The FDA cracking down on Facebook marketing is a clear signal that companies have to treat Facebook the same way they would treat any other media they use in their communication with the public
In the past 6 months the FDA has issued 6 warning letters mostly for unapproved claims but when it comes to unapproved claims social media creates a unique challenge for companies in the healthcare industry at large (that includes manufacturers and distributors of supplements and other products not usually considered drugs or medical devices but could be construed as related to health) in that comments posted by third parties can also be construed as claims and the simple fact of liking a comment constitutes an endorsement of the claim by the owner of the page
Healthcare companies have to be very careful as to not only what they say or claim but how they say it. Since the way they say it could be construed as a health claim and as such is regulated by the FDA
When it comes to communication with the public, companies in the health field shoud treat social media as they would any other more traditional method of communication with the public like website, press releases, advertising…
And when it comes to social media they need to be very careful to monitor third party posting on any of their social media account, that include posts on their social media wall, comments on their blog posts… and remember that any “liking” is considered an endorsement of the claim and can land them in a lot of trouble with the FD
They should also be careful as to what they post in their about or profile section and insure they do not write anything that could be construed as an unsubstantiated or unapproved claim
If your company operates in a regulated environment, make sure you hire social media or marketing consultants who know about compliance and it’s impact on your company