The Danger of Celebrity

Kim Kardashian's Instagram account joins a long line of celebrity endorsers whose communications have been cited by the FDA.

The following list is definitely incomplete, and I'd appreciate people adding to it in the comments, but this is just a smattering off the top of my head of the celebrity endorsers who have been cited in FDA enforcement:

Magic Johnson in 2009 for Kaletra

Ty Pennington in 2008 for Adderall

Eric Bergoust in 2002 for Tamiflu

Joan Lunden in 2000 for Claritin

Jackie Joyner-Kersee in 1997 for Flovent

Are celebrities dangerous?

Well, they are likely to be featured in high-profile campaigns, especially television advertising, and FDA has always made clear that from a public health perspective, they pay particular attention to high-profile campaigns because their broader reach translates into a greater public health impact.

In addition, celebrities can present a host of issues for otherwise-staid pharmaceutical company employees. There's certainly something thrilling about getting to meet them, and there might be a bit of reticence to tell them exactly what to say. Celebrities themselves are frequently going to have significant experience with endorsing products, and that experience can make them more dangerous. The rules of the road for pharmaceutical promotion are just different, and if a company doesn't have sufficient procedures in place to ensure compliance with scripts and specific language, then it's very easy to start weighing the costs of a reshoot against the risk of FDA enforcement. And once that Rubicon has been crossed, it's very difficult to return.