FDA Still Not Ready to Tackle Mobile Promotion

Updated to correct error of publishing an incomplete sentence and a misspelling.

On Thursday, FDA held a webinar about its recent social media guidances. Despite technical difficulties that prevented many (including me) from attending the webinar, FDA did field questions from some of the attendees, and late on Friday afternoon, they posted that Q&A along with the slides from the presentation portion of the event.

In reviewing the Q&A about the space-limited presentation of risk information guidance, one exchange stood out:

Q1. Does this draft guidance apply to space limitations imposed by mobile devices?

A1: This draft guidance does not address technology-specific layout features that may result in product promotion presentations that differ depending on the technology used to view them (e.g., mobile devices, desktop computer monitors, and tablets). The scope of this draft guidance is specific to Internet/social media platforms that impose character space limitations.

While the guidance itself clearly specifies that its scope is limited to social media platforms and paid search with character-count limitations*, it is disappointing to see the exchange. Perhaps it was the nature of the question that resulted in this specific answer, but one would certainly like to know how widely applicable the principles from this guidance are to mobile devices in particular because many of the issues that apply to presentation of risk information in limited character counts also apply to presentation in limited space.

In addition, though, this Q&A further emphasizes one of my concerns about the guidance. It concerns itself solely with the content of each individual Tweet** and completely ignores the surrounding context and nature of Twitter interactions. That larger context is part of what I have begun fleshing out via a previous post about a different Twitter proposal. There is far more going on when a person views a Tweet than just the 140 characters in the Tweet itself, and I believe that FDA is inappropriately limiting both its evaluation of what can make a Tweet compliant (or non-compliant) and its understanding of the actual uses of Twitter and other social media platforms.

Social media hosts public conversations, and just as you would not expect every single sentence uttered to include the complete conversation, you should not necessarily expect every Tweet to include everything needed to achieve a compliant communication.

Further adding to the difficulty is that just as FDA is finally providing guidance to address some of the most pressing issues in social media, we're seeing massive shifts in the consumption of social media itself with an increasing amount of social media interaction happening via mobile devices. So much so that some people have taken to referring to the combined fields as "somo" or "moso" to underline how much the line between social media and mobile has blurred.




* "This draft guidance also does not address responsive web design or other technology-specific layout features that may result in product promotion presentations that differ depending on the technology used to view them (e.g., desktop computer monitors, mobile devices, tablets)." (page 2)

** It's worth noting that people have been referring to this guidance informally as the Twitter guidance, and by refusing to discuss how to apply its principles beyond Twitter and Google, that moniker seems even more appropriate. For years, FDA declaimed its intention to not provide guidance that was limited to any specific platform(s) because of how rapidly the platforms evolved, and yet, ironically, it seems as if FDA is now intentionally doing exactly that.