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February 18, 2015
Bob Ehrlich, CEO, DTC Perspectives
"Consumers.. remember very little…so less is more." -Bob Ehrlich

FDA is proposing a study which I call “less is more.” The study is long overdue. They are concerned that too many risks are being presented in television ads and perhaps this confuses consumers. The basic lesson of advertising is to focus on the main point or compelling benefit if you want people to remember it. That lesson also applies to risk.

Consumers deserve to know about any significant risk of a drug they are taking or may take. Current DTC ads are risk heavy and loading ads with the many potential risks and side effects obscure what really are the most important. So if something minor happens to one in ten thousand people, is that worthy of being mentioned?

I have always been an advocate of presenting the odds of serious risk. FDA needs to provide guidance in consumer terms. If I have several friends who got a side effect, then that is worth mentioning. If I have to dig in the medical literature to find the one person having a side effect it is not. FDA is considering doing what any reasonable person would do. That is, discuss risk in the context of its frequency and seriousness.

We do not require auto makers to say you may die driving their car. We do not require airlines to discuss the risk of a crash. Yet drugs seem to be treated as something deserving of the mention of anything that may happen if taken. It is about time consumers were given some better information. If it kills one in a five hundred thousand do I really need to be told that in an ad?

I hope this study can provide some data that will help. This falls in the category of better late than never. There is, of course, a lot of general literature on advertising recall, and perhaps FDA could make sensible conclusions based on the existing vast history on advertising concepts. That would say consumers watching ads can remember very little, so less is more.

I know FDA is filled with bright people so I assume they know this concept. What is frustrating is their pace in advancing sensible regulation. By the time they finish this study it will be twenty years since television ads were presented to consumers. If consumers are risk confused now, they were in 1997 as well. FDA has told me numerous times how busy they are, so it is no surprise they are just getting to this study. It is a sad commentary, however, on their staffing and/or their priorities.

I guess we must be thankful FDA took some regulatory liberties and allowed the 60 second ad in 1997. So despite the nearly two decades it took to get here, the study is important for industry and its customers.
Bob Ehrlich, CEO, DTC Perspectives

Bob Ehrlich