Saturday, December 5, 2009

Logo? Or Loco?

Last month, after the FDA held its hearings on establishing guidelines for social media for pharma, I wrote a piece somewhat supportive of phARMA's suggestion that the industry establish an FDA "seal of approval"- type logo.

Since then, I've had numerous conversations on the subject with many very smart people who are either directly or closely involved in the FDA discussion and am starting to get more of a handle on how such a solution could possibly work.

As Dan Solomon, CEO of Virilion (the "V" in our new joint venture, EV Healthcare) points out, the electronics industry has long been policing itself for safety standards through the auspices of the independent product safety certification organization, Underwriter Laboratories.

Since the early 1900s, the "UL" logo has appeared on everything from fire extinguishers to washers and dryers, to show consumers that the products on which it is stamped have been proven to be in accordance with Underwriters Laboratories' strict safety standards.

According to the UL's own website, "The UL Mark on a product means that UL has tested and evaluated representative samples of that product and determined that they meet UL requirements. Under a variety of programs products are periodically checked by UL at the manufacturing facility to make sure they continue to meet UL requirements."

In turn, UL testing has to meet the standards set by the federal government's Occupational Safety and Health Administration (OSHA).

So if the electronics industry, which bears the responsibility of preventing countless injuries and deaths of consumers by electrical shock and fire, can police itself this way, is it such a stretch to ask the pharma industry to do the same?

Couldn't pharma, in conjunction with the FDA, come to an agreement on what the standards of responsible marketing should be, and then create its own FDA-authorized governing body to uphold them?

And couldn't every piece of pharma-created marketing material – both online and off – proudly wear a seal of approval, stating that it meets the highest standards, and that the FDA is more than welcome to come kick the tires?

Just a thought.

– Mark

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1 comment:

  1. The analogy to UL is not appropriate for drugs, which have different effects on different patient populations. Because of this, "approved" drug information is dynamic and changes as more real world -- as opposed to clinical trial -- data is collected. That being said, if there were some symbol, logo, or seal, it should definitely NOT be the FDA logo, but a new logo maintained by the FDA that links to a page where ALL the latest FDA-generated safety information about the drug can be found. IMHO.