vvEPA
               United States    :
               Environmental Protection
               Agency
               Prevention, Pesticides,
               and Toxic Substances
               (7409)
EPA742-R-99-004
October 1999
Consumer Labeling Initiative
Phase Tj  Pteport     ^
                             SPECIAL!
                                 Names
                                 aam
                            Needle
                   Internet Address (URL) • http://www.epa.gov
       Recycled/Recyclable • Printed with Vegetable OH Based Inks on Recycled Paper (Minimum 30% Postconsumer)

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Consumer Labeling Initiative
           Phase II Report
                   prepared for:
                   Julie Winters
              Pollution Prevention Division
         Office of Pollution Prevention and Toxics
          U.S. Environmental Protection Agency
                 401 M. Street, SW
                Washington, DC 20460

                      and

                    John Alter
               Chemical Control Division
         Office of Pollution Prevention and Toxics
          U.S. Environmental Protection Agency
                 401 M. Street, SW
                Washington, DC 20460
                    prepared by:

                 Abt Associates Inc.
                  55 Wheeler Street
              Cambridge, MA 02138-1168
               Contract Number: 68-W6-0021
                   October, 1999

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                       TABLE OF CONTENTS
 TABLE OF CONTENTS  	                    I

 LIST OF APPENDICES	           vii

 LIST OF TABLES  	                               •
                                             **"**"**•*'••"••••••••••»•«••••.  I.A.

 LIST OF CHARTS	                                  •
                                          ••••••••••••••«•»•«.. ....,...,>>ti>  J\,L

 LIST OF ACRONYMS  	                                    „:::
                                       ""***""*"•••••••••«••••,•••••••»•.«... A.111
                                                                            \
 FOREWORD	         xv
      Outline of the Phase II Report	   xvji
      How to Use this Report	xjx

 EXECUTIVE SUMMARY	       j
      The Phase II Process  	   2
      Phase II Research	4
      Conclusions of Quantitative and Qualitative Research	6
      Phase II Recommendations	   7
            Signal Words and Hazard Hierarchy Recommendations	7
            Ingredients Recommendations	8
            Label Format Recommendations	g
            Consumer Education and "Read the Label FIRST!" Recommendations	10
            Storage and Disposal Recommendations	10
      EPA Actions on CLI Recommendations	12
            Draft OPP Strategy for Implementation of the Phase II Label Changes	12
            CLI Media Event	13
            Completion of the Phase II Report	14
            Consumer Education Campaign  	        14
      Next Steps for the CLI	16

Chapter 1: OVERVIEW OF PHASE II OF THE CLI 	17
      Focus of Phase II	18
      CLI Participants and Their Roles	19
            Role of the EPA	.19
            Role of the CLI Task Force Members	19
            Role of EPA Partners	19
            Stakeholder Outreach	20
            Other Participants in the CLI	21
      The Process of Phase II 	22
            The History of Phase II 	22
      Research in Phase II	25
                                Table of Contents

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             First Aid Qualitative Research	25
             Quantitative Consumer Research	„	25
             Qualitative Consumer Mini Focus Groups 	26
       CLI Subgroup Activities	 28
             Quantitative and Qualitative Research Core Group	28
             Standardized Environmental Information on Product Labels Subgroup	29
             Storage and Disposal Subgroup	30
             Consumer Education Subgroup	30

Chapter 2: QUANTITATIVE RESEARCH  	33
       Strategy for the Quantitative Research  	35
       Quantitative Study Design	36
             Screening to Identify Product Category Users for Use in the Study	36
             Non-User Results	37
             Sample for the Telephone Interviews and Mail Questionnaire	38
       Telephone and Mail Questionnaires  	40
             Survey Questionnaires and Learning Objectives	41
             Telephone Interview Outline	41
             Mail Questionnaire Outline	43
       Quantitative Research Data	44
             Statistical Testing of Data	44
             Breakdown of CLI Data	44
             Data Precision  	46
       Quantitative Research Findings and Implications	47
             Learning Objectives and Topic Areas	47
             Findings and Implications	48

Chapter 3: QUALITATIVE RESEARCH  	85
       Research Design	87
             Recruitment Criteria	87
             Development of the Discussion Guides	89
       Process of the Mini Focus Groups	90
       Findings from the Mini Focus  Groups	92
             Past Experience and Product Selection	92
             Reading Labels and Implications of Not Reading Labels	92
             Satisfaction with Current Labels for Products Discussed	93
             Which Label Sections Participants Read	93
             Why and When Mini Focus Group Participants Read Product Labels	94
             Locations for Types of Label Information	94
             Signal Words	95
             Graphical Representation of Signal Words	96
             Understanding Directions for Use	 98
             Precautionary and Other Label Statements 	99
             Listing Ingredients	,	101
             Boxed Formats	102
             Separate Pamphlet	 103
                                   Table of Contents

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             Label Standardization	103
             Logos for the "Read the Label FIRST!" Campaign	105

Chapter 4: QUANTITATIVE AND QUALITATIVE RESEARCH CONCLUSIONS  	107

Chapter 5: FIRST AID — QUALITATIVE RESEARCH	109
       First Aid Phase I Findings	109
       First Aid Phase II Goals and Objectives 	110
       First Aid Phase II Activities	110
             Methodology of One-on-One Interviews	Ill
             Strengths and Limitations of Qualitative Research	Ill
       Findings from First Aid Qualitative Interviews	112
             General Findings  	112
             Findings Specific to Particular First Aid Statements	113
       First Aid Statements as a Result of Phase II  	120

Chapter 6: PHASE II SUB-GROUPS	123

SUB-SECTION 1: Standardized Environmental Information on Product Labels Subgroup .. 123

SUB-SECTION 2: Storage and Disposal Subgroup	125
       Findings from Phase I	 125
       Goals and Objectives for  Phase II	125
       Storage and Disposal Activities in Phase II	126
             North American Hazardous Materials Management Association (NAHMMA)
                   Annual Meeting	126
             North American Hazardous Materials Management Association (NAHMMA)
                   Mailing	126
             Chemical Specialties Manufacturers Association (CSMA) and Household and
                   Institutional  Products Information Council (HIPIC) Members'
                   Presentations 	127
             The Waste Watch Center (WWC) Report on Household Hazardous Waste (HHW)
                   Management Programs  	127
             Discussion Paper Evolving from the 1995 Cleaning Products Summit  	128
             Telephone Conversations	128
       Learnings from Phase II Research	129
             Learnings from the NAHMMA Annual Meeting	129
             Information from NAHMMA Mailing  	129
             Chemical Specialties Manufacturers Association (CSMA) and Household and
                   Institutional  Products Information Council (HIPIC) Members'
                   Presentations	133
             Waste Watch Center (WWC) Report on Household Hazardous Waste (HHW)
                   Programs	138
             Discussion Paper Evolving from the 1995 Cleaning Products Summit  	140
             Findings from Telephone Conversations	143
       CLI Storage and Disposal Subgroup Activities	145
                                  Table of Contents
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             Areas of Agreement for Storage and Disposal Label Language  	145
             Areas of Disagreement for Label Language  	146
             Suggestions for Label Language for Partially-filled Containers	147

SUB-SECTION 3: Consumer Education Subgroup	150
      Overview and Goals of the Consumer Education Campaign  	150
      CLI Consumer Education Subgroup Activities	152
             Components of the Consumer Education Plan  	152

Chapter 7: PARTNER AND TASK FORCE MEETINGS	155
      March 20,1997 CLI Phase II "Kick-off Meeting  	155
      February 1998 Partner and Task Force Meeting	157
      September 1998 Partner and Task Force Meeting	158
      April  1999 Partner and Task Force Meeting	159

Chapter 8: STAKEHOLDER INTERACTIONS AND COMMENTS	161
      Stakeholder Outreach	161
             Media Conferences and Public Announcements	161
             Publications/Memos and Correspondence	161
             CLI Website	162
             Stakeholder Meetings	162
      Stakeholder Comments	 164
             Comments on the CLI 	164
             Comments on EPA Policy 	164
             Comments on Quantitative Research	164
             Comments on Labeling  	165
             Comments on Consumer Education	165
             Comments on the Flammability of Products	166
             Comments on Disclosure	166
             Comments Relating to Storage and Disposal Issues	166
             EPA Response to Stakeholder Comments	168

Chapter 9: CLI PHASE II RECOMMENDATIONS	169
             Signal Words and Hazard Hierarchy Recommendations	170
             Ingredients Recommendations	170
             Label Format Recommendations	171
             Consumer Education and "Read the Label FIRST!" Recommendations	173
             Storage and Disposal Recommendations	173
      EPA Actions on CLI Recommendations	175
             Draft OPP Strategy for Implementation of the Phase II Label Changes	175
             CLI Media Event	176
             Completion of the Phase II Report	177
             Consumer Education Campaign 	177

Chapter 10: PUBLIC REVIEW OF THE CLI PHASE II REPORT DRAFT	179
      Comments on the CLI Phase II Report Draft	180
iv
Table of Contents

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      Comments on the CLI	

Chapter 11: PEER REVIEW COMMENTS ON THE PHASE II REPORT DRAFT  	183
      Background  	           183
      Document Reviewed	        183
      Peer Reviewers	          183
      Charge to Reviewers  	           184
      Summary of Reviewers' Comments 	    184
            Study Design	184
            Study Results and Recommendations 	185
            Other Comments  	  18g
            Peer Review Process	             187
      Questions to the Peer Reviewers	188
            Study Design	   188
            Study Implementation	188
            Study Results and Recommendations	 188
            Peer Review Process  	189
            Other	    189
                                Table of Contents

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                        LIST OF APPENDICES
1-1: List of Products Included in the CLI  	195
1-2: List of CLI Task Force Members	199
1-3: List of CLI Partners  	203
1-4: List of CLI Stakeholders  	207
1-5: Members of the CLI Quantitative Research Subgroup — Core Group	213
1-6: Members of Qualitative Subgroup	217
1-7: Members of Standardized Environmental Information Subgroup	221
1-8: Members of Storage and Disposal Subgroup	225
1-9: Members of Consumer Education Subgroup	229

2-1: Quantitative Research Screening Questionnaire  	235
2-2: Quantitative Research Telephone Questionnaires 	239
2-3: Quantitative Research Mock Labels	269
2-4: Quantitative Research Mail Questionnaires	277

3-1: Qualitative Research Telephone Recruitment Screening Questionnaires for Outdoor
Pesticides, Indoor Insecticides, and Household Cleaners 	301
3-2: Qualitative Research Discussion Guides for Outdoor Pesticides, Indoor Insecticides, and
Household Cleaners	319
3-3: Signal Meter Mock Label	337
3-4: Outdoor Pesticides Mock Label	341
3-5: Household Cleaners Mock Label	371
3-6: Indoor Insecticides Mock Label	401
3-7: Drafts of "Read the Label FIRST!" Campaign Logo	441
3-8: Open-ended Questions on Consumer Label Preference	449

5-1: Pesticide Labeling Under the Federal Insecticide, Fungicide and Rodenticide Act	455
5-2: First Aid Qualitative Research Participant Screener for 1-on-l Interviews on Household
Cleaners, Indoor Insecticides, and Outdoor Pesticides	467
5-3: First Aid Qualitative Research Discussion Guide, Consumer Comprehension of the
Proposed First Aid Statement Language	"	475

6-1: North American Hazardous Materials Management Association (NAHMMA) Storage and
Disposal Questionnaire for States	479

7-1: CLI Kick-off Meeting Notes, Crystal City, VA, March 20, 1997	483
7-2: Summary of Partner and Task Force Meeting, February 17, 18, 1998  	489
7-3: Highlights from CLI Partners and Task Force Meeting, Ramada Old Town,
Alexandria, VA, September 23 and 24, 1998 	527
7-4: Summary of the Partners and Task Force Meeting, April 7-8,1999,
Alexandria, VA 	539
8-1: List of Stakeholders Contributing Comments on CLI	551
                                  List of Appendices
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10-1: List of Commentors on the CLI Phase II Report Draft	555
viii
List of Appendices

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                            LIST OF TABLES

Table 2-1: Learning Objectives, Survey Questions, and Potential Action Steps	42
Table 2-2: How Satisfied Are You Overall With the Information
       Currently Available on Product Packaging? (%)  	49
Table 2-3: Preference Statements for Household Cleaner Labels	50
Table 2-4: Preference Statements for Indoor Insecticide Labels ...-	51
Table 2-5: Preference Statements for Outdoor Pesticide Labels	52
Table 2-6: Was All of the Information on the Label Where You Expected It To Be? (%)	54
Table 2-7: Ability to Identify Effects on Personal and Children's Health or Safety (%)  	55
Table 2-8: Ability to Identify Product Contents or Ingredients (%)  	56
Table 2-9: Frequency of Reading in Store (%)  	57
Table 2-10: What Information Found on the Packaging of Products Is Most Important to You?
        	;58
Table 2-11: Summary of Items Never Read (%)	.'59
Table 2-12: What Information Do You Want to Be Able to Find Most Easily?	60
Table 2-13: When Deciding Which Product to Purchase, Which of the Following Types of
       Information, If Any, Do You Look for?  	60
Table 2-14:.Which Way Would You Most Like to See The Information Shown? (%)	62
Table 2-15: Reasons Why Never Read Indoor Insecticides (%)	65
Table 2-16: Reasons Why Never Read Household Cleaner (%)	66
Table 2-17: Reasons Why Never Read Outdoor Insecticides (%)	67
Table 2-18: What Do You Think This Icon/Picture Means?(%)*	69
Table 2-19: Besides Packaging Where Else Do You Get Information
       About the Products You Use? (%)	74
Table 2-20: Why Do  You Look for Information about Ingredients?	76
Table 2-21: Statements Regarding Respondents' Attitude Toward Product Categories	80
Table 3-1: Number of Mini Focus Groups for Each City and Product Category  	90
Table 5-1: Proposed Guidance for Standard First Aid Statements  	120
                                    List of Tables
                                                                                 IX

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                            LIST OF CHARTS
Chart 2-1: How Satisfied Are You Overall With the Information Currently Available on Product
      Packaging?	49
Chart 2-2: Was All of the Information on the Label Where You Expected It to Be?	54
Chart 2-3: Ability to Identify Effects on Personal and Children's Health or Safety	55
Chart 2-4: Ability to Identify Product Contents or Ingredients	56
Chart 2-5: Frequency of Reading in Store	57
Chart 2-6: Summary of Items Never Read	59
Chart 2-7: Which Way Would You Most Like to See the Information Shown?	62
Chart 2-8: Which of the Two Product Packages Has The Type of Information You Prefer?
      (Household Cleaner)  	63
Chart 2-9: For Each Type of Information, Which Do You Prefer Regarding Product Contents or
      Ingredients? 	64
Chart 2-10: Reasons Why Never Read Indoor Insecticides	65
Chart 2-11: Reasons Why Never Read Household Cleaner 	66
Chart 2-12: Reasons Why Never Read Outdoor Insecticides 	67
Chart 2-13: What Do You Think This Icon/Picture Means? (Plastic Material Code)	69
Chart 2-14: What Level of Risk Do You Associate With a Product That Has the Following
      Words on Label? 	.. 71
Chart 2-15: What Level of Risk Do You Associate With a Product That Has the Following
      Words on Label? 	72
Chart 2-16: When Shopping Do You Look on Product Packaging for Possible
      Harmful Effects? 	72
Chart 2-17: Besides packaging Where Else Do You Get Information About the Products You
      Use?	74
Chart 2-18: When Shopping Do You Look for Information About the Ingredients?	76
Chart 2-19: If an Indoor Insecticide Label Were to Provide You With Additional Information
      About Ingredients, Which of the Following Would You Prefer?  	77
Chart 2-20: If a Household Cleaner Label Were to Provide You With Additional Information
      About Ingredients, Which of the Following Would You Prefer?  	77
Chart 2-21: If an Outdoor Pesticide Label Were to Provide You With Additional Information
      About Ingredients, Which of the Following Would You Prefer?	78
                                    List of Charts
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                        LIST OF ACRONYMS
APCC       American Poison Control Centers
ARC        American Red Cross
BOD        Biological Oxygen Demand
CESQG     Conditionally Exempt Small quantity Generator
CLI         Consumer Labeling Initiative
CPSC       Consumer Product Safety Commission
CSMA      Chemical Specialties Manufacturers Association
CTF        Communications Task Force
EPA        Environmental Protection Agency
FDA        Food and Drug Administration
FIFRA      Federal Insecticide, Fungicide, and Rodenticide Act
HHW       Household Hazardous Waste
HIPIC       Household and Institutional Products Information Council
LOEL       Lowest-Observed-Effect-Level
MRF        Material Recovery Facilities
MSWL      Municipal Solid Waste Landfill
NAHMMA  North American Hazardous Materials Management Association
NOEC       No-Observed-Effect-Concentration
NOEL       No-Observed-Effect-Level
OPP        Office of Pesticide Programs
OPPTS      Office of Prevention, Pesticides and Toxic Substances
PEC        Predicted Environmental Concentration
POTW      Publicly Owned Treatment Works
PPDC       Pesticide Program Dialogue Committee
PR         Pesticide Registration Notice
RCRA       Resource Conservation and Recovery Act
TSS        Total Suspended Solids
WWC       Waste Watch Center
                                 List of Acronyms
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                                 FOREWORD
The Consumer Labeling Initiative (CLI), a pilot program of the U.S. Environmental Protection
Agency, was initiated in March 1996. The initiation of the project was announced in a Federal
Register (FR) notice dated March 22, 1996 (61 FR 12011). The goal of the CLI is to foster
pollution prevention, empower consumer choice, and improve consumer understanding of safe
use, environmental, and health information on household consumer product labels.  The CLI is a
multi-phased pilot project focusing on indoor insecticides, outdoor pesticides, and household
hard surface cleaners (i.e., floor and basin, tub and tile), some of which are registered
antimicrobials/disinfectants. The CLI has involved a wide range of participants representing
many interests related to consumer labeling issues, including federal and state government
agencies, private industry, public interest groups, and individual citizens.

CLI participants have worked  voluntarily for more than three years, with the goal of finding
ways to help consumers:

       •      quickly locate essential safe and appropriate use,  environmental, and health
              information on product labels;

       •      use information on the labels to reasonably compare products intended for similar
              uses;

       •      purchase, use, store, and dispose of products safely and with minimal effect on the
              environment; and

       »      make informed choices among products based on their own needs and values.

Phase I of the CLI involved performing qualitative consumer research and summarizing existing
research and programs concerning the effectiveness and limitations of labeling as a policy tool to
protect public health. The Phase I Report (EPA-700-R-96-001, September 1996) published the
findings, recommendations, and action steps that resulted from Phase I research.
Recommendations made at the conclusion of Phase I included the suggestion for a second phase.

Phase II of the CLI began in October 1996. Phase II of the CLI followed directly from Phase I,
with the intention of providing more support for the Phase I research findings.  Its activities were
intended to include the following:

       B      perform in-depth quantitative research to establish a baseline of consumer
              understanding, attitudes, behavior, and satisfaction about product labels;

       •      carry out qualitative research on potential standardized information,  particularly
              for ingredients, precautionary statements, and signal words;

       •      develop a multi-faceted, broad-based education campaign to 1) help  consumers
              understand and use labels effectively, and 2) disseminate information about future
              labeling changes;
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              find simpler, clearer ways to word label information about what to do in an
              accident or emergency involving household products;

              perform research about storage and disposal information, with the goal of
              improving labels to address conflicting laws, ordinances, and community
              practices for waste recycling and disposal; and

              identify other information about ingredients that consumers want and need on
              labels for pesticides and other products.
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                        Outline of the Phase II Report

The Executive Summary, which appears before Chapter 1, highlights the types of research
performed in Phase II and describes important findings, implications, and conclusions of the
research, as well as the EPA recommendations developed through the project.

Chapter 1, Overview of Phase IIofCLI, describes the overall process, structure, activities,
findings, and recommendations of Phase II of the CLI.

During Phase II, CLI participants funded and directed quantitative and qualitative research to
assess consumers' comprehension, attitudes, behavior, and satisfaction with labeling; to evaluate
alternatives; and to recommend comprehensive, specific improvements to labels, as well as
regulatory or policy changes that would enable these improvements. Chapters 2, 3, and 4 discuss
hi detail the quantitative and qualitative research process., findings, and conclusions.

The quantitative segment of this research (Chapter 2) involved a detailed and comprehensive
national telephone and mail survey. Chapter 2 describes the goals, methodology, process, and
results of this quantitative research. The results are discussed in two categories: findings and
implications. Findings result directly from the quantitative survey results and are supported by
the data. Implications, however, are derived from the findings and are included to identify
connections between separate but related findings.

The qualitative research done in Phase I formed the basis of the quantitative research, which in
turn provided a necessary foundation for continuing qualitative research in Phase II. The CLI's
quantitative research team identified a number of areas in which a more in-depth interview
technique could be used to advantage, particularly exploring consumers' preferences regarding
possible language and format options for standardized product labels. Qualitative focus groups
were designed and run with 27 groups of consumers in different parts of the United States. This
research is described in Chapter 3.

The findings  and implications reported in Chapters 2 and 3 are very extensive and closely
connected conceptually. To help readers assimilate these research data and understand the
directions in which they point,  a separate chapter (Chapter 4) outlines the conclusions of both the
quantitative and qualitative research. Conclusions, as used in this report, are defined as broad
statements — arising from the research findings and implications — about product  labels and
consumers' comprehension, satisfaction, and preferences.

The next four chapters focus on other related work done during Phase II. Chapter 5 discusses
qualitative research that was performed to update and improve First Aid statements on consumer
product labels for indoor insecticides, outdoor pesticides, and household hard surface cleaners.
The research  involved in-depth one-on-one interviews with consumers to identify problematic
language and potential alternative wording.

The CLI is a collaboration among many different stakeholders, who explored many issues related
to product labeling for household insecticides, pesticides, and hard surface cleaners.  Chapter 6
describes the different subgroups that contributed to Phase II, the specific activities undertaken
by the subgroups, the process followed by each subgroup, and the findings that the subgroups
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generated. Specifically, this chapter describes the work of (a) the Standardized Environmental
Information Subgroup, (b) the Storage and Disposal Subgroup, and (c) the Consumer Education
Subgroup.

One of the most important elements of the CLI has been the coming together of some of its most
committed participants and stakeholders, including CLI Partners and the CLI Task Force. The
Task Force consists of federal, state, and other regulatory entities with expertise and interest on
labeling issues. The Partners are a larger group of voluntary participants who have expressed
interest in these labeling issues and have made a long-term commitment to participate actively in
the work of the CLI. Several large Partner and Task Force meetings were held during the course
of Phase II. Chapter 7 discusses the information that was presented at each of these meetings.

Throughout its history, the CLI has encouraged the input and participation of all interested
individuals and groups, regardless of their level of involvement. Stakeholders provided
particularly valuable input in identifying possible deficiencies in current labels and in suggesting
options for changes to EPA programs not directly related to product labels. Stakeholders have
included consumer product manufacturers, retailers, marketers, trade associations, environmental
labeling program practitioners, government (federal, state, and local) agencies (including non-
U.S. government agencies), academics, public interest groups, consumer groups, environmental
groups, health and safety professionals, standards-setting organizations, media groups, and
individual citizens. Chapter 8 describes both the outreach efforts made by the CLI to obtain
comments from all interested stakeholders, and the Stakeholder responses submitted in the
course of Phase II. Chapter 8 focuses specifically on the participation of stakeholders other than
Partners and Task Force members.

Finally, Chapter 9 lists the recommendations for action that came out of Phase II. The Partners
and Task Force members together drafted and approved recommendations regarding Signal
Words and Hazard Hierarchy, Ingredients, Label Formats, Consumer Education, and Storage and
Disposal. The CLI carefully considered all the Phase II research findings, implications, and
conclusions discussed in Chapters 2 through 4, as well as the supplementary research described
in Chapters 5 through 8, in coming up with its recommendations. The final list of
recommendations was submitted to EPA senior management for consideration, and during the
April 7-8th, 1999 Partner and Task Force meeting, EPA announced which recommendations
could be implemented immediately, and which still needed approval from EPA senior
management. (See Chapter 9 for details.)
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                           How to Use this Report

Individuals who are interested primarily in the outcomes of Phase II research should begin by
reading the Executive Summary, which outlines the goals of Phase II, briefly discusses the
process that was followed, and lists all the recommendations.

Readers with a strong interest in a particular topic may go directly to one or more specific
chapters. This report has been structured so that each chapter can be understood independently of
the others.

For readers who are interested in the Phase II research methodology and findings, many of the
Appendices to this report provide a great deal  of useful related information about the CLI and the
Phase II research. A complete list of appendices can be found in the Table of Contents. The
report and the appendices will be available in print from the National Technical Information
Service (NTIS)  or from the Administrative Record (AR-139). The report and the appendices will
also be available electronically through the Internet at the following site —
http://www.epa.gov/opptintr/labeling.

For further information about the Consumer Labeling Initiative, including access to all
previously published  documents and descriptions of future activities, readers are encouraged to
visit the CLI website  (http://www.epa.gov/opptintr/labeling).  Alternatively, interested parties
can obtain CLI information from the Administrative Record AR-139, located at the TSCA Non-
confidential Information Center, N.E. Mall Room B-607, EPA Headquarters, 401 M. Street,
Washington DC 20460.  All raw data from the CLI research, correspondence, comments, and
publications are in the Administrative Record. Consumer Labeling Initiative publications may
be ordered from the Pollution Prevention Information Clearinghouse by calling 202-260-1023 or
by sending an e-mail  to ppic@epa.gov.
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                       EXECUTIVE SUMMARY
The Consumer Labeling Initiative (CLI), a pilot program of the U.S. Environmental Protection
Agency, began in March 1996 with a Federal Register (FR) notice (61 FR 12011). A voluntary
initiative, the CLI was established with the goal to foster pollution prevention, empower
consumer choice, and improve consumer understanding of safe use, environmental, and health
information on household consumer product labels.  The CLI is a multi-phased pilot project
focusing on indoor insecticides, outdoor pesticides, and household hard surface cleaners (i.e.,
floor and basin, tub and tile), some of which are registered antimicrobials/disinfectants.

The CLI was undertaken in two parts. Phase I began in early 1996 and ended on September 30,
1996. The Phase I Report (EPA, September 1996) published the findings, recommendations,
and action steps. Phase II, which began in October 1996, resulted from this first phase of
research.  Phase II addressed issues that Phase I did not complete or include, and focused on the
following objectives:

       •      performing in-depth quantitative consumer research to establish a baseline of
             understanding about consumer attitudes, behavior, and satisfaction concerning
             these types of product labels;

       •      carrying out qualitative research about potential standardized labeling
             information, particularly for ingredients, precautionary statements, and.signal
             words;

       •      developing a multi-faceted, broad-based education campaign to help consumers
             understand and use labels effectively, and to disseminate information about future
             labeling changes;

       •      finding simpler, clearer ways to word label information about what to do in an
             accident or emergency involving household products;

       •      performing further research about storage arid disposal information, with the goal
             of improving labels to address conflicting laws, ordinances, and community
             practices for recycling and disposal of waste; and

       •      identifying what other information about ingredients consumers want and need on
             labels for pesticides and other products.
                                  Executive Summary

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                              The Phase II Process

The CLI is a voluntary initiative that depends upon extensive stakeholder participation. EPA
staff have worked with stakeholders on all aspects on the CLI, and oversaw the research and
preparation of the reports. EPA made certain decisions and recommendations about policy
questions and issues that arose during the project, but only after requesting input from Task
Force members, EPA Partners, and other stakeholder groups. Dissenting opinions have always
been invited, and a wide diversity of opinions is reflected in the findings. All stakeholders with
an interest hi labeling issues concerning consumer products have been strongly encouraged to
participate.

CLI Stakeholders were organized into several types of groups, including the CLI Task Force,
Partners, and specific task subgroups. The CLI also invited the participation of other interested
stakeholders throughout the Initiative. Notices in CLI "Updates" (brief documents published at
several times during Phase II and distributed widely), website postings, and mailings invited
individuals to contact key EPA staffers, join subgroups, attend meetings, and provide feedback.

The CLI Task Force was created by EPA to provide direction for the Initiative. The Task Force
consists of federal, state, and other regulatory entities that have expertise and/or interest in
labeling issues. The Task Force helped to determine the overall direction of the project, provided
input on the development of the research plan, shared labeling-related experience and
knowledge, coordinated with EPA to avoid regulatory duplication or interference, and
participated in the design and execution of the CLI research.

After the Task Force was set in motion, EPA invited all interested entities and individuals to
become "CLI Partners" and participate regularly and on a long-term basis in the CLI. In Phase
II, the Partners, along with EPA and the Task Force, worked on the design, testing, and execution
of the quantitative and qualitative research; provided information and data for the literature
review; funded and directed quantitative research; reviewed components of this report; donated
their considerable experience and effort to the research process; and provided input on specific
policy-related issues being debated. The active CLI Partners included a number of businesses
and trade associations related to manufacturing and distributing these products.  They helped to
disseminate information on the CLI to their members, and to assemble and organize comments
and ideas from their membership for presentation to EPA.

Subgroups of CLI Partner and Task Force Members concentrated on each of the following areas
during Phase II:

       •     consumer research about knowledge, attitudes, and behaviors related to labeling
             information. Consumer research was pursued separately by both a Quantitative
             Research Subgroup and a Qualitative Research Subgroup, each composed of
             experts in the techniques relevant to that type of research;

       •     standardized environmental information;

       •     storage and disposal information on products;
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       •      identification of ingredients on product labels;

       •      First Aid statements on product labels;

       •      consumer education related to label awareness and use; and

       •      outreach to CLI stakeholders.

CLI Partner and Task Force members, as a whole, met in person several times during Phase II.
During these meetings, subgroups presented their findings to the CLI Partner and Task Force
members and other interested Stakeholders. Future direction of the CLI was also discussed and
planned.

Throughout the CLI, the EPA actively encouraged the participation of all interested Stakeholders
through outreach methods, including public announcements, publication of memos and other
documents, posting of all relevant information about Phase II to the CLI website, and public
meetings.  The CLI offered Stakeholders a wide variety of opportunities for ongoing comments
and feedback to EPA.
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                               Phase II Research

A crucial part of Phase II was the funding, development, and implementation of a detailed
quantitative telephone and mail survey to assess consumers' comprehension, attitudes, behavior,
and satisfaction with labeling, and to evaluate alternatives. CLI Partners funded and directed the
quantitative research, with input from all CLI participants. An independent market research and
polling firm conducted the survey. The study included consumers from many demographic
segments of the U.S. population, including low-income, low-education, and minority
representation.  The survey included questions about locating label information, how well
consumers understand the information, when and where they consult the labels, the relative
importance of different kinds of label information, and which information they wish to be able to
find most quickly and easily.

The quantitative survey was designed to address six learning objectives that were identified as a
result of the CLI Phase I research. The learning objectives aimed to determine the following:

       •      determine the current situation relative to consumers' satisfaction with the format
              and content of existing labels;

       •      determine consumers' hierarchy of importance of basic label information;

       •      determine where on the label consumers expect to find particular information,
              such as First Aid and ingredients;

       •      determine consumers' current comprehension of label language;

       •      determine whether or not a preference exists for non-FIFRA over FIFRA labels
              (for household cleaner category only); and

       •      determine consumers' reaction to standardized safe use, environmental, health and
              safety information.

These learning objectives were intended to focus the Phase II research on specific issues related
to improving labels. Each  objective was intended to generate research findings that would
enable the EPA and CLI Stakeholders to take immediate and near-term steps to improve labels.
Some changes, such as revised guidance and regulations, are almost entirely under the purview
of EPA. Others, such as consumer education, involve many Stakeholders and require a longer
time frame. Most important was the willingness of industry Partners owning significant market
share of products in the three categories to make label changes based on this process.

These learning objectives and the results of the quantitative research were expected to lead to
certain actionable steps that the EPA and its CLI Partners could implement, such as these:

       •      quantify key learnings from the  qualitative research in Phase I of CLI;

       •      collect data that will serve as input into additional qualitative and quantitative
              research, such as  consumer evaluation of potential new label formats;
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       •      benchmark current consumer practices and preferences, so that changes in
              behavior/preference (based on label changes and on consumer education
              activities) can be assessed;

       •      provide information that will allow the EPA and its Partners to consider policy
              implications and to take some immediate action steps;

       •      guide the Consumer Education Subgroups's efforts;

       •      guide the Storage and Disposal Subgroup in making recommendations; and

       •      provide information for potential changes to label language and formats.

In addition to the quantitative research, qualitative research in the form of small ("mini") focus
groups was conducted with consumers in three U.S. cities during the Summer of 1998.  These
groups were intended to elicit in-depth, qualitative information on a number of topics related to
the quantitative research surveys. The qualitative research was funded by EPA.

The key learning objectives for the qualitative research, were to determine the following:

       •      Consumer preference for a specific format for the presentation of standardized
              information.

       •      Consumer  understanding of the  same information  presented in different formats.

       •      Consumer preference for which information should be presented in box(es) or
              other standardized formats of information groups together.

       •      Consumer preference for where particular groupings of information should be
              located on the product label.

       •      Consumer understanding of the existence of a hazard hierarchy in the signal
              words CAUTION, WARNING, DANGER, when conveyed graphically,  and of
              the point in the hierarchy on which a given product falls.

       •      Consumer preference for a particular graphical representation of the CAUTION,
              WARNING, DANGER hierarchy and product status information.

       •      Consumer understanding of the association between the product ingredients, the
             hazard(s), and the relative hierarchy.
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      Conclusions of Quantitative and Qualitative Research

The CLI Partners and Task Force developed findings and implications from the quantitative and
qualitative research. These findings and implications yielded a number of conclusions, which
follow:

1.    There is no strong motivator that suggests fundamental label changes, but language and
      format can be improved.  Consumers are generally satisfied with current labels and are
      able to find the information they want on the label. However, the data indicate that
      improvements would encourage more reading and use of product labels.

2.    Labels for each of the product categories should not be treated in the same way since
      consumers perceive the products differently and have different label reading habits for
      each category, as follows —

       *     Household cleaner labels should be simpler, with exceptional information (i.e.,
             very important or different than anticipated) highlighted.  There is a lower
             motivation to carefully read these labels because of the perceived familiarity with
             cleaning products.

       *•     Indoor insecticide labels are quite effective now. Incremental changes to simplify
             labels and make them easier to understand should be tested.

       *•     Outdoor pesticide labels are confusing because they are more complex and less
             frequently used, and therefore less  familiar to consumers. They should be
             simplified and arranged for easier reading.

3.    Consumers want  clear, concise, easy-to-read information that connects consequences with
      actions.  Instructions on labels should say  'why' and jargon should be avoided.

4.    Consumers look to all traditional media to gain information. Therefore, outreach to
      consumers should incorporate traditional media, and should also include education efforts
      directed toward store personnel and other "influencers."

5.    Ingredient information can be communicated by name, type or category of ingredient, and
      purpose of ingredient, not just by a list of chemical names.  Ingredients should be
      presented in tabular form, with flexibility as to where in the label they are located (e.g.,
      front vs. back panel of the label).

6.    Additional information is needed to better understand how to answer the need some
       consumers expressed for  useful ingredient information.  A full disclosure list of names
       does not further consumer understanding.

These conclusions are supported by detailed research findings.
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                        Phase II Recommendations

Out of the Conclusions of the research, the CLI developed suggested Recommendations. These
Recommendations were developed by the CLI Partner and Task Force Members in September
1998, and subsequently were presented to the EPA. The complete list of suggested
Recommendations stemming from the September 1998 Partners and Task Force meeting follows.

Signal Words and  Hazard Hierarchy Recommendations

Product Label Changes

1.     For products that fall into toxicity categories 1,2, or 3, recommend that manufacturers be
      encouraged to voluntarily put one or more bullet points underneath the signal word on the
      front label, explaining the precautions associated with the product. The statement which
      currently refers people to turn to the back of the package for more explanation of the
      precautions should remain on the front of the label.

Further Research

1.     Recommend that additional research be conducted on the effects of "highlighting" and
      graphical depictions of the signal words on the front of the label before any such changes
      are implemented.  ("Highlighting" means things such as bolding the word, boxing the
      word, using colors to make the word stand out, making the word bigger, etc.; graphical
      depictions could include bar graphs, thermometers, "laugh meters," or similar designs
      incorporating all three words into a hierarchical visual format.) Also explore as a part of
      this research "information fragmentation" (i.e., placing precautionary-related information
      on both the front and back label panels) issues. Note on intent: the need for this research
      is not intended to preclude the change recommended pertaining to placing the precaution
      bullet on the front panel with the signal word.

Policy Choices

1.     For toxicity category 4 products only, the EPA should consider not having a signal word.
      (Currently, both category 3 and category 4 products can have the signal word "Caution"
      associated with them.)

2.     The EPA should determine what the consumer should understand about signal words and
      the hazard hierarchy. If the intent is for the signal words to flag for the consumer that
      care should be taken, then the recommendations here are enough along with appropriate
      educational efforts (see education recommendations). If the intent is for the hazard
      hierarchy to be understood, then additional research and education are necessary.

Consumer Education

1.     Recommend that an effort be made to educate consumers about the meaning of the signal
      words, and how they are defined and used on labels. This should be done in a factual
      context, and without judgement calls which conclude the meaning for the consumer (i.e.,
      the Agency should not recommend that consumers always buy products marked
      CAUTION in preference to products marked DANGER).
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Ingredients Recommendations

Product Label Changes

1.     Recommend that the EPA not make any across-the-board label changes for ingredients at
       the present time.

2.     Recommend that the EPA allow manufacturers the flexibility to voluntarily provide
       "other ingredient" information on the label in a way that consumers in the study
       expressed they wanted (i.e., listed by category, perhaps with some explanation of
       purpose).

3.     Recommend that the EPA allow manufacturers more flexibility in where they provide
       ingredient information (e.g., back panel versus front panel).

Further Research

1.     Recommend that the EPA conduct further research to identify how to supply consumers'
       expressed need for medical information to people who want it. It was noted that
       information learned from the quantitative research of Phase II should be incorporated in
       any further research.

Policy Choices

1.     Recommend that the EPA further examine how to provide ingredient information on the
       label in the way consumers expressed they want it, as indicated by the research (i.e., give
       them categories of ingredients along with the purpose.) Also, refer to research
       recommendations in the format section.

Consumer Education

I.     Educate consumers about ingredient information on labels (i.e., why they appear on the
       label and the meaning of "active" and "other"), through the "Read the Label FIRSTr
       campaign. Additionally, it was suggested that the education campaign be utilized to
       inform the public about where to get health and safety information, e.g., for people prone
       to allergies, etc.

Label Format Recommendations

Product Label Changes

1.     Recommend that statements that were clearly preferred by consumers in the quantitative
       research be used, as appropriate, and that the EPA make program changes to allow this to
       happen to the extent possible.

Directions for Use

2.     Recommend that the EPA consider replacing the statement, "It is a violation of Federal
       law to use this product in a manner inconsistent with its labeling," with the simpler
       phrase tested on the quantitative survey — "Use only as directed on this label."
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 3.      Recommend that manufacturers voluntarily put direction for use in bulleted form with no
        wrapping text (i.e., making sure that each new direction for use is set off on a separate
        line, and does not continue on the same line), using ordinal numbers if sequence is
        important.

 Precautionary Statements
 4.
 5.
       Recommend that manufacturers voluntarily put the principal health hazard information
       from the precautionary statements in bulleted form underneath signal words.

       Recommend that manufacturers and the EPA, where possible, use simple language,
       avoiding jargon; avoid wrapped text; keep sections together in same column; use more
       white space; and eliminate needless words. This recommendation was particularly
       expressed with regard to precautionary statements.
6.
       Recommend that the EPA remove language that is not appropriate to consumers from
       precautionary statements, e.g., language more appropriate for agricultural pesticides, etc.

Precautionary Statements — First Aid Specific
7.
8.
       Recommend that manufacturers voluntarily put First Aid information in a table format
       and within a box.

       Recommend that manufacturers who provide a toll-free number for emergencies
       voluntarily include that number beneath or within any table/box that includes First Aid
       information.
Further Research
1.
2.
       Recommend that further research be structured to investigate location and presentation of
       ingredient information (e.g., placing ingredient information on the front or back of the
       label, tabular formats, etc.), before any across-the-board changes are made to ingredients
       information. This recommendation addresses the variation in need which can arise
       between product categories, e.g., indoor and outdoor versus cleaner product labels.

       Recommend that further research be conducted to investigate how the information
       hierarchy (i.e., information that consumers in the quantitative research said was most
       important to them) translates into the order in which information appears on labels.

Policy Choices

1.      Given the efforts in other non-CLI forums to standardize the use of icons, further work on
       this topic should not be pursued as a part of the CLI.

Consumer Education

1.      Recommend that the "Read the Label FIRST!" campaign educate consumers that it is
       acceptable for them to open and read label booklets (particularly for outdoor pesticide
       products) in the store.
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Consumer Education and "Read the Label FIRST!"
Recommendations

It was noted that the Consumer Education Subgroup will address any recommendations from
other topic areas related to Consumer Education.

1.      Educate consumers on what specific parts of the label mean or are intended to
       communicate; specifically, signal words, active and other ingredients, storage and
       disposal, and precautionary statements including First Aid.

2.      As the CLI project continues, expand membership of the Consumer Education Subgroup
       to include brand managers, marketing staff, and  label designers from within the Partner
       companies, particularly with respect to designing and assessing the impact of the logo for
       the "Read the Label FIRST!" campaign.

3.      Recommend that messages conveyed through the consumer education campaign be
       market-tested in appropriate ways before they are launched.

4.      Recommend that retailers be brought into the Consumer Education Subgroup, as they will
       be important for distributing the messages developed by the group.

Storage  and Disposal Recommendations

Phase II Follow Up

1.     Recommend that the EPA send information from the quantitative study about recycling
       symbols (those with chasing arrows) to relevant organizations.

2.     Recommend the EPA gather any available information on risk assessments regarding
       product disposal from states, manufacturers, and other appropriate organizations and
       share this information with all  applicable parties, in an effort to coordinate these types of
       studies.

3.     Recommend that the quantitative data on disposal practices be sent to the North
       American Hazardous Materials Management Association (NAHMMA) and that
       NAHMMA be encouraged to share this information with  its members.

Product Label Changes

1.     Recommend that for empty containers, the statement on product labels read, "Place in
       trash. Recycle where available." The recycling statement would be optional for
       manufacturers. Also optional, manufacturers may use the statement that reads: "Do not
       re-use container."

2.     Recommend that, given that there was no agreement on label statements for partially
       filled containers, there be a delay in any Pesticide Registration (PR) notice regarding the
       disposal statement on empty containers until the EPA makes a policy decision about how
       to handle partially filled containers.
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3.      Recommend to keep the status quo for storage statements on product labels.
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               EPA Actions on CLI Recommendations

During the April 7-8,1999, Partner and Task Force meeting, the EPA discussed how it intended
to address the recommendations made during the September 1998 Partner and Task Force
meeting.  The EPA's Office of Pesticide Programs (OPP) is handling the recommendations for
label changes, and it presented a draft strategy for dealing with those recommendations at the
April 1999 meeting.  Also at the meeting, planning was initiated for a CLI media event in Spring
2000, to announce the CLI recommendations; and updates on both the completion of the Phase II
Report and the Consumer Education Campaign activities were presented.

Draft OPP Strategy  for Implementation of the Phase II Label Changes

OPP's draft strategy for implementing some of the CLI recommendations, presented in the April
1999 Partner and Task Force meeting, includes the following:

1.     OPP will circulate an internal guidance memorandum to forewarn EPA product managers
       about the type of paperwork to expect coming from companies making label changes
       recommended by the CLI. The memo would cover label changes that can be approved
       now, changes that would be considered on a case-by-case basis, and changes that would
       not be considered at present. These draft changes are listed below.

2.     Revised First Aid statements have been agreed upon and a draft Pesticide Registration
       (PR) notice announcing these new statements is currently being reviewed by EPA staff.
       The PR notice is expected to be issued in Fall/Winter 1999.

3.     PR notices for all recommendation topics will be issued after the guidance memo. Some
       PR notices may be issued as "final" notices without a time period allotted for public
       comment, while others will be issued "for comment."

4.     Label changes will  apply to all FIFRA regulated pesticide products, not just consumer
       pesticides and household cleaners.

5.     Sometime in the future, the PR notices will be incorporated into EPA regulation, where
       necessary.

Label Changes That Can be Submitted Now

While manufacturers must abide by current regulations, they can submit the following label
changes to the OPP (see Appendices 3-3 to 3-6 for examples of some of these label changes):

       •     adding hazard bullet points under signal words;

       »     removing inappropriate language on consumer labels;

       •     providing information on "other ingredients" in a variety of ways; and

       •     presenting first aid information in simplified formats, including a toll-free
             number, and using the new revised First Aid statements.
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Changes to the overall label format and presentation that can currently be made include:

       •     use of preferred statements;

       •     use of simpler language and less jargon;

       •     use of revised hazard and use statements;

       •     use of bullet formats;

       •     avoidance of narrative text formats (e.g., using bullets and headings);

       •     keeping sections together in the same column;

       •     using white space;

       •     eliminating needless words, while still abiding by current regulations;

       •     adding numbers for sequential actions;

       •     use of tables;

       •     adding sub-heading into the Directions for Use section; and

       •     rearranging precautionary statements to give prominence to those of greater
             interest.

Label Changes That Need to be Discussed with EPA Product Managers Before
Submitting

       •     changing the location of the ingredients statement.

Label Changes That Cannot be Submitted at Present Time

       •     changing, combining, or deleting headings;

       •     locating storage and disposal instructions outside of the Directions for Use
             section;

       •     revising the Federal misuse statement; and

       •     leaving off the signal word for products in toxicity category 4.

CLI Media Event

During the April 1999 Partner and Task Force meeting, the EPA informed CLI Stakeholders
about plans for an upcoming media event, to announce some of the labeling recommendations
that EPA will be making as a result of the CLI. Plans for the media event were postponed until
Spring 2000, however, to coincide with the 'kick-off of the CLI Consumer Education
Campaign; the media event will serve as the 'kick-off event for the "Read the label FIRST!"
Campaign. This launch is timed to coincide the appearance of newly redesigned labels on store
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shelves with consumers' general interest in seasonal gardening and cleaning activities.
Eventually, the Consumer Education Subgroup intends to finalize and make available to the
public a variety of educational materials (e.g., brochures, pamphlets, etc.).

1.    The goals of the media event are to announce to the public CLI's accomplishments,
      inform the public that labels are changing to become simpler, promote the "Read the
      Label FIRST!" campaign, promote the CLI partnership between EPA and its
      Stakeholders, and increase consumer awareness in general regarding product labels.

2.    The media event is scheduled for Spring 2000. It was proposed at the April 1999 meeting
      that because the event serves as a way in which to reach the general public, a well-known
      public figure may be appropriate to convey the messages of the event, in addition to the
      EPA and CLI Partners.

3.    The target audience for the media event is the general public, the trade press, community
      newspapers, and lifestyle magazines.

4.    Messages for the event will be drafted by EPA and circulated to CLI Partners and other
      Stakeholders prior to the event.

Completion of the Phase II Report

An update on the Phase II Report and details for its completion were presented to CLI Partner
and Task Force members during the April 1999 meeting.  Partners and Task Force members were
informed that all of EPA's recommendations on label changes, as a result of CLI, will be
included in the Report. Partner and Task Force members agreed that displaying the Phase II
findings on the Internet before the completion of the Report would be counterproductive and,
therefore, resources should be spent on completion of the Report.

Consumer Education Campaign

An update of the activities since the September 1998 Partner and Task Force meeting regarding
the Consumer Education Campaign was presented during the April 1999 meeting.

1.     Upon recommendation from the September Partner and Task Force meeting, the
       Consumer Education Subgroup had been expanded to include marketing, brand, outreach,
       and public relations experts.

2.     A message development group was formed to develop the messages for the "Read the
       Label FIRST!" campaign, for use  in  both outreach fliers and/or brochures.

3.     A message placement group was also formed to identify and implement the most
       appropriate avenues for distributing  the messages and products for the Consumer
       Education Campaign in order to promote the "Read the Label FIRST!" campaign.

4.     Ideas for generating a unique logo for the "Read the Label FIRST!" campaign were
       shared during the April 1999 Partner and Task Force meeting. Logo design concepts
       included the idea of a design competition or contracting with a graphic designer to
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produce the logo. The goal would be to have a logo in place that companies and other
CLI participants could use on products, in advertising, and on education materials in time
for the Spring 2000 promotion period.
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                            Next Steps for the CLI

The launch of the "Read the Label FIRST!" consumer education campaign by EPA and the CLI
Partner and Task Force members is targeted for Spring 2000. The campaign will include media
messages about the entire CLI project. EPA's Office of Pesticide Programs will be
implementing its strategy for adopting and announcing label changes beginning in the Summer of
1999 and continuing through 2000. Policy issues that were identified by the CLI and that remain
to be resolved — for example, the appropriate disposal language to be used on partially filled
containers — will be addressed separately by the Office of Pesticide Programs. Final changes to
First Aid statements are expected to be announced in a Pesticide Registration (PR)  notice in
Fall/Winter 1999.  The CLI will continue to accept public comment on the project and its effects,
and the Agency will consider implementing future research to assess the effectiveness of both the
recommended changes in labels and the "Read the Label FIRST!" campaign.
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                                   CHAPTER 1


            OVERVIEW OF  PHASE II OF THE CLI


This chapter describes the goals, structure, processes, and activities of Phase II of the Consumer
Labeling Initiative (CLI). Phase I of the CLI included qualitative research to investigate
consumer comprehension and satisfaction with product labels for indoor insecticides, outdoor
pesticides, and household cleaners'. Phase II, begun in October 1996, involved a more in-depth
investigation of label information and consumer satisfaction, comprehension and preference for
these product labels.

During Phase I, recommendations were made regarding the following topics:

       •     label changes that could be implemented immediately. Announced in September
             1997, these included using the headings First Aid and "other ingredients";

       •     further improvement to labels that could be made, but that would require
             additional quantitative research to investigate how to make these improvements;

       •     gaining an understanding of consumers' comprehension of and preference for
             current labels on household cleaning products, indoor insecticides, and outdoor
             pesticides;

       •     addressing consumer needs for better information about specific issues, such as
             ingredient and storage and disposal information; and

       •     creating a consumer education campaign to inform consumers about the
             importance of reading product labels carefully.
      1 For a complete list of all the product types that are covered under the CLI, please refer to Appendix 1-1.

                       Chapter 1: Overview of Phase II of the CLI                      17

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                               Focus of Phase II

The Environmental Protection Agency's (EPA) commitment to Phase II of the CLI was
announced in a September 1997 press briefing by EPA Assistant Administrator, Lynn Goldman.
Phase II focused on the following issues:

       •      rinding simpler, clearer ways to word advice concerning an accident or emergency
              involving household products;

       "      initiating a multi-faceted, broad-based education campaign to help consumers
              understand and use labels effectively, and to disseminate information about future
              labeling changes;

       •      investigating further issues regarding storage and disposal information, with the
              goal of resolving conflicts among product labels and laws, ordinances, and
              community practices for recycling and disposal of waste;

       •      conducting in-depth research to determine baseline consumer understanding,
              attitudes, behavior, and satisfaction about thess types of product labels; and

       •      conducting research to determine what ingredient information consumers want
              and need on labels for pesticides and other household products.
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                      CLI Participants and Their Roles

 The CLI is a voluntary initiative that depends upon extensive Stakeholder participation. The
 many Stakeholder groups involved in the CLI have included: consumer product manufacturers;
 retailers; marketers; trade associations; environmental labeling program practitioners;
 government (federal, state, and local) agencies, including non-U.S. government agencies; EPA
 Partners; academics; public interest groups; consumer groups; environmental groups; health and
 safety professionals; standard-setting organizations; media groups; interested companies; and
 individual citizens.

 All Stakeholders with an interest in labeling issues concerning consumer products have been
 encouraged to participate. Stakeholders have been actively involved in project planning,
 implementation, review, and comment. Stakeholders have provided particularly valuable input
 in identifying possible deficiencies in current labels and in suggesting options for changes to
 EPA programs not directly related to product labels. Individual consumers also participated in
 qualitative and quantitative aspects of the research.

 Role of the EPA

 The EPA staff directed the project and  worked with Stakeholders on all aspects of the CLI,
 oversaw the qualitative research, and prepared the Phase I and Phase II reports.  After
 considering the input from Task Force members and CLI Partners, the EPA made  certain
 decisions and recommendations about some policy questions and issues that arose during the
 project.  Dissenting opinions were always invited, and a wide diversity of viewpoints is reflected
 in the findings.

 Role of the CLI Task Force Members

 The CLI Task Force was created by the EPA to provide direction for the initiative. The Task
 Force consisted of federal, state, and other regulatory entities that have expertise and/or interest
 in labeling issues. The Task Force helped to determine the overall direction of the project,
 provided input on the development of the research plan, shared labeling-related experience and
 knowledge, and participated in the design and execution of the CLI research. Appendix 1-2
 includes the complete list of Task Force members.

 Role of EPA Partners

 After the Task Force was set in motion, the EPA invited all interested entities and individuals to
 become "CLI Partners" and participate regularly and on a long-term basis in the CLI.  In Phase II,
the  Partners worked on, and were crucial to, the design, testing, and execution of qualitative and
quantitative research; funded quantitative research; provided information sources for the
literature review; reviewed sections of this report; and donated their considerable experience and
expertise to the research process. The active CLI Partners Included a number of businesses
holding significant market shares of these product categories, and trade associations related to
manufacturing and distributing indoor insecticide, outdoor pesticide, and household cleaner
                         Chapter 1: Overview of Phase II of the CLI
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products. Partners also helped to disseminate information on the CLI to their members and
colleagues. They also assembled and organized comments and ideas from their membership for
presentation to the EPA. Appendix 1-3 lists the CLI partners.

Stakeholder Outreach

Success of the CLI required the involvement of many project Stakeholders. Over the course of
both phases of the CLI, hundreds of individuals and organizations expressed interest in the
initiative.  These Stakeholders included consumer advocacy groups, environmental groups,
consumers, health and safety professionals and organizations, international groups, government
agencies, manufacturers of consumer household products, and retailers (for a listing of CLI
Stakeholders, please refer to Appendix 1-4).  The CLI Partners attempted to identify the
particular interests of individual Stakeholders and the most effective ways to communicate with
and learn from them. Communication methods that were utilized to identify and communicate
with Stakeholders included the following:

       •     press conferences and public announcements for all important milestones in the
             CLI, such as the Phase I and Phase II recommendations;

       •     public meetings, announced and publicized several months in advance, at which
             Stakeholder feedback was actively sought;

       •     news releases;

       •     publication and dissemination of CLI informational memos to EPA staff, Partners,
             Task Force Members, subgroup members, and other participants;

       »     publication and dissemination of consumer-oriented CLI "Updates" to all parties
             that had expressed interest;

       "     posting of all published materials on the CLI website, in a form that could be
             downloaded or printed online;

       •     publication of the names, telephone numbers, and e-mail addresses of CLI project
             leaders at the EPA;

       •     active encouragement of participation by new Stakeholders;

       •     identification of important points for feedback on the CLI process and content;

       •     solicitation of written comments on public notices printed in the Federal Register;
             and

       •      informational meetings of Stakeholders with the EPA management and staff.
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Other Participants in the CLI

Other businesses that participated in the CLI included:

       •     Abt Associates Inc., which, under contract to EPA, in Phase I reviewed the
             literature and Stakeholder comments and wrote the Phase I report; and hi Phase II
             coordinated work of many participants, as well as performed research, helped to
             develop questions for the quantitative research, and wrote the Phase II report;

       •     Macro International, which, under contract to EPA, conducted the qualitative
             research in Phase I, and the First Aid one-on-one interviews in Phase II;

       •     The Newman Group, Ltd., which, under contract to EPA, performed the
             qualitative survey research in Phase II; and

       •     National Family Opinion Research (NFO), which, under contract to one or more
             CLI Partners, performed the quantitative survey research in Phase II.
                        Chapter 1: Overview of Phase II of the CLI
21

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                           The Process of Phase II

At the close of Phase I, it was decided that in-depth quantitative research was needed to further
investigate consumer understanding, preference, and satisfaction with current product labels.
Additional information was needed on specific topics such as First Aid, ingredient information,
precautionary statements, direction for use, storage and disposal instructions, consumer
education, and standardized environmental information on product labels. Smaller subgroups of
Partner and Task Force members were established to develop the quantitative research and to
address these specific topics.

Throughout the course of Phase II, subgroups worked both separately and together.  Information
from quantitative and qualitative research was incorporated into decisions made by different
subgroups. Similarly, knowledge provided by various subgroup members was taken into
consideration when developing the quantitative and qualitative research; although, hi one case,
an omission led to inconclusive data. For example, the Storage and Disposal Subgroup shared
information with the Consumer Education Subgroup in preparation for the Consumer Education
Campaign. Another example of this interaction is that the quantitative mail survey questionnaire
included questions about consumers' storage and disposal practices.

The  History of Phase II

Phase II of the CLI began in October 1996. Between then and February 1997, Stakeholders
involved in CLI engaged in planning and preparation activities.  The group formally adopted and
initiated a joint strategy for Phase II during the March 1997 CLI "kick-off Partner and Task
Force meeting. At this  meeting the proposal for the Phase II quantitative research was presented
and Partner and Task Force members gave their support for the research plan and development.
It was announced at this meeting that EPA would be unable to fund any quantitative research,
given the magnitude of the project. Company and trade association partners felt very strongly
that such research would be vital for producing sound recommendations for label improvement,
and they voluntarily undertook to jointly fund and direct a quantitative research program that
would involve all of the CLI project participants.  Interim label improvements arising from the
Phase I research were also announced at this meeting, as were policy initiatives such as
standardizing label information. Finally, preliminary ideas for a consumer education campaign
were discussed at this meeting.

In April 1997, the EPA met with environmental and public interest groups, and other interested
parties, to bring them up to date on the CLI project and to introduce to them the quantitative
research plan, interim label changes, policy initiatives, and consumer education project.
Environmental and public interest groups were invited to actively participate in all aspects of the
development of Phase II.

After initiation of Phase II, a media event was held in September 1997. The Assistant
Administrator  of EPA's Office of Prevention, Pesticides and Toxic Substances (OPPTS), Lynn
Goldman, announced the immediate label changes that resulted from Phase I of CLI.  These
included: inclusion of a toll-free number on labels so that consumers could call someone  in case
of emergencies, use of common names for ingredients instead of chemical names, encouraging
companies to use "other ingredients" instead of "inert ingredients," simple first aid instructions,
22
Chapter 1: Overview of Phase II of the CLI

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and changing the heading for these to read "First Aid." It was also announced that in Phase II a
fuller investigation of the ingredients issues (i.e., right-to-know issues), and storage and disposal
issues would take place. Finally, the initiation of the quantitative research and the development
of the consumer education efforts were announced at this media event.

In February 1998, the entire CLI Partner and Task Force met in Alexandria, VA. At that
meeting, the various subgroups gave status updates of the work they had done up to that point.
Development of the quantitative consumer research was well under way and the research Core
Group updated the rest of the Partner and Task Force members on the research methodology,
questionnaire development, and research implementation. The EPA's Deputy Assistant
Administrator for the Office of Prevention, Pesticides and Toxic Substances, Susan Way land,
asked Partner and Task Force members to begin investigating the feasibility of including
standardized environmental information on product labels of household cleaners, indoor
insecticides, and outdoor pesticides.

Implementation of the (national) quantitative survey began in April 1998 with screening for
participants and ended in June 1998. Results from the quantitative research were tabulated in
several volumes of raw data.  Relevant data were shared with the various subgroups (e.g.,
information about consumers' sources of information was shared with the Consumer Education
Subgroup), to gain feedback and interpretation of the data from the subgroup. The data were
analyzed by the research Core Group. This group met several times via conference calls and
face-to-face meetings throughout the months of July and August to interpret and analyze the data
in order to develop findings and implications.

During June 1998, while the quantitative research was coming to a close, a small subset of the
Research Core Group was formed to address the Phase I charge of investigating standardized
environmental information on product labels. It was decided that qualitative consumer research
would be the best way to find out what types of environmental information consumers want to
see on labels. At this point, results from the quantitative research were beginning to materialize,
and they showed that, by and large, consumers did not consider environmental information to be
one of the more important parts of product labels.  Instead, they indicated that standardized label
formats would be useful for increasing consumer comprehension of label information. The Core
Group's focus, therefore, shifted: the qualitative research, used to enhance the findings from the
quantitative research, would also be used to investigate consumer preference for standardized
label formats.

Qualitative research took place during July and August 1998. Results from the research were
incorporated into the overall conclusions from Phase II. The findings, implications, and
conclusions of both the quantitative and qualitative research were presented to the entire CLI
Partner and Task Force on the first day of the Partner and Task Force meeting in Washington,
DC, in September 1998. Subgroups also presented the work they had done since the February
meeting. During the second day of the meeting, CLI Partner and Task Force members made
recommendations to the EPA for potential next steps (beyond Phase II) for CLI.

In April 1999, the EPA held another Partner and Task Force meeting  in Alexandria, VA, to
update CLI participants on steps that had been taken since, and in response to, the
recommendations made at the September meeting. The CLI recommendations were considered
by the EPA. The EPA's Office of Pesticide Programs (OPP) announced how it intended to
                          Chapter 1: Overview of Phase II of the CLI
23

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 address the recommendations for label changes. Planning for a media event in Spring 2000 was
 announced.  In addition, an update for the completion of the Phase II Report was given, as well as
 an update on the activities for the Consumer Education Campaign.
24
Chapter 1: Overview of Phase II of the CLI

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                             Research in Phase II

First Aid Qualitative Research

Phase II began by addressing the issues relating to First Aid information on product labels. The
qualitative research in Phase I found that the consumers tested often referred to the First Aid
section on labels only in the event of an emergency or accident.  When prompted to read the text
during the qualitative survey, however, many of these consumers reported that the phrases on
labels that tell them what to do in these types of situations were confusing.

During Phase I, CLI Stakeholders had recommended that one of the goals for Phase II of CLI be
to find simpler, clearer ways to provide instructions to consumers about what to do in case of an
emergency or accident.  In accordance with this goal, the phrase "Statement of Practical
Treatment" was replaced by "First Aid." Furthermore, CLI Stakeholders worked with the EPA's
OPP to update and improve First Aid statements.  The CLI team made a decision, based on
previous research, to replace the word "physician" with "doctor" and "area of contact" with
"skin."

During Phase II, qualitative consumer research was conducted on a series of proposed First Aid
statements, to assess the potential for changing, simplifying, and clarifying these statements. In
July of 1997, the CLI conducted 23 follow-up interviews with consumers to test several proposed
wordings of First Aid statements. (See Chapter 5 for a full description of the Qualitative First
Aid research.) First Aid instructions for all combinations of the Federal Insecticide, Fungicide,
and Rodenticide Act's (FIFRA's) toxicity categories and hazard indicators were tested. The
Office of Pesticide Programs (OPP) proposed an initial set of First Aid statements, with input
from industry, the American Poison Control Center, and other CLI Partners and Stakeholders.

Based on the results of these consumer interviews, the EPA revised the First Aid statements.
CLI Partners, Task Force members, and Stakeholders, such as the American Red Cross, PPDC,
and academia, commented and gave their feedback on these revisions. The statements were
subsequently revised  one final time, taking all of the feedback into account.  The final revisions
to the First Aid statements are expected to be released in an OPP Pesticide Registration (PR)
notice in Fall/Winter  1999.  See Chapter 5 for a detailed discussion of the First Aid qualitative
research.

Quantitative Consumer Research

Phase I research yielded qualitative results about the circumstances under which consumers read
product labels, which parts of labels they pay the most attention to, and satisfaction about current
label information and format. Since the qualitative research could not provide quantifiable
results, the CLI used quantitative research in Phase II for this purpose.

The quantitative research was a major component of Phase II of the CLI. The research was
funded by several CLI industry Partners. The development of the quantitative research, including
questionnaire development, was a collaborative group effort involving industry Partners, EPA
personnel, Task Force members from the EPA and other federal agencies, (e.g., the (Consumer
Product Safety Commission (CPSC), and the Food and Drag  Administration (FDA)), as well as
                         Chapter 1: Overview of Phase III of the CLI
25

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 other interested CLI Stakeholders.  The industry Partners hired an independent market research
 and polling firm, National Family Opinion (NFO), to conduct the survey.  The study design team
 took direction from the results of the CLI Phase I research, including the many public comments
 received, as well as input from the various CLI Subgroups (see discussion below) that were
 meeting at the same time as the survey was being developed and implemented.

 The quantitative research consisted of a national survey of consumers.  The survey aimed to:

        •     collect more data from consumers about potential new label formats and wording
              changes;

        •     benchmark and study current consumer practices and preferences with regard to
              product labels, to help the CLI determine what other label changes are appropriate
              and how best to make them;

        •     provide information to  help the EPA and CLI Project partners consider policy
              implications and take some immediate actions;

        •     assess consumer ability to locate label information;

        «     measure consumer comprehension of labels; and

        «     provide demographic analysis capability.

 The survey was conducted during May and early June 1998.  Survey results were analyzed during
 the Summer of 1998. The survey included questions about how consumers locate label
 information, how well consumers understand the information, when and where they consult the
 labels, the relative importance of different kinds  of label information, and which information
 consumers wish to find most quickly.  The quantitative portion of the study included both a
 mailed, written survey instrument and  a telephone interview.  The study was designed-to include
 a fair representation of low-income, low-education, and ethnic minorities in the U.S. See
 Chapter 2 for a detailed discussion of the survey  research design, implementation, and results.

 Qualitative Consumer Mini Focus Groups

 The qualitative research performed in Phase I, backed by Stakeholder comments and the
 literature review, found that while generally satisfied with the labels, many consumers do not
 consistently read or understand product labels for household pesticides, insecticides, and hard
 surface cleaners. This finding was also supported by Phase I Stakeholder comments and the
 Phase I literature review. Possible reasons that were proposed for this finding included:

       •     excessively technical and sometimes obscure wording of information on labels;

       •     poor layout and design of information, with inadequate contrast and difficult-to-
             read type;

       •     information that does not address consumers' needs;

       •     consumers' lack of understanding  of the potential benefits of reading the label
             information;
26
Chapter 1: Overview of Phase II of the CLI

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       •      consumers' lack of motivation to read labels; and

       •      general consumer satisfaction with the existing level of information on labels.

