In comments addressed to the FDA, many drug companies and ad hoc industry groups are suggesting ways drug companies can legally “engage” with patients, physicians, and consumers in online social media discussions (see, for example, “A Pharma ‘Social Media Working Group’ Submits Comments to FDA“).

The hope is that new FDA guidelines (or regulations) will help them do that.

Some drug companies imagine the day when they will be able to host open discussions on their web sites — even sites.

The question is, under what terms? Specifically, what conversations will they allow and not allow and how will they deal with posts that are “not allowed?” Every social media site has to have a policy regarding this issue.

Once you allow online conversation, you open yourself up to unsolicited commercial posts (ie, spam), posts from disgruntled employees or people with an axe to grind, posts from competitors and their employees who want to bash your products, anonymous posts from your own employees trying to put your product in a better light than is warranted by the package insert, posts from lawyers trying to get a class-action lawsuit going, well-meaning posts by patients spewing misinformation about your products, etc., etc., etc.

Pharma companies are especially prone to these kinds of posts. Believe me, managing online discussions is no walk in the park with your mandolin. It takes a lot of work and attention.

It would take a lot MORE work if every post submitted first had to be reviewed by your legal/regulatory people before it could be published. Naturally, neither the L/R people nor the SM evangelists within pharma want that burden. Hence, pharmacos suggest that posts to their discussion boards should be UNMODERATED. Of course, they say that this is the only way to allow social media to work as it should – uninhibited, free speech.

What pharma wants to do is to moderate AFTER the fact. That is, remove posts that violate the terms of use. This is how CafePharma works. It has a very active community with very many useful discussions. But the pharma industry is not loving it — there are many posts from disgruntled employees that criticize the industry. These posts are often X-rated.

Of course, this does not mean that discussions on pharma-owned Web sites would degenerate to the level of CafePharma. But, hey, it could happen!

I moderate every comment submitted to this blog before it is posted. Every day I get comments like this one from “marry”: “Blogs are so informative where we get lots of information on any topic. Nice job keep it up!!” First of all, it does not add anything to the conversation. But more important, when you click on “marry” you are likely to end up ion a Web site selling something — probably counterfeit Viagra pills!

Does the industry want its discussion boards filled with that kind of content? Of course not! But their method of dealing with it leaves a lot to be desired. I imagine one designated employee coming in every morning and reviewing the posts made the previous 24 hours and spending an hour or so deleting the ones that violate the terms or commenting on the off-label ones and keeping them around for awhile so everyone can tell it’s off-label (some propose deleting these after 48 hours, some do not indicate any specific time limit).

It’s all about the FTE devoted to the job — the less, the better! Moderation before the fact may require too many FTEs. After the fact, it is much more manageable.

But in social media time, 48, 24 or even 2 hours is a long time! Just ask Ray Kerins, Pfizer’s head of corporate communications. While he was busy in traffic court, the Twittersphere buzzed and re-buzzed about whether or not @pfizer_news, which was just launched, was an official Pfizer Twitter account! (see “Pfizer’s Social Media Strategy: Piss Off John Mack, Get Hundreds of New Followers!“)

To paraphrase Omar Khayyam: “The Moving Finger posts; and, having Tweeted, Moves on: nor all your Piety nor Wit Shall lure it back to cancel half a Line, Nor all your Tears wash out a Word of it.”