The latest from DTC Perspectives

FDA Testing DTC Distractions

A new study by DDMAC is going to delve into whether television ads have distracting positive visuals which limit consumer risk information comprehension. DDMAC has always made judgments subjectively when pre-reviewing submitted ads on these distractions. They never liked commercials that had too many moving parts while side effects and risks were discussed.

This is the first time that DDMAC will try to get some definitive consumer data on whether positive visuals really do distract from consumer comprehension and retention of risks. They will test mock ads next year and get some data. This will be used for determining whether new guidance is needed on visuals and supers.

I support the study because DDMAC has assumed that the pretty background visuals that have too many scenes are distracting. I remember the original Lipitor ads were rejected because our background visuals showed a car moving too fast as risks were read. DDMAC made us slow down the motion of the car. None of us agreed with their subjective assessment but once the reviewers decided, there was no way to refute their views. Their subjective view trumped our subjective view. So anything that is based on quantitative data is worthwhile.

There have been studies on risk comprehension by drug companies. AstraZeneca did some excellent work on the number of risks consumers can process and found less is more. This DDMAC study will be done in 2009 sometime. I assume any new guidance on risk presentation on television will not be out, if at all, before 2010. Better late than never I guess, as DDMAC has waited 12 years after they allowed branded ads to finally do this study. I think the lack of research by DDMAC is a problem. They need to have the staff and budgets to test a number of creative factors in ads. It is a sad state of affairs that it takes so long to replace subjectivity with some actual consumer data. If you want to provide DDMAC comments on this study it is docket number 2007N-0321.

So I look forward to this data and future studies. I hope DDMAC can accelerate their future market research because consumers deserve clear information on all elements of DTC ads. I know DDMAC personnel are doing their best with current resources, but resources are the problem. Instead of political bluster from Stupak and Dingell, give DDMAC what they really need to oversee DTC advertising.