Quantitative survey techniques, including those used in Phase II quantitative research, do not
lend themselves well to detailed probing of interviewees to uncover why and how they react to a
variety of different text phrasings and formats. The CLI felt that a more subjective approach
would enlighten certain areas of inquiry. The CLI, therefore, pursued further qualitative research
in Phase II to investigate:

       •      consumer understanding of where to locate information on product labels;

       •      consumer understanding of the meaning of specific phrases;

       •      possible alternatives to the way certain label information is stated;

       •      how labels can be more clearly designed;

       •      consumer interpretation of certain "signal" words, such as DANGER;

       •      consumer reactions to the possibility of standardizing label information;

       •      consumer reactions to possible logo designs for the Consumer Education
              Campaign; and

       •      compelling motivators for reading and understanding labels.

Qualitative research was funded by the EPA, which hired The Newman Group, Ltd. to conduct
the research.  The qualitative research took the format of 27 "mini" focus groups, each consisting
of 3 to 5 participants, who were purchasers and users of the products under consideration. Nine
focus groups were held in each of three cities, Chicago, IL; Ft. Lauderdale, FL; and Dallas, TX,
during July and August of 1998. In each city, hard surface cleaners, indoor insecticides, and
outdoor pesticides were each covered by three separate focus group discussions. A strong effort
was made to represent low-income, less-educated, and minority-group segments of the
populations of each city.

See Chapter 3 for a detailed discussion of the Phase II qualitative research design,
implementation, and results.
                          Chapter 1: Overview of Phase III of the CLI
27

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                           CLI Subgroup Activities

The CLI was envisioned from the beginning as a partnership and a process involving teamwork
among many Stakeholders. Phase II of the CLI had several different focuses, each of which
required the expertise of different EPA management and Stakeholders. Subgroups concentrated
on each of the following areas:

       •     research on consumer knowledge, attitudes, and behaviors related to labeling
             information;

       •     standardized environmental information;

       •     storage and disposal information on products; and

       •     consumer education related to label awareness and use.

Members of each subgroup consisted of CLI Partners, Task Force members, EPA, other federal
agency personnel, and other interested CLI Stakeholders. Each subgroup made efforts to keep
other CLI groups informed of all significant activities and findings. Subgroup members were
responsible for collaborating with others in their subgroup and conveying information from the
subgroup meetings to people in their own organizations. Subgroups provided information to the
group developing and implementing the quantitative and qualitative research. Input from
subgroups was instrumental in survey development, analysis of the survey results, and
formulation of the Phase II recommendations. In many ways, the work of each subgroup affected
that of the others, and the CLI has been a dynamic process of teamwork among the many
Stakeholders.

Quantitative and Qualitative Research Core Group

A group of 22 CLI Stakeholders volunteered their time and expertise to coordinate the
quantitative and qualitative research of Phase II. Members included key people from the EPA,
market researchers from Amway Corporation, Bayer Corporation, the Chemical Specialties
Manufacturers Association (CSMA), Procter and Gamble, Reckitt and Colman, The Clorox
Company, Monsanto Lawn and Garden, S.C. Johnson and Son, Inc., RISE (Responsible
Industries for a Sound Environment), the Consumer Product Safety Commission (CPSC), and the
Food and Drug Administration (FDA). Appendix 1-5 lists all the Core Group members who
were involved primarily with the quantitative research.

The group met on a weekly basis via conference calls to develop and refine questions for the
quantitative survey instruments (telephone and mail survey).  The market researchers from the
companies were experts in their field and were able to provide input on the types of questions
and question formats that would be appropriate for each product category. The group worked
together to formulate questions addressing consumer understanding, preference, and satisfaction
with current labels. Additional questions were asked regarding specific topic areas, such as
ingredient information. (See Chapter 2 for a full description of the quantitative research.)
28
Chapter 1: Overview of Phase II of the CLI

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The Core Group also developed the focus and questions for the qualitative research and helped
familiarize The Newman Group, Inc. with the CLI and its goals and objectives. Members of the
Core Group observed several of the qualitative focus groups and provided feedback after each
group on ways in which the moderator might be better able to convey the ideas being tested in
subsequent focus groups. Appendix 1-6 lists all the members of the Qualitative Subgroup.

Finally, after the quantitative and qualitative research was completed, a small subset of the Core
Group (consisting of market researchers [one each from Amway Corporation, Bayer Corporation,
The Clorox Company, Procter and Gamble, and S.C. Johnson and Son, Inc.] and three EPA Task
Force members), continued to meet on a weekly basis to interpret and analyze the survey results.
This group studied the data thoroughly, and formulated findings, implications, and conclusions.
(See Chapters 2, 3 and 4 for a complete discussion of the findings, implications, and conclusions
from the quantitative and qualitative research.)

Standardized Environmental information on Product Labels Subgroup

A small working group consisting of EPA personnel and industry Partners was formed to address
the issue of standardized environmental information on product labels.  The group initially met
regularly;  as the scope of this issue changed, the group also met with the research Core Group.
Appendix 1-7 lists all the members of the Standardized Environmental Information Subgroup.

Initially, the group set out to investigate the possibility of developing standardized information
on product labels in the form of a facts box of environmental information (analogous to the food
nutrition label). Based on input from this working group and the desire of the Agency to advance
the development of this concept and frame the debate, consumer research on standardizing
environmental information was performed as part of the quantitative research. Part of the
quantitative research asked consumers what they felt was the most important information on a
label and to identify which types of information they looked for hi different situations. The
quantitative research found that consumers interviewed did not generally consider environmental
information to be one of the more important sections of the product labels. Consumers also said
that a standardized format for labels would help them to more easily locate the information that
they consider to be important.

The group's focus regarding standardization of information on product labels then shifted.  Given
what consumers were saying, the group decided that it was most important to test variations of
standardized formats on product labels to see whether any of the formats improved consumers'
understanding of label information. It was decided that various box and standardized label
formats would be tested via the qualitative research. Consumers in the focus groups were asked
questions about their preference for specific formats, whether the formats made a difference in
their understanding of the information presented, and whether they had a preference for which
information should be presented in standardized or box formats.

See Chapter 6, section 1 for a more details regarding the standardized format research.
                         Chapter 1: Overview of Phase II of the CLI
29

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 Storage and Disposal Subgroup

 The Storage and Disposal Subgroup was formed at the end of Phase I to address some of the key
 findings from Phase I research on storage and disposal issues. (The complete Storage and
 Disposal Subgroup is listed in Appendix 1-8.) These Phase I findings included the following:

        •     consumers often do not read storage and disposal instructions;

        «     consumers frequently attempt to recycle the empty plastic containers that
              hazardous household products come in, which often violates regulations relating
              to public health and safety; and

        •     EPA standard disposal instructions on labels may conflict with some state or local
              laws or practices.

 In Phase II, the CLI Storage and Disposal Subgroup directed research to obtain a better overview
 and understanding of current state and local regulations and practices regarding storage and
 disposal of household hazardous products.  The Subgroup also identified problems related to
 modifying storage and disposal language on labels. An informal survey was made of members of
 the North American Hazardous Materials Management Association (NAHMMA). Telephone
 interviews, a literature review, and discussions with and presentations of data by a variety of
 Stakeholders supplemented the survey results. Input from the storage and disposal groups was
 also taken into consideration when formulating questions for the qualitative and quantitative
 research, and in the analysis of the research data.

 See Chapter 6, section 2 for a detailed discussion of the Storage  and Disposal Subgroup
 activities.

 Consumer Education Subgroup

 The ultimate goal of the CLI is to change the behavior of consumers regarding pesticides and
 household cleaning products, especially to:

       «      increase reading and use of labels;

       «      decrease the misuse of products;

       •      decrease the incidence of accidents involving products; and

       •      decrease environmental impacts caused by improper use, storage, and disposal of
             these products.

Phase I research and the extensive literature search, supported by many Stakeholder comments,
found that many consumers do not consistently or thoroughly read labels for these types of
products.  Changes of label information or design will not be beneficial to consumers unless they
read the labels. As part of Phase II, the CLI therefore established a Consumer Education
30
Chapter 1: Overview of Phase II of the CLI

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Subgroup, to concentrate on ways to 1) increase consumer awareness of labels; 2) encourage
consumers to read labels and use their information thoughtfully, for both their personal safety
and as part of their environmental responsibility; and 3) to help people understand the
information presented on labels. Appendix 1-9 lists all the members of the Consumer Education
Subgroup.

The Consumer Education Subgroup conceptualized, developed, and began implementing a
broad-based, long-range consumer education plan intended to help people to read, understand,
interpret, and use label information. The Subgroup developed an easily understood message
—"Read the Label FIRSTF— and began developing a unique, memorable, consumer-friendly
logo of the message.  The various components of the campaign were designed to work with and
reinforce each other.  The Subgroup also strategized the goals of the education campaign and
support materials, and suggested ways in which to use the materials. The subgroup prepared
brochures targeting different audience groups, and designed succinct messages that can be
adapted to a variety of educational approaches and materials.

See Chapter 6, section 3 for a detailed discussion of the Consumer Education Campaign.
                         Chapter 1: Overview of Phase II of the CLI
31

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                                    CHAPTER 2
                    QUANTITATIVE RESEARCH
At the end of Phase I, EPA, in consultation with CLI Partner and Task Force members, concurred
with the recommendation that quantitative research in Phase II would be valuable to better
understand consumers' preference for, comprehension of, and satisfaction with current product
labels.  A quantitative approach was favored because it was necessary to obtain statistically
sound data to support the findings from the earlier qualitative research.  Furthermore, unlike
qualitative research data, quantitative research data are representative of the study population and
projectable to the entire population. Quantitative research was also used to determine the
prevalence of particular opinions on a given issue expressed in the qualitative interviews.
Additionally, quantitative research was appropriate for measuring both attitudes and behavior of
consumers to current and new product labels. Demonstrating their support for this concept, the
CLI Partners volunteered to fund and direct this research, which they felt would be of use even
beyond the CLI.  Quantitative research also provides a baseline that can be surveyed periodically
to determine changes in attitude and behavior.

The Phase II quantitative consumer research was designed to assess consumer comprehension,
attitudes, behavior and satisfaction with labeling and to evaluate labeling alternatives (for both
registered and non-registered products) in the outdoor pesticide, indoor insecticide, and hard
surface cleaner categories. The quantitative survey was organized along the six learning
objectives identified by the CLI Partner and Task Force members at the  beginning of Phase II.
These learning objectives are as follows:
Quantitative Learning Objectives

       Determine the current situation relative to consumers' satisfaction with the format and
       content of existing labels;

       Determine consumers' hierarchy of importance of basic label information;

       Determine where on the label consumers expect to find particular information, such as
       First Aid and ingredients;

       Determine consumers' current comprehension of label language;

       Determine whether or not a preference exists for non-FIFRA over FIFRA labels (for
       household cleaner category only); and

       Determine consumers' reaction to standardized safe use, environmental, health and safety
       information.
                             Chapter 2: Quantitative Research
33

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 Each learning objective was intended to generate research findings that would enable the EPA
 and CLI Stakeholders to take immediate and short-term steps toward label improvements.  Some
 changes, such as revised guidance and regulations, are almost entirely under the purview of the
 EPA. Other changes are entirely within the purview of the product marketers but may be subject
 to EPA label approval.  Others, such as consumer education, involve many Stakeholders and
 would be implemented over a longer time period. The results of the quantitative research were
 expected to lead to certain actionable steps, such as:

        •     quantify key learnings from the qualitative research in Phase I of CLI;

        •     collect data that will serve as input into additional quantitative research, such as
              consumer evaluation of potential new label formats;

        •     benchmark current consumer practices and preferences, so that changes in
              behavior/preference (based on label changes) can be assessed;

        •     provide information that will allow the EPA and its Partners to consider policy
              implications and to take some immediate action steps;

        •     guide the Consumer Education Subgroups's efforts;

        •     guide the Storage and Disposal Subgroup in making recommendations; and

        •     provide information for potential changes to label formats.
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Chapter 2: Quantitative Research

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                Strategy for the Quantitative Research

The design and implementation plan of the quantitative research was developed by the Research
Core Group, consisting of EPA personnel, industry and trade association Partners, people from
other federal and state agencies, and other interested CLI Stakeholders.  The Core Group began,
by addressing the learning objectives identified at the beginning of Phase II by CLI Partner and
Task Force members, to develop the quantitative screening and survey questionnaires. Several of
the members of the research group were market researchers in their own organizations and,
therefore, had extensive experience with survey design. The quantitative research was
voluntarily undertaken and funded by industry and trade association Partners of CLI including:
AgrEvo Environmental Health; American Cyanamid (American Home Products); Bayer
Corporation; the Chemical Specialties Manufacturers Association (CSMA); Dow AgroSciences;
FMC; Reckitt & Colman; S.C. Johnson & Son, Inc.; The Procter and Gamble Company; The
Clorox Company; Purcell Industries, Inc.; Riverdale Chemical Co.; SC Johnson; The Andersons,
Inc.; The Scotts Co.; Solaris (Monsanto); United Industries Corporation; and the RISE
(Responsible Industry for a Sound Environment). This group of companies hired an independent
survey research firm, National Family Opinion (NFO) Research, Inc. to  implement the study.

During Phase II, the Core Group met on a weekly basis via telephone conference calls, and
occasionally in ad hoc face-to-face meetings, to discuss the development of the survey
instruments, the implementation of the survey itself, and interpretation of the data once the
results of the survey were available. In July 1998, a smaller subgroup of the Core Group met in
Washington, D.C., to discuss the survey data in detail and establish some of the preliminary
findings from the survey results. This smaller group consisted of EPA Task Force members, and
market researchers from Amway Corporation; Bayer Corporation; S.C. Johnson and Son, Inc.;
and the Procter and Gamble Company. In August, the subgroup finalized the preliminary
findings and prepared data tables to illustrate these conclusions.  In September 1998, the
subgroup presented these results at the Partner and Task Force meeting in Alexandria, VA.
                             Chapter 2: Quantitative Research
35

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                            Quantitative Study Design

 The quantitative study consisted of three parts: an initial screening (to identify potential study
 participants), followed by telephone interviews and a self-administered mail questionnaire among
 those selected to participate in the main portion of the quantitative study.
                                   The Three Parts of the
                                Quantitative Study Design
Initial Screening
identifies potential
study participants
>
'
Telephone interviews
conducted by NFO
                                     Participants complete
                                    self-administered mail
                                        questionnaire
Screening to Identify Product Category Users for Use in the Study

In the first part of the quantitative phase of the study, a postcard with a very short screening
questionnaire (screener) was mailed to members of the NFO Panel.2
       2 Consumers were screened from NFO Research's consumer panel of 550,000 households. The panel of
550,000 was randomly chosen from the population as a whole. The NFO panel consumers have agreed in advance
to participate in marketing research studies. When households become members of the NFO panel, they provide a
large amount of demographic information about their household (e.g., age and gender of household members,
household income, household size, education and employment information on the male and female heads of
household, and many other types of information).  This large database of pre-recruited households allows NFO
Research to:

•   easily find households which are willing to participate in marketing research studies, particularly those that are
    longer and more complex in nature;
•   design the sample (i.e., determine which households are chosen to participate in the study) in a way that ensures
    that the demographic make-up of participants (and thus the results) are representative of the U.S. population as
    a whole; and
•   eliminate the need to collect a series of demographic information from each respondent, since the panel
    database already contains a large amount of demographic information for each panel household.
36
Chapter 2: Quantitative Research

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The screener contained questions to identify consumers eligible for participation in the main
portion of the quantitative study (and to eliminate those consumers not eligible for participation).
Screener questions asked respondents the following:

       •      Whether any household member used a household cleaner in the past 12 months.
              For those who indicated usage of a household cleaner, the age and gender of the
              household member who is the primary user of household cleaners;

       •      Whether any household member used an indoor insecticide in the past 12 months.
              For those who indicated usage of an indoor insecticide, the age and gender of the
              household member who is the primary user of indoor insecticides;

       •      Whether any household member used an outdoor pesticide in the past 12 months.
              For those who indicated usage of an outdoor pesticide, the age and gender of the
              household member who is the primary user of outdoor pesticides; and

       •      Whether the respondent had gone to the store to purchase each of the three types
              of products, but did not because of information contained on the label of the
              product.

In March 1998, the screening postcard was mailed out to a total of 10,000 NFO consumer panel
households. The distribution of recipients who received this postcard was balanced to be
representative of the U.S. population as a whole on age and. gender of the head of household,
geographic region, household size, market size, and household income. An additional 2,250
postcards were mailed out to households from three low incidence groups of interest (minority,
lower formal educational level, lower income) onNFO's panel of 550,000, to ensure adequate
representation in the final survey results. These low incidence groups were also balanced to be
representative of their counterparts in the overall U.S. population. In April 1998, returns were
closed out and the returns tabulated.  A total of 8,447 households returned the postcard (69% of
the number sent out). These results were then used to determine which households and which
individuals to include in the main portion of the CLI quantitative study (i.e., phone and mail
questionnaires) for appropriate demographic representation. Appendix 2-1 contains the
screening questionnaire.

Non-User Results

As stated above, non-users (in the past 12 months) were excluded from the main portion of the
quantitative study.  It must be noted that among the group of consumers who said on the screener
that they had not used the specific products in the past 12 months (and were thus ineligible for
inclusion in the main portion of the study), a small number also indicated on the screener that
they went to the store to buy such a product, but did not purchase it because of information on the
package (6% of those who did not purchase household cleaners, 7% of those who did not
purchase indoor insecticides, and 5% of those who did not purchase outdoor pesticides). The
information on the package cited as the reason consumers did not buy the product was not
specified. It cannot be determined, therefore, what biasing impact, if any, was created by
excluding these consumers from the study. Based on the low number of consumers who were
excluded (between 5% and 7% of non-users for each category), it is unlikely that any such biases
would alter the survey findings in any meaningful way.
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Sample for the Telephone Interviews and Mail Questionnaire

For each product category, a group was formed of participants who indicated that they had used
that type of product in the past 12 months.  Additionally, supplemental samples of low-income
households (i.e., those making less than $10,000 per year), less educated heads of household (i.e.,
those with less than high school education), and minorities were drawn for all three categories,
and a supplemental sample of fogger users was also drawn for the indoor insecticides category.
These additional samples were needed because the overall incidence of these groups in the U.S.
population is so low that there would not be enough members of these groups in the nationally
representative sample to allow for meaningful quantitative analysis of these particular groups.

These supplemental groups (i.e., supplemental samples) were included only for analyses that
looked specifically at the group for which the supplemental sample was pulled.  For example, the
respondents who were part of the supplemental group for low-income households were included
only in the separate analysis of consumers from low-income households. Excluding these special
supplemental groups of respondents from other groups (e.g., the nationally representative
sample) prevented the creation of an unnatural skew toward over-representing consumers from
those groups for which a supplemental sample was pulled. It is important to note that, due to
random selection, there  are still members among the nationally representative sample who fall
into the demographic groups for which supplemental samples were pulled.

The samples for each product category were balanced to be representative of the portion of the
U.S. population that uses that particular category (i.e., household cleaners, indoor insecticides,
outdoor pesticides). The samples were balanced on the following demographic variables:

       •     age of user,

       •     gender of user,

       •     household income,

       •     household size,

       •     market size, and

       •     geographic region.
38                          Chapter 2: Quantitative Research

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The self-administered mail questionnaires were mailed out to a total of 6,438 households, broken
down as follows:
Nationally representative sample of (category users:
All categories
1,775 per category
Supplemental Samples

Indoor insecticides
Household cleaners
Outdoor pesticides
Low-education
heads of
household
102
102
108
Low-income
households
122
124
132
Minority
households
77
90
112
Fogger users
144
N/A
N/A
When survey returns were closed in early June 1998, a total of 3,234 consumers (50% of the total
sent out) completed both the telephone and mail portions of the study, with approximately 850 to
900 being nationally representative users of each of the three product categories. As appropriate,
the remainder of returns were used to supplement the various low incidence groups.
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                   Telephone and Mail Questionnaires
The main portion of the CLI quantitative study was composed of 1) a telephone interview,
followed by 2) a self-administered 8-page mail questionnaire. The telephone interview was used
to collect information that would have been difficult to collect without direct interaction with an
interviewer (e.g., having the respondent state where certain label sections were located).
Telephone interviewers also allowed for clarifications and follow-up probing of responses
regarding comprehension. Questions on the phone survey were rotated so that any order bias or
"question fatigue" would be avoided. The mail questionnaire was used to collect a large amount
of detailed information that could not be collected over the telephone due to time (i.e., length of
interview) considerations. The telephone  interview also asked consumers for "top of mind"
responses to mimic actual consumer behavior (e.g., exercise of choices  and capabilities) when
they encounter the label both in the store and at home.

There were three different versions of the  survey: one for household cleaning products, one for
indoor insecticides, and one for outdoor pesticides, with the bulk of questions being identical on
all three. In April 1998, participants were sent one version of the questionnaire booklet, along
with a letter of instruction and a "mock" label (for use in both the phone and mail portions of the
study). The mock label was representative of a typical product label for the product category for
which respondents were selected.  Participants were instructed to await  a telephone call before
completing the self-administered mail questionnaire.  After allowing time for mail delivery,
respondents were contacted by phone in early May and asked to complete a 10-minute telephone
interview (average time), with responses collected using a computerized telephone questionnaire.
After completion of the telephone survey,  respondents were then instructed to complete the 8-
page mail questionnaire and return it to NFO Research. After one month for completion and
return of the self-administered mail questionnaire, returns were closed in early June  1998, and all
results from the telephone and mail surveys were then tabulated.  Only results from those
completing both the telephone and the mail portions of the survey were  included in the final
results.
               Procedure for Telephone and Mail Questionnaires
April 1998:
respondents
receive
questionnaire
booklet
Early May:
respondents
complete
telephone
interview
Respondents
complete
questionnaire
and return it
to NFO
Research
June 1998:
results from
telephone
and mail
surveys are
tabulated
40
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Survey Questionnaires and Learning Objectives

The telephone and mail survey instruments were designed by the Core Group (quantitative
research group) to address the learning objectives outlined at the beginning of this chapter.  The
learning objectives, questions from each questionnaire relating to that learning objective, and the
potential action steps emerging from these questions are provided in Table 2-1.

In addition to the learning objectives, the Core Group developed the survey instruments to
investigate consumer attitudes, behaviors, and understanding related to specific areas and issues,
including:

       •      Consumer Education — What other sources of information, besides the product
              label, do consumers turn to for information about the product?

       •      Product Ingredients — Do consumers understand the ingredient listing on
              products and know how to use this information?

       •      Signal Words — Do consumers understand the  signal word hierarchy for
              CAUTION, WARNING, and DANGER?

       •      Storage and Disposal — What are consumers' current storage and disposal
              practices?

       •      Precautionary Statements — What are consumers' understanding and use of
              precautionary statements?

Telephone Interview Outline

The telephone interview questionnaire used "mock" labels to ask questions related to consumers'
comprehension of and ease of finding information on the labels.  More specifically, the telephone
questionnaire tested respondents' ability to locate key sections of the label, the accuracy with
which respondents were able to locate these sections, and their opinions on the ease of finding
these  sections. Respondents also were asked what they thought certain language on the label
meant, including specific key words and phrases.  Finally, the telephone survey asked several
demographic questions. (See Appendix 2-2 for copies of the phone questionnaires, and
Appendix 2-3 for the mock labels.) Each interview was conducted by trained interviewers from
NFO Research, Inc., and lasted approximately 10-12 minutes.  At the conclusion of the telephone
interview, the interviewer instructed the respondent to complete the written questionnaire in his
or her own time and mail it back to NFO Research, Inc., once completed.
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         Table 2-1: Learning Objectives, Survey Questions, and Potential Action Steps
Learning Objective
Questions Relevant to the Learning
Objectives Addressed the Following:
      Potential Action Steps
1) Determine current
  satisfaction with the format
  and content of existing labels
Telephone:
• ease of locating key label sections
Mail:
• overall satisfaction with the current label
• likes and dislikes of label sections
If current labels are not meeting
consumers' needs, provide general
input on which sections need further
revisions. Level of consumer
dissatisfaction indicates strength of
motivation for change, thus
determining focus and degree of
difficulty for education effort.
2) Determine consumers'
  hierarchy of importance of
  basic label information

3) Determine where on the label
  consumers expect to find
  label information
Telephone:
• ease of locating key label sections
Mail:
• where and how often consumers read
  sections of labels
• information on labels that are the most
  and least important
• where consumers expect to find
  information on labels, and which
  information they want to find most easily
• where consumers expect to find recycling
  icons
Make format recommendations, such
as organizing information when
needed in the store, before use, or in
case of emergency.
4) Assess consumers'
  comprehension of current
  label language
Telephone:
• comprehension of language by label
  section
Mail:
• meaning of the recycling icons
• likes and dislikes about label sections
1. Identify terminology that
   consumers find difficult to
   understand.
2. Recommend additional qualitative
   work with consumers to
   understand what terminology
   should be used, as appropriate.
3. Recommend word changes
   (limited).
5) Determine preference of
   FIFRA versus non-FIFRA
   labels (for household cleaner
   category only)
Mail:
• like and dislikes about label sections
•- consumers' preference for FIFRA and
  non-FIFRA labels
• paired preference statements
1. Quantify whether non-FIFRA label
  is preferred to FIFRA language.
2. Make word changes where
  possible.
3. Make format recommendations,
  such as organizing information
  when needed in the store, before
  use, or in case of an emergency.
6) Solicit consumers' reactions
   to standardized information
   on safe use, environmental,
   and health information
Mail:
• most and least important information to
  consumers
• where consumers expect to find
  information on a label, and which
  information they want to find most easily
• where and how often consumers read
  sections of the label	
1. Provide direction on the types of
  information that could be
  standardized.
2. Make format (location)
  recommendations.
      42
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 Mail Questionnaire Outline

 The mail questionnaires (see Appendix 2-4) were designed to address the following specific
 questions:

        «      respondents' overall satisfaction with current labels;

        •      when (i.e., in the store or right before use) and how often respondents read label
               sections;

        •      if they do not read the label, why not;

        •      most and least important information to respondents;

        •      where respondents expect to find information on a label, and which information
               they want to find most easily;

        •      respondent likes and dislikes about product label sections;

        •      other sources (besides the label) for product information;

        "      meaning of recycling icons, including what actions respondents think the icons are
               asking them to take, and where they expect to find these icons on the product
               packaging;

        •      respondent preference for FIFRA versus non-FIFRA labels (for household
               cleaning product category only);3

        «      respondent preference for FIFRA language and alternate wording;

        •      respondent attitude toward reading product labels;  and

        •      respondent habits and practices, such as: products used; accident experience;
               current storage, disposal, and recycling practices; and the incidence of product
               category use and non-purchase due to confusion about the label.
        Pesticides, disinfectants, and antimicrobial cleaners are subject to labeling requirements under FIFRA.
Other products (i.e., in the case of products covered by CLI, non-disinfectant and/or antimicrobial household
cleaners), are governed by other authorities. In the cleaner category, therefore, product labels are markedly
different, depending on whether FIFRA or a different statute applies, even through the products in the bottle may be
similar. For the CLI quantitative research, respondents in the household cleaners category were presented with a
FIFRA and a non-FIFRA label to determine how each was perceived.
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                         Quantitative Research Data

National Family Opinion Research completed collection of the survey responses and data
tabulation during the months of June and early July4. In the final count, the total number of
responses received for the mail and the telephone surveys were as follows:

       •      Household Cleaners — 894 completes;

       •      Outdoor Pesticides — 846 completes; and

       •      Indoor Pesticides — 889 completes.

Statistical  Testing of Data

When comparing different groups of data quantitatively, statistical tests are needed to help
determine which data are meaningful and which are not. A two-tailed t-test, which compares the
percentages or means of interest and the sample  sizes, was used to determine whether differences
existing among groups are significant on a statistical level.

This type of statistical testing is done based on the level of significance desired. Data are most
frequently tested for significance at levels between 80% and 95%. The higher the level of
statistical testing performed, the more likely it is that data differences detected in the study
reliably reflect differences in the "real world." If a significant difference between two data points
at the 95% confidence interval is found to exist,  this means that the same study, if conducted 100
times, would show a significant difference reflected in its data at least 95 of those times. For the
CLI study, data were tested at the 95% confidence level. In the raw data tables, significance was
routinely tested. For each question asked, the mean, standard deviation, and standard error are
also shown for each type of respondent.

Breakdown of CLI Data

The Core Group determined that it would be important to investigate whether significant
differences existed among various groups of respondents. To this end, the raw data were broken
down by various demographic categories and by ways in which respondents answered several
key questions.  These breakdowns were necessary so that analysis and comparisons could be
made among different groups that responded to the questionnaire. For example, the gender
category allowed the Core Group to determine if there is any significant difference between the
numbers of males and females who read information on product labels. A total of seven
demographic categories were made for the CLI study as follows:

       •      gender (male, female);

       •      household income (less than $ 10,000; $ 10,000-$24,999; $25,000-$49,999; and
              $50,000 or greater);
       4 A complete set of the quantitative data may be found in the EPA's Public Docket, Administrative Record
AR-139. The availability of the data for public review was announced in a Federal Register (FR) notice (63 FR
57298, October 27, 1998).
44
Chapter 2: Quantitative Research

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       •     respondent education level (less than high school, high school graduate, and some
              college level education);

       •     minority status (yes, no);

       •     age of respondent (18-34, 35-54, and 55 or older);

       •     presence of children in the household (yes, no);

       •     dog/cat ownership (yes, no); and

       •     overall satisfaction level expressed with the label for that category, as indicated on
              the mail questionnaire.

In addition, seven categories were made to compare the ways in which respondents answered key
questions of interest for the Core Group's analysis, as follows:

       •     frequency with which labels are read (respondents who read label section
              "occasionally or every time," or those who "do not read label sections
              occasionally or every time");

       •      ability to correctly identify most sections (respondents who were able to correctly
              locate label sections and those that could not correctly locate label sections two or
              more times);

       •      whether or not respondents looked for information about ingredients (respondents
              who said that they looked for ingredient information and those that said that they
              did not look for this information);

       •      preferred ingredient format (respondents' preference for four different ingredient
              information presentation options (for details on these options, refer to question 4c
              on mail questionnaires in Appendix 2-4);

       •      whether or not respondents looked for information about harmful effects of the
              product (respondents who said that they look for information on a label on the
              harmful effects of a label, and those that said that they did not);

       •      preferred labeling format (respondents who answered that they would "make no
              change to the current label format," those that said they would like to see
              "headings to highlight key facts," and those that said that they preferred the
              suggested "box format"); and

       •      geographic regiori (indication of where respondents were from for use by the
              Storage & Disposal Subgroup to see how respondents from states with strong
              household hazardous waste management programs ("strong HHW") answered
              questions in comparison to those respondents from other states ("other HHW")).
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Data Precision

Based on a standard statistical measure for sample sizes of about 850 to 900 respondents, the
data for the nationally representative sample of users for each of the three product categories are
accurate to + 3Yz% at the 95% confidence interval.  This means that if the study were conducted
100 times and 50% of respondents gave a certain response, 95 out of those 100 tests would yield
a result for that response if given by between 46.5% and 53.5% of respondents. As percentages
move towards the extremes (i.e., closer to 0% and 100%), the precision of these data points will
actually be higher. It is important to note that these precision measures refer to specific data
points, and not to differences between data points.  Precision for groups with smaller sample
sizes will be lower.
46
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         Quantitative Research Findings and implications
The raw data tabulations were analyzed by the Research Core Group for several reasons:

       •      to discover what overall findings, or observations, could be made from the
              quantitative data about consumers' comprehension, attitudes, behavior and
              satisfaction with labeling;

       •      to identify the implications, or connections, among the various findings related to
              a learning objective or topic area; and

       •      to evaluate labeling alternatives (for both registered and non-registered products)
              in the outdoor pesticides, indoor insecticides, and hard surface cleaner categories.

The Core Group hoped to be able to organize the findings in accordance with the learning
questions and the topic areas studied hi the quantitative research. Once  in-depth analysis began,
however, it became evident that the data leading to the findings were not clear-cut, but in fact
overlapped with one or more of the learning objectives and topic areas.

Wherever possible in this report, findings and implications have been organized according to
topic area.  Data charts and tables follow the findings that they support; most charts are presented
in both graphic and numerical formats. Implications of the findings are provided following the
findings from which these have been drawn.

Learning Objectives and Topic Areas

The quantitative survey was designed to address six learning objectives identified by the CLI
Partner and Task Force members at the beginning of Phase II.
Quantitative Learning Objectives

       Determine the current situation relative to consumers' satisfaction with the format and
       content of existing labels;

       Determine consumers' hierarchy of importance of basic label information;

       Determine where on the label consumers expect to find particular information, such as
       First Aid and ingredients;

       Determine consumers' current comprehension of label language;

       Determine whether or not a preference exists for non-FIFRA over FIFRA labels (for
       household cleaner category only); and

       Determine consumers' reaction to standardized safe use, environmental, health and safety
       information.
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In addition to the learning objectives, the quantitative study also focused on the following topic
areas:
Specific Topic Areas Addressed by the Quantitative Research

       Consumer Education — What other sources of information, besides the product label, do
       consumers turn to for information about the product?

       Product Ingredients — Do consumers understand the ingredient listing oh products and
       know how to use this information?

       Signal Words — Do consumers understand the signal word hierarchy for CAUTION,
       WARNING, and DANGER?

       Storage and Disposal — What are consumers' current storage and disposal practices?

       Precautionary Statements — What are consumers' understanding and use of
       precautionary statements?
Findings and Implications

Terminology

Findings are observations resulting directly from the quantitative survey results and are
supported by the data.

Implications show connections among the various findings related to a topic or learning objective
and are derived from consideration of the quantitative findings.

Findings on Respondents' Satisfaction with Existing Labels (Chart 2-1, Table 2-2)

In general, respondents expressed overall satisfaction with the product labels in the three product
categories.  However, when presented with specific alternate label formats or language
preferences, they indicated  a desire for specific changes.
48                           Chapter 2: Quantitative Research

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                                       Chart 2-1

                 HOW SATISFIED ARE YOU OVERALL WITH THE INFORMATION
                     CURRENTLY AVAILABLE ON PRODUCT PACKAGING?
                 Outdoor Pesticide (n=846)
                Household Cleaner (n=894)
                 Indoor Insecticide (n=889)
Extremely
Not Very
                                    0%    20%    40%    60%    80%    100%

                                       Q|  Very        83  Somewhat
                                       G  Not At All
Table 2-2: How Satisfied Are You Overall With the Information
Currently Available on Product Packaging? (%)

Outdoor Pesticide
Household Cleaner
Indoor Insecticide
Extremely
9
7
9
Very
51
52
55
Somewhat
35
37
32
Not Very
4
3
3
Not At All
1
1
1
                                 (Base = All Respondents)
Findings on Respondents Comprehension of Existing Labels (Tables 2-3, 2-4, 2-5)

1.      Overall respondents' comprehension of the label sections was high in all three product
       categories.  A consistent exception to this finding is that over half of the respondents
       found the words in the ingredients section to be confusing.

2.      The overwhelming majority of respondents for all three product categories said there
       were no confusing words or phrases in any of the various label sections. In the outdoor
       pesticides category, however, over one third said there were confusing words or phrases
       in the environmental hazards section.

3.      In all three product categories, respondents preferred the alternative, revised statements
       over the existing label language, with only a few limited exceptions.
                             Chapter 2: Quantitative Research
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5.
In each of the three product categories, comprehension of the label language was high,
with just a few exceptions. However, there are noteworthy findings for Indoor
insecticides and outdoor pesticide categories:

    »  For indoor insecticides — nearly one-half of the respondents indicated that there
       was something confusing about the First Aid section of the label.  A large
       majority of these respondents had difficulty with the phrase "gastric lavage is
       indicated if material is taken internally."

    •  For outdoor pesticides — one-third of the respondents indicated confusion with
       the Environmental Hazards section.  The phrase "This product is toxic to aquatic
       invertebrates" was mentioned most often as the source of this confusion.

Respondents were fairly definitive with regard to the preference for various statements
tested related to household cleaners. In particular, each statement had two-thirds or more
of the respondents preferring one alternative or the other. Please refer to the following
table for a complete listing of statement preferences.
Table 2-3: Preference Statements for Household Cleaner Labels
% Preferring
66.8
32.0
87.4
78.4
73.1
Statement A
For safe and effective use,
read the label first
For safe and effective use,
read the label first
Hazards to humans and
animals
Environmental hazards
Avoid contact with eyes
Statement B
Use safely. Read the label
before use
Use only as directed on this
label
Effects on humans and
animals
Effects on the environment
Protect your eyes during
application. Wear safety
glasses.
% Preferring
33.2
68.0
12.6
21.6
26.9
50
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6.      While consumers exhibited strong preference for certain statements on indoor insecticide
       labels such as "Can be absorbed through skin" (97%) versus "Can be absorbed dermally"
       (3%), there was considerably less agreement on statements such as "Do not re-enter for X
       hours after application" (52%) versus "Allow X hours before re-entering treated rooms"
       (48%). Please refer to the following table for a complete listing of statement preferences.
Table 2-4: Preference Statements for Indoor Insecticide Labels
% Preferring
33.8
24.5
41.7
91.0
85.5
56.8
48.0
57.1
30.4
3.0
Statement A
Repeat as needed
Do not allow children or pet to
contact treated areas
For safe and effective use,
read the label first
Hazards to humans and
animals
Environmental hazards
Avoid contact with eyes
Allow X hours before re-
entering treated rooms
Use only in well-ventilated area
Do not spray directly over food
or utensils
Can be absorbed dermally
Statement B
Apply no more than X
treatments per week
Keep children or pets out of
treated areas for X minutes
Use only as directed on this
label
Human and animal effects
Environmental effects
Protect your eyes during
application. Wear safety
glasses.
Do not re-enter for X hours
after application
Open windows before use to
provide free flow of air
Do not apply where spray
may settle onto food or
utensils
Can be absorbed through
skin
% Preferring
66.2
75.5
58.3
9.00
14.5
43.2
52.0
42.9
69.6
97
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7.     Consumers exhibited strong preferences for certain statements found on outdoor pesticide
       labels such as "Hazards to humans and animals" (96%) versus "Human and animal
       effects" (4%).  There was considerably less agreement on statements such as "This
       pesticide can kill wildlife" (56%) versus "This pesticide is toxic to wildlife" (44%).
       Please refer to the following table for a complete listing of statement preferences.
Table 2-5: Preference Statements for Outdoor Pesticide Labels
% Preferring
35.0
96.3
89.8
6.10
27.9
14.5
10.8
3.90
11.7
44.2
41.0
5.6
3.5
33.7
2.60
Statement A
Use safely. Read the label before
use
Hazards to humans and animals
Environmental hazards
Re-entry not allowed until sprays
are dry
Do not apply directly to water
Do not contaminate water when
disposing of equipment
washwaters or rinsate
Do not contaminate water when
disposing of equipment
washwaters or rinsate
Do not use where soils are
permeable
Do not use where soils are
permeable
This pesticide is toxic to wildlife
This pesticide is toxic to wildlife
and domestic animals
Do not apply when weather
conditions favor drift from treated
areas
Pre-harvest Interval-allow X hours
before picking or eating crops
Drift or runoff may adversely affect
fish and nontarget plants
Phytotoxic to woody plants
Statement B
Use only as directed on this
label
Human and animal effects
Environmental effects
Do not re-enter treated area
until spray has dried
Do not apply directly to lakes,
streams, rivers, or ponds
Do not dump rinse water into
sewers or other bodies of
water
Do not dump leftover pesticide
or rinse water into drains or
sewers
Do not use where product may
seep into ground water
Do not apply to sandy soils
This pesticide can kill wildlife
This pesticide may harm pets
and wildlife
Do not apply in windy
conditions. Pesticides may
drift away from application site
Do not pick or eat garden
crops for X hours after
application
Drift or runoff may
unintentionally harm fish and
plants
Application may injure woody
plants
% Preferring
65.0
3.70
10.2
93.9
72.1
85.5
89.2
96.1
88.3
55.8
59.0
94.4
96.5
66.3
97.4
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Table 2-5: Preference Statements for Outdoor Pesticide Labels
% Preferring
76.4
46.9
22.3
Statement A
Wrap in paper and dispose of in
trash
Do not apply where runoff can
occur
Repeated contact may cause skin
sensitization reactions in come
individuals. Avoid contact with
skin.
Statement B
For information on safe
disposal of unused product,
contact a household
hazardous waste program, or
your local or state
environmental agency
Do not use on sloped areas
when heavy rain is expected
May cause skin allergies to
develop. Avoid contact with
skin
% Preferring
23.6
53.1
77.7
8.     There were demographic differences in respondents' comprehension of the labels:
          "  Respondents in higher income categories understood labels better.
          •  Respondents at higher education levels understood labels better.
          •  Respondents in the younger age categories understood labels better.

9.     Ability to locate information on the label and comprehension of that information correlate
       positively with income and education and correlate inversely with age.  This is true
       despite higher reported interest in label information among the elderly,  less educated, and
       lower income participants in the survey.

10.    Interest in specific information on labels (e.g., looking for information on harmful effects)
       correlates positively with understanding labels.
Findings on Respondents' Ease of Locating Information on Labels (Chart 2-2, Table 2-6,
Table 2-7)
11.    In all three product categories, an overwhelming majority of respondents indicated that
       the information on the label was where they expected it to be. Of those who did not find
       the information where they expected, the most popular suggestion was to put the
       ingredients on the back label. (For specific product information, see Charts 2-3 and 2-4
       and Table 2-7.)

12.       The information respondents found most difficult to locate on product labels were:
          •  For all three product categories — where the product should not be used.
          •  For outdoor pesticides — First Aid information and precautions to pets and the
              environmental effects for wildlife.
          •  For indoor insecticides — precautions to personal health.
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                                        Chart 2-2
                      WAS ALL OF THE INFORMATION ON THE LABEL
                              WHERE YOU EXPECTED IT TO BE?
               Outdoor Pesticide -
              Household Cleaner -
                Indoor Insecticide
                            0%      20%     40%     60%     80%     100%

                                   D  Yes   D  No
                                 (Base = All Respondents)
Table 2-6: Was All of the Information on the Label Where You Expected It To Be? (%)

Outdoor Pesticide
Household Cleaner
Indoor Insecticide
Yes
93
87
90
No
7
13
10
                                (Base = All Respondents)
54
Chapter 2: Quantitative Research

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                         Chart 2-3
              ABILITY TO IDENTIFY EFFECTS
   ON PERSONAL AND CHILDREN'S HEALTH OR SAFETY
100%
 80%
 20%
  0%
Indoor Insecticide

3  Correct Response
fTH  Could Not Find
Household Cleaner
                                           Outdoor Pesticide
                                 Incorrect Response
Table 2-7: Ability to Identify Effects on Personal and Children's Health or Safety (%)

Outdoor Pesticide
Household Cleaner
Indoor Insecticide
Could Not Find
3
6
7
Incorrect Response
32
13
27
Correct Response
65
81
66
                 (Base = All Respondents)
              Chapter 2: Quantitative Research
                                              55

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                                     Chart 2-4

                               ABILITY TO IDENTIFY
                         PRODUCT CONTENTS OR INGREDIENTS
             100%
              80%
             20%
              0%
                     Indoor Insecticide    Household Cleaner    Outdoor Pesticide

                    £]  Correct Response    Q  Incorrect Response
                    UJ  Could Not Find
Table 2-8: Ability to Identify Product Contents or Ingredients (%)

Outdoor Pesticide
Household Cleaner
Indoor insecticide
Could Not Find
6
4
4
Incorrect Response
1
8
4
Correct Response
93
88
92
                                (Base = All Respondents)
Implications Regarding Respondents' Comprehension of and Ease of Locating
Information on Product Labels
A.     There is a need to make certain label sections easier to find quickly.

B.     There are ways in which label sections can be made easier to find quickly, read and
       comprehend.

C.     Most of the word and phrase revisions were preferred and would increase comprehension
       of the label.
56
Chapter 2: Quantitative Research

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Findings on Respondents' Hierarchy of Importance of Information on Product Labels
(Chart 2-5, Chart 2-6, Table 2-9, Table 2-10, Table 2-11, Table 2-12, Table 2-13)

13.    For all three product categories, the label information that respondents read in the store
       and before use included: brand name, directions for use, a description of what the product
       does, a description of where not to use the product, and precautions for the effects on
       personal and children's health.

14.    The frequencies of reading labels were significantly higher among outdoor pesticides
       users followed by indoor insecticides users followed by household cleaners users. This is
       true for nearly all sections of the label.
                                       Chart 2-5

                         FREQUENCY OF READING IN STORE
                   Manufact r-
                 Health Effects -
             Where Not To Use -
         Description/What It Does -
                   Directions
                  Brand Name
         0%       20%      40%       60%      80%

Indoor Insecticide    |||  Household Cleaner    S  Outdoor Pesticide

               (Base = All Respondents)
                                                                          100%
Table 2-9: Frequency of Reading in Store (%)

Outdoor Pesticide
Household Cleaner
Indoor Insecticide
Brand
Name
88
87
87
Directions
83
64
78
Description/
What It Does
82
63
77
Where
Not To
Use
79
59
71
Health
Effects
73
53
68
Manufacturer
65
56
57
                                   Base = All Respondents
                              Chapter 2: Quantitative Research
                                                                     57

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 15.     For the three product categories, respondents indicated that the following information is
        important, and they would like to locate it easily:

           "  Directions for use,

           •  Description of what the product does,

           •  Description of where not to use the product,

           •  Information about effects on personal and children's health (except for cleaners
              users), and

           •  Emergency information.
Table 2-10: What Information Found on the Packaging of Products Is Most
Important to You?
Indoor Insecticide
Directions on how to use the
product 80%
Description of what the product
does 69%
Information about effects on
personal and children's health
or safety 49%
Information on what to do in an
emergency or in case of an
accident 45%
Information about where the
product should not be used 42%
Household Cleaner
Directions on how to use the
product 83%
Description of what the product
does 72%
Information about where the
product should not be used 52%
Brand Name 49%
Information on what to do in an
emergency or in case of an
accident 48%
Outdoor Pesticide
Directions on how to use the
product 85%
Description of what the product
does 73%
Information about effects on
personal and children's health
or safety 48%
Information about where the
product should not be used 46%
Information on what to do in an
emergency or in case of an
accident 35%
                                 (Base = All Respondents)
16.    In all three product categories, respondents always indicated that the least important
       information to them on current labels was the positive environmental claims statements
       (e.g., contains no CFCs, contains no phosphates) and the name of the manufacturer. In all
       three product categories, respondents ranked label information about disposal, storage,
       ingredients, and a consumer information phone number as the least important.
58
Chapter 2: Quantitative Research

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                                          Chart 2-6

                            SUMMARY OF ITEMS NEVER READ
               o%
                       Indoor Insecticide
Household Cleaner
Outdoor Pesticide
                             Phone for Info
                             Env. Claims: No CFCs/Phosphates or Water Based
                             Ingredients
                             Manufacturer
                             Disposal Info
                             Storage Info
Table 2-1 1 : Summary of Items Never Read (%)

Phone for Info
Positive Environmental
Claims: No CFCs/
Phosphates or Water
Based
Ingredients
Manufacturer
Disposal Info
Storage Info
Indoor Insecticide
46
39
22
21
17
11
Household Cleaner
51
39
22
20
24
15
Outdoor Pesticide
41
26
15
15
11
6
                                  (Base = All Respondents)
17.    For outdoor pesticides and indoor insecticides, respondents consistently indicated that
       they do not read or give importance to statements on environmental claims (e.g., contains
       no CFCs).
                               Chapter 2: Quantitative Research
                                               59

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 18.    In all three product categories, there is a similarity between the label information
        perceived to be the most important and the information that respondents indicated that
        they wish to find most easily. The top three (in order of preference) are: (1) directions for
        use, (2) a description of what the product does, and (3) precautionary statements related
        to human health (please see Table 2-10).
Table 2-12: What Information Do You Want to Be Able to Find Most Easily?
Indoor Insecticide
Directions on how to use the
product 69%
Description of what the product
does 57%
Information on what to do in an
emergency or in case of an
accident 47%
Information about effects on
personal and children's health
or safety 43%
Information about where the
product should not be used 36%
Household Cleaner
Directions on how to use the
product 72%
Description of what the product
does 61%
Information on what to do in an
emergency or in case of an
accident 49%
Information about where the
product should not be used 44%
Information about effects on
personal and children's health
or safety 39%
Outdoor Pesticide
Directions on how to use the
product 76%
Description of what the product
does 63%
Information about where the
product should not be used 44%
Information about effects on
personal and children's health
or safety 43%
Information on what to do in an
emergency or in case of an
accident 41%
                                 (Base = All Respondents)
Table 2-13: When Deciding Which Product to Purchase, Which of the Following Types
of Information, If Any, Do You Look for?
Indoor Insecticide
Product characteristics, such as
non-staining, non-corrosive,
won't scratch surface, low odor,
etc. 63%
Will not harm wildlife, pets, fish
56%
Non-flammable 42%
Low potential for harming plants
41%
Packaging allows for reduced
contact with the product 33%
Household Cleaner
Product characteristics, such as
non-staining, non-corrosive,
won't scratch surface, low odor,
etc. 81%
Non-flammable 44%
Container or packaging
characteristics 23%
No phosphates 17%
No CFCs 13%
Outdoor Pesticide
Will not harm wildlife, pets, fish
52%
Low potential for harming plants
49%
Low potential for contaminating
ground water 48%
Packaging allows for reduced
contact with the product 40%
Non-flammable 36%
                                 (Base = All Respondents)
60
Chapter 2: Quantitative Research

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Implications Regarding Respondents' Hierarchy of Importance of Information on Product
Labels

A.     Consumers regularly looked for the information that they regard as important: the product
       purpose and personal precautionary information.

B.     People want to be able to find information they regard as important quickly. Any
       modifications of the label should allow this information to be easily identifiable.

C.     Respondents were less concerned about label information relating to storage and
       environmental issues, including disposal information, environmental claims, and
       environmental effects.
Findings on Label Format (Chart 2-7, Table 2-14)

19.    After being given a description of different formats, respondents in all three product
       categories preferred a box format on the label, like the nutrition facts box, that presents
       information consistently among products in the same category.
                             Chapter 2: Quantitative Research
61

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                               Chart 2-7
                  WHICH WAY WOULD YOU MOST LIKE
                  TO SEE THE INFORMATION SHOWN?
No Answer -
None of Above -
Box Format -
Key Facts Highlighted -
Would not Change -
Does not make a difference -
fe
g

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III

                     0%
          Outdoor Pesticide
10%     20%
Household Cleaner
                   30%     40%
                     Indoor Insecticide
50%
Table 2-14: Which Way Would You Most Like to See The Information Shown? (%)

Outdoor Pesticide
n=846
Household Cleaner
n=894
Indoor Insecticide
n=889
Does not make
a difference
18
23
18
Would not
Change
8
6
10
Key Facts
High-
lighted
29
23
30
Box
Format
39
42
34
None of
Above
2
2
2
No
Answer
4
3
5
                                (Base = All Respondents)
Implications Regarding Label Format
A.     Label comprehension can be improved by using standard formats.
B.     Ease of use encourages more frequent label reading.	
62
Chapter 2: Quantitative Research

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Findings on Respondents' Preference for FIFRA versus Non-FIFRA Product
Labels (Chart 2-8, Chart 2-9)5

20.   Over half of the respondents in the household cleaner category preferred the FIFRA label
      (the type of label appearing on EPA registered products), including the overall label and
      the subparts on directions for use, where the product should not be used, effects on
      personal health, ingredients, storage, disposal, and emergency information, over the non-
      FIFRA label (labels appearing on non-registered, but similar, products).
                                       Chart 2-8
                      WHICH OF THE TWO PRODUCT PACKAGES HAS
           THE TYPE OF INFORMATION YOU PREFER? (Household Cleaner)
                   Non-FIFRA Type 33.0%
                                                       No Preference 10.0%
                     FIFRA Type 57.0%
                               (Base = All Respondents)
       ' Non-FIFRA labels do not exist for the indoor insecticides and outdoor pesticides product categories.

                            Chapter 2: Quantitative Research
63

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                                  Chart 2-9

          FOR EACH TYPE OF INFORMATION, WHICH DO YOU PREFER
             REGARDING PRODUCT CONTENTS OR INGREDIENTS?
              Non-FIFRA 16.0%
                                              No Preference 26.0%
                     FIFRA 58.0%
                          (Base - All Respondents)
Implications Regarding Respondents' Preferability for FIFRA versus Non-FIFRA Product
Labels

A.    Consumers desire specific types of information to appear on the product label.
64
Chapter 2: Quantitative Research

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Findings on Storage and Disposal Information (Chart 2-10, Chart 2-11, Chart 2-12,
Table 2-15,  Table 2-16, Table 2-17)

21.    Outdoor pesticide and indoor insecticide users read the storage and disposal information
       significantly more than household cleaner respondents.

22.    The most frequent reasons given for not reading storage and disposal information in the
       store was that it is "information they already know," followed by "just don't read it."
                                Chart 2-10

                     REASONS WHY NEVER READ
                         INDOOR INSECTICIDES

Print Too Small -
Do Not Have Time -
Do Not Need to Know -
Already Know -
Do Not Understand -
'f Just Do Not -
••^••^^•••^•^•••••ini;
&
111
mfmttfsonfiMm
V™V"V™S!
njtfnw&wss&i

t_^_=*_J


- 	 •* 	 •* 	 ^~
^••*fri«rf|rirtfrM»rffr»«^»«^«




•*«t^

W 	 -jT 	 "W 	 3T



         Disposal
0%       10%       20%

         ||| Storage
30%       40%       50%

 £j Contents/Ingredients
Table 2-15: Reasons Why Never Read Indoor Insecticides (%)

Disposal (150)
Storage (102)
Contents/
Ingredients (200)
Just
Do Not
40
25
29
Do Not
Understand
0
1
27
Already
Know
35
48
3
Do Not
Need to
Know
19
10
29
Do Not
Have Time
1
2
2
Print Too
Small
3
4
3

No
Answer
5
17
13
   (Base = All Indoor Pesticide Respondents Who Said They Never Read Storage & Disposal, and
           Ingredients Information, Out of a Total of 889 Indoor Pesticide Respondents)
                              Chapter 2: Quantitative Research
                                                                                     65

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                             Chart 2-11
                    REASONS WHY NEVER READ
                        HOUSEHOLD CLEANER
No Answer -
Print Too Small -
Do Not Have Time -
Do Not Need to Know -i
Already Know -
Do Not Understand -
Just Do Not -

i i
l^n*^natyn£iki(nnMn
^
j^™fef"
nqpajf

H***\***i
m>
.uAu6i
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i
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•


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	 2
imlhmmmmi
s

mmmmmmi

                0%    5%   10%   15%

    (2  Disposal           H|  Storage
            20%   25%   30%   35%   40%

                 [5  Contents/Ingredients
Table 2-16: Reasons Why Never Read Household Cleaner (%)

Disposal (216)
Storage (131)
Contents/
Ingredients (201)
Just
Do Not
38
21
31
Do Not
Understand
0
1
15
Already
Know
32
39
10
Do Not
Need to
Know
19
20
31
Do Not
Have Time
3
6
4
Print Too
Small
4
3
3
No
Answer
9
15
11
(Base = All Household Cleaner Respondents Who Said They Never Read Storage & Disposal, and
Ingredients Information, Out of a Total of 894 Household Cleaner Respondents)
66
Chapter 2: Quantitative Research

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                               Chart 2-12
                        REASONS WHY NEVER READ
                          OUTDOOR INSECTICIDES

Print Too Small -
Do Not Have Time -
Do Not Need to Know -
Already Know -
Do Not Understnd -
Just Do Not -
f jr i
	 f 	 i 	
1MB ••••••
" ^C ^g
^








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                  0%
             Disposal
10%        20%

 HI  Storage
30%        40%

[^  Contents/Ingredients
                                                                         50%
Table 2-17: Reasons Why Never Read Outdoor Insecticides (%)

Disposal (93)
Storage (54)
Contents/
Ingredients (127)
Just
Do Not
50
28
22
Do Not
Understand
1
0
33
Already
Know
28
30
3
Do Not
Need to
Know
14
13
32:
Do Not
Have Time
5
2
3
Print Too
Small
4
6
6
No
Answer
5
26
10
 (Base = All Outdoor Pesticide Respondents Who Said They Never Read Storage & Disposal, and
         Ingredients Information, Out of a Total of 846 Outdoor Pesticide Respondents )
23.    The following represents the findings of an "open-ended" question regarding methods of
       disposal:6

          •  In all three categories, most respondents disposed of pesticides and cleaner
              products or packages in the trash;

          •  Household cleaner users recycled more frequently than those responding in the
              indoor and outdoor product categories;
       6It is not known whether respondents were referring to the disposal of containers, unused product, or both.
                              Chapter 2: Quantitative Research
                                                         67

-------
 24.
    •  One in ten outdoor pesticide users disposed through special collections, which is
       more than users of indoor insecticides and cleaners;

    •  Less than 10% overall used special collections;

    "  Cleaner users found it acceptable to dispose of products/residues down the drain;

    •  Few users indicated that they disposed of products down the drain or diluted and
       used them up; and

    •  Virtually no consumers said they call the city or county for disposal advice;

There were no significant differences in responses from respondents in the states with
strong household hazardous waste programs, versus those respondents from states that do
not have strong household hazardous wastes programs.
 Implications Regarding Storage and Disposal Information

 A.     Storage and disposal issues are of low priority and are not important to consumers.
 Findings on Recycling Claims and Symbols (Chart 2-13, Table 2-18)

 25.    A high percentage of survey participants responded either "Not really sure" or gave an
       incorrect response for every question under each symbol. This was true even allowing for
       local recycling programs that might make some answers correct for panelists in those
       localities.
68
                     Chapter 2: Quantitative Research

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                                 Chart 2-13
          WHAT DO YOU THINK THIS ICON/PICTURE MEANS?
                         (Plastic Material Code)*
                       No Answer
      Package Made of Recycled Steel - §
     Package Made of Recycled Paper
             Package Not Recyclable
             100% Recycled Material
Package Contains X% Recycled Material -jg^SF1
           Environmentally Preferable
         Package Is Recycled Material
                Package Recyclable
0%   5%  10%  15% 20%  25%  30%  35%  40%
Household Cleaner        Indoor Insecticide
^•A^h AB^BH^
§
»s
^
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P ^
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IB
^£ •!•£•! ^ ^


-I '
• mfmmmUmmmfmmmm
\ 	 1 	 '
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immfmrnmi

•mbvm.
•
         Outdoor Pesticide
Table 2-18: What Do You Think This icon/Picture Means?(%)*

Outdoor
Pesticide
Household
Cleaner
Indoor
Pesticide

Outdoor
Pesticide
Household
Cleaner
Indoor
Pesticide
Not Really
Sure
37
39
40
100%
Recycled
Material
5
3
4
Package
Recyclable
35
36
33
Package Not
Recyclable
3
2
2
Package is
Recycled
Material
27
21
24
Package
Made of
Recycled
Paper
1
2
2
Environ-
mentally
Preferable
10
12
8
Package
Made of
Recycled
Steel
1
1
1
Package
Contains X%
Recycled
Material
3
5
4
No Answer
7
8
8
                             (Base = All Respondents)
               * Please refer to Question 9 on the mail questionnaire, Appendix 2-4
                         Chapter 2: Quantitative Research
                                                69

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 26.
 27.
 28.
 The symbols with descriptive language (e.g., "100% Recycled Paperboard") did provide
 some improvement in response accuracy.  However, the correct response rate was less
 than 75% in every case and usually less than 60%.

 For the HDPE question, there was no answer selection for the type of plastic from which
 the package was made. This confounded the interpretation of responses to.that question,
 since respondents may have felt compelled to provide some other answer.

 The demographic groups and other subgroups that demonstrated more capability for
 reading and understanding labels identified the correct responses for these symbols more
 frequently.  These same consumers also tended to view products bearing these symbols as
 environmentally preferable.
 Implications Regarding Recycling Claims and Symbols
 A.
 B.
The effectiveness of the tested symbols in communicating with the general public is not
great. However, this seems to be related to the complexity of the messages carried and
the lack of a compelling motivator to learn.

The positive correlation of comprehension with additional information in the symbol and
inferred environmental benefit indicates that these are motivators for some consumers.
 Findings on Product Label Signal Words (Chart 2-14, Chart 2-15, Chart 2-16)

 29.    Respondents understood that the terms DANGER, WARNING, and CAUTION
       characterize a level of risk or personal hazard. They understood the three terms to be
       generally relative, with DANGER describing the highest risk, WARNING a medium risk,
       and CAUTION a lower risk. Respondents also perceived the range of risk described by
       the three words to start at a medium, rather than at a low, risk level.  Even CAUTION
       was perceived by over half of the respondents to describe a lower to moderate level of
       risk, not a low risk.
70
                     Chapter 2: Quantitative Research

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                                Chart 2-14

     WHAT LEVEL OF RISK DO YOU ASSOCIATE WITH A PRODUCT
            THAT HAS THE FOLLOWING WORDS ON LABEL?
% 4 or 5*
                Mean Based Scale From 1 to 5, where 5=High Risk
   100%
    Caution


Indoor Insecticide
     Warning


Household Cleaner
                                                          Danger


                                                    Outdoor Pesticide
                          (Base = All Respondents)

    a Percent of respondents who associated the signal words with a level of risk of four or five.
                        Chapter 2: Quantitative Research
                                                71

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                                     Chart 2-15

            WHAT LEVEL OF RISK DO YOU ASSOCIATE WITH A PRODUCT
                  THAT HAS THE FOLLOWING WORDS ON LABEL?
                     Mean Based Scale From 1 to 5, where 5=High Risk
  Caution

Indoor Insecticide
                                        Warning

                                 ^2  Household Cleaner

                               (Base = All Respondents)
     Danger

Outdoor Pesticide
30.    None of the respondents mentioned the signal word as one of the things they use to
       determine the possible harmful effects of a product.
                                     Chart 2-16

            WHEN SHOPPING DO YOU LOOK ON PRODUCT PACKAGING
                       FOR POSSIBLE HARMFUL EFFECTS?
           Outdoor Pesticide
          Household Cleaner -
           Indoor Insecticide -
                                                                     100%
                               (Base = All Respondents)
72
          Chapter 2: Quantitative Research

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31.     Just under half of respondents agreed either completely or somewhat that the words
       CAUTION, WARNING, and DANGER on a product mean the same thing to them.
Implications Regarding Signal Words on Product Labels

A.     Consumers do not understand the EPA's purpose for using signal words.

B.     All three words convey some level of concern.
Findings on Respondents' Sources of Information and Education (Chart 2-17, Table 2-19)

32.    Besides the packaging, respondents identified the top sources to which they referred for
       product information to be (see Chart 2-17):

          •  Indoor insecticides — store displays, TV ads, friends/family/co-workers, product
             brochures, and magazine ads;

          •  Outdoor pesticides — store displays, product brochures, friends/family/co-
             workers, store salespersons, and TV ads; and

          •  Household cleaners — TV ads, friends/family/co-workers, store displays,
             magazine ads, product brochures;

33.    One in five outdoor pesticide users would contact a university or county extension service
       for more information about a product.
                             Chapter 2: Quantitative Research
73

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                                  Chart 2-17
      BESIDES PACKAGING WHERE ELSE DO YOU GET INFORMATION
                     ABOUT THE PRODUCTS YOU USE?
             Internet/Web
                 Library -
       Government Agency -
          Consumer Group -
       Environmental Group -
           Poison Control -
           Univ. Extension -
             Manufacturer
               Brochure
    Friend/Family/Co-Worker -
                    TV
                At Store -
      Newspaper/Magazines

                      0%

           Outdoor Pesticide

^Jf~~'~M_
25?3C~!i
frMgfc^^
'

gfa^a^






r
i — '




— —

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	 1
i





























  10%
     20%
30%
40%
50%
60%
70%
[  Household Cleaners
                            Indoor Insecticide
Table 2-19: Besides Packaging Where Else Do You Get Information
About the Products You Use? (%)

Outdoor
Pesticide
Household
Cleaner
Indoor
Pesticide

Outdoor
Pesticide
Household
Cleaner
Indoor
Pesticide
Newspapers/
Magazines
54.7
65.8
55.8
Poison
Control
7.4
5.3
11.6
At Store
69.7
47.5
53.0
TV
49.1
66.3
49.6
Environmental
Group
7.6
5.6
7.0
Friend/
Family/
Coworker
44.4
55.9
38.0
Consumer
Group
7.0
7.2
7.0
Brochure
44.7
32.7
37.6
Govern-
ment
Agency
10.3
2.2
5.1
Manufacturer
16.8
14.7
17.9
Library
5.9
3.1
6.0
University
Extension
17.0
3.0
11.8
Internet/
Web
5.4
3.0
5.8
                               (Base = All Respondents)
74
Chapter 2: Quantitative Research

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 Implications Regarding Respondents' Sources of Information and Education
A.    Consumer education and information efforts should design and deliver to the sources that
       people use.

B.    Consumers expect to get information through traditional means, rather than seeking it
       through companies or the government.

C.    Extension agents are also a target audience for the consumer education program.
Findings on Ingredients Information (Chart 2-18, Chart 2-19, Chart 2-20, Chart 2-21,
Table 2-20)
34.
35.
36.
 37.
38.
Approximately 90% of the telephone survey respondents were able to find and properly
identify the ingredients/contents section of the label for all three product categories. The
ability to find this section on the cleaners label, however, was significantly lower than on
the other labels. Demographic subgroups did not show any surprising subgroup trends in
their ability to find this label section.

After trying to find various sections during the phone survey, nearly 90% of the
respondents stated that label information was positioned where they expected it to be.
There were statistical differences among all categories, with satisfaction being greatest
with outdoor  pesticide and poorest with cleaners, although cleaners still received an
87.6% affirmative response.  Of the specific requests for change, the highest was
"ingredients should be on the back label."  However, only 2 to 4% of all respondents
voiced that request.

In all three product categories, of those respondents who never read the  ingredients
section (approximately 25% for all categories), an unusually high percentage of them did
not read it because they did not understand the information in the section.

When asked if they look for ingredient informations approximately 40% responded
affirmatively  for the household cleaner and indoor insecticide product categories, but a
statistically higher percentage (48%) answered "yes" in the outdoor pesticide category.
The most prominent reason for reading this section was product comparison. However,
approximately 15% claimed concern for health of a family member; this was higher (and
the difference statistically significant) for indoor pesticide and household cleaners.

