RTCRM

x-posted from www.thatdigitalstuff.com

Understandably pharma can’t keep up with all the back and forth – banner ads that clearly violate the same issues outlined in the Treximet letter continue to proliferate the Internet.

The best pharma (and the agencies that develop their creative can do) is assess the general advertising FDA guidelines and consider the implications for the digital space. They have to use past tense warning letters to dictate future initiatives, and decide whether they should proactively pull things from market that present a risk of receiving letters.

So what are the immediate considerations?

1. Scrolling important safety information (ISI) is questionable

Due to the physical size limitations of banner ads, creative teams have traditionally developed scrollable ISI to meet branded pharma fair balance requirements. The FDA is concerned with a) the size of scrolling ISI and 2) the likelihood that people will actually read it. Scrolling ISIs are usually tiny and fast- no one reads them. Furthermore, they are separated from the “real” content. The eeny-weeny format makes it easy to overlook. As a result, the FDA warns that this execution does not meet balanced requirements. Therefor, creative teams must find a way to include ISI in branded banners in a way that is as accessible and as visible as any related claims.

2. Colors, font and imagery matter

The detailed Treximet letter indicates that the FDA expects experiental equality for digital execution of fair balance. Similar to guidelines for print and broadcast, the FDA warning letter dictates that banner ads should visually treat risk and benefit material equally. Font, color, text size, imagery and animation should be evaluated for creative equality. Additionally, this risk information likely needs to integrate smoothly with benefit information, so as not to appear like separate content.

3. Rich media or bust

As more and more FDA requirements arise in a medium where ad space is physically limited, standard flash banners may no longer suffice. Flash, while generally less expensive to develop, offers less room to support the above two implications than rich media. Creative teams should look to rich media, which offers both expandable space and more visually engaging technology. The exception: for some pharma brands, branded reminder ads may be the only option – in this case flash is likely more cost efficient.

In the end, it will really become a creative challenge to execute against the FDA guidelines. Integrating risk and benefit information in tiny-boxed-ad-space will likely require incremental time to concept, design and develop. The brands that will be most successful at over coming this hurdle, will be those that consider the abilities of digital creative execution, not simply the limitations.