A lot has been said recently about some things that Johnson & Johnson and its operating companies have been doing on the social web.

For instance, a few weeks ago the WSJ Health Blog and Eye on FDA both highlighted a new Facebook tool from our Vistakon company that would help remind members to replace and buy new contact lenses. This followed recent interest in the ADHD Moms page on Facebook that Johnson & Johnson’s McNeil Pediatrics is hosting.

Though many folks have applauded these efforts, a few – like John at the Pharma Marketing Blog – have questioned whether any of these are really social networking.

As John put it:

Part of social networking is the ability of ordinary people like you and me — JNJ customers — to add comments to social networks set up by others. Usually when pharmaceutical companies host a social network channel, they turn off the comments for obvious and understandable reasons.

It’s a great point. Let’s face it – at this stage, many of these corporate efforts – particularly in the healthcare field — don’t quite match what you or I do when we use Facebook or Twitter or engage with others online. (Ok. To be honest, I still don’t use Twitter that often – I just have trouble figuring out where Marc Monseau ends and Marc Monseau, Company Spokesman begins… but that’s ANOTHER story.) While I would argue that what is being done is a good start, it nonetheless begs the question – why not more?

Well, as Tricia Geoghegan was quoted saying in the WSJ Health Blog post about the ADHD Moms page on Facebook, in the healthcare realm, this can be rather, um…. complicated.

Take the case of what we had to think through as we developed THIS little ‘ole blog.
In addition to our well-known consumer products, Johnson & Johnson also sells prescription medicines and medical devices — which are highly regulated products. That’s where things become complex. Among the many considerations we had to take into account as we tried to move from simply broadcasting messages to engaging in conversations, we had to sort out how we would handle comments that could include reports of adverse events (which legally must be reported to the FDA — something we routinely do) – and could include a discussion of so-called “off-label” or unapproved uses of our products, which we do not support or encourage.

Ultimately, the decision was reached, right or wrong, to create a comments policy that would encourage comments that would be “on topic” – as well as to not allow comments that could get us into legal or regulatory trouble.

These limits haven’t been such a big problem for JNJBTW (despite some suggestions to the contrary (link)) Since it is a corporate blog, JNJBTW tends to touch on corporate matters such as the company’s strategy and other corporate-wide initiatives – and so it is rare that we talk about products. After all, that’s something our operating companies are more familiar with.

But as Johnson & Johnson’s operating companies (and, based on what I’ve heard from others in the industry, their competitors as well) try to figure out how to get involved in the conversation, the question of how to manage these comments inevitably comes up.

Clearly there need to be some measures put into place to mitigate the risk of legal or regulatory liability. However, the more hurdles that are put into place, the less credible, useful or open those online efforts become, and in the end you may be left with something that could be criticized as being more akin to a traditional, one-way communications effort.

And so what we have ended up doing in many cases is take some small steps to get more comfortable with getting involved. We are also making sure we have processes in place to handle adverse event reports and that we have responsible people involved who can respond quickly to questions.

At the same time, projects like JNJBTW and the Johnson & Johnson health channel on YouTube are giving us some great experience.