In all three product categories, few survey respondents specified a label change request,
but the highest response (~3%) was "list all ingredients."
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                                        Chart 2-18

                          WHEN SHOPPING DO YOU LOOK FOR
                         INFORMATION ABOUT THE INGREDIENTS?
            Outdoor Pesticides
           Household Cleaners -
            Indoor Insecticides -
      20%       40%

       0  Yes   H  No

    (Base = All Respondents)
                                                    60%
80%
100%
Table 2-20: Why Do You Look for Information about Ingredients?
Indoor Insecticide
(n=343)
I want to compare different
products 66%
I or another household member
want to avoid using certain
chemicals because of allergies
or other health related reasons
41%
I'm looking for the name of a
specific ingredient 38%
I want to know the scientific
names of the ingredients 22%
Household Cleaner
(n=338)
I want to compare different
products 64%
I or another household member
want to avoid using certain
chemicals because of allergies
or other health related reasons
47%
I'm looking for the name of a
specific ingredient 25%
I want to know the scientific
names of the ingredients 1 6%
Outdoor Pesticide
(n=408)
I want to compare different
products 57%
I'm looking for the name of a
specific ingredient 30%
I or another household member
want to avoid using certain
chemicals because of allergies
or other health related reasons
27%
I want to know the scientific
names of the ingredients 14%
    (Base = All Respondents Who Said They Look for Ingredient Information While Shopping)
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                          Chart 2-19a
   IF AN INDOOR INSECTICIDE LABEL WERE TO PROVIDE YOU
    WITH ADDITIONAL INFORMATION ABOUT INGREDIENTS
       WHICH OF THE FOLLOWING WOULD YOU PREFER?

           Full Disclosure 31.0%
                                          No Preference 12.0%
                                          Current Format 14.0%
Categories with Purpose 34.0%
                                   Categories Only 9.0%
                    (Base = All Respondents)
                          Chart 2-20*
     IF A HOUSEHOLD CLEANER LABEL WERE TO PROVIDE YOU
       WITH ADDITIONAL INFORMATION ABOUT INGREDIENTS,
        WHICH OF THE FOLLOWING WOULD YOU PREFER?
  Categories with Purpose 43.0%
Full Disclosure 25.0%
                                            No Preference 5.0'
                                          Current Format 21.0?

                                Categories Only 6.0%
                     (Base = All Respondents)
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                                 Chart 2-21=
        IF AN OUTDOOR PESTICIDE LABEL WERE TO PROVIDE YOU
          WITH ADDITIONAL INFORMATION ABOUT INGREDIENTS,
            WHICH OF THE FOLLOWING WOULD YOU PREFER?
     Categories with Purpose 46.0%
              Full Disclosure 25.0%
                                                   No Preference 6.0%
                                                  Current Format 15.0%
                                          Categories Only 8.0%
                          (Base = All Respondents)

* (For charts 2-19,2-20, and 2-21) Please refer to Question 4c in the mail questionnaires in
Appendix 2-4.

39.    When given a choice of "ingredients" formats, three out of four respondents chose less
       than full disclosure (providing names and % of all ingredients). Options listing
       categories of ingredients along with a description of the purpose of the ingredients were
       preferred.

40.    One in eight respondents used the ingredient statement to determine possible harmful
       effects from the ingredients listed.

41.    In each of the three product categories, the phrase "other ingredients" was not fully
       understood.

42.    "Ingredients" was ranked seventh among sections for importance, but well below the top
       six in all three product categories. It was also infrequently cited as a section to be found
       most easily.

43.    The label preference for the ingredients section of the FIFRA vs. non-FIFRA cleaners
       label was comparable to the overall preference (58% favoring FIFRA) and the highest
       preference for FIFRA labeling of the individual sections tested.
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Implications Regarding Ingredients Information on Product Labels

A.     Characteristics of the cleaner label make it somewhat more difficult to find the contents
       statement on that label. Cleaners are perceived to be inherently different than pesticides.

B.     Consumers are likely to be satisfied with current placement of ingredients if the format
       and purpose of this section are clear.

C.     Consumers do not know how to use the ingredients statement as currently presented.

D.     Ingredients are easier to find and read in tabular form on the front label panel.

E.     While a small group of people have a strong desire for full ingredient disclosure on
       labels, full disclosure is not required to meet the needs most consumers cite for ingredient
       information.

F.     Ingredients are sometimes relied upon as a surrogate for hazard information.
Findings on Respondents' Attitude Toward Product Categories

The following table captures reactions to consumer values in the attitude battery for each of the
three product categories. (Please refer to question 11 in the indoor insecticide and outdoor
pesticide mail questionnaires and question 12 in the household cleaner mail questionnaire in
Appendix 2-4.)
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ATTITUDE BATTERY KEY
             Number on top left of each cell indicates percentage of respondents who said they
             "agree completely" with the statements given.

             Number on top right of each cell indicates percentage of respondents who said
             they either "agree completely" or "agree somewhat" with the statements given.

             Number in the middle center of each cell indicates the deviation from the mean.
             The higher the deviation, the more strongly the attitude is held.

             [Brackets] indicate a negative deviation from the mean.
Table 2-21: Statements Regarding Respondents' Attitude Toward Product
Categories
Statement (Indoor Insecticide
It is important that the packaging
tell me how soon I/my
children/pet can re-enter the
treated area
Labels should say whether the
product should not be used by or
around pregnant women
The level of harmful effects of a
product plays a role in deciding
which product I purchase
It is important to know the
minimum time before I can safely
re-apply the product
I know how to use so there is no
need to read the label
Using product safely is common
sense
The more product I use at a time,
the more effective it will be
No need to worry about storage if
CR closure is used
Unused product should be
disposed down the drain

60.2 89.5
1.46
49.2 82.3
1.26
38.2 86.0
1.20
1.6 12.1
[1.02]
40.2 83.2
1.10
1.3 8.4
[1.03]
4.1 14.7
[1.00]
4.6 11.1
[1.08]
Household Cleaner

53.5 85.2
1.34
35.2 77.0
1.05
-
1.6 12.8
[0.86]
40.8 84.3
1.14
0.8 8.4
[0.93]
7.6 19.1
[0-79]
20.3. 46.6
0.23
Outdoor Pesticide
65.4 93.5
1.56
56.2 87.2
1.38
44.0 81.7
1.19
-
0.6 4.7
[1.31]
32.9 78.3
0.91
0.7 7.5
[1.05]
3.6 11.0
[1.18]
1.6 3.0
[1.54]
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Table 2-21 : Statements Regarding Respondents' Attitude Toward Product
Categories
Statement
I know what to recycle so I don't
need to read the label
I don't worry about chemicals in
products
Would like information on long
term effects on label
I always purchase the least
harmful product
It is more important to me to
know which ingredients might be
more harmful than how effective
they are
Peel open label has more
information than flat label
Repeat as necessary means
reapply as soon as see bugs
Overall satisfaction with current
label information
I feel more comfortable if all
ingredients are listed
Need more information on how
much or how long to apply for
desired result
For disposal, I rely more on
experience than the label
For use, I rely more on
experience than label
It is necessary to wrap in paper
before disposal
Easy to find product information I
need
Information on the label is hard
to understand
Indoor Insecticide
3.1 10.9
[0.91]
5.0 17.9
[0.92]
32.6 71.9
0.95
32.1 67.2
0.86
31.6 68.5
0.81
-
26.9 69.1
0.76
15.2 68.7
0.73
26.9 52.8
0.58
17.9 57.9
0.56
5.3 26.4
[0.45]
5.7 29.8
[0.31]
17.3 35.6
0.14
12.7 59 .5
0.52
10 8 49.2
0.24
Household Cleaner
2.5 16.7
[0.66]
4.0 22.4
[0.66]
25.1 58.6
0.66
25.4 57.7
0.65
.".
-
-
11.4 64.8
0.64
24.4 55.2
0.60
-
6.6 35.4
[0.19]
7.2 43.0
0.05
5.7 16.1
[0.51]
11.6 57.1
0.50
8.2 44.7
0.20
Outdoor Pesticide
1.3 7.0
[1.08]
3.2 16.5
[0.94]
30.1 67.5
0.87
34.3 68.4
0.89
27.6 63.7
0.69
26.6 65.5
0.80
-
10.1 64.4
0.62
27.4 57.9
0.63
-
1.9 17.7
[0.84]
1.5 14.7
[0.86]
19.3 47.9
0.46
107 53.8
0.40
13.0 57.5
0.46
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Table 2-21 : Statements Regarding Respondents' Attitude Toward Product
Categories
Statement [Indoor Insecticide [Household Cleaner
The government insures the
product is safe to use
If I can buy in trusted store, the
product must be safe to use
Fewer possible harmful effects
means poorer performance
I read labels because a
household member has allergy/
health problem
Disposal instructions on the label
don't agree with my community
It's OK to open the peel open
label in the store
The manufacturer assures
product safety
I don't need complete listing of
ingredient Information; I don't
understand it anyway
Environmental or natural
products often don't work well
CAUTION/ WARNING/
DANGER all mean the same
thing to me
7.4 36.3
[0.10]
15.3 36.8
[0.08]
4.0 26.9
[0.24]
19.1 34.8
[0.15]
3.6 15.9
[0.29]
-
11.6 38.4
0.03
12.4 41.7
[0.03]
6.0 40.0
0.08
16.2 48.4
0.07
5.7 27.0
[0.32]
12.6 30.8
[0.22]
2.3 16.2
[0.48]
13.4 28.2
[0.34]
2.2 22.0
[0.12]

10.2 38.3
[0.02]
8.3 37.3
[0.10]
3.5 29.6
[0.14]
15.9 49.0
0.11
Outdoor Pesticide
3.8 25.8
[0.40]
9.5 25.5
0.40]
7.2 39.1
0.12
12.1 27.1
[0.35]
3.1 15.0
[0.31]
23.7 48.4
0.29
6.3 29.8
[0.30]
8.4 34.9
[0.25]
6.0 36.2
0.03
13.9 44.0
[0.06]
Findings are as follows:

44.    The highest response to attitude questions was for personal health and safety information
       and for instructions, especially those associated with safe use.

45.    The consumer attitude toward household cleaners was different from attitudes toward the
       other two product categories.  Significant differences were found from both indoor
       insecticides and outdoor pesticides in about 60% of the questions, and at least one other
       category in about 95% of the questions common to all categories.

46.    In approximately two-thirds of the questions common to indoor insecticides and outdoor
       pesticides, there was a significant difference in attitudes between those two product
       categories.
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47.    The largest numerical differences in response were those for down the drain disposal,
       knowing what to recycle without label assistance, and greater reliance on experience than
       label information for either disposal or use. In each case, respondents showed much less
       concern and/or greater familiarity for household cleaners.

48.    Respondents understood that cleaners may be disposed of down the drain but indoor
       insecticides and outdoor pesticides should not be.
Implications Regarding Respondents' Attitudes Toward Product Categories
A.     Household cleaners are perceived to be lower risk than pesticides in both use and
       disposal. Consumers are much more familiar with these products and are less likely to
       read the label for information.

B.     Indoor insecticides are more familiar to respondents than outdoor pesticides so the
       comfort level in using those products is greater. However, the indoor usage is associated
       with greater concern about health effects.

C.     Consumers want specific information on use of these products so they can assure
       personal, family, and pet safety while getting the desired performance.
Findings on Germ Killing Potential Information

49.    Respondents were asked to rank, from high to low, the germ killing potential of each of
       the following terms: deodorizer, cleaner, sanitizer, anti-bacterial, and disinfectant.
       Respondents indicated the germ killing power of each individual term, and generally
       ranked all the terms hi the correct order.  The exception, however, was that respondents
       saw "anti-bacterial" as having more germ killing potential than either disinfectants or
       sanitizers, when, in fact, "anti-bacterial" refers to any product which kills bacteria.

50.    When asked on the phone survey to define "disinfection," over 80% of respondents
       answered correctly.

Findings on Product Category Comparisons

51.    The labels of household cleaners are less completely read than those of indoor
       insecticides and outdoor pesticides. Fewer consumers routinely  read any section of the
       label on cleaners except the brand name.

52.    For household cleaners label readers:

          • Brand name is of higher importance, and

          • Health and safety information of lower importance.
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 53.    For all sections of the label, the indoor insecticide product label was found to be more
        effective in communicating the right amount of information with a greater specificity.

           •  Active and Other Ingredients — indoor insecticide better than both household
              cleaner and outdoor pesticide,                                               !

           •  Directions for Use — indoor insecticide better than outdoor pesticide and much
              better than cleaner,
                                                                                        I
           •  Storage and Disposal — outdoor pesticide worse than either indoor insecticide or
              household cleaner,

           •  Precautionary Statements — both indoor insecticide and outdoor pesticide better
              than household cleaner, and

           •  First Aid— both indoor insecticide and household cleaners better than outdoor
              pesticide.

 54.    About twice as many consumers had purchased cleaning products as had purchased either;
       indoor insecticides or outdoor pesticides.

 55.    Many more consumers disposed of unwanted household cleaning products and/or
       containers by rinsing out, pouring down the drain, throwing in the trash unwrapped, and
       recycling. The indoor insecticide and outdoor pesticide products and containers were
       wrapped before being placed in trash much more than household cleaners were.
Implications Regarding Product Category Comparisons
A.     Household cleaners have greater familiarity and lower perceived risk for consumers. This
       results in more purchasing by brand name and less label reading. The most effective
       labels are on indoor insecticides, possibly because these labels are routinely read by
	consumers with a higher level of concern.
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                                   CHAPTER 3
                     QUALITATIVE RESEARCH
The Qualitative Subgroup included EPA staff, the CLI Task Force, and the EPA Partners.  (See
Appendix 1-6 for the complete list of Qualitative Subgroup members.) The Qualitative
Subgroup used the results from the Phase II quantitative research performed during the summer
of 1998 (for details, see Chapter 2) to determine the content of the qualitative testing. This
quantitative research performed during April and June 1998 found that consumers generally do
not read environmental information on product labels for outdoor pesticides, household cleaners,
and indoor insecticides. Survey respondents did indicate, however, that a standardized for mat
would help them to understand label information.

The Qualitative Subgroup decided to perform qualitative consumer research, in the form of focus
groups with consumers, to examine label format issues and consumer motivations and behavior
in depth.  (See the section that follows on "Research Design" for more information about the
structure of focus groups.) The Qualitative Subgroup used several types of input to develop
seven "key learning objectives," which were intended to guide the qualitative research. Inputs
included the CLI Stakeholder comments gathered during Phase I research, the results of one-on-
one qualitative interviews performed during Phase I, and the quantitative research completed in
Phase II.  The key learning objectives for the qualitative research, and the assumptions on which
they were based, follow:
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Qualitative Research Learning Objectives — Determine:

Consumer preference for a specific format for the presentation of standardized information. This
is based on an assumption that a comparison is needed to test consumer preferences between a "box"
format and other standardized designs of information grouped together, for example standard short
phrases, with the same information content. This also assumes that it is possible to have more than one
"box" or other standardized information presentation format on a given label.

Consumer understanding of the same information presented in different formats. This is based on
an assumption that a comparison is needed to test whether one format does a better job than others of
improving consumer comprehension of the information presented.

Consumer preference for which information should be presented in box(es) or other standardized
formats of information groups together. This assumes that an interactive interview method will be
used; for example, giving participants the opportunity to arrange information on a Velcro board. This
also assumes that it is possible to have more than one "box" or standard format on a given label, because
consumers may look for different information at different times or decision occasions.

Consumer preference for where particular groupings of information should be located on the
product label.  This is based on an assumption that certain information should be grouped together in a
box or standard format(s) and that this grouping or groupings could be  located on the label by decision
occasion, that is, collecting information sought at the time of purchase,  the time or use, or when storing
or disposing of the product. This also assumes that it is possible to have more than one box or standard
format on a given label.

Consumer understanding of the existence of a hazard hierarchy in the signal words CAUTION,
WARNING, DANGER, when conveyed graphically, and of the point in the hierarchy on which a
given product falls. This is based on the assumption that a graphical presentation of the hierarchy may
improve consumer comprehension of the meaning of the signal words, and that different representations
may have different degrees of success in conveying this information. Various graphical interpretations
should be tested, including such things as a variegated color bar graph, thermometer, traffic light, etc.,
where the image includes a pointer or other device to indicate where on the progression the specific
product fits.

Consumer preference for a particular graphical representation of the CAUTION, WARNING,
DANGER hierarchy and product status information. This acknowledges that preference may or may
not relate to the effectiveness of a particular design in correctly conveying understanding of the
hierarchy information.

Consumer understanding of the association between the product ingredients, the hazard(s), and the
relative hierarchy. This is based on an assumption that consumers will better understand the
importance of the safe use of products if safety-related information, including environmental, hazard,
and hierarchy information, is presented together.
The EPA sent out a Request for Proposal (an official document published in the Commerce
Business Daily to identify qualified organizations that conduct qualitative research). The
Newman Group, Ltd., was contracted to work with EPA.  EPA funded the qualitative research.
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                                Research Design

The strength of qualitative research is that it can be used to identify specific areas of
investigation that may have not been considered previously, or issues of concern to specific
populations. Qualitative research may also be used to "frame" issues — that is, investigate ways
to approach issues — or explore ways to word survey questions. It can also be used to further
explore quantitative data.

It is important to recognize that results obtained from qualitative research cannot be generalized
to a larger population, because qualitative research does not produce statistically significant and
projectable findings. It is important that qualitative data not be misinterpreted or misrepresented
in quantitative terms.  For example, the statement "9 of the 12 participants interviewed" should
not be interpreted as meaning "75%  of the population," because this would incorrectly indicate
that the 12 participants who were interviewed represented a statistically accurate sample.  Any
findings from qualitative research should be validated if needed using quantitative methods.

Qualitative research methodologies share certain elements:

       •      a trained moderator;

       •      specific recruitment of study participants who qualify, based on detailed screening
              criteria; and

       •      a discussion guide designed to obtain the answers to the key research questions.

The qualitative research for Phase II of the CLI was designed to find out more about how
consumers respond to various types  of information and formats presented on the labels of
outdoor pesticides, household cleaners, and indoor insecticides, and to probe in more depth some
of the information received from the written surveys. The research design consisted of a series of
"mini" focus groups with users of outdoor pesticides, household cleaners, and indoor
insecticides. The mini focus group format (three to five participants) was thought to be the most
useful for gaining a more in-depth understanding of consumers' reaction to a variety of label
designs.  The mini focus group environment allows for greater participation by each respondent
than does a larger focus group (usually about eight to ten people).  A small focus group also
allows people to ask questions of each other and have more free-flowing discussions. The
Qualitative Subgroup felt that the CLI could learn more from this type of discussion than from a
question-and-answer or one-on-one interview format.

Recruitment Criteria

Only product users were included in this study, to ensure that group participants would have
some baseline familiarity with product labels. This knowledge could be used as a benchmark to
probe participants' understanding of and reaction to the labels presented during the groups. A
decision to include non-users would have introduced too  much variability into the study design.

Three cities were selected for the research: Ft. Lauderdale, FL; Dallas, TX; and Chicago, IL.
These locations are known to have a large insect population that affects consumers, and therefore
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 many consumers in these areas purchase and use indoor insecticides and outdoor pesticides. This
 large consumer base was expected to make selection of group participants easier.
                                                                                        j
 Participants were recruited by telephone, using a recruitment screening questionnaire that clearly
 identified them as product users for one of the three selected product categories. (The
 recruitment screening questionnaires are reproduced in Appendix 3-1.) Recruiting specifications
 for each product category follow:

 Mini Focus Groups to Discuss Outdoor House and Garden Pesticides
                                                                                        \
 Men and women who were most responsible for the purchase and usage of outdoor house and
 garden pesticides were recruited for these groups. Qualified respondents had purchased an
 outdoor house and garden pesticide at least once in the past six months, and had used the
 purchased pesticide at least once.  These people were treating a broad range of insect types (e.g.,
 the Florida groups included some people who were treating fire ants).  A few people who used
 weed-and-feed combination products (fertilizer and insecticide) were included.  People were
 recruited to represent a variety of demographics (age, work status, home owner/renter,
 occupation, and gender, within each mini-group). All professional lawn service providers,
 exterminators, and farmers were excluded from these groups, so as not to bias the responses of
 the other participants, since these groups receive specific training on these types of products..

 Mini Focus Groups to Discuss Indoor Insecticides

 Men and women who were most responsible for the purchase of indoor insecticides for their
 household were recruited for the mini focus groups on indoor insecticides. Qualified respondents
 had seen ants, roaches, or fleas in their residence, had purchased an indoor insecticide at least
 once in the past six months, and had used the insecticide purchased at least once. People
 representing a variety of demographics (age, work status, home owner/renter, occupation, and
 gender, within each mini-group) were recruited.  All professional  exterminators were excluded
 from this research so as not to bias the responses of the other participants.

 Mini Focus Groups to Discuss Household Cleaners

 Men and women who were most responsible for the purchase and use of household cleaners were
 recruited for these groups. Qualified respondents had purchased a household hard surface
 cleaner at least once in the past six months, and had used the product at least once in the past
 month.  People representing a variety of demographics (age, work status, home owner/renter,
 occupation, and gender, within each mini-group) were recruited. People who worked in
 professional cleaning services were excluded to prevent any professional bias, based on
 familiarity or training with the products.

All Groups

Additionally, the recruits for all three types of groups met the following criteria:

       •     they  had not participated  in another focus group within the past six months;
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       •     they had not personally been employed, or had immediate family employed, in
             advertising, marketing research, manufacturing, sales, or distributing of indoor
             insecticides, outdoor pesticides, or household cleaners;

       •     they had passed a project articulateness check (see the last question on the
             recruitment screening questionnaire);

       •     they included a mix of responses to the question about whether or not they read
             labels for the product category discussed;

       •     they included a mix of families with and without children;

       •    : they included a mix of families with and without pets;

       •     they included a mix of families who were light or heavy users of the product
             category; and

       B     they included a mix of urban and suburban dwellers.

Development of the Discussion Guides

The Qualitative Subgroup members and The Newman Group, Ltd. jointly developed discussion
guides to be used in moderating the mini focus groups. The discussion guides were designed to
obtain as much information as possible that would address the seven key learning objectives
mentioned at the beginning of this chapter.  The guides were designed to encourage relatively
open-ended conversation, allowing consumers to discuss their actual experiences when reading
and using labels. Copies of the discussion guides for each product category appear in Appendix
3-2.

Due to the fluid, qualitative nature of focus group research and to the fact that 27 groups were
held, topics sometimes were approached in an order other than that described in Appendix 3-2,  or
were worded in a slightly different manner. Also, the discussion guides were refined throughout
the course of the research, which enabled later groups to discuss new issues and view different
ways of expressing concepts on product labels. Not all groups discussed every issue that is
mentioned in this chapter.
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                     Process of the Mini Focus Groups

 A total of 27 mini focus groups were held, involving 112 participants.  Each group included three
 to five people. All groups were moderated by The Newman Group, Ltd. Participants were
 encouraged to talk freely and initiate conversations with each other, as well as to respond to the
 questions posed by the moderator. Each group met for between 90 and 120 minutes. Verbatim
 written transcripts, videotapes, and summaries were made of all sessions for the express purpose
 of writing the findings report.
Table 3-1: Number of Mini Focus Groups for Each City and Product Cateaorv
Area
Indoor Insecticides
Outdoor Pesticides
Household Cleaners
Ft. Lauderdale
3
3
3
Dallas
3
3
3
Chicago
3
3
3
 "Mock labels" were created for the focus groups, in order to show representative label features
 and concepts to guide and spark discussion (see Appendices 3-3 — 3-6). These mock labels gave
 consumers an opportunity to personally examine many variations of product label information
 and provide immediate feedback.  None of these mock labels existed for use on any existing
 products. They were produced for the mini focus groups by manufacturers of the product
 categories being discussed. The mock labels underwent some changes throughout the course of
 the groups, as people made suggestions or expressed opinions related to the graphical
 representation or signal words and the use of boxes.

 During each session, after some preliminary information on labeling was obtained, the moderator
 asked participants to refer to certain mock labels from their packet to coincide with a specific
 section of the discussion. By the end of the discussion, participants had viewed all of the mock
 labels for their product category. The order in which the different sections of labels  were
 discussed was intentionally varied from group to group, so as not to encourage any particular
 "position bias." (For example, if the Ingredients section was discussed first in one group, it was
 discussed second in another group.) The participants were told that at any time they could say
 they preferred the "Control Label," which represented the typical way labels in the category were
 currently being designed. Also, during some of the later sessions, participants were asked to
 evaluate  certain precautionary phrases that appear on labels (see Appendix 3-8).

 At the end of each session, a short  amount of time was devoted to obtaining participants' input
 on various draft logos (see Appendix 3-7) for a proposed "Read the Label FIRST!" Consumer
 Education Campaign.  (Chapter 6 discusses the CLI Consumer Education Campaign in more
 detail.)

 The topics that follow discuss the reactions of participants in the mini focus groups to different
 types of label information, including Signal Words, Directions for Use, and Precautionary
 Language. The participants also discussed alternative formats for label information.  A list of the
 mock labels used for each topic appears at the end of that section. The actual mock labels that
 participants discussed can be found in Appendices 3-3 — 3-6.  (Appendix 3-3=mock  labels
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shown for signal words; Appendix 3-4=mock labels for outdoor pesticides; Appendix 3-5=mock
labels for household cleaners; Appendix 3-6=mock labels for indoor insecticides.)
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                   Findings from the Mini Focus Groups

 This section summarizes the most notable overall findings from the mini focus groups, and
 includes selected illustrative quotations from participants. Text in [square brackets] was added
 by the moderator to clarify the comment. At the end of each quote readers will find the category
 of product being discussed, the time of the mini focus group, and the state in which it was held.

 Past Experience and Product Selection

 At the start of each mini focus group, and before any mock labels were introduced, the moderator
 asked the participants to talk in general about their past experience with reading labels. They
 discussed the following issues:

        •     why they did or did not tend to read product labels;

        •     in what situations they tended to read labels in general, and specifically when they
              tended to read labels on the category of products they had been recruited to
              discuss;

       «     what they looked for when they read these labels;
                                                                                       j
       •     how satisfied they were with the information that was currently available;
                                                                                       i
       •     whether the information was easy to understand;

       •     whether they would have liked to see any additional information on these product
              labels; and

       •     whether they could suggest any format or presentation improvements.

 Reading Labels and Implications of Not Reading Labels

 In general, the more familiar a participant was with a product, the less compelled s/he might feel
 to read the label. If someone had repeatedly used a product with success, s/he might not consult
 the label unless something about that product changed, the container was redesigned or looked
 different, copy on the label said "new and improved", or a problem had occurred with past use.

 Some participants commented:

       "Well, I know I only read them for the use. I'll usually do that at the store. I don Y sit there and
       read every sentence or anything, but I -will read them to see -where to use them or whatever  the
       product is for," (Household Cleaners,  5PM, TX).

       "At the store, I'd look to see that it was for the job I wanted.  The next thing I would look for was
       to see how easy it was to use, was one more complicated than the other. I wouldn 't look at
       ingredients at that point, but just to see how to use it," (Household Cleaners, 5PM, FL).

       "I 've learned that I check out the ingredients.  I have mixed bleach with ammonia by accident.
       Because Ididn 't read it I just thought I was making me a strong manly cleaner. It cleaned me
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       right out of my apartment. So I'll [look at ingredients] and if it is not giving me what I need to
       know, then I'm not going to buy it," (Household Cleaners, 5PM, TX).

       "I would read the label the first time I used it. Then probably wouldn 't bother with reading the
       label again until possibly they 've changed the format of the label and for some reason it appears
       to me that it's a new and improved product so then I might look at it again to see what they 've
       done to change it," (Household Cleaners, 4PM, IL).

Users of outdoor pesticides and indoor insecticides appeared more likely than users of household
cleaners to read the  labels of these products. The moderator felt that this reaction might be in
part related to the more complicated tasks of mixing or diluting many outdoor pesticides, or to
the perception that pesticides and insecticides have stronger formulations than household
cleaning products. People may also read the labels of outdoor pesticides and indoor insecticides
more often because  these products kill visible "live organisms" and thus may be perceived to be
more dangerous than household cleaners.

Participants felt that not reading labels put product users at risk. They mentioned the following
potential problems associated with not reading labels:

              using the wrong product for a specific purpose;
              not using the correct application process;
              losing money if the wrong product was purchased;
              using the improper dilution or mixture;
              not knowing if protective clothing, goggles etc. were necessary;
              not being aware of the need for proper ventilation;
              not knowing how to deal with a problem;
              causing possible damage to furniture, carpet, wood (inside), or other plants
              (outside);
              improperly disposing of a product or container;
              not knowing how  dangerous a product was to use; and
              compromising the safety of children or pets.
Satisfaction with Current Labels for Products Discussed

Most participants indicated that they were satisfied with existing labels, and they initially offered
few suggestions for improving them.  When given options for changes, however, they agreed that
certain changes might be useful.  (These ideas are discussed later in this chapter, in the section
"Label Standardization," and in other sections of the chapter, such as "Boxed Formats.")

Which Label Sections Participants Read

Some group participants said they read the entire label. Other participants said that they read
specific information or sections of the label that were most important to them.  The moderator
felt that many, if not most participants, did not regularly read any of the product labels discussed
unless they had encountered a problem, but that it was very difficult for participants to admit
this, and that there is no direct evidence to support this opinion.
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 Participants were most likely to read the front of the label, to learn what the product was
 supposed to do.  Participants said that the front label gave them a quick overview of the product,
 whereas the back contained directions or additional precautionary information, as the following'
 quote shows:

        "Ijust think the front of the product is going to attract the person's eye, to see if they want to buy
        that product. I know that when I buy something I'd rather see what it does. I really don't care
        what the ingredients are as long as it says that's what it is going to do.  Then I'll look to the back
        and see what the instructions are and see what it does and how you do it. "(Household Cleaners
        6:30PM, TX)

 Why and When  Mini Focus Group Participants Read Product Labels

 Participants tended to use product labels on an as-needed basis, as did the consumers interviewed
 in the Phase I qualitative research.  The more familiar a participant was with a specific product,
 the less likely s/he was to read the label. Consumers discussing household cleaning products
 indicated that they read these labels infrequently. Indoor insecticide and outdoor pesticide users
 tended to read these labels more frequently because they did not use these products as regularly
 (and thus could be assumed to  have less familiarity with the label information). Participants
 tended to read the labels for products that "kill something alive" (i.e., indoor insecticides and
 outdoor pesticides) more often than they read labels of household cleaners and disinfectants.

 Most participants said they first read labels at the store when selecting products. They most
 often read about the function of the product (what it would do), directions for use, and/or
 precautionary statements for human health. Some participants also looked at the ingredient
 listing to ascertain the specific  composition of the product, which helped them judge which
 product was a better buy (e.g., the higher the amount of active ingredients, the more you got for
 your money).  A few participants read the ingredients because they stated that they were allergic
 to a specific ingredient; however, when asked, they could not name the ingredient to which they
 were allergic.  These people said they would not knowingly buy products that would trigger an
 allergic reaction for anyone in their family.

 Participants stated that, at home, they most often consulted the directions for use.

 Locations for Types of Label Information

 When discussing the best locations for specific information on a product label, participants said:

       •      the front of the product/label should focus on brand and product purpose;

       •      basic precautionary information should be on the front of the product, with in-
              depth information on the back;

       •      ingredients should appear on the back of the product (especially for household
              cleaners), unless this would require the elimination of other information that
             typically appears on the back. Only comparison shoppers (people who compared
              ingredients at the time of initial product selection) wanted ingredients on the
             front; and
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       •      usage directions, tips, First Aid, and additional precautions should be listed on the
              back.

Signal Words

This section of the discussion focused on the hierarchy of "signal words" and graphical
representations of the signal words. All mini focus group participants had trouble with the
concept of a hierarchy of acute toxicity concerns. This hierarchy is intended to convey that
CAUTION implies the lowest level of hazard, WARNING somewhat more hazard, and
DANGER the greatest hazard. Manufacturers of pesticides, insecticides, fungicides, and
rodenticides must list one of these words  on the product label, under specific rules established by
the Federal Insecticide, Fungicide,  and Rodenticide Act (FIFRA).

Before the hierarchy was explained to them, however, most participants in the mini focus groups
thought that the signal word printed on the label was chosen arbitrarily by the manufacturer.  In
general, participants thought initially that CAUTION, WARNING, and DANGER all meant
"Take care and keep out of the reach of children."

When the concept was explained to them, participants responded positively, as shown in the
following statements:

       "This is very informational to me. lam amazed." (HouseholdCleaners, 8PM, TX)

       "I'm less ignorant tonight than I-was when I came here  because I thought that CAUTION,
       WARNING, and DANGER were basically semantic terms that people chose to describe
       something that you needed to look at. I didn 't know that it was a government regulation. I
       thought they were interchangeable.  But when you see them laid out like this you understand that
       there is actually a difference between the level of danger or safety that you're experiencing."
       (Outdoor Pesticides, 6:30, TX)

Some participants subsequently expressed a preference for products labeled DANGER. This
word indicated to them that these products would contain the strongest concentration available,
that less would need to be used to get the job done, or that it could be used less often because it
was stronger or more effective than a product labeled CAUTION.  Other participants, however,
stated that they would not use a product labeled DANGER out of fear for themselves, their
children, or pets. Some comments about this issue follow:

        "The way I see it, DANGER means that it is more potent, so I think it is going to work better. It
       could have more side effects problems and that is why you 'd need to know what the DANGER
       [meant] or was for." (Indoor Insecticides 8PM, IL)

        "It would be different for me if I had small kids around  the house. I know that all of it is
       dangerous to kids, but if it is color-coded say red, and is [labeled] dangerous, it would make me
        be more cautious at home. Although still in my mind it  would make me think that this product
        [labeled DANGER] might work better on what I am trying to use it for." (Household Cleaners,
        6:30, TX)

        "Ifyou were looking for a safe product you would buy a CA UTION product.  If you were looking
       for something that really cleaned and you were willing to take chances, you 'd go for the
        DANGER product." (Household Cleaners, 8PM, TX)
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  Graphical Representation of Signal Words
                                                                                          i
  Several different graphical (visual) representations of the signal words were shown to the groups
  (Appendix 3-3). The initial representation, which was based on Stakeholder input showed a
  horizontal or vertical bar divided into thirds, with the first third light, the second third darker and
  the last third almost black. (The first groups saw black and white versions; later groups also saw
  color versions.) The mock labels were shown to participants in Ft. Lauderdale and Dallas  In
  addition, participants in the Chicago indoor insecticide groups also viewed graphics of a meter
  and a thermometer.  These participants generally found the meter to be somewhat easier to
  understand than the bar graph.  The meter seemed to be more intuitively obvious of a ranking
  scale, because it could clearly show the progression from a low to a high level of concern  One
  participant remarked:

        "I like the meter. Because it makes me think of when you 're driving a car and the speedometer
        When you are going slower you are safer and when you speed up you get into the danger zone '
        so I guess I can relate to it in that way." (Indoor Insecticides, 8PM, IL)

  The color gradation of the graphical signal word representation (see Appendix 3-3) was not
  interpreted by participants as indicating a scale of concern (with light area indicating less
  concern, and dark areas indicating the most concern). Instead, the darkest shaded area, with the
  word DANGER in it, stood out  for all participants, even when the arrow under the bar pointed to
  CAUTION or WARNING. Using numbers in conjunction with the signal words only added to
 participants' confusion, as the following comments illustrate:

        "// is very confusing. Hike the control [with one word] better." (Outdoor Pesticides, 5PM, TX)

        "Well, it just makes it like they 're putting on an extra warning or something. Because everyone
        knows that cleaner, you need to be cautious with. But then you have the extra caution on there,
        then it makes it seem like maybe there's something else in there that you don't know about thai
        might be worse." (Household Cleaners, 6:30, TX)

 Most participants preferred the version that lists only one signal word,  with a bulleted
 precautionary statement below it (Appendices 3-3 - 3-6). Participants felt that this
 representation would ensure that all outdoor pesticides and indoor insecticides would be treated
 with the same level of care, no matter which signal word was used.
                                                                                          I
 Some groups saw labels in which the medical concern associated with the signal word was listed
 below the signal word (Appendices 3-3 - 3-6). Participants who saw this version liked it
 because they thought it would help them to further identify possible areas of concern regarding
 improper product use, as this person said:

       "Plus it saves you from turning the can around and looking to find out why. Here it just tells you
       the deal right there." (Indoor Insecticides, 8PM, IL)
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Most participants felt that indoor insecticide and outdoor pesticide labels would benefit most
from including medical concerns below the signal word. Household cleaning products were not
generally viewed as being as "potentially dangerous" as indoor insecticides and outdoor
pesticides. One person put it this way:

       "/ may apply outdoor pesticides in the same way, but I would have more respect for the
       application [seeing the signal graph].  I might treat them differently." (Outdoor Pesticides, 6:30,
       TX)

Participants in the later sessions (held in Chicago and Dallas) suggested that "color coding" be
used for the signal words, which they felt would be superior to black print. They specified the
following colors:

       •     Yellow for CAUTION;

       •     Orange for WARNING; and

       •     Red for DANGER.

Education and Outreach about the Signal Word Hierarchy

Overall, participants felt that an extensive educational program would be needed to promote
consumers' understanding of the current  signal words:

        "Be nice if they spent some commercial money on informing us of the difference between
       CAUTION, WARNING, and DANGER."  (Indoor Insecticides,  6PM, TX)

        "Now that you 've explained it that way, I mean I could see why you do this. If that became the
       norm for everything,  I think it would be great. I would look to see the different warnings."
        (Household Cleaners, 6:00, IL)

Participants suggested considering the following in developing such a campaign:

        •     make sure that labels of product types are consistent (like  food labeling
              information); and

        •     use color rather than a black and white representation.

 Participants also suggested that manufacturers of these products should include a "scale" on their
 labels showing the hazard level of the product (such as the graphical representations of the signal
 words discussed previously).  Participants generally felt that manufacturers that do this would be
 viewed as being more honest.  One person  said:

        "/ think if some manufacturer is putting this on there, that corporation has in mind to give as
        much information that they think people  who use it want to know." (Household Cleaners, 4PM,
        IL)
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 Mock Labels Used in Discussions of Signal Words (see Appendices 3-3 — 3-6):
 Appendix 3-3: Signal Meter (presented to participants in color)
 Appendix 3-4: Outdoor Pesticides - Front 4, Front 5, Front 6, Front 7, Control Front
 Appendix 3-5: Household Cleaners - Front 6, Front 7, Front 8, Front 9, Control Front
 Appendix 3-6: Indoor Insecticides - Front 8, Front 9, Front 10, Front 11, Front  12, Control Front
 Signal Graph Samples	
 Understanding Directions for Use

 Group participants generally preferred that the Directions for Use section of the label have the
 following characteristics:

       •     a numbered sequence for directions (when appropriate), because the numbers
              would suggest the proper order of steps to take in using a product, and because it
              would be easier for users to find their place again if temporarily interrupted while
              reading the directions for use;

       •     all text for a step kept to one line, instead continuing ("wrapping") onto multiple
              lines;

       •     more "white space;" and

       •     avoidance of unnecessary words and descriptions.

 Participants in the Outdoor Pesticides groups talked about the sample heading "Responsible Use"
 (Appendix 3-4 — Label sample 10 Back). Many participants thought this language was
 intimidating and "talked down" to consumers, as the following person stated:

       "To me 'Responsible Use' makes it a little scarier, a little insulting.  Responsible use implies that
       maybe you are irresponsible, maybe you shouldn 't be messing with this stuff." (Outdoor
       Pesticides, 5PM, TX).

 Group participants were also asked to provide feedback about possible alternate wording for
 precautionary statements. One statement in each pair is typical of current label language, and the
 other statement is  a possible alternative to the current statement. Participants generally preferred
 usage directions that included a specific time frame linked with a directional step.  The statement
 that was preferred by more participants is shown in italics, with "X"  indicating a placeholder for
 a number.

 Statements tested:

       Repeat as  needed.

       Preferred: Apply  no more than  "X"  treatments  per week.
       Do  not allow  children or pets to contact treated areas.

       Preferred: Keep children or pets out of treatment  area  for  "X"
       minutes.
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Participants thought it was appropriate to put directions for use on the back label, as currently
done. They preferred the front label to be as uncluttered as possible, for aesthetic reasons.
Mock Labels Used in Discussions of Directions for Use (see Appendices 3-4 — 3-6):
Appendix 3-4: Outdoor Pesticides — Back 9, Back 10, Back 11, and Control Back
Appendix 3-5: Household Cleaners — Back 10, Back 11, and Control Back
Appendix 3-6: Indoor Insecticides — Back 6, Back 7, and Control Back	
Precautionary and Other Label Statements

As in the discussion of the label section on Directions for Use, group participants preferred to
have precautionary statements presented in bullet points, each limited to one line of text. They
.found one-line statements to be easier to read than statements that continue onto more than one
line.  Similarly, participants preferred to have all language for the precautionary statements in the
same column of text on the label. They found it difficult to follow text that wrapped from the
bottom of the left-hand column to the top of the right hand column.

Participants were also asked to provide feedback to different pairs of precautionary language
statements.  One statement in each pair is typical of current label language, and the other
statement is a possible alternative to the  current statement.  In general, participants preferred
statements that used "simple" and specific language.

Statement tested:

       It  is  a violation of  Federal  law to  use this  product  in  a manner
       inconsistent with its  labeling.
       Preferred:  For safe and  effective use read the label  first.

Some participants commented:

       "It [second statement above] sounds friendlier, it doesn 't intimidate me, and gets to the point."
       (Indoor Insecticides, 8PM, IL)

       "Is there really an insect police? It says it's a violation of Federal law to use this product in a
       manner inconsistent -with	. Are the police going to come to your door and say you sprayed it
       from fourteen inches, and you're going to jail." (Indoor Insecticides, 4PM, IL)

       "It [first statement above] is like pushing me around. Right away I am intimidated." (Outdoor
       Pesticides, 8PM, IL)

 Statement tested:

       Hazards  to humans  and domestic animals.
        Preferred: Hazards to humans  and  animals.
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 One person commented:

       "/ would say domestic is just a word that doesn 't need to be there." (Household Cleaners 6-30
       TX)

 Statement tested:

       This product  is toxic  to aquatic  invertebrates

       Preferred: This product  can kill  aquatic insects,  shrimp,  crabs,
       and crayfish.

 Statement tested:

       This pesticide  is  toxic  to wildlife.

       Preferred: This product  can kill  wildlife.

 Statement tested:

       This pesticide  is  toxic  to wildlife and domestic animals

       Preferred: This pesticide  may harm pets and  wildlife.

 One comment follows:

       "I think laymen's terms are easier to understand for most people as opposed to words like toxic
       which may be confusing." (Outdoor Pesticides, 8PM, IL)

 Statement tested:

       Do not  apply where runoff  can  occur.

       Preferred:  Do not  use on sloped areas when heavy rain is
       expected.
Mock Labels Used in Discussions of Precautionary Statements
(see Appendices 3-4 — 3-6):
Appendix 3-4: Outdoor Pesticides - Back 8, Back 9, back 10, and Control Back
Appendix 3-5: Household Cleaners — Back 4, Back 5, and Control Back
Appendix 3-6: Indoor Insecticides — Back 4, back 5, Control Back
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Listing Ingredients

Many participants said that they never read the ingredients on outdoor pesticides, household
cleaners, or indoor insecticides because they had no idea what this information means. They
agreed that adding concise and simple language explanations of ingredients (to describe the role
of specific ingredients) would be beneficial. Explanations would give the average consumer a
better understanding of the need for specific ingredients in a product's formulation. One
participant commented:

       "Maybe I guess that is why some people don't even care about reading the ingredients because
       you don't know half of the stuff they list on there.  So if they have something like this [simple
       language explanations] then maybe I could say 'okay, well then they 're going to tell me what
       this or that means.' Then I could actually say I am going to actually read what is there. But if I
       don't know what it means, then I'm not going to bother with reading it." (Indoor Insecticides,
       8PM, IL)

       "Some of these ingredients are like $50 words that only a scientist knows what it means, and then
       right next to it they give you the percentage and like what does that mean to me? In other words,
       it would be nice if they could put it in plain and simple terms that an ordinary person could
       understand." (Household Cleaners, 4PM, IL)

Even though most participants did not know the purpose of the ingredients in outdoor pesticides
and indoor insecticides, they wanted full disclosure of ingredients in case of an emergency.  By
having this information on the label they felt that they would be able to quickly obtain the correct
medical advice for dealing with a possible problem. They seemed to feel that outdoor pesticides
and indoor insecticides are "stronger" because they often list specific directions for use, special
clothing, tools, or timing of application, and because they kill "visible" organisms. Although
household cleaners also may kill bacteria, participants did not consider these products to be as
strong or potentially "dangerous" as outdoor pesticides or indoor insecticides.

Participants liked the idea of manufacturers giving Poison Control Centers a list of ingredients
for specific products. They thought this would be more efficient than having a person read the
contents to Poison Control. They also indicted, however, that this would not eliminate the need
for ingredients to be listed on the label.

Location of Ingredients Information

Participants who discussed household cleaning products thought it was quite acceptable for
manufacturers to list ingredients on the back label. They felt that the front label of these products
should focus on selling the brand. One participant stated:

       "I didn 't realize there was nothing on the front. But I like the clean look of the front of this
       package. I like all of this [ingredients] on the back. I do like that you have the other ingredients
       [listed] so that if somebody on a poison hotline were to say 'What else is in the product?' I have
       them [the ingredients] all here.  I really don't care what percentage [are used for the
       ingredients].  (Household Cleaners, 5PM, TX)
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 On the other hand, participants for the outdoor pesticides and indoor insecticides categories were,
 divided about whether the front or back label would be a better location for ingredients.
 Participants who compared ingredients when choosing products particularly liked seeing
 ingredients on the front label.
 Mock Labels for Discussions of Ingredients (see Appendices 3-4 — 3-6):
 Appendix 3-4: Outdoor Pesticides — Front 1, Front 2, Back 3, and Control Front
 Appendix 3-5: Household Cleaners - Front 1, Front 2, Back 3, and Control Front
 Appendix 3-6: Indoor Insecticides - Front 1, Back 2, Front 3, and Control Front
 Boxed Formats

 Boxing information (i.e., putting a box border around the text) was perceived by mini focus
 group participants to be a very positive change to current label design.  Participants said that a
 box would have a visual impact because it would draw one's eye to that area on a container.
 Participants felt that consumers would interpret boxed information as being the most important,
 such as directions for use, precautions for human health, or First Aid. Boxes that were stacked
 vertically seemed to work better than side-by-side boxes. Representative comments follow:

       "It's the -way all the nutrition information was suddenly put on food bags and boxes. When that
       happened I was glad to see it because it did make me read it more  often because it was so much
       clearer. It was more distinctive and that's what this makes me think of. I'm likely to read this
       because it's more distinctive. Somebody took the time to lay it out clearly because they felt it
       was important for me to read." (Household Cleaners, 4PM, IL)

       "You know, even though you 're supposed to read the whole label, if you cheat and don't [read
       the whole label] you 'd better read the box." (Outdoor Pesticides, 5PM, TX)

       "Boxing shows me that for some reason it needs some prominence,  or the manufacturer has
       given it prominence for some reason and I need to pay particular attention to the things in those
       boxes." (Outdoor Pesticides, 5PM, TX)

Participants also pointed out that too many boxes on a label might dilute the visual impact. They
felt that only the most important information on a product should be boxed.  Participants thought
that boxing First Aid information was a particularly good idea because:

       •      it was easy to read,

       •      it identified a problem and gave a simple answer,

       •      it stood out from the other important information on the label,

       •      it was boldly presented, and

       •      it had more white space around the text.
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Some focus groups were shown an "integrated" or "combined" label (Appendices 3-4 — 3-6),
which used a variety of formats for different sections of the label.  By incorporating bullets,
boxes, white space, etc., the label became more interesting visually.  One participant commented:

       "Hike the mixing of information so that things can be located more easily. Especially if they
       •were consistently done between products.  [For example] if the hazardous information is boxed
       always, and the usage directions are bulletedyou would have a better idea of how to find it [this
       information]. But even if it were not consistent I think by having white space and having areas
       of information in different formats that it would be easier to read.  It 'sjust easier to read."
       (Household Cleaners, 4PM, IL)
Mock Labels for Discussions of Boxed Formats (see Appendices 3-4 — 3-6):

Appendix 3-4: Outdoor Pesticides — Back 12
Appendix 3-5: Household Cleaners — Front 12, Back 13, Front and Back of Control
Appendix 3-6: Indoor Insecticides — Back 13, Back 14, Back 15, Integrated Label
Separate Pamphlet

The idea of using a removable pamphlet to provide product information, such as the pamphlets
that are included with some outdoor pesticide products, was not favored.  Most participants
preferred to see all the information presented on the container itself. Their reasons included the
following:

       •      the sample pamphlet had too much information and tended to inhibit reading;

       •      since these products are generally kept outside, the pamphlet could easily be lost
              or damaged; and

       •      because many of these products need to be mixed with water, the pamphlet could
              be damaged by contact with water.

Participants generally liked the highlighted heading that was used on the outdoor pesticide
pamphlet. This design feature seemed to help participants locate a specific topic area on the
product, and also made the label look clean and organized.

Label Standardization

Many participants thought that a standardized label format (e.g., each product having the same
kind of layout, putting specific sections in the same place on all labels, using the same typeface)
would be helpful for the categories of products addressed in this research, because this might
encourage consumers to read labels more often or to read more of the label.  Participants put it
this way:

       "I would think [it could possibly have an effect on using the product more safely and effectively]
       because you know where to find all your information real quick. Since you know where to find it
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       you don't have to worry so hard about looking for it.  When you look hard for it, it \vill
       discourage you from reading it. It's something that is simple, easy, right there. If you know
       where it is you 're going to read it." (Household Cleaners, 8PM, FL)

       "You know what would really be wonderful, just kind of pie in the sky.  You know how they do on
       the nutritional labels, they 're all the same for all food products. Wouldn 't that be great to have
       something like that on cleaning product labels. [They could include] toxicity levels, and maybe
       strength levels." (Household Cleaners, 8PM, TX)

Participants were very consistent in their desire to have labels that are easier to read, and were
especially interested in changes that would decrease clutter and increase readability. The most
frequent suggestion for all categories of labels was to use larger type that is easier to read. Many
participants had difficulty reading the small print on labels and felt this change would save time
and encourage label reading. Some people felt that the size of the print suggested the relative
importance of the information, with larger type indicating more importance than smaller type.

Participants suggested the following specific format changes:

       •      use a larger type size (font);

       •      use bold lettering or an easy to read font style;

       •      use bullet points for text, and keep sentences short and all on one line;

       •      use numbers for directions when appropriate;

       •      use simple language. Be direct, brief, and to the point;

       •      include more white space;

       •      box important information for quick and easy reference;

       •      provide a rationale for using a product in a particular manner. (For example, say
               "For safe and effective use read the label first" instead of "It is a violation of
               Federal law to use this product in a manner inconsistent with its labeling");

       •      give specific time references, such as "Apply no more than 'X' treatments per
               week" or "Keep children or pets out of treatment area for 'X' minutes;"

       •      list a Poison Control 800 (toll-free) number. (Prior to the mini focus groups,
               many participants had not been aware that they should call Poison Control first
               rather than their doctor or a hospital);7

       •      highlight topic or section headings; and

       •      print the caution hierarchy in color.
Control.
       7At the time this report was written, no single national or central toll-free number existed for Poison
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Some relevant comments made by participants follow:

       "/ think the [printing on the label] should be made a little larger. Sometimes you just look at it
       and you don't see it because it is so small print." (Household Cleaners, 5PM, FL)

       "Something that just caught my eye, having little ones, is maybe put that number /for Poison
       Control] right on the can." (Household Cleaners, 5PM, FL)

       "If you have the text wrapped, you are more likely to miss something important. When you are
       shopping you 're certainly going to take the one that is clearer [looking] that you can
       understand. With the other one you are going to get frustrated and you 're just going to put it
       right down and say I haven't got time to go through this." (Household Cleaners, 5PM, FL)

       "It looks like it [the Control Label] is more complicated because it looks like there is so much
       more in there. It looks like it is more dangerous than it needs to be. Whereas if it is set up in a
       simple and concise format that you can read and understand, it does not look as bad."
       (Household Cleaners, 5PM, FL)

       "If it is neater and laid out better, I'd be more prone to read the -whole thing." (Household
       Cleaners, 5PM, FL)

       "I like bolded key -words and I like bullets under each bolded -word. It kind of separates things."
       (Household Cleaners, 4PM, IL)

Many participants said that if the design/format changes discussed above were implemented,
they thought that consumers might read these product labels more often, might read more parts of
labels, and would be able to find information on labels more easily and quickly.

Participants also suggested that making such changes might improve the public image of
manufacturers, who would be perceived as being more honest with consumers by presenting their
products in a forthright manner.

Logos for the "Read the Label FIRST!"  Campaign

Various drafts of possible logos to support a "Read the Label FIRST!" Campaign (see Appendix
3-7) were presented to the mini focus groups to obtain feedback from consumers  about the logo
designs and about effective ways to reach consumers and motivate them to read the labels of
these types of products.  (Most participants said that they thought such a consumer campaign
would be a good idea in general, but that it might not really be meant for them because they
already read labels.)

The groups were asked whether any of these logos would be "more compelling" for them on the
label of an outdoor pesticide/household cleaner/indoor insecticide. They also  were asked
whether they had any emotional ties to any of the  logos, and what other factors besides the logo
and the "Read the Label FIRST!" slogan would motivate them to read labels on these products.
They were also asked if they would be significantly more motivated to read the directions for use
and the precautionary statements if they understood that doing so would allow them to use the
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product more safely and effectively. To place the discussions in context for participants, the
moderator talked about another public service campaign, the "Buckle Up for Safety" Seat Belt
campaign, and asked people some questions about their memories of and reactions to this
campaign.

Participants said that child safety, pet safety, personal safety, and correct product use were the
main reasons they would read the label on an outdoor pesticide, household cleaner, or indoor
insecticide. They also said that they might be fearful that the following things could happen if
they did not read a label:
                                                        I
       •     they might use the product improperly if they did not read directions for use;

       •     they might use the product for the wrong reason;
                                                        i
       •     someone (the user or a family member) might have an allergic reaction to a
             specific ingredient(s);

       •     the environment might be harmed; and

       •     personal property might be damaged.
                                                        I
Participants indicated that for a logo to be compelling, it would need to reinforce some of these
emotional reason(s) for reading labels. Participants felt that none of the logos presented truly
communicated such an association. Of the drafts they reviewed, they preferred the octagonal
shape (Appendix 3-7) because of its association with the meaning of a stop sign: "Stop. Look
and listen." Nevertheless, they said that this logo did not arouse any empathy or emotional drive
directed toward children and/or pets.

Participants were also asked for outreach suggestions to educate consumers about the "Read the
Label FIRST!" Campaign.  Their  ideas included a variety of media: a sticker on the product,
school education programs, TV public service spots, and grocery aisle promotions.
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                                   CHAPTER 4
   QUANTITATIVE AND QUALITATIVE RESEARCH
                             CONCLUSIONS
In July 1998 the research Core Group and The Newman Group, Ltd., met in a face-to-face
meeting in Alexandria, VA to finalize the quantitative findings and implications, to discuss what
was learned from the qualitative mini focus group research, and to discuss the overall
conclusions for Phase II of the CLI.

As mentioned in Chapters 2 and 3, the findings result directly from the quantitative survey results
and are supported by the quantitative data. Implications show connections among the various
findings related to a topic or learning objective, and are derived from the quantitative findings.
The formulation of implications involved a certain element of interpretation of the quantitative
data, but they can be traced directly to the data. The overall conclusions of the Phase II research
draw from findings and implications of the quantitative research, the information obtained during
the qualitative mini focus group research, and all of the other Phase II activities (e.g., subgroup
meetings, Stakeholder comments, First Aid qualitative research).  Conclusions are broad
statements, which the research Core Group developed as they interpreted these various sources of
information and data, about product labels arid consumers' comprehension, satisfaction, and
preference for labels.

The conclusions from the Phase II quantitative and qualitative research are as follows:

1.     There is no strong motivator that suggests fundamental label changes, but language and
      format can be improved. Consumers are generally satisfied with current labels and are
      able to find the information they want on the label. However, the data indicate that
      improvements would encourage more reading and use of product labels.

2.     Labels for each of the product categories should not be treated  in the same way since
      consumers perceive the products differently and have different label reading habits for
      each category, as follows —

      *•   Household cleaner labels should be simpler, with exceptional information (i.e., very
          important or different than anticipated) highlighted. There is a lower motivation to
          carefully read these labels because of the perceived familiarity with cleaning
          products.

      >   Indoor insecticide labels are quite effective now, Incremental changes to simplify
          labels and make them easier to understand should be tested.

      >   Outdoor pesticide labels are confusing because they are more complex and less
          frequently used, and therefore less familiar to consumers. They should be simplified
          and arranged for easier reading.
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3.     Consumers want clear, concise, easy-to-read information that connects consequences with
       actions. Instructions on labels should say 'why' and jargon should be avoided.
                                                                                        I
4.     Consumers look to all traditional media to gain information. Therefore, outreach to
       consumers should incorporate traditional media, and should also include education efforts
       directed toward store personnel and other "influencers."
                                                        !    •                         .   I
5.     Ingredient information can be communicated by name, type or category of ingredient, and
       purpose of ingredient, not just by a list of chemical names. Ingredients should be
       presented in tabular form, with flexibility as to where in the label they are located (e.g.,
       front vs. back panel of the label).

6.     Additional information is needed to better understand how to answer the need some
       consumers expressed for useful ingredient information.  A full disclosure list of names
       does not further consumer understanding.

These conclusions are supported by detailed research findings.
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                                   CHAPTERS:


         FIRST AID — QUALITATIVE RESEARCH


This chapter reviews the findings and activities concerning First Aid from Phase I and presents
the activities and findings from Phase II.

                         First Aid Phase I Findings

During Phase I of the CLI, qualitative research, one-on-one interviews, and literature searches of
existing studies were performed in order to assess consumer behavior and preferences regarding
First Aid statements. The research indicated, among other tilings, that most consumers only read
First Aid information after accidental exposure to a product. Additionally, consumer perception
of a product's hazards was found to be the most significant indicator of whether or not a
consumer would read the First Aid information.  Phase I results indicated that many consumers
liked having precautionary information on product labels, and view precautionary and warning
statements positively (Kraus and Slovic, 1998. Consumer Risk Perception of Household
Chemicals, p. 49).  The results also showed that precautionary statements have little impact on
purchasing behavior.

Phase I research on label clarity concluded that consumers had a difficult time understanding the
phrase "Statement of Practical Treatment" and consistently misinterpreted the EPA-mandated
labeling, "Hazards to humans and animals," to mean that a product was automatically hazardous.
As a result, the CLI made the interim recommendation for manufacturers to voluntarily replace
the phrase "Statement of Practical Treatment" with "First Aid." EPA Assistant Administrator
Lynn Goldman formally announced this recommendation at a press briefing in September 1997.

A wide range of CLI Stakeholders made many varied comments concerning precautionary and
First Aid information during Phase I. Commenters recommended listing a product's health
effects (both acute and chronic), whether the product contained any known carcinogens or
mutagens, and health hazards and environmental  hazards associated with each ingredient.  Some
Stakeholders suggested that the label state how the product would affect pregnant women and
children, and indicate what health testing had been performed.  Stakeholders also requested that
First Aid information be technically accurate, relevant to how the product is used, misused or
disposed, and based on sound toxicological and environmental risk assessment. They also
suggested that labels include information concerning exposure factors and the types of personal
protective equipment needed when handling these products.

Given the comments received in Phase I of the project, and CLI's goal of making labels more
comprehensible to  consumers, it was decided that testing of revised First Aid statements with
consumers take place during Phase II.
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                 First Aid Phase II Goals and Objectives

 In Phase II, EPA's Office of Pesticide Programs (OPP) tapped into the CLI to gather information
 they needed to update and improve First Aid statements. Specifically, consumers were
 interviewed about their comprehension of a series of proposed First Aid statements in order to
 assess the potential for changing, simplifying and clarifying these statements.

                         First Aid Phase II Activities
                                                                                       i
 Based on input from the qualitative research conducted in Phase I of the project, EPA's Office of
 Pesticide Programs (OPP) made several revisions to the First Aid statements on product labels in
 March 1996. These revised statements underwent additional changes based on input from States
 and CLI industry Partners, academics, and poison control centers. In July 1997, the CLI tested
 these revised statements in a series of one-on-one interviews with consumers. The purpose of the
 interviews was to gain an understanding of consumers' comprehension of First Aid instructions.

 Based on initial reactions and input from the interviews with consumers, the First Aid statements
 were further revised. From August to October 1997, these statements were distributed for
 comment to the American Red Cross, the Consumer Product Safety Commission, the American
 Poison Control Centers, the Communications Task Force of the Pesticide Program Dialogue
 Committee, and other CLI Partners and Stakeholders. The revised First Aid statements were the
 ones that were used and tested on the mail questionnaire and the mini focus groups of the Phase
 II quantitative and qualitative research. (For details of the quantitative research please refer to
 Chapter 2.  For details of the qualitative research please refer to  Chapter 3). Since the
 completion of quantitative and qualitative research in Summer 1998, EPA's OPP has made some
 additional minor revisions as a result of internal OPP review and comments from the
 International Poison Control Center. The final First Aid statements will be released in an Office
 of Pesticide Programs Pesticide Registration (PR) notice in Fall/Winter 1999.

 The First Aid statements corresponded with the Federal Insecticide, Fungicide, and Rodenticide
 Act (FIFRA), which, among other things, regulates what types of information, wording and
 format of labels must appear on pesticide products (40 CFR 156.10). Under FIFRA, the type of
 text that must be placed on a pesticide label is determined by the toxicity category of the product.
 Each product is assigned a toxicity category on a scale of one to  four. A toxicity rating of one
 represents the highest toxicity level for any of the different ways that a person can be exposed to
 the product. These routes of exposure include exposure through the mouth (oral ingestion), the
 skin (dermal absorption and irritation), the eyes, and the lungs (inhalation).  (For more
 information on FIFRA refer to Appendix 5-1.)
                                                                                       i
 First Aid statements were proposed for each toxicity category, excluding category four, for which
there are no  specific First Aid statements required by regulation. Alternative statements were
 also proposed for the phrase on the label regarding the decision to seek medical advice, as well as
 for the note instructing people to bring the product label with them when seeking medical advice.
Before the interviews began, the CLI team made a decision, based on Phase  I research, to replace
the word "physician" with "doctor" and "area of contact" with "skin."
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Methodology of One-on-One Interviews

A total of 23 one-on-one interviews were conducted by Macro International, a research
consulting firm hired by the EPA, to evaluate consumer comprehension of and preferences for
alternate wording of first-aid statements.  The interviews were conducted on July 7 and 8, 1997,
in Calverton, MD, by one of the three moderators who had conducted the original CLI Phase I
qualitative research in 1996. Respondents were recruited using a screening instrument that
determined whether they used household cleaners, outdoor pesticides, and/or indoor insecticides
(see Appendix 5-2).  Interviewees were paid for their participation. Participants were shown
variations of specific First Aid instructions. The moderator used a structured set of questions,
but the order was varied from one respondent to the next. Additionally, questions were
sometimes modified (e.g., in the situation when participants were asked what they would do if a
product came into contact with their eyes), when it became evident that there was confusion or
variation among  consumers' interpretation and/or understanding of the question. Each interview
lasted approximately 30 minutes and was observed by several representatives of CLI Partners
and EPA staff. A debriefing session with observers and the moderator was held after completion
of the first 17 interviews, and again after the completion of all 23 interviews.

Strengths and  Limitations of Qualitative Research

The primary strength of qualitative research is that it can identify issues of concern to specific
populations, and it also  can be used to frame questions that can be developed further to derive
quantitative data about a topic. As the results of this study will indicate, one-on-one interviews
often identify issues that researchers may not have considered previously, or they may suggest
framing questions differently to gather more accurate information.

It is important to note that results from one-on-one interviews, focus groups, and other
qualitative research methods cannot be generalized to a larger population.  A focus group or
interview pool is not a statistical representation of the population.  It is also important that the
interpretation of qualitative data not be misrepresented in quantitative terms. For example, a
statement that "nine  of the twelve respondents"  who participated in a study agreed on a particular
point should not be interpreted as "75 percent of the population agreed that	," because
qualitative data cannot be extrapolated to describe the population as a whole.
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            Findings from First Aid Qualitative Interviews
 The consumer interviews on the wording of First Aid statements generated many findings. The
 researchers identified a number of findings regarding precautionary and first-aid statements
 based on the 23 one-on-one interviews. This section first summarizes general results applicable
 to all First Aid statements, and then examines specific results for each statement tested.

 General Findings
 1.
4.
5.
6.
7.


8.


9.
 Confirming Phase I results, consumers in these interviews indicated that they did not
 regularly read the product labels.

 Interviewees responded best to simple, very specific first-aid statements that explained
 what they actually could do themselves.  They also seemed more inclined to do what was
 called for when it was most specifically stated ("Rinse skin for 10-15 minutes," rather
 than, "Rinse skin thoroughly").

 On label format, the interviewees preferred short, bulleted sentences that did not wrap
 around onto the following line.

 Interviewees also responded well to instructions for something concrete to do in a panic
 situation (e.g., "First give water, then call a doctor"). Giving an instruction that the
 person could follow and feel that they were taking a practical action seemed to have a
 calming effect. As one interviewee said, "Don't make me think in an emergency, tell me
 specifics — if the most appropriate action is to call a Poison Control Center, then say that
 rather than'Get medical advice.'"

 The consumers interviewed followed advice they learned in the past.  Even when they
 were in a situation where the First Aid information on the label would have been helpful,
 their instinct was to follow instructions they had heard before ("induce vomiting," for
 example), rather than look at the label of the product for First Aid information.

 The qualitative research found that interviewees did not look on the label for the Poison
 Control Center number. Most of the consumers interviewed seemed to know that the
 number is in the telephone book under emergency numbers. People with children had the
 number more handy than people without.

 Interviewees' interpretations of the term "rinsing" varied widely. The consumers
 interviewed indicated that they stop "rinsing" as soon as the irritation stops.

