As Social Media Grows, So Should Your Sense of Caution


When my father and I started the lab in the late ‘90s, we delivered our Certificates of Analysis (C of As) via the U.S. Post Office and email. I licked stamps and placed them on large envelopes. Then I put a Post-It-note on the fax machine informing others of my intention to occupy the line by dialing into what was called “The World Wide Web.”

We used this magical process to send the C of As via email. While it was inconveniently lengthy, dial -up and email was revolutionary for its time. Our clients loved getting their reports digitally first and then, again, hand signed in the mail. Along with the hand-signed C of As, we sent a comment card with hopes to receive it in return with some positive feedback on our services and maybe a referral to another customer.

Soon after that something called a “Digital Subscriber Line” (DSL) became available, quadrupled bandwidth, and again revolutionized business communication (among other things). It’s mind-blowing to think how business carried on without such technology (before the web and even before faxes). We wrote letters and patiently waited until we were returned a product, response, result, or inquiry. Now, this aforementioned computing power is regularly found in a teenager’s smartphone, DSL is outdated, and emails arrive at nearly the same rate as my resting heart beat.

Technology has been and continues to be a strongly persuasive reason to change or improve how we do things. And not just computing power and connectivity: communication, and its content, has changed faces many times. While the term is quickly becoming a cliché, “social media” refers to an exchange of information and ideas in virtual communities and networks. It has become important in how we learn as well as how we solicit our services and goods to our prospective customers. We now have the option to be in “relationships with information.” Our ability to access data immediately through web browsers and social media is creating a new culture of real-time information seekers and communicators.

The problem is that what once was part of a one-on-one business model is now seen by everybody. So, yes, social media is the new press release, the reminder that you’ll be at Trade Show X, that nifty sales pitch. But is it an internal communication? Absolutely not. Social media sites don’t discriminate but they also do a poor job of being discrete. You’re business is now an open book—and everyone wants to take a peek.

The FDA has made it clear that it is perusing social networking sites like Facebook for “missteps.” (See Marc Ullman’s post for more on this.) With these “missteps” come FDA 483 notices and even fines or cease-and-desist letters: it was determined that a company could be accused of false drug claims by “liking” a customer’s testimonial on its Facebook site. This new digital comment card, while fast and effective, is now a potential liability.

The lesson? You can have 100 ladders to get you over the wall, but if you don’t know how to use the ladders correctly you will spend a lifetime looking up. Social media and technology are making it easier to communicate with our clients on a regular basis—without actually having much to say. You can’t get complacent. Staying in front of them—a phone call, a visit, even an email that doesn’t begin “Dear Client”— is sometimes all that’s needed to stay relevant.

Running a business is all about maintenance, especially with social media. So update your LinkedIn, add a group picture on your Facebook page, tweet a link to an interesting article, and so on and so forth; Just do so as if your ultra-conservative grandmother (who also works at the FDA) is watching. Make sure any comments are legit. After all, the world is watching.


Categories: FDA 483 Live Feed, Product Verification/Validation, Regulations