Poking O’s in the FDA

cheerios-box-front-2007In many organizations that I’ve worked with in the past, product and marketing development have had a business process to guide the development of marketing copy and product claims to ensure that a legally compliant but flexible approach is taken to communicate with the consumer. That’s why this recent article at WSJ.com (may require registration) caught my attention. I’m nearly certain that General Mills and their marketing agencies have negotiated the language time and again with all manner of experts to ensure accuracy. Instead, my focus is on the group that’s supposed to protect us: the FDA!

The real question is “What has changed that raised the FDA’s inept ire?”. General Mills has been making this claim for more than a decade, but the FDA never seemed to have a problem before. I think it is safe to assume that every member of that organization should have been exposed to some form of Cheerios advertising or perhaps consumes the cereal themselves, so I’m not so sure that ‘new developments’ would be a sufficient answer to give.

As a business analyst, I can only hope that recent organizational changes have been made to better carry out the part of the FDA’s stated mission of

“helping the public get the accurate, science-based information they need to use medicines and foods to improve their health”

and a division of the FDA is now devoted to media monitoring activities. Otherwise, this is a sad indictment on the government’s state of affairs, which highlights ineptitude, lack of awareness/relevance, and an inability to enforce real change.

Recommendation: Just as many companies’ PR divisions monitor a myriad of media channels to ensure that their brand is secure, so too should the FDA ensure that their “enforcement activites” have actual consequences by enabling or building a Media division that covers radio, television, Web, and print channels (and more in the future with the maturing of the mobile channel and other platforms as well). The Media division would then be a “first line of defense” to pick up these claims, acting as a public rights advocate and triage expert by:

  • acting as a first responder to marketing claims as soon as they are published in the wider mediums,
  • queuing up severe violations in a prioritized fashion and publishing this list on some government publication medium,
  • creating marketing guidelines on language and visuals for the layman marketer and business owner to follow, and
  • making all of this transparent to the public.

The public should be confident about the FDA and how they are in fact doing their job, and considering that the FDA is funded by tax dollars, we should demand efficacy.

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