According to Contextweb, an advertising technology firm, marketers are remiss in assuming that consumers are only interested in clicking on a pharma banner when it’s on a medical or health site. By understanding what kinds of non-health sites – and categories of sites – that individuals visit (individuals that click on a pharma ad, that is), marketers can take advantage of cheap inventory served up in other content categories, like travel or sports, says Tanayia Washington, author of the report.

“We’re not advocating that [marketers] step away from health content, as a pharmaceutical advertiser. We’re advocating that you go beyond it…you can expand your buy,” says Washington. “The assumption is that if individuals are consuming a lot of this [non-health] content, they’re really interested in that content. If we can find them where their interest is, it’s a perfect fit for the advertiser.”

The report found that WebMD and Everyday Health reached 16.9% and 17.8%, respectively, of online consumers searching for information on a treatment for an ailment or condition, while the comparable reach figure for the long tail was 69.9%. Similar figures were seen with users who “bought a prescription for an ailment or condition.”

Washington said that placing pharma ads on a non-health site provided brand lift, although health sites offered the most brand lift.

Scaling up on the long tail is easily done, once a target group’s web behavior can be extrapolated, but safety is a big concern; advertisers don’t want their ads mixed up with inappropriate content. “As a pharma advertiser, you’re very concerned about safe environments, so you need to make sure that partners can provide that environment, and scale it, at the page level,” said Washington.

We would like to showcase the best of the year by spotlighting some of the most creative and innovative ads — but we need to know that what peaks our interest works for you too! Please send all suggestions by January 3rd.

The stated aim is to assist FDA’s Division of Drug Marketing, Advertising, and Communications (DDMAC) in its efforts to deter promotional activities. DDMAC examines promotional pieces submitted to the agency, scans ads and TV commercials informally, and monitors drug company exhibits and programs at medical meetings. An important source of information is all the complaints the division receives are from industry competitors who see another company getting away with off-label promotion or unfair comparisons. It’s impossible for DDMAC to catch everything, and certainly not what’s said in meetings between doctors and sales reps or at sponsored dinner programs.

To kick off the Bad Ad program, which was announced last month, DDMAC staffers will give talks and distribute educational materials to providers at medical conventions and society meetings. A brochure advises doctors on how to recognize misleading promos: omitting risks, overstating effectiveness, promoting off-label uses, or making misleading comparative claims. FDA is making it easy for doctors to squeal about objectionable messages by establishing a special call-in number and email address.

It’s not yet clear if the campaign will generate a lot of finger-pointing—or if it does, how DDMAC will deal reports that are vague and undocumented (anonymous calls are okay). Marketers fear that doctors will file complaints based on misunderstandings and personal prejudices. Supporters of the program anticipate that marketers and sales reps will modify their pitches if they think that their audience is taking a much closer look at what they say. But free-speech advocates like the Washington Legal Foundation fear it will chill open exchange of health information, which can be useful.

The Bad Ad campaign fits FDA’s effort to step up enforcement, as Commissioner Margaret Hamburg promised a year ago. The agency has issued 186 warning letters so far this year, putting it on track to meet last year’s record of 570 enforcement missives, according to BNet Pharma. And more of those are coming from DDMAC, which doubled its warning-letter rate to 41 in 2009, vs. 21 the year before. Many recent letters challenge Internet marketing, an activity that remains on FDA’s radar screen. In April, DDMAC sent a long warning letter to Novartis challenging the company’s use of Web sites to promote unapproved uses and to make unsubstantiated claims for Gleevec. FDA plans to develop guidelines on Internet promotion and use of social media by drug marketers, but it’s proving to be a complicated business.

Google just showed off mockups of its fancy new pharma ads at FDA’s social media hearing, on November 12. A few months back, the big G mentioned that it was working on ads to appease both pharmaceutical marketers and FDA, but this is the first time most people got to lay eyes on the new ad units.

According to Mary Ann Belliveau, Google’s director of healthcare advertising, the new ads will include both brand name and healthcare information, as well as a brand URL. To make the ads FDA compliant, each unit will include an abridged warning notice that links to the full risk information. The lead subject line will link to the brand site, so each ad will have two different URLs linking to two different locations.

As it stands right now, pharma companies cannot use brand names and brand URLs in link ads without risk information. This is pretty much impossible to achieve since the risk info takes up too much room on the tiny ads. The other option is to only include the disease state and a generic URL, but Belliveau made it clear in her presentation that this isn’t a practical option.

