If you’re familiar with the Partnership for Safe Medicines (PSM), you’re familiar with our goal: to mitigate the threat of counterfeit and unsafe medicines to patients.

The internet and social media have been both a hindrance to our efforts—giving legs to unlicensed online pharmacies, search engine advertising and spam—and a help—providing a tool for outreach and advocacy efforts, all while providing choice and access for patients.

So when the U.S. Food and Drug Administration (FDA) issued its call for comments for a public hearing on the promotion of FDA-regulated medical products using the internet and social media, we had a lot to say.
In addition to enunciating our desire to see a crackdown on search engine advertising of pharmaceuticals, we outlined three key challenges in regard to social media and pharmaceutical products:

  1. Lack of advertiser oversight and gate-keeping. For example, Facebook vaguely instructs its advertisers against posting ads for “uncertified pharmaceutical products.”
  2. Lack of cooperation from trusted medical sites. PSM has encountered problems messaging to well-known medical sites, demonstrating that legitimate organizations can be stymied from communicating FDA alerts and recalls with affected groups.
  3. Policing advertiser content versus user-generated content. While advertiser content can be easily monitored, policing user-generated content about pharmaceuticals can be a gray area for administrators.

We also submitted a handful of solutions to the FDA that, in conjunction with other regulatory bodies, can shutter advertisers and peddlers of counterfeit drugs on the Web. Among our proposed solutions:

  1. Regulation of internet drug sellers, including online pharmacies. Simply, internet pharmacies should face the same standards as their offline counterparts.
  2. Search engine-specific regulations for advertising programs that discourage them from taking advertising dollars from unlicensed and unapproved sources, as well as incentives for search engines to shut down unauthorized sellers. This could include banning pharmaceutical-related keywords and a greater enforcement of advertisers bidding on trademarked pharmaceutical terms, among other solutions.
  3. Enabling verified social media accounts for authorized sellers and pharmaceutical companies. FDA could work with Twitter and other social networking platforms to verify pharmaceutical accounts, enabling consumers to get information from authentic sources.
  4. Software programs that block drug SPAM from personal computers. Programs that block pharmaceutical spam could be easily installed on personal computers and B-to-B partnerships could be created to encourage computer makers to include complimentary software with new purchases.
  5. FDA monitoring of social media and SMS alerts. Monitoring ongoing conversations online will help FDA pinpoint users who are peddling illicit products online. Furthermore, text-based warnings for cell phones and other handheld devices could communicate important alerts to affected patient groups, medical providers and medical centers.

To view our complete set of recommendations, read our official remarks to the FDA. We encourage you to keep up with this issue by following PSM on Twitter, and reading tweets tagged #fdasm.