Over-the-Counter Product Gobbledygook 

by Ken Bresler

A version of this article appeared in Pharmaceutical Executive, October 2000.

The 1999 FDA regulation governing labels for over-the-counter drugs won a “No Gobbledygook” award. But the regulation doesn’t ban gobbledygook. It merely allows plain English.

As a matter of fact, the regulation, which was issued in March 1999 and will be phased in over the next few years, specifically allows gobbledygook. Perhaps the “No Gobbledygook” award, from Vice President Al Gore and the National Partnership for Reinventing Government, should be renamed the “Some Gobbledygook” award.

For example, the regulation doesn’t ban “aggravate” from labels or require the phrase “make worse.” It allows both.

The regulation explicitly allows “application” or “applying.” It does not require “putting on” or “rubbing in” – although it implicitly allows them.

The regulation bars only one major gobbledygook word on nonprescription labels and inserts: “contraindications.”

Here is a list of common label and package-insert jargon; simpler substitutions that the FDA approves; and simpler substitutions that the FDA is silent on.

The first column is the jargon. The second column explains what the FDA says in its1999 regulation. If there’s an entry in the row, rather than “NA,” the jargon is always acceptable to the FDA. The last column recommends one of the FDA’s choices. Or it recommends words that the FDA doesn’t mention but are in the spirit of the 1999 regulation.

What are the general principles for my recommendations?

Use short words instead of long words. They’re easier to understand and easier to fit on a label.

Use words that are easy to read and pronounce instead of difficult words. Even if a consumer knows what “physician” means when she hears it, she might not be able to read it.

Use verbs instead of nouns. They’re easier to understand.

Use the active voice instead of the passive voice. For example, use the phrase “Use as your doctor advised you.” Don’t use the phrase “Use as advised by your doctor” or “Use as advised.” The active voice is generally easier to understand. Some passive-voice phrases are particularly hard to understand because they drop the object. For example, “Use as advised” drops the object of the sentence, the doctor, and leaves it unclear who is doing the advising.

Why should your company do more than the FDA requires? If both “aggravates” and “makes worse” are acceptable to the FDA, why aggravate yourself with “makes worse”?

If the FDA says that “application” and “applying” are both acceptable, and says nothing about “putting on,” why should your company use the phrase “putting on”?

Because you want people to use your product. You want them to use it right. You want to be a consumer-friendly company. You want to be the company whose products the pharmacist recommends to consumers, because the directions are clear.

Can any label or insert use any of these simpler substitutions, no matter what the drug or product? Not necessarily. Ask a lawyer. Or as a jargon aficionado would say, “Seek the expert advice from a duly experienced legal practitioner.”

There’s some stuffiness that a decongestant just won’t help. Even some of the FDA regulation is stuffy. The FDA, referring to itself, wrote: “The agency endeavors to require the least amount of information possible to assure proper self-selection and use.” The agency won’t win an award for that sentence. That doesn’t prove that the agency is hypocritical. It proves how hard it is to write simply. This list should help.

