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What on earth is Instagram

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Questions I Intend to Ask DDMAC Director Thomas Abrams at the ePharma Summit

I've noticed that FDA's DDMAC Director Thomas Abrams has been making presentations at several recent drug industry conferences. At the 10th Annual ePharma Summit that begins today in New York City (see here), Abrams presentation is titled: "Regulation and Oversight of Prescription Drug Promotion: Update from DDMAC," which is similar to presentations he's made at other conferences.

Of course, as I mentioned in a previous post ("11.5 Things I'd Like to Learn at ePharma Summit"), most attendees of the ePharma Summit are looking for updates on FDA's guidelines for use of the Internet and social media by pharmaceutical companies; ie, Where are they? When are they? What are they?

From a preview of Abrams' Powerpoint presentation, it appears that he will have very little to say in answer to these questions. Only 3 out of 46 slides concern social media guidelines. Two slides merely summarize what we already know: how many people made presentations at the November 15, 2009 public hearing and how many comments FDA received to the public docket.

The third slide describes the FDA's guidance sausage-making process (shown below; click for enlarged view):

Again, nothing new: Abrams, for example, has said before that FDA will issue "multiple guidances." We are somewhere in the "Prepare a draft guidance document and vet through internal clearance process" stage; ie, the sausage is jammed in the machine.

Here's what I hope to ask Tom Abrams at the Summit (if he allows questions from the audience):

"Tom -- I hope I can call you 'Tom'; I've seen you at so many of these conferences that I feel we should be friends on Facebook or Twitter if not in real life, but I can't find you on these social networks, so maybe I should stick to Mr. Abrams: What's holding up the process of releasing SM guidance? For example:

• "Has President Obama's recent executive order for government agencies to review all regulations old and new to determine if they hinder economic growth thrown a monkey wrench into FDA's 'Social Media Guidance Process'? That is, is the FDA's guidance process slowed down because of this extra internal review that is required?

"Any comments at all about this issue that might be affecting the FDA's guidance process will be appreciated."

BTW, look for me wearing a special shirt, which may or may not be this one:

The Socialisation of the Internet is Bogus

"The whole web is now socialised..." said Alex Butler in a pharmaphorum interview ("Psoriasis 360: How pharma can do social media").

Alex does NOT mean that socialists have taken over the Internet, although, if you think about it ... hmmm. I digress...

"We live in a post-advertising age where messages no longer resonate without dialogue, and where information is best exchanged through community," said Butler (see "Social media doesn't really exist" and listen to this Pharma Marketing Talk podcast interview of Alex Butler: "Is 'Social Media' a Distinction Without Meaning in Today's World?"). "But although it is tempting to think that contact is now king, in fact high value dynamic content, valued by the consumer, has never been more important...there is little of value on the internet that is not socialised in some form, even if it is just the capacity to comment and share. So how as an industry can we influence the exchange of ideas and information if we are not prepared to be where our audience and communities exist?"

When all is said and done, what Alex is really saying is that commenting, sharing, and all that community stuff really is second fiddle to content. Throughout his comments to pharmaphorum, Alex refers to Facebook, Twitter, etc. as "channels" through which he reaches his audience to deliver valuable content.

Some agencies and consultants are telling their pharma clients that social media is NOT a channel -- it's a different way of interacting with people online. Frankly, I think that is bogus.

First, VERY FEW PEOPLE on the Internet -- and that includes Facebook and Twitter -- are social. I mean VERY FEW are socializing with entities like brands and corporations or even real people from companies, publications, and other corporate entities.

For example, there are about 20,000 individuals that VISIT (and presumably READ) this blog every month. Maybe 12 or so submit comments and perhaps a few dozen tweet (share) the content with their friends online. I suspect the ratios are similar at publications that receive a lot more comments and shares. That is, at least 98% of visitors to blogs, Facebook, or Twitter followers are "lurkers" -- they don't socialize, they read.

Which is just fine with me! I don't have time to socialize with 20,000 visitors to this blog and I'm sure you don't have time for that either! (Which is the #2 reason why the Internet is NOT social. Or is that part of reason #1? Whatever!)