 Virtually all of the people interviewed believed that injuries to the skin were much less
serious than injuries to the eyes.

Interviewees had no perception of dermal absorption (that a substance can be absorbed
through the skin, causing harm).  They believed that if the product was harmful, they
would feel it or see the effects on their skin (the irritation concept).
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Findings Specific to Particular First Aid Statements

Specific findings are presented according to the type of First Aid statement tested.  The First Aid
statements give instructions on what to do in case of exposure to a potentially harmful product.
As described earlier, First Aid instructions are tailored to the exposure scenario and toxicity
category (defined by FIFRA) of the particular product.  First Aid statements related to particular
exposure scenarios are lettered arbitrarily for ease of reference. The revised format of each
proposed First Aid statement reflects interview results,  and comments from the American Red
Cross, the Consumer Product Safety Commission, the American Poison Control Centers, the
Communications Task Force of the Pesticide Program Dialogue Committee, and other CLI
Partners and Stakeholders. As mentioned above final versions of the First Aid label statements
are expected to be released in Fall/Winter 1999, and will take into consideration all of these
comments and revisions, as well as results from the Phase II quantitative and qualitative research.

Results Relating to the Initial Medical Phrase on a Product Label

Interview participants  viewed the following three versions of the message to seek medical
treatment:

       Get medical advice.

       Get medical attention.

       Call a doctor or poison control center for further treatment advice.

The first interviews did not reveal much information. This may have been due to the fact that the
statements were vague and were not placed in context for the participants.  Although participants
frequently considered  all three statements to mean the same thing, they appeared to prefer the
phrase, "Call doctor or poison control center for further treatment advice."

In interviews 18-23, participants instead were questioned on the wording of the phrase within the
context of other statements. In the context of other First Aid statements, people seemed to
prefer, "Call doctor or poison control center for further treatment advice," to the other versions.

First Aid Statement Relating to Ingestion

For Acute Oral Contact with a Product in Toxicitv  Category 1.  2. or 3

The following versions of the First Aid instruction for ingestion of a product in toxicity category
1, 2 or 3, were shown to each interviewee:

       If person is able to swallow, give sips of milk or water.  Call a doctor or poison control
       center for further treatment advice.

       If swallowed, immediately call a Poison Control Center or doctor and follow their
       advice. Drink  a glassful of water.

       If the person is alert and able to swallow, give sips of milk or water. Call a doctor or
       poison control center for further treatment advice.
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 Most interviewees were confused by the meaning of some of these words and phrases. They
 interpreted the phrase "drink a glassful" to mean "all at once" and thought that the word
 "sips"meant "drink only a small quantity, not a glassful."  Several respondents noted that having
 the "give sips" direction located before the "call poison control center" had a calming effect on
 them and would enable them to take control of the situation better. The phrase "alert and able"
 was unclear to respondents because some people did not understand the word "alert," while the
 phrase "able to swallow" seemed clearer.  The "milk or water" phrase also caused confusion.
 Some people thought that milk would neutralize the negative effects of the product or coat the
 throat and digestive system.  One woman suggested that milk would induce vomiting, while
 several respondents felt that people might "react to milk," and so water should be used.

 Furthermore, many respondents had read First Aid statements at some time in the past instructing
 them to induce vomiting, so even though these tested directions did not mention inducing
 vomiting, some of them said that they would do so anyway. Many of them said they would
 induce vomiting by syrup of ipecac.  Within a larger context, several observers mentioned that if
 certain common behaviors should not be followed, labels should provide specific information
 advising it. No one mentioned sticking fingers down the throat to induce vomiting. It therefore
 seemed that this instruction was not frequently read, and would not be missed if it was removed.

 Based on the  consumer interviews and input from the American Red Cross, the Consumer
 Product Safety Commission, the American Poison Control Centers, the Communications Task
 Force of the Pesticide Program Dialogue Committee, and other CLI Partners and Stakeholders,
 the suggested statement on ingestion for category 1,  2,  or 3 products reads as follows:

       >•  Call a poison control center or doctor immediately for treatment advice.
       >  Have person sip a glass of water if able to swallow.
       >  Do not induce vomiting unless told to by poison control center or doctor.

 First Aid Statements Relating to Skin Exposure

 For Acute Dermal Contact with a Product in  Toxicitv Category 1 or 2

 (There Is No Category 3 for Dermal Contact)

Participants read the following versions of the First Aid statement:

       Rinse  area of contact thoroughly with running -water. Call a physician or poison control
       center for further treatment advice.

       Rinse skin thoroughly with running water.  Call a doctor or poison control center for
      Jurther treatment advice.

       Remove contaminated clothing. Rinse skin immediately with plenty of water.  Obtain
       immediate medical advice.

There were many different interpretations of the phrase "rinse skin thoroughly." Some people
interpreted it as requiring them to scrub their skin. Others felt that this instruction implied
rinsing should occur for a long time; when asked how long was "long," they replied, "Oh, two or
three minutes." Still others thought that to rinse skin thoroughly one would have to use soap or
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some other cleansing agent.  Interviewees perceived the message containing the phrase "rinse
skin thoroughly" to be giving the same instructions as the messages for skin irritation (see
section C and D, below).

None of the participants for this study were familiar with the concept of dermal toxicity (i.e.,
something being toxic if it is absorbed through the skin).  "Even when the moderator mentioned
that some products can be absorbed into the skin and cause damage, the respondents indicated
that they could tell that things were okay if they had no burning or tingling sensation on the
affected area."8

There was a marked difference in perception between the statement, "Remove contaminated
clothing. Rinse skin immediately with plenty of water. Obtain immediate medical advice," and
the others.  The phrase "Remove contaminated clothing" implied a much more serious
circumstance to all of the respondents. The combination of the words "remove clothes,"
"contaminated," and "immediately" contributed to the potency of the message.

As a way of determining what consumers would do in a given situation, and to ascertain if they
need specific directions for emergency situations, participants were asked what they would do if
they spilled a pesticide on themselves. Some participants mentioned removing contaminated
clothes; others did not. Some of the participants who did not mention clothing removal claimed
later that "of course" they would take the clothes off; they just had not said so earlier.

Based on the consumer interviews and input from the American Red Cross, the Consumer
Product Safety Commission, the American Poison Control Centers, the Communications Task
Force of the Pesticide Program Dialogue Committee, and other CLI Partners and Stakeholders,
the suggested statement on skin exposure for an acute dermal exposure to a product in toxicity
category 1 or 2 was suggested as follows:

       »•   Take off contaminated clothing.
       >   Rinse skin immediately with plenty of water for 15-20 minutes.
       »•  -Call a poison control center or doctor for treatment advice.


For Skin Irritation from a Product in Toxicitv Category 1 or 2

Since language for this category is very similar to that for other skin categories, statements
regarding this category were not specifically tested. As a result of the finding that interviewees
did not recognize the difference between "skin irritation" and "dermal absorption," it was
suggested that the First Aid  language defined above, in section B, for acute dermal could be used
instead.
        * Draft Summary Report, Consumer Interviews on First Aid Label Information, September 3, 1997. (A
 copy of this report can be found in the EPA Public Docket, Administrative Record, AR-139.)

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For Skin Irritation from a Product in Toxicitv Category 3

Participants were presented the following two versions of the instruction of what to do if skin
were exposed to a product identified in toxicity category number 3:

       Rinse skin thoroughly.  Call a doctor or poison control center for further treatment
       advice if irritation persists.

       Rinse skin for 10-15 minutes. Call a doctor or poison control center for further treatment
       advice.

Most of the participants said that they preferred the statement that gave specific instructions
about how long to rinse, rather than the statement to "rinse thoroughly."  Some even said that the
specific instructions had a calming effect on them because it told them exactly what to do, so
they did not have to worry about whether or not they were "doing it right:."

Although participants appeared to understand what was meant by the term "irritation" (i.e.,
redness, itching, burning, tingling, rash, welts), Most people were unable to distinguish between
the relative severity of dermal toxicity and the less severe skin irritation.  Participants also
seemed to have more concern about the risk of potential eye damage than skin damage.

Based on consumer interviews and input from the American Red Cross, the Consumer Product
Safety Commission, the American Poison Control Centers, the Communications Task Force of
the Pesticide Program Dialogue Committee, and other CLI Partners and Stakeholders, the
statement on skin irritation for a category 3 product was revised by EPA's Office of Pesticide
Programs. The suggested First Aid statement is now the same as for toxicity categories 1 and 2.


First Aid Statement Relating to Inhalation

For Acute Inhalation of a Product in Toxicitv Category 1. 2 or 3

The folio whig versions of the First Aid statement on inhalation of a category 1, 2 or 3 product
were presented to interviewees:

       If breathing is affected, get fresh air immediately.  Get medical attention. If not
       breathing, give artificial respiration.

       Move person to fresh air.  If not breathing, give artificial respiration and call an
       ambulance. Call a doctor or poison control center for further treatment advice.
                                                         •
       Remove victim to fresh air.  If not breathing, give artificial respiration and call an
       ambulance. Call a doctor or poison control center for further treatment advice (This
       statement was presented for the first  17 interviews.)

       Move person to fresh air.  If breathing is affected, call doctor or poison control center. If
      person is not breathing, call ambulance and give artificial respiration.  (This statement
       was added for the last 6 interviews)
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Most participants during the first 17 interviews did not like the word "victim," so the statement
containing the phrase, "Remove victim to. fresh air," was not shown during the last six interviews
and a new statement was added in its place.

Interview results suggested that if the "Call an ambulance" advice was given first in order to
solicit help right away, then people would feel that they were doing something constructive.
Interview results indicated that most people did not know how to perform artificial respiration.
Some found it scary if that was the only advice given. Although only one or two participants
knew how to perform artificial respiration, most said that they would try to do it if no one else
were around to give help.

Most of the participants preferred, "Call a doctor or poison control center," to the phrase, "Get
medical attention."  Interestingly, the phrase, "Get fresh air," was sometimes interpreted as
bringing fresh air to the person, such as getting a fan or bringing oxygen to the person.

None of the statements was understood by all. For the last six interviews, the following wording
was tested:

       Move person to fresh air.  If breathing is affected, call doctor or poison control center. If
       person is not breathing, call ambulance and give artificial respiration.

This revised statement appeared to be better understood.

Based on consumer interviews and input from the American Red Cross, the Consumer Product
Safety Commission, the American Poison Control Centers, the Communications Task Force of
the Pesticide Program Dialogue Committee, and other CLI Partners and Stakeholders, the
statement was revised by EPA's Office of Pesticide Programs. The suggested First Aid
statement on inhalation of a product in toxicity category 1, 2 or 3 is:

       >  Move person to fresh air.
       >•  If a person is not breathing, call 911 or an ambulance, then give artificial respiration,
          preferably mouth-to-mouth if possible.
       *  Call a poison control center or doctor for further treatment advice.

First Aid Statements Relating to the Eyes

For Eve Irritation from a Product in Toxicitv Category 1 or 2
Each person was asked to first read aloud the following statements about what to do in the case
of eye exposure to a product in toxicity category 1 or 2, and then to demonstrate to the
interviewer how he/she would accomplish the task:

       In case of eye contact, immediately flush eye thoroughly with water for 10-15 minutes.
       Call a poison control center or doctor if irritation persists.

       Open eyelid and rinse eye slowly and gently with water.  Continue to rinse eye for 10-15
       minutes.  Call a doctor or poison control center for further treatment advice if irritation
       persists.
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117

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 Virtually all of the interviewees indicated that they considered eye injuries to be among the most
 serious.  "My eyes are very important to me" was a typical statement.

 Participants had a wide variety of techniques for rinsing the eye.  Some demonstrated holding
 their heads over a washbasin and cupping water with their hands to "rinse" the eye, or holding
 their head tilted under a faucet and letting water run over it. Others said they would tilt their
 head back, hold the eye open, and pour water from a glass.  Still others said they would dab at the
 eye with a wet rag, use an eyedropper to drip water into the eye, or use an eye wash. (At least
 two of the respondents said they had eye wash devices in their homes.)

 When it became evident that the phrase "open eyelid" was confusing to participants, the
 moderator tried several other phrases such as "hold eye open," "hold eyes open," and "hold
 eyelids open." The phrase "hold eyes open" elicited a number of responses.  Some participants
 said that they would use their hands to physically hold the eye open, while others said they would
 "hold it open with the muscle" in the eye.  "Hold eyelids open" was interpreted by some the same
 as "hold  eye open," while others said that it meant to turn the eyelids out and away from the eye.
 Overall, the term "hold eye open" appeared to work better.

 The word "flush" was sometimes misunderstood to imply volume and speed, despite the fact that
 the rest of the direction specified that the action be undertaken "slowly and gently." Some people
 thought that "slowly and gently" implied that faster flushing would cause damage to the eye.

 Several participants said that they appreciated the directions in one message to use lukewarm
 water because, "I wouldn't have known that."

 The singular word "eye" was clearer than "eyes" or "eyelids." The original messages included
 "eyes" in the plural. Once the phrases were changed to the singular, people had an easier time
 interpreting the message,  as a few participants said, "How am I going to hold my eyes open and
 then flush water on them?" implying that their hands would be full just holding the eyes open.

 Based on consumer interviews and input from the American Red Cross, the Consumer Product
 Safety Commission, the American Poison Control Centers, the Communications Task Force of
 the Pesticide Program Dialogue Committee, and other CLI Partners and Stakeholders, the
 suggested statement for eye irritation from a product in toxicity category 1 or 2 read as follows:

       *   Hold eye open and rinse slowly and gently with water for 15-20 minutes. Remove
          contact lenses, if present, after the first 5 minutes, then  continue rinsing.

       >   Call poison control center or doctor for treatment advice.

 For Eye Irritation from a Product in Toxicitv Category 3

Participants looked at the  following First Aid instruction regarding eye exposure to a product
ranked in category 3:

      Hold eye  open and rinse with lukewarm water for 10-15 minutes. Call a doctor or poison
      control center if irritation persists.
118
Chapter 5: First Aid — Qualitative Research

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Findings were very similar to those of eye irritation categories 1 and 2 (see Section F, above).

Based on consumer interviews and input from the American Red Cross, the Consumer Product
Safety Commission, the American Poison Control Centers, the Communications Task Force of
the Pesticide Program Dialogue Committee, and other CLI Partners and Stakeholders, the
suggested statement was the same as the instructions for eye irritation from a product in toxicity
category 1 or 2, but the phrase "if irritation persists" was added to the end.  The suggested
statement for eye exposure to a toxicity category 3 product reads the same as that for toxicity
categories 1 and 2.

The Notes Section of the First Aid Label

Respondents were shown two versions of a note that instructs people to bring the product with
them if seeking medical assistance.

       NOTE: When calling poison control center, have product label accessible. If advised to
       seek treatment in an emergency room or doctor's office, bring the product label to show
       medical personnel.

       NOTE: When calling for treatment advice, have product label available. If advised to
       seek treatment, bring product and label with you.

Part of the wording on the note was misunderstood. Some participants misunderstood the word
"accessible," while others did not interpret "available" to mean "right at hand."  A few of the
people interviewed thought that the note was directing them to call the poison control center.

Based on consumer interviews and input from the American Red Cross, the Consumer Product
Safety Commission, the American Poison Control Centers, the Communications Task Force of
the Pesticide Program Dialogue Committee, and other CLI Partners and Stakeholders, the
suggested text for the note reads as follows:

       *  ' When calling the doctor or poison control center, have product label available.
       >   When going to the emergency room or doctor's office, take the product and label with
           you.
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119

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             First Aid Statements as a Result of Phase II
 Since the completion of the Phase II quantitative and qualitative survey research, EPA's Office
 of Pesticide Programs has proposed draft guidelines for First Aid statements on FIFRA products
 (this includes indoor insecticides, outdoor pesticides, and household cleaner products which are
 subject to FIFRA regulations).  These draft guidelines are based on the findings from the one-on-
 one interviews described above, the numerous comments received from participating CLI
 Partners, and the findings from the Phase II quantitative and qualitative research. As EPA
 continues to finalize these statements, it will continue to work closely with the organizations that
 have been involved in this process thus far. These guidelines are expected to be announced by
 OPP in a Pesticide Registration (PR) notice in Fall/Winter 1999.

 The guidelines are as follows:
Table 5-1 : Proposed Guidance for Standard First Aid Statements
Route of Exposure and Toxicity Category
Ingestion/acute oral toxicity categories 1 ,2,
and 3
Acute oral toxicity category 4
Skin exposure/acute dermal toxicity, and
irritation categories 1,2, and 3
Dermal and skin irritation toxicity category 4
Inhalation acute toxicity categories 1,2, and 3
Inhalation toxicity category 4
First Aid Statement
If swallowed:
-Call a poison control center or doctor immediately
for treatment advice.
-Have person sip a glass of water if able to swallow.
-Do not induce vomiting unless told to by a poison
control center or doctor.
Statement is not required. Registrants may use
toxicity category 1-3 statements if they choose!
If on skin:
-Take off contaminated clothing.
-Rinse skin immediately with plenty of water for 15-
20 minutes.
-Call a poison control center or doctor for treatment
advice.
Statement is not required. Registrants may use
category 1-3 statements if they choose
If inhaled:
-Move person to fresh air.
-If a person is not breathing, call 91 1 or an
ambulance, then give artificial respiration, preferably
mouth-to-mouth if possible.
-Call a poison control center or doctor for further
treatment advice.
Statement is not required. Registrants may use
category 1-3 statements if they choose
120
Chapter 5: First Aid — Qualitative Research

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Table 5-1 : Proposed Guidance for Standard First Aid Statements
Eye irritation categories 1 ,2, and 3
Eye irritation toxicity category 4
General information to include either near the
First Aid statement or emergency phone
number
If in eyes:
-Hold eye open and rinse slowly and gently with
water for 15-20 minutes. Remove contact lenses, if
present, after the first 5 minutes, then continue
rinsing.
-Call a poison control center or doctor for treatment
advice.
Statement is not required. Registrants may use
toxicity category 1-3 statements if they choose.
-Have the product container or label with you when
calling a poison control center or doctor or going for
treatment.
Chapter 5: First Aid — Qualitative Research
121

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                                  CHAPTER 6:


                      PHASE II SUB-GROUPS


SUB-SECTION  1:  Standardized Environmental Information on
                        Product Labels Subgroup

At the end of Phase I, the CLI recommended that the EPA determine the effects of standardizing
environmental messages on product labels.

During Phase II of the CLI, a subgroup was formed to address the issue of standardized
environmental information on product labels. The subgroup was created to investigate the
possibility of standardizing environmental information and displaying it on product labels in a
box format, analogous to the food nutrition label. Appendix 1-7 lists the members of the
Standardized Environmental Information Subgroup.

The subgroup was formed at the CLI Partner and Task Force Meeting held in February 1998 (See
Chapter 7 for more information on this meeting). During this meeting, two presentations were
given on standardizing environmental information on product labels, in order to engage
Stakeholders in framing the debate.  Andrew Stoeckle of Abt Associates presented a paper that
he had written with Julie Winters of the EPA, that explored issues related to standardizing
environmental information on product labels. Julie Spagnoli of Bayer Corp gave the second
presentation. See Appendix 7-1, the February 1998 Partner and Task Force meeting notes, for a
copy of the presentation.

The group initially met regularly, but merged its meetings with those of the quantitative core
research group as the scope of the issue changed. The following issues were raised during
subgroup discussions:

      •      standardized environmental information may be difficult to compile for pesticide
             products because product life cycle information can be complex;

      •      the information that people may want varies among different product categories;

      •      there may be insufficient data for some of the products;

      •      displaying comparative information on product labels may entail releasing
             company proprietary information; and

      H      thoroughly testing the kind of information interviewees want, and that the EPA
             would be able to supply, would take much longer than the time frame of Phase II
             of the CLI.

Input from the subgroup, combined with the desire of the Agency to advance the development of
the box concept and frame the debate, led to the decision to do research on standardizing

  Chapter 6: Phase II Sub-Groups — Sub-section 1 - Standardized Environmental Information on
                              Product Labels Subgroup                           123

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 environmental labels during the Phase II quantitative research.  This research focused on the box
 format, as well as interviewee demand for environmental information.  More specifically, during
 the quantitative research, interviewees were asked which type of label information was the most
 important to them, and to identify what types of label information they looked for in different
 situations.
                                                                                       .  |
 The results of the quantitative research supported the idea of standardizing general label
 information. The research found that many interviewees think that a standardized format for the
 label would help them to locate the information that they consider to be important. Regarding
 what types of information interviewees consider to be important, the quantitative research
 indicated that interviewees in general do not consider environmental information to be one of the
 more important sections of product labels. For more detailed information on the results of the
 quantitative consumer research relating to standardized environmental information, refer to
 Chapter 2.

 After the results from the quantitative consumer research indicated that interviewees did not view
 environmental information as the most important on product labels, the focus regarding
 standardization of environmental information on product labels shifted from determining what
 type of information should  be standardized to concentrating on finding a comprehendible label
 format for information already existing on product labels. During the qualitative focus groups
 that followed the quantitative research, interviewees were questioned about their preference for
 specific labeling formats, whether the formats made a difference in their understanding of the
 information presented, and  whether they had a preference for which information should be
 presented in standardized or box formats.  To read the results of the qualitative research
 regarding standardized environmental information on labels, please refer to Chapter 3.
 Chapter 6: Phase II Sub-Groups — Sub-section 1 - Standardized Environmental Information on
124                             Product Labels Subgroup

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         SUB-SECTION 2: Storage and Disposal Subgroup

Through its Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), the EPA is the only
federal agency involved with labeling that mandates disposal instructions on product labels. This
mandate creates a problem, since the research found that most residential consumers are not
interested in the disposal information. Other agencies involved with labeling, for example, the
Federal Trade Commission (FTC), do not have such mandates. FIFRA disposal statements may
conflict, however, with state and local requirements and practices.  These types of conflicts
prompted the need for further investigation into storage and disposal issues during Phase II of the
CLI. Additionally, storage and disposal instructions on product labels are frequently not read by
consumers; this has, in some cases, lead to improper storage and disposal of products and
containers.

                            Findings from  Phase I

Phase I of the CLI found that consumers do not read storage and disposal information on product
labels. The majority of consumers interviewed during the Phase I qualitative research indicated
that the storage and disposal section of product labels contains information that they perceive as
"common sense," and they feel they have a fairly good understanding of the instructions already.
Phase I research found, however, that consumers sometimes dispose of product containers
improperly, either because of poor comprehension of the instructions, or because the instructions
themselves (e.g., wrap in paper and dispose of in the trash) may conflict with state and local
disposal laws or practices.

                   Goals and Objectives for Phase II

Phase II of the CLI addressed issues relating to storage and disposal of unused pesticide,
insecticide, and household cleaner products, as well as disposal of empty containers of these
products. Upon recommendation from Phase I of the CLI, a subgroup of CLI Partner and Task
Force members interested in storage and disposal issues was formed to gain a better
understanding of why interviewees do not read this information, and to investigate ways to
increase interviewee comprehension and utilization of this information. One of the objectives for
the group was to research what, if any, state and local storage and disposal regulations, policies,
and practices exist for the  three product  categories and product containers. The Subgroup was
charged with making recommendations  for changes to storage and disposal language on product
labels, as needed, so that consumers are  not inadvertently Instructed to store and dispose of
unused product and containers in ways that violate their state and local laws and practices. The
group also collaborated with the CLI Consumer Education Subgroup to find ways to increase
consumers' reading and comprehension of the storage and disposal sections of product labels.
       Chapter 6: Phase II Sub-Groups — Sub-Section 2 - Storage and Disposal Subgroup    125

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              Storage and Disposal Activities in Phase U

 To address storage and disposal issues, several activities took place during Phase II of the CLI,
 including:

       •     primary research and data analysis of the quantitative survey with regard to
              storage and disposal issues,

       •     mini focus group research in the qualitative study of Phase II,

       •     information requests and literature reviews on storage and disposal issues,

       •     independent studies and research,

       "     information exchanges through the CLI Storage and Disposal Subgroup, and

       •     data gathering regarding household hazardous waste (HHW) management
              programs.

 A brief description of each of these activities is provided below. Learnings from each of these
 activities are presented separately following the summary of storage and disposal activities.

 North American Hazardous  Materials Management Association
 (NAHMMA) Annual Meeting
                                                      i
 The EPA held a session on storage and disposal during the North American Hazardous Materials
 Management Association (NAHMMA) annual meeting in San Diego on November 19, 19979.
 Approximately 20 to 30 people attended the session. The EPA gave a brief overview of the CLI
 and the issues surrounding storage and disposal information on product labels in particular.  The
 session was opened to the audience, which consisted primarily of individuals concerned with
 product (as opposed to container) disposal, to gather participants' opinions on how storage and
 disposal issues may be addressed on product labels.

 North American Hazardous  Materials Management Association
 (NAHMMA) Mailing

An information request was distributed by the NAHMMA to its 300 members. The request
contained six questions regarding:

       •     requirements, policies, and programs for disposing of pesticide and hard surface
             cleaner containers and unused product;
      9 NAHMMA is a non-profit association of individuals, businesses, governmental, and non-profit officials,
dedicated to pollution prevention and reducing hazardous components entering municipal waste streams from
households, small businesses, and other entities.

126   Chapter 6: Phase II Sub-Groups — Sub-Section 2 - Storage and Disposal Subgroup

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       •     requirements, policies, and programs for recycling pesticide and hard surface
             cleaner containers;

       •     recycling of aerosol cans;

       •     interviewee participation in local hazardous waste pick-up days or amnesties for
             pesticide and hard surface cleaners containers and unused product;

       •     interviewee participation in recycling programs for empty aerosol and plastic
             containers; and

       •     common practices for storage of pesticides and hard surface cleaners.

Appendix 6-1 contains a copy of the questions mailed to NAHMMA members.

Chemical Specialties Manufacturers Association  (CSMA) and
Household and Institutional  Products Information Council (H1PIC)
Members' Presentations

Member companies of the Chemical Specialties Manufacturers Association (CSMA) and the
Household and Institutional Products Information Council (HIPIC) presented findings on
research on disposal of products manufactured by CSMA and HIPIC companies, to the EPA in
May 1998.10-n The presentations included results of:

       •     environmental risk assessments on disposal of consumer products, such as "down
             the drain" products, to publicly owned treatment works (POTWs), municipal solid
             waste landfills (MSWL), and septic systems;

       •     aerosol recycling; and

       •     trends in household insecticide technology, and how this pertains to safety and
             HHW considerations.

For copies of the CSMA and HIPIC presentations, please refer to EPA's Public Docket
Administrative Record AR-139.

The Waste Watch  Center (WWC) Report on  Household Hazardous
Waste (HHW) Management Programs
       10 CSMA is a voluntary nonprofit trade association of some 400 companies engaged in the manufacture,
 formulation, distribution, and sale of non-agricultural pesticides, antimicrobials, detergents and cleaning
 compounds, industrial and automotive specialty chemicals and polishes, and floor maintenance products for
 household, institutional, and industrial uses.

       11 HIPIC, formed in 1994, was established to provide fact-based information on the proper use, storage,
 disposal, and recycling of household and institutional products. Its membership includes many suppliers and
 manufacturers of household and institutional products.

       Chapter 6: Phase II Sub-Groups — Sub-Section 2 - Storage and Disposal Subgroup    127

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  The Waste Watch Center (WWC) compiled information on a number of HHW programs in the
  United States for the EPA. WWC is a non-profit organization that has been collecting
  information on HHW collection programs since 1988. Three main sets of data were provided by
                                                        '•                              I

        •      a comprehensive listing of HHW programs in the United States as of 1997;

        •      a summary of state regulations that prevent HHWs from being placed in the trash-
               and                                                                    '

        •      a listing of non-regulatory measures by state, local, and regional governments to
               encourage HHWs to either be re-used, recycled, or managed as hazardous waste.

 For a copy of the WWC report, please refer to the EPA Public Docket Administrative Record
 AR-139.

 Discussion Paper Evolving from the 1995 Cleaning Products Summit

 Representatives from state and local organizations in the CLI Subgroup provided a previously
 prepared paper entitled "Concerns with Household Cleaning Products - A White Paper," to the
 CLI Subgroup for discussion and information. (The Subgroup was never able to discuss the
 paper in detail, however.) The paper outlines health and environmental concerns regarding
 household hazardous products, including household cleaning products.  The paper addressed
 concerns regarding methods of disposal for household hazardous products: in particular, how
 disposal practices have adversely affected HHW management programs.

 For a copy of the discussion paper, please refer to the EPA Public Docket Administrative Record
 AR-139.

 Telephone Conversations

 In addition, the EPA spoke by telephone with several professionals in the hazardous waste
 management and recycling fields, and the EPA's Regional offices, including the following:

       •     officials in state or regional hazardous waste departments;

       •     waste materials handlers (e.g., people working in recycling or material recovery
             companies);

       "     individuals at trade associations (e.g., the Steel Recycling Institute (SRI) and the
             American Association for Plastic Container Recovery (AAPR); and

       •     EPA Regional office personnel.

The primary goal of these calls was to gain a variety of perspectives about storage and disposal
requirements or problem areas surrounding these issues.
128   Chapter 6: Phase II Sub-Groups — Sub-Section 2 - Storage and Disposal Subgroup

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For a listing of individual and/or organizations contacted by telephone, and/or copies of some of
the transcripts from the telephone conversations, please refer to the EPA Public Docket
Administrative Record AR-139.

                   Learnings from Phase II Research

Learnings from the NAHMMA Annual Meeting

During the NAHMMA annual meeting, the EPA held a session that gave an overview of the CLI
and the storage and disposal issues involved in the Initiative.  The session was opened to receive
feedback from participants on storage and disposal labeling issues. The majority of people
attending the session were already aware of many of the storage and disposal issues, and were,
therefore, able to provide the EPA with well informed discussion and suggestions. Many of the
people attending the session were more focused on the disposal of unused product than on
disposal of containers.  Attendees made several points:

       •     many states do not have statutes specifically addressing disposal of household
             pesticides, insecticides, and hard surface cleaners, and programs that do exist for
             these products vary widely across states and localities;

       •     instructions on labels such as "wrap in newspaper and throw in trash" are not
             appropriate. Commentators preferred language that instructs consumers to "use it
             up," such as, "Only buy what you need," then "Give what you have left over to
             someone else who will use it" and finally, "Bring any unused product to a HHW
             collection facility or event"; and

       •     for consumers to obtain correct disposal information for HHWs, it is not enough
             to simply have language on a label instructing them to "call your local waste
             management agency," because many people would not know whom to call.
             Instead, several people suggested that a national toll-free number giving
             consumers information about disposal requirements in then1 local communities
             may be a better option.

Information from NAHMMA Mailing

The mailing to NAHMMA members had a low response rate. Of the 300 members who received
the mailing, only 13 states and localities, representing 12 states, responded. The organizations
that responded were:

       •     West Central Indiana Solid  Waste District (Indiana);

       •     State of New Mexico Environment Department, Solid Waste Bureau (New
             Mexico);

       •     Minnesota Pollution Control Agency, Hazardous Waste Division (Minnesota);

       •     Minnesota Department of Agriculture (Minnesota);
       Chapter 6: Phase II Sub-Groups — Sub-Section 2 - Storage and Disposal Subgroup    129

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        •     Walla Walla County Regional Planning Department, Recycling and Waste
               Management Division (Washington);

        •     Oregon Department of Environmental Quality, Household Hazardous Waste,
               Solid Waste Policy and Program Development Section (Oregon);

        •      Wisconsin Department of Agriculture, Trade and Consumer Protection
               Department (Wisconsin);

        •      Texas Natural Resources Conservation Commission, Clean Texas
               2000/Household Hazardous Waste Management (Texas);

        »      City of Lawrence, Waste Reduction and Recycling Division (Kansas);

        •      Sonoma County, Household Hazardous Waste Program and Sonoma County
               Waste Management Agency (California);

        •      Michigan Department of Environmental Quality, Waste Management Division
               (Michigan);

        «     New York Department of Environmental Conservation, Division of Solid and
              Hazardous Materials (New York); and

        •     Vermont Department of Environmental Conservation, Agency for Natural
              Resources (Vermont).

 Regulations, policies, and programs pertaining to disposal of household pesticides, insecticides,
 and hard surface cleaners vary greatly, both among and within the states and localities that
 responded to the mailing. Most of the states and local authorities that responded classify the
 three product categories as HHW.  According to respondents, in most states it is up to local
 governments to regulate disposal of these types of wastes. It is important to note, however, that
 many respondents did not distinguish between disposal of unused product and disposal of empty
 containers.

 State and Local Requirements, Policies, and Programs for Disposal of Unused Pesticide
 and Hard Surface Cleaner Product and Containers

 In many of the states that responded to the mailing, consumers are generally encouraged, but not
 required, to bring their unused pesticide or hard surface cleaner products and containers to  local
 HHW collection events or facilities. Some states that responded, however, have either statewide
 and/or local HHW management programs as part of their state hazardous waste management
 plans12.  (HHWs are exempt from federal hazardous waste regulations under Subtitle C of the
 Resource Conservation and Recovery Act (RCRA)). Minnesota, for example, has a statewide
 hazardous waste management plan that includes a mandatory HHW management program, and
 requires every region in the state (a region may contain anywhere from two to ten counties') to
 have a permanent HHW collection facility.  Consumers are encouraged to participate in the
       2 For a complete list of all states with HHW programs, refer to discussion of the WWC report.

130   Chapter 6: Phase II Sub-Groups — Sub-Section 2 - Storage and Disposal Subgroup

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state's HHW programs but are not required to; they do not face any penalties if they do not
participate. Minnesota has some of the most established and extensive regulations regarding
disposal of unused pesticides and hard surface cleaners, as well as empty containers.  Currently,
there are 41 permanent HHW collection facilities in the state (Waste Watch Center, 1998).
Consumers are urged to buy products only in quantities they think they will need and to use up as
much of the product as possible, or give it away to someone else who can use it.  In the case of
unused pesticides, consumers are then encouraged to take them to a local HHW collection
facility or event. As part of the  state HHW program, Minnesota has an extensive consumer
education program, 'which provides detailed information for consumers on the best ways to store
and dispose of their unused pesticide and household cleaner products and containers.

The West Central Indiana Solid Waste District was one of the few states that made a distinction
between how they handle empty containers and unused product. For example, Indiana's State
Chemist's office has a program  for recycling empty pesticide containers into plastic lumber.
Unused pesticide and  hard surface cleaner product can be taken to collection centers operated by
solid waste districts, which either have permanent collection facilities or one-day collection
events.

Vermont handles pesticides and hard surface cleaners somewhat differently than the other states
that responded to the NAHMMA mailing. Vermont's pesticide regulations distinguish between
household, agricultural, and commercial pesticides on the basis of the materials themselves,
rather than on the basis of who uses them. All pesticides are subject to the  Vermont Department
of Agriculture, Food and Markets (DAF&M) regulations.  These regulations state that "obsolete,
excess, and mixtures of pesticides" have to be disposed of in accordance with Vermont's
Hazardous Waste Management  Regulations (which follow RCRA Subtitle C regulations). The
DAF&M regulations for pesticide containers state that "disposal of pesticide containers shall
comply with instructions on the labeling and with other state and federal regulations."

Finally, some states, including Texas and Wisconsin, which have statewide collection programs
for agricultural pesticides, will  accept HHWs in their collections if the agricultural collection
program has funds remaining. Alternatively, remaining funds and/or grants may be made
available to local governments to help them establish HHW collection programs or annual
collection events.

State and Local Requirements, Policies, and Programs for Recycling of Pesticide and
Hard Surface Cleaner Containers

The majority of the thirteen organizations that responded to the mailing said that they did not
have specific statewide regulations pertaining to recycling of pesticide and  hard surface cleaner
containers.  Because the vast majority of recycling programs are operated by municipal
governments that must coordinate with local waste hauling companies, it is up to the company
 and the local government to decide what materials can and. cannot be recycled. Market forces
primarily determine what materials end up being recycled. If a recycling company can cost-
 effectively recycle a specific material, they will be more willing to collect it. For example, in
 most states, certain "clean" plastics (i.e., plastics #1 and #2) are accepted for recycling; hard
 surface cleaner containers made of these types of plastics are usually accepted by recycling
 programs. Acceptance of aerosol containers containing haird surface cleaners for recycling,


        Chapter 6: Phase II Sub-Groups — Sub-Section 2 - Storage and Disposal Subgroup    131

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 however, is uneven. It is usually left up to the discretion of the waste haulers to decide if it is
 economical for them to collect these containers.
                                                         I                      •          i
 According to respondents, since pesticide containers (plastic and aerosol) may contain some
 residual chemicals, they may be considered to be hazardous wastes in some localities.
 Consequently, these containers may not be permitted in the local recycling stream or may not be
 collected by the local waste hauler. According to respondents, this exclusion occurs primarily
 because residual chemicals may increase the likelihood of contamination of other recyclable
 materials. Respondents noted that in some cases, waste haulers in their areas are reluctant to
 collect pesticide containers, because the cost of decontaminating their collection bailer far
 outweighs the benefits of collecting these types of containers. In most of the states that
 responded to the mailing, consumers are instructed to follow the directions on the product label
 for disposal instructions.

 State and Local Requirements, Policies, and Programs for the Recycling of Aerosol
 Containers

 Recycling of aerosol containers (usually cans) varies from state to state and from locality to
 locality. In all 12 states that responded to the NAHMMA mailing, consumers are asked to empty
 their aerosol cans prior to recycling or disposing. (Containers can be emptied either at a local
 HHW collection facility or event, or by making sure that all of the product is used up.)
 Acceptability of aerosol cans, either at recycling centers or through curbside programs, largely
 depends on the recycler's locality and whether the local recycling company will accept the
 material.  Some waste haulers are reluctant to collect aerosol cans because they say that it is
 difficult to determine if the can is completely empty or completely de-pressurized, and waste
 haulers say that this can lead to contamination and/or fire hazards for other recyclable materials.
 Acceptability of aerosol cans for recycling often also depends on the contents of the can. In most
 states, aerosol cans that  contained pesticides are usually not accepted for recycling (because of
 potential contamination and fire hazards). It should be noted, however, that the EPA's PR notice
 94-2 authorizes recycling of empty aerosol pesticide containers. In terms of aerosol cans that
 contained hard surface cleaners, however, it is up to the local recycling program to decide
 whether it will accept these cans.

 The CSMA and HIPIC countered the argument that there are risks associated with aerosol
 recycling, as many waste haulers stated, with data showing the growth in aerosol recycling in the
 U.S.  The presentation was given to the EPA in conjunction with other presentations made  by
 members of CSMA and HIPIC in May 1998. (See discussion below).
                                                         j                                i
 Consumer Participation or Reaction to Local Hazardous Waste Pick-up Days or Amnesty
 Programs

 Many of the respondents did not distinguish between participation rates for pesticides or hard
 surface cleaners and all other hazardous wastes, most likely because this information is not
tracked separately by product type. In some states, information on overall  consumer
participation in pick-up/amnesty days is not tracked at all.  In most of the states that responded to
the NAHMMA mailing, consumer participation in hazardous waste pick-up days or amnesty
programs was reported to be "quite high." Most states reported an average participation rate of
between 3% and 5% of the population (i.e., local population).  Although the percent of the total

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population participating in these programs may seem low, HHW program managers say that
participation is "quite high" because the need for pick-up days and/or amnesty programs may not
be continuous; i.e., when an event such as this occurs the participation rate is high, but may seem
low when averaged over the entire population.

Consumer Participation or Reaction to Recycling Programs for Empty Aerosol or Plastic
Containers

Consumer participation in recycling programs for aerosol and plastic containers is mixed. Many
states do not break down data on consumer participation or reaction to recycling programs
according to the materials recycled.  A few states indicated that participation/reaction to
recycling programs for plastic containers tends to be higher and more positive than that for
aerosol cans.  According to these respondents, this difference occurs primarily because
consumers are familiar with recycling plastics, whereas recycling of aerosol cans is still a
relatively new idea in many communities.

Common Practices for Storage of Pesticide and Hard Surface Cleaners

Most of the 12 states that responded to the mailing indicated that they do not have specific
requirements or policies for storage of household pesticides, insecticides, and hard surface
cleaners, aside from the label instruction that says to "Keep out of reach of children." Minnesota
does, however, provide consumers with a flier on storage and use of general household
chemicals. In states that have established regulations for agricultural pesticides, there are
stringent regulations for the storage of these types of pesticides. For example, in Vermont, no
distinction is made between household and agricultural pesticides, and, therefore, household
pesticides must be stored in accordance with agricultural pesticide regulations. The regulations
state that these products must be stored so as to avoid leakage,  and to make sure that pesticide
containers are resistant to corrosion, leakage, puncture, or cracking.

Chemical Specialties Manufacturers Association (CSMA) and
Household and Institutional Products  Information Council (HIPIC)
Members' Presentations

The CSMA and HIPIC members' presentations began with a discussion of several risk
assessment studies.-Risk assessment estimates the potential for toxicity of chemicals to humans
or harm to the environment.  Conducting a risk assessment includes: hazard identification, dose-
response assessments, exposure assessments, and risk or outcome characterization.  In most
cases, toxicity risk to humans or harm to the environment is determined by hazard identification
and an evaluation of dose-response relationships; determining whether there is a hazard to
humans is often dependent on whether a dose-response relationship exists (Kimmel et al., 1990).
A dose-response relationship compares the actual concentration of toxic materials in the
environment with either the no-observed-effect-level (NOEL) and/or the lowest-observed-effect-
level (LOEL). The NOEL is the highest dose that can be given without any effects being
observed. The no-observed-effect-concentration (NOEC) is the highest concentration of toxic
material in the environment that does not cause an adverse effect to the environment and the
surrounding communities. The actual concentration of materials, sometimes referred to as the
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  predicted environmental concentration (PEC), is then compared to the NOEC to determine if the
  concentration of materials in the environment may be potentially harmful.

  Several methodologies may be used to assess the environmental fate of a chemical. The most
  common is mathematical modeling of the fate and transport of the chemical in the environment.
  Other methods include chemical analysis, either through laboratory simulations of "real-world"
  situations, or through representative environmental samples (RES) (long-term monitoring of the
  environment). These last two methods are used less frequently due to the immense costs
  involved.

  Several factors are taken into consideration to determine the PEC. First, characterization of the
  chemicals themselves and information on potential emissions is made.  Additionally, a pathway
  analysis (i.e., the most likely pathway, either air, water, or soil,) for the emissions is determined.
  Finally, assessment of the endpoint for the chemicals is conducted. Emissions estimates and
  physical and chemical data feed into an assessment of the fate of the chemical(s) in the
  environment. This is what is used to determine the PEC. If the ratio between the PEC and the
 NOEC is less than or equal to one, then it is safe to dispose of the chemical in the environment in
 the quantities estimated.  Generally, for acute effects a safety factor is included.  If the ratio is
 greater than or equal to one, then the concentration of chemical in the environment may cause
 potential harm to the environment.

 Environmental Risk Assessment of Consumer Products: Introduction and Evaluation of
 Publicly Owned Treatment Works (POTWs)

 The Procter and  Gamble Company (P&G) presented the findings from an environmental risk
 assessment of disposing consumer products (such as household cleaning products) to publicly
 owned treatment works (POTWs). P&G's risk assessment study utilized a mathematical model
 and laboratory data. The model looked at the disposal of household products typically designed
 for "down the drain" use, for the entire U.S. population that is connected to POTWs (about 75%).
 P&G pointed out that products are formulations of different chemicals (e.g., active ingredients,
 carriers, and additives), and each of these components has a particular fate in the environment.
 P&G's model assumed both a typical disposal of the product consisting of release of the product
 to the sewage system during normal use of the product, as well as a worst-case scenario in which
 the entire product is dumped  down the drain.

 The model examined what the effects to a POTW's functionality would be if excess amounts of
 major domestic detergent surfactants used in household products, perborate (bleach), or
 quaternary ammonium chloride compounds were put down the drain. To determine the effects
 on a POTW, the efficiency of aerobic and anaerobic functions of the microbes responsible for
 waste removal in POTWs was studied.  From these studies P&G determined that none of the
 products, in the amounts tested, would have a negative effect on the functionality of a POTW.
 Thus, P&G concluded that POTWs are capable of handling household consumer products, even
 in worst-case situations.

 Septic Systems — Product Use and Disposal

The second presentation was made by The Clorox Company (Clorox), a leading manufacturer of
household cleaning products.  Clorox described why studying septic systems is important
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(approximately 25% of the U.S. population uses septic systems to treat their wastewater), and
how down-the-drain products are tested and evaluated to determine the products' impact on
septic systems.

The presentation began with a brief overview of how septic systems operate and a description of
the test procedures used to measure the impact of down-the-drain products on a septic system.
Septic tank compatibility of down-the-drain products is determined by evaluating microbial
toxicity, sludge setting, and the biodegradation/removal potential. In addition, there are
laboratory mini-septic systems that monitor coliform count, pH, chemical and biological oxygen
demand and wastewater flow rates. The results of these tests are used to develop no-observed-
effect-concentrations (NOEC). Information on consumer use habits and packaging size allows
for developing a Predicted Environmental Concentration (PEC). The NOEC is compared to the
PEC. The greater the NOEC/PEC ratio, the greater the safety margin. As the safety margin
increases, the risk associated with adverse effects decreases.

Clorox presented a hypothetical example of consumer normal use (1/4 cup/gallon; 1-5 times per
week), heavy use (Y2 cup/gallon; 8 times per week), and worst-case misuse (1 gallon; largest
container) of a down-the-drain product. Based on the above consumer use patterns, the PEC is:
normal use — 21 to 105 milligrams per liter (mg/liter); heavy use — 335 mg/liter; and worst case
— 1,335 mg/liter.  Assume that test results indicate a NOEC of 2500 mg/liter. Then, even under
the worst case scenario (consumer disposing entire content of largest container directly into
septic tank), no adverse effects would be expected.

Clorox also presented screen test results that examined the effects of disposing copious amounts
(i.e., 10-300 times normal use) of household ingredients into a septic system.

Environmental Risk Assessment: Municipal Solid Waste Landfills (MSWL)

The final presentation of risk assessment models was given by the Amway Corporation
(Amway). Amway presented the findings of a risk assessment model that examined the effects
of disposing household products to municipal solid waste landfills (MSWL). Amway presented
a comprehensive model of the various stages of conducting a risk assessment of disposing
household products to MSWL.

The first step is identifying the hazards and the risks of this type of disposal  by determining the
exposure compartments (e.g., hazards of raw material components, hazards of using the products,
hazards during storage and disposal of the product) and the hazard identification (i.e., the
toxicity, reactivity, flammability, and corrosivity of the products). Toxicity  was chosen as the
primary hazard because it is not necessarily mitigated by landfill dilution, as are the other hazard
characteristics usually cited for municipal solid wastes. Also, toxicity could potentially
aggregate in the leachate and should be accounted for using a rigorous risk assessment model as
the one presented by Amway.

The second step assesses risk by identifying the various routes of product disposal (e.g., down
the drain, through MSWL, recycling, composting, or special collections), and the various routes
of exposure of the product (i.e., surface water, ground water," air, and direct contact).
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The model tested the potential effects of disposal of household hazardous products on a RCRA
"Subtitle D" MSWL, assuming a worst-case scenario (i.e., 100% emission to leachate and 100%
emission to air). RCRA Subtitle D landfills have to comply with regulations concerning
specified soil types, and be sited to avoid sensitive areas and seismic activities; the landfill must
be equipped for venting of gases, and must meet specific liner requirements (usually double-
lined). Finally, leachate from these landfills must'be monitored, and there must be continuous
monitoring of the landfill liner to detect any failures.

Amway also presented several case studies, utilizing risk assessment models, in which the typical
concentrations of household products such as, toilet bowl cleaners, glass cleaners, and bleach,
disposed of to MSWL, were compared to the NOEC for these products in landfills. In almost all
of the cases, it was found that these types of household products do not pose an adverse threat to
the functionality of MSWL; RCRA Subtitle D landfills are capable of handling the
concentrations of household products that consumers dispose into them.

Aerosol Containers Handled Through the Recycling and Solid Waste Streams

The CSMA and HIPIC made a presentation on the advantages of recycling empty aerosol
containers. They pointed out that the majority of aerosol cans are made of recyclable steel, and
that the majority of them are made with 25% or more recycled content.  Steel is the most
recycled commodity. It was pointed out that steel manufacturers have use for the high-quality
steel from which aerosol cans are made. Recycling of empty aerosol cans benefits the
environment and is economical. The CSMA and HIPIC pointed out that if all empty aerosol cans
manufactured in the United States per year were recycled, there would be enough empty
household residential aerosols to manufacture 160,000 cars. They also emphasized that steel
recycling is energy efficient, stating that every pound of steel recycled saves 5,450 BTUs of
energy, and that every ton of recycled steel saves 2,500 pounds of iron ore, 1,000 pounds of coal,
and 40 pounds of limestone.

Data were also presented demonstrating the growth in empty household residential aerosol
recycling. In the early  1990s, only one community recycled empty household residential
aerosols, compared to 5,000 communities today that include aerosols in their recycling programs.
Additionally, several states have issued statewide endorsements stating that they support and
encourage the recycling of empty aerosol containers in their recycling programs.  These states
include Michigan, Wisconsin, Illinois, New Jersey, Ohio, Florida, North Carolina, Pennsylvania,
Texas, and California.  (The CSMA and HIPIC provided supporting letters from each of these
states, highlighting their support for aerosol recycling in their state recycling programs.)

Finally, the CSMA and HIPIC presented data from a risk assessment study that was sponsored
by the CSMA and conducted by the Factory Mutual Research Corporation (an independent fire
engineering research group), which studied the risks of aerosol containers in Material Recycling
Facilities (MRF). The study focused on the potential for release of container contents, the
potential for ignition, and the potential for fire or explosion during the pre-bailing, bailing, and
post-bailing stages.  It was found that because of the operating conditions in MRFs, and in the
bailers in particular (e.g., there is not much air circulation within the bailer itself, and therefore
little likelihood of materials in the bailer igniting), the risks of these types of accidents were
minimal and comparable to other risks in the facilities. The CSMA and HIPIC concluded their
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presentation with a brief overview of ways in which risks at MRFs that handle aerosol containers
may be minimized.  For example, one of the primary ways to reduce risk is through consumer
education efforts that inform consumers to use up all of the product in the container and to place
only empty aerosol containers in the recycling bin. Similarly, education of employees working
at MRFs can help to minimize risks as they become more adept at handling loads that include
some of these containers. Finally, adding magnetic separation (so that only the empty cans are
picked up) or ventilation to bailer operations can further decrease the chances of explosions or
fires.

Trends in Household Insecticide Technology Relevant to Product Safety and Household
Hazardous Waste (HHW) Considerations

S.C. Johnson and Son, Inc. (S.C. Johnson) presented data on recent trends in the household
insecticide products (HIP) industry, as well as information regarding whether these products
should be categorized as HHW. For purposes of this discussion, the focus was on insecticides
used indoors (HIP); lawn and garden products were not considered.  S.C. Johnson began by
presenting summary data on the different types of products that make up the household
insecticide product category.

Information on the trends in the active ingredients used in indoor insecticide spray products was
presented. The data demonstrated that, over the past six decades, the trend in the types of active
ingredients used in these products has been to eliminate the use of chemicals, such as chlorinated
hydrocarbons (DDT and chlordane), and increase the use of synthetic pyrethroids and natural
pyrethroids. Additionally, these "newer" active ingredients are more efficient, and are therefore
typically used at significantly lower concentrations than their predecessors. Similarly, another
trend in indoor insecticides has been to substitute water for organic solvents as the diluent in
ready-to-use sprays. As an example, Raid™ Ant and Roach Killer, the leading product in this
category, now has 60% water in its product formulation, whereas before 1995, this same product
had no water in its formulation. This trend is consistent among other Raid™ products, with some
products (Raid™ trigger products) containing as much as 97% water.

Additionally, natural and synthetic pyrethroids have much lower leachability potentials, and
therefore less potential to contaminate groundwater sources.  (Indoor insecticides may have
potential for groundwater contamination through leaching of active ingredients through soil
layers in and around landfills.) S.C. Johnson's research showed that the most commonly used
active ingredients in household insecticides today (i.e., synthetic pyrethroids and certain active
ingredients used in bait forms) are either too insoluble in water, or they tend to be too tightly
bound to soil particles, to have any significant leaching potential to groundwater sources The
exceptions to this are active ingredients such as diazinon and propoxur (Baygon), which are not
often used in HIP these days, can be found in residual quantities in soils, and have some slight
capacity to partition to soil water and move with the water.

To support these findings, S.C. Johnson presented data on certain physical/chemical parameters
relevant to environmental fate for active ingredients used in HIP, and data from the EPA's
Pesticide in Groundwater Database on detection of active ingredients used in insecticides in
groundwater.  These data are based on monitoring studies conducted between 1971 and 1991
throughout the U.S. The data showed that, with the exception of detections of insecticides in
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 agricultural areas, concentrations of insecticide active ingredients typically did not exceed
 allowable maximum contaminant levels (MCL) set by the EPA.

 Finally, S.C. Johnson pointed out that there have been recent shifts in the types of insecticides
 being used by consumers.  Traditional sprays and foggers have been joined by, and to some
 degree replaced by, insecticides in forms such as baits that are sold in child-resistant plastic
 stations and non-chemical devices such as sticky tapes that trap insects. Additionally, research is
 being conducted on the possibilities of efficient use and marketing of "bio-pesticides," though
 this category has not achieved significant marketplace success among HIP to date.

 Given the data presented and the fact that household insecticide products as discussed have not
 always been considered to be "toxic" or "acutely toxic" under either RCRA or FIFRA
 regulations, S.C. Johnson offered the opinion that these types of pesticides should not be
 considered "household hazardous wastes," and they do not need to be diverted from municipal
 solid waste streams.
                                                       i                               |

 Waste Watch Center (WWC) Report on Household  Hazardous Waste
 (HHW) Programs

 The WWC provided the EPA with a listing of HHW programs in the United States, as of 1997.
 The data include both permanent and non-permanent HHW programs; farm and conditionally
 exempt small quantity generator waste; specialized programs, such as those that collect only
 paints, only farm pesticides, or only dry cell batteries; and curbside or special used oil collection
 programs. Waste Watch Center defined a HHW program as being permanent if the program had
 "at least monthly collections held at either a fixed site or at a dedicated mobile facility" (WWC,
 1998). Since no central directory of HHW programs currently exists, WWC complied the data
 from various sources, including state and municipal information, project sponsor materials,
 personal contacts, and reporting forms.

 In discussions regarding the data provided by WWC, the CLI Storage and Disposal Subgroup
 pointed out several limitations. For example, although the data provided comprehensive
 information on the number of HHW programs in the country, it  did not provide population
 information, such as the number of people using these programs, or how many people are being
 served by each HHW program. Additionally, members of the Subgroup pointed out that
participation hi HHW programs is likely to be more erratic than, for example, a recycling
program. This implies that participation in an HHW program may therefore_not be as extensive
as the WWC data suggest. One member of the Subgroup mentioned that in his locality, HHW
collection events occur quite infrequently.  Therefore, if a consumer missed a collection date,
they would be more likely to place the HHW in the trash.

 WWC's Data on HHW Programs

The WWC's data provided some key findings, presented below, broken down by the data on
HHWs and information  on policies, regulations, and programs at the state and local level:

       •      the number of HHW programs in the U.S. has steadily increased since  1980;

       •      the total number of HHW programs in the U.S., as of 1997, was 14,591;

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       •      the total number of permanent HHW programs in the U.S., as of 1997, was 442
              programs;

       •      every state in the U.S. has some type of HHW program;

       •      items that are collected by HHW programs include, but are not limited to: used
              paints, used motor oils, pesticide, cleaning products, household batteries,
              fluorescent light bulbs, explosives, photochemicals, solvents, automotive parts,
              etc.;

       •      California, Florida, Massachusetts, New Jersey, Minnesota, and Washington have
              the largest number of HHW programs — each of these states has over 500 HHW
              programs throughout the state; and

       •      almost every state (except North Dakota, South Dakota, Nebraska, Louisiana,
              Mississippi, Georgia, West Virginia, and Maine) has at least one permanent HHW
              program, as defined by WWC.

The WWC compiled information from official records and documentation, as well as from
conversations with experts in the field, about existing state and local official and un-official
rules, regulations, policies, and practices that govern the disposal of HHWs.  Some of the types
of state, local, or regional regulations include the following:

       •      defining as hazardous wastes all household wastes that contain hazardous
              substances. Some states, such as California., do not allow these types of wastes
              into the solid waste stream;

       •      defining some products of wastes, which are solid wastes under RCRA, as
              hazardous;

       •      having land bans that exclude certain hazardous products from landfills;

       •      prohibiting certain hazardous wastes from being placed in the trash or brought to
              some solid waste companies or municipal solid waste (MSW) facilities (i.e.,
              composting facilities and incinerators);

       •      requiring that products containing certain hazardous substances be labeled to
              inform consumers that these products should not be placed in the trash;

       •      requiring manufacturers to take back discarded products from consumers, so that
              local governments are relieved of paying for their disposal and/or recycling costs
              (e.g., in New Jersey); and

       •      mandating that local recycling programs be established, and that these programs
              meet specific recycling targets.  Collection of household hazardous products by
              these recycling programs may help communities meet these recycling goals.
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In addition to the mandatory programs described above, several states and localities have
established non-regulatory approaches for managing HHWs — or, at the very least, to prevent
them from being placed in the trash or being dumped down the drain. Examples of these include:

       •      establishing state funded and operated HHW collections at local and regional
              levels;

       •      designating responsibility, often to the regional (rather than state) level
              government, to keep HHW and conditionally exempt small quantity generator
              (CESQG) wastes out of the solid waste stream;

       •      providing funding (e.g., in California, Vermont, Washington, Minnesota) to
              regional governments to develop a plan to manage HHW and CESQG wastes at
              the regional level;

       •      providing funding to local and regional governments to operate HHW collection
              days;

       •      providing funding to local and regional governments to establish permanent HHW
              collection facilities;

       •      establishing education programs in coordination with state, local, and regional
              HHW management programs;
                                                       i                               i
       •      adopting the EPA's Universal Waste Rule;

       •      developing manuals and training courses for consumers on the best ways to
              dispose of their HHWs as part of HHW management plans;
                                                       i                               i
       •      establishing product labeling requirements to help consumers identify products
              that contain hazardous substances; and

       •      providing consumers with information on alternative products that do not contain
              hazardous substances. Local governments have an interest in providing this
              information because they are the ones that bear the costs of managing HHWs in
              their waste streams.

Discussion Paper  Evolving from the 1995 Cleaning Products Summit
                                                       i                               I
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Representatives from state and local organizations in the Storage and Disposal Subgroup
provided a paper entitled "Concerns with Household Cleaning Products — A White Paper" to the
Storage and Disposal Subgroup  for its information and discussion. The Subgroup was never able
to discuss the paper in detail, however. The paper was written in  1996 by Philip Dickey of the
Washington Toxics Coalition (WTC) in collaboration with Dana Duxbury of the Waste Watch
Center (WWC), David Galvin of the King County Local Hazardous Waste Management
Program, Brian Johnson of the City of Santa Monica Environmental Programs Division, and
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Arthur Weissman of Green Seal. The paper discusses several issues relating to HHWs and to
household cleaning products. The paper was provided to the Storage and Disposal Subgroup as a
discussion paper to inform the Subgroup about:

       •      state and local agencies' concerns with current storage and disposal instructions
              on product labels, and to explain why state and local agencies advocate that labels
              instruct consumers to contact their local agencies for proper disposal instructions;

       •      to provide background on HHW programs; and

       •      to initiate discussion regarding the potential harmful effects of household cleaning
              products to the environment and to human health and safety.

The paper evolved from a meeting called the "Cleaning Products Summit" held in March 1995.
The paper addresses concerns raised by both those who work with HHW programs and
manufacturers of household cleaning products. In particular, it discusses the debate between
these two groups about the definition of HHW and the types of products that should and should
not be included in the definition. Manufacturers of household cleaning products argue that their
products should not be included in HHW programs because they contain only "small
concentrations of active ingredients" (Dickey et al., 1996, available in Administrative Record).
Those who manage HHW programs argue that household cleaning products should be included
in HHW programs because, even though concentrations of these ingredients may be low, the
active and/or inert ingredients contained in these products may be hazardous.

The discussion below highlights some of the topics covered in the paper.

Purposes of Household Hazardous Waste Facilities and Programs

The paper begins with a discussion of the purposes of HHW programs.  Manufacturers have
argued that HHW programs have traditionally handled only HHWs as defined under the
Resource Conservation and Recovery Act (RCRA). Consequently, these programs may not be as
useful as they once were, because so few of today's household products end up as hazardous
wastes as defined under RCRA.  According to the authors, however, HHW programs continue to
be useful and necessary because they do not simply collect wastes from households, but often are
the main waste collectors  for conditionally exempt small quantity generators (CESQG). As a
result they often collect products, for example, janitorial cleaning agents, which are hazardous.
Additionally, HHW programs collect wastes that have a hazardous component to them,
regardless of the volume and concentration of these hazardous components, because the
cumulative impacts of these chemicals may in fact have a significant impact on the environment
and to human health and safety.

Dickey et al. also point out that HHW programs have increased their function beyond that of
waste collection facilities.  Many HHW programs have extensive consumer education programs
that try to educate the public about issues other than disposal, of products alone, including the
proper storage and use of products, and their misuse, as well as pollution prevention and source
reduction in general. In addition, the authors point out that the materials brought into a HHW
facility (including household cleaning products, used motor oil, paints, pesticides, etc.),  are not
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always seen as "waste." These products can often be used for other purposes; many HHW
facilities are beginning to find ways to reuse and recycle the products brought into their facilities.

Definition of Household Hazardous Waste

There is a clear difference in how both HHW managers and manufacturers of household cleaning
products define HHW. Household hazardous waste managers generally define HHWs as waste
from residential sources that exhibits characteristics of hazardous wastes, such as: toxicity,
corrosivity, ignitability, or reactivity. Manufacturers of household cleaning products, as
represented by the Chemical Specialities Manufacturers Association (CSMA), define HHW as
any "discarded household material which creates by itself or in conjunction with other household
materials a verifiable level of toxicity that adversely affects health or the environment."

Dickey et al. point out that there is a clear distinction between the two definitions.  First, the
CSMA definition only considers the toxicity of a product and not any of the other characteristics
that hazardous wastes may exhibit. Also, they point out that unlike the CSMA definition, the
definition used by HHW managers does not simply consider the adverse effects of HHW, but
considers the potential dangers and/or risks of these wastes. Because of this difference in
definitions, household cleaning products are considered HHWs by most HHW program
managers, even though they may not be as hazardous as other materials collected by HHW
programs (e.g., paints or used motor oil).

Effects of Household Cleaning Products

The paper also provides details about the health and environmental effects of ingredients found
in cleaning products.  In particular, the paper discusses information and data on the health effects
of certain ingredients found in  some cleaning products, such as skin/eye/lung irritation,
inhalation problems, and carcinogenic effects.  Dickey et al. also provide information and
supporting data on the environmental effects that these ingredients can have when disposed of
down the drain or in the trash.  Examples include eutrophication of lakes, rivers, and estuaries;
biodegradability and bioconcentration of the ingredients; the effects of heavy metals and organic
compounds in household wastewaters; and the effects of volatile organic compound (VOC)
emissions from these products.

Concerns Regarding Household Hazardous Wastes

The paper specifically addresses several concerns about HHWs, particularly cleaning products
considered by managers of HHW programs to be HHWs.  Occasionally, localities will perform
"sorts" of their solid waste stream to assess what types of products  are in the waste stream.
According to several solid waste sorts, the average volume of HHW in the solid waste stream is
between 0.3% and 0.5% by weight (from Systems, 1985 and Rathje, Wilson et al., 1987, in
Dickey et al., 1996). Dickey et al. stress that even though these percentages are relatively small,
they can amount to significant quantities when converted to actual volumes of waste.
Additionally, even though these HHWs represent relatively small percentages  of the total
municipal solid waste stream, they contribute to the majority of the toxicity, corrosivity, and
reactivity of the wastestream.
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 Hazardous chemicals found in household cleaning products can pose other real risks to the
 facilities and workers who handle these wastes.  Hazardous wastes may leak out of trucks,
 loaders, and landfills. Chemicals may also react with other materials in the solid waste stream
 and cause acid or alkaline releases, as well as increase the risk of flammability. Workers who
 pick up household trash may be exposed to HHW chemicals that are mixed in with the municipal
 waste stream. Dickey et al. cite a California study done in 1982 which found that "3 percent of
 refuse collection workers in the state were injured due to contact with HHW" (California Solid
 Waste Board, 1984, in Dickey et al.,  1996).  Though national statistics for these types of
 incidents are rare, many local agencies are beginning to keep these types of statistics for their
 municipalities. They are also tracking the medical costs to localities arising from these kinds of
 injuries. In addition, many localities also state that the mitigation costs of chemical spills and
 exposures can be quite significant.

 Managers of HHW programs have expressed serious concerns about the potential for explosions
 and damage to waste handling equipment that may result from reactions between HHW
 chemicals or liquids and solid wastes. For this reason, HHWs are banned from the municipal
 solid waste stream in many localities.

 Dickey et al. refute the household cleaning product and household  pesticide manufacturers'
 conclusion that disposal of their products in the trash or down the drain does not present any
 significant adverse effects  to municipal landfills. Dickey et al. contend that these conclusions are
 based on studies of RCRA Subtitle D landfills, which are required to have a double lining at their
 base to prevent leachate from leaking into groundwater (See CSMA and HIPIC discussion
 above).  The authors add, however, that a large proportion of landfills in the U.S. were built prior
 to this requirement, and may therefore pose a risk of leaching into nearby groundwater.
 According to the paper, studies have shown that, in some cases, HHW chemicals have been
 found in these leachates and can be quite harmful (e.g., lead or mercury). Municipalities are now
 finding themselves in the position of having to pay for huge clean-up of these older landfill sites.
 The authors also cite studies that show that the lining in current landfills may eventually wear
 down and increase the chances of landfill leachates seeping into groundwater systems (LaPage
 and Winton, 1994, in Dickey et al., 1996).

 The paper concludes by recognizing that all products have environmental impacts.  Dickey et al.
 encourage product manufacturers to take these impacts, however minor, into consideration.  They
 suggest that manufacturers can do this by practicing resource-conservation and pollution
prevention, and by eliminating the use of chemicals (e.g., dioxin and its precursors) in their
products that are known to be harmful to human health and the environment.

