Effective risk management requires comms' early participation

The latest round of FDA warning letters to food manufacturers, who are stepping over the line between marketing claims and health claims, provides a ringside seat into the daily judgment calls that communicators are often asked to weigh in on — if they know about them.

The latest round of FDA warning letters to food manufacturers, who are stepping over the line between marketing claims and health claims, provides a ringside seat into the daily judgment calls that communicators are often asked to weigh in on — if they know about them. 

A March 5th PRweek editorial stated that communications pros should have prevented this latest round of FDA warnings, but what we will never know is did they try and were overruled, or were they even part of the decision.

Anyone who has crafted a press release for a marketed pharmaceutical drug can tell you that there are no shortages of opinions on what a drug's label says you can or can't say. As you might expect, product marketing often aligns on a more bullish set of adjectives and claims, while regulatory and legal line up on the opposite side. Brokering the compromise and pleasing neither camp is often the job of communications. 

But this may not always happen for products that traditionally have operated in a less-regulated environment where PR more frequently is ‘part of the marketing mix' and is used more as a channel. In these situations, communications would rarely be consulted for an opinion on claims made in a product advertisement or Web site, or they would be brought in too late in the process to make significant changes. More often than not, despite numerous reputation-bruising incidents, there still prevails an “ask forgiveness, not permission” mentality in many sales- and marketing-driven organizations, and the ROI for the improved sales generated by the claim would be considered justification for the wrist-slap the FDA warning letter produces. 

Sometimes an organization simply doesn't have the right kind of communicators in the right places. Effective communicators have a special knack or ‘radar' for picking up potential issues before others see them, and connecting the dots between recent external developments – for example, increased FDA warning letters – and a current marketing campaign.

Many of the influencers that communicators take their clues from – the media, government, community stakeholders, advocate groups, employees – do not voice their opinion quietly. Their displeasure with your company or product will be abrupt, public, and likely disruptive to your operations. It's difficult to calculate an ROI on that.

A significant portion of an effective communications function is to throw a flag on the internal corporate playing field before the external referees have a chance to. An ounce of prevention is worth a pound of cure.

Mary Lynn Carver is SVP of PR for St. Jude Children's Research Hospital. She spent 11 years in the pharma communications trenches in the US and London. Her column looks at healthcare PR issues and topics related to the management of the communications function. She can be reached at mary.carver@stjude.org.

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