NEW JERSEY, August 13, 2001: If the FDA were a car, we think it would be a Volvo.

It's the government agency responsible for the safety of all medications and food products. But does the FDA does have a brand identity?

First, let's define what brand identity is. Some call it brand character, some know it as brand essence. But our definition of brand identity is that phrase or sentence that sums up the experience of interacting with a brand. Every time a customer comes in contact with a brand, the sum "take away" is the brand's identity. Whether it's an ad, a letter, a speech, a press release, a web site, or any other communication vehicle, every one contributes to building the brand's identity.

Other factors influencing a brand's identity are the tone of the copy. The attitude of the headline. The spirit of the tagline. The style of the typography. The choice of colors. The perspective of the artwork. The meaning of the graphics. The emotion. The message. The impact. It all adds up to help differentiate one brand from another.

For example, consider the soft drink market: the brand identity for Mountain Dew could be described as "in-your-face, youthful exuberance, the drink for extreme thirst." This is achieved through ads depicting young men and women enjoying all kinds of extreme sports -- from sky surfing to bungee jumping -- these guys can do it all with the great taste of this highy-caffeinated soft drink. The TV spots are punctuated by the tagline, "Do the Dew."

The brand identity for Gatorade is different. One can describe the Gatorade brand identity as "aggressive, athletic, the essence of performance, what you need to succeed." This brand identity is created through ads depicting serious athletes, all at the top of their game, sweating out drops of Gatorade while outperforming their rivals. The TV spots conclude with the tagline, "Is it in you?"

Now, let's look at the FDA. How does it come in contact with its customers? What are the communication vehicles it employs? And how does it differentiate itself from other government agencies? Does the FDA have a brand identity?

The FDA reaches its "customers" through letters, press releases, and speeches. We can't recall any advertising sponsored by the FDA, but these corporate communication vehicles all have a certain tone: serious, methodical, meticulous, and thorough. Consider a letter you have received from the FDA about a drug. Regardless of whether or not it's an approval letter, the tone and essence are consistent: this is the government, and this is where we stand about the efficacy and safety of your medication.

However, the FDA also reaches its audiences through its policies. Its standards. Its laws. And its decisions about medications. These combine to help shape how we perceive the FDA, to the perception one has about the agency. Product recalls. Requests for additional data. Non-approval letters. Lengthy review times. Recently, it appears that the FDA has stepped up its level of scrutiny regarding new drug applications. Janet Woodcock, director of the FDA's drug division, asserts that there is not a trend toward tougher, more careful reviews. Just fewer, lengthier drug review committees.

But with several high-profile recalls in the last few years, it seems reasonable to expect the FDA to step up its level of review toward new drug applications. Combine this with a recent increase in letters from DDMAC to most if not all of the major drug manufacturers about "misleading" claims in marketing materials, and one gets the impression that the FDA is strengthening its "position" by using these "vehichles" to shape -- or reshape -- its "brand identity." We think the FDA is developing its brand identity as the "tough, fair, and thorough agency that is most concerned with public safety."

When President Bush appoints a director, which is expected to happen sometime later this year, this will help put the finishing touches on the FDA brand identity. Until then, we're closely watching the impact of the Baycol withdrawal, and the impact it will have on FDA policy.

By the way, any suggestions for a tagline for the FDA?

NEXT WEEK: PositionInk #3: The use of celebrity: good brand building or creative crutch?

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