 Findings from Telephone Conversations

 Several phone calls were made to individuals knowledgeable about  HHW management. Calls
were placed to trade associations such as the Steel Recycling Institute, the National Association
for Plastic Container Recovery, the Solid Waste Association of North America, and the
American Plastics Council. Calls were also placed to a few HHW management programs,
including those in Missouri, Nebraska, and Washington state.
       Chapter 6: Phase II Sub-Groups — Sub-Section 2 - Storage and Disposal Subgroup    143

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Many of the people contacted had information on regulations, policies, and programs regarding
disposal of containers, but were less able to provide detailed information on regulations, policies,
and programs regarding storage and disposal of unused product. Many thought that, in general,
consumers would likely have to dispose of unused product at permanent or mobile collection
facilities or events.  Several people stated that California and Minnesota were the only states, to
their knowledge, that mandated that unused HHW products be disposed of at local collection
facilities.
                                                         i                                i
The Steel Recycling Institute provided information about the recycling of aerosol cans.
According to SRI, there are 4,500 municipal locations, serving over one hundred million people,
that include aerosols in their recycling programs. SRI often works with local governments on
their recycling programs and provides guidance on how steel recycling can be incorporated into
their recycling stream.  In many localities recycling of aerosol cans is a relatively new concept.
Through its brochures and other literature, SRI provides guidance for proper disposal of aerosol
cans and their contents.  Consumers are instructed to make sure that aerosol cans are completely
empty before they can be recycled (either at the curbside or through a recycling center) in areas
where cans are accepted into the recycling stream.  Additionally, SRI instructs customers to take
aerosol cans, which are either not empty or too old and rusty for the contents to  be used up, to
special collection centers or events in their local communities, rather than recycling the can.
144    Chapter 6: Phase II Sub-Groups — Sub-Section 2 - Storage and Disposal Subgroup

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           CLI Storage and Disposal Subgroup Activities

Storage and disposal labeling issues were discussed during regular conference calls among
members of the Storage and Disposal subgroup. (For a complete list of Subgroup members
please see Appendix 1-8.) The Storage and Disposal Subgroup met weekly or bi-weekly, via
conference call, between February and September 1998. The Storage and Disposal Subgroup
was formed to make recommendations for improving storage and disposal information on
product labels, as well as to discuss potential problems and next steps in addressing storage and
disposal language changes on product labels. A challenge facing the group was to discover how
to provide universal language on a label that does not conflict with state and local regulations,
policies, and programs, but which informs consumers of proper storage and disposal procedures.
The Subgroup concluded that because product labeling is mandated on a federal level, label
language cannot address every variation in storage and disposal requirements, policies, and
programs across the nation.

Several suggestions were made by Subgroup members for changes to the current language on
product labels, but it was difficult for the group to come to a, consensus on a statement best suited
for each product category. It was also difficult for the Subgroup to reach a consensus on many of
the recommendations  suggested by Subgroup members, due to differing views and concerns.

The Subgroup convened in a face-to-face meeting on September 22, 1998, prior to the CLI
Partner and Task Force meeting. The purpose of the meeting was to come to an agreement over
issues that the group was unable to resolve or address over conference calls, as well as to make
recommendations to CLI Partner and Task Force members. The day was spent deliberating over
several issues, including the different viewpoints among industry and state and local agency
Partners, regarding the type of instructions that should be placed on product labels.  At the end of
the day, a consensus was reached regarding label language for empty containers, but not on the
appropriate language for partially-filled household pesticide containers or household cleaner
containers.

Areas of Agreement for Storage and Disposal  Label Language

The Storage and Disposal Subgroup agreed on label language changes for empty pesticide and
household cleaner containers. The group recommended that the language on these containers
read:

       "Place in trash.  Recycle where available."

The group suggested that the recycling statement be optional for manufacturers. The group also
recommended that manufacturers be allowed to use an optional statement that reads:

       "Do not re-use container."

Finally, the group agreed to have the storage instructions on product labels remain as they
currently appear.
      Chapter6: Phase II Sub-Groups — Sub-Section 2-Storage and Disposal Subgroup    145

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 Areas of Disagreement for Label Language

 The Storage and Disposal Subgroup debated over several months about the appropriate language
 for partially-filled pesticide and household cleaner containers. They never reached a consensus.
 The group suggested that the decision for any change to label language (i.e., for language on
 empty cleaner and pesticide containers) be delayed until the EPA makes a policy decision about
 how to handle partially-filled containers.

 Representatives from state and local organizations suggested changing current label disposal
 language to instruct consumers to first call their local waste authority to get proper disposal
 instructions for their locajities, and, if not told otherwise, to dispose of the product in the trash.
 They argued that current disposal language is often in conflict with their own laws, practices, or
 programs, which ban HHWs from municipal landfills. Label language should therefore instruct
 consumers to contact their local authorities to get the correct disposal instruction for their area.
 Representatives from state and local organizations in the Storage and Disposal Subgroup issued
 the following statement at the CLI Partner and Task Force meeting (September 1998):

       "The CLI Subgroup representatives from state and local organizations have agreed that the
       status quo disposal instructions are unacceptable to some state and local programs. Existing
       label instructions result in unfair CERCLA liability for local agencies as well as sanitation
       worker injuries due to HHW releases from the solid waste system. Additionally, local HHW
       programs attempt to be consistent with the EPA-endorsed waste management hierarchy or reuse
       and recycling before disposal.  For partially-filled containers, the statement "call your local
       environmental, health, or waste department for disposal instructions" is appropriate."

 The suggestion to place a statement to contact local authorities was rejected by most of the
 industry Stakeholders in the Subgroup, who argued that instructing consumers to contact their
 local authorities or HHW programs to get proper disposal instructions would give consumers the
 impression that then" products are harmful.  They also argued that many of these programs often
 misrepresent and give consumers wrong information about their products. Industry Stakeholders
 in the Subgroup argued that their products are safe to dispose of in the trash or down the drain,
 and should not be classified as HHW. They provided evidence in support of this (see CSMA and
 HIPIC discussion, above). They said that state and local organizations did not provide scientific
 evidence for their conclusions.  Additionally, industry representatives argued that putting a
 statement such as "call your local authority..." would be confusing for consumers, because it is
 difficult for consumers to know which agency is the proper one for them to contact.
 Furthermore, industry representatives cite data that found that the majority of people usually use
up all of the product in a container before disposing of it. The  representatives argue that the
 disposal of partially-filled containers is not as significant as state and local organizations claim.
The industry representatives from the household cleaner and indoor insecticide industry, as
represented by CSMA and HIPIC, issued the following statement at the CLI Partner and Task
Force meeting (September 1998):

       "The majority of industry participants believe there is a substantial body of scientific support for
       making the recommendation to dispose of CLI-coveredproducts through the normal waste
       systems, either in the trash or down the drain, depending on the product type. No such scientific
       support for directing consumers to call their local authorities for alternate disposal methods has
       been presented to the Subgroup.  Therefore, making such a change to the label is unjustified. We
146    Chapter 6: Phase II Sub-Groups — Sub-Section 2 - Storage and Disposal Subgroup

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       are also concerned about referring consumers to local authorities that are disseminating
       inaccurate information. Many products are mis-characterized as hazardous by local agencies
       and inappropriate information on 'alternatives' is also provided as well. Furthermore,
       consumers may not have easy access to their 'local authorities' and may not even know which
       agency to call."

State and local authorities believe the industry data that supports the above statement are limited
and based on limited risk assessments (e.g., considering only the effects to RCRA Subtitle D
landfills without studying the effects of HHW leakage in older, unlined landfills). Additionally,
they state that industry studies are based on limited products and formulations and do not take
into account the cumulative effects of all of the ingredients in these products, many of which
may be considered hazardous.

Some industry representatives in the Storage and Disposal Subgroup from the outdoor pesticide
industry do, however, view some of their products differently. These representatives stated that
they do not have evidence to show that their products are safe to dispose of down the drain, and
they are not opposed to directing consumers to contact their local waste handling agency for
disposal instructions.  It should be noted, however, that this is not the view shared by the entire
outdoor pesticide industry.

Other general recommendations and suggestions were made to the CLI Partner and Task Force
members at the September meeting. These are discussed in the recommendations chapter
(Chapter 9).

Suggestions for  Label Language for Partially-filled Containers

Although no consensus was reached at the September 22, 1998, face-to-face meeting on the issue
of partially-filled containers, the Subgroup did make several suggestions over the course of the
conference calls, for label language for different types of products (e.g., pesticides, household
cleaners, liquids, solids, etc.) presented below. The arguments for and against these statements
are  also presented wherever possible.

Disposal of Partially-filled Liquid Cleaner Containers

Several suggestions were made for label language for partially-filled liquid cleaner containers:

1.      Representatives from state and local organizations in the Subgroup suggested that these
       containers say, "Call your local environmental, health or waste department for specific
       disposal instructions. If no restrictions, pour down the drain while running water. Do
       not mix with other products during disposal."

2.      Industry representatives suggested, "Pour product down the drain while running water
       [Do not mix with other products]," with the latter part of the statement being optional.

Both of these suggestions have associated tradeoffs. Both options allow for disposal of the liquid
cleaner down the drain.  The first option, however, is too long to fit on a product label.  Some
members of the Subgroup pointed that the second option conflicts with some  state and local
laws,  polices, and practices.
       Chapter 6: Phase II Sub-Groups — Sub-Section 2 - Storage and Disposal Subgroup    147

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 Disposal of Partially-filled Liquid Pesticide Containers

 Three suggestions were made by members of the Subgroup for label language for partially-filled
 liquid pesticide containers:

 1.     Option 1 read, "Call your local waste disposal service.  If local laws permit, put partially
       fall container in trash. [Never pour product down any drain]," with the latter part of the
       statement as optional.

 2.     Another option read, "Call your local environmental, health or waste department for
       specific disposal instructions."

 3.     The third statement suggestion was for the label to say,  "Place in trash."

 Both the first and the second options were seen by state and local organi2ations representatives
 as viable, since they did not contradict state and local laws or practices.  Also, the first option
 gave consumers an alternative if they found that there was no local guidance for disposal of
 liquid pesticide containers. The third option was seen as contradicting some state and local laws,
 practices, and regulations.

 Disposal of Partially-filled Aerosol Containers

 There was disagreement from both the representatives from  state and local organizations and the
 industry representatives on suggestions for disposal instructions for partially-filled aerosol
 containers. The following three suggestions were made, but no consensus was reached for
 reasons outlined above.

 1.     "Call your local environmental, health or waste department for specific disposal
       instructions."
                                                          i
 2.     "Place in trash."

 3.     "Call your local waste disposal service. If local laws permit, place partially full
       container in trash."

 Except for the second suggestion, all of the above options would allow consumers to be in
 compliance with any state or local practices concerning the disposal of partially-filled aerosol
 cans. The third option also gives consumers alternatives if there are no specific guidelines for
these containers. As with liquid cleaner and pesticide containers, the option to place the
 container in the trash is not an ideal one for state and local organizations, as this instruction can
 contradict state and local laws and practices.

 Disposal of Partially-filled Solid Cleaner Containers

As with liquid and aerosol containers, industry representatives suggested that the text on labels of
partially-filled solid cleaner containers read,  "Place in trash," whereas representatives from state
 and local organizations wanted it to read,  "Call your local environmental, health or waste
 department for specific disposal instructions." Arguments similar to those above were made for
both of these statements. Agency representatives felt that instructions to call a local waste
148    Chapter 6: Phase II Sub-Groups — Sub-Section 2 - Storage and Disposal Subgroup

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department for disposal instructions has the added benefit that if specific instructions are not
available, then the agency would likely encourage the consumer to use up the product or give it
to someone who can use it up. This direction would allow consumers to practice source
reduction, which is preferred over disposal for managing wastes.

Disposal of Partially-filled Solid Pesticide Containers

Similar suggestions were made for partially-filled solid pesticide containers:

1.     Industry representatives favored the statement, "Place in trash."

2.     Representatives from state and local organizations wanted label language to be changed
       to read, "Call your local environmental, health or waste department for specific disposal
       instructions."

Similar arguments for and against each of these statements were offered by both groups of
Stakeholders in the Subgroup.

As mentioned above, no consensus was reached on an appropriate statement for partially-filled
containers, and it was decided that any change of this sort would have to be a decision of the
EPA.

Finally, CSMA and HIPIC representatives suggested to the Subgroup that a committee be
formed to develop risk-based criteria for directing particular consumer pesticides that may
warrant special handling to waste collection programs, such as household hazardous waste
programs.  They suggested that the committee be composed of experts from the field of risk-
assessment, EPA, consumer pesticide manufacturers, the solid waste management industry, state
and local HHW programs, and other appropriate  experts. The suggestion was rejected, however,
by members of the Subgroup from state and local agencies who argued that the decision to divert
some of these products to HHW programs should not be based solely on risk assessment studies.

Storage and disposal issues were addressed again at a CLI Partner and Task Force meeting in
April 1999. Jean Frane, of the Office of Pesticide Programs (OPP), briefly summarized recent
OPP activities relating to storage and disposal issues, specifically addressing the impasse reached
by the Storage and Disposal Subgroup (i.e., the conflict between storage and disposal
instructions on some product labels and local/state regulations, policies, or practices).  At this
meeting, it was pointed out that states are reluctant to advance the "Read the Label FIRST!"
campaign while there are still outstanding unresolved issues concerning the storage and disposal
section of the label. Although no new language has currently been proposed, OPP met with
representatives of state and local organizations, as well as representatives from industry, and
expects to have a proposal on storage and disposal language by Fall/Winter 1999.
       Chapter 6: Phase II Sub-Groups — Sub-Section 2 - Storage and Disposal Subgroup     149

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         SUB-SECTION 3: Consumer Education Subgroup

 In Phase I of the CLI, research findings, literature review summaries, and Stakeholder comments
 indicated that many consumers do not consistently or thoroughly read or use the labels of indoor
 insecticides, outdoor pesticides, and household cleaning products. For this reason, changes to
 label information or design will not lead to significant benefits to consumer knowledge,
 understanding, or health and safety—unless consumers first readfae labels.

 Consumers have also stated in a variety of research arenas that they do not understand much of
 the content of many of these product labels. In addition—and more importantly from the point of
 consumer education—they have expressed that they often do not feel motivated to read the labels,
 because they see little personal benefit in doing so.

  Overview and Goals of the Consumer Education Campaign

 A primary goal of the Consumer Education Campaign is to increase consumer awareness of label
 information on a national level. Reaching consumers nationwide can represent a major
 commitment of tune and resources. The CLI benefits greatly from equal involvement of a
 variety of participants, many of whom have the ability and willingness to help produce and
 disseminate consumer education materials. The campaign thus involves and encourages the
 participation of many organizations that represent avenues for reaching consumers directly, such
 as:

       •     CLI Partners' organizations;

       •     state and local government agencies;

       •     non-profit organizations;

       •     schools, libraries, and civic groups; and

       •     local media, such as newspapers, magazines, radio, and cable channels.

 Such broad participation by many organizations greatly increases the possibilities for exposing
 consumers to repeated messages, and thus increases the success of the campaign.

The CLI's goals included:

       •     improving product labels so that they would be easier for consumers to
             understand;

       «     helping consumers to become more aware of product labels and the information
             they contain;

       •     helping consumers to feel more motivated to read and understand label
             information;

       •     giving consumers better tools for understanding label information; and

          	  	             ^	                r   '     •	        	
150   Chapter 6: Phase II Sub-Groups — Sub-Section 3 - Consumer Education Subgroup

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       •      encouraging consumers to more consistently and more thoroughly read labels of
              these products, prior to purchase, use, storage, and disposal.

To address these goals, the CLI established a Consumer Education Subgroup in Phase II, to
encourage safe and environmentally responsible behavior by consumers regarding indoor
insecticides, outdoor pesticides, and household cleaning products.  This group included more
than 20 participants, representing organizations that have an interest in consumer education
issues related to product labeling.  Various businesses, state agencies, non-profit organizations,
other organizations, and EPA staff members are represented.  The group was expanded according
to the recommendation presented by the Phase II research., to include marketing, brand, outreach,
education, and public relations experts. The complete list of participants can be found in
Appendix 1-9.

The CLI was initiated to identify ways to:

       •      increase reading and use of labels;

       •      decrease the misuse of products;

       •      decrease the incidence of accidents involving products; and

       •      decrease environmental impacts caused by improper storage and disposal.
        Chapter 6: Phase II Sub-Groups — Sub-Section 3 - Consumer Education Subgroup    151

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            CLI Consumer Education Subgroup Activities

 During Phase II, meetings of the subgroup occurred approximately every two or three weeks,
 mainly through conference calls. All members of the subgroup received advance notice of the
 calls, and future meetings were tentatively scheduled during these calls.  An average of more
 than a dozen participants attended these calls. Participants discussed the concept and need for an
 education campaign logo, slogan, materials to be used for consumer education, media venues,
 and strategic plans.  Feedback from all participants was always encouraged; whenever possible,
 Stakeholder opinions were weighed heavily in making decisions. After the September 1998
 Partner and Task Force meeting, the Subgroup was divided up into smaller groups targeting
 message development for consumer education materials, the placement of the consumer
 education materials, and the development of a consumer education campaign logo.  Based on
 recommendations from the meeting, Partners were asked to encourage the participation of key
 marketing personnel from their organizations.

 The Consumer Education Subgroup conceptualized, developed, and began implementing a
 broad-based, long-range consumer education plan intended to help people to read, understand,
 interpret, and use label information.  The Subgroup developed an easily understood
 message—"Read the Label FIRST!"—and, at the time this report went to press, was in the process
 of developing a unique, memorable, consumer-friendly logo.  The Subgroup also drafted text for
 outreach brochures targeting gardeners, children's health, pet protection, and household products,
 that was presented at a Partner and Task Force meeting in April 1999.  The various components
 of the campaign will be designed to work with and reinforce each other.

 Components of the Consumer Education Plan

 The EPA and its CLI Partner and Task Force members intend to begin implementing the
 consumer education effort in Spring 2000 with the public launch of the nationwide "Read the
 Label FIRST!" campaign. This launch is timed to coincide with the appearance of newly
 redesigned labels on store shelves and with the consumers' general interest in seasonal gardening
 and cleaning activities. Eventually, the Consumer Education Subgroup intends to finalize and
 make available to the public a variety of materials, possibly including but not necessarily limited
 to the following:

       •     brochures or flyers for a general consumer audience, pet owners, parents, and
             gardeners;

       •     posters;

       •     a fact sheet on label changes resulting from the CLI;

       •     camera-ready logos; and

       •     a publicity guidance document outlining a variety of cost-effective ways to use the
             Campaign's logo, slogans, taglines, brochures, and other materials.
152   Chapter 6: Phase II Sub-Groups — Sub-Section 3 - Consumer Education Subgroup

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To make the Campaign materials useful to as many organizations as possible, the Consumer
Education Subgroup hopes to make the materials available in easy-to-use formats. Restrictions
on how organizations may use the materials will be minimized.

At this point in time, the Consumer Education Subgroup expects to use a variety of methods to
announce and distribute materials for the Campaign, potentially including the following:

       •      sending camera-ready materials to all CLI Partners, Task Force Members, and
              Consumer Education Subgroup members, via regular mail and e-mail;

       •      distributing materials to trade associations for certain audiences (e.g., the national
              Parent-Teacher Association);

       •      distributing materials through product manufacturers (who often provide
              information at point of purchase, via mailings, etc.);

       •      posting of materials on the CLI website, available for downloading; and

       •      mailing press releases and information packets to appropriate organizations.

To be effective, consumer education needs to be directed toward identified needs. Therefore, the
work to be implemented by the Consumer Education Subgroup depends on decisions and
recommendations made by other CLI subgroups. Findings from other components of the CLI
have and will continue to feed into the work of the Consumer Education Subgroup.

The intent of the Campaign is to have consistent, mutually reinforcing messages targeting
specific consumer audiences and originating from all CLI participants and interested groups.
The "Read the Label FIRST!" message will thus come from government, industry, health,
environmental, and consumer groups alike. The slogan and logo are designed to be accompanied
by reasons why reading the label is important, addressing the main motivating factors for label
reading that were identified in the quantitative and qualitative research. Child and pet safety,
environmental benefits, and gaining the best value  for money spent will feature among the top
reasons to read labels and follow label directions.

Following its initial emphasis on getting consumers to notice and read labels, the intent of the
CLI is to expand the Campaign to help people better understand the information that appears on
labels. This would include education in the meaning and use of signal words (CAUTION,
WARNING, DANGER), as well as information designed to teach people why environmental
information and storage and disposal information — which research shows are among the least
often read sections on the label — are important to the consumer.

The Consumer Education Subgroup has proposed a long-range Campaign designed to unfold,
expand, and develop over a number of years, including nationally televised ads and educational
curricula.
       Chapter 6: Phase II Sub-Groups — Sub-Section 3 - Consumer Education Subgroup    153

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                                  CHAPTER 7:
         PARTNER AND TASK FORCE MEETINGS
CLI Partner and Task Force members met four times during Phase II of the CLI. These meetings
were used to provide updates on the progress of the project, as well as to obtain consensus on
decisions that needed to be made during Phase II of CLI. During these meetings, sub-groups
presented their findings to the CLI Partner and Task Force members and other interested
Stakeholders.  Future CLI activities were also discussed and planned.

          March 20, 1997 CLI Phase  II "Kick-off" Meeting

In March 1997, CLI Partner and Task Force members met to begin work on the second phase of
the CLI. The meeting began with a review of the key points coming out of Phase I of the CLI as
a setting for the initiation of Phase II.

At this meeting, EPA announced that budgetary and Paperwork Reduction Act constraints would
make it impossible for the Agency to fund quantitative research of the type and magnitude that
had been recommended by Phase I of the CLI. The Agency indicated that it would neither
require nor request that such research be done, although it conceded that quantitative research
would be extremely valuable. Several of the CLI industry and trade association partners decided
that the research was too important to be eliminated from the program, and volunteered to fund
and direct it, with input from all of the CLI participants. The EPA's role in connection with the
quantitative research has thus been one of a facilitator, consultant, and recipient.

Three of these industry partners presented a research plan for the Phase II quantitative research at
this meeting. The Bayer Corporation, Procter and Gamble, and S.C. Johnson and Son, Inc. gave
this presentation.  Discussion on the research plan included, but was not limited to: making sure
that the questions be clear in asking consumers what they understand about labels and not what
they preferred; providing a 'mock-label' to consumers; collecting data on consumer attitudes
toward products; collecting information on standardized environmental information.

The EPA also announced that there would be a meeting between the EPA and environmental and
public interest groups in  April 1997, and invited CLI Partner and Task Force members to attend.
The purpose of the April meeting was to update these groups on the progress of the CLI, and to
obtain their input and participation for its development.

The meeting was  also a forum to re-cap the immediate and longer term label changes that could
be made as a result of Phase I of CLI. Immediate label changes included: 1) inclusion of a toll-
free number on product labels, so that consumers have someone to call in case of emergencies; 2)
using the common names of ingredients instead of their chemical names; 3) using the word
"other ingredients" instead of "inert ingredients; and 4) using a clear heading for the first aid
section of the label, which is to  read "First Aid," instead of "Statement of Practical Treatment."
                       Chapter 7: Partner and Task Force Meetings
155

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 Longer-term changes would be addressed by Subgroups and included: 1) further investigation of
 First Aid statements; 2) further investigation of the ingredients issues (i.e., right-to-know issues
 regarding full disclosure of ingredients); and 3) further investigation of the storage and disposal
 issues, and how to address the conflict between label language and state and local policies,
 regulations, and practices.
                                                                                        j
 During this meeting, the EPA announced that they are interested in investigating the idea of a
 standardized "eco-facts box" on product labels (like the nutrition box).  The EPA suggested
 investigating this through the quantitative research.

 Finally, the Minnesota Pollution Control Agency presented details of its Consumer Label
 Education Program as a stepping stone for the CLI consumer education effort. It was decided
 that any consumer education campaign for CLI should focus on "reading the label," rather than
 on infrequent but real risks of the products themselves.

 For details on the discussion that took place during this meeting, refer to Appendix 7-1.
156
Chapter 7: Partner and Task Force Meetings

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          February 1998 Partner and Task Force Meeting

The second meeting took place February 17-18, 1998, in Alexandria, VA. The meeting was
announced one to two months prior to the meeting. All Partner and Task Force members and
other interested parties were invited to attend.  Forty CLI Partner and Task Force members were
in attendance. (For a list of meeting participants, please refer to Appendix 7-1.) The meeting
served as a forum for subgroups to update Partner and Task Force members on their activities.

On the first day of the meeting, members of the Quantitative Research subgroup updated meeting
attendees on the progress of the quantitative research and the subgroup's plans for implementing
the quantitative survey. The group affirmed that the survey would address the learning
objectives defined hi Phase I, and outlined a schedule for completing the research.

The concept of standardizing environmental information on product labels was introduced and an
outline for discussion was proposed.  To engage Stakeholders in framing the debate, Andrew
Stoeckle of Abt Associates presented a paper written with Julie Winters of the EPA, that
explored issues relating'to standardizing environmental information on product labels. Julie
Spagnoli of Bayer Corporation also did a presentation on the topic. A core subgroup of CLI
members was identified to work on the issue.

Members from the subgroups on Ingredient Identification and First Aid gave presentations on the
status of their work. In addition, sessions were held to discuss other issues not covered by a
specific sub-group. These issues included multi-lingual consumers and literacy level of
consumers, the use of icons or signal  words on product labels, label format, and environmental
claims of a product.

On the second day of the meeting, Susan Wayland, Deputy Assistant Administrator for the
Office of Prevention, Pesticides and Toxic Substances, spoke to CLI Partner and Task Force
members. She encouraged the group to find out what environmental information consumers
wanted to know, and how they wanted that information presented.

The subgroups on Consumer Education, and Storage and Disposal, presented updates of their
activities to meeting attendees. A session was also held to update Partner  and Task Force
members and CLI Stakeholders on EPA efforts to involve Stakeholders in the CLI.

At the end of the meeting, items for future action were compiled from the  two days of
presentations and discussion. CLI project management and time lines were also discussed. For
more detailed information on the discussion that took place during this meeting, refer to
Appendix 7-2.
                        Chapter 7: Partner and Task Force Meetings
157

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          September 1998 Partner and Task Force Meeting

 CLI Partner and Task Force members met again on September 23 and 24 in Alexandria, VA.
 Efforts were made beforehand to encourage the involvement of as many participants as possible.
 A CLI Update, published in August 1998, invited interested parties to attend the meeting.  The
 update was sent to all Partner and Task Force members and CLI Stakeholders, and was posted on
 the World Wide Web.  Some project Stakeholders, such as environmental organizations, were
 telephoned and personally invited to the meeting by EPA staff members.  Forty-seven people
 were in attendance. Julie Winters of the U.S. EPA's OPPTS served as the moderator. (For a
 complete list of attendees, refer to Appendix 7-2.)

 The goals of the meeting were:

       •     to present the data and the findings of Phase II quantitative and qualitative
              research, in order to ensure the understanding of participants;

       •     to develop possible recommendations and action steps arising out of Phase II
              work;

       •     to make policy recommendations when possible and appropriate;

       •     to recommend label changes and identify tradeoffs in going forward; and

       •     to recommend further research where necessary.

 During the first day, findings, implications and conclusions from both the  quantitative and
 qualitative Phase II CLI research were presented. Members of the subgroups on Storage and
 Disposal and Consumer Education also gave reports on their activities.

 On the second day of the meeting, participants were asked to make recommendations to the EPA
 on policy changes, immediate label changes, and areas for further research, based on the
 information presented the day before. For a full list of the recommendations, please refer to
 Chapter 9. Discussion included topics addressed on the first day, as well as ingredient
 information, signal words, hazard hierarchy, and label format/language.  CLI recommendations
 on which participants could agree were adopted to be presented to the EPA, for consideration by
 the Agency for possible adoption. For details on the discussion that took place during this
 meeting, refer to Appendix 7-3.
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             April 1999 Partner and Task Force Meeting

The fourth CLI Partner and Task Force Meeting was held on April 7 and 8, 1999, in Alexandria,
VA, to update Stakeholders on CLI events that had happened since the September 1998 meeting.
Thirty Partner and Task Force members attended the meeting. Topics of discussion included
plans for an upcoming media event, implementation of CLI proposed label changes by the Office
of Pesticide Programs (OPP), issues related to storage and disposal,  and the consumer education
campaign. (To view the meeting summary and notes, refer to Appendix 7-4.)

The EPA informed CLI Stakeholders about plans for an upcoming media event, to be held in
Spring 2000, to announce some of the labeling recommendations that EPA will be making as a
result of the CLI. The Partners and Task Force discussed potential messages, goals, and details
of the event.

Jean Frane from the OPP informed project Stakeholders how the CLI recommendations made in
September 1998 were being implemented. The OPP revised the First Aid Statements, using CLI
recommendations, and expects to release a Pesticide Registration  (PR) notice citing these new
recommendations in Fall/Winter 1999. Certain label changes, recommended at the September
Partner and Task Force meeting, were adopted by the EPA as changes that can be currently
submitted to the OPP.  These label changes, changes that will be considered on a case-by-case
basis, and changes that will not be considered at present until formal implementing documents
are published, were presented to CLI Stakeholders and are listed at the end of Chapter 9.

Storage and disposal issues were also discussed by Jean Frane of the OPP. At the meeting, it
was pointed out that some states are reluctant to take part the "Read  the Label FIRST!" campaign
while there are still unresolved issues concerning the storage and disposal section of the label.

The Consumer Education sub-group updated Stakeholders on events pertaining to Consumer
Education.  The Subgroup presented drafted text for outreach brochures targeting gardeners,
children's health, pet protection, and household products.  Message placement plans and the
process of designing a consumer education campaign logo were also discussed.
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                                 CHAPTER 8:
 STAKEHOLDER INTERACTIONS AND COMMENTS
This section summarizes interactions with and comments made by CLI Stakeholders during
Phase II. (To view actual Stakeholder comments, refer to EPA Public Docket, Administrative
Record, AR-139.) CLI Stakeholders included consumer advocacy groups, environmental groups,
consumers, health and safety professionals and organizations, international groups, government
agencies, manufacturers of consumer household products, and retailers. Specific interactions
with and comments made by Stakeholders who were part of CLI Phase II subgroups are not
presented here, since they are addressed in other sections of this report. Interactions with
Stakeholders during Phase I of the CLI were summarized in the CLI Phase I Report. (A
complete list of CLI Stakeholders is provided in Appendix  1-4.)

                          Stakeholder Outreach

Throughout the CLI, the EPA actively encouraged the participation of Stakeholders through a
variety of methods. The Agency attempted to identify the most effective ways to communicate
with and learn from project participants, as well as to identify their particular interests. The
many methods utilized to communicate with Stakeholders are detailed below.

Media Conferences and Public Announceiments

Media conferences and public announcements were issued for all important milestones in the
CLI. The initiation of Phase II was formally announced by Lynn Goldman, the Assistant
Administrator for Office of Prevention, Pesticides, and Toxic Substances, and six of the CLI
Partners, at a press conference in September 1997. Details  of this media event can be found in
Chapter 1 of this report (Overview of the Phase II Process), under  the section entitled "The
History of Phase II."  Similar to what happened for Phase I recommendations, an EPA media
event will be held for Phase II recommendations in Spring 2000. First Aid label changes will be
announced by a Pesticide Registration (PR) notice released in Fall/Winter 1999.

Publications/Memos and Correspondence*

The EPA strove to make information about the CLI accessible to all interested parties. To
introduce people to the concepts of the CLI, the EPA published a fact sheet on the initiative in
September  1997.  This informational handout detailed the background, research process, and
Phase I research findings of the CLI, and listed contact information. It was sent to over 1,000
people interested in CLI and was posted on the CLI website,
http://www. epa. gov/opptintr/labeling

 Four consumer-oriented CLI "Updates" were produced and disseminated to all parties that
 expressed interest in the CLI. The first update was written during Phase I. During Phase II, two
 updates were produced, both containing information on the status  of the CLI and contact
 information for interested parties. They were sent to about 1,000 people (this list included
                    Chapter 8: Stakeholder Interactions and Comments
161

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 people who had indicated interest in the CLI, as well as organizations arid press contacts
 identified by the EPA) and were posted on the CLI website.

 An attempt was made to keep active CLI participants informed and involved in the progress of
 the CLI.  Informational CLI memos were produced and disseminated to all CLI staffers and
 Stakeholders. For example, at the onset of the quantitative and qualitative research, the EPA sent
 out information about the research to CLI Partner and Task Force members and solicited
 comments from them.  Information about these research efforts was also sent to other interested
 CLI Stakeholders through memos.  A Federal Register (FR) notice was published on Tuesday
 October 27,1998 (63 FR 57298) announcing the availability of the raw data from the
 quantitative research.

 The EPA actively solicited the opinion of environmental and consumer advocacy groups.  Before
 the start of the Phase II quantitative research, the EPA sent a letter to environmental and
 consumer advocacy groups, updating them on the progress of the CLI and inviting comments and
 questions regarding the quantitative study. (For a copy of the letter, refer to EPA Public Docket
 AR #139.) See below for a summary of Stakeholder comments.

 CLI Website

 A web page was created for the CLI on the EPA website. Here, anyone with Internet access can
 read about the initiative, E-mail comments on the CLI to the EPA, or download documents. All
 materials published by the CLI have been posted on the website, in a form that can be
 downloaded or printed online.  The website address is http://www.epa.gov/opptintr/labeling/

 Stakeholder Meetings

 Aside from the four Partner and Task Force meetings, several other meetings were held between
 the EPA and/or the EPA and CLI Partner and Task Force members and other interested
 Stakeholders.  (For information on the four Partner and Task Force meetings please refer to
 Chapter 7 hi this report.)

 In April 1997 the EPA and several CLI Partner and Task Force members held a meeting in
 Crystal City, VA, with environmental and public interest groups and other interested parties.
 The purpose of the meeting was to provide these groups with an update of the CLI activities up
 to that point, in particular to announce the quantitative research plan. Topics discussed included
 an overview of Phases I and II of the project;  the legal and financial issues relating to the finding
 of the quantitative research; the quantitative research design, funding, and methodology; storage
 and disposal issues; ingredients issues; interim label improvements; consumer education; and the
 role that non-governmental organizations can play in CLI. Participants thanked EPA for inviting
 them to be a part of CLI and encouraged the EPA to keep the lines of communication open.
 They felt that doing so would encourage more NGOs to participate in CLI, as well as help
 identify why more of these organizations are not participating in the Initiative.
                                                        i                               i
 In June 1997 another meeting was held with key environmental and public interest groups.  The
 meeting was between EPA Task Force members, Susan Wayland (Deputy Administrator of
 OPPTS), David Roe of the Environmental Defense Fund (EOF), Carolyn Hartman of the U.S.
162
Chapter 8: Stakeholder Interactions and Comments

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Public Interest Group (U.S. PIRG) and Jeff Wise of the National Environmental Trust (NET).
The purpose of the meeting was to better understand the environmental and public interest
groups' agenda on labeling issues, and to determine if CLI could fit into their agenda.
                     Chapter 8: Stakeholder Interactions and Comments
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                            Stakeholder Comments

 Throughout the CLI, Stakeholders were encouraged to provide their comments on the initiative
 by E-mailing them to the website, responding to the PR notice and EPA publications/memos, and
 by contacting EPA staff directly. These comments  are presented below. Comments from
 Stakeholders who participated in CLI Phase II subgroups are not presented here, since they are
 addressed in other sections of this report. For a list  of all contributing Stakeholders who
 commented during Phase II, please refer to Appendix 8-1.

 Comments on the CLI

 Some of the Stakeholder comments addressed the focus of the CLI.  One Stakeholder
 recommended that the EPA issue a clear statement specifying the reason behind its involvement
 in the CLI.

 A few comments addressed the inclusion of certain groups of people into the planning group of
 the CLI. For example, one Stakeholder commented that the CLI planning and steering group
 should include consumers. Another person thought  that public interest groups should be
 included in the list of Partners (the Stakeholder provided a list of examples of groups that could
 be included).

 One commenter suggested expanding the range of products that are covered by the CLI to
 include scented candles.  They cited a report that scented candles may be harmful to pregnant
 women and young children because some of these candles, according to the report, may emit
 volatile organic compounds (VOCs), reproductive toxins, neuro-toxins, and/or carcinogens. The
 commenter requested that candles intended to be burned in the home list all ingredients and that
 their labels give warning regarding inhalation of emissions from these candles.

 Comments on EPA  Policy

 One Stakeholder commented that to address the root of the labeling issue, EPA would have to
 make a policy decision. He/she wrote that "to improve public health, and curtail environmental
 degradation from inappropriate disposal of hazardous pesticides and cleaners, it will be necessary
 to take a proactive stand," and suggested that the EPA "mandate, legislate, and eliminate the
 casual and unnecessary use" of hazardous pesticides and cleaners. Using pesticides as an
 example, the Stakeholder reasoned that "if pesticides are bad or questionable, if the chemicals
 can, or may initiate cancer in children, or manifest disease years after exposure, if they are
 polluting our water, poisoning our fish, contaminating our soil, and degrading our air, we must
 ask ourselves,'Do we want them to be so easily available, with a bunch of small print caveats
 that no one is going to bother reading anyway?'"

 Comments on Quantitative Research

 Regarding the quantitative study, some Stakeholders  were interested in ensuring that the survey
 adequately represented minority, low-income, and  low-education consumers.  One Stakeholder
suggested broadening the study to include respondents with different cultural backgrounds and
who speak languages other than English. Another  wanted to know if the survey would target
164
Chapter 8: Stakeholder Interactions and Comments

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product users involved in janitorial, gardening and cleaning businesses and was glad to find out
that the quantitative survey planned to address non-users of products as well as users. (Non-
product users were not tested but were screened.)

One Stakeholder recommended that the study test a variety of alternative labels, both current
labels and prototypes.  This person also wanted the study to explore the possibility of listing
factors that are unknown about a product, such as whether a specific ingredient has been tested
for possible adverse health effects, writing: "Current label information does not indicate the
extent to which ingredients are tested and which ingredients the health precautions apply to.
Without either explanation or a mock label that somehow indicates that this information is
missing, respondents are not likely to raise this as an issue. The study leaves in place the 'what
you don't know can't hurt you' aspect of current labeling."

Another Stakeholder requested that the quantitative study include a clear statement of purpose, in
order to focus participants on environmental and health information.

Comments on Labeling

Stakeholders made suggestions about information to include on product labels. One person, who
suffers from a medical reaction to formaldehyde, requested that formaldehyde be listed on all
products, even when it is not an active ingredient.  Another citizen commented that product
labels ought to include the instruction, "do not flush down toilet."

One Stakeholder suggested the use of icons or graphics for products containing chemicals that
are potentially harmful to children and pets. This person recommended that these products
prominently feature an "obvious, easily understood WARNING with a picture of a small child,
and a pet on the front label to immediately put people on notice without reading any further, or
for those lacking full command of the language."

Another Stakeholder pointed out that the EPA should not overlook the importance and value of
labeling requirements, which may not have immediate use for the consumer, but which may
force a manufacturer to reformulate a product to reduce a health risk.  This person urged the EPA
to look at the experience of California, a state with its own specific labeling criteria, as an
example for potential label reform. The commenter had contributed during Phase I and felt that
his/her organization's earlier comments had been "completely ignored."

A person who submitted comments stressed the importance of making label language very
simple, pointing out that young adults often may not comprehend the language on product labels
and may sometimes use these products.  The citizen also pointed out that simpler language  is
essential for product users who might have limited English reading skills.

Comments on Consumer Education

Opinions on the proposed consumer education campaign varied. One Stakeholder thought that
the "Read the Label FIRSTl" campaign was an important component of the CLI.  Another person
felt that the education campaign was doomed to failure, reasoning that the CLI effort would not
be able to compete with the persuasive advertising campaigns of companies.
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 Representatives from the Working Group on Community Right-to-Know, Consumers Union,
 Environmental Working Group, Farmworker Justice Fund, Friends of the Earth, National
 Coalition Against the Misuse of Pesticides, Natural Resources Defense Council, Northwest
 Coalition for Alternatives to Pesticides, U.S. Public Interest Research Group, and World Wildlife
 Fund submitted a joint letter to the CLI.  These groups expressed concern about the timing of the
 consumer education project. Their letter urged the EPA to address the following questions
 before proceeding with the consumer education project:

        •  How will the project educate the public about the presence and potential hazards of
           most toxic ingredients, which are not disclosed on pesticide product labels?

        •  How will the project change the behavior of manufacturers (as opposed to the
           behavior of consumers)?

        •  What CLI milestones has EPA established for requiring full disclosure on pesticide
           product labels and for resolving alleged confidential busines:; information issues?

        •  How will the project communicate that certain information on health and
           environmental hazards is not available, i.e., for inert ingredients, contaminants, and
           toxic metabolites, and that EPA relies on industry self-certification for information?

 Comments on  the Flammability  of Products
                                                                                      I
                                                       !                               I
 A Stakeholder, whose business was destroyed in a fire caused by an aerosol pesticide product,
 expressed concern with the flammability of products. This person wrote, "I have interviewed fire
 protection officials all over this country, and these products have been causing thousands of fires
 and killing people for many years." The citizen  was also upset that the CLI had not been initiated
 earlier.

 Comments on  Disclosure

 Representatives from the Working  Group on Community Right-to-Know, Consumers Union,
 Environmental Working Group, Farmworker Justice Fund, Friends of the Earth, National
 Coalition Against the Misuse of Pesticides, Natural Resources Defense Council, Northwest
 Coalition for Alternatives to Pesticides, U.S. Public Interest Research Group, and World Wildlife
 Fund also commented on disclosure of ingredient information on product labels. They expressed
 concern about what they saw as, "the agency's lack of progress on requiring manufacturers to
 fully disclose toxic ingredients and health hazards on labels." Their letter followed up on a letter
 that they and 60 other environmental, consumer and public health organizations had sent during
 Phase I.
                                                       I                               I

 Comments Relating to Storage and Disposal Issues

 Respondents to the information request  sent to the North American Hazardous Materials
 Management Association (NAHMMA)  shared additional comments and opinions on storage and
 disposal of product containers. The Sonoma County Waste Management Agency stated that
incorrect label instructions, such as, "wrap in newspaper and throw in trash," have led to illegal
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Chapter 8: Stakeholder Interactions and Comment:;

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and harmful disposal of household hazardous wastes (HHW). As a result of illegal and/or
harmful disposal of these wastes, Sonoma County has had to spend millions of dollars to divert
these wastes from their local landfill (HHWs are not accepted in Sonoma County's landfill).
Additionally, the County attributes incorrect labeling instructions to the fact that in 1996, while
70% of their local population were aware of their local HHW program, the same percentage did
not know they possessed HHWs.

The Sonoma County representative suggested that the EPA require product labels to indicate
whether the product is hazardous and suggested adding to the label a toll-free number providing
local or state disposal information. The County feels that this is a better option than the current
language of, "contact your local waste management department." Finally, the Sonoma County
Waste Management Agency would like the EPA to require fall disclosure of product contents on
labels. The County feels that this will be more effective than warning labels, in providing
consumers with an indication of the potential hazard of the product.

Comments were also provided by the State of Wisconsin's Department of Agriculture, Trade and
Commerce Protection.  The Department stated that labels are already too cluttered with
information, and that adding more information to labels will not be beneficial for consumers.
The Department pointed out that consumers are able to cope with only "so much information"
and the EPA should not present more than basic storage and disposal information on labels.
Finally, the Department suggested that the EPA work with industry representatives when
developing labeling language.

In September 1998, CSMA and HIPIC sent a letter to Deputy Assistant Administrator of the
EPA's Office of Prevention, Pesticides and Toxic Substances (OPPTS), Susan Way land, stating
their position that they do not support the recommended label language advocated by EPA staff
and some of the other Storage and Disposal Work Group members. They believe the claim that
there is sufficient need or justification to warrant inclusion of a statement on product labels
directing consumers to contact their local authorities for disposal information, when disposing of
partially full containers is not supported by  any compelling evidence. CSMA and HIPIC believe
there is a substantial body of scientific support for making the recommendation to dispose of
these products through the normal waste systems, either in the trash or down the drain, depending
on product type. They stated that no such scientific support for directing consumers to call their
local authorities has been presented to the Work Group. The letter also offers comments about
some of the work presented to the Work Group, and includes comments regarding the quality of
information disseminated by local authorities.

In January 1999, the North American Hazardous Materials Management Association
(NAHMMA), sent a letter to Mr. Stephen Johnson, Acting Deputy Assistant Administrator,
OPPTS, thanking him for meeting with them in late December on the Consumer Labeling
Initiative (CLI). The letter outlined NAHMMA's position on several of the issues that arose in
the meeting. NAHMMA reiterated the State and Local Agency position that pesticide product
labels should refer product users to an appropriate local agency  for disposal instructions and, if
necessary, to the state waste management agency. Some of the  major issues discussed were: 1)
language could be added to the above disposal instruction referring callers to a toll-free hotline if
the caller can't reach a local contact; NAHMMA suggests either EPA's RCRA/Superfund or
NPTN hotline could be that number; 2) state and local  officials  should make the decisions on
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 how to manage pesticide wastes from households and small businesses, but current pesticide
 product labels thwart those efforts by informing people to dispose of pesticides in the garbage.
 NAHMMA mentions that there is local liability to pay for contaminated solid waste landfills and
 local water supplies; 3) while NAHMMA agrees that further in-depth scientific analysis of
 potential impacts of various categories of pesticides is warranted, no line can be drawn among
 pesticides to determine which should be collected and which should be disposed of that all
 municipalities will agree to; 4) the EPA is asked to provide nominal funding to update and
 maintain the state contact list; 5) NAHMMA suggests that a PR Notice be issued with the
 recommended changes, and requests that the solution to the storage and disposal issue be
 included as part of the CLI.
                                                         j
 At the same time, CSMA and HIPIC sent a letter of thanks to Mr. Stephen Johnson and Ms.
 Marcia Mulkey for meeting with CSMA and HIPIC and their member companies on January 6,
 1999, to discuss issues surrounding the efforts to develop disposal instructions for partially-filled
 containers. The letter states that the group did reach consensus on disposal instructions for
 empty containers, and that over 90% of containers are empty when discarded. CSMA and HIPIC
 reiterated their positions that there is significant scientific data to justify disposing of partially-
 filled containers in the trash, and there is no understanding of how widespread the state/local
 laws are that prohibit this practice.  The letter continues by encouraging resolution of this issue,
 and reiterates the organization's earlier suggestion that a committee be formed to develop risk-
 based criteria for directing particular consumer pesticides that may warrant special handling to
 waste collection programs designed to accommodate this level of management.  The letter
 concludes by urging that any new statements be issued in  a Rule as outlined by the
 Administrative Procedures Act.

 In addition, when the effort to revise the disposal instructions on pesticide and hard surface
 cleaner labels by the Storage and Disposal Subgroup ended in a stalemate, the Office of
 Prevention, Pesticides, and Toxic Substances (OPPTS) received approximately 55 letters from
 organizations around the country involved with, or interested in, the subject of household
 hazardous waste.  These letters have been included in the CLI's Administrative Record (AR-
 139). Generally, all of the letters reflected the following sentiments: EPA's disposal instructions
 should not contribute to a locality's CERCLA liability; EPA shouldn't undermine state/local
 authority to manage these wastes; EPA shouldn't undermine local educational efforts related to
 these products; in 1981 there weren't many local programs for collecting/managing these wastes
 but now there are; and EPA's disposal instructions shouldn't contribute to sanitation worker
 exposures to these products, or spills of these products into the environment.

 EPA Response to Stakeholder Comments

The EPA responded by mail or e-mail to all Stakeholders who contributed substantive comments
or raised specific questions during Phase II. These responses are available through the EPA's
Public Docket, Administrative Record, AR-139.
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Chapter 8: Stakeholder Interactions and Comments

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                                   CHAPTER 9
            CLI PHASE II RECOMMENDATIONS
The recommendations presented below were suggested by CLI Stakeholders present on the
second day of the CLI Partner Task Force Meeting (September 24, 1998). These are the
recommendations that the CLI (as represented by the Partner and Task Force members present at
the meeting) made to the EPA. The EPA responded to the recommendations regarding which
label changes can currently (i.e., at the time this report was written) be made at the April 1999
Partner and Task Force meeting.  In addition, plans for a CLI media event to take place in Spring
2000, plans of completion of the Phase II Report, and plans for the Consumer Education
Campaign were also announced at the April meeting. A section describing the label changes and
the new developments for CLI follows the CLI recommendations.

Prior to the Partner and Task Force meeting, Susan Wayland, Deputy Assistant Administrator for
the EPA's Office of Prevention, Pesticides, and Toxic Substances, had asked Stakeholders to
consider the following items when making recommendations:

      •    identify what product label changes can be implemented immediately, and the
            options and associated tradeoffs;

      •    identify any needs for further research, the options and associated tradeoffs, and
            anticipated end points for making label changes; and

      •    identify any needed policy choices, and the possible options and associated
            tradeoffs for each choice.

Topics for discussion during the meeting included the following:

      •    signal words, and hazard hierarchy,

      •    ingredients,

      •    label format,

      •    consumer  education, and

      •    storage and disposal.

For each of these discussion topics, the Partner and Task Force members attempted to address
each of the items identified above. In many cases, the issue of Consumer Education overlapped
with the discussion topics, and was considered as a stand alone topic in others.  Information or
recommendations regarding consumer education are therefore captured both by discussion topic
and under the Consumer Education topic area.
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 Signal Words and Hazard Hierarchy Recommendations
 Product Label Changes
 1.
       For products that fall into toxicity categories 1, 2, or 3, recommend that manufacturers be
       encouraged to voluntarily put one or more bullet points underneath the signal word on the
       front label, explaining the precautions associated with the product. The statement which
       currently refers people to turn to the back of the package for more explanation of the
       precautions should remain on the front of the label.

Further Research
                                                      \                               i
1.     Recommend that additional research be conducted on the effects of "highlighting" and
       graphical depictions of the signal words on the front of the label before any such changes
       are implemented. ("Highlighting" means things such as holding the word, boxing  the
       word, using colors to make the word stand out, making the word bigger, etc.; graphical
       depictions could include bar graphs, thermometers, "laugh meters," or similar designs
       incorporating all three words into a hierarchical visual format.) Also explore as a part of
       this research "information fragmentation" (i.e., placing precautionary-related information
       on both the front and back label panels) issues. Note on intent: 1he need for this research
       is not intended to preclude the change recommended pertaining to placing the precaution
       bullet on the front panel with the signal word.

Policy Choices

1.      For toxicity category 4 products only, the EPA should consider not having a signal word.
       (Currently, both category 3 and category 4 products can have the signal word "Caution"
       associated with them.)

2.      The EPA should determine what the consumer should understand about signal words and
       the hazard hierarchy. If the intent is for the signal words to flag for the consumer that
       care should be taken, then the recommendations here are enough along with appropriate
       educational efforts (see education recommendations).  If the intent is for the hazard
       hierarchy to be understood, then additional research and education are necessary.

Consumer Education

1.      Recommend that an effort be made to educate consumers about the meaning of the  signal
       words, and how they are defined and used on labels. This should be done in a factual
       context, and without judgement calls which conclude the meaning for the consumer (i.e.,
       the Agency should not recommend that consumers always buy products marked
       CAUTION in preference to products marked DANGER).

Ingredients  Recommendations

Product Label Changes

I.      Recommend that the EPA not make any across-the-board label changes for ingredients at
       the present time.
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                        Chapter 9: CLI Phase II Recommendations

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2.
3.
Recommend that the EPA allow manufacturers the flexibility to voluntarily provide
"other ingredient" information on the label in a way that consumers in the study
expressed they wanted (i.e., listed by category, perhaps with some explanation of
purpose).

Recommend that the EPA allow manufacturers more flexibility in where they provide
ingredient information (e.g., back panel versus front panel).
Further Research

1.     Recommend that the EPA conduct further research to identify how to supply consumers'
       expressed need for medical information to people who want it. It was noted that
       information learned from the quantitative research of Phase II should be incorporated in
       any further research.

Policy Choices

1.     Recommend that the EPA further examine how to provide ingredient information on the
       label in the way consumers expressed they want it, as indicated by the research (i.e., give
       them categories of ingredients along with the purpose.) Also, refer to research
       recommendations in the format section.

Consumer Education

1.     Educate consumers about ingredient information on labels (i.e., why they appear on the
       label and the meaning of "active" and "other"), through the "Read the Label FIRST!"
       campaign. Additionally, it was suggested that the education campaign be utilized to
       inform the public about where to get health and safety information, e.g., for people prone
       to allergies, etc.

Label Format Recommendations

Product Label Changes

1.      Recommend that statements that were clearly preferred by consumers in the quantitative
       research be used, as appropriate, and that the EPA make program changes to allow this to
       happen to the extent possible.

Directions for Use

2.      Recommend that the EPA consider replacing the statement, "It is a violation of Federal
       law to use this product in a manner inconsistent with its labeling," with the simpler
       phrase tested on the quantitative survey — "Use only as directed on this label."

3.      Recommend that manufacturers  voluntarily put direction for use in bulleted form with no
       wrapping text (i.e., making sure that each new direction for use is set off on a separate
       line, and does not continue on the same line), using ordinal numbers if sequence is
       important.
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Precautionary Statements
4.     Recommend that manufacturers voluntarily put the principal health hazard information
       from the precautionary statements in bulleted form underneath signal words.

5.     Recommend that manufacturers and the EPA, where possible, use simple language,
       avoiding jargon; avoid wrapped text; keep sections together in same column; use more
       white space; and eliminate needless words.  This recommendation was particularly
       expressed with regard to precautionary statements.

6.     Recommend that the EPA remove language that is not appropriate to consumers from
       precautionary statements, e.g., language more appropriate for agricultural pesticides, etc.

Precautionary Statements — First Aid Specific

7.     Recommend that manufacturers voluntarily put First Aid information in a table format
       and within a box.

8.     Recommend that manufacturers who provide a toll-free number for emergencies
       voluntarily include that number beneath or within any table/box that includes First Aid
       information.

Further Research

1.     Recommend that further research be structured to investigate location and presentation of
       ingredient information (e.g., placing ingredient information on the front or back of the
       label, tabular formats, etc.), before any across-the-board changes are made to ingredients
       information. This recommendation addresses the variation in need which can arise
       between product categories,  e.g., indoor and outdoor versus cleaner product labels.
                                                        i
2.     Recommend that further research be conducted to investigate how the information
       hierarchy (i.e., information that consumers in the quantitative research said was most
       important to them) translates into the order in which information appears on labels.

Policy Choices

1.     Given the efforts in other non-CLI forums to standardize the use of icons, further work on
       this topic should not be pursued as a part of the CLI."
Consumer Education
1.      Recommend that the "Read the Label FIRST!" campaig
       acceptable for them to open and read label booklets (particularly
       products) in the store.
                               n educate consumers that it is
                                        for outdoor pesticide
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Chapter 9: CLI Phase II Recommendations

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 Consumer Education and "Read the Label FIRST!"
 Recommendations
It was noted that the Consumer Education Subgroup will address any recommendations from
other topic areas related to Consumer Education.

1.     Educate consumers on what specific parts of the label mean or are intended to
       communicate; specifically, signal words, active and other ingredients, storage and
       disposal, and precautionary statements including First Aid.

2.     As the CLI project continues, expand membership of the Consumer Education Subgroup
       to include brand managers, marketing staff, and label designers from within the Partner
       companies, particularly with respect to designing and assessing the impact of the logo for
       the "Read the Label FIRST!" campaign.

3.     Recommend that messages conveyed through the consumer education campaign be
       market-tested in appropriate ways before they are launched.

4.     Recommend that retailers be brought into the Consumer Education Subgroup, as they will
       be important for distributing the messages developed by the group.

Storage and Disposal Recommendations

Phase // Follow Up
1.
2.
3.
Recommend that the EPA send information from the quantitative study about recycling
symbols (those with chasing arrows) to relevant organizations.

Recommend the EPA gather any available information on risk assessments regarding
product disposal from states, manufacturers, and other appropriate organizations and
share this information with all applicable parties, in an effort to coordinate these types of
studies.

Recommend that the quantitative data on disposal practices be sent to the North
American Hazardous Materials Management Association (NAHMMA) and that
NAHMMA be encouraged to share this information with its members.
Product Label Changes
1.
2.
Recommend that for empty containers, the statement on product labels read, "Place in
trash. Recycle where available." The recycling statement would be optional for
manufacturers. Also optional, manufacturers may use the statement that reads: "Do not
re-use container."

Recommend that, given that there was no agreement on label statements for partially
filled containers, there be a delay in any Pesticide Registration (PR) notice regarding the
disposal statement on empty containers until the EPA makes a policy decision about how
to handle partially filled containers.
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3.     Recommend to keep the status quo for storage statements on product labels.
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                EPA Actions on CLI Recommendations

During the April 7-8, 1999, Partner and Task Force meeting, the EPA discussed how it intended
to address the recommendations made during the September 1998 Partner and Task Force
meeting. The EPA's Office of Pesticide Programs (OPP) is handling the recommendations for
label changes, and it presented a draft strategy for dealing with those recommendations at the
April 1999 meeting. Also at the meeting, planning was initiated for a CLI media event in Spring
2000, to announce the CLI recommendations; and updates on both the completion of the Phase II
Report and the Consumer Education Campaign activities were presented.

Draft OPP Strategy for Implementation of the Phase II Label Changes

OPP's draft strategy for implementing some of the CLI recommendations, presented in the April
1999 Partner and Task Force meeting, includes the following:

1.     OPP will circulate an internal guidance memorandum to forewarn EPA product managers
      about the type of paperwork to expect coming from companies making label changes
      recommended by the CLI. The memo would cover label changes that can be approved
      now, changes that would be considered on a case-by-case basis, and changes that would
      not be considered at present. These draft changes are listed below.

2.     Revised First Aid statements have been agreed upon and a draft Pesticide Registration
      (PR) notice announcing these new statements is currently being reviewed by EPA staff.
      The PR notice is expected to be issued in Fall/Winter 1999.

3.     PR notices for all recommendation topics will be issued after the guidance memo. Some
      PR notices may be issued as "final" notices without a time period allotted for public
      comment, while others will be issued "for comment."

4.     Label changes will apply to all FIFRA regulated pesticide products, not just consumer
      pesticides and household cleaners.

5.     Sometime in the future, the PR notices will be incorporated into EPA regulation, where
      necessary.

Label Changes That Can be  Submitted Now

While manufacturers must abide by current regulations, they can submit the following label
changes to the OPP (see Appendices 3-3 to 3-6 for examples of some of these label changes):

      •     adding hazard bullet points under signal words;

      •     removing inappropriate language on consumer labels;

      •     providing information on "other ingredients" In a variety of ways; and

      •     presenting first aid information in simplified formats, including a toll-free
             number, and using the new revised First Aid statements.
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Changes to the overall label format and presentation that can currently be made include:
                                                       !
       •     use of preferred statements;

       •     use of simpler language and less jargon;

       •     use of revised hazard and use statements;

       •     use of bullet formats;

       •     avoidance of narrative text formats (e.g., using bullets and headings);

       •     keeping sections together in the same column;

       *     using white space;

       •     eliminating needless words, while still abiding by current regulations;

       •     adding numbers for sequential actions;

       •     use of tables;

       •     adding sub-heading into the Directions for Use section; and

       •     rearranging precautionary statements to give prominence to those of greater
             interest.

Label Changes That Need to be Discussed with EPA Product Managers Before
Submitting

       •     changing the  location of the ingredients statement.

Label Changes That Cannot be Submitted at Present Time

       •     changing, combining, or deleting headings;

       •     locating storage and disposal instructions outside of the Directions for Use
             section;

       •     revising the Federal misuse statement; and

       •     leaving off the signal word for products in toxicity category 4.

CLI Media Event

During the April 1999 Partner and Task Force meeting, the EPA informed CLI Stakeholders
about plans for an upcoming media event, to announce some of the labeling recommendations
that EPA will be making as a result of the  CLI. Plans for the media event were postponed until
Spring 2000, however, to coincide with the 'kick-off of the CLI Consumer Education
Campaign; the media event will serve as the 'kick-off  event for the "Read the label FIRST!"
Campaign. This launch is timed to coincide the appearance of newly redesigned labels on store
176
Chapter 9: CLI Phase II Recommendations

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shelves with consumers' general interest in seasonal gardening and cleaning activities.
Eventually, the Consumer Education Subgroup intends to finalize and make available to the
public a variety of educational materials (e.g., brochures, pamphlets, etc.).

1.     The goals of the media event are to announce to the public CLFs accomplishments,
      inform the public that labels are changing to become simpler, promote the "Read the
      Label FIRST!" campaign, promote the CLI partnership between EPA and its
      Stakeholders, and increase consumer awareness in general regarding product labels.

2.     The media event is scheduled for Spring 2000. It was proposed at the April 1999 meeting
      that because the event serves as a way in which to reach the general public, a well-known
      public figure may be appropriate to convey the messages of the event, in addition to the
      EPA and CLI Partners.

3.     The target audience for the media event is the general public, the trade press, community
      newspapers, and lifestyle magazines.

4.     Messages for the event will be drafted by EPA and circulated to CLI Partners and other
      Stakeholders prior to the event.

Completion of the  Phase II Report

An update on the Phase II Report and details for its completion were presented to CLI Partner
and Task Force members during the April 1999 meeting. Partners and Task Force members were
informed that all of EPA's recommendations on label changes, as a result of CLI, will be
included in the Report. Partner and Task Force members agreed that displaying the Phase II
findings on the Internet before the completion of the Report would be counterproductive and,
therefore, resources should be spent on completion of the Report.

Consumer Education Campaign

An update of the activities since the September 1998 Partner and Task Force meeting regarding
the Consumer Education Campaign was presented during the April 1999 meeting.

1.     Upon recommendation from the September Partner and Task Force meeting, the
      Consumer Education Subgroup had been expanded to include marketing, brand, outreach,
      and public relations experts.

2.     A message development group was formed to develop the messages for the "Read the
      Label FIRST!" campaign, for use in both outreach fliers and/or brochures.

3.     A message placement group was also formed to identify and implement the most
      appropriate avenues for distributing the messages and products for the Consumer
      Education Campaign in order to promote the "Read the Label FIRST!" campaign.

4.     Ideas for generating a unique logo for the "Read the Label FIRST!" campaign were
      shared during the April 1999 Partner and Task Force meeting.  Logo design concepts
      included the idea of a design competition or contracting with a graphic designer to
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       produce the logo. The goal would be to have a logo in place that companies and other
       CLI participants could use on products, in advertising, and on education materials in time
       for the Spring 2000 promotion period.
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                                   CHAPTER 10
   PUBLIC REVIEW OF THE CLI PHASE II REPORT
                                    DRAFT
Before the CLI Phase II report was finalized, it was made available to project Stakeholders and
the public for comment. This chapter describes how comments were solicited and incorporated,
and presents an overview of the feedback received.

Project Stakeholders and the public were provided a one month period, from July 1 to July 29,
1999, to review and comment upon a draft of the CLI Phase II report.  In late June 1999, all
project Stakeholders in the CLI database, which includes over 700 people, were notified, by
facsimile, e-mail or letter, of the opportunity to review the draft. This notification included
instructions on obtaining a copy of the draft and issuing comments.  A Federal Register (FR)
notice (64 FR 38422) indicating the availability of the draft report, requesting comments, and
describing the comment process, was also published on July 16, 1999. On July  1, 1999, the draft
report was posted in a downloadable format on a temporary web site established for the purpose.
Paper copies of the draft were sent out upon request. The draft was also made available via the
Administrative Record  (AR-139). Two conference calls, publicized in the initial notice and on
the web site, and open to anyone, were held during the month of July to discuss  substantial
comments and issues.

Three commenters requested an extension of time to comment on the draft report, noting that the
date of publication of the Federal Register notice had not provided a full thirty-day comment
period. EPA denied these requests, noting that the fiscal schedule for publishing the report
would not accommodate an extension; that the draft report itself, being technical in nature and
lacking regulatory effect, would not generally be subject to public comment at all prior to
publication; that large sections of the draft report had been prepared  in an open, joint stakeholder
meeting process and had gone through prior comment iterations; and that special and extensive
30-day notice had been provided to all groups who had ever expressed any interest in the project
by commenting at earlier stages.

Comments were issued by EPA staff, industry, trade and environmental organizations, and the
public. All of the comments were reviewed carefully. Editorial comments that clarified or did
not alter the meaning of the text were incorporated. Comments on the report's recommendations,
findings, implications, and conclusions were noted but not incorporated, because these sections
were developed through a joint Stakeholder process, which included review by project
Stakeholders. Comments that clarified people's own previous comments were accepted, whereas
comments that modified someone else's comments were not.  General comments on the research
and process of the CLI  and topics addressed in the report are summarized below. These
comments are divided up according to those that address the report and those that address
specific aspects of the CLI. All comments submitted on the CLI Phase II Draft Report can be
viewed in the Administrative Record (AR-139).
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              Comments on the CLI Phase II Report Draft

 Most Stakeholders who had been involved throughout Phase II agreed that the Phase II report
 reflects the CLI Phase II process accurately . Many comments on the CLI Phase II Report Draft
 were editorial or clarifying in nature. People and groups also commented upon whether or not
 they agreed with the report's findings and recommendations.  Some people also suggested
 additions to the report.

 Many comments were submitted on the Storage and Disposal chapter of the report. Industry
 representatives commented on the appropriateness of including certain sections in the Storage
 and Disposal chapter (Chapter 6), particularly in the chapter sub-section describing the Storage
 and Disposal Subgroup activities. They argued that certain topics should not be included in this
 section because they were not officially discussed within the Subgroup.  Commenters offered
 their opinions on whether or not they agreed with the proposed language, and offered arguments
 highlighting advantages and disadvantages for each proposed statement. Additionally, a few
 commenters pointed out potential problems with some of the proposed storage and disposal
 language (i.e., that they may violate certain regulations or policies). In addition to providing
 feedback on the proposed language suggested by the Storage and Disposal Subgroup, some
 commenters offered then: own suggestions for alternative statements.

 Comments were also issued about the label language tested in the quantitative and qualitative
 research. For example, language regarding the Federal Use statement was questioned (see
 discussion below).

