YouTube + Poor Oversight = FDA Trouble

Here is a cautionary tale for Rx/Dx companies thinking about social media.

The Boston-based Prescription Project said Wednesday that it has filed a petition asking the U.S. Food and Drug Administration to force North Chicago-based Abbott and two other medical-device makers to remove their YouTube spots.

The group says Abbott has four videos on YouTube that promote Xience, its new drug-coated heart stent that was launched in the United States in July. The videos “contain none of the federally mandated warnings or provisions required of medical-device advertisements,” the group said in a statement.

Now, I don't think this was malicious in any way or a way to "skirt" laws as stated in the article. Probably the easiest thing that you can do is post videos to YouTube. I can see the conversation now:

Marketing Manager A: We need to do some social media.

Marketing Manager B: Hey, we have all of the videos we produced for
the launch, we can post those to YouTube.

Marketing Manager A: Hey, great idea why don't we have the agency do it, I'm not sure how YouTube works.

Marketing Manager A to Director of Marketing: Yes, we have a social media campaign, you can go to YouTube....

I have well covered the issues with blogging for Rx/Dx companies from a legal and regulatory perspective and this is another example that social media is not a campaign. Let me repeat, social media is not a marketing campaign. It doesn't have a beginning and it doesn't have an end, it is a commitment. It requires a strategy, it requires resources to support and it can touch all phases of the business from market research to customer service. And as I have said, those that understand that will be much better off.

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