DTC (direct-to-consumer advertising)

1920s-1930s: marketing to consumers by promoting the institutional brand of the ethical firm as a whole (E.R. Squibb; Parke, Davis). No mention of specific products or indications; “Institutional advertising, in other words, advertised the concept of ethical pharmaceuticals” (Greene & Herzberg, 795). 1950s& 1960s: “By the mid-1950s, the popular promotion of brand-name prescription drugs through public relations and new-generation institutional advertisements had become a thriving and unregulated gray area of DTC marketing” (796). Boom in industrial public relations, so that drug firms “began to use public relations techniques in new ways that came very close to popular advertising of specific branded products (e.g., P-D’s Benadryl); Roche insert of Librium ad in issues of Time mailed to doctors for use in waiting rooms (Roche censured by Congress); “indirect-to-consumer advertising” in 50s & 60s accompanied by “energetic exploration of non-advertising marketing through newsreels, article placements, event planning, and other domains of public relations” (797). “Short shorts” offered to newspapers; “featurettes” to radio and TV stations; industry-ghostwritten media coverage via the “backgrounder,” seemingly legitimate news articles about new drugs in po0pular magazines written by journalists commissioned by the industry’s Medical and Pharmaceutical Information Bureau (MPIB). 1980s: In 1981, British Boots Pharmaceuticals ran general ads for Rufen (prescription ibuprofen) and Merck ran ads for Pneumovax (antipneumococcal vaccine). 1985: FDA issues notice asserting jurisdiction over DTC advertising and indicating prior standards of “fair Balance” and “brief summary” provided American consumers with adequate safeguard from misleading claims in general-interest ads. This effectively limited DTC advertising to print media (799). 1997: following hearings convened in 1995, FDA issued a draft guidance on DTC advertising, followed by a final guidance in 1999, that redefined “adequate provision” of risks and benefits to include reference to a toll-free number or website (800). At the same time, FDA continued to insist that company press releases needed to give fair balance to the benefits and risks of drugs. “ . . . one might ask who needs press releases when consumers continually encounter celebrity endorsements, ‘astroturf’ (planned and industry-funded ‘grassroots’ disease awareness programs), friendly (or for-hire) science writers, and the like? . . . We are left in the same strange situation that has prevailed for much of the twentieth century: explicit forms of advertising are carefully monitored and regulated but widely decried, while informal or indirect promotions still flourish with virtually no oversight” (800) “ . . . federal regulatory categories have been inadequate to capture the bewildering profusion of marketing techniques employed by the pharmaceutical industry. ‘Ethical,’ ‘advertising,’ ‘labeling,’ ‘education,’ ‘public relations’: each of these [terms] has meaning, technically, but they are of limited value when companies routinely pursue broader marketing strategies that synergistically combine all of them often in the same campaign. . . . There is no golden age to return to by stamping out promotion” (801).