 One commenter from the  EPA voiced many criticisms of the report. The commenter:

       •      felt that some of the CLI Phase II findings and conclusions were not supported by
              the data presented in the report;

       •      questioned how specific aspects of the label changes would be implemented (e.g.,
              use of "white space," elimination of needless words, specification of how long to
              wait before re-entering a treated area);

       •      disagreed with parts of the CLI Phase II process; and

       •      criticized aspects of the research design (e.g., poorly-designed mock labels,
              unclear and leading wording of some research questions).

NAHMMA expressed its frustration that EPA has failed to make a policy decision on pesticide
disposal to be included in this Phase II Report.  The absence of meaningful outcome on this area
of the project is very disconcerting to state and local governments.
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                            Comments on the CLI

The CLI yielded a range of comments. The initiative was praised by some for highlighting
problems with label language. Others thought the initiative should be expanded. Addressing the
roles of CLI participants, one commenter felt that these roles were weighted toward those with
stake in the pesticide market. Another felt that consumers and public interest groups should have
been included as CLI Partners.

Conflicting views were expressed regarding where on the label product ingredients should be
listed.  Reasons stated for keeping the ingredients statement on the front panel included:
1) respondents seemed satisfied with the current placement,, and 2) consumers and other
regulators might need to find the information in a hurry.  One reason stated in support of
allowing manufacturers to locate the ingredients statement on the back of the label was that
customers are accustomed to looking there, since many other consumer products list ingredients
on the back of the label. Comments on ingredients also addressed how and what type of
ingredient information should be presented.

The proposal to change the mandatory Federal use statement from, "It is a violation of Federal
law to use this product in a manner inconsistent with its labeling," to, "Use only as directed on
this label," elicited many comments. It was pointed out that the new proposed statement may not
convey the fact that failure to follow the label was against the law. Furthermore, it was
commented that this proposed change may make it illegal to use the product  in a way that the
label does not prescribe. Suggestions included keeping the current Federal use statement, or
proposing additional language for the EPA's consideration.

The majority of comments received about storage and disposal were  related to the lack of
resolution regarding disposal language for unused pesticides and household cleaner products.
Comments from state and local agencies reiterated their frustration that there had not been an
EPA policy decision to resolve this issue at the time the draft Phase II Report was available for
comment. Industry representatives and trade associations also reiterated their viewpoint that
language on product labels directing consumers to call a local authority for disposal instructions
was inappropriate.

Many people expressed support for the CLI consumer education campaign.  The "Read the Label
FIRSTl" slogan was applauded as being direct and concise. It was also suggested that the slogan
needs no logo. Some comments addressed what to include in the content of the consumer education
campaign.

Other comments addressed the label format, use of graphics,  and  First Aid and  precautionary
statements. More than one person commented on the difficulty of incorporating more blank space,
bullets, and unwrapped text on labels, due to the limited amount of space on labels. Comments were
issued both in support for and against the use of icons and graphics on product labels. Comments
in favor of and opposing the use of a visual format to display the signal word were also  provided.
It was suggested that if symbols and icons are used, they should be harmonized with those used in
the European Union and/or Canada. Comments were also meide on the specific wording of First Aid
statements.  It was also pointed out that the First Aid instruction to  induce vomiting may not be
appropriate for products with more than 10% petroleum distillate, due to the aspiration hazard.  In
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 addition, it was suggested that the order of precautionary statements should reflect the importance
 of the statements.
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                                 CHAPTER 11


     PEER REVIEW COMMENTS ON THE PHASE II

                           REPORT DRAFT


                                Background

The use of qualitative and quantitative research with a large number of consumers to determine
consumer behavior and opinion is a relatively new and unique approach for EPA. The Consumer
Labeling Initiative (CLI) had its Phase I Report peer reviewed in 1996 and found the reviewers'
comments to be quite informative and helpful. Given the potential magnitude and impact of the
recommendations deriving from the CLI's Phase II research, the EPA and CLI participants
wanted to determine whether we had gone about our research appropriately and whether
independent researchers believed the recommendations were supported by the research. With
those goals in mind, a peer review of the Phase II Draft Report was undertaken.

                           Document Reviewed

The document reviewed was the Consumer Labeling Initiative Phase II Report - Draft, July 1,
1999. The Report contained the following major sections:  1) Executive Summary; 2) Overview
of Phase II of the CLI; 3) Quantitative Research; 4) Qualitative Research; 5) Quantitative and
Qualitative Research Conclusions; 6) First Aid - Qualitative Research; 7) Phase II Sub-groups; 8)
Partner and Task Force Meetings; 9) Stakeholder Interactions  and Comments; 10) CLI Phase II
Recommendations; and finally many appendices supporting the research efforts. Appendices
included: 1) Lists of participants; 2) Quantitative, qualitative, and first aid research screening
documents, discussion guides, questionnaires, and mock labels; 3) notes of all major meetings;
and, 4) a list of stakeholders who had submitted comments. The stakeholder comments were not
included in the reviewed draft, and were included in the subsequent revision.

                              Peer Reviewers

The peer review was conducted by four independent reviewers not associated with either the
United States Environmental Protection Agency, or the Consumer Labeling Initiative project.
Reviewers were selected based on their expertise or experience in the fields of consumer
behavior, consumer opinion, risk and hazard communications, consumer research and testing,
and consumer education. Reviewers included: Dr. J. Stanley Black, Community Response
Analyst, Office of Community Relations, Illinois Environmental Protection Agency; Dr. Albert J.
Ignatowski, Principal, HazCom Consulting, and Senior Fellow, Wharton School, Risk
Management and Decision Processes Center, University of Pennsylvania; Dr.  Sidney I. Lirtzman,
Dean, Zicklin School of Business, and Emanuel Saxe Professor of Management, Baruch College,
 City University  of New York; and Beth Resnick, Associate Director, Division of Public Health
 Practice, National Association of City and County Health Officials.
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                              Charge to Reviewers

  Reviewers were asked to respond to 26 questions in five categories: Study Design; Study
  Implementation-quantitative, qualitative, and research groups; Study Results and'
  Recommendations; the Peer Review Process; and any other comments not falling into those
  categories. The questions, which are included later in this chapter, asked, for example about the
  appropriateness of the study methodologies and statistical methods chosen, the adequacy of the
  screening and survey instruments used, whether the key learning objectives were represented
  sufficiently in the research; whether the findings and recommendations were clearly supported bv
  the research, etc.                                                             v*       J

                    Summary of Reviewers' Comments

  Generally all of the reviewers' responses to the review questions were quite positive. However
  there were some specific criticisms which are mentioned below. The most negative comments '
 concerned the length and complexity of the written questionnaire.  Comments which were
 submitted concerning specifics in the report itself have been addressed in the final version and so
 are not addressed here.

 Study Design

 All of the reviewers agreed the methodologies used in the study were appropriate and addressed
 the key learning objectives. One reviewer suggested that presenting randomly selected
 householders with a set of varied label formats might have provided more realistic results than
 the mail or phone surveys, but he also said the cost and logistical complications of that approach
 might not have been warranted by the increased value of the information obtained. Another
 reviewer believed that more valid information with respect to comprehension would have been
 obtained using personal interviews. Another reviewer didn't think enough focus  was given to
 label alternatives for low-level readers and non-English speakers.

 Qualitative Study Implementation

 Screeners

 Generally the reviewers reported the recruitment procedures to be adequate. However, one
 reviewer stated it would have been better to focus on non-purchasers of products,  and use the
 purchasers as a control group.  Another reviewer said the selection criteria for the focus groups
 seemed quite inexact, but went on to say there were no claims that the groups were representative
 but only aimed for a reasonable variability.

 Discussion Guides and Learning Objectives

 All reviewers said the guides seemed sufficient and the objectives were represented. One
 reviewer suggested he would have asked participants for their preferences regarding label
 formats before showing any mock samples.

 Mock Label Adequacy
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All the reviewers agreed the labels were appropriate. One reviewer believed that there was too
much emphasis on designing labels that mimicked existing FIFRA label design requirements,
and then asking respondents if they liked them. The reviewer went on to say he would have
preferred even more emphasis been devoted to isolating some key features of label design and
presenting them in a manner to elicit respondent preferences.  Another was concerned there
appeared to have been too many labels.

Quantitative Study Implementation

Screeners and Discussion Guides

All reviewers generally agreed the recruitment screeners and discussion guides were appropriate
and adequate.

Written Questionnaire

All of the reviewers felt the written questionnaire was entirely too long. They had concerns
about its complexity, smallness of type, and dense format. They were concerned the length could
have lead to "question fatigue" and at least one reviewer expressed some concern about
projecting the results because of that fatigue. Another reviewer suggested it would have been
better if the items in the questionnaire were divided among subgroups of the study population,
with appropriate redundancy for checking constancy.

Statistical Methods

Generally the reviewers were satisfied, but one reviewer said the tables were primitive (only
percentages are reported) and he couldn't tell if tests of significance were performed routinely or
not. He went on to say the size of the quantitative sample is large enough that some of the results
have to be considered very important.

Learning Objectives

All agreed the learning objectives were adequately represented in the mail and phone
questionnaires.

One reviewer did not think it appropriate that industry funded the quantitative research.

Research Groups

When asked "did the work of the groups appear to reflect what was being learned in the
qualitative and quantitative research" all but one reviewer claimed they were unable to answer
the question because of its vagueness.  One reviewer did say the work of the groups was
consistent with the gist of the results from the quantitative research.

 Study Results and  Recommendations

 Findings Supported by Research

 All the reviewers agreed the findings were supported by the research. One said, however, there
 was no attempt to qualify  or moderate  the findings based on the quite divergent results of the
 subgroup of respondents, namely the less-well educated, lower-income, and minority
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 populations. Another reviewer expressed concern about whether we actually can determine
 consumers' current comprehension of the label language; although, he goes on to say "if one
 looks at the results of the preference data it is possible to draw the inference there is significant
 lack of comprehension of the standard label language because of preference for language which
 uses simpler words, phrases, and is active and directive toward specific goals." He later states it
 is only in the interviews on the first aid statements one is able to find reports of consumer
 confusion as to the meaning of words and phrases. This particular reviewer believed only
 personal interviews should be used to determine comprehension.

 Use of Quotes

 While the reviewers said the discussion and recommendations seemed relevant in relation to the
 quotes used, most said a wider sampling of quotes would have given them more confidence in
 the quotes selected.

 Enough Raw Data Presented

 All the reviewers agreed there was enough data presented. One reviewer said it should only be
 construed to represent consumer opinion and not actual behavior. He went on to say that while
 demographic information was obtained for all respondents, the tables are not broken down by
 these groups so the impact, if any, can be directly assessed.  Another reviewer said "it is a very
 rich resource for evaluating consumer responses in this area."

 All the reviewers agreed the conclusions and recommendations were supported by the findings
 and data.

 Other Comments

 Does the Report Adequately Explain the Project
                                                       !
 All said yes, although one did say it was repetitive.

 Are Stakeholder Concerns Adequately Represented/Addressed

 Some reviewers felt stakeholder concerns were adequately represented, while others expressed
 some confusion or dissatisfaction. Limited stakeholder comments appeared in the version which
 was given to the peer reviewers. Significant additional stakeholder comments were included in
 the final version.  One reviewer said more consumers and state and local agency representatives
 should have been included in the planning and steering groups and that increased retailer
 participation would have been helpful as well.

 Storage and Disposal

 One reviewer believed the extensive information on waste and container disposal was not well
 incorporated into consideration of the label design. Recommendations for including this
 information on labels seem "weak." The input for the various stakeholder groups was interesting
 but not directly germane to the study purpose.  Another reviewer said it would have been more
 objective if both industry and the state and local organizations had presented reports or papers,
rather than providing information differently.
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Consumer Education

One reviewer suggested the education campaign should include references to source reduction
and other alternative products and that retailers should be included since they will most likely
play a large part in this effort.

One reviewer commented the study could have been significantly strengthened if more of the
"interested parties" were professional hazard communicators.  The reviewer went on to say he
did not wish to dimmish the value and import of much of what was learned; he found many of
the conclusions immediately useful.

Peer Review Process

The reviewers all agreed this type of review should be done for similar efforts. One reviewer
wrote the review procedure was commendable and long overdue. All reviewers agreed allotting
more time to do the review would have been helpful. All agreed the materials provided to do the
review were sufficient, but could have been organized better to facilitate the review; for example,
the order of appendix materials, clearer labeling of appendix materials, references to the
appropriate sections included in the questions, etc. One reviewer said the materials were
unwieldy and offered several suggestions on how to improve the report.
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                     Questions to the Peer Reviewers

  Study Design

        1.      Were appropriate methodologies chosen to conduct the study?

        2.      Were appropriate methodologies chosen to address the key learning objectives?

 Study Implementation

 Qualitative:
        3.


        4.


        5.

        6.

 Quantitative:

        7.


        8.

        9.

        10.
 Were the recruitment screeners appropriate to acquire the: type of consumers
 needed to conduct this study?

 Were the questions asked in the discussion guides appropriate and/or sufficient to
 acquire the necessary consumer opinions about labels?

 Were the key learning objectives represented in the discussion guides?

 Did the mock labels/samples appear to be adequate for the participants?



 Were the recruitment screeners and practices appropriate to acquire the type and
 quantity of consumers needed to conduct the quantitative survey?

 Was the telephone interview outline adequate for its purpose?

 Was the length, structure and content of the written questionnaire appropriate?

 Were appropriate statistical methods and processes used to compile and evaluate
the data from the surveys?
       11.    Were the key learning objectives adequately represented by the questions on the
             mail and phone surveys?

Research Groups:

       12.    Did the work of the groups appear to reflect what was being learned in the
             qualitative and quantitative research?

Study Results and Recommendations

        13.   Are the findings supported by the research?

        14.   Are the implications reasonable, based on the findings?

        15.   Based on the quotes provided in the text from the focus groups, do the discussion
             and recommendations seem relevant?
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        16.   Is enough raw data presented to provide the reader with a clear picture of
             consumer behavior/opinions regarding labels?

        17.   Are the conclusions supported by the findings and data?

        18.   Do the recommendations appear supported by the research findings?

        19.   Do the report findings/recommendations concerning the consumer education
             campaign, storage and disposal, standardized information, etc. appear to be
             supported by the research?

Peer Review Process

      20.    Should the Agency consider this type of review for similar research efforts? If
             not, why not?

      21.    Were the materials sufficient for your review? If not, what additional materials
             would you like to have seen included in the package.

      22.    Was the time allotment adequate for review of the material and preparation of
             comments?  If not, how much time do you believe is reasonably required to
             perform this review?
       23.    What changes would you suggest to improve the process?
Other
       24.   Does the report adequately explain the goals, process, and accomplishments of the
             project?

       25.   Are stakeholder concerns adequately represented/addressed?

       26.   Are there any additional areas you would like to address or comments you would
             like to include?
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Consumer Labeling Initiative
      Phase II Report
      APPENDICES

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                              List of Appendices

The appendices numbering corresponds with the number of the chapter in which the appendix is
first mentioned. There are no appendices that correspond with chapters 4 or 9.

1-1: List of Products Included in the CLI 	195
1-2: List of CLI Task Force Members	199
1-3: List of CLI Partners 	203
1-4: List of CLI Stakeholders	207
1-5: Members of the CLI Quantitative Research Subgroup — Core Group	213
1-6: Members of Qualitative Subgroup	217
1-7: Members of Standardized Environmental Information Subgroup	 221
1-8: Members of Storage and Disposal Subgroup	225
1-9: Members of Consumer Education Subgroup	229

2-1: Quantitative Research Screening Questionnaire 	: .. . 235
2-2: Quantitative Research Telephone Questionnaires 	239
2-3: Quantitative Research Mock Labels	269
2-4: Quantitative Research Mail Questionnaires	277

3-1: Qualitative Research Telephone Recruitment Screening Questionnaires for Outdoor
Pesticides, Indoor Insecticides, and Household Cleaners 	301
3-2: Qualitative Research Discussion Guides for Outdoor Pesticides, Indoor Insecticides, and
Household Cleaners	319
3-3: Signal Meter Mock Label	337
3-4: Outdoor Pesticides Mock Label	341
3-5: Household Cleaners Mock Label	371
3-6: Indoor Insecticides Mock Label	401
3-7: Drafts of  "Read the Label FIRST!" Campaign Logo	441
3-8: Open-ended Questions on Consumer Label Preference	449

5-1: Pesticide Labeling Under the Federal Insecticide, Fungicide and Rodenticide Act	455
5-2: First Aid Qualitative Research Participant Screener for 1-on-l Interviews on Household
Cleaners, Indoor Insecticides, and Outdoor Pesticides 	467
5-3: First Aid Qualitative Research Discussion Guide, Consumer Comprehension of the
Proposed First Aid Statement Language	475

6-1: North American Hazardous Materials Management Association (NAHMMA) Storage and
Disposal Questionnaire for States 	479

7-1: CLI Kick-off Meeting Notes, Crystal City, VA, March 20, 1997	483
7-2: Summary of Partner and Task Force Meeting, February 17, 18, 1998  	489
7-3: Highlights from CLI Partners and Task Force Meeting, Ramada Old Town,
Alexandria, VA, September 23 and 24, 1998	 527
7-4: Summary of the Partners and Task Force Meeting, April 7-8, 1999,
Alexandria, VA  	539
                                                                                        193

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    8-1: List of Stakeholders Contributing Comments on CLI	551




    10-1: List of Commentors on the CLI Phase II Report Draft	555
194

-------
                   Appendix 1-1:
List of Products Included in the CLI
                              195

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                  Appendix 1-1:  List of Products Included in the CLI

Hard surface cleaners for consumer use:
               most are ready-to-use spray bottles, but not all of them (some are gels, powders)
               general all purpose cleaners, including bleach and ammonia - floor and sink cleaners
               tub and tile cleaners
               toilet bowl cleaners
               mildew and mold removers

Some of each in the above categories are EPA registered disinfectants and/or antimicrobials.

Strong sterilents, etc. used by hospitals or other institutions are not included unless they are generally
sold/available to consumers

CLI does not include laundry products, dishwashing products, drain cleaners/openers,  oven cleaners,
furniture polishes, metal cleaners, polishers, etc. Window cleaners would only be included if they were
general purpose cleaners.

Indoor insecticides for consumer use:
        •      insecticides for ants, roaches, mosquitoes and other flying insects
        •      insecticides in the form of sprays, baits, total release foggers (bug bombs), fumigators,
               powders, gels, or chalk
        •      flea treatments for carpets/furniture, NOT any products that go on the  pets themselves
 Outdoor pesticides sold, for consumer use:
        •      all herbicides for lawns and gardens and combination weed killer/fertilizers but not just
               fertilizers
        •      all insecticides for trees/shrubs — includes products that control fire ants but NOT
               pesticides used by professionals for termite control or other purposes
        •      all fungicides
        • "     slug, snail, grub, nematode, etc. killers - repellents

 These are covered by CLI if the products are in the in the form of granules, pellets, dusts, powders,
 ready-to-use sprays and foams, hose end sprays, concentrates.
                                                                                            197

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               Appendix 1-2:
List of CLI Task Force Members
                          199

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                       Appendix 1-2: CLI Task Force Members
                Name
Andrew Stoeckle
Srabani Roy
Susan Altman
Jennifer Andrews
Barry Cortez
Jacqueline Elder
Robert Ochsman
Carolyn Shanoff
Janice Podoll Frankle
Colleen Tressler
Mary Engle
Richard Williams Jr.
Alan Levy
Ken Falci
Annette Frahm
Lynn Halverson
Mary Ellen Setting
Sally Patrick
Jan Newman
Jean Frane
Julie Winters
Glenda Dugan
Bob Perlis
Pep Fuller
Amy Newman
Michael Firestone
Jim Downing
Amy Breed love
Elaine Francis
Linda Arrington
Cameo Smoot
Alison Kinn
John Alter
Nicole Christian
 Kathy Seikel
Annette Washington
 Candy Brassard
 Deborah Hartman
 Mary Dominiak
 Susan Wayland
 Dan Brown
 David Stangel
 Michael Gilkes
 Julie Fairfax
 John Miller
                    Organization
Abt Associates Inc. (contractor)
Abt Associates Inc. (contractor)
Abt Associates Inc. (contractor)
Abt Associates Inc. (contractor)
California DPR
Consumer Products Safety Commission
Consumer Product Safety Commission
Federal Trade Commission
Federal Trade Commission
Federal Trade Commission
Federal Trade Commission
Food and Drug Administration
Food and Drug Administration
Food and Drug Administration
King County Hazardous Waste Program
Macro International Inc. (contractor)
Maryland Department of Agriculture
Minnesota Pollution Control Agency
The Newman Group, Inc. (contractor)
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
Vermont Agency of Natural Resources
                                                                                      201

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    Appendix 1-3:
List of CLI Partners
              203

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                          Appendix 1-3: List of CLI Partners
               Name
Robert Hamilton
Julie Spagnoli
Mike Hilton
Louis Difo
Brigid Klein
Steve Kellner
David Wilcox
Al Campbell
George Meindl
Janet Kreizman
Joele Richardson
Warren Stickle
Holly Hody
Dennis Ward
Andrea Scheuerman
Michael Bender
Gary Schifilliti
John Shari
Mathew Grayer
Steve Rosenberg
Ellen Brown
Jan Wengler
Eileen Moyer
Allen James, CAE
Angela Bendorf
Elizabeth Lawder
Robert L. Rod
John Boomsma
Stuart McArthur
John Owens
Marilyn Blood
Alberta Helmke
Chip Brewer
Paula Bodey
Belinda Jones
Jim Larkin
Jeffrey Hoi lender
Dawn Walters
Jim Hasler
Therese Adkins
William McCormick
Terry Bedell
Pat Meehan
Karen Smith
Carol Berning
Maureen Howard
Kathie Tryson
                     Organization
Amway Corporation
Bayer Corporation
Bayer Corporation
Bioserv Inc.
Chemical Specialties Manufacturers Association
Chemical Specialties Manufacturers Association
Colgate-Palmolive Company
Dragon
FMC Corp.
Household and Institutional Products Information Council
International Poison Center
International Sanitary Supply Association
Monsanto Company
Monsanto Lawn and Garden
Monsanto Lawn and Garden
North American Hazardous Materials Management Association
Olin Corp.
Reckitt & Colman
Reckitt & Colman
Reckitt & Colman
Reckitt & Colman
Reckitt & Colman
Reckitt & Colman
RISE (Responsible Industry for a Sound Environment)
RISE (Responsible Industry for a Sound Environment)
RISE (Responsible Industry for a Sound Environment)
Rod Products Company Inc.
S.C. Johnson and Son, Inc.
S.C. Johnson and Son, Inc.
S.C. Johnson and Son, Inc.
S.C. Johnson and Son, Inc.
S.C. Johnson and Son, Inc.
S.C. Johnson and Son, Inc.
Scotts (acting on behalf of trade organization)
Scotts (acting on behalf of trade organization)
Scotts (acting on behalf of trade organization)
Seventh Generation, Inc
The Andersons
The Clorox Company
The Clorox Company
The Clorox Company
The Clorox Company
The Clorox Company
The Procter & Gamble Company
The Procter & Gamble Company
The Procter & Gamble Company
United  Industries
                                                                                    205

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I 1'

-------
         Appendix 1-4:
List of CLI Stakeholders
                 207

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                        Appendix 1-4: List of CLI Stakeholders
             Name
Mark Adams
DaleN. Long
Allen Spalt
Tim Fisher
Larry Culleen
Kerry Callahan
Bridget McNamer
Durwood Zaelke
Dan Fagan/Mary Lavelle"
Sandy Schubert
John Hausoul
Marilyn Goris
Susan Mudd
Liz Wessle
Joanna Hoelscher
Brian Johnson
Rod  Leonard
Deborah Siefert
Susan Boyd
Chad Dobson
Jean Halloran
Laurie-Ann Flanagan
Melody Reardon
Colonel Larry G. McCourry
Janice deGast
David Coffie
Nancy Royal-Jones
Ed Holt
Jennifer Bergman
David Roe
Richard Denison
Paul Locke
Suellen Reiner
Peter Monteque
Keit Davies
Michael Dershowitz
Kevin  Bank
James  Mills
Carl C. Smith
Glenn  Roberts
Debra  Yap
Charles Gallagher
Barbara Ellison
Arthur B. Weissman
Doug Evans
Mark Dorfman
Kathryn Gilje
Jim  Hanna
                      Organization
Agricultural Resource Center
American Society of Safety Engineers
Arnold & Porter
ASTSWMO
Business for Social Responsibility
Center for International Law
Center for Public Integrity
Children's Health Environment Coalition
Chlorine Chemistry Council
Citizens for a Better Environment
Citizens for a Better Environment
Citizens for a Better Environment
Citizens for a Better Environment
City of Santa Monica Environmental Programs
Community Nutrition Institute
Community Nutrition Institute
Concern, Inc.
Consumer's Choice Council
Consumers Union
D.C. Legislative & Regulatory Services
Defense Logistics Agency
Defense Logistics Agency
Defense Logistics Agency
Defense Logistics Agericy
Defense Logistics Agency
Ed Holt & Associates
Energetics
Environmental Defense Fund
Environmental Defense Fund
Environmental Law Institute
Environmental Law Institute
Environmental Research Foundation
Environmental Working Group
Federal Trade Commission
Federal Trade Commission
Federal Trade Commission
Foundation for Advancement of Science  and Education
Fragrance Mat'l Association of U.S.
General Services Administration
General Services Administration, FSS
General Services Administration, FSS
Green Seal
Howrey & Simons
Inform,  Inc.
Institute for Agriculture and Trade Policy
King County Department of Natural Resources
                                                                                     209

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   Jeff Harris
   Jerry McNeil
   Jay Feldman
   Kim Michalski
   Jeff Wise
   Gina Solomon
   Norma Grier
   Jim Moore
   Richard Belzer
   Jason Daien
   E. Donald Elliott
   Cindy Barnes
   Marion Moses
   Dr Thomas Dean
   Ruth Troeschler
   Robert K. Musil
   Lori Wallach
   Fred Withrow
   Diana Post
   Richard Donovan
   Beth Davis
   Harry Albert
   Elaine Weidman
   Linda Brown
   Elaine Auld
   Richard Opatick
   Bill Heenan
   Charles Griffith
   Kim Woodbury
   Rachel Donnette
   Mario Teisl
   Charles Williams
   Linda Singletary
   Sandra Ellixson
   John M. Damare
   Jessica Wasserman
   Skip Jones
   Krista Johnsen Leuteritz
   Katie Kroehle
   Joseph Galdo
   Jim Fremont
   Charles McClam
   Jennings Wong
   Kenneth Naser
   Alyce Boyd-Stewart
   Frazer Hilder
   Lawrence I.  Wagner
   Dana Arnold
   Sue Nogas
   Diane Beal
   Padmini Singh
 Lawrence Berkeley National Laboratory
 National Association of Counties
 National Coalition Against the Misuse of Pesticides
 National Consumers League
 National Environmental Trust
 Natural Resources Defense Council
 Northwest Coalition Against Pesticides
 NY Coalition for Alternatives to Pesticides
 Office of Management and Budget
 Partners for Environmental Protection
 Paul Hastings Law Offices
 Pest Management Regulatory Agency, Health Canada
 Pesticide Education Center
 Pesticide Information Office
 Pesticide Task Force
 Physicians for Social Responsibility
 Public Citizen
 Purdue
 Rachel Carson Council
 Rainforest Alliance
 Rhone-Poulenc Ag Company
 Rhone-Poulenc Ag Company
 Scientific Certification Systems
 Scientific Certification Systems
 Society for Public Health Education
 SOCMA
 Steel Recycling Institute
 The Ecology Center of Ann Arbor
 The Home Depot
 Thurston Co. Environmental Health
 University of Maine
 U.S. Department of Agriculture
 U.S. Department of Agriculture
 U.S. Department of Agriculture
 U.S. Department of Agriculture
 U.S. Department of Commerce
 U.S. Department of Commerce
 U.S. Department of Commerce
 U.S. Department of Energy
 U.S. Department of Energy
 U.S. Department of Energy
 U.S. Department of Justice
 U.S. Department of the Interior
 U.S. Department of the Interior
 U.S. Department of Transportation
 U.S. Department of Transportation
 U.S. Department of Transportation
 U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
210

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Steve Morrill
Lynn DeSautels
Sylvia Subt
Charles Vidich
Mike Fanning
Bernie  Denno
Roy Chaudet
Mike Barr
Carolyn Hartman
Daniel  Rosenberg
Peter DeFur
Bill Shapiro
Phillip  Dickey
Lynne Anderson
Terry Thiele
Myfanwy MacDonald
Frances Irwin
Sarah Lynch
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Government Printing Office
U.S. Postal Service
U.S. Postal Service
U.S. Postal Service
U.S. Postal Service
U.S. Postal Service
U.S. Public Interest Research Group
US Public Interest Research Group
Virginia Commonwealth Univ.
Volvo Cars of North America, Inc.
Washington Toxics Coalition
West Coast Working Group for ISO 14000
White Consolidated Industries
Women's Network on Health and the Environment
World Resources Institute
World Wildlife Fund
                                                                                      211

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                                 Appendix 1-5:
Members of the CLI Quantitative Research Subgroup
                                  — Core Group
                                          213

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      Appendix 1-5: Members of the CLI Quantitative Research Subgroup
                                     Core Group
                 Name
Andrew Stoeckle
Srabani Roy
Robert Hamilton
Mike Hilton
Julie Spagnoli
Alan Levy
Andrea Scheuerman
Dennis Ward
Larry  Jacobs
Ellen  Brown
Allen  James, CAE
John Boomsma
John Owens
Terry Bedell
Jim Hasler
Maureen Howard
Robert Ochsman
Jean Frane
Julie Winters
Deborah Hartman
Amy  Breedlove
Annette Washington
Nicole Christian
Mary Dominiak
                Organization
Abt Associates Inc. (contractor)
Abt Associates Inc.(contractor)
Amway Corporation
Bayer Corporation
Bayer Corporation
Food and Drug Administration
Monsanto Lawn and Garden
Monsanto Lawn and Garden
NFO Research, Inc. (contractor)
Reckitt & Colman
RISE (Responsible Industry for a Sound Environment)
S.C. Johnson and Son, Inc.
S.C. Johnson and Son, Inc.
The Clorox Company
The Clorox Company
The Procter & Gamble Company
U.S. Consumer Products Safety Commission
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
                                                                                   215

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                Appendix 1-6:
Members of Qualitative Subgroup
                         217

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              Appendix 1-6: Members of the CLI Qualitative Subgroup
                  Name
Andrew Stoeckle
Srabani Roy
Robert Hamilton
Julie Spagnoli
Mike Hilton
Alan Levy
Andrea Scheuerman
Larry Jacobs
Sally Patrick
Ellen Brown
Allen James, CAE
John Boomsma
John Owens
Terry Bedell
Jim Hasler
Jan Newman
Maureen Howard
Robert Ochsman
Jean Frane
Julie Winters
Amy Breedlove
Annette Washington
Nicole Christian
Mary Dominiak
                 Organization
Abt Associates Inc. (contractor)
Abt Associates Inc. (contractor)
Amway Corporation
Bayer Corporation
Bayer Corporation
Food and Drug Administration
Monsanto Lawn and Garden
NFO Research, Inc. (contractor)
Minnesota Pollution Control Agency
Reckitt & Colman
RISE (Responsible Industry for a Sound Environment)
S.C. Johnson and  Son, Inc.
S.C. Johnson and  Son, Inc.
The Clorox Company
The Clorox Company
The Newman Group, Inc. (contractor)
The Procter & Gamble Company
U.S. Consumer Products Safety Commission
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
                                                                                    219

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                                          Appendix 1-7:
Members of Standardized Environmental Information Subgroup
                                                   221

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   Appendix 1-7: Members of the CLI Standardized Environmental Information
                                     Subgroup
                 Name
Andrew Stoeckle
Julie Spagnoli
Mike Hilton
Allen James, CAE
John Owens
Jean Frane
Amy Breedlove
Mary Dominiak
                Organization
Abt Associates Inc. (contractor)
Bayer Corporation
Bayer Corporation
RISE (Responsible Industry for a Sound Environment)
S.C. Johnson and Son, Inc.
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
                                                                                223

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                         Appendix 1-8:
Members of Storage and Disposal Subgroup
                                   225

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        Appendix 1-8: Members of the CLI Storage and Disposal Subgroup
              Name
Srabani Roy
Ariu Levi
Robert Hamilton
Charles Boyd
Brigid Klein
Brian Johnson
Janet Kreizman
Jim Hanna
Sally Patrick
Holly Hody
Dennis Ward
Jan Wengler
John Owens
Leanne Wooden
Chris Voell
Jim McCabe
Sue Nogas
Jean Frane
Mary Dominiak
Julie Winters
Annette Washington
Nicole Christian
Kathie Tryson
Marie Steinwachs
Phillip Dickey
Dana Duxbury
                     Organization
Abt Associates Inc. (contractor)
Alameda City Household Hazardous Waste
Amway Corporation
Bayer Compay
Chemical Specialties Manufacturers Association
City of Santa Monica Environmental Programs
Household & Institutional Products Information Council
King County Department of Natural Resources
Minnesota Pollution Control Agency
Monsanto Company
Monsanto Lawn and Garden
Reckitt & Colman
S.C. Johnson and Son, Inc.
Seattle Public Utilities
Solid Waste Association of North America
The Clorox Company
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
United Industries
University of Missouri Outreach and Extension
Washington Toxics Coalition
Waste Watch Center
                                                                                    227

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                        Appendix 1-9:
Members of Consumer Education Subgroup
                                 229

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         Appendix 1-9: Members of the CLl Consumer Education Subgroup

Prior to September 1998 Partner and Task Force Meeting
                 Name
Susan Altman
Jennifer Andrews
Srabani Roy
MelindaTiemeyer
Julie Spagnoli
Brigid Klein
Colleen Tressler
Carolyn Shanoff
Janet Kreizman
Rick Kingston
Annette Frahm
Mary Grodner
Sally Patrick
Gary Schifilliti
Donna Moramarco
Elizabeth Lawder
Angela Bendorf
Allen James
Stuart McArthur
Jeffrey Hoi lender
Dawn Watzlavick
Terry Bedell
Jim Hasler
Therese Adkins
 Karen Smith
 Kathy Seikel
 William  Sproat
 Mary Dominiak
John Alter
 Jean Frane
 Julie Winters
 Nicole Christian
 Jim Downing
 Amy Breedlove
 Annette  Washington
 Alison Kinn
 John Miller
                  Organization
Abt Associates Inc. (contractor)
Abt Associates Inc. (contractor)
Abt Associates Inc. (contractor)
Bayer Corp/Valentine Radford
Bayer Corporation
Chemical Specialties Manufacturers Association
Federal Trade Commission
Federal Trade Commission
Household & Institutional Products Information Council
International Poison Center
King County Hazardous Waste Program
Louisiana State University
Minnesota Pollution Control Agency
Olin Corp.
Plantamerica
RISE (Responsible Industry for a Sound Environment)
RISE (Responsible Industry fora Sound Environment)
RISE (Responsible Industry for a Sound Environment)
S.C. Johnson and Son, Inc.
Seventh Generation, Inc
Solid Waste Association of North America
The Clorox Company
The Clorox Company
The Clorox Company
The Procter & Gamble Company
U.S. Environmental Protection Agency
U.S-. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
Vermont Agency of Natural Resources
 After the September 1998 Partners and Task Force Meeting
                  Name
 Bob Batteese
 Susan Altman
 Jennifer Andrews
 Srabani Roy
                  Organization
 AAPCO
 Abt Associates Inc. (contractor)
 Abt Associates Inc. (contractor)
 Abt Associates Inc. (contractor)
                                                                                     231

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   Robert Hamilton
   Melinda Tiemeyer
   Mike Hilton
   Julie Spagnoli
   Brigid Klein
   Carolyn Shanoff
   Colleen Tressler
   Janice Podoll Frankle
   George Meindl
   Janet Kreizman
   Joele Richardson
   Rick Kingston
   Annette Frahm
   Mary Grodner
   Mary Ellen Setting
   Sally Patrick
   Holly Hody
   Dennis Ward
   Gary Schifilliti
   Donna Moramarco
   Ellen Brown
   Jan Wengler
   Angela Bendorf
   Elizabeth Lawder
   Allen James, CAE
   Robert L. Rod
   Stuart McArthur
   Marilyn Blood
   John Owens
   Paula Bodey
   Jeffrey Hoi lender
   Chris Voell
   Dawn C. Watzlavick
   Jim Hasler
   Therese Adkins
   Karen Smith
   Maureen Howard
   John W. Impson
   Linda Arrington
   Jim Downing
   Amy Breedlove
   Candy Brassard
   Julie Winters
   Jean Frane
   Mary Dominiak
   David Stangel
   Dana Arnold
   Annette Washington
   Kathy Seikel
   Nicole Christian
   Alison Kinn
 Amway Corporation
 Bayer Corp/Valentine Radford
 Bayer Corporation
 Bayer Corporation
 Chemical Specialties Manufacturers Association
 Federal Trade Commission
 Federal Trade Commission
 Federal Trade Commission
 FMC Corp.
 Household & Institutional Products Information Council
 International Poison Center
 International Poison Control Center
 King County Hazardous Waste Program
 Louisiana State University
 Maryland Department of Agriculture
 Minnesota Pollution Control Agency
 Monsanto Company
 Monsanto Lawn and Garden
 Olin Corp.
 Plantamerica
 Reckitt & Colman
 Reckitt & Colman
 RISE (Responsible Industry for a Sound Environment)
 RISE (Responsible Industry for a Sound Environment)
 RISE (Responsible Industry for a Sound Environment)
 Rod Products Company Inc.
 S.C. Johnson and Son, Inc.
 S.C. Johnson and Son, Inc.
 S.C. Johnson and Son, Inc.
 Scotts
 Seventh Generation, Inc
 Solid Waste Association of North America
 Sofid Waste Association of North America
 The Clorox Company
 The Clorox Company
 The Procter & Gamble Company
 The Procter & Gamble Company
 U.S. Department of Agriculture
 U.S. Environmental Protection Agency
 U.S. Environmental Protection Agency
 U.S. Environmental Protection Agency
 U.S. Environmental Protection Agency
 U.S. Environmental Protection Agency
 U.S. Environmental Protection Agency
 U.S. Environmental Protection Agency
 U.S. Environmental Protection Agency
 U.S. Environmental Protection Agency
 U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
232

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William Sproat
Marie Steinwachs
John Miller
Heather Hansen
Dana Duxbury
U.S. Environmental Protection Agency
University of Missouri Outreach and Extension
Vermont Agency of Natural Resources
Washington Friends of Farms & Forests
WasteWatch Center
                                                                                       233

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                              Appendix 2-1:
Quantitative Research Screening Questionnaire
                                     235

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ONSWER THIS SIDE FIRST        33708-02 n
la.  In the past 12 months, has any member of your
     household used any of the following types of
     household cleaners: all purpose cleaner, toilet
     bowl cleaner, bathroom cleaner or mold and
     mildew remover?
 i n Yes -» (Continue) 2 Q No -» (Slkip To Qu. 2a)

 1b.  Indicate age and sex of primary user.

     Age:  _ yrs.   Sex:  iQ Male zQ Female

 1c.  Is this person also the primary purchaser?
         i n Yes        2 D No

 2a.  In the past 12 months, has any member of your
     household used any of the following types of
     indoor insecticide products: sprays, baits,
     powders, or indoor foggers?
 t  D Yes -» (Continue) t D  No -» (Skip To Qu. 3a)

 2b.  Indicate age and sex of primary user.
      Age: _ yrs.  Sex: t£] Male zQ Female

 2c.  Is this person also the primary purchaser?
         t  D Yes        2 D No

 3a.  In the past 12 months, has any member of your
      household used any of the following types of
      outdoor pesticide  products to eliminate or control
      weeds, bugs, or pests in your yard/garden:
      granules, sprays,  or powders?
  i n Yes -» (Continue) j D No -» (Skip To Qu. 4)

 3b.  Indicate age and sex of primary twer.
      Age: _ yrs.   Sex:  iQ Male 2 D Female

  3c.   Is this person also the primary purchaser?
         i Q Yes         t D No

  4.    Which of the following types of products, if any,
       have you gone to the store to purchase but did
       not purchase any at all because of the information
       on the package? (X ALL That Apply)
          i n  Household cleaner
          s Q  Indoor insecticide
          j Q  Outdoor pesticide
          4 n  None of the above
                               CONTINUE O
                                                                        237

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                                Appendix 2-2:
Quantitative Research Telephone Questionnaires
                                       239

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                                                 34958-1
                                                 DATE:
                                                 INTERVIEWER:
A.
                                     Hello, I'm calling on behalf of Carol Adams of National Family
                                     Opinion. Have I reached the (INSERT LAST NAME) residence?
                                     (IF CORRECT RESIDENCE, CONTINUE.   OTHERWISE,
                                     TERMINATE) May I please speak to the person in your household
                                     who is MOST RESPONSIBLE FOR PURCHASING AND USING
                                     INDOOR INSECTICIDE  PRODUCTS?  (WHEN PROPER
                                     RESPONDENTON PHONE, REPEATLEAD-INAND CONTINUE)
                                     (IF RESPONDENTNOT AVAILABLE, ARRANGE A CALLBACK)
                                     I am calling about the indoor insecticide study. I would like to ask
                                     you some questions about the materials you received.

A few days ago you were sent a letter and two sealed envelopes. Did you receive them? (TAKE DK AS NO)
            Yes	1
            No	2 - (TERMINATE)
                                                                               241

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Open the envelope marked "label"
moment to look at this label.
      Inside is a replica of a label you would see on an indoor insecticide product. Take a
(NOTE:


(NOTE:
ROTATE QUESTIONS 1-9a)
IF RESPONDENT READS ANY PART OF PARAGRAPH LISTED ON "CORRECT
RESPONSE", IT IS A CORRECT RESPONSE)
1.     Now go to the place that gives directions on how to use the product and read to me from that section.
       (WAIT FOR RESPONDENT TO READ) (RECORD ONE RESPONSE ONLY)

                    Correct response (DIRECTIONS FOR USE: it is a
                      violation of Federal Law to use this product in a
                      manner inconsistent with its labeling.  FOR
                      HOUSEHOLD USE: SHAKE WELL BEFORE
                      EACH USE  Hold container upright. Do not spray
                      up into air. Apply to surfaces only. Point spray
                      opening toward surface to be sprayed and press
                      button firmly. Hold about 12" from surface being
                      sprayed. Spray until surfaces are wet Repeat
                      treatment as necessary. ROACHES, PALMETTO
                      BUGS, WATERBUGS, CRICKETS, SILVERFISH,
                      AND SPIDERS: Spray directly on insects when
                      possible. Thoroughly spray cracks, baseboards,
                      underneath kitchen shelves, and other places
                      where insects habitate. ANTS AND EARWIGS:
                      Spray door sills, wood frames, outside foundations
                      and porches.  Spray directly on ant hills. FLIES,
                      MOSQUITOES, GNATS, WASPS: Apply on
                      screens, walls, door and window frames, and
                      other surfaces where insects congregate)	1
                    Incorrect response	2

                    Could not find	3

                    DK/Refused	4
     242
                                                                                           34958-1

-------
2.      Now, please find a description of what the product does and read it to me.  (WAIT FOR RESPONDENT TO
       READ) (RECORD ONE RESPONSE ONLY)
                                      l
                    Correct response (ANT & ROACH KILLER
                       FRESH SCENT. Kills fast in two ways: (1) it
                       kills bugs fast-on contact and (2) it keeps on
                       killing with residual action even after you spray,
                       for up to 6 weeks)	1
                    Incorrect response	2

                    Could not find	3

                    DK/Refused	4
       Next, please locate information about where the product should not be used and read it to me.  (WAIT FOR
       RESPONDENT TO READ) (RECORD ONE RESPONSE ONLY)

                    Correct response (Avoid excessive wetting of
                       asphalt, tile, rubber and plastic materials. Do
                       not apply to humans, pets, plants or contaminate
                       feed, food stuffs, dishes or utensils. Cover and
                       avoid spraying fish aquariums. Cover or
                       remove exposed food, dishes, utensils and
                       food handling equipment)	1
                     Incorrect response	2

                     Could not find	'.	3

                     DK/Refused	4
       And can you please locate information about the effects on personal and children's health or safety and read
       them to me? (WAIT FOR RESPONDENT TO READ) (RECORD ONE RESPONSE ONLY)

                     Correct response (PRECAUTIONARY
                       STATEMENTS HAZARDS TO HUMANS
                       AND DOMESTIC ANIMALS: CAUTION:
                       Harmful or fatal if swallowed or absorbed
                       through the skin.  Avoid breathing spray mist.
                       Avoid contact with skin or clothing. Wash
                       thoroughly with soap and water after handling.
                       Provide adequate ventilation of area being
                       treated.)	
                     Incorrect response

                     Could not find	
                     DK/Refused.
.1

.2

.3

.4
                                                                                       243

-------
S.     Now please find information about effects on pets, wildlife or water and read them to me.  (WAIT FOR
      RESPONDENT TO READ) (RECORD ONE RESPONSE ONLY)
                                    1
                   Correct response (PRECAUTIONARY
                     STATEMENTS, HAZARDS TO HUMANS AND
                     DOMESTIC ANIMALS: CAUTION: Do not apply to
                     humans, pets, plants or contaminate feed,
                     food stuffs, dishes or utensils)	1

                   Incorrect response	2

                   Could not find	3

                   DK/Refused	4


6.     Now can you please locate product contents or ingredients and read one to me?  (WAIT FOR RESPONDENT
       TO READ, SPELL OR GET EVEN CLOSE TO PRONOUNCING)  (RECORD ONE RESPONSE ONLY)

                    Correct response (ACTIVE INGREDIENTS:
                      Permethrin 0.20%, 2 - (1-Methylethoxy) phenol
                      methylcarbamate 0.50%. Tralomethrin (1R)
                      0.01 %, d-trans Allethrin 0.05%, Pyrethrins 0.20%,
                      Piperonyl butoxide technical 0.50%,
                      OTHER INGREDIENTS: 98.54%. contains petroleum
                      distillates. Total = 100%)	• 1

                    Incorrect response	2

                    Could not find	3

                    DK/Refused	4


 7      Now please go to the part of the label that gives you information on how to store the product and read it to me.
        (WAIT FOR RESPONDENT TO READ)  (RECORD ONE RESPONSE ONLY)

                    Correct response (STORAGE: Store away from
                      heat or open flames, in an area inaccessible
                      to children)	1  ..-

                    Incorrect response	2

                    Could not find	3

                    DK/Refused	4
     244
                                                                                           34958-1

-------
8.      Next please find the area that gives you information on how to dispose of the packaging of the product and read
       it to me.  (WAIT FOR RESPONDENT TO READ) (RECORD ONE RESPONSE ONLY)

                    Correct response (DISPOSAL: This container
                      may be recycled in the few but growing number of
                      communities where aerosol can recycling is
                      available. Before offering for recycling, empty the
                      can by using the product according to the label.
                      (DO NOT PUNCTURE)  If recycling is not available,
                      replace cap, wrap in several layers of newspaper
                      and discard in trash)	1
                    Incorrect response	2

                    Could not find	3
                    DK/Refused.
 9a.    Now can you find the place that gives you information on what to do in an emergency or in case of accident and
       read to me from that section.  (WAIT FOR RESPONDENT TO READ)  (RECORD ONE RESPONSE ONLY)

                    Correct response (FIRST AID. IF SWALLOWED:
                      Call doctor or Poison Control Center immediately.
                      Gastric lavage is indicated in material was taken
                      internally. (Do not induce vomiting).
                      IF IN EYES: Flush with plenty of water.
                      IF ON SKIN: Wash promptly with soap and
                      water.  Get medical attention if irritation persists
                      or develops. IF INHALED: Remove victim to
                      fresh air. Apply artificial respiration if indicated.)..
                     Incorrect response

                     Could not find	
                     DK/Refused.
.1

.2

.3

.4
 9b.    Was all of the information on this label where you expected it to be?  (TAKE DK AS NO)


                     Yes	1 - (SKIP TO QU. 10a)

                     No	2


 9c.    What information was not where you .expected it to be? (RECORD VERBATIM) (CLARIFY VAGUE
        RESPONSES)

                                       TYPE DIRECTLY INTO CRT
                                                                                       245
                                                                                              34958-1

-------
10a.    Now please look at the section on the back of the label entitled "Directions for use". Are there any WORDS or
       PHRASES in this section that could be CONFUSING or DIFFICULT to understand? (DO NOT READ LIST)
       (ACCEPT ONE RESPONSE ONLY) ;

                    Yes	1

                    No	2 - (SKIP TO QU. 11a)

                    DK/Refused	3 - (SKIP TO QU. 11a)


10b.    What WORDS or PHRASES are those? (DO NOT READ LIST) (ACCEPT MULTIPLES)

                    It is a violation of federal law to use this product in a
                     manner inconsistent with its labeling	1

                    Avoid excessive wetting	2

                    Other (Specify): 	3

                    DK/Refused	4


11a.    Now please go to the section on the back of the label titled "Storage" and a bit further down "Disposal". Are there
       any WORDS or PHRASES in this section that could be CONFUSING or DIFFICULT to understand? (DO NOT
       READ LIST)  (ACCEPT ONE RESPONSE ONLY)

                    Yes	1

                    No	2-(SKIPTOQU.12a)

                    DK/Refused	3 - (SKIP TO QU. 12a)


11b.    What words or phrases are those?  (RECORD VERBATIM)

                                     TYPE DIRECTLY INTO CRT
12a.   Now please look at the section on the back of the label titled "Precautionary Statements". Are there any WORDS
       or PHRASES that could be CONFUSING or DIFFICULT to understand?  (DO NOT READ LIST)  (ACCEPT ONE
       RESPONSE ONLY)

                    Yes	1

                    No	2 - (SKIP TO QU. 13a)

                    DK/Refused	3 - (SKIP TO QU. 13a)

                                                            i                              ij

12b.   What words or phrases are those? (DO NOT READ LIST) (ACCEPT MULTIPLES)

                    Hazards to humans and domestic animals	1

                    Provide adequate ventilation of area being treated	2

                    Other (Specify): .	3
                    DK/Refused	           4
                                                 6
34958-1

-------
13a.   Next, I would like you to look at the section on the back of the label titled "First Aid". Are there any WORDS or
      PHRASES in this section that could be CONFUSING or DIFFICULT to understand? (DO NOT READ LIST)
      (ACCEPT ONE RESPONSE ONLY) '

                   Yes	.'	1

                   No	2 - (SKIP TO QU. 14a)

                   DK/Refused	3 - (SKIP TO QU. 14a)


13b.   What WORDS or PHRASES are those? (DO NOT READ LIST) (ACCEPT MULTIPLES)

                   (IF IN EYES) Flush with plenty of water	1

                   (IF INHALED) Remove victim to fresh air	2

                   If irritation persists	3

                   Gastric lavage is indicated if
                     material was taken internally	4

                   Other (Specify):	5

                   DK/Refused	6


14a.   And finally, I would like you to take a look at the section on the back of the label titled "Physical or chemical
       hazards'. Are there any WORDS or PHRASES in this section that could  be CONFUSING or DIFFICULT to
       understand? (DO NOT READ LIST)  (ACCEPT ONE RESPONSE ONLY)

                   Yes	1

                    No	„	2 - (SKIP TO NOTE BEFORE QU. 15a)

                    DK/Refused	3 - (SKIP TO NOTE BEFORE QU. 15a)


 14b.   What WORDS or PHRASES are those? (DO NOT READ LIST) (ACCEPT MULTIPLES)

                    Do not puncture or incinerate container	1

                    Other (Specify):	2

                    DK/Refused	3
                                                                                     247

-------
15.    Now I'm going to read you some words or phrases from this label. For each one, please tell me what it means to
      you.
(NOTE:
                IF CODE 1 NOT MENTIONED IN QUESTION 10b ASK QUESTION 15a. OTHERWISE
                SKIP TO NOTE BEFORE QUESTION 15b)                           »vw»c,
15a.
Under directions for use, what does "It is a violation of federal law to use this product in a manner inconsistent
with its labeling", mean to you?  (RECORD VERBATIM) (CLARIFY VAGUE RESPONSES)

                              TYPE DIRECT INTO CRT
(NOTE:
                IF CODE 2 NOT MENTIONED IN QUESTION 10b ASK QUESTION 15b. OTHERWISE
                SKIP TO NOTE BEFORE QUESTION 15c)
15b.   Halfway through directions for use, what does "Avoid excessive wetting" mean to you? (RECORD VERBATIM)


                                    TYPE DIRECT INTO CRT
(NOTE:
                IF CODE 1 NOT MENTIONED IN QUESTION 12b ASK QUESTION 15c. OTHERWISE,
                SKIP TO NOTE BEFORE QUESTION 15d)
15c.
Under the title precautionary statements, what does "hazards to humans and domestic animals" mean to you?
(RECORD VERBATIM) (CLARIFY VAGUE RESPONSES)
                                    TYPE DIRECT INTO CRT
(NOTE:
               IF CODE 2 NOT MENTIONED IN QUESTION 12b ASK QUESTION 15d. OTHERWISE,
               SKIP TO NOTE BEFORE QUESTION 15e)
15d.   Halfway through the precautionary statements, what does "provide adequat§"ventilation of area treated" mean to
      you? (RECORD VERBATIM) (CLARIFY VAGUE RESPONSES)


                                    TYPE DIRECT INTO CRT
(NOTE:
               IF CODE 3 NOT MENTIONED IN QUESTION 13b ASK QUESTION 15e. OTHERWISE
               SKIP TO NOTE BEFORE QUESTION 15f)
15e.
Look at the second sentence under the title "First Aid". What does this statement "if irritation persists" mean to
you? (RECORD VERBATIM)  (CLARIFY VAGUE RESPONSES)

                              TYPE DIRECT INTO CRT
(NOTE:
                IF CODE 1 NOT MENTIONED IN QUESTION 13b ASK QUESTION 15f. OTHERWISE
                SKIP TO NOTE BEFORE QUESTION 15g)
                                                                                     34958-1

-------
15f.   Look at where it says "if in eyes" in capital lecters and tell me what "flush with plenty of water" means to you?
      (RECORD VERBATIM) (CLARIFY VAGUE RESPONSES)

                                      TYPE DIRECT INTO CRT
(NOTE:
IF CODE 2 NOT MENTIONED IN QUESTION 13b ASK QUESTION 15g. OTHERWISE,
SKIP TO NOTE BEFORE QUESTION 1Sh)
15g.  Look at where it says "if inhaled" in capital letters and tell me what "remove victim to fresh air" means to you?
      (RECORD VERBATIM) (CLARIFY VAGUE RESPONSES)

                                      TYPE DIRECT INTO CRT
(NOTE:
IF CODE 1 NOT MENTIONED IN QUESTION 14b ASK QUESTION 15h. OTHERWISE,
SKIP TO NOTE BEFORE QUESTION 151)
15h.   In the physical or chemical hazards section what does "do not puncture or incinerate container" mean to you?
       (RECORD VERBATIM) (CLARIFY VAGUE RESPONSES)

                                      TYPE DIRECT INTO CRT


15i.    Now, please look at the front of the label at where the ingredients are listed and tell me what "other ingredients"
       means to you? (RECORD VERBATIM) (CLARIFY VAGUE RESPONSES)

                                      TYPE DIRECT INTO CRT


 16.    Just to keep our records up-to-date, may I have your age please? (REFUSED = 98)

                   Age:	


 17.    (RECORD SEX FROM VOICE):

                   Male	1

                   Female	2


 Those are all of the questions I have this (MORNING/AFTERNOON/EVENING). Sometime  in the next day or so, please
 open up the envelope marked "Questionnaire"" and complete and return the survey inside. Please keep the replica of the
 indoor insecticide label handy while you are filling out the questionnaire. You will need to refer to it. Thank you for
 participating. (TERMINATE)
                                                                                   249

-------
                                                 34958-2
                                                 DATE:
                                                 INTERVIEWER:
                                           Hello, I'm calling on behalf of Carol Adams of National Family
                                           Opinion. Have I reached the (INSERT LAST NAME) residence?
                                           (IF CORRECT  RESIDENCE,  CONTINUE.  OTHERWISE,
                                           TERMINATE) May I please speak to the person in your household
                                           who is MOST RESPONSIBLE: FOR PURCHASING AND USING
                                           HOUSEHOLD CLEANER PRODUCTS?  (WHEN PROPER
                                           RESPONDENTON PHONE, REPEATLEAD-IN AND CONTINUE)
                                           (IFRESPONDENTNOTAVAILABLE,ARRANGEACALLBACK)
                                           I am calling about the household cleaner study. I would like to ask
                                           you some questions about the materials you received.

A.    A few, days ago you were sent a letter and two sealed envelopes.  Did you receive them? (TAKE DK AS NO)
                  Yes	1
                  No	2 - (TERMINATE)

Open the envelope marked "label". Inside is a replica of a label you would see on a household cleaner product. Take a
moment to look at this label.

(NOTE:      ROTATE QUESTIONS 1-7)

(NOTE:      IF RESPONDENT READS ANY PART OF PARAGRAPH LISTED ON "CORRECT RESPONSE," IT IS
            A CORRECT RESPONSE)
NATIONAL FAMILY OPINION
                                                                                     34958-2

-------
1.      Now go to the place that gives directions on how to use the product and read to me from that section. (WAIT
       FOR RESPONDENT TO READ)  (RECORD ONE RESPONSE ONLY)

                     Correct response (Directions For Use: It is a
                       violation of Federal law to use this product in a
                       manner inconsistent with its labeling. TO OPERATE:
                       Turn nozzle to "Spray" or "Stream".  GENERAL
                       CLEANING: Holding nozzle 6 to 8 inches from surface,
                       spray soiled area, then wipe clean.  Note: A rinse is
                       required for surfaces in direct contact with food.  Do
                       not use on marble surfaces.  DISINFECTION: Spray
                       until thoroughly wet Let stand 10 minutes before
                       wiping or rinsing. For heavily soiled surfaces, preclean
                       according to General Cleaning directions. MILDEW
                       Preclean surface, then spray until thoroughly wet.
                       Let air dry. Repeat weekly or when new growth
                       appears)	1

                     Incorrect response	2

                     Could  not find	3

                     DK/Refused	4


 2.     Now, please find a description of what the product does and read it to me.  (WAIT FOR RESPONDENT TO
       READ) (RECORD ONE RESPONSE ONLY)

                     Correct response (Cuts Grease! Kills Germs! All
                        Purpose Cleaner! VUiam All Purpose Cleaner cleans,
                        deodorizes and disinfects household surfaces.
                        Cuts grease and grime, removes stains. Kills
                        Staphylococcus, Streptococcus and Salmonella
                        bacteria)	1

                     Incorrect response	2

                     Could not find	3

                     DK/Refused	4


 3.     Next, please locate information about the product causing damage to surfaces and read them to me. (WAIT FOR
        RESPONDENT TO READ)  (RECORD ONE RESPONSE ONLY)

                     Correct response (Do not use on marble surfaces)	1

                     Incorrect response	2

                     Could not find	3

                     DK/Refused	4
  NATIONAL FAMILY OPINION
                                                                                         251

-------
4.
And can you please locate information about the effects on personal and children's health or safety and read
them to me? (WAIT FOR RESPONDENT TO READ) (RECORD ONE RESPONSE ONLY)

             Correct response (KEEP OUT OF REACH OF
               CHILDREN. CAUTION: See back panel for
               additional precautionary statements.
               PRECAUTIONARY STATEMENTS: HAZARDS TO
               HUMANS AND DOMESTIC ANIMALS. CAUTION:
               CAUSES EYE IRRITATION. Do not get in eyes, on
               skin or clothing. Avoid contact with food)	1
                   Incorrect response	2

                   Could not find	3
                   DK/Refused.
5.    Now can you please locate the product contents or ingredients and read one to me?  (WAIT FOR
      RESPONDENT TO READ, SPELL OR GET EVEN CLOSE TO PRONOUNCING) (RECORD ONE RESPONSE
      ONLY)

                   Correct response
                     (ACTIVE INGREDIENTS: Alkyl (C12 40%,
                     C14 60%, c16 10%) dimethyl benzyl
                     ammonium chloride	0.3%

                     OTHER INGREDIENTS	99.7%

                     TOTAL INGREDIENTS	100.0%)	1

                   Incorrect response	2

                   Could not find	3

                   DK/Refused	4

                                                                    I       '            ii
6.    Now please go to the part of the label that gives you information on how to store the product and read it to me
      (WAIT FOR RESPONDENT TO READ) (RECORD ONE RESPONSE ONLY)

                   Correct response (STORAGE AND DISPOSAL: store in
                     areas inaccessible to small children.  Do not reuse
                     empty container. Rinse thoroughly & discard in
                     the trash)	1

                   Incorrect response	2

                   Could not find	3

                   DK/Refused	4
NATIONAL FAMILY OPINION
                                                                                       34958-2

-------
7.    ' And please go to the part of the label that gives you information on how to dispose of the product packaging and
      read it to me.  (WAIT FOR RESPONDENT TO READ)  (RECORD ONE RESPONSE ONLY)

                    Correct response (STORAGE AND DISPOSAL:
                      do not reuse empty containers.  Rinse thoroughly
                      and discard in trash)	1

                    Incorrect response	2

                    Could not find	3

                    DK/Refused	4


8.     Now can you find the place that gives you information on what to do in an emergency or in case of accident and
      read it to me?  (WAIT FOR RESPONDENT TO READ) (RECORD ONE RESPONSE ONLY)

                    Correct response (FIRST AID: In case of eye contact,
                      flush with plenty of water for at least 15 minutes.
                      Call a physician if irritation persists)	1

                    Incorrect response	2

                    Could not find	•.	3

                    DK/Refused	4


 9a.    Was all of the information on this label where you expected it to be? (TAKE DK AS NO)

                    Yes	1 - (SKIP TO QU. 10a)

                    No	2


 9b.    What information was not where you expected it to be?  (RECORD VERBATIM) (CLARIFY VAGUE
       RESPONSES)

                                     TYPE DIRECTLY INTO CRT


 10a.   Now please look at the section on the back of the label entitled "Directions for use". Are there any WORDS or
       PHRASES in this section that could be CONFUSING or DIFFICULT to understand? (DO NOT READ LIST)
       (ACCEPT ONE RESPONSE ONLY)

                    Yes	1

                     No	2 - (SKIP TO QU. 11 a)

                     DK/Refused	3 - (SKIP TO QU. 11a)
  NATIONAL FAMILY OPINION
                                                                                    253

-------
10b.  What WORDS or PHRASES are those? (DO NOT READ LIST) (ACCEPT MULTIPLES)
                    It is a violation of federal law to use this product in a
                      manner inconsistent with its labeling	1
                    Other (Specify):	2
                    DK/Refused	3

11a.  Now please go to the sections titled "General Cleaning", "Disinfection" and "mildew". Are there any WORDS or
      PHRASES in these sections that could be CONFUSING or DIFFICULT to understand? (DO NOT READ LIST)
      (ACCEPT ONE RESPONSE ONLY)                                         *                  ;
                    Yes	1
                    No	2 - (SKIP TO QU. 12a)
                    DK/Refused	3 - (SKIP TO QU. 12a)

11b.  What words or phrases are those? (DO NOT READ LIST) (ACCEPT MULTIPLES)
                    A rinse is required	1
                    Disinfection	2
                    Predean	3
                    Thoroughly wet	4
                    Other (Specify): _____	5
                    DK/Refused	„	6

12a.  Now please look at the section on the back of the label titled "Precautionary Statements". Are there any words or
      phrases that could be confusing or difficult to understand? (DO NOT READ LIST) (ACCEPT ONE RESPONSE
      ONLY)
                    Yes	_	„.. 1
                    No	2 - (SKIP TO QU. 13a)
                    DK/Refused	5 - (SKIP TO QU. 13a)

12b.  What words or phrases are those? (DO NOT READ LIST) (ACCEPT MULTIPLES)
                    Hazards to humans and domestic animals	1
                    Other (Specify):	2
                    DK/Refused	3
NATIONAL FAMILY OPINION
                                                                                         34958-:

-------
13a.   Next I would like you to look at the section on the back of the label titled "First Aid". Are there any WORDS or
      PHRASES in this section that could be CONFUSING or DIFFICULT to understand? (DO NOT READ LIST)
      (ACCEPT ONE RESPONSE ONLY)

                   Yes	1

                   No	2 - (SKIP TO QU. 14a)

                   DK/Refused	3  - (SKIP TO QU. 14a)


13b.  What WORDS or PHRASES are those? (DO NOT READ LIST) (ACCEPT MULTIPLES)

                   (IN CASE OF EYE CONTACT) Flush with
                     plenty of water	1

                   Other (Specify):	2

                   DK/Refused	3


 14a.   And finally, I would like you to take a look at the section on the back of the label titled "Storage and disposal". Are
       there any WORDS or PHRASES in this section that could be CONFUSING or DIFFICULT to understand? (DO
       NOT READ LIST) (ACCEPT ONE RESPONSE ONLY)

                   Yes	1

                    No	2 -(SKIP TO NOTE BEFORE QU. 15a)

                    DK/Refused	5  - (SKIP TO NOTE BEFORE QU. 15a)


 14b.   What WORDS or PHRASES are those?  (DO NOT READ LIST) (ACCEPT MULTIPLES)

                    Store in areas inaccessible to small children	1

                    Other (Specify):	2

                    DK/Refused	3


        Now I'm going to read you some words or phrases from this label. For each one, please tell me what it means to
        you.


