The following article about the FDA’s communication with Zarbees about its use of Facebook to “like” comments from customers claiming medical uses of the company’s products caught my eye - http://charlottesville.legalexaminer.com/uncategorized/fda-monitoring-facebook-cites-supplement-manufacturer-zarbees-for-likes/. I consider it to be an early warning about a tsunami of bad and suspect health claims that FDA and consumers will be facing. Fueled by virtually free publication to everyone on the Internet, there is a fast growing mismatch between published claims about the efficacy of products and FDA’s (or anyone’s) ability to regulate marketing.
The central concept of our recommendation on the FDASIA framework (see previous post) is to create a system that bring real world efficacy and safety into public view. Zarbees is not a regulated product, of course, but if applied to it our system for “Open Outcomes Based Regulation (OOBR)” would bring both the “likes” and “dislikes” into view. Online ratings platforms for doctors, restaurants, products and contractors have some of these features, which effectively reduce the regulatory burden.