As part of its recent changes to medicine labelling regulation, the Therapeutic Goods Administration (TGA), the Australian Medicines Regulator, changed the requirements for over the counter (OTC) medications. These are medicines available in community pharmacies but without a doctor’s prescription. As part of new requirements TGA issued Guidance document which they claim is Best Practice. 1 Medicine labels – Guidance on TGO 91 and TGO 92, Page 41 of 79 V2.1 July 2019
As part of that they offer a series of back of pack ‘best practice’ labels for commonly available pharmacy only medicines. Below is an example. 2Medicine labels – Guidance on TGO 91 and TGO 92 Page 66 of 79 V2.1 July 2019.
If you are an information designer, you will know that prima facie this is not an example of best practice or even good practice. But rather than take you on a guided tour of all its faults, I’m going to confine myself here to pointing out what is likely to happen if the labelling were tested using routine diagnostic testing methods. I do so on the basis of data from hundreds of such tests conducted confidentially for pharmaceutical companies. Though I shall obviously refrain from citing any detailed results.
1. Overall appearance
Consumers all over the world are familiar with the appearance of this type of back of pack. It’s commonly used (or rather misused) in many jurisdictions and is easily recognisable by consumers as driven by legal requirements. A common comment made by consumers in testing is that it is:
…not really meant for consumers. It’s there to protect the company from prosecution.
2. Using past experience
Drawing on their own past experience, consumers do not expect to find it easy to read and even less easy to understand.
In testing this type of public document we explain at the beginning of testing that we will be asking people questions about the medicine and its use and insist that they try and answer the question using the information on the packaging. Their response is often to try answering the questions without looking at the packaging, using their own experience instead. We remind them to use the packaging as we go through the testing. The fact that we have to remind them repeatedly is telling. Simply put, they don’t like reading these panels. We suspect that outside of our testing they would be even less likely to read them.
3. Stopping readers
As if to reinforce consumers’ view of the purpose of the back of pack, the first thing they see after the totally redundant heading Medicines Information, is Active Ingredients. We know from research we undertook on behalf of the government, which was subsequently published publicly as an example of best practice by the Australian Language and Literacy Council, that the best place for Active ingredients is last not first. 3Penman, Robyn, David Sless, and Rob Wiseman. “Best Practice in Accessible Documents in the Private Sector,” In Putting it Plainly: Current Developments and Needs in Plain English and Accessible Reading Materials, Canberra: Australian Language and Literacy Council, 1996.
Putting it first and asking consumers to read the names of the active ingredients is doubly duanting.
- The words ‘Paracetamol’ and ‘Ibuprofen’ are part of a technical language used by Doctors and Pharmacists and therefore unfamiliar and potentially meaningless to most consumers.
- Consumers have difficulty pronouncing these unfamiliar words.
This reinforces consumers view that this is not written with them in mind, and they are inclined to give up and not read any further.
All of this is taking place in the few short seconds that consumers give normally to the back of pack. I could go on in great detail, but the point is made. There are many faults in this packaging beyond the two major ones above. Suffice to say that this label is unlikely to meet even the minimal usability standards set out in the industry code of practice.
When TGA was proposing these new regulations many of us asked that any new labelling proposed should be tested. The TGA said it would, but never kept it’s promise. Medicine users deserve better.