At first blush, the idea seems a little far-fetched. During a time when policy-makers and members of the public are obsessively pre-occupied with the issue of safety, the idea of removing most of the warning language from advertising seems completely counter-intuitive. This is especially true given the fact that Direct-to-Consumer advertising is the focus of so much criticism in the U.S.
However, in the spirit of less is more, this group, made up of advertising, marketing and public relations associations, may be onto something. Not long ago, I wrote a posting about Black Box Warnings and the proclivity that the FDA has to slap a warning on a product without having conducted any studies to see if the Black Box is an effective means of communicating risk to physicians.
Similarly, advertisements are required to contain huge amounts of information about risk. If you look at a print ad, there is an enormous amount of small print attached to each ad. I am a fairly savvy healthcare consumer. I have NEVER read the fine print on one of those ads. I also NEVER could recite back all of the risk information that is crammed into a broadcast advertisement. I wonder if anyone outside the circle of people who have to write it, proofread and approve it, ever have.
Another aspect of the petition is to ask the FDA for create a standing advisory committee of academic and professional experts in consumer behavior to provide communications advice to the agency. While an interesting notion, it is doubtful that an agency, strapped for cash, can indulge in this kind of luxury.
While the paring down of risk information in advertisements may be a good idea, it does seem to be in the wrong place at the wrong time. If there are serious intentions to support this position, however, any proponent would be well-advised to conduct some well-designed studies that demonstrate that the fine print in advertising is, if not impairing patient understanding, doing absolutely nothing to promote it. In other words, if you are going to maintain that the status quo needs to be changed, you need to supply more evidence than an opinion.
Likewise, if consumer groups believe that the status quo is effective, they should do some studies that discover how useful all that small print really is. I’d like to know just who reads all that small print, so that I can be sure never to invite them to one of my dinner parties.