Big Pharma
Whether you are analyzing a pharmaceutical campaign or not, you can learn a lot about advertising (and your opinions about it) by studying the constraints placed by law on the drug industry.
Let’s start here: read the article linked to this line, then return to the lecture. Watch the ads and look for what this article has to say about the rhetoric of drug sales. The author doesn’t use the word “rhetoric,” but she does deal with the issue. Keep the window open so we can deal with these ads.
This article brings up some issues that need scrutiny in the pharmaceutical industry marketing push: direct-to-consumer advertising (which we are going to dig into in more detail), targeting doctors, and changing the rhetoric of medicine.
Of the three, I fear that the third is the most frightening–for the future of all advertising. Allowing direct-to-consumer advertising has opened the door for the pharmaceutical companies to do exactly what this article warns: turn patients into consumers and drugs into commodities. Are we destined to be the new drug culture, telling our doctors which designer pharmaceutical we want rather than allowing our doctors to do the prescribing–or allowing them to choose not to prescribe drugs? Are we already there?
What Big Pharma is supposed to do
The FDA, which seems to be failing in its diligence, has nearly 30 pages of requirements that drug companies must follow in their advertising. When these requirements were written, they seemed to cover all avenues of marketing and advertising available. But as the article points out, the move to consumerize the rhetoric of the industry has been advanced through the “free” marketing they get on shows like Oprah and in the news. And the FDA cannot control those programs.
So what can they control? Here are some of the basic regulations.
Prominent Naming.
The name of the drug must be prominent…but so must the names of the active ingredients. This regulation should help prevent the kind of loophole Pfizer found for remarketing Prozac under a new name. But who really knows what the active ingredient in Prozac is? Pfizer was never required to reveal that this “new” disease was being treated by an antidepressant.
Look at this antidepressant ad:
Can you identify the active ingredients? Are they mentioned? I’m sure you know the name of the product. But I want you to notice the list of side affects. We’ll come back to it, but we’re talking about a drug that is similar to Prozac–which has the same side affects! Ladies, would you want your doctor giving you this kind of drug to deal with your PMS? It seems to me that over the counter (OTC) Motrin deals with all the same symptoms with none of the terrifying side affects.
Dosage information.
According to the FDA, the dosage must be included in some manner. Many ads try to be subtle (“if taken once a day”) while others, like some birth control methods, feature less frequent doses as part of the benefit list. Here’s a great example: if I say Sally Field and osteoporosis drug Boniva in the same sentence, I imagine that, if you have been in the US any time in the last 12 months, you can tell me the dosage of the pill. The entire campaign focuses on the dose–it is the drug’s major selling point.
But what about that Cymbalta ad? Watch it again. Is it hidden in the gentle, creepy voice over? Is it prominently placed on the screen? How do they get around it? Well, there are some loopholes and one is to stress that this available only by prescription and that “only your doctor” can determine if you need it. This tells me that there is no set dosage.
Warnings.
All contraindications, side effects, warnings, precautions, etc. must be mentioned in the ad. The only exemption–reminder advertising–is still rife with a list of necessary inclusions: drug name, ingredient names, dosage form, pack quantity, name, address and phone number of company, price, etc., and can NOT include information about what the drug does. Occasionally you will see a reminder ad, but mostly you see this:
This ad won a ton of awards! And, from an artistic point of view, it’s a fairly clever way to follow the rules. But they created this two-minute monstrosity in response to a 2005 sanction from the FDA. I’m curious to know why this is the only NSAID that got slapped down…except that the others are getting around the FDA by a)avoiding direct-to-consumer advertising altogether or b)building a following with their OTC varieties.
Most NSAIDs fall in to the second category: Advil, Tylenol and Aleve all beat the FDA rap by advertising only their OTC products. They can say anything in those ads. The regulations ONLY APPLY TO PRESCRIPTION DRUGS!
But regarding the warning list: I often wonder, upon seeing these ads, why someone would knowingly place themselves in such danger. It’s one thing for a doctor to prescribe a drug and explain the possible side affects. But why would you ASK for something after hearing how dangerous it is? It seems to me that these decisions should be left to the prescribing doctor, not dictated by patient whim.
True vs. untrue.
This seems like a no-brainer, but one of the restrictions clearly spelled out by the FDA is that an untrue statement or implication may not later be “corrected” by a true statement. Lots of non-drug products make untrue statements or imply that their products are able to do much more than they really do. Think about the Enzyte “natural male enhancement” ads. I realize it may be too small to see on the screen, but see if you can’t find the “does not treat erectile dysfunction” disclaimer (that’s the “truth” behind the untruth):
I promise you it is there. The other part of that disclaimer says that Enzyte has not been approved by the FDA. So how do they get away with advertising it? Well, its ingredient list reads like the herbal supplement section at Wal-Mart, including niacin, ginseng and gingko biloba. Herbals are not under FDA jurisdiction.
I think some ads do get around this by telling only partial truths. The article talked about Restylane, the cosmetic filler. I would submit that using a young woman who likely has not had such a procedure to advertise the product verges on untruth.
But isn’t that what advertising does? Create an image that is not necessarily true, but perception of truth? By turning patients into consumers, drug companies are creating a perception that we have control over our health care, when in fact there are many options beyond the chemical ones.
This is where we have to stop in order to keep this lecture from lasting for several days! You might want to consider this information as you analyze other ads–what other products are limited in their advertising scope? What other products should be? Would our world be a different place if all advertising labored under restrictions of some sort? How would we possibly enforce that in a free republic?