  (NOTE:       IF CODE 1 NOT MENTIONED IN QUESTION 10b ASK QUESTION 15a. OTHERWISE, SKIP TO NOTE
              BEFORE QUESTION 15b)


  15a    Under directions for use, what does "It is a violation of federal law to use this product in a manner inconsistent
    :   with its labeling", mean to you? (RECORD VERBATIM)  (CLARIFY VAGUE RESPONSES)

                                      TYPE DIRECT INTO CRT
  NATIONAL FAMILY OPINION
                                                                                  255

-------
(NOTE:
                                    'N QUESTI°N 11b ASK QUESTION 15b. OTHERWISE, SKIP TO NOTE
    "  VA^ufRESPO^SES)5601100' ^ d°6S "disinfection" mean to YOU? (RECORD VERBATIM) (CLARIFY




                                    TYPE DIRECT INTO CRT
(NOTE:      IF CODE 1 NOT

            BEFORE QUESTION
                                   'N QUESTION 12b ASK QUESTION 15c. OTHERWISE, SKIP TO NOTE
15c.   By the title precautionary statements, what does "hazards to

      (RECORD VERBATIM) (CLARIFY VAGUE RESPONSES)
                                                                               to you?
                                    TYPE DIRECT INTO CRT
(NOTE:
            BEFORE
      VAGUE RESPONSES)
        IN QUESTION 13b ASK QUESTION 15d. OTHERWISE, SKIP TO NOTE






does "flush with plenty of water" mean to you? (RECORD VERBATIM) (CLARIFY




        TYPE DIRECT INTO CRT
(NOTE:
15e.   Look i
            QUE° TO1NlS) MENTI°NED IN QUESTION 14b ASK QUESTION 15«s. OTHERWISE, SKIP TO
                 mir^Bo wp™.s™i?n- VVhat does tnis statement, "store in areas inaccessible to
                 (RECORD VERBATIM) (CLARIFY VAGUE RESPONSES)



                                   TYPE DIRECT INTO CRT
15f.
                                   TYPE DIRECT INTO CRT




16.    Just to keep our records up-to-date, may I have your age please? (REFUSED = 98)


                  Age:	




17.    (RECORD SEX FROM VOICE):



                  Male	


                  Female	
                                                          .1


                                                          .2
NATIONAL FAMILY OPINION
                                                                                  34958-2

-------
(NOTE:      IF CODE 1 NOT MENTIONED IN QUESTION 11b ASK QUESTION 15b. OTHERWISE, SKIP TO NOTE
            BEFORE QUESTION 15c)


15b.   In the general cleaning section, what does "a rinse is required" mean to you? (RECORD VERBATIM) (CLARIFY
      VAGUE RESPONSES)

                                    TYPE DIRECT INTO CRT


(NOTE:      IF CODE 1 NOT MENTIONED IN QUESTION 12b ASK QUESTION 15c. OTHERWISE, SKIP TO NOTE
            BEFORE QUESTION 15d)


15c.   By the title precautionary statements, what does "hazards to humans and domestic animals" mean to you?
      (RECORD VERBATIM) (CLARIFY VAGUE RESPONSES)

                                    TYPE DIRECT INTO CRT


(NOTE:       IF CODE 1 NOT MENTIONED IN QUESTION 13b ASK QUESTION 15d. OTHERWISE, SKIP TO NOTE
             BEFORE QUESTION 15e)


15d.   In the first aid section, what does "flush with plenty of water" mean to you?  (RECORD VERBATIM)  (CLARIFY
       VAGUE RESPONSES)

                                    TYPE DIRECT INTO CRT


 (NOTE:       IF CODE 1 NOT MENTIONED IN QUESTION 14b ASK QUESTION 15e. OTHERWISE, SKIP TO
             QUESTION 15f)


 15e.   Look in the storage and disposal section. What does this statement, "store in areas inaccessible to children"
       mean to you?  (RECORD VERBATIM) (CLARIFY VAGUE RESPONSES)

                                     TYPE DIRECT INTO CRT


 15f     Now please look at the front of the label at where the ingredients are listed and tell me what "other ingredients"
        means to you? (RECORD VERBATIM) (CLARIFY VAGUE RESPONSES)

                                     TYPE DIRECT INTO CRT


 16.     Just to keep our records up-to-date, may I have your age please? (REFUSED = 98)

                    Age: 	.	
  17.    (RECORD SEX FROM VOICE):

                    Male	

                    Female	
.1

.2
  NATIONAL FAMILY OPINION
                                                                                 257

-------
Those are all of the questions I have this (MORNING/AFTERNOON/EVENING). Sometime in the next day or so please
open up the envelope marked "Questionnaire" and complete and return the survey inside. Please keep the replica of the
household cleaner product label handy while you are filling out the questionnaire. You will need to refer to it  Thank vou
for participating.  (TERMINATE)                                                                '
                                                                                              34958-2

-------
                                                 34958-3
                                                 DATE:
                                                 INTERVIEWER:
                                           Hello, I'm calling on behalf of Carol Adams of National Family
                                           Opinion. Have I reached the (INSERT LAST NAME) residence?
                                           (IF CORRECT RESIDENCE, CONTINUE.  OTHERWISE,
                                           TERMINATE) May I please speak to the person in your household
                                           who is MOST RESPONSIBLE FOR PURCHASING AND USING
                                           OUTDOOR PESTICIDE  PRODUCTS?  (WHEN PROPER
                                           RESPONDENTON PHONE, REPEAT LEAD-IN AND CONTINUE)
                                           (IF RESPONDEiNTNOT AVAILABLE, ARRANGE A CALLBACK)
                                           I am calling about the outdoor pesticide study. I would like to askyou
                                           some questions about the materials you received.

A.    A few days ago you were sent a letter and two sealed envelopes. Did you receive them? (TAKE DK AS NO)
                  Yes	1
                  No	2 - (TERMINATE)
                                                                               259

-------
Open the envelope marked "label". Inside is a replica of a label you would see on an outdoor pesticide product  Take a
moment to look at this label.
(NOTE:
ROTATE QUESTIONS 1 - 9a)
(NOTE:       IF RESPONDENT READS ANY PART OF PARAGRAPH LISTED ON "CORRECT RESPONSE", IT IS
             A CORRECT RESPONSE)
1.     Please go to the place that gives directions on how to use the product and read to me from that section.  (WAIT
      FOR RESPONDENT TO READ) (RECORD ONE RESPONSE ONLY)

                   Correct response (DIRECTIONS FOR USE: It is a
                     violation of Federal law to use this product in a
                     manner inconsistent with its labeling.  READ
                     ENTIRE LABEL. USE STRICTLY IN
                     ACCORDANCE WITH LABEL
                     PRECAUTIONARY STATEMENTS AND
                     DIRECTIONS. HOW TO USE: Turn sprayer
                     nozzle to open. Adjust nozzle to give a coarse
                     spray. Aim at center of weed and spray to wet.
                     Spray any time weeds are actively growing.
                     Do not apply when rain or temperatures over 85
                     degrees F are expected within 24 hours. Hard to
                     control weeds may require repeat application in
                     2 to 3 weeks. V\feeds in newly seeded lawns may
                     be sprayed after lawn has been mowed 3 times.)..,
                   Incorrect response

                   Could not find	
                   DK/Refused.
                                                   .1

                                                   .2

                                                   .3

                                                   .4
   260
                                                                                         34958-3

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2.      Now, please find a description of what the product does and read it to me.  (WAIT FOR RESPONDENT TO
       READ) (RECORD ONE RESPONSE ONLY)

                     Correct response (WEED KILLER: Kills broadleaf
                      weeds in lawns - roots and all. Kills weeds, not
                      lawn grasses when used according to directions.
                       Ready-To-Use. No Mixing. KILLS: Bur Clover,
                      Carpetweeds, Chickweeds, Creeping Charlie,
                      Cudweed, Curly Dock, Dandelion, English
                       Daisy, False Dandelion, Flarea, Florida Pusley,
                       Heartleaf Drymary, Henbit, Oxalis, Pennywort,
                       Plantains, Purslane, Red Sorrel, Sheep Sorrel,
                       Spurges, Thistles, Toadflax, White Clover, Wild
                       Carrot, Wild Geranium, Wild Onion. KILLS
                      WEEDS - NOT LAWN GRASSES. KILLS:
                       Dandelion, Clover, Plantain, Chickweed, Oxalis,
                       Spurge, Henbit, English Daisy, Wild Onion and
                       many other listed weeds.)	
                     Incorrect response

                     Could not find	
                     DK/Refused.
.1

.2

.3

.4
       Next, please locate information about where this product should not be used and read it to me.  (WAIT FOR
       RESPONDENT TO READ) (RECORD ONE RESPONSE ONLY)

                     Correct response (IMPORTANT: Do not use this
                       product for controlling weeds in vegetable
                       gardens, flower beds or around shrubs or
                       ornamental plants.  Temporary discoloration
                       may occur to St. Augustine, Centipede, and
                       Bentgrass lawns.)	1
                     Incorrect response	2

                     Could not find	3

                     DK/Refused	4
                                                                                        261

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4.
And can you please locate information about the effects on personal and children's health or safety and read one
tome? (WAIT FOR RESPONDENT TO READ)  (RECORD ONE RESPONSE ONLY)

             Correct response (PRECAUTIONARY
                STATEMENTS. HAZARDS TO HUMANS
                AND DOMESTIC ANIMALS. CAUTION:
                Harmful if absorbed through skin. APPLYING:
                When applying this product wear goggles or face
                shield, long pants, long sleeved shirt, socks,
                shoes, and chemical resistant gloves. Wash
                nondisposable gloves thoroughly with soap and
                water before removing. Remove contaminated
                clothing and launder separately before reuse.
                Promptly and thoroughly wash hands and exposed
                skin with soap and water after using this product.
                Remove saturated clothing as soon as possible
                and shower.)	1
S.
                    Incorrect response	2

                    Could not find	3

                    DK/Refused	4
Now please find information about the effects on pets, wildlife or water and read one to me.  (WAIT FOR
RESPONDENT TO READ) (RECORD ONE RESPONSE ONLY)

             Correct response (ENVIRONMENTAL
                HAZARDS. This product is toxic to aquatic
                invertebrates. Drift or runoff may adversely
                affect aquatic invertebates and nontarget plants.
                Do not apply directly to water.  Exercise caution
                when disposing of waste as groundwater
                contamination may result from careless handling
                or spills. Do not contaminate water when disposing
                of equipment washwater.)	1
                    Incorrect response	2

                    Could not find	3

                    DK/Refused	4
       Now can you please locate product contents or ingredients and read the first ingredient to me?  (WAIT FOR
       RESPONDENT TO READ, SPELL TO GET EVEN CLOSE TO PRONOUNCING)  (RECORD ONE RESPONSE
       ONLY)
                     Correct response (ACTIVE INGREDIENTS:
                       2, 4-D dimethylamine salt 0.20%, MCPA
                       dimethylamine salt 0.20%)	
                                                           .1
                     Incorrect response	2

                     Could not find	3

                     DK/Refused	4
    262
                                                                                             34958-3

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7.
Now please go to the part of the label that gives you information on how to store the product and read to me from
that section.  (WAIT FOR RESPONDENT TO READ) (RECORD ONE RESPONSE ONLY)

             Correct response (STORAGE AND DISPOSAL.
               STORAGE: Flip down spout to close. NO
               NEED TO DISCONNECT TRIGGER SPRAYER.
               Close nozzle on trigger sprayer. Snap sprayer back
               in place.  Keep from freezing. Keep pesticide in
               original container. Do not put concentrate or dilute
               into food or drink containers. Avoid contamination
               of feed and foodstuffs. Store in a cool, dry place,
               preferably in a locked storage area.)	1
                    Incorrect response	2

                    Could not find	3
                    DK/Refused,
8.
Next, please find the area that gives you information on how to dispose of the packaging of the product and read
to me from that section.  (WAIT FOR RESPONDENT TO READ) (RECORD ONE RESPONSE ONLY)

              Correct response (DISPOSAL. PRODUCT -
                Partially filled bottle may be disposed of by
                securely wrapping original container in several
                layers of newspaper and discard in trash.
                CONTAINER - Do not reuse empty container.
                Wrap container and put in trash.)	1
9a.
              Incorrect response	2

              Could not find	3

              DK/Refused	_....,.	4


Now can you find the place that gives you information on what to do in an emergency or in case of accident and
read to me from that section.  (WAIT FOR RESPONDENT TO READ)  (RECORD ONE RESPONSE ONLY)

              Correct response (FIRST AID:  If on skin, wash with
                plenty of soap and water. Note to physicians:
                Emergency information call 1-800-000-0000.)	1

              First aid	2

              Incorrect response	3

              Could not find	4

              DK/Refused	5
 9b.    Was all of the information on this label where you expected it to be? (TAKE DK AS NO)

                    Yes	1 - (SKIP TO QU. 10a)

                    No	2
                                                                                      263

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9c.     What information was not where you expected it to be?  (RECORD VERBATIM) (CLARIFY VAGUE
       RESPONSES)

                                      TYPE DIRECTLY INTO CRT
10a.   Now please look at the section on the back of the label titled "Directions for use". Are there any WORDS or
       PHRASES in this section that could be CONFUSING or DIFFICULT to understand?

                    Yes	1

                    No	2 - (SKIP TO QU. 11a)

                    DK/Refused	3 - (SKIP TO QU. 11a)


10b.   V\Aiat WORDS or PHRASES are those?  (DO NOT READ LIST) (ACCEPT MULTIPLES)

                    It is a violation of federal law to use this product in a
                      manner inconsistent with its labeling	1

                    Use strictly in accordance with label precautionary
                      statements and directions	2


                    Coarse spray	3

                    Other (Specify): 	4

                    DK/Refused	5


 11 a.   Now please go to the section on the back of the label titled "Storage and Disposal". Are there any WORDS or
       PHRASES in this section that could be CONFUSING or DIFFICULT to understand?

                    Yes	1

                     No	2-(SKIP TO QU. 12a)

                     DK/Refused	3 - (SKIP TO QU. 12a)


 11 b.   What words or phrases are those?  (RECORD VERBATIM)

                                      TYPE DIRECTLY INTO CRT


 12a.    Now please look at the section on the back of the label titled "Precautionary Statements".  Are there any words or
        phrases in this section that could be confusing or difficult to understand?  (DO NOT READ LIST) (ACCEPT ONE
        RESPONSE ONLY)

                     Yes	1

                     No	2-(SKIP TO QU. 13a)

                     DK/Refused	3- (SKIP TO QU. 13a)
     264
34958-3

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12b.   What words or phrases are those? (DO NOT READ LIST) (ACCEPT MULTIPLES)
                   Hazards to humans and domestic animals	1
                   Other (Specify): 	;	2
                   DK/Refused	3

13a.   Please look at the section labeled environmental hazards. Are there any WORDS or PHRASES in this section
      that could be CONFUSING or DIFFICULT to understand? (DO NOT READ LIST) (ACCEPT ONE RESPONSE
      ONLY)
                   Yes	1
                   No	2-(SKIP TO NOTE BEFORE QU.14a)
                   DK/Refused	3 - (SKIP TO NOTE BEFORE QU. 14a)

13b.  What words or phrases are those? (DO NOT READ LIST) (ACCEPT MULTIPLES)

                   This product is toxic to aquatic invertebrates	1
                   Drift or runoff may adversely affect aquatic invertebrates
                      and nontarget plants	2
                   Do not contaminate water when disposing of
                      equipment washwaters	3
                   Other (Specify):	4
                    DK/Refused	~	5

 Now I'm going to read you some words or phrases from this label.  For each one, please tell me what it means to you.

 (NOTE:      IF CODE 1 NOT MENTIONED IN QUESTION 10b ASK. QUESTION 14a.  OTHERWISE, SKIP TO NOTE
             BEFORE QUESTION 14b)

 14a.   Under directions for use, what does "It is a violation of federal law to use this product in a manner inconsistent
       with its labeling", mean to you? (RECORD VERBATIM) (CLARIFY VAGUE RESPONSES)
                                     TYPE DIRECTLY INTO CRT

 (NOTE:      IF CODE 2 NOT MENTIONED IN QUESTION 10b ASK QUESTION 14b.  OTHERWISE, SKIP TO NOTE
             BEFORE QUESTION 14c)
 14b.   Halfway through directions for use, what does "Use strictly in accordance with label precautionary statements and
        directions" mean to you? (RECORD VERBATIM) (CLARIFY VAGUE RESPONSES)
                                     TYPE DIRECTLY INTO CRT
                                                                                   265

-------
(NOTE:      IF CODE 3 NOT MENTIONED IN QUESTION 10b ASK QUESTION 14c. OTHERWISE, SKIP TO NOTE
            BEFORE QUESTION 14d)



14c.   Near the title "how to use", what does "coarse spray" mean to you? (RECORD VERBATIM) (CLARIFY VAGUE
      RESPONSES)


                                   TYPE DIRECTLY INTO CRT



(NOTE:      IF CODE 1 NOT MENTIONED IN QUESTION 12b ASK QUESTION 14d. OTHERWISE, SKIP TO NOTE
            BEFORE QUESTION 14e)
                                                                                       !'

14d.   At the beginning of the precautionary statements, what does "hazards to humans and domestic animals" mean to
      ybu? (RECORD VERBATIM) (CLARIFY VAGUE RESPONSES)


                                   TYPE DIRECTLY INTO CRT



(NOTE:      IF CODE 1 NOT MENTIONED IN QUESTION 13b ASK QUESTION 14e. OTHERWISE, SKIP TO NOTE
            BEFORE QUESTION 14f)



14e.   Lookfiear the title "environmental hazards". What does this statement, "this product is toxic to aquatic
      invertebrates" mean to you?  (READ VERBATIM) (CLARIFY VAGUE RESPONSES)

                                   TYPE DIRECTLY INTO CRT


(NOTE:      IF CODE 2 NOT MENTIONED IN QUESTION 13b ASK QUESTION 14f. OTHERWISE, SKIP TO NOTE
            BEFORE QUESTION 14g)


14f.   Still looking in the "environmental hazards" section tell me what "drift or runoff may adversely affect aquatic
      invertebrates and npntarget plants" means to you? (READ VERBATIM) (CLARIFY VAGUE RESPONSES)

                                   TYPE DIRECTLY INTO CRT


(NOTE:      IF CODE 3 NOT MENTIONED IN QUESTION 13b ASK QUESTION 14g. OTHERWISE, SKIP TO
            QUESTION 14h)

14g.  At the end of the "environmental hazards" section tell me what "do not contaminate water when disposing of
      equipment washwaters" means to you? (READ VERBATIM) (CLARIFY VAGUE RESPONSES)

                                   TYPE DIRECTLY INTO CRT


14h.  Now, please look at the front of the label at where the ingredients are listed and tell me what "other ingredients"
      means to you? (READ VERBATIM) (CLARIFY VAGUE RESPONSES)

                                   TYPE DIRECTLY INTO CRT
    266
                                                                                     34958-3

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15.     Just to keep our records up-to-date, may I have your age please? (REFUSED = 98)

                    Age:	



16.     (RECORD SEX FROM VOICE):

                    Male	1

                    Female	2



Those are all of the questions I have this (MORNING/AFTERNOON/EVENING).  Sometime in the next day or so, please
open up the envelope marked  "Questionnaire" and complete and return the survey inside. Please keep the replica of the
outdoor pesticide label on hand while you are filling out the questionnaire. You will need to refer to it  Thank you for
participating.  (TERMINATE)
                                                                                        267

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                   Appendix 2-3:
Quantitative Research Mock Labels
                          269

-------

-------
                   Kills fast
                   for up to
                   6 weeks
  Fresh Scent
ACmCHSKBUBITS:
ftftttritf .
                            1.50%
 KEEP OUT OF REACH OF CHILDREN
    NETWT.11.50Z.(326g)
                                               This label is a representation
                                               of the information
                                               seen on real products, but
                                               does not accurately duplicau
                                               a real brand.
                                               271

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                                                                             KILLER} Fresh Scent
                                                    Kills fast in two ways: (1) it kills bugs fast-on contact
                                                    and (2) it keeps on killing with residual action even
                                                    after you spray, for up to 6 weeks.
                                                    DIKECTIOHSFORUSE:
                                                     it is a violation of Federal Law to use this product in a manner inconsistent with
                                                     its labeling,
                                                     FOR HOUSEHOLD USE: SHAKE WELL BEFORE EACH USE. hold container
                                                     upr^hLDonotsprayupintoair.Applytosurfacesonly.Pointsprayopeimg
                                                     toward surface to be sprayed and press button firmly. Hold about 12" from
                                                     surface being sprayed. Spray until surfaces are wet. Avoid excessive wetting ol
                                                     asphalt, Vie, rubber and plastic materials. More frequent application will be
                                                     reouired to maintain control on plywood surfaces. Repeat treatment as
                                                     necessary. ROACHES. PALMETTO KIGS, WATERBUES, CRICKETS,
                                                     SILVERFISH, AND SPIDERS: Spray directly on insects when possible.
                                                     Thoroughly spray cracks, baseboards, underneath kitchen shelves, and other
                                                     places where insects habitate.AIITS AMD EARWIGS: Spray door sills, wood
                                                     frames, outside foundations and porches. Spray directly on ant hills. FUES,
                                                     MOSQUITOES, GNATS, WASPS: Apply on screens, walls, door and
                                                     window frames, and other surfaces where insects congregate.	
                                                     STORAGE: Store awayfrom heat or open flames, in an area inaccessible to
                                                     children. DISPOSAL nis container may be recycled in the tew     ^^^
                                                     but growing number ol communities mere aerosol can
                                                     recycling is available. Before offering for recycling, empty
                                                     the can by using the product according to me label.
                                                     (DO NOT PUNCTURE!) It recycling is not available, replace
                                                     cap, wrap in several layers ol newspaper and discard in trash.

                                                     PRECAUT10HARY STATEMENTS
                                                     HAZARDS TO HUMAHS AND DOMESTIC AHIMALS:
                                                     CAUTIOH: Harmful or fatal it swallowed or absorbed through theskin. Avoid
                                                     breathing spray mist. Avoid contact with skin or clothing, wash thoroughly with
                                                     soap and water after handling. Provide adenuate ventilation of area being heated.
                                                     Do not apply to humans, pe&, plants or contaminate teed. food stuffs, dishes or
                                                     uter^. Cover and avoid spraying fish aquariums. Cover or remove exposedtood.
                                                     dishes, utensils and food handling equipment Keep out of reach of cnudren.
                                                     FIRST AID
                                                              _       _ __
                                                      IF SWALLOWED: Call doctor or Poison Control Center immediately. Gastric
                                                      lame is indicated if material was taken internally. IDo not induce vomiting).
                                                      IFffiEYES: Flush with plenty ol water. IF OH SUN: Wash promptly with soap
                                                      and water. Get medical attention if irritation persists or develops.lF INHALED:
                                                      Remove victim to fresh air. Apply artificial respiration if indicated. NOTE TO
                                                      PHYSICIAN: nis product contains a choHnesterase inhibitor. If symptoms of
                                                      cholinesterase inhibition are present, atropine is antidotiat.
                                                                                  PHYSICAL Off CHEMICAL HAZARDS:
                                                                                  FLAMMABLE, CONTENTS UNDER
                                                                                  PRESSURE. Keep amy from heat,
                                                                                  sparks, open flame or pilot lights. Do
                                                                                  not puncture or incinerate container.
                                                                                  Exposure to temperatures above 130'
                                                                                  may cause bursting.
                                                                                  Questions? Comments?
                                                                                  CaltSOO-m-4567
                                                                                  Weekdays 9-9
                                                                                  Eastern time
                                                                                  ©19XXWham
                                                                                  EPA Reg No. 0000000
                                                                                  EPAEst.No.OOOO-XX-0
                                                                                                                                         This label is a representation
                                                                                                                                         of the information
                                                                                                                                         seen on nil products, but
                                                                                                                                         does not accurately duplicate
                                                                                                                                         a real brand.
272

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                        -v^^nsthytbM^immotiwcttaidi—aW
                          I "OTHER IN6RBHENT$,.
                                         ,
NETWT22FLOZ( 1PT60Z)650ml  •;-;TOTALINSREDIEHTS
.WOW
                                                                           273

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274
                                       WHAM™ M tapes* dnwr dew, teodorins wd tetttOs houjihok) ssrhcei Cits
                                      w*bl^btin^.TOOP£llATET.raK^^.to•SW•w•S^rm^8ENEI^Cl£AHWa• Holing
                                      mob 6 to t ache fan office, tpny MM m, tlun mripe ct»in. Note A oat it nqwid fcr
                                      nrficts in tntt eonact wto hod Do *ot m on rartd wfte«. BSBlffCllOK: Sjny did
                                      icccrinj to 6«nl during Dinctioni MEOEW: Pneliin trim, Hwi jpny dnU torooghtif
                                      wstUl»r*Y.Bip«tYmHY or wtuninw growth ip()«»fi
                                            CAUSES BE HfflnATON. Do Mt fit in lyis, n ildn or cMring. A»ok) eontietiwllifiKidj.
                                     Mtfon prate. SIMM! AMD OBPOSW: San in «K ttKtutUa to ml eMdna Do not
                                     nw» mpty contiMrs. Riwt tewsNy «d fccrt n to*.
                                     Hut boali is ndi of S% pofl-cawiimr ncytM HOPE plistic.
                                     OUESMNS7 COMMUTST CiU 1-«H&5555
                                     EPARls.No5&56.EPAE3tNo.5B-XX.1,YY-lZZ-3
                                     MADE BYTOE WHAM COMPANY, IMMHi Strut
                                      Anywhm.USA. 12341 SAT1SWCT10N GUARANTIED: If you in
                                      M( Mf MSsfW, widi tte pradwt phut eiB or wiili to Iri
                                       is wby. Wtoi wriiinj, pkui nchrfi ttw br code nuinbtn
                                       Kid codt printed on this pickne.

-------

 Kills Swaaieaf
                   Weed Killer
Kills Weeds-Hot Lawn Grasses
KILLS: Dandelion, Clover, Ptoitain,
Chiciweed, (Ms, Spurge, Henbit,
EngiishD3isy,WildOnionand
ManyOiiterUstedWeeds
                020%
MCPA.c*nWt!yt>nineol"_ 02)%
OOwhgraioC ______ 99£0%
Totl	10000%
 Method 6275:016%
 MCMlCUequkalcntO.17%
KEPOVTOF REACH OFCHILDREN
CAUTION ************
NET CONTENTS 1 GAL/3.78 L
                                                                    Tin's libel is a repnstntation of tht information;
                                                                     products, tout tats not tccttntdY duplicate a n 275

-------
 jV U:

Si
         *''
                                          WedKWer
                                           Hlsbwadleafmdsinlams-rootsandall. Kills weeds, not lawn grasses whenusedacconHngto
                                           Erections. Ready-toJJse. No Mixing.

                 KJLLS:BurClover, Caipetweeds, duckweeds, Creeping Chaiie, Cudweed, CuriyDock, Dandelion, English Daisy, False Dandelion,
                 FMee.RoridaPiisley.HearaeafDiyniaiy.HeiM, Orate, Pennywort, Plantains, Purslane, RedSoml, SheepSomt, Spurges, Thistles,
                 Toadflax, meClover, WidCamt, WildGemum, Wild Onion.
                 DJRECTJONSFORUSE
                 It G a viotuxn o( Federal lav to use Ms product in a namer rcorccfent with
                 bbbdnj
                 HOW TO USE: Turn sjwyer nozzle to open. Adjust nozzle to give a cone spny.
                 Am a ca*r of ««ed and spw to weL Spray *y Ime weeds « a*rty
                 otwwB. Do irt apply wtw mi or ferapntus ow Hf n eq»cW wSwi
                 24 hours. Kri to eonW weeds nay require repeal apptabon in 2 to 3 weeks.
                 Weeds n ne«V seeded bums may be sprayed after bwn he been mowed

                 WPOROKT. Do not use Ws product fcr eatnjftig weeds in wgeSMe gsifcns,
                 low beds or mund stnbs or onamnbl ptot. tiaiipewy dBCdorafion
                 m^ occur on Si AugusGne. Oertfede, and Bertgnss bwns.
                 STORAGE AND DISPOSAL
                 STORAGE: ftp down spout to dose. NO USD
                 TODBCOHN£CTTO66EH:PRAYER.Cteenan)e
                 on timer sprays-. Srap sonyer bade in pta. Keep
                 (rem freezing. Keep pesticide in origin! container.
                 Do not put concensus or (Bute into food or drink
                 iu/tUinefs. Awid contaniiratDn o( feed and
                 tccdstuHs. Store in a cool dry place, mfenMy in a
                 kxtedstoraoearta.
                 DBPOSAlifflOOUa- PartSaBy (Bed bcffle nay He disposed of by securely
                 wrappiM onginal contarcr in several hyers of newspaper and discard in
                 tnsh. CONTAINER - Do not reuse empty container. Wrap container and put
                 ntrash.
                                                                 PRECAUTIONARY STATEMENTS
                                                                 HAZARDS TO HUMANS t DOMESTIC AMKALS
                                                                 CAUTION: HarmU i adsorbed through skin APPUfWG: When applying te
                                                                 product wear gojgte a tace shield, long pans, long staved shit socks, shoes,
                                                                 and chemical reseat gkws. Wash nondisposable gloves twoughy with soap
                                                                 andwafcr betare icnoviriBJtoiriow corttninaed doCmgand bunder
                                                                 anuatrV befue reuse, ft uiipUy and tnoi'ouoh^ wash runds and opostti ddn
                                                                 wBh soap and water rter usiig ths product Rernow sztuntad dothviQ as soon
                                                                 as possible and shower.

                                                                       Do not alow uflios such as chjdren and pete on ttttnent area
                                                                       during ippicalDn or to reentomated anas until spray has dried.

                                                                 HOT Aflhff on sto, wash waiplenlyol soap and water. Mote toPlBuiait.
                                                                 Emeroency Irtomafai caO 1-8OHXCKIOOO.

                                                                 BWBONWHDU. HAZARDS: Ths product is tax to iquatc mnttrafes. Drift
                                                                 or runoB may adveneV aflect aqufflc iwrttnte and nontaiget pMs. Do not
                                                                 appV diracay to w«r. Bouse cauton when disposing of wase as grouiowa&
                                                                 con&nwation way tesul tnxn careless handfnp, or spfis. Do not contaminztB
                                                                 wafer when olsposiio of flqupnientwashwafers.

                                                                 HOtlgBijg assumes alnaponsMly tor safely and use not in accordance
                                                                 with defections.
                                                                tfSh Metal MannHoi all 1-MO«5«55
                                                                 ^m. PndDCtWonnabnani-IOO-5554556
                                                                «*jdmortc ttltf weed Cmww
                                                                Unttandty
                                                                TheWeo) Company
                                                                lOOMinsnet
276
                                                                                                 This label is a representation of the information seen on rei
                                                                                                  pmducts. but does not accurately duplicate a real brand.
                        jiili:! ,  LI'HiiUi

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                          Appendix 2-4:
Quantitative Research Mail Questionnaires
                                    277

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-------
National Family Opinion
                                                                   P.O. Box HT-I Toledo. OH -)>S-,
                                                                 Toll-Free Number l-SOO-Sy-WT
                                                                 Mon - Fn. K.UO AM lo 11 ix> R\l F'M
                                                                 Sat it .Sun. 10.0U AM lo (i:CX) HM EST
                                                                  c-rruil addrev C3trol9nfoi.com
IMPORTANT! PLEASE READ:
PLEASE PUT ASIDE THE LABEL REPLICA YOU USED DURING THE PHONE INTERVIEW UNTIL INSTRUCTED TO
LOOK AT IT AGAIN. THE FOLLOWING QUESTIONS ARE ABOUT INFORMATION ON THE PACKAGING OF ALL
INDOOR INSECTICIDE PRODUCTS THAT ARE AVAILABLE.
WHEN ANSWERING THESE QUESTIONS, PLEASE ONLYTHINK ABOUT THE INFORMATION THAT IS ON THE
PACKAGING OF INDOOR INSECTICIDE PRODUCTS. WHEN I REFER TO INDOOR INSECTICIDE PRODUCTS I
MEAN ANT AND ROACH KILLER. BUG SPRAY, INSECT BAITS, AND FOGGERS FOR USE INSIDE YOUR HOME.
1.
2a.

2b.

2c.
      i D Extremely satisfied
      2 O Very satisfied
      3 D Somewhat satisfied
      4 D Not very satisfied
      5 D Not at all satisfied

NOW I HAVE SOME QUESTIONS ABOUT SPECIFIC INFORMATION FOUND ON THE PACKAGING OF ANY
INDOOR INSECTICIDE PRODUCTS.
In Column "A" below, please indicate how often, if ever, you read each type of information listed on the package
white you are In the store. (X ONE Box For EACH Type Of Information In Column "A")
In Column "B" below, please indicate how often, if ever, you read each type of information listed on the package just
before or while you are using the product at home. (X ONE Box For EACH Type Of Information In Column "B")
For EACH type of information you said you NEVER read at all (In Column "A" & "B"), please indicate in Column
"C" all the reasons that you NEVER read that type of information.  (X ALL That Apply In Column "C" For EACH
Type Of Information You NEVER Read)
Brand name 	
Name of manufacturer 	
Phone number for information 	
Directions on how to use the produc
Description of what product does 	
Information about where the product
should not be used 	
"A"
Frequency
Of Reading
In Store
ft
• O d
• d d
dC
• d C
. ,n d
Information about effects on personal
and children's health or safety 	 d C
Information about effects on
pets, wildlife or water 	 Q »n
Product contents or ingredients 	 d d
Information on how to store product.. Q d
Information on how to dispose
of product packaging 	 i[3 sQ
Information on what to do in an
emergency or in case ol accident Q d
Statement that the product contains
no CFC's 	 ifj C

First Time Only
d
d
d
d
d
d
d
d
d
|
d
d
d
d
d
d
d
d
d
d
d
d
d
"B"
frequency ot
Reading Just
Before Or
While Using
Every Time
j
First Time Only
1
dddd
O d d d
dddd
dddd
dddd
dddd
dddd
dddd
dddd
dddd
dddd
dddd
'Dddd
1
-C"
Reasons Why Never
Read (In Store And Just
Before/Wh te Usina)
I Just Don't
d
d
O
O
d
O
jl!
d
d
d
d
d
d
d
d
d
d
It Is Information
1 Already Know
d
d
d
d
d
d
d
•d
d
d
d
d
d
It Is Information
1 Don't Need To
Know
d
d
d
d
d
d
d
d
d
d
d
d
1 Don't Have
Time
d
d
d
d
d
d
d
d
d
d
d
d
The Print
Is Too Small
d
d
d
d
d
d
d
d
d
d
d
d
27!

-------
                                                                                                            . products. In
                          ouiiuiiue iu UIIIIK ouuui me types 01 inrormauon rouna on tne packaging ot mooor »lo=~"r'~rol,nost important to
                          Column "A", read each type of information listed, and then please ?X" the four types that are mosi imponam TO
                          you. (X Four Boxes In Column "A")                                                      ...     .
                          Now, in Column "B", indicate the four types of information found on the packaging of indoor insecticide proaucis
                          that are least important to you. (X Four Boxes In Column "B")
                          In Column "C", indicate the four types of information you want to be able to find most easily on the packaging of an indoor
                          insecticide products when you are shopping for an indoor insecticide product. (X UpTo FOUR Boxes In Column C )
                                                            Four Most
                                                            Important
Brand name [[[ °O
Name of manufacturer [[[ o€D
Phone number for information ..... [[[ oQ
Directions on how to use the product [[[ «O
Description of what product does .................................................. . ......... osQ
Information about where the product should not be used ....................... «n
Information about effects on personal and children's health or safety .... o?Q
Information about effects on pets, wildlife or water .............................. ...«Q
Product contents or ingredients [[[ «O
Information on how to store product [[[ «O
Information on how to dispose of product packaging .............................. "D
Information on what to do in an emergency or in case of accident ......... «£]
Statement that product contains no CFC's ............................................. P
                    >D

                    'D
                    4C.
   When shopping for or using an indoor insecticide product, do you look for information about the
   ingredients?    , n Yes -»(Continue)    2 Q No -»(Skip To Qu. 4c)
   Why do you took for information about ingredients? (X ALL That Apply)
I'm looking for the name of a specific ingredient
I want to know the scientific names of the ingredients
I want to compare different products
I or another household member want to avoid using certain chemicals because of allergies or other health related reasons

   If an indoor pesticide label were to provide you with additional information about ingredients, which of the following
   would you prefer? (X ONE Box)
280
                                  NOTE: These lists represent what might be on an actual label in the ingredient section. On a real label.
                                             'X's'would be;
                   . ...          actual numb	

          '    Active Ingredients:  Permethrin (3-Phenoxypheny)methy(+/-)cis-trans-3-
                (2,2 dichroroethenyl) 2,2-dimethylcyclopropanecarboxyfate	0.20%
              2-(1 -Methytethoxy) phenol methytearbamate	0.50/6
              Pyrethrins	0.35%
              Piperonyl butoxide technical	°-50 /0
              Other Ingredients:
              Water......	.,	.-.	xx-x%
              Butane/Propane (4/1)	xx.x%
              Petroleum Distillate (aliphatic hydrocarbon)	x.x%
              Polyoxyethylene sorbitan monooleate	x-*»
              Sorbitan monooteate	XJ"»
              Perfume	•	«•«%
              Sodium Benzoate	•*-j!'r
              TOTAL                  	100%
          »n OPTION^"	
              Active Ingredients: Permethrin (3-Phenoxypheny)methy(+/-)cis-trans-3-
                (2,2 dicTiloroethenyl) 2.2-dimethyteyclopropanecarboxylate	2'|5%
              2-(l -Methytethoxy) phenol methytearbamate	0.50%
              Pyrethrins	nino/
              Piperonyl butoxide technical	v;2-52%
              Other Ingredients  	98.45%
              Other ingredients are: Water, Butane/Propane (spray propellent), petroleum-based solvent (to
                dissolve active ingredients), emulsifiers (to keep product from separating), perfume, corrosion
                inhibitor (stop can from rusting)
              TOTAL	100%
          3 n OPTION 3	
              Active Ingredients:  Permethrin (3-Phenoxypheny)methy(+/-)cis-trans-3-
                (2.2 dichloroethenyl) 2,2-
                dimethylcyclopropanecarboxyiate
              2-(1 -Metriytethoxy) phenol methylearbamate.
              Pyrethrins•	0.35%
              Piperonyl butoxide technical
              Other Ingredients
              TOTAL..."

          '   Active Ingredients: Permethrin (3-Phenoxypheny)methy(+/-)cis-trans-3-

-------
4d.
4f.
If you need to get additional information about product ingredients beyond that already found on the product
packaging, where do you prefer to get this information? (X ALL That Apply)
       1 n I do not need additional information
       2 Q Through the manufacturer by mail or by phone
       3 D From an 80° telephone number
       4 n From the product packaging
       s n On tne Internet/Web
       e Q Poison Control Center
       7 Q In a product brochure
       a D Prom a government agency
        D Other (Specify):	

When you are in the store shopping for an indoor pesticide product, do you look for information on the product
packaging to determine the possible harmful effects of the product?
              1 n Yes
              2Q No-
               •»(Continue)
               . (SkipToQu. 5)
       What information on the product packaging do you use to determine the possible harmful effects of the product?
       (Please Be As Specific As Possible)
       When deciding which indoor insecticide product to purchase, which of the following types of information, if any do
       you look for?  (X ALL That Apply)
            , 01 n Container or packaging characteristics (such as made of recycled plastic, recyclable, etc.)
             02 D Product characteristics such as non-staining, non-corrosive, won't scratch surface, low odor, etc.
             03 n Water-based
             04 D No CFC's
             os n Botanical (if product is derived from plant extracts)
             oe D Non-flammable (gas/liquid, etc.)
             or O Low potential for harming plants
             M n Will not harm pets or fish
             o» G Packaging allows for reduced contact with the product
             10 D None of the above

       What level of risk or personal hazard, if any, do you associate with an indoor insecticide product that has the
       following words on the label? Use a scale from 1 to 5 where "1" means no risk and "5" means a high risk. (X ONE
       Box For EACH Word)
              Risk/Personal Hazard Associated With ...
              The word "Caution"
              The word "Danger"
              The word "Warning"	
              A label where none of these words are required
                                                      No Risk
                                                          1      2
                                                     	O    G
                                                     	G    G
                                                               G

3
G
G
G
G

4
G
G
G
G
High Don't
Risk Know
5 6
G G
G G
G G
G G
7.     Besides the packaging, where else do you get information about indoor insecticide products you use?
       (X ALL That Apply)
     01 D Store display
     oz O Store salesperson
     os Q Product manufacturer (800#)
     04 n Friend/family member/co-worker
     os D Newspaper ad
    . M Q Magazine ad
     07 n TV ad
     09 D TV infomercial
     09 n "How-to" TV program or video
     10 n TV News story
     11 Q Newspaper or magazine story
     » D Product brochure
     n n Poison Control Center
 » n University or county extension service
 » n Library
 « Q Environmental group
 17 Q Consumer group
 11 Q City government agency
• it Q County government agency
 » Q State government agency
      Federal government agency
      Consumer Reports
     \ Yellow Pages
     I Fire department
     ! Internet website
     I Other (Specify):
                                                     2,
                                                     a
                                                      > D Do not get additional information
         Some products show selected information in the same way and place on the packaging.  If indoor insecticides
         were to do this, which of the following ways, If any, would you most like to see the information shown?
         (X ONE Box)
               i Q Does not make a difference to me
               2 D Would not change the current format
               3 n A format with phrases and standard headings to highlight key facts
               4 Q A box format, like the nutrition facts box found on food packages, that presents information consistent!1
                     among indoor insecticide products
               5 Q None of the above.
                                                                                         281

-------
           Ul
          2
          CD
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Ul
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              Q
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-------
to Listed below are several statements that may appear on the packaging of an indoor insecticide product. For each
pair, "X" the box next to the statement you prefer. (X ONE Statement For EACH Pair)
Prefer Pf*!er
This e This
Segment Statement
, fj 	 "Repeat as needed" - OR - "Apply no more than X treatments
iwrweek" 	 i f~l

'D
• D
'D
'D
'D
iD
-D
'D
'D

	 "Do not allow children or pets
to contact treated areas"
	 "For safe and effective
use, read the label first"
	 "Hazards to humans and animals"
	 "Environmental hazards"
	 "Avoid contact with eyes"
	 "Allow X hours before re-entering
treated rooms."
	 "Use only in well-ventilated area."
	 "Do not spray directly over food
or utensils."
	 "Can be absorbed dermally"

-OR-
-OR-
-OR-
-OR-
-OR-
-OR-
-OR-
-OR-
-OR-

"Keep children or pets out
of treated areas for X minutes" 	

"Use only as directed on this label" 	

"Human and animal effects" 	

"Environmental effects" 	

"Protect your eyes during application
Wear safety glasses." 	

"Oo not re-enter for X hours after
application." 	

"Open windows before use to provide
free flow of air." 	 ,

"Do not apply where spray may settle
onto food or utensils." 	

"Can be absorbed through skin." 	


.... 3 n

. 2 n

2 n

a Fl
*— '
.... a D

.... 2 n







11.    Please indicate how much you agree or disagree with each of the following statements. (X ONE Box For EACH

       Statement)                                                         Neither
                                                    Agree    _ Agree    Agree Nor  JMsagree    Disagree
                                                 Completely Somewhat  Disagree  Somewhat
The level of the possible harmful effects of a product plays
   an important role in deciding which product I purchase .
I don't worry about chemicals in indoor insecticide products d
Manufacturers make sure the products they sen are safe to use.. 
-------
                                                                      d
Question 11 Continued                                                    Neither
                                                  Agree      Agree    Agree Nor  Disagree   Disagree
                                                Completely Somewhat  Disagree   Somewhat  Completely

Environmentally friendly or natural products often don't
  work as well as other products	
I don't have to worry about where I store a product
  that is in a child-resistant package	
I would like information on long term health effects to
  be included on indoor insecticide products	
Labels should say whether the product should not be
  used by or around pregnant women	d
Overall, I am satisfied with the type of information
  on indoor insecticide products	d
I need more information about how much or how long to
  apply a product to get rid of insects in my home	d
It is important to know the minimum amount of time required
  before I can safely reapply an insecticide product	d
"Repeat as necessary" means I should apply the insecticide
  as soon as insects appear	d
d

d

d

d

d

d

d

d
                                                                                            3D



                                                                                            3D
d



3D


3D


3D
                                                                                                       d
                                                                                                      d
 d



 d

 •D

d

d
  NOW, I'D LIKE YOU TO REFER TO THE REPLICA OFTHE LABEL I SENT YOU. PLEASE USE THAT LABELTO
  ANSWER QUESTIONS 12a - 12e.

       Please look at the part on the front of the label titled 'Active Ingredients", and a bit further down, "Other
       mgredients"  Listed below are some statements that could describe this part of the label. In Column "A  please
       indicate•whether you agree, neither agree nor disagree, or disagree that each statement descnbes this part of the
       label. (X ONE Box For EACH Statement In Column "A")
       Now olease took at the part on the back of the label titled "Directions For Use". The statements listed below could
       describe this part of the package. In Column "B". please indicate whether you agree, neither agree nor disagree, or
       dj^gret that each statement describes this part oTthe label. (X ONE Box For EACH Statement In Column "B")
       Now oo to the part of the label titled "Storage", and a bit further down. "Disposal". In Column "C". please indicate
       whether you agree neither agree nor disagree, or disagree that each statement descnbes this part of the label.
       (X ONE Box For EACH Statement In Column "C")
                  t2h
                  12c

                         (X ONE
                  12d   Next please took at the part of the label titled "Precautionary Statements". Again, in Column "D", please indicate
                                                                                                       i   art of the label.
                   12e.
        Next Please took at Hie pan OT uie laoei miea rrecauiiunary ouiieiiroiiia . nyai	wwm.ii.i  ^ ,K.w-— ..._.__
        whetheryou agree, neither agree nor disagree, or disagree that each statement descnbes this part of the label.
        (X ONE Box For EACH Statement In Column "D")
        Finally refer to the part of the label indicated by the title "First Aid". In Column c  , jjioa»o KHJIMIV
        agree neither agree nor disagree, or disagree that each statement describes this part of the laoei.
        For EACH Statement In Column "E")
The words in this section could be
confusing or difficult to understand ...
The title of this section helps me
understand what type of information
"A"
Active & Other
Ingredients
<*
....C
,r
This section contains just the right
The Information in this section is not
specific enough (i.e., is too vague) 	 i£Z
Even after reading this section, I am
not sure I would know how to
follow these instructions 	
Neither Agree
Nor Disagree |
d
d
d
I d
i
O)
•
in
5
d
d
d
d
"B"
Directions
For Use
1
d
d
d
d
>n
Neither Agree
Nor Disagree
d
d
d
d
d
Disagree
d
d
d
d
=n
. "C"
Storage &
Disposal
0
1,
<
d
d
d
d
d
Neither Agree
Nor Disagree
d
d
d
d
d
1
s
5
d
d
d
d
d
Precautionary
Statements
<"
Neither Agree
Nor Disagree
d d
d d
d d
d d
0 d
f
5
d
d
d
d
d
"E"
First
Aid
B
i
P either Agree
or Disagree
d d
d d
d d
d d
d d
I
£
5
d
d
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O
                                                                                                      * Of Packages Used
                                                                                                        Part 12 Months
284
  13a.   Which, if any, of the following indoor insecticide products have you, yourself, purchased in the past 12 months?
        (X ALL That Apply In Column "A")
  13b.   Which, H any, of the following indoor insecticide products have you, yourself. uSfid in the past 12 months?
        (X ALL That Apply In Column "B")
  13c.   How many packages of indoor insecticide products have you used in the past 12 months? Please count a
        package containing several baits or foggars as one package. (Write In ONE Number For EACH In
        Column "C")                                                       -B>.             ..„..

                                                       Purchased        Used Past
                                                     Pa«t 12 Months      12 Months

                Flying insect spray	'D               'D           	
                Ant and roach spray	d               d           	
                Ant and roach baits	 d               d           	
                Indoor loggers	«D               CD           	
                Ant and roach powder	d               d           	

  13d.   How often do you, yourself, apply any of the above indoor insecticide products during the time when insects are a
         problem? (X ONE Box)
               1 D Once a day or more often
               2 n Once every 2-3 days
               3 n Once a week
               4 Q Once every 2-3 weeks
               i Q Once a month
               • rjj Once every few months              _                                          34958-2b

-------
14*.   Have you, yourself, had an accident with an indoor insecticide product in the past 12 months?
             i n Yes -• (Continue)
             sDNo-»(SkipToOu.15)

14b.   Please describe the accident you had with the indoor insecticide product. (Write In Below, Please Be As
       Specif ic As Possible)
15.    Please describe how you currently dispose of indoor insecticide products when you are done using them? (Write
       In Below, Please Be As Specific As Possible)
16.    Are there any other general comments on label information that you would like to make? (Write In Below, Please
       Be As Specific As Possible)
                    Thank you for your help with this study. Please return your completed
                  questionnaire in the enclosed postage-paid envelope as soon as possible.
                                                                                         285

-------
                   National Family Opinion
                                                                  P.O. Box 474 Toledo.
                                                                Toll-Free Number: 1-80O-537-409-
                                                                Mon - Fri. 8:00 AM to 11:00 PM EST
                                                                Sat & Sun. 10:00 AM to 6:00 PM EST
                                                                  e-mail address: carolCnfoi.com
                    2a.
                    2b.
                    2c.
IMPORTANT! PLEASE READ:
PLEASE PUTTHE LABEL REPLICA YOU USED DURING THE PHONE INTERVIEW ASIDE UNTIL
INSTRUCTED TO LOOK AT IT AGAIN. THE FOLLOWING QUESTIONS ARE ABOUT INFORMATION ON THE
PACKAGING OF ALL HOUSEHOLD CLEANER PRODUCTS THAT ARE AVAILABLE.

WHEN ANSWERING THESE QUESTIONS, PLEASE ONLY THINK ABOUT THE INFORMATION THAT IS ON
THE PACKAGING OF HOUSEHOLD CLEANER PRODUCTS. WHEN I REFER TO HOUSEHOLD CLEANER
PRODUCTS, I MEAN ALL PURPOSE CLEANERS,TOILET BOWL CLEANERS, BATHROOM CLEANERS AND
MOLD AND MILDEW REMOVERS.

Please indicate how satisfied you are OVERALL with the information currently available on the packaging of
household cleaner products. (X ONE Box)
      i D Extremely satisfied
      x D Very satisfied
      3 D Somewhat satisfied
      «D Not very satisfied
      5 D Not at all satisfied
NOW I HAVE SOME QUESTIONS ABOUT SPECIRC INFORMATION FOUND ON THE PACKAGING OF ANY
HOUSEHOLD CLEANER PRODUCTS.
In Column "A" below, please indicate how often, if ever, you read each type or information listed on me package
While'you are in the store. (X ONE Box For EACH Type Of Information In Column "A")

In Column "B" below, please indicate how often, H ever, you read each type of information listed on the package
just before or while you are using the product at home. (X ONE Box For EACH Type Of Information In
Column "B")
For EACH type of information you said you NEVER read at all (in Column "A" and "B"), please indicate in
Column "C" all the reasons that you NEVER read that type of information. (X ALL That Apply In Column "C"
For EACH Type Of Information You NEVER Read)
286








"A"




Frequency
Of Reading


I
UJ

Name of manufacturer 	 d
Phone number for information 	 d
Directions on how to use the product d
Description of what product does — d
Information about where the product
should not be used 	 d
Information about effects on personal
and children's health or safety . — iG
Product contents or ingredients 	 iQ
Information on how to store product.. C
Information on how to dispose
of product packaging .... . . il I
Information on what to do in an
emergency or in case of accident C
In Store

J
•
8
o
d
*^^
d
d
d
d
d

d
d
d

ap~!

d
Statement that the product contains
no Dhosohates 	 iD. id
.£•
O
|
^
•3
EC
aT]
*^_l
d
d
d
d

d
d
d

J~~J

d
>n



|
j— i
d
d
d
d
d

d
d
d

«n
^LiJ
d
d
•B"
frequency 01
Reading Just
Before Or
While Using

1
1

d
d
d
d
d

d
d
d

d

d
d

J
3
8
d
2?
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dd


|
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ddd
ddd
dd

d

>n

d

d

ddd
«C
C
d
-C"





Reasons Why Never
Read (In Store And Just
Before/While Using)

I !|1!
1 ||i|||
d d
d d
d d
d d
d d
d d

d d
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                                                                                                        34958-30

-------
3a.
3c.
 3d.
Please continue to think about the types of information found on the packaging of household cleaner products.  In
Column "A" below, read each type of information listed, and then please *X* the four types that are most
important to you. (X Pour Boxes In Column "A")
How, in Column "B", please indicate the four types of information found on the packaging of household cleaner
products that are least important to you.  (X Four Boxes In Column "B")
In Column "C", please indicate the four types of information you want to be able to find most easily on the packaging
of a household cleaner when you are shopping for a household cleaner.  (X Up To FOUR Boxes In Column "C")
                                                               "A"           «
-------
                       4d.    H you need to get additional information about product ingredients beyond that already found on the product
                              packaging, where do you prefer to get this information? (X ALL That Apply)
                            i D I d° not need additional information                      6 fj Poison Control Center
                            : P Through the manufacturer by mail or by phone             ? Q In a product brochure
                            a n From an BOO telephone number                         , Q From a government agency
                            4 n From the product packaging                              r-i otner (Specify):	
                            s D On the Internet/Web •
                       4e.
                       4f.
       When you are in the store shopping for a household cleaner product, do you look for information on the product
       packaging to determine the possible harmful effects of the product?
                                        Yes
                       • (Continue)                      s Q No -• (Skip To Qu. 5)

       (MMMBcAsS °" We As^pSsl^ef9'"9 d° V°U "^  D Oo not get additional
       information
                              Some products show selected information in the same way and place on the packaging. If household cleaners
                              were to do this, which of the following ways, if any, would you most like to see the information shown? (X ONE
                              Box)
                                    i D  Does not make a difference to me
                                    3 n  Would not change the current format
                                    s D  A format with sentences and headings to highlight key items
                                    4 D  A box format, like the nutrition facts box found on food packages, that presents information
                                          consistently among household cleaner products
                                    s O  None of the above
288
                                                                                                                      34958-3*

-------
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-------
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IM nisi ntmMiittV Not nconiiMnded for uu on wood for
pined uriicu. test» smil vci fast GENERAL CIEANING
Add 1/4 ci9 per giHan of wiur Usuilty no rinsing niqurcd
WARNMG ETE HXnUIT Da not get in eyes For tenwve
li«i or tnjtongtd uu. weir gloves MST AID ETES •
toiiinJunty MM wife mur lor IS wMtes H mutwn
peisoo. Ml e pnyliciln ff SWAllOWEO • Dmk i gtosful of
witcr Clll i olwcan CEP OUT OF UACM OF CNHDREN
CONIAWS: He«mie ttt MMK  ortictMO.  clw*B|
               Mkmrrtt. teaw  n >>«e«tinii
                                     :  TO
          ~-   OtSfOSt  Uu uo. gn «w>v or (xx-
          I;   unused prodrcl down dnm end Hush
    • {tSgH?   wmwmr


               UM BvIH£"wniircOMMNttnrmn.
              Package #T31
                             I  These labels are a representation ot the information seen on real products but do not accurately duplicate a real brand.
290
                                        34958-3*

-------
lOa.   Please refer to the previous page of pictures and tell me which of these two product packages has the type of
       information you prefer overall? (X ONE Box)

              i n Package #R24
              2 n Package #T31
              3 Q No preference

10b.   Now for each type of information listed below, please tell me whether you prefer Package #R24, Package #T31. or
       whether you have no preference. (X ONE Box For EACH Type Of Information)

                                                              Prefer           Prefer              No
                                                          Piiekage »R24     Package 
-------
                      Question 12 Continued
                                                                                         \                           1
                                                                                              Neither
                                                                        Agree      Agree    Agree Nor  Disagree   Disagree
                                                                     Completely Somewhat  Disagree  Somewhat Completely
                      I know which product containers to recycle so I do not
                        need to look on the label	ifj        $3         CD         Q         €3
                      I've noticed the instructions on the label for throwing
                        away a product or its container don't agree with what
                        my community tells me to do	ifj        2n.         3n.         n
"C"
Storage &
Disposal
1
CD
O
CD
CD
in
Neither Agree
Nor Disagree
CD
CD
CD
CD
»n
B
5
CD
CD
CD
CD
in
"D"
Precautionary
Statements
1
0
-D
O
0
in
Neither Agree
Nor Disagree
CD
CD
CD
CD
sn
I
O)
o
CD
CD
CD
CD
in
"E"
First Aid
Agree
Neither Agree
Nor Disagree
CD CD
CD CD
CD CD
CD CD
in *n
I
a>
s
Q
CD
CD
CD
CD
>n
292
                                                                                                                   34958-3a

-------
14a.   Which, if any, of the following household cleaner products have you, yourself, used in the past 12 months?
       (X ALL That Apply In Column "A")

14b.   Which, if any, of the following household cleaner products have you, yourself, purchased in the past 12 months?
       (X ALL That Apply In Column "B")
                                                   "A"                   "B"
                                                Used Past             Purchased
                                                12 Months           Past 12 Months
              All purpose cleaner	iQ                   tfj
              Toilet bowl cleaner	jQ                   2fj
              Bathroom cleaner	sQ                   sQ
              Mold and mildew remover	4Q                   4Q

15a.   Have you, yourself, had an accident with an household cleaner product in the past 12 months?

             1 D Yes -»(Continue)
             z D No-*(SkipTo Qu. 16)

15b.   Please describe the accident you had with the household cleaner product. (Write in Below, Please Be As
       Specific As Possible)
16.    Please describe how you currently dispose of household cleaner products when you are done using them?
       (Write In Below, Please Be As Specific As Possible)
17.    Are there any other general comments on label information that you would like to make? (Write In Below, Please
       Be As Specific As Possible)
                    Thank you for your help with this study. Please return your completed
                  questionnaire in the enclosed postage-paid envelope as soon as possible.
                                                                                      293

-------
                  National Family Opinion
   RO. Box 47-1 Toledo. OH -iJftVi
 Toll-Free Number: 1-80O-537-409"
 Mon - Fri. H:00 AM 10 11:00 FM F.ST
Sat & Sun. 10:00 AM In 6:00 PM F.ST
  e-nuil address carolCn/oLcom
                   IMPORTANT! PLEASE READ:
                   PLEASE PUTTHE LABEL REPLICA YOU USED DURING THE PHONE INTERVIEW ASIDE UNTIL INSTRUCTED TO
                   LOOKATITAGAIN^HEFOLLWINGQ^                                    PACKAGING OF ALL
                   OUTDOOR PESTICIDE PRODUCTS THAT ARE AVAILABLE.
                   WHEN ANSWERING THESE QUESTIONS, PLEASE ONLYTHINK ABOUTTHE INFORMATION THAT IS ON THE
                   PACKAGING OF OUTDOOR PESTICIDE PRODUCTS. WHEN I REFER TO OUTDOOR PESTICIDE PRODUCTS, I
                   MEAN PRODUCTS SUCH AS SPRAYS, BAITS, POWDERS OR INDOOR FOGGERS.
                   1.     Please indicate how satisfied you are OVER ALL with the information currently available on the packaging of
                         outdoor pesticide products. (X ONE Box)
                               i D Extremely satisfied
                               zn Very satisfied
                               i D Somewhat satisfied
                               4Q Not very satisfied
                               s D N°tat a" satisfied

                          NOW I HAVE SOME QUESTIONS ABOUT SPECIFIC INFORMATION FOUND ON THE PACKAGING OF ANY
                          OUTDOOR PESTICIDE PRODUCTS.
                   2a.    In Column "A" below, please indicate how often, if ever, you read each type of information listed on the package
                          while you are in the store. (X ONE Box For EACH Type Of Information In Column "A")
                   2b.    In Column "B" below, please indicate how often, if ever, you read each type of information listed on the package
                          just before or while you are using the product. (X ONE Box For EACH Type Of Information In Column "B")
                   2c.    For EACH type of information you said you NEVER read at all (In Column "A" Arid "B"), please indicate in
                          Column "C" all the reasons that you NEVER read that type of information. (X ALL That Apply In Column "C"
                                                             ~   "
294
For EACH Type Of Informs
Ion You NEVER Read)


A"

Frequency
Of Reading
m Store
Every Time
in

Phone number for information 	 C
Directions on how to use the product t£
Description of what product does 	 id
Information about where the product
should not be used 	 d
Information about effects on personal
and children's health or safety 	 C
Information about effects on
Product contents or ingredients 	 C
Information on how to store product.. C
Information on how to dispose
of product packaging 	 i£
Information on what to do in an
emergency or in case of accident C
Statements that the product
fe water-based 	 iP


Occasionally .
First Time Only
d d
dd
dd
dd
dd
dd
dd
dd
dd
dd
)dd
)dd
|
d
d
d
d
d
d
d
d
d
d
d
d
d


B"

Frequency of
Reading Just
Before Or
While Using
Every Time
Occasionally
First Time Only
!
dddd
dddd
dddd
dddd
dddd
dddd
dddd
dddd
dddd
dddd
dddd
dddd
dddd
1
-C"
Reasons Why Never
Read (In Store And Just
Before/While Usino)
1 Just Don't
d
d
d
d
d
d
d
d
d
d
d
d
d
1 Don't
Understand What
The Information/
Language Means
d
d
d
d
d
d .
d
d
d
d
d
d
d
— 2
d
d
d
d
d
d
d
d
d
d
d
d
d
c e
d
d
d
d
d
d
d
d
d
d
d
d
d
I Don't Have
Time
d
d
d
d
d
d
d
d
d
d
d
i]

d
d
d
d
d
d
d
d
d
d
d
d
d
34958-4b

-------
 3a.
3b.
3c.
3d.
 Please continue to think about the types of information found on the packaging of outdoor pesticide products. In
 Column "A" below, read each type of information listed, and then please "X" the tour types that are most
 important to you.  (X Four Boxes In Column "A")
 Now, in Column "B". please indicate the four types of information found on the packaging of outdoor pesticide
 products that are least important to you.  (X  Four Boxes In Column "B")
 In Column "C", please indicate the four types of information you want to be able to find most easily on the
 packaging of an outdoor pesticide product when you are shopping for an outdoor pesticide product. (X Up To
 FOUR Boxes In Column "C")
                                                                "A"           "B"          "C"
                                                                                       Four Types Of
                                                                                        Information
                                                                           Four Least Want To Find
                                                                            Important   Most Easily
                                                               . 4'Dichlorophenoxvacetic acid, dimethylamine salt)	'.	0.20%
                MCPA i2-(2-Methyl-4-chlorophenoxy) proprionic acid, dimethylamine salt]	0.20%
                Other Ingredients:
                Solvents (including water)	                              xx x%
                Surfactants	                       	xx'x%
                Stabilizers	       	 x'x%
                Preservative	™.™!!™"™	x'x%
                Corrosion inhibitor	!.™!".'"™™™!!"™	!."!!!.'."!!!]"!.'x!x%

-------
                     4d.
                     4f.
If you need to get additional information about product ingredients beyond that already found on the product
packaging, where do you prefer to get this information? (X ONE Box)
       i n I do not need additional information
       2 fj Through the manufacturer by mail or by phone
       3 D From a" 800 telephone number
       4 Q From the product packaging
       s D On the Internet/Web
       e D Poison Control Center
       7 Q In a product brochure
       e D From a government agency
        n Other (Specify):	
When you are in the store shopping for an outdoor pesticide product do you look for information on the product
packaging to determine the possible harmful effects of the product?
       i D Yes -«(Continue)
       zQ No-»(SkipToQu.5)
What information on the product packaging do you use to determine the possible harmful effects of the product?
(Please Be As Specific As Possible)
                     S.
                      7.
When deciding which outdoor pesticide product to purchase, which of the following types of information, if any, do
you look for? (X ALL That Apply)
      01 D Container or packaging characteristics (such as made of recycled plastic, recyclable, etc.)
      02 O Water-based
      03 D No CFC's
      04 O No phosphates
      os D Biological, or plant pesticide
      x D Botanical (if product is derived from plant extracts)
      07 Q Non-flammable (gas/liquid, etc.)
      ot O Low toxicity to insects or non-target-organisms
      o> D "use of (this material) will reduce drift"
      10 D  Low potential for contaminating ground water
      11 Q  Low potential for leaching
      w D  Low potential for harming plants
      n D  Will not harm fish or wildlife
      M Q  Packaging allows for reduced contact with the product
      is Q  None of the above
 What level of risk or personal hazard, if any, do you associate with an outdoor pesticide product that has the
 following words on the label?  Use a scale from 1 to 5 where *1' means no risk and *5* means a high risk.
 (X ONE Box For EACH Word)
Risk/Personal Hazard Associated With ...
The word 'Caution' [[[ d
The word 'Danger [[[ ••••  Q Magazine ad
                         07 D TV ad
                         e> D TV inJomercial
                         e* D "How-to" TV program or video
                                      TV News story
n O Newspaper or magazine story  » C
n Q Product brochure             n C
» D Poison Control Center        a C
» Q University or county extension  » C
      service                      ~~
is D Library
it D Environmental group
17 Q Consumer group
u D City government agency
                                w D County government agency
                                  "
                                                                      State government agency
                                                                      Federal government agency
                                                                      Consumer Reports
                                                                      Yellow Pages
                                                                      Fire department
                                                                      Internet website
                                                                      Other (Specify):
                                                                      D° not get additional Information
                              Some products show selected information in the same way and place on the packaging, if outdoor pesticides
                              were to do this  which of the following ways, if any, would you most like to see the information shown? (X ON
                              Box)
                                    i D Does not make a difference to me
                                    i D Would not change the current format
                                    3 O A format with sentences and headings to highlight key items
                                    4 n A box format, like the nutrition facts box found on food packages, that presents information
                                          consistently among outdoor pesticide products

-------
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                                                297
Htllonml Ftmllv Oolnlen

-------
                   10.    Listed below are several statements that may appear oh the packaging of an outdoor pesticide product.  For eacr
                          pair. "X" the box next to the statement you prefer.  (X ONE Statement For EACH Pair)
Prefer
This
Statement
i D .....Use safely. Read the label before use
, Q 	 Hazards to humans and animals
, fj 	 Environmental hazards
-OR-
-OR-
-OR-






Prefer
This
Statement
~~
. —

. —
	
                         D..... Re-entry not allowed until sprays are dry   - OR -
                                                       Do not re-enter treated area until
                                                       spray has dried	
                         fj	DO not apply directly to water
                                                                      -OR-
                                                       Do not apply directly to lakes, streams
                                                       rivers, or ponds	
                            	Do not contaminate water when disposing  - OR •
                               of equipment washwaters or rinsate	
                                                       Do not dump rinsewater into sewers or
                                                       other bodies of water	
                            ..... Do not contaminate water when disposing  - OR -
                               of equipment washwaters or rinsate	
                                                       Do not dump leftover pesticide or
                                                       rinsewater into drains or sewers	2 Q
                            	DO not use where soils are permeable     - OR -
                                                       Do not use where product may seep
                                                       into ground water	2 D
                            - Do not use W"0'6 soils are permeable     - OR -      Do not apply to sandy soils	2 D
                            	This pesticide is toxic to wildlife
                                                                      -OR-
                                                      This pesticide can kill wildlife	: D
                        i Q	This pesticide is toxic to wildlife and
                                domestic animals
                                          - OR -      This pesticide may harm pets and
                                                      wildlife	z D
                               Do not apply when weather conditions
                               favor drift from treated areas
                                          - OR -      Do not apply in windy conditions. Pesticides
                                                      may drift away from application site	2 D
                               .Pre-harvest Interval-allow X hours
                                before picking or eating crops
                                          - OR -'     Do not pick or eat garden crops tor
                                                      x hours after application	2 D
                                Drift or runoff may adversely affect
                                fish and nontarget plants
                                          - OR -       Drift or runoff may unintentionally harm
                                                       fish and plants	' D
                         t D .....Phytotoxic to woody plants
                                                                      -OR-
                                                      Applteation may injure woody plants
                             	Wrap in paper and dispose of in trash
                                          - OR -       For information on safe disposal of
                                                    •   unused product, contact a household
                                                       hazardous waste program, or your local
                                                       or state environmental agency	2 D
|	Do not apply where runoff can occur      - OR -
                                                                                   Do not use on sloped areas when heavy
                                                                                   rain is expected
                             	Repeated contact may cause skin
                                sensitization reactions in some
                                individuals. Avoid contact with skin
                                                                      -OR-
                                                       May cause skin allergies to develop
                                                       Avoid contact with skin	z D
298
                                                                                                                        34958-4b

-------
11.    Please indicate how much you agree or disagree with each of the following statements.
       Statement)
                                                                         Neither
                                                   Agree      Agree    Agree Nor
                                                 Completely  Somewhat   Disagree
The level of possible harmful effects of a product plays
  an important role in deciding which product I purchase.... iQ         CD        CD
In general, products that have fewer possible harmful
  effects don't work well as those that have more
  possible harmful effects	O         CD        CD
I always try to purchase the product with the fewest possible
  harmful effects available for my purpose	CD.         iQ        a[3
I don't worry about chemicals in outdoor
  pesticide products	.'	Q         J[3        CD
Manufacturers make sure the products they sell
  are safe to use	O         CD        CD
If I can buy an outdoor pesticide product in the store
  where I usuajly shop, it must be safe to use	CD         CD        CD
The government ensures that outdoor pesticide
   products are safe to use	>D         CD        CD
 Using outdoor pesticide products safely and effectively is
   a matter of common sense	CD         CD        CD
 Information on products is often hard to understand	iQ         C]        CD
 I know how to use outdoor pesticide products so
   there is no need to read the label	iQ         CD        CD
 I read labels because someone in my household has
   allergies or health problems	CD         CD        CD
 When it comes to using products. I rely more on my own
   experiences than I do on the information on a product—CD         CD        CD
 When it comes to throwing away products, I rely more on
   my own  experiences than I do on the information on
   a product	CD         CD        CD
 It is easy for me to find the information I need on outdoor
   pesticide products	'D         CD        CD
 The words "Warning", "Caution" and "Danger on a
   product  mean the same thing to me	O         CD        CD
 It is necessary to wrap outdoor pesticide products in
   paper or plastic before throwing away	CD         CD        CD
 I know which product containers to recycle so I do not
   need to look on the label	CD         CD        CD
 The instructions on the label for throwing
   away a product or its container don't agree with what
   my community tells me to do		tQ         CD        CD
 Unused outdoor pesticide product should be poured
   down the drain or toilet to dispose of it rather than
   throwing it in the trash	O         CD        CD
 I feel more comfortable if the label lists every ingredient — iQ         CD        CD
 I don't need the complete list of ingredients that are in                         •
   a product because I don't know what they are anyway	iQ         CD        CD
 It's more important to know which ingredients might be
   harmful to me than to know which ones will kill the pest... iQ         CD        CD
 The more outdoor pesticide product I use at one time,
   the more off ective it will be	O         CD         CD
  Environmentally friendly or natural products often don't
   work as well as other products		'O         CD         CD
  It's okay tor a buyer to open the "peel open booklets"
   attached to pesticide products before they buy them	iQ         CD         CD
  Peel open booklets on labels have more useful information
   than a regular flat label	CD         CD         CD
  I don't have to worry about where I store a
    product that is in a child resistant package	CD         CD         CD
  I would like information on long term health effects to
    be included on outdoor pesticide products		iQ         CD         CD
  Labels should say whether the product should  not be used by
    or around pregnant women	'D         CD         CD
  Overall, I am satisfied with the type  of information
    on outdoor pesticide products	
-------
NOW, I'D LIKE YOU TO REFER TO THE REPLICA OFTHE LABEL I SENtYOU. PLEASE USETHAT LABELTO
ANSWER QUESTIONS 12a - 12e.
12a.   Please look at the part on the front of the label titled "Active Ingredients", and a bit further down "Other  _
       Ingredients". Listed below are some statements that could describe this part of the label. In Column A . please
       indicate whether you agree, neither agree nor disagree, or disagree that each statement describes this part ot ine
       label. (X ONE Box For EACH Statement In Column "A")
       Now, please look at the part on the back of the label titled "Directions For Use". The statements listed Delow couic
       describe this part of the package In Column "B", please indicate whether you agree, neither agree nor disagree, or
       disagree that each statement describes this part of the label. (X ONE Box For EACH Statement In Column "B")
       Now, go to the part of the label titled "Storage", and a bit further down, "Disposal". In Column "C", please
       indicate whether you agree, neither agree nor disagree or disagree that each statement describes this part of the
       label. (X ONE Box For EACH Statement In Column "C")
       Next, please look at the part of the label titled "Precautionary Statements".  Again, in Column "D", please indicate
       whether you agree, neither agree nor disagree, or disagree that each statement describes this part of the label.
       (X ONE Box For EACH Statement In Column "D")
       Finally, refer to the part of the label indicated by the title "First Aid". In Column "E". please indicate whether you
       agree, neither agree nor disagree, or disagree that each statement describes this part of the label. (X ONE Box
       For EACH Statement In Column "E")
                        12b.
                        12c.
                        12d.
                        12e.







