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TALK ABOUT SPLITTING HEADACHES. For both consumers and America's $2.7 billion over-the-counter pain-killer industry, the advertising war between Johnson & Johnson's No. 1 brand Tylenol and American Home Products' No. 2 Advil has begun to feel like a migraine.

The pounding began last fall when Johnson & Johnson launched a television attack ad that soon had the two companies decrying the side effects of each other's products. You know, the ones in which a very serious-looking actor "discovers" that Brand X just might possibly be more harmful than, say, swallowing drain cleaner. The confusing charges and countercharges prompted the major TV networks to pull the harshest spots; ABC went so far as to ban all drug commercials that take potshots at rival remedies.

Undaunted, the combatants have now resumed their fight in print, where American Home Products, a $13.4 billion maker of such brands as Anacin and Preparation H, launched an assault on Tylenol last week. The company paid for a full-page ad in the New York Times and other papers to reprint an open letter written by Antonio Benedi, a former appointments secretary for George Bush, who blames Tylenol for the liver failure that forced him to have an emergency transplant in 1993.

Johnson & Johnson was furious not just about the letter but also at the fact that the newspapers published it without labeling it advertising. Worse, in J&J's view, at the bottom of the ad was a message that Whitehall-Robins Healthcare was underwriting the reprint "as a public service." Not exactly, since it's the unit of American Home Products that makes Advil.

This latest attack led industry watchers to warn that the infighting could become suicidal. "This has exploded out of control," says Paul Kelly, president of Silvermine Consulting in Westport, Connecticut, which advises consumer-products companies. "Sooner or later people are going to get concerned about the whole category [of pain-killers] and stay away." There is, in fact, no real cause for such consumer concerns.

Despite the hysteria, all over-the-counter headache remedies today are generally safe for the vast majority of consumers, as long as they follow the recommended dosage. (See chart.) But, as for all drugs, there are exceptions, some of which are minor, some rare--and all of which must be noted by the manufacturer, providing plenty of ammunition for adversaries to attack.

The scorched-earth campaigns have pointed out the hazards of widely used headache remedies such as Tylenol and Advil as dramatically as any critic could. And that can't be good for business. J&J's McNeil Consumer products unit, which makes Tylenol, has sold 240 billion tablets and capsules of Tylenol over the past three decades. Tylenol represents more than $800 million in annual sales for J&J, which last year had total sales of $18.8 billion. But Tylenol's market share has been slipping, to 30.1% last year from 34% in 1994.

Tylenol is being challenged by new over-the-counter drugs such as naproxen (brand name: Aleve) and ketoprofen (brand name: Orudis), as well as aspirin. Advil, which is ibuprofen, holds a 12.9% market share and has sold more than 48 billion doses since it became nonprescription in 1984. It contributes some $350 million annually to American Home Products' coffers.

The ad that set off alarms last week presented the harrowing first-person account of Benedi, 40, who in 1994 won an $8.8 million damage award in Virginia in a suit against McNeil and J&J. (A three-judge appeals panel upheld the jury award last year.) Benedi took the recommended dosage of Tylenol to fight a bout with the flu. Benedi, who generally drank two or three glasses of wine with dinner each evening, stopped drinking while taking the medication. But several days later he suffered "complete liver failure" and only an 11th-hour transplant saved him.

Since then, Johnson & Johnson has printed a warning on Tylenol packages that advises consumers who have three or more drinks daily to consult a physician before taking the pain-killer. According to Dr. Tony Temple, McNeil's executive director of medical affairs, the warning is aimed at people "who are chronic heavy drinkers."

But Dr. Hyman Zimmerman, a liver expert and professor emeritus of medicine at George Washington University, argues that the warning is not explicit enough. Zimmerman, who testified on Benedi's behalf, says chronic drinkers should take no more than two grams (an amount equal to four extra-strength Tylenol gelcaps) a day to avoid possible liver damage. Says he: "If you wake up at 2 in the morning with a headache or a toothache, you are not going to call your doctor to ask if it's O.K. to take Tylenol." Meanwhile, the Food and Drug Administration has been preparing a warning about the dangers of interaction between pain-killers and alcohol that would go on all over-the-counter headache remedies--including Advil.

Benedi, who describes himself as an occasional business consultant, ran his open letter in the Washington Times (circ. 94,500) on March 14 in what he called a warning to other consumers. "I look at my kids, and I have to say I don't know how long I'll live because these people failed to warn me," he says. "That's why I felt a responsibility to write." Among his most avid readers were officials of American Home Products who got Benedi's permission to place the open letter in the New York Times (circ. more than 1 million) last Wednesday at a cost of some $67,000.

Johnson & Johnson's indignation is a bit misplaced, considering that it fired the first shot in this war last fall. In TV spots created by the ad firm Saatchi & Saatchi, J&J attacked ibuprofen, suggesting that it could interfere with medicine for hypertension. J&J next ran Saatchi & Saatchi commercials claiming that ibuprofen could be harmful to persons who suffer from ulcers.

In striking back, American Home Products zeroed in on the alcohol warning on Tylenol packages. In ads created by its agency, Young & Rubicam, a silver-haired actor reads the warning with obvious concern and advises viewers to "Ask your doctor. Advil may be a smarter choice." That only provoked Johnson & Johnson to create a nationwide campaign "to address misinformation" in the Advil commercial. Included were ads in 50 major publications plus a 1-800 hot-line number to field questions from consumers. At the same time, J&J lodged a complaint with the networks challenging the Advil commercials.

All this was too much for TV executives, who rarely get befuddled enough to turn down business. In announcing a ban on attack ads last month, ABC said it feared that such spots could be "misinterpreted" by viewers as "overplaying the health concerns involved." The other networks pulled the fiercest ads but continue to run milder comparison spots.

The network withdrawals drew a tight-lipped response from Robert Pitofsky, chairman of the Federal Trade Commission. "I support comparative advertising," Pitofsky says. "I hope that this is not an occasion to suppress comparative ads overall." Perhaps not, but the rat-a-tat of battling drug claims has been making heads feel like the morning after. Hey, has anyone got an aspirin?