Jargon	The FDA’s 1999 regulation	Ken Bresler’s Recommendation
abdominal	Use “abdominal” or “stomach” (in context only). The FDA does not explain which context it means.	Use “stomach” or “near the stomach.”
accompanied by	Use “accompanied by,” “you also have,” or “that occurs with.”	Use “you also have.”
administer	Use “administer” or “give.”	Use “give.”  It is a simple one-syllable word, as opposed to “administer,” which has four syllables.
aggravate	Use “aggravate” or “make worse.”	Use “make worse.”  It’s simpler than “aggravate.”
application	Use “application” or “applying.”	Use “putting on” or “rubbing in.”  They’re simpler phrases.  Don’t use  “application,” which also has means “job application.”  Why use a same word that is more common in a different context?
apply	NA	Use “put on” or “rub in.”  Don’t use “apply.”  The local drugstore is full of products with “apply” in the directions.  The same drugstore may have a sign in the window, “Now Hiring.  Apply Within.”  Why risk confusing consumers, who are more familiar with the second usage?
area	NA	Use “skin” if that is what you mean.
are uncertain	Use “are uncertain” or “do not know.”	Use “do not know,” “are unsure,” or “are not sure.”
assistance	Use “assistance,” “help,” or “aid.”	Use “help” or “aid.”  They are simple single-syllable words.  “Assistance” has three syllables.  If you’re shipwrecked and you spell out a message on the beach in coconuts, what are you going to say?  “Help.”  Not “assistance.”  Not “aid.”
assist	NA	Use “help.”
associated with	Use “associated with,” “due to,” or “caused by”	Use “due to” or “caused by.”  They’re shorter, simpler, and clearer than “associated with.”  When you read in the newspaper that someone is “associated” with organized crime, is he a mobster or not?  Newspapers are sometimes vague on purpose, but labels should not be.
avoid	NA	Use the phrases “don’t,” “as little as possible,” or “keep away from.”
avoid contact with eyes	Use “avoid contact with eyes” or “do not get into eyes.”	Use “do not get into eyes” or “keep away from eyes.”  Don’t use “avoid contact with eyes,” for three reasons. One, the package label might advise the consumer to contact a doctor.  That means “contact” will be used on the same label in two different senses.  Two, consumers should do more than avoidgetting this stuff in their eyes; they should not do so. Three, in the context of eyes, “contact” can mean”contact lenses.” Why risk confusion, even momentarily?
avoid excess handling	NA	Use the phrase “handle this as little as possible.”
avoid contamination	Use “avoid contamination” or “avoid contaminating.”	This is a hard one, because “contaminate” doesn’t have a commonly used synonym.  Recommendation: “Don’t get dirt / anything else / [name of contaminant] in this product.”
avoid inhaling	Use “avoid inhaling” or “do not inhale.”	Use “do not breathe this product,” or, if appropriate, “do not breathe the fumes.”
before a doctor is consulted	Use the phrases “before a doctor is consulted,” “without first consulting your doctor,” or “consult your doctor before.”	Use “ask” or “talk with,” whichever is appropriate. Use the phrases, “before asking your doctor” or “before talking with your doctor”; or “ask your doctor before” or “talk with your doctor before”; or “ask your doctor first” or “talk with your doctor” first.
beverages	Use “beverages” or “drinks.”	Use “drinks.”  Even people who know what “beverages” means hardly use the word in conversation.  One common context for “beverages” is “alcoholic beverages.”  If that’s what you mean, just say, “alcoholic drinks.”
broken skin	NA	Use “cuts and scrapes” if that’s what you mean.  Use “cuts, scrapes, rashes, and burns” if that’s what you mean.
cleanse	Use “cleanse” or “clean.”	Use “clean.”  It is simpler, conversational, and easier to pronounce.
consecutive	NA	Use “in a row.”
consult	At one point in the regulation, the FDA recommends using “consult,” “contact,” or “ask.”  Elsewhere, it recommends using “consult” or “advise.”	Use “contact” or “ask.”  They’re simpler words than consult.  “Ask” has the additional advantage of being a single syllable.
develops	Use “develops,” “begins,” or “occurs.”	Use “starts,” “happens,” or “comes.”
difficulty	Use “difficulty” or “trouble.”	Use “trouble.”  It has two syllables; “difficulty” has four.
difficulty in urination	Use “difficulty in urination” or “trouble urinating.”	Use “trouble urinating.”   Not only is “trouble” shorter and more conversational than “difficulty,” but “urinating” is a verb, which is preferable to the noun “urination.”  See “urinating.”
direct (as a verb)	NA	Use “tell.”
