Creativity Through Understanding - Pharmaceutical Executive

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Creativity Through Understanding
Creative consumer campaigns begin with a clear understanding of pharma rules and regulations

Pharmaceutical Executive


Do DTC's detractors have a valid point when they say that DTC is causing patients to demand drugs they might not need?


Mel Sokotch is the author of Shortcuts To The Obvious: How to Get More Effective Advertising More Effectively
I think a lot of the watchdogs and critics have a good argument—there has been a lot of opportunism in the business. Vioxx, for instance: The COX-2 products were initially indicated for people who had significant arthritis who were taking 10, 12, 15 aspirins a day. The market ended up marketing those products for charley horses on the weekend, and they were overprescribed. I also think the erectile dysfunction (ED) medicines made egregious mistakes by running provocative advertising in programming that was watched by inappropriate audiences, like kids. Running ED-medicine ads during the Super Bowl, I think, is a mistake. And obviously it's been banned since then. So I think the critics certainly have some ammunition on the one hand. On the other side, I hope we, the defenders, will end up prevailing in this thing.

What advice would you give a pharma marketing team trying to market a new drug that they're not quite sure how to handle?

They must study and embrace the FDA regulations for product-claim advertising and for disease-awareness advertising, and they must study and embrace the regulations from Pharmaceutical Research and Manufacturers of America (PhRMA). They should look really carefully at some of the most creative advertising on the air and study how they handled the regulations and were still able to be creative. There are Web sites that agencies can visit to get all the letters that have been written to advertisers about advertising that was in violation and look at what was wrong with those commercials to avoid those pitfalls.

What pitfalls would you tell them to avoid?

There are two really big pitfalls in this business: one is minimizing the side effects and the other is expanding on the indication. Industry has gotten in trouble for obscuring the warnings in commercials, and that is a terrible mistake. But on the other hand, there's always this interesting issue in terms of how to present the benefit. One of the medicines for social anxiety, Paxil, got a letter of violation a number of years ago. It was indicated for social anxiety, and that means you're afraid to go out and you really have a panic attack when you get involved with a bunch of people. The ad was presenting people who were simply nervous or fearful about social situations. Both minimizing risk and expanding on the indication are pitfalls that have got to be carefully watched.

Do you think there's any chance that DTC in the United States could be abolished?

If industry had stayed on the trajectory it was on a few years ago–marketing certain medications, emphasizing too many lifestyle medications, and running inappropriate advertising in the wrong programming–I think the whole thing could have been lost. Congressmen were saying, "Hey, I don't want to be watching a family program with my granddaughter when an ED commercial comes on the air and I have to explain it to them." So long as industry operates in a responsible way, I think DTC will be fine. It's hard to regulate everybody when we've got an open market. There are going to be mistakes, and there's going to be opportunism, and there's going to be stupidity from time to time. I think the PhRMA guidelines have made a big difference, but I think the industry's really going to have to continue to work on regulating itself.


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