Drug makers are responding with heavy criticism to FDA's draft guidance on interactive promotional media for drugs and biologics. Among the chief critics is PhRMA, whose public comment highlights two major concerns with the draft guidance. The group rejects FDA's assumption that manufacturers have total control over third-party content. PhRMA also says the guidance document incorrectly considers any statements by manufacturers on social media as promotional labeling or advertising. This approach could have a chilling effect on speech otherwise protected by the Constitution.
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