directly	Use “directly,” “immediately,” or “right away.”	Use “immediately” or “right away.”  Don’t use “directly,” which is an obscure synonym for “immediately.”
discard	Use “discard” or “throw away.”	Use “throw away.”  It’s more conversational.
discontinue	Use “discontinue,” “stop,” or “quit.”	Use “stop” or “quit.”  They are more conversational and both have a single syllable.  “Discontinue” has four syllables and is pretentious.
dosage	NA	Use “dose.”  It’s shorter and easier to understand.
drowsiness	Use “drowsiness” or “the drowsiness effect.”	Use the phrases “may make you drowsy” or “may make you sleepy.”
enlargement of	Use “enlargement of” or “an enlarged.”	Use “get bigger” or “make…bigger.”
except under the advice of a doctor	Use “except under the advice of a doctor,” “unless directed by a doctor,” or “unless told to do so by a doctor.”	Use “unless a doctor tells you to do so.”  The other phrases are in the passive voice, which is harder to understand than the active voice.  The phrase “except under the advice of a doctor” is also hard to understand because it uses a noun (“advice”) instead of a verb (“tells”).
exceed	Use “exceed,” “use more than,” or “go beyond.”	Use the phrases “use more than,” or “go beyond.”
exceed recommended dosage	Use “exceed recommended dosage” or “use more than directed.”	Use the phrases “use / take more than a doctor / the directions tell you to” or “use / take more than the dose you’re supposed to.”
excessive	Use “excessive” or “too much.”	Use the phrase “too much.”
excitability may occur	Use “excitability may occur” or “you may get excited.”	Use “you may get excited” or “you may get jumpy.”  Don’t use “excitability may occur.”  It’s in the passive voice, and doesn’t reveal where or in whom this excitability may happen (not “occur”).
exposure to the sun	NA	Use “go out in the sun,” “in the sun,” or “while outside in the sun.”
experience	Use “experience” or “feel.”	Use “feel.”  It’s one syllable, as opposed to four.
external use	NA	Use the phrase “use on the outside of your body.”
following (as in “after”)	NA	Use “after.”  “Following means “after,” but it’s also a verb, as in “following the leader.”  Why risk confusion with the verb, even momentarily?
for relief of	Use “for relief of” or “relieves.”	Use “relieves” or “makes better.”
for temporary reduction of	Use  “for temporary reduction of” or “temporarily reduces.”	Use “temporarily makes smaller” or “temporarily makes better” (as in “temporarily reduces swelling”).
for temporary relief of	Use “for temporary relief of” or “temporarily relieves.”	Use “temporarily relieves” or “temporarily makes better.”
for treatment of	Use “for treatment of” or “treats.”	Use “treats.”  It’s a single word with a single syllable, and is a verb.  Don’t use “for treatment of,” which is three words, with a total of four syllables, and relies on a noun, “treatment.”
frequently	Use “frequently” or “often.”	Use “often.”  It’s shorter and more conversational.
if contact occurs	NA	Use “if you get this in / on.”
if practical	Use “when practical” or “if possible.”	Use “if possible” or “if you can.”
immediately	Use “immediately,” or “as soon as.”	Use “as soon as,” “right away,” “quickly,” or “now” (as in “Call a doctor now”).
immediately following	Use “immediately following” or “right after.”	Use “right after.”  It  has three syllables, as opposed to eight syllables for “immediately following.”
improve	Use “improve,” “get better,” or “make better.”	Use “get better” or “make better.”  A consumer may understand “improve” when it is spoken, but it’s a hard word to read.
increased	Use “increased” or “more.”	Use “more.”
increase your risk of	Use “increase your risk of” or “cause.”	Use “cause” or “make…more likely.”
indications	Use “indications” or “uses.”	Use the word “uses.”  It is shorter and more conversational.  And “indications” is not a synonym for “uses” in everyday language.
ingest	NA	Use “eat” or “swallow.”
ingestion (as in “not intended for ingestion”)	NA	Use “Don’t eat or swallow” or “Use only on the outside of your body.”
inhalation	Use “inhalation” or “puff.”	Use “puff” or “breathe in.”
insert	NA	Use “put in.”
instill	Use “instill” or “put.”	Use “put.”
instruct	NA	Use “tell.”
intended (as in “not intended for ingestion”)	NA	Use the phrase “Don’t use.”  Don’t use the word “intended.”  Whether a product is intended for a certain use is irrelevant if your true aim is that people don’t use it a certain way.
liberally (as in “apply liberally”)	NA	Use “a lot” or “generously,” as in the phrases, “use generously” or “put on a lot.”
minimize	Use “minimize” or “reduce.”	Use “make less” or “make less likely.”
