even if they are a bit unclear and more restrictive than wed like. And were lucky enough that many industry trailblazers have participated in social media already with plenty of good examples to follow.

The Rules as We Know Them in the U.S.
Like it or not, here are the rules we have to work with today:

1. Same rules apply. The same rules apply for the Internet as do for print, TV, direct mail, and other offline mediums. Virtually all warning letters issued to date for any online efforts were due to misrepresentation of claims, risk information, and fair balance. It wasnt because of the medium itself. And to date, there has not been one warning letter Im aware of that has been issued for a social media effort.


2. At least for now, space restrictions are real. For now, if theres not enough space to communicate fair balance and risk information when it needs to be there, FDA has made it clear theyre not going to make exceptions. This would apply to branded search engine marketing as well as short-form communications such as Twitter and SMS.

So what can a pharma marketer do? If it makes sense for your brand, you can still be a part of social media. But yes, you still have to play it safe. Heres how:

"Doing" Social Media in Today's Environment

1. Make sure youve laid the foundation. Do you have a cross-functional social media task force in place? Are they working on or have they published a social media policy for your company? If not, what are you waiting for? If FDA opens up the social media doors by clarifying what can and cant be done, dont you want to be ready?


2. Listen in. Ive been thrilled to see a heightened interest from our clients in social media listening. My company, Intouch Solutions, offers trainings on social media listening and conducts Social Media Audits as well. Even if your regulatory folks arent yet comfortable joining the conversation, at least youll know whats being said behind your back. Not to mention other benefits of listening such as:
   >> Brand affinity/sentiment measurement How do people feel about your brand currently? Set a benchmark and, as you launch new initiatives, see how the needle has moved.
   >> Identify the influencers whos talking about this condition, your brand, and your competitors, and how much influence do they have?
   >> Measuring message spread Are your messages spreading, and are they resonating?
   >> Public relations monitoring How well are your PR efforts permeating the space?
   >> And so much more


3. Set up shop. While many argue its not pure social media, take a look at the social media channels such as YouTube that allow some level of control over content. It could be a good idea because (a) At least youll be there, in some capacity, if your customers are searching for you, and (b) Youll have that much more of a leg up over competitors if FDA announces guidelines that will open up features like comments. As always, I recommend not looking at a bag of tactics but seeing what best fits your objectives, but options that might fit this conscientiously controlled channel include:
   >> YouTube channels
   >> Facebook pages and apps (with special controls and moderation in place)
   >> Twitter To be safe, it probably needs to be unbranded for now. For example, we recently launched an iPhone App for sanofi-aventis called GoMeals, and we supplement that effort with a Twitter account that serves in a customer service capacity. Its been a big hit.


4. Claim your space. Make sure youve at least secured your name and accounts on properties such as Twitter, LinkedIn, YouTube, and Flickr (kind of like securing URLs for your company or brand or campaign). Also, consider if youre allowed to officially claiming your Google Sidewiki space. Several companies including sanofi-aventis, Astra Zeneca, and Roche, are starting to do just that.

So as the noise dies down and fades away following the FDA hearings, I ask you this:

Is there really any excuse, given the above, to let your social media efforts fade away as well?