In April, FDA sent out 14 warning letters to pharma companies that were mixing brand and health information without risk information in the actual search ad. Many of the pharma companies assumed that as long as risk/benefit information was within one click away, then they were in the clear. They assumed wrong, and many were forced to pull their search ads.

Earlier in the day, Yahoo said that it was testing new rich links in text ads to try to appease FDA requirements. The new ads would allow risk or company information to appear when a user hovers over a logo.

FDA is taking in all the suggestions from the Big Two search firms during the two-day hearing, but made it clear that this is just an information gathering process and that a formal decision on guidelines or actions would be down the road.

Image Courtesy of Google

Additionally, the company did tiny modifications on each letter, dropping the serif from the “P,” making the “F” less bulbous, and adding slant to the “E” in the direction of the oval.

Pfizer didn’t get back to me by press time to go over details as to why it changed its iconic logo, or the cost of revamping the design. However, Underconsideration.com, a really cool design blog, broke down history of the logo, and scored a few comments from the team behind the logo at Siegel+Gale.

The “Pfizer oval” was introduced in 1991. Over time, a great deal of equity was built into that logo, and it is widely recognized around the world. But today, Pfizer is a different company. It’s changed through global growth, numerous acquisitions, entry into new therapeutic areas, and development of life-changing medicines. The new logo keeps much of that existing equity, but with the brightened color, approachable type face, and tilted oval it signals positive change and forward momentum and asks people to take a fresh look at Pfizer because it is not the same company it was in 1991.

In addition to an updated logo, the new visual system also helps to signify this shift. The \ dotted display type face, illustration style, and bright multi-color palette work together to communicate the company’s  vision of advancing better health for all people around the world.

While the new logo probably won’t cause a stir like Tropicana’s recent rebranding or the new Pepsi logo, it is interesting to see what design fans think of the new treatment. Impressive, tired, let us know in the comment area below.

Also, if you are a designer interested in revamping Pfizer’s logo, feel free to drop us a line at gkoroneos@advanstar.com. We’ll publish the best redesigns on the back page of an upcoming issue of Pharmaceutical Executive.

J&J received a violation letter in response to a journal ad for its topical anti-inflammatory cream Ertaczo, emblazoned with the words “Crush. Kill. Destroy,” in large, orange letters. FDA states that the company is way off-base in touting total annihilation of athlete’s foot, rather that a decrease and potential for cure.

“Although [trial] results show modest effectiveness, they clearly do not support the claims that Ertaczo ‘wipes out’ or crushes, kills, and destroys tinea infections,” DDMAC wrote in the letter.

FDA also took issue with the suggested claims that Erataczo is approved for all patients. In fact, the drug is not approved for patients less than 12 years old.

Allergen got an even harsher letter, stating that its journal advertisement for the acne gel Aczone is a complete misrepresentation of the results of a clinical study, and that the ad “grossly overstates the efficacy of the drug by presenting only the most favorable result for Aczone.”

The ad stated that patients could see a reduction in acne by as much as 24 percent in two weeks. The study FDA is referring to showed that at two weeks, patients showed only a 2 percent decrease in inflammatory lesions.

Finally, Galderma received a warning letter regarding professional visual aids for its skin discoloration cream Tri-Luma. According to DDMAC, the ads “suggest uses for Tri-Luma that have not been approved by FDA, and thus create new  ‘intended uses’ for the drug for which the product lacks adequate directions, broaden indication for Tri-Luma, and omit and minimize important risk information for the drug.”

FDA wanted to find out what people really think of the risk information printed on the back of pharmaceutical advertising. Surprise, people tend to absorb far less information from the giant blocks of text printed in drab language.

DDMAC social science analyst Amy O’Donoghue explained FDA’s recent study results to an audience of marketers at Drug Information Association’s annual meeting, yesterday.

“We recognize the current situation where pharma can just reproduce risk information written to doctors in print ads,” O’Donoghue said. So, we looked at current format and different ways of presenting the information and what format.”

The first study examined how people use the current brief information to determine if risk info and med condition affect the time people spend reading the ad, the comprehension of the info, the selection of topics, and the intention to ask a doctor.

FDA created a fake drug called Oncazil, which they used to treat asthma, high cholesterol, excess weight and produced low risk ad or high risk ads for each disease state.

Of the 800 people that saw the ad, most of the, were more worried about the heart valve damage risk in the high-risk advertisement. The average reader spent 26 seconds reading the promotion page and 41 seconds reading the brief summary.

“The conclusions we reached are that the presence of a serious risk did not change the time spent on either page,” O’Donoghue said.

In another study, FDA only looked at overweight drugs. They studied the different formats of brief summaries to see which format presents risk info in the most digestible manner.

• Traditional summary has risk info buried in a giant mix of text in three columns, on back page.
• Q&A format has less info and is more of a dialogue.
• Highlights section is more reader-friendly.
• The drug facts box version was designed similar to the OTC brief summary.

This was a mall intercept campaign and was computer administered, however the screen was the size of a magazine page. 300 people were interviewed.

FDA found no difference in reported intention to ask doctor or differences in risk/benefit tradeoff. Self-efficacy differed by format and people who saw the drug facts box were more confident that they understood the risk information than on the traditional summary.

Most people were positive about the drug facts ad box and the traditional received the lowest marks. People had a significantly more positive attitude towards the highlights and drug facts (54 percent).

“People who like a format more might spend more time on the ad and get more out of it,” O’Donoghue said. “FDA hasn’t outlawed any format, but additional studies will be done to determine content of brief summary forthcoming.”

#5 Brian Perkins, vice president, corporate affairs
Johnson & Johnson
Ad Budget: $2.41 billion
Key attributes: company’s sponsorship of the Beijing Olympics; conversion of Pfizer allergy drug Zyrtec to OTC; continued innovative marketing endeavors with expansion of its BabyCenter portal

#8 Susan Edwards, vice president, marketing
GlaxoSmithKline
Ad Budget: $2.46 billion
Key attributes: consumer business up with diet drug Alli (a $200 million brand); Sensodyne growing at double-digits speed; new CEO Andrew Witty outlines plan for more emphasis on consumer products and less on pharmaceuticals

#21 Ian Read, president, worldwide pharmaceutical operations
Pfizer
Ad Budget: $1.25 billion
Key attributes: Lyrica and Sutent both up more than 50 percent in the first half; Viagra sales were up 13 percent in the second quarter despite competition; agreement made to forestall direct generic competition against Lipitor until 2011

#23 Herb Ehrenthal, group vice president, global advertising and marketing communications
Schering-Plough Corp.
Ad Budget: $1.09 billion
Key attributes: strong pipeline of drugs in the making; big acquisition of biotech company Organon; organic sales rose 1.4 percent in second quarter

#24 Bernard Poussot, CEO
Wyeth
Ad Budget: $1.08 billion
Key attributes: raised full-year expectations with its second quarter earnings; acquired the Thermacare analgesic-heat-wraps brand from P&G; Thermacare can be coupled with its Advil ibuprofen brand

For a more complete list of agencies, see the 100 Leading National Advertisers 2008 database on AdAge.com

While I’m not 100 percent positive, it looks like this might have been the first time FDA actually name-dropped a social networking service in a warning letter. Which poses the question: Is FDA watching YouTube, and what does this mean for pharma?

Ignite Health’s Fabio Gratton told me that this ramification could go one of two ways. Pharma could view it as the feds are now treating YouTube with the same degree of importance as television and other media outlets, thereby validating the online service. Or it could scare pharma away from posting videos on YouTube, because that could warrant a warning letter.

So where does FDA stand?

I sent an email to FDA spokesperson Felicia Stewart with one question: Are you guys watching YouTube for pharma ads?

She missed the deadline for the article, but lo and behold, this morning I got a nice, concise answer from the feds.

DDMAC has been and continues to monitor the many vehicles that companies use to promote their prescription drug products. Our monitoring includes magazine ads, TV ads, promotional exhibits at medical conferences, Internet, sales brochures, journal ads, and consumer mailers and brochures. Internet monitoring includes promotion done by or on behalf of drug companies such as companies’ own product Web sites and their placement of promotion on others Web sites. The action addressing promotion by the company on YouTube is one example. Another example is the action addressing Pfizer’s promotion on cnn.com for Viagra.

There you have it. FDA is watching YouTube, and boy, do I wish I was the guy or gal being paid to troll the Web all day looking for errant pharma ads or remixes of the Rozerem beaver singing the Tay Zonday classic “Chocolate Rain.”