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Don’t Hold Your Breath for an “FDA-Approved” Logo for Your Medical Device Social Media Efforts

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Can "trust" enter our discussion?

The lock in the corner of your browser indicates the website is legit. Go ahead and transact business with your credit card number and personal information—your information is secure. All is well. That is, until it isn’t. If it hasn’t happened already, that little lock can be duplicated and put to nefarious uses.

Same thing with an FDA seal of approval logo to place on your blog or website. Pharmaceutical companies are suggesting such a graphic as a way to set their audiences (and their corporate lawyers and the teams of regulators, their board members and shareholders) at ease. Seeing a logo would be an admission that the contents included are all good to go.

That’ll never happen.

That‘s because while the FDA may approve a device or drug for market, they work hard at not becoming responsible for the results the product. And for a set of folks who want to read every word in a document before it hits the street—people who care about the font size of your disclaimers (5 pt? Too small! 6 pt? OK.)—granting a seal of approval to the wild west of social media would be like arming the inmates and locking the prison doors behind them as you shoo them out (may I mix metaphors?). Aside from the fact that even a word-guy can duplicate a logo and affix it to anything, there is simply no way the FDA will be responsible for watching all the dialogue that must—and will—take place. Hiring staff for such Big Brother activity would break the bank (wait—banks are already broken).

Somewhere in the future, the dusty notion of “trust” may well rise up again. I know it seems quaint, like a whiff from centuries past, but it simply is not possible to regulate every part of dialogue. Just ask East Germany. Or watch “The Lives of Others.”

Dialogue is not about guarantees. It is about exploring. Perhaps the best we can do is to voluntarily adhere to a growing body of disclosure best practices.


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