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Does Readability Matter in Regulatory Documents?

7/10/2015

1 Comment

 
This may sound like a rhetorical question, but I have worked with many people in the pharmaceutical industry for whom readability is not high on the list of priorities. For documents to be submitted to regulatory agencies, the accuracy of data and compliance with regulations are certainly the most critical concern. After this, however, importance can vary widely among members of a drug development team on specific issues, ranging from strict adherence to in-house templates and styles to how many tables should be replaced by figures. More often than not, team members just want each document to look exactly like every other document of the same kind written within the company for the last 10 years. Those got the drugs approved, didn't they? If the process isn't broken, why fix it? 

It is understandable that readability is not a major concern. Regulatory writing is generally considered the most rigid and standardized genre of medical writing. The industry around the world follows ICH guidelines and templates for study reports, protocols, and summaries, which can breed a sense of complacency. Regulatory agencies employ experts in the review of applications, who surely do not mind highly complex data presentation, dense text, and lots of jargon. In addition, standardization and uniformity are indeed important in technical writing (that's another subject onto itself), although they are often confused with a lack of flexibility. Most important, submissions are often put together under very tight deadlines, and there is simply no time to bother with such "luxury" as document readability. 

So why does readability matter? The answer is simple. On the other side of each submission, a real person will read these documents, and it is to your advantage to get on their good side. 

When I worked as an FDA labeling reviewer, I read many briefing packages and new drug applications and, in some cases, felt the frustration of wading through poorly written and illogically organized text. I heard medical reviewers sigh with resignation. One person said she wished that poor writing were grounds enough for refusal to file. Poorly written documents take longer to read and absorb, are less persuasive, and reduce the effectiveness of the message. 

Think about the workload of the medical reviewers who will look at your submission, and imagine how much a crystal clear, easy-to-read, logically organized application would lighten their mental load. Everyone has experienced the sensation of smooth sailing when reading a well written article with no "bump" of confusion or disconnected reasoning. The mood of the reviewer depends on the readability of your documents, which in turn may leave a general impression in your favor. Even if your data are overwhelmingly and indisputably positive, readability can substantially reduce the review duration and get your product on the market a few days before the mandatory review deadline. This can mean thousands or millions of dollars in extra revenue or an edge over your competitors. 

Nathaniel Hawthorne wrote, "Easy reading is damn hard writing." That truth applies even more to technical writing than to fiction, where data are abundant and complex.  
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    I am a freelance medical writer in the pharmaceutical industry.

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