mucous membranes	NA	Use “nose, eyes, mouth, ears,” and if applicable, “vagina and anus.”
nervousness, dizziness, sleeplessness occurs	Use “nervousness, dizziness, sleeplessness occurs,” or “you get nervous, dizzy, or sleepless.”	Use “you get nervous or dizzy, or you lose sleep.”  Don’t use “nervousness, dizziness, sleeplessness occurs.”  That phrase doesn’t say in whom the conditions occur.  And that phrase depends on nouns.  These particular nouns are longer and harder to understand that the corresponding adjectives (“nervous” and “dizzy”) and verb (“lose sleep”).
not to exceed	Use “not to exceed,” “do not exceed,” or “not more than.”	Use “not more than.”
not to be swallowed	NA	Use “Don’t swallow this.”
obtain	Use “obtain” or “get.”	Use “get.”
occur	NA	Use “happen.”
over-apply	NA	Use the phrases “put too much on” or “put on too much.”
per day	Use “per day” or “daily.”	Use “daily.”
perforation of	Use “perforation of” or “hole in.”	Use “hole in.”
persists	Use “persists,” “persistent,” “continues,” “does not go away,” or “lasts.”	Use “continues,” “does not go away,” “lasts,” “stays,” or “still have.”
persistent	Use “persistent,” “that does not go away,” “that continues,” or “that lasts.”	Use “that continues,” “that does not go away,” “that lasts,” “that stays,” or “that you still have.”  Don’t use “persistent.”  It is more complex word than the other phrases.  It is also an adjective, which is harder to understand than a verb.
physician	Use “physician” or “doctor.”	Use “doctor.”  It’s shorter, more conversational, and easier to read for people who have trouble reading English, including non-native English speakers.  Readers must know how to pronounce “ph”; the “s,” which sounds like a “z”; the “y”; and the “ci,” which sounds like “sh.”
present (as in “redness is present”)	NA	Use “you have redness” or “the child has redness.”
presently	Use “presently” or “now.”	Use “now.”  Don’t use “presently”!  It is three syllables and a less common word than “now.”  More importantly, “presently”  means both “now” and“soon”!  Do you want the consumer to call a doctor now or soon?  If now, say “now.”  If soon, say “soon.”
prior	NA	Use “before.”
produce	Use “produce” or “cause.”	Use “cause,” “lead to,”  or “make.” Don’t use “produce.”  It  has a common homograph (as in “fresh produce”) that can cause (not “produce”) confusion.
promptly	Use “promptly,” “quickly,” or “right away.”	Don’t use “promptly,” which is an imprecise word.  Does it mean “now” or “soon”?  Use, as appropriate, “quickly,” “right away,” “as soon as,” or “now.”
pulmonary	Use “pulmonary” or “lung.”	Use “lung.”  It’s not long.
reapply	NA	Use “put on again.”  Don’t use “reapply.”  That’s people  do when they don’t get the job they want.
recur	Use “recur,” “reoccur,” “return,” or “come back.”	Use “return” or “come back.”  They’re more common.
reduce	Use “reduce” or “minimize.”	Use “make less” or “make less likely.”
seek professional assistance	NA	Use “get medical help” or “contact a doctor.”  Don’t use “seek professional assistance.”  What kind of professional assistance?  Certainly not an accountant.  So just say “medical” or “doctor.”
sensation	Use “sensation” or “feeling”	Use “feeling.”  It’s shorter, easier to read, and more conversational.
solution	Use “solution” or “liquid.”	Use “liquid.”  Don’t use “solution,” which people use more commonly in the context of solving problems.
rectal use	NA	Use the phrase “use on your rectum.”  The noun “rectum” is unfamiliar enough to people.  The adjective “rectal” is less familiar.
tends	NA	Use “is likely to.”
topical use	NA	Use the phrase “use only on your skin.”
uncertain	Use “uncertain” or “do not know.”	Use “do not know,”  “are unsure,” or “are not sure.”
unless directed by a doctor	Use “unless directed by a doctor,” “except under the advice of a doctor,” or “unless told to do so by a doctor.”	Use “unless a doctor tells you to do so.”  The other phrases are in the passive voice, which is harder to understand than the active voice.  The phrase “except under the advice of a doctor” is also hard to understand because it uses a noun (“advice”) instead of a verb (“tells”).
use caution	Use the phrase “use caution” or “be careful.	Use “be careful.”  It’s easier to read and more conversational.  When you went outside to play as a child, your mother said, “Be careful,” not “Use caution.”
vaginal use	NA	Use the phrase “use on your vagina.”  Don’t use the phrase “vaginal use,” which is a concept.  The phrase “use on your vagina” is concrete.
when practical	Use “when practical” or “if possible.”	Use “if you can.”
worsens	Use “worsens,” “gets worse,” or “makes worse.”	Use “gets worse” or “makes worse.”