"A"

Active & Other
Ing


V
5,
confusing or difficult to understand 	 i| |

The title of this section helps me
understand what type of information
this section contains just the right

The information in this section is not

Even after reading this section, 1 am
not sure 1 would know how to

redients
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an
13a. Which, if any, of the following outdoor pesticide products have you, yourself, used in the past 12 months?
(X ALLThat Apply In Column "A")
                        13b.   Which, if any. of the following outdoor pesticide products have you, yourself, purchased in the past 12 months?
                               (X ALLThat Apply In Column "B")             "A"                   "B"
                                                                    Used Past 12 Mos.   Purchased Past 12 Mos.
                        Product Form  Granules/pellets (applied by push
                                         spreader or sprinkled)	iD                   'D
                                       Dusts/Powders (no mixing)	sO                   €H
                                       Ready-tp-Use Sprays &_Foams
                                         (no mixing)	oD                   3D
                                       Hose-End Spray Concentrates (mix with
                                         water while spraying)	«D                   4D
                                       Concentrates (mixed with water before
                                         using)	>O                   5D
                        Product Type  Lawn herbicide	eD                   «D
                                       Fruit/Vegetable insecticide or fungicide	?D                   7D
                                       Tree/Shrub insecticide or fungicide	*D                   «O

                        14a.   Have you. yourself, had an accident with an outdoor pesticide product in the past 12 months?
                                      i D Yes -* (Continue)                      a D No ~* (Skip To Qu. 15)

                        14b.   Please describe the accident you had with the outdoor pesticide product. (Write In Below, Please Be As
                               Specific As Possible)
                         15.     Please describe how you currently dispose of outdoor pesticide products when you are done using them?
                                (Write In Below, Please Be As Specific As Possible)
                         16.
        Are there any other general comments on label information that you would like to make? (Write In
        Be As Specific As Possible)
Below, Please
300
                     Thank you for your help with this study. Please return your completed
                   questionnaire In the enclosed postage-paid envelope as soon as possible.
                                                                                                                      34958-4b

-------
                                                    Appendix 3-1 :
Qualitative Research Telephone Recruitment Screening Questionnaires
   for Indoor Insecticides, Household Cleaners, and Outdoor Pesticides
                                                          301

-------

-------
                     INDOOR
 NAME
                                        HOME#
 ADDRESS
                             WORK#
 MALE ( )    FEMALE ( )  RECRUIT A MIX FOR EACH SESSION
 Day Three: Indoor Insceticides
Group 1
Group 2
Group 3
4PM
6PM
8PM
Hello. My name is_
              from
We are an independent
        •*       '          	              * »VS» MO.W UJ.L AJLIVACL^Cl lW.CJ.lt
marketing research company. Today we are conducting a research study about
common indoor insecticides. I would like to speak with the person who is most
responsible for the purchase and use of indoor insecticides in your household  Is
that you? Yes ( ) No ( ). IF YES CONTINUE; IF NO, THANK AND ASK FOR
QUALIFYING FAMILY MEMBER AGE 18 OR OLDER. IF NO FAMILY
MEMBERS QUALIFY, TERMINATE.

1. Does anyone in your household work for any of the following companies?
   READ LIST AND CHECK IF YES.
   A market research firm
   An advertising agency
   A public relations firm
   An insecticide company
   A chemical company
   A pharmaceutical company
   A pest exterminator
   Any company that manufactures,
   distributes, or sells indoor insecticides
   (insect, pests, and bug killers)
                         ( ^TERMINATE
                         ( TERMINATE
                         ( ^TERMINATE
                         ( ^TERMINATE
                         ( ^TERMINATE
                         ( ^TERMINATE
                         ( TERMINATE
                        ( ^TERMINATE
2.  Have you participated in any market research group
   discussions?
   No   ( )
   Yes   ( ) ASK .-When did you last participate in a group discussion?
                DO NOT READ LIST.
                6 months or less         ( ) TERMINATE
                more than 6 months     ( ) CONTINUE

3.  Would you say you are responsible for: READ LIST.
   Less than 50% of your household's indoor insecticide usage ( ) TERMINATE
   50% or more of your household's indoor insecticide usage  ( ) CONTINUE
The Newman Group, Ltd.
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                        INDOOR INSECTICIDES
 4.  In the past 6 months, going back until January of 1998, have you personally
    purchased any indoor insecticides?
    No          ( )   TERMINATE
    Yes         ( )

 5.  Which of these statements describes you when you purchase an indoor insecticide.
    You may select more than one. ROTATE ORDER OF STATEMENTS.
                                                    Yes      No
    I read the ingredient/usage label in the store.           ( )      ( )
    I read the ingredient/usage label at home before I use it. ( )      ( )
    I read the ingredient/usage label when I store it.        ( )      ( )
    I read the ingredient /usage label when I throw it away  ( )      ( )
    I don't read title ingredient/usage label at all.           ( )      ( )
    RECRUIT A MIX OF RESPONSES.

 6.  During the past six months, have you had any problems with insects inside
    your home? No( ) TERMINATE   Yes  ( ) ASK6B.

6B.  What type of indoor insect problems did you have in the past 6 months?
    DO NOT READ LIST.            ants                         (  )
    RECRUIT A GOOD MIX.         fleas in the home not on pets     (  )
                                    roaches                      (  )
                                    water bugs                   (  )
                                    Other Specify:	

 7. In the past six months, how often have you used an indoor insecticide
    0              ( ) TERMINATE
    1-4 times       ( ) Light users
    5 plus times    ( ) Heavy Users
    RECRUIT A MIX OF HEAVY AND LIGHT USERS.

 8. Which of the following types of indoor insecticides have you personally
    purchased and used in the past 6 months? You may choose more than one.
    READ LIST.
    Sprays                                        (  )
     Baits (black, gray, or white stations where bugs eat bait
     and carry it back to their colony or nest) ( )
    Indoor foggers, fumigators, bug bombs             (  )
     Powders like boric acid or gels                    (  )
     Chalks                                        (  )
     Indoor plant treatments (aphids, mealy bugs)
     Flea treatment products to be used on pets
     Liquids
     Other Specify:
                                                   ( ^TERMINATE IF ONLY
                                                   ( )  TREATMENT USED
      None of the above
                                                  ( ) TERMINATE
304
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                      INDOQRINSECTICIDES
 9. In order to organize your comments, into which of the following age ranges
    do you fall: READ LIST.
    under 18
    18-25
    26-35
    36-50
    51-65
    65-70
    Over 70
 ( )
 ( )
 0
 ()
'(.)'
 ( )
 ( )
THANK AND TERMINATE
    RECRUIT A GOOD MIX

10.  What is your ethnic background?
    African American     ( )
    Asian               ( )
    Caucasian           ( )
    Hispanic            ( )
    Native American      ( )
    Other Specify:
    RECRUIT A GOOD MIX

 11. What is the highest level of education you have? DO NOT READ LIST
    Less than high school  ( )
    Graduated high school ( )
    College              ( )
    RECRUIT A GOOD MIX

12.  Do you have any children under 18 in your household?
    No ( )
    Yes ( ) ASK: What are their specific ages?
  .  GET MIX OF RESPONDENTS WITH AND WITHOUT CHILDREN
                              AND
    GET SOME RESPONDENTS WITH CHILDREN UNDER 8 YRS. OLD.

13.  Are you currently employed?
    Fulltime  (35 hrs. a week or more)  (  ) ASKQ13B.
    Part time  (Less than 35 hrs. a week) (  ) ASK Q13B.
    Not employed                    OSKIPTOQ14.

13B. What is your occupation?	
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                        INDOOR INSECTICIDES
                                 .,        ,  ,      ...      ,|

   14. Would you describe the area in which you live as being urban, suburban, or
       rural?
       urban         ( )
       suburban      ( )
       rural         ( )

       INCLUDE A MIX OF RESPONDENTS THAT IS REPRESENTATIVE OF
       THE LOCAL POPULATION.
                                                 .      I
   15.  Would you describe your residence as a:  READ LIST

       House        ( )
       Apartment    ( )
       Duplex       ( )
       Townhouse    ( )
       Assisted living ( ) TERMINATE
       Other Specify:	
       RECRUIT A GOOD MIX

   16.  Do you own or rent your residence?
       Own          ( )
       Rent          ( )

   17.  Do you have any household pets?
       No           ( )
       Yes           ( ) ASK: What type of pet do you have?
                        Dog  '( )
                        Cat    ( )
                        Bird   ( )
                        Other Specify:	
       WE ARE LOOKING FOR SOME RESPONDENTS TO HAVE FURRY PETS
       SUCH AS A DOG, CAT, OR BIRD.
306
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                      INPOOR INSECTICIDES

18.  Please rate yourself on each of the following statements using a scale of 1 to 5, where
    1 means you strongly agree, 2 means you agree somewhat, 3 means you neither
    agree nor disagree, 4 means you disagree somewhat, and 5 means you strongly
    disagree. READ STATEMENT.
    Would you say you ...             strongly agree                1
                                    agree somewhat               2
                                    neither agree nor disagree      3
                                    disagree somewhat            4
                                    strongly disagree              5
 A. I would feel comfortable talking in a small group.
. TERMINATE IF 4 OR 5
 B. I usually have an opinion on any given subject and can express that opinion freely.
                                           	TERMINATE IF 4 OR 5
 C. I prefer letting others do the talking.              	TERMINATE IF 1 OR 2

 IF "4" OR "5" MENTIONED TO STATEMENTS A OR B TERMINATE AND TALLY.
 IF "1,2, OR 3" MENTIONED TO STATEMENT C TERMINATE AND TALLY.

 We would like to invite you to a market research discussion group with 4 other
 people. This meeting will last from ______ AM/PM on	1998. You
 will be given $	as a token of our appreciation for attending. Would you
 like to be one of the selected people in this project?

 GIVE APPROPRIATE DIRECTIONS TO FACILITY. REMIND THEM THAT
 IF THEY ARE NOT ABLE TO ATTEND THEY SHOULD CALL
 IMMEDIATELY SO THAT YOU CAN FIND A REPLACEMENT FOR THEM. _
 REMIND RESPONDENTS TO BRING GLASSES IF THEY NEED THEM
 FOR READING MATERIALS DISTRIBUTED AT THE GROUP.
  The Newman Group, Ltd.
               307

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  NAME
                HOUSEHOLD  CLEANERS
                         	HOME#
  ADDRESS
                                    WORKS
  MALE ( )   FEMALE ( ) RECRUIT A MIX FOR EACH SESSION

  Day Two:  Household Cleaners (City)	;	
   Group 1
   Group 2
   GroupS
        4PM
        6PM
        8PM
   Hello. My name is_
                      from
We are an independent
   marketing research company. Today we are conducting a research study about
   common household cleaning products. I would like to speak with the person
   who is most responsible for the majority of cleaning tasks in your household. Is
   that you? Yes ( ) No ( ). IF YES CONTINUE; IF NO, THANK AND ASK FOR
   QUALIFYING FAMILY MEMBER AGE 18 OR OLDER.  IF NO FAMILY
   MEMBERS QUALIFY, TERMINATE.

   1.  Does anyone in your household work for any of the following companies?
      READ LIST AND CHECK IF YES.
      A market research firm
      An advertising agency
      A public relations firm
      An insecticide company
      A chemical company
      A pharmaceutical company
      A professional cleaning service
      Any company that manufactures,
      distributes, or sells household
      cleaning products
                                 ( TERMINATE
                                 ( /TERMINATE
                                 ( /TERMINATE
                                 ( /TERMINATE
                                 ( TERMINATE
                                 ( TERMINATE
                                 ( /TERMINATE
                                 ( /TERMINATE
   2.
Have you participated in any market research group
discussions?
No   ( )
Yes   ( ) ASK :When did you last participate in a group discussion?
              DO NOT READ LIST.
              6 months or less        ( ) TERMINATE
              more than 6 months     ( ) CONTINUE
      Would you say you are responsible for:  READ LIST.
      Less than 50% of your household cleaning tasks   ( )
      50% or more of your household cleaning tasks    ( )
                                              TERMINATE
                                              CONTINUE
308
                                                     July 7,1998

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                     HOUSEHOLD CLEANF.RS
 4. In the past 6 months, going back until January of 1998, have you personally
    purchased any household cleaning products for your home?
    No        ( )    TERMINATE
    Yes        ( )

 5. Which of these statements describes you when you purchase a household
    cleaning product? You may select more than one
    ROTATE ORDER OF STATEMENTS               Yes      No
    I read the ingredient/usage label in the store.           (  )      ( )
    I read the ingredient/usage label at home before I use it.  ( )      ( )
    I read the ingredient/usage label when I store it.        (  )      ( )
    I read the ingredient /usage label when I throw it away  (  )      ( )
    I don't read the ingredient/usage label at all.           (  )      ( )

    RECRUIT A MIX OF RESPONSES.

 6. Which of the following products do you use? READ LIST.
                                     # of times used per week/month
    basin tub and tile cleaner    ()	
    toilet bowl cleaner         ( )	
    mold and mildew remover   ( )	
    bleach                    ( )      	
    drain cleaners              ( )	
    glass cleaners              ( )	

6B.. FOR EACH CHECKED ASK: How many times a week/month do you
    generally use	? READ LIST.

    4-6 times per week
    2-3times per week
    once a week              	.__
    2-3 times a month
    once a month
    less than once a month

    ADD UP ALL THE PRODUCTS TO GET USAGE. RECRUIT A MIX OF
    RESPONDENTS. MUST USE AT LEAST ONE PRODUCT ONCE A
    MONTH OR MORE.
    4-6 times per week
    2-3 times per week
    once a week
    2-3 times a month
    once a month
    less than once a month
HEAVY USAGE
LIGHT USAGE
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                                                                 309

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                      HOUSEHOLD  CLEANERS
   7.  Do you currrently use any household cleaners tht claim to kill germs?
      No ( )   Yes ( ) ASK: Which ones do you use?
      RECRUIT A GOOD MIX OF NO & YES AND PRODUCTS USED.
   8.  In order to organize your comments, into which of the following age ranges
      do you fall: READ LIST
      under 18       ( )   THANK AND TERMINATE.
      18-25          ( )
      26-35          ( )
      36-50          ( )
      51-65          ( )
      65-70          ( )
      Over 70       ( )
      RECRUIT A GOOD MIX.

   9. What is your ethnic background?
      African American     ( )
      Asian               ( )
      Caucasian           ( )
      Hispanic            ( )
      Native American      ( )
      Other Specify:.
       RECRUIT A GOOD MIX.

  10.  What is the highest level of education you have? DO NOT READ LIST.
       Less than high school  ( )
       Graduated high school ( )
       College
       RECRUIT A GOOD MIX

  11.  Do you have any children under 18 in your household?
       No  ( )  Yes ( ) ASK: What are their specific ages?
       GET MIX OF RESPONDENTS WITH AND WITHOUT CHILDREN
                                AND
       GET SOME RESPONDENTS WITH CHILDREN UNDER 8 YRS. OLD.

   12.  Are you currently employed?
       Full time   (35 hrs. a week or more)  ( ) ASK Q12B.
       Part time   (Less than 35 hrs. a week) ( ) ASK Q12B.
       Not employed                  - ()SKIPTOQ13.
   12B. What is your occupation?
310
July 7,1998
        < «*  :!!:,i !•:!»!. I

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                    HOUSEHOLD  CLEANERS

 13. Would you describe the area in which you live as being urban, suburban, or
    rural?
    urban         ( )
    suburban      ( )
    rural          ( )

    INCLUDE A MIX OF RESPONDENTS THAT IS REPRESENTATIVE OF
    THE LOCAL POPULATION.

14.  Would you describe your residence as a: READ LIST
    House         ( )
    Apartment     ( )
    Duplex        ( )
    Townhouse     ( )
    Assisted living  ( ) TERMINATE
    Other Specify:	
15.  Do you own or rent your residence?
    Own          ( )
    Rent          ( )

16.  Do you have any household pets?
    No            ( )
    Yes           ( ) ASK: What type of pet do you have?
                     Dog    ( )
                     Cat    ( )
                     Bird    ( )
                     Other Specify:	
    WE ARE LOOKING FOR SOME RESPONDENTS TO HAVE FURRY PETS
    SUCH AS A DOG, CAT, OR BIRD.
 The Newman Group, Ltd.
311

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                         HOUSEHOLD CLEANERS
                                                          i
   17.  Please rate yourself on each of the following statements using a scale of 1 to 5, where
        1 means you strongly agree, 2 means you agree somewhat, 3 means you neither
        agree nor disagree, 4 means you disagree somewhat, and 5 means you strongly
        disagree. READ STATEMENT.
        Would you say you...             strongly agree                 1
                                       agree somewhat               2
                                       neither agree nor disagree       3
                                       disagree somewhat            4
                                       strongly disagree               5
     A. I would feel comfortable talking in a small group.
TERMINATE IF 4 OR 5
     B. I usually have an opinion on any given subject and can express that opinion freely.
                                               	__ TERMINATE IF 4 OR 5
     C. I prefer letting others do the talking.               	TERMINATE IF 1 OR 2
                                                         I , j                  !
     IF "4" OR "5" MENTIONED TO STATEMENTS A OR B TERMINATE AND TALLY.
     IF "1,2, or 3" MENTIONED TO STATEMENT C TERMINATE AND TALLY.

     We would like to invite you to a market research discussion group with 4 other
     people. This meeting will last from __-^ AM/PM on	1998. You
     will be given $	as a token of our appreciation for attending. Would you
     like to be one of the selected people in this project?

     GIVE APPROPRIATE DIRECTIONS TO FACILITY. REMIND THEM THAT
     IF THEY ARE NOT ABLE TO ATTEND THEY SHOULD CALL
     IMMEDIATELY OU THAT YOU CAN FIND A REPLACEMENT FOR THEM. _
     REMIND RESPONDENTS TO BRING GLASSES IF THEY NEED THEM
     FOR READING MATERIALS DISTRIBUTED AT THE GROUP.
312
          July 7,1998

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NAME
                  OUTDOOR PESTICIDES
                 	_____ HOME#
ADDRESS
                                     WORKS
MALEO   FEMALE ()  RECRUIT A MIX FOR EACH SESSION

Day One: Outdoor Pesticides (city)	
Group 1
Group 2
Group 3
                4PM
                6PM
                8PM
Hello. My name is_
                      from
                                	. We are an independent
marketing research company. Today we are conducting a research study about
common outdoor pesticides I would like to speak with the person who is most
responsible for buying and using bug killer or weed killer in your yard. Is that
you? Yes ( ) No ( ). IF YES CONTINUE; IF NO, THANK AND ASK FOR
QUALIFYING FAMILY MEMBER AGE 18 OR OLDER. IF NO FAMILY
MEMBERS QUALIFY, TERMINATE.

1.  Does anyone in your household work for any of the following companies?
   READ LIST AND CHECK IF YES.
   A market research firm
   An advertising agency
   A public relations firm
   An insecticide company
   A chemical company
   A pharmaceutical company
   A pest exterminator
   A landscape or lawn service
   Farming
   Any company that manufactures,
   distributes, or sells lawn and garden
   products (bug killers or weed killers)
                                 ( )TERMINATE
                                 ( )TERMINATE
                                 ( TERMINATE
                                 ( )TERMINATE
                                 ( TERMINATE
                                 ( )TERMINATE
                                 ( ^TERMINATE
                                 ( )TERMINATE
                                 ( TERMINATE
                                 ( ^TERMINATE
2.
Have you participated in any market research group
discussions?
No   ( )
Yes   ( ) ASK: When did you last participate in a group discussion?
              DO NOT READ LIST.
              6 months or less         ( ) TERMINATE
              more than 6 months     ( ) CONTINUE
The Newman Group, Ltd.
                                                            313

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                         OUTDOOR PESTICIDES
    3.  Would you describe your residence as a: READ LIST.

       House         ( )
       Apartment     ( ) TERMINATE
       Duplex        ( )
       Townhouse    ( )
       Assisted living  ( ) TERMINATE
       Other Specify:	
    4.  Do you own or rent your residence?
       Own          < )
       Rent          ( )

    5.  Does your residence have a private yard, vegetable garden, or flower garden?
       Yes      ( )
       No      ( ) TERMINATE
                                                        i
    6.  Do you personally care for that yard or garden?
       Yes      ( )
       No      ( ) TERMINATE

    7.  Are you the person who actually applies bug or weed killer in your yard or
       garden?
       Yes      ( )
       No      ( ) TERMINATE
                                                        I                 •  •
    8.  Would you say you are responsible for: READ LIST.
       Less than 50% of your household's usage of outdoor bug killer or weed killer ( )
       TERMINATE
       50% or more of your household's usage of outdoor bug killer or weed killer  ( )
       CONTINUE

    9.  In the past 6 months, going back until January of 1998, have you personally
       purchased any outdoor bug killer or weed killer?
       No         ( )   TERMINATE
       Yes         ( )

   10.  Which of these statements describes you when you purchase an outdoor bug
       killer or weed killer?  You may select more than one.
       PLEASE ROTATE ORDER OF STATEMENTS       Ye§.       No
       I read the ingredient/usage label in the store.           ( )       (  )
       I read the ingredient/usage label at home before I use it. ( )       (  )
       I read the ingredient/usage label when I store it.        ( )       (  )
       I read the ingredient /usage label when I throw it away  ( )       (  )
       I don't read the ingredient/usage label at all.           ( )       (  )
       RECRUIT A MIX OF RESPONSES.
314
July 7,1998

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                       OUTDOOR PESTICIDES
11 A. In the past 6 months, how frequently have you personally used an outdoor
     bug killer?
     0             ( ) * POSSIBLE TERMINATE SEE NOTE
     1-4 times      ( ) Light users
     5 plus times    ( ) Heavy Users

11B. In the past 6 months, how frequently have you personally used an outdoor
     weed killer?
     0             ( )* POSSIBLE TERMINATE SEE NOTE
     1-4 times      ( ) Light users
     5 plus times    ( ) Heavy Users

     * IF BOTH BUG KILLER Q.11A AND WEED KILLER Q.11B HAVE NOT
     BEEN USED IN PAST 6 MONTHS TERMINATE. IF ONLY ONE (BUG
     KILLER OR WEED KILLER) NOT USED, OKAY. RECRUIT A GOOD MIX,
     LIGHT AND HEAVY USER, BUG KILLER ONLY, WEED KILLER ONLY.

  12. What type of outdoor pests or weeds have you had problems with in your
     yard or garden?
      INCLUDE A WIDE RANGE OF INSECT PROBLEMS.

  13.  This year, have you used a "weed and feed" that is a fertilizer product that
      also contains something to kill weeds?
      Yes          ( )
      No          ( )

      RECRUIT A GOOD MIX.

  14.  In order to organize your comments, into which of the following age ranges
      do you fall: READ LIST
      under 18      ( )    THANK AND TERMINATE
      18-25         ( )
      26-35         ( )
      36-50         ( )
      51-65         ( )
      65-70         ( )
      Over 70       ()•-..

      RECRUIT A GOOD MIX
    The Newman Group, Ltd.
315

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                          OUTDOOR PESTICIDES
   15.  What is your ethnic background?
        African American     ( )
        Asian              ( )
        Caucasian           ( )
        Hispanic            ( )
        Native American     ( )
        Other Specify:
        RECRUIT A GOOD MIX

    16.  What is the highest level of education you have? DO NOT READ LIST
        Less than high school  ( )
        Graduated high school ( )
        College
        RECRUIT A GOOD MIX

    17.  Do you have any children under 18 in your household?
        No  ( )
        Yes ( ) ASK: What are their specific ages?
        GET MIX OF RESPONDENTS WITH AND WITHOUT CHILDREN
                                 AND
        GET SOME RESPONDENTS WITH CHILDREN UNDER 8 YRS. OLD.
               I,'.''            '       " ' '          '"'"'I     '  ' "
    18.  Are you currently employed?
        Fulltime   (35 hrs. a week or more)  (  ) ASKQ18B.
        Part time   (Less than 35 hrs. a week) (  ) ASK Q18B.
        Not employed                "   ()SKIPTOQ19.
                                                         i

   18B.  What is your occupation?	
    19.  Would you describe the area in which you live as being urban, suburban, or
        rural?
      •  urban         ( )
        suburban      ( )
        rural          ( )

        INCLUDE A MIX OF RESPONDENTS THAT IS REPRESENTATIVE OF
        THE LOCAL POPULATION.
316
July 7,1998

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                       OUTDOOR PESTICIDES
20.  Do you have any household pets that are allowed to go outside?
    No
    Yes
                 ( ) What type of pet do you have?
                      Dog    ()
                      Cat    ( )
                      Bird    ( )
                      Other Specify:	__
    WE ARE LOOKING FOR SOME RESPONDENTS TO HAVE FURRY PETS
    SUCH AS A DOG, CAT, OR BIRD.

21.  Please rate yourself on each of the following statements using a scale of 1 to 5, where
    1 means you strongly agree, 2 means you agree somewhat, 3 means you neither
    agree nor disagree, 4 means you disagree somewhat, and 5 means you strongly
    disagree. READ STATEMENT.
    Would you say you...             strongly agree                 1
                                    agree somewhat               2
                                    neither agree nor disagree       3
                                    disagree somewhat             4
                                    strongly disagree               5
                                                 . TERMINATE IF 4 OR 5
A. I would feel comfortable talking in a small group.      	

B. I usually have an opinion on any given subject and can express that opinion freely.
                                          	TERMINATE IF 4 OR 5
C. I prefer letting others do the talking.              	TERMINATE IF 1 OR 2

IF "4" OR "5" MENTIONED TO STATEMENTS A OR B TERMINATE AND TALLY.
IF "1,2, OR 3" MENTIONED TO STATEMENT' C TERMINATE AND TALLY.

We would like to invite you to a market research discussion group with 4 other
people. This meeting will last from __-_ AM/PM on	1998. You
will be given $	 as a token of our appreciation for attending. Would you
like to be one of the selected people in this project?

GIVE APPROPRIATE DIRECTIONS TO FACILITY. REMIND THEM THAT
IF THEY ARE NOT ABLE TO ATTEND THEY SHOULD CALL
IMMEDIATELY SO THAT YOU CAN FIND A REPLACEMENT FOR THEM. _
REMIND RESPONDENTS TO BRING GLASSES IF THEY NEED THEM
FOR READING MATERIALS DISTRIBUTED AT THE GROUP.
 The Newman Group, Ltd.
                                                                317

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                                              Appendix 3-2:
                   Qualitative Research Discussion Guides for
Indoor Insecticides, Household Cleaners, and Outdoor Pesticides
                                                     319

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          Discussion Guide CLI:  Indoor Insecticide Products

 I.  Moderator Introduction (1 minute)
    Greet the respondents:  We're talking to people today about the
    labels on products they to kill bugs and insects inside their home. These are
    commonly called indoor insecticide products.

    A. No wrong answers to any questions asked.
    B. All we want is to get honest feedback from you.
    C. Explain taping and one way mirror

 II. Participant Introductions (4 minutes)
    Let's start with you telling me something about yourselves.

    A. Name
    B. Occupation
    C Married or single? Any children? Ages of children?
IIL
Past Experience and Product Selection (10 minutes)
Today we are going to be focusing our attention on the labels of
products commonly called indoor insecticides.
A. Why do we read labels? (List on easel))                  -  .
B. Why don't we read labels? (List on easel)
C. When do you read the label on Indoor insecticide products? What are you
   looking for? (probe: in the store prior to purchase, at home prior to use, (oilier)
   don't read the label, why?
B. How satisfied are you with the information currently available on the
   package of these products? Now I want to show you an example of an
   existing label. (Existing Example)
E. Is the information on this label of indoor insecticide product easy or
   difficult to understand? Explain what you mean by that
F. Is there any additional information you would like to see on the label of
   indoor insecticide products?             .
G. Are there any improvements you would like to see on the presentation or
   format of information on the label for indoor insecticide products?
   The Newman Group, Ltd.
   Indoor Insecticide Products
                                                              321

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             IV. Understanding Ingredient Listings (15 minutes)
                 A national study has been conducted with people like you about the
                 information on the labels of indoor insecticide products.  From this study we
                 learned that people want certain information about these products on the
                 label. Some people like this information presented in one way and other
                 people prefer it presented in a different way. I would like you to imagine that
                 you are in a store ready to buy an indoor insecticide product. I am going to
                 show you several examples for labels.  Remember, at any time you can choose
                 the existing label example. We are now going to focus our attention on the
                 ingredient listing on Indoor insecticide products.

                 Show ingredient prop boards along with existing example

                 A.  What information do you need in the ingredient listing for an indoor
                     insecticide? Why do you need this information?
                     IF FULL FORMULA ALREADY AVAILABLE TO POISON CONTROL
                     WHAT INFO IS NECESSARY ON LABEL? WHICH FORMAT IS
                     PREFERRED?  WHY?
                 B.  Do any of these formats make it easier for you to find the ingredient
                     information you want?
                 C.  Of these examples, which format of the ingredient information do you feel
                     better about? Why?
                 D.  Would any of these label examples help you to use an indoor insecticide
                     more safely or effectively? Explain;
                 E.  Do you have a preference for the ingredient information being presented
                     on me front or back of the label? Why?
                 F.  Would any of these ingredient sections encourage you to read more of the
                     label or read the label more of te"n? Which one? Why?

               V. Understanding Precautionary Language (5 minutes)
                 We are now going to focus our attention on the precautionary language used
                 on indoor insecticide product labels. (Back Label)

               - Show both precautionary label prop boards at same time with existing example

                 A.  What information are you looking for in the precautionary statement
                     section on a label for an indoor insecticide?
                 B.  Do any of these precaution examples provide you with any information
                     that is more useful or easier to understand than the existing label?
                 C.  Of these examples, which format of the precautionary information do you
                     feel better about? Why?
                 D.  Do these phrases or words mean the same thing or do they each mean
                     Something different— "Precautionary Statements", "Caution", "Hazard to
                     humans and animals"
                     ~ • i  	£  .                            •     ,   .     .  i
                 E.  Would any of these precautionary statements help you to use an indoor
                     insecticide more safely or effectively? Explain.
               The Newman Group, Ltd.
               Indoor Insecticide Products
October 11,1998
i

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YL
    F. If it said "call poison control center where formula is registered" on the
        label, how would you feel about this? Could any information on the label
        be omitted if the formula was registered at poison control?
    F.  Would any of these precautionary language sections encourage you to
        read more of the label or read the label more often? Which one? Why?
Understanding Usage and Directions (20 minutes)
 We are now going to focus our attention on die directions for use on indoor
 insecticide product labels.

 Show both directions for use prop boards and existing example.

 A. What information are you looking for in the direction for use section on a
    label for indoor insecticide?
 B. Do any of these directions for use examples provide you with any
    information that is more useful or easier to understand than the existing
    label?
 C. Of these examples, which format for the directions for use information do
    you feel better about? Why? (Probe numbers and bullets)
 D. Does a certain format make you think the indoor insecticide product will
    be easier to use?
 E. Would your perception of an indoor insecticide product be changed by
    either of these directions for use sections? Explain.
 F. Would any of these directions for use sections help you to use an indoor
    insecticide more safely or effectively? Explain.
 G. Would any of these directions for use sections encourage you to read more
    of the label or read the label more often? Which one? Why?

 SHOW PAIRED STATEMENTS AND GET REACTION
VII.
  Understanding Signal Words (10 minutes)
  We are now going to focus our attention on the signal words used on indoor
  insecticide product labels, (label front only)

  Show label prop boards (4 examples)

  A. Have you ever seen anything like this before? (focus on signal words)
  B. How do you feel about this format (three words in a box)  compared to the
     format on the existing label (caution)!
  C. What does this box with the words caution/warrdng/danger mean to you?
     (level of human health concerns).
  D. Which word reflects a product that is less hazardous, more hazardous?
  E. How do you feel about the presentation of the "caution" information?
     Which do you prefer? Why? (with and without bullet points)
   The Newman Group, Ltd.
   Indoor Insecticide Products
                                                                    323

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               For products that are less hazardous than the caution ones with the bullet
               points, is there a word that would convey that to you? (careful, take care,
               law risk, beware, precaution)
           F. Does a indoor insecticide product need to have all three words on the label
               if only one applies? Explain?
           G.  What is your feeling about the vertical or horizontal presentation of this
               information? Which do you prefer? Why?
           H. What does the gradation of the shading in the boxes corresponding to the
               words caution, warning, danger say to you? Is that a good idea?  Why?
           I.  Of all these labels I have shown you and the existing example do any
               labels indicate a more hazardous product? (products with indicator pointed
               to Danger vs. pointed to Caution)
           J.  Would any of these caution/warning/danger formats encourage you to
               read more of the label or read the label more often? Which one? Why?
           K  Would any of these caution/warning/danger help you to use an indoor
               insecticide more safely or effectively? Explain.
                                                                  i
      VIII. Reaction to Label Standardization Initiative;  Box Format (10 minutes)
           A. .What do you think about a standardized label format on all indoor
               insecticide products?  Is there an advantage to this? Any disadvantages?
                                                                  1
               Now I would like you to look at these labels and specifically focus
               oh the information grouped together in the boxes. (Box format)

            Show box format label prop boards together with existing example.

            B.  Should boxes be used or not used on a label? Why?
            C. Does the box format make this information easier or more difficult to find
               on a indoor insecticide product?
            D. Does the box format make it possible to understand this information more
               djiiickly or less quickly?
            E. What information should be put into a box? Why? What information is
               most important to put into a box?
            F.  Which box format would encourage you to read more of the label or read
               the label more often?
            G. Could a product have too many boxes?
            H. Do you have any other suggestions on how to format this information
               that you would feel better about?
        I2L.
   Reaction to Logos (5 minutes)
   Go back to easel lists
   A. Why do we read labels on indoor insecticide products?
   B. What might happen if we don't read the label on an indoor insecticide
      product?
324
   (PARAPHRASE;
The Newman Group, Ltd.
Indoor Insecticide Products
                                                                   October 11,1998

-------
  Both the manufacturers of these products and various government agencies
  want people to use products safely and effectively. One way to know how to
  use a product to its greatest effectiveness without endangering children,
  health, pets, or the environment is to read the information on the label.
  Because of this, these companies and agencies would really like to encourage
  and remind people to read the label.

  One idea is to start a public service campaign to encourage people to read
  labels first. In order to promote this campaign a logo needs to be developed
  that visually speaks to people.

  Does anyone remember the pubic service campaign used for car safety
  "buckle up for safety buckle up."
           What was compelling about this message?
           Did this have any emotional impact for you? Explain.
           What about this slogan made you change your behavior?
  Read the Label First Campaign
           What about reading the labels on indoor insecticides? How can we
            get people to buy into this action?
           What would be compelling?
           What would be an emotional reason?

  Do you remember the logo for the buckle up for safety campaign?

  Show logos
  A. Which logo, if any, would be  more compelling for you in a "read the label
      first campaign? Why? Are there any emotional ties to this?
  B. What other factors  or suggestions besides the slogan "read the label first
    - . and the logo" could be used to better motivate you to read product labels
      on indoor insecticide products?
  C. Would you be significantly more motivated to read the directions and
      precautions on the label of indoor insecticide products if you understood
      that by doing so, it would allow you to use the product more safely and
      effectively?

X.  Closure (5 minutes)
   The manufacturers of these products want to make sure that they are giving
   people like you the information they need to choose the right products for
   your needs and how to safely use and dispose of products once you have
   brought them home. After reviewing all of this information today, what
   should my recommendations be to them?
The Newman Group, Lid.
Indoor Insecticide Products
325

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                 Discussion Guide CLI; Household Cleaner Products
                                                             I        '          '!
         I.  Moderator Introduction  (1 minute)
            Greet the respondents: We're talking to people today about the
            labels on products they use to clean inside their home. These are commonly
            called household cleaner products.

            A. No wrong answers to any questions asked.
            B.  All we want is to get honest feedback from you.
            C.  Explain taping and one way mirror

         II. Participant Introductions (4 minutes)
            Lef s start with you telling me something about yourselves.

            A. Name
            B.  Occupation
            C.  Married or single? Any children? Ages of children?

       III.  Fast Experience and Product Selection (10 minutes)
            Today we are going to be focusing our attention on the labels of
            products commonly called household cleaners.
            A. Why do we read labels? (List on easel))
            B.  Why don't we read labels? (List on easel)
            C.  When do you read the label on household cleaner products? What are
               you looking for? (probe: in the store prior to purchase, at home prior to use,
               (other)  don't read the label, why?
            B.  How satisfied are you with the information currently available on the
               package of these products? Now I want to show you an example of an
               existing label. (Existing Example)
            E.  Is the information on this label of hpusehold cleaner product easy or
               difficult to understand? Explain what you mean by that.
            F.  Is there any additional information you would like to see on the label of
               household cleaner products?
            G. Are there any improvements you would like to see on the presentation or
               format of information on the label for household cleaner products?
326      The Newman Group, Ltd.
         Household Cleaner Products
October11,1998
                                                            41

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IV.  Understanding Ingredient Listings
     A national study has been conducted with people like you about the
     information on the labels of household cleaner products. From this study we
     learned that people want certain information about these products on the
     label. Some people like this information presented in one way and other
     people prefer it presented in a different way. I would like you to imagine that
     you are in a store ready to buy a household cleaner product. I am going to
     show you several examples for labels. Remember, at any time you can choose
     the existing label example. We are now going to focus our attention on the
     ingredient listing on Household cleaner products.

     Show ingredient prop boards along with existing example

     A. What information do you need in the ingredient listing for a household
       cleaner?  Why do you need this information?
       IF FULL FORMULA ALREADY AVAILABLE TO POISON CONTROL
       WHAT INFO IS NECESSARY ON LABEL? WHICH FORMAT IS
       PREFERRED? WHY?
     B. Do any of these formats make it easier for you to find the ingredient
       information you want?
     C. Of these examples, which format of the ingredient information do you feel
       better about? Why?
     D. Would any of these label examples help you to use a household cleaner
       more safely or effectively? Explain.
     E. Do you have a preference for the ingredient information being presented
       on the front or back of the label?  Why?
     F. Would any of these ingredient sections encourage you to read more of the
       label or read the label more often? Which one? Why?

 V.  Understanding Precautionary Language (5 minutes)
     We are now going to focus our attention on the precautionary language used
     on household cleaner product labels. (Back Label)

     Show both precautionary label prop boards at same time with existing example

     A. What information are you looking for in the precautionary statement
       section on a label for a household cleaner?
     B. Do any of these precaution examples provide you with any information
       that is more useful or easier to understand than the existing label?
     C. Of these examples, which format of the precautionary information do you
       feel better about? Why?
     D. Do these phrases or words mean the same thing or do they each mean
       something different- "Precautionary Statements", "Caution", "Hazard to
       humans and animals"
     E. Would any of these precautionary statements help you to use a household
       cleaner more safely or effectively? Explain.
 The Newman Group, Ltd.
 Household Cleaner Products
327

-------
         F. If it said "call poison control center where formula is registered" on the
            label, how would you feel about this? Could any information on the label
            be omitted if the formula was registered at poison control?
         F. Would any of these precautionary language sections encourage you to
            read more of the label or read the label more often? Which one? Why?
                                                               i
     VI. Understanding Usage and Directions (20 minutes)
         We are now going to focus our attention on the directions for use on
         household cleaner product labels.
                                                       •  •      I
         Shaw both directions for use prop boards and existing example.

         A. What information are you looking for in the direction for use section on a
            label for household cleaner?
         B. Do any of these directions for use examples provide you with any
             information that is more useful or easier to understand than the existing
             label?
          C. Of these examples, which format for the directions for use information do
             you feel better about? Why? (Probe numbers and bullets')
          D. Does a certain format make you think the household cleaner product will
             be easier to use?
          E. Would your perception of a household cleaner product be changed by
             either of these directions for use sections? Explain.
          F. Would any of these directions  for use sections help you to use a household
             cleaner more safely or effectively? Explain.
          G. Would any of these directions  for use sections encourage you to read more
             of the label or read the label more often? Which one? Why?
     YIL
          SHOW PAIRED STATEMENTS AND GET REACTION
  Understanding Signal Words (10 minutes)
  We are now going to focus our attention on the signal words used on
  household cleaner product labels, (label front only)
                                                     .  \
        1 '•                                              !
  Show label prop boards (4 examples)

  A. Have you ever seen anything like this before? (focus on signal words)
  B. How do you feel about this format (three words in a box)  compared to the
     format on the existing label (caution)!
  C. What does this box with the words caution/warning/danger mean to you?
      (level of human health concerns).
  D. Which word reflects a product that is less hazardous, more hazardous?
  E. How do you feel about the presentation of the "caution" information?
     Which do you prefer? Why? (with and without bullet points)
328
The Newman Group, Ltd.
Household Cleaner Products
                                                                  October 11,1998

-------
         For products that are less hazardous than the caution ones with the bullet
         points, is there a word that would convey that to you? (careful, take care,
         low risk, beware, precaution)
      F.  Does a household cleaner product need to have all three words on the
         label if only one applies? Explain?
      G. What is your feeling about the vertical or horizontal presentation of this
         information?  Which do you prefer? Why?
      H. What does the gradation of the shading in the boxes corresponding to the
         words caution, warning, danger say to you? Is that a good idea?  Why?
      I.  Of all these labels I have shown you and the existing example do  any
         labels indicate a more hazardous product? (products with indicator pointed
         to Danger vs. pointed to Caution)
      J.  Would any of these caution/warning/danger formats encourage you to
         read more of the label or read the label more often? Which one? Why?
      K Would any of these caution/warning/danger help you to use a household
         cleaner more safely or effectively? Explain.

VIII.  Reaction to Label Standardization Initiative: Box Format (10 minutes)
      A. What do you  think about a standardized label format on all household
         cleaner products?  Is there an advantage to this? Any disadvantages?

         Now I would like you to look at these labels and specifically focus
         on the information grouped together in the boxes. (Box format)

      Show box format label prop boards together with existing example.

      B. Should boxes be used or not used on a label? Why?
      C. Does the box format make this information easier or more difficult to find
         on a household cleaner product?
      D. Does the box format make it possible to understand this information more
         quickly or less quickly?
      E. What information should be put into a box? Why? What information is
         most important to put into a box?
    ,  F. Which box format would encourage you to read more of the label or read
         the label more often?
      G. Could a product have too many boxes?
      H. Do you have any other suggestions on how to format this information
         that you would feel better about?
  IX.
Reaction to Logos (5 minutes)
Go back to easel lists
A. Why do we read labels on household cleaner products?
B. What might happen if we don't read the label on a household cleaner
   product?

(PARAPHRASE;
    The Newman Group, Ltd.
    Household Cleaner Products
                                                                 329

-------
          Both the manufacturers of these products and various government agencies
          want people to use products safely and effectively. One way to know how to
          use a product to its greatest effectiveness with out endangering children,
          health, pets, or the environment is to read the information on the label.
          Because of this, these companies and agencies would really like to encourage
          and remind people to read the label.
                                                               !
          One idea is to start a public service campaign to encourage people to read
          labels first.  In order to promote this campaign a logo needs to be developed
          that visually speaks to people.

          Does anyone remember the pubic service campaign used for car safety
          "buckle up for safety buckle up."
                   What was compelling about this message?
                   Did this have any emotional impact for you? Explain.
                   What about this slogan made you change your behavior?
          Read  the Label First Campaign
                   What about reading  the labels on household cleaners? How can we
                         get people to buy into this action?
                   What would be compelling?
                   What would be an emotional reason?
                                                               i
          Do you remember the logo for the buckle up for safety campaign?

          Show logos
          A. Which logo, if any, would be more compelling for you in a "read the label
              first campaign? Why? Are there any emotional ties to this?
          B.  What other factors or suggestions besides the slogan "read the label first
              and the logo" could be used to better motivate you to read product labels
              on household cleaner products?
          C. Would you be significantly more motivated to read the directions and
              precautions on the label of  household cleaner products if you understood
              that by doing so, it would allow you to use the product more safely and
              effectively?

        X. Closure (5 minutes!
           The manufacturers of these products want to make sure that they are giving
           people like you the information they need to choose the right products for
           your needs and how to safely use and dispose of products once you have
           brought them home. After reviewing all of this information today, what
           should my recommendations be to them?
330
The Newman Group, Ltd.
Household Cleaner Products
                                                                 October 11,1998

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          Discussion Guide CLI; Outdoor Pesticide  Products

  I.  Moderator Introduction (1 minute)
     Greet the respondents: We're talking to people today about the
     labels on products they to kill bugs and insects in their yard or garden. These
     are commonly called outdoor pesticide products.

     A. No wrong answers to any questions asked.
     B. All we want is to get honest feedback from you.
     C Explain taping and one way mirror

  II. Participant Introductions f4 minutes)
     Lef s start with you telling me something about yourselves.

     A. Name
     B. Occupation
     C. Married or single? Any children? Ages of children?

III.  Past Experience and Product Selection (10 m inuf«*s)
     Today we are going to be focusing our attention on the labels of
     products commonly called outdoor pesticides.
     A. Why do we read labels? (List on easel))
     B. Why don't we read labels? (List on easel)
     C. When do you read the label on outdoor pesticide products? What are you
       looking for? (probe: in the store prior  to purchase, at home prior to use, (other)
       don't read the label, why?
     B. How satisfied are you with the information currently available on the
       package of these products? Now I want to show you an example of an
       existing label. (Existing Example)
     E. Is the information on this label of outdoor pesticide product easy or
       difficult to understand? Explain what you mean by that.
     F. Is there any additional information you would like to see on the label of
       outdoor pesticide products?
     G. Are there any improvements you would like to see on the presentation or
       format of information on the label for outdoor pesticide products?
  The 'Newman Group, Ltd.
  Outdoor Pesticide Products
331

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         Understanding Ingredient Listings (15 minutes)
         A national study has been conducted with people like you about the
         information on the labels of outdoor pesticide products. From this study we
         learned that people want certain information about these products on the
         label. Some people like this information presented in one way and other
         people prefer it presented in a different way. I -would like you to" imagine that
         you are in a store ready to buy an outdoor pesticide product. I am going to
         show you several examples for labels. Remember, at any time you can choose
         the existing label example. We are now going to focus our attention on the
         ingredient listing on outdoor pesticide products.
                                                            i
         Show ingredient prop boards along with existing example
                                                            \
         A. What information do you need in the ingredient listing for an outdoor
            pesticide? Why do you need this information?
            IF FULL FORMULA ALREADY AVAILABLE TO POISON CONTROL
            WHAT INFO IS NECESSARY ON LABEL?  WHICH FORMAT IS
            PREFERRED? WHY?
         B. Do any of these formats make it easier for you to find the ingredient
            information you want?
         C. Of these examples, which format of the ingredient information do you feel
            better about? Why?
         D. Would any of these label examples help you to use an outdoor pesticide
            more safely or effectively? Explain.
         E. Do you have a preference for the ingredient information being presented
            on the front or back of the label? Why?
         F. Would any of these ingredient sections encourage you to read more of the
            label or read the label more often? Which one? Why?

      V. Understanding Precautionary Language (5 minutes)
         We are now going to focus our attention on the precautionary language used
         on outdoor pesticide product labels.  (Back Label)

         Show both precautionary label prop boards at same time, with existing example

         A. What information are you looking for in the precautionary statement
            section on a label for an outdoor pesticide ?
         B. Do any of these precaution examples provide you with any information
            that is more useful or easier to understand than the existing label?
         C. Of these examples, which format of the precautionary information do you
            feel better about? Why?
         D. Do these phrases or words mean the same thing or do they each mean
             something different- "Precautionary Statements", "Caution", "Hazard to
             humans and animals"
         E. Would any of these precautionary statements help you to use an outdoor
             pesticide more safely or effectively? Explain.
332
The Newman Group, Ltd.
Outdoor Pesticide Products
                                                               October 11,1998

-------
      R If it said "call poison control center where formula is registered" on the
         label, how would you feel about this? Could any information on the label
         be omitted if the formula was registered at poison control?
      F.  Would any of these precautionary language sections encourage you to
         read more of the label or read the label more often? Which one? Why?

 VI. Understanding Usage and Directions (20 mitiufpp)
      We are now going to focus our attention on the directions for use on outdoor
      pesticide  product labels.

      Show both directions for use prop boards and existing example.

      A.  What information are you looking for in the direction for use section on a
         label for outdoor pesticide ?
      B.  Do any of these directions for use examples provide you with any
         information that is more useful or easier to understand than the existing

      C.  Of these examples, which format for the directions for use information do
         you feel better about? Why? (Probe numbers and bullets)
      D.  Does a certain format make you think the outdoor pesticide product will
        be easier to use?
      E. Would your perception of an outdoor pesticide product be changed by
        either of these directions for use sections? Explain.
        What is your feeling about the section labeled "responsible use".
      F. Would any of these directions for use sections help you to use an outdoor
        pesticide more safely or effectively?  Explain.'
      G. Would any of these directions for use sections encourage you to read more
        of the label or read the label more often? Which one? Why?
VIL
     SHOW PAIRED STATEMENTS AND GET REACTION
Understanding Signal Words (10 minutes)
We are now going to focus our attention on the sienal words used on outdoor
pesticide product labels, (label front only)

Show label prop boards (4 examples)

A. Have you ever seen anything like this before? (focus on signal words)
B. How do you feel about this format (three words in a box)  compared to the
   format on the existing label (caution)?
C. What does this box with the words caution/warning/danger mean to you?
   (level of human health concerns).
D. Which word reflects a product that is less hazardous, more hazardous?
E. How do you feel about the presentation of the "caution" information?
   Which do you prefer? Why? (with and without bullet points)
  The Newman Group, Ltd.
  Outdoor Pesticide Products
                                                                 333

-------
              For products that are less hazardous than the caution ones with the bullet
              points, is there a word that would convey that to you? (careful, take care,
              law risk, beware, precaution)
           F. Does a outdoor pesticide product need to have all three words on the label
              if only one applies? Explain?
           G. What is your feeling about the vertical or horizontal presentation of this
              information? Which do you prefer? Why?
           H. What does the gradation of the shading in the boxes corresponding to the
              words caution, warning, danger say to you? Is that a good idea? Why?
           I.  Of all these labels I have shown you and the existing example do any
              labels indicate a more hazardous product? (products with indicator pointed
              to Danger vs. pointed to Caution)
           J.  Would any of these caution/warning/danger formats encourage you to
              read more of the label or read the label more often? Which one? Why?
           K. Would any of these caution/warning/danger help you to use an outdoor
              pesticide more safely or effectively? Explain.
           Reaction to Label Standardization Initiative: Box Format (10 minutes)
           A. What do you think about a standardized label format on all outdoor
              pesticide products? Is there an advantage to this? Any disadvantages?
                                                               i      ,  '..,.•
                                                           .• .  i       • •
              Now I would like you to look at these labels and specifically focus
              on the information grouped together in the boxes. (Box format)

           Show box format label prop boards together with existing example.

           B. Should boxes be used or not used on a label? Why?
           C. Does the box format make-this information easier or more difficult to find
              on a outdoor pesticide product?
           D. Does the box format make it possible to understand this information more
              quickly or less quickly?
           E. What information should be put into a box? Why? What information is
              most important to,put into a box?
           F. Which box format would encourage you to read more of the label or read
              the label more of ten?
           G. Could a product have too many boxes?
           H. Do you have any other suggestions on how to format this information
              that you would feel better about?
            Reaction to Logos (5 minutes)
            Go back to easel lists
            A. Why do we read labels on outdoor pesticide products?
            B. What might happen if we don't read the label on a outdoor pesticide
               product?

            (PARAPHRASE)
334
The Newman Group, Ltd.
Outdoor Pesticide Products
                                                                  October 11,1998

-------
   Both the manufacturers of these products and various government agencies
   want people to use products safely and effectively. One way to know how to
   use a product to its greatest effectiveness with out endangering children,
   health, pets, or the environment is to read the information on the label.
   Because of this, these companies and agencies would really like to encourage
   and remind people to read the label.

   One idea is to start a public service campaign to encourage people to read
   labels first.  In order to promote this campaign a logo needs to be developed
   that visually speaks to people.

   Does anyone remember the pubic service campaign used for car safety
   "buckle up for safety buckle up."
            What was compelling about this message?
            Did this have any emotional impact for you? Explain.
            What about this slogan made you change your behavior?
   Read the Label First Campaign
            What about reading the labels on outdoor pesticides? How can we
      get people to buy into this action?
            What would be compelling?
            What would be an emotional reason?

   Do you remember the logo for the buckle up for safety campaign?

   Show logos
   A. Which logo, if any, would be more compelling for you in a "read the label
      first campaign? Why?  Are there any emotional ties to this?
   B. What other factors or suggestions besides the slogan "read the label first
      and the logo" could be used to better motivate you to read product labels
      on outdoor pesticide products?
   C. Would you be significantly more motivated to read the directions and
      precautions on the label of outdoor pesticide products if you understood
      that by doing so, it would allow you to use the product more safely and
      effectively?

X. Closure (5 minutes)
   The manufacturers of these products want to make sure that they are giving
   people like you the information they need to choose the right products for
   your needs and how to safely use and dispose of products once  you have
   brought them home. After reviewing all of this information today, what
   should my recommendations be to them?
The Newman Group, Ltd.
Outdoor Pesticide Products
335

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         Appendix 3-3:
Signal Meter Mock Label
                 337

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-------
339

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340

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               Appendix 3-4:
Outdoor Pesticides Mock Label
                       341

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                         Weed Killer
      Kills Weeds - Not Lawn Grasses
      KILLS: Dandelion, Qmr, Plantain,
      Cnkkweed, Oxalis, Spurge, Henbit,
      English Daisy, WiM Onion and
      Many Otter Listed Weeds
      KEEP OUT OF REACH OF CHILDREN
      CAUTION
      NE CONTENTS 1 GAL/3.78 L
TTiis /J&«; /s « repmstnation of the Mentation seen on real  I
 products, but does not accurately duplicate a nal brand.   \
342

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                                    Ri.illove ipiifct r. Pull
                                    mill All mi WftY OUT
                              Weed Killer.
                              Kills broadteaf weeds in Isms-roots and all Kills weeds, not lawn grasses when used according to
                              directions. Ready-toilse. No Mixing.

KILLS- BurCtover, Carpetweeds, Chickweeds, Creeping Charlie, Cudweed, CurifDock Dandelion. English Daisy, ^Dandelion,
Filaree Florida Pusley, HearteafDrymary, Henbit Oxalis, Pennywort, Plantains, Purslane, RedSorrel, Sheep Sorrel, Spurges,
Thistles, Toadfiax, White Clover, Wild Carrot, Wild Geranium, Wild Onion.
DIRECTIONS FOR USE                         .        _^
It is a violation of Federal tw to we this product in a manner mconsstent with
its labeling.
HEM STORE UBEL USE STRICTLY IN ACCORDANCE WITH LABEL
PRECAUTIONARY STATEMENTS AND DIRECTIONS.
HOW TO USE Turn sprayer nor* to open. Adjust nosle to give a coarse spray.
Aim at center ol weed and spray to wet Spray any time weeds affectively   .
drawing Do not apply when rain or temperatures over 8s Fare expected within
24 hours. Hard to control weeds may require repeat application in 2 to 3 weens.
Weeds in newly seeded lawns may be sprayed alter lawn has been mowed
3 times.
IMPORTANT: Do not use this product for controlling weeds in vegetable gardens,
flower beds or around shrubs or ornamental plants. Temporary discoloration
 may occur on St Augustine. Centipede, and Bentgrass lawns.

 STORAGE AND DISPOSAL
 STORAGE: Flip down spout to dose. NO NEED
 TO DISCONNECT TRIGGER SPRAYER. Close node
 on trigger sprayer. Snap sprayer back in place. Keep
 from freezing. Keep pesticide n original container.
 Do not put concentrate or dilute into food or drink
 containers. Avoid contamination of feed and
 foodstuffs. Store in a eooL dry place, preferably in a

  DISPOSAL?PRODUCT - Partially filled bottle may be disposed of by securely
 wrapping  original container in several layers of newspaper and dsard in
 trash. CONTAINER - Do not reuse empty container. Wrap container and put
  in trash.
 PRECAUTIONARY STATEMENTS
 HAZARDS TO HUMANS t DOMESTIC ANIMALS  •
 CAUTION: Harmful if absorbed through skin. APPLYING: When applying this
 product wear goggles or face shield, long pants, long sleeved shirt, socks, shoes,
 and chemical resistant gloves. Wash nondisposabte gloves thoroughly with soap
 and water before removing. Remove contaminated clothing and launder
 separately before reuse. Promptly and thoroughly wash hands and exposed stan
' with soap and water after using this product. Remove saturated dothing as soon
 as possible and shower.
   • ..  .  Do not allow others such as children and pets on treatment ana
  Tr^  during application or to reenter treated anas until spray has dned.
 RRST AID: If on sldn. wash with plenty of soap and water. Note to Physicians:
 Emergency information ca81-SOMOu-OOCO.
 ENVIRONMENTAL HAZARDS: This product is toxic to aquatic invertebrates. Drift
 or runoff may adversely affect aquatic invertebrates and nonttiBet plants. Do not
 apply directly to water. Exercise caution when disposing of waste as groundwater
 contamination may result from careless handling or spills. Do not contamrale
 water when disposing of equipment washwaters.
  NOTICE: Buyer assumes all responsibility tor safely and use not in accoidance
 with directions.
           «N*ol WKnlM al HOH5WHS
           rn*d UraM nO 1-M4S-BS
  8TnOBrart ol TM Weed Coraany
  Mvuboumlfr
  ThsWMdtareuny
  lOOMwSme
  «flyMmUSAt2M5
  EPA too-No. 0004000
  EWEaOOMW-1    MideinUSA
                                                                                                           This latial is a rtpnsenation at to
                                                                                                             products, but does not accurate
                                                                                     i SM/I on real
                                                                                     inalbiand.

-------
                                                £CTng«gKS%m^ai^'Mc=aSa=M«ai.:rr±arSsacgrac=aM^-S
                                                                     l*is£?i&£&l£*££Z**s£iS

      mwBrSfflffitt
                      Weed Killer
    Kills Weeds - Not Lawn Grasses
    KILLS: Dandelion, Clover, Plantain,
    Chtctoveed, Oxalis, Spurge, Henbit, •
    English Daisy, Wild Onion and
    Many Other Listed Weeds
    For Home Lawns Only
                        ..100.00%
     •2.4-0 aoa eowifert. sxnef sxctc trf AOAC
     KEEP OUT OF REACH OF CHILDREN
m  CAUTION
 m  NET CONTENTS 1 GAL/3.78 L


                                                                             TTr/s tefis/ /s a representation of the intornation seen on ml  I
                                                                              products, but does not accurately duplicate t real bond.   I
                                                                                                                   Front -
344

-------
                                                                                                                                                                    Back-
                                     Remove sprayer. Pull
                                     rmrlAII  THE WAY OUT.
                              Wed Killer.
                                                                       Insert red plug into spout'
                                                                       (on cap) until it clicks.
                                                                                                         Flip up spout Open
                                                                                                         nozzle at end ol sprayer.
                              Kills broadleaf weeds in lawns- roots and all. Kills weeds, not lawn grasses when used according to
                              directions. Ready-to-Use. No Mixing.

KILLS' Bur Oom Carpetweeds, Chickweeds, Creeping Charlie, Cudweed, Curly Dock, Dandslion, English Daisy, False'Dandelion,
Filaree HoridiiPusley, Heartleaf Drymary, Henbit. Oxalis, Pennywort, Plantains, Purslane, Red Sorrel, Sheep Sorrel, Spurges,
Thistles, Toadflax, White Clover. Wild Carrot. Wild Geranium, Wild Onion.
DIRECTIONS FOR USE                          .     .....
It is a violation of Federal law to use this product in a manner inconsistent with
its labeling.   .
READ ENTIRE LABa. USE STRICTLY IN ACCORDANCE WITH LABa
PRECAUTIONARY STATEMENTS AND DIRECTIONS.
HOW TO USE: Turn sprayer nozzle to open. Adjust nozzle to give a coarse spray.
Aim at center of weed and spray to wet Spray any time weeos are actively
crowing Do not apply when ram or temperatures over 85V are expected within
24 hours  Hard to control weeds may require repeat application in 2 to 3weeks.
Weeds in newly seeded lawns may be sprayed after lawn has been mowed
Slimes.         ,.      .   .
IMPORTANT: Do not use this product for controlling weeds in vegetable gardens.
flower beds or around shrubs or ornamental plants. Temporary discoloration
may occur on St Augustine. Centipede, and Bentgrass iawns.

 STORAGE AND  DISPOSAL
 STORAGE' Rip down spout to close. NO NEED
 TO DISCONNECT TRIGGER SPRAYER. Close nozzle
 on trigger sprayer. Snap sprayer back in place. Keep