In comments submitted to the FDA regarding recent social media guidance (read “FDA Publishes First Piece of Long-Awaited Social Media Guidance” for background), Klick Health — an interactive agency that has pharma clients — asked a lot of questions. One interesting question was “What browsers does the FDA use when reviewing social media sites such as Facebook?”

Actually, Klick said this:

“Since public social properties will be reported via links, we would like the FDA to publicize what browsers it uses when looking at these properties. Normally, this would not be an issue as the social properties tend to render well on all recent browsers but screen captures provided on the NOV letter regarding Tirosint cast doubt on what the FDA may be seeing when it reviews social properties.”

Klick Health believes FDA may be using out-of-date browsers that make it tough to know whether a Facebook page — such as the Tirosint page in question — was in development or whether it had “actual content” when the FDA looked at it.

As evidence, Klick Health referred FDA to a screen capture of the page on its blog where it compared what the page looks like on a “modern” browser (see below):

Click for an enlarged view.

In the March 19, 2014,blog post, Klick Health noted that the draft guidance on social reporting released in January “tells marketers to just send links on a monthly basis rather than PDFs” and but Klick Health offered this advice:

“However, if regulatory groups cannot trust that the FDA will use browsers that are compatible with the social channels being reviewed they may still decide to create PDFs of screenshots to ensure the FDA sees the sites the same way that consumers do” (read “What browsers do FDA reviewers use?“).

Speaking of browsers and links, Klick Health’s comments did NOT include the details as summarized here, but rather merely included a link to its blog post in a footnote. Hopefully, FDA will see the link, click on it and be able to launch a “modern” browser to view Klick Health’s site.