On the Brink of Breakthrough: The Beautiful Chaos of Guiding First-Time Launch Teams
- Edward Foley
- Nov 15
- 3 min read

There’s a particular energy that surrounds a small, emerging biopharma company approaching its first drug launch. It’s a mix of excitement, fear, ambition, and sheer logistical overwhelm; equal parts moonshot and tightrope.
For regulatory advertising and promotional consultants, this territory is familiar. It is exhilarating, messy, and incredibly high stakes. And it never fails to reveal the same truth: scientific brilliance does not automatically translate into commercial readiness.
In fact, many of these companies find themselves on the verge of FDA approval with no established MRL (or PRC) structure, no internal compliance guardrails, and only a vague notion of what “launch” actually entails. That’s when consultants like me get the call. Sometimes too late, sometimes just in time, always urgently.
Working with these first-time launch teams is a master class in patience, creativity, diplomacy, and regulatory discipline. It’s also where some of the biggest pitfalls surface.
The First-Time Launch Blind Spot
The most striking pattern among emerging companies is not a lack of intelligence or work ethic—it’s a lack of experience.
These teams are often made up of world-class scientists and visionary founders who have spent years focused on discovery, not commercialization.
Their first instinct is to pour enthusiasm into every communication. And that’s precisely where things start to wobble. Without a history of advisory comments, without institutional memory, without a claims library, these teams are building a plane while it’s already taxiing down the runway.
The Pitfalls No One Warns Them About
Enthusiasm That Outruns the Evidence
Scientists love their data. They should.But emerging teams often want to spotlight exploratory findings, dramatic subgroup effects, or mechanistic theories that sound compelling but drift into pre-approval promotion. It takes a seasoned reviewer to gently but firmly translate scientific pride into compliant storytelling.
Preapproval Grey Zones That Aren’t Grey at All
Disease awareness, congress materials, and early digital footprints feel harmless to the uninitiated. However, this is where investigational promotion risks start to ratchet up. FDA's stanced on pre-approval promotion is clear. Implying efficacy, foreshadowing approval, or hinting at availability long before the PDUFA date is strictly forbidden. The danger typically isn’t intentional. It’s simply inexperience.
They're Doing it so why Can't we?
This is an age old request. Unfortunately, competitors don’t always get it right. My role is to advise on levels of risk and the company can either assume the risk, or not. I try to counsel my clients on taking smart, business risk, that never involves obvious patient harm.
The “We’ll Build It Later” Mirage
Small companies rarely prioritize promotional review early. Then, as approval draws near, content creation accelerates—fast. Suddenly there’s a scramble to develop SOPs, define roles, establish review gates, and teach everyone what the FDA actually expects.
Underestimating the Sheer Weight of a Launch
Many first-timers imagine a handful of core assets: a website, a leave-behind, maybe a booth for a scientific congress. In reality, a launch is a content ecosystem—hundreds of materials across HCP, patient, payer, digital, sales, training, and congress channels.Without a content map, timelines will collapse and panic will ensue.
One of my favorite phrases to say in these situations is, "If everything is a priority, then nothing is a priority"
Cross-Functional Misfires
In organizations where commercial, medical, and regulatory functions are newly formed, confusion is inevitable. Who approves which claims? Who owns digital? Who reviews patient materials? Without alignment, every asset becomes a negotiation.
Where Compliance Forward Comes In
This is precisely the space where Compliance Forward thrives. Small companies don’t need a massive, fully staffed MRL department. What they need is expertise; not only in FDA advertising and promotion rules, but in the realities of emerging-company culture.
In an industry where one misstep can derail years of progress, early strategic compliance should be thought of an advantage, rather than a necessary box to check. With the right partnership, a company’s first launch doesn’t feel like a scramble. It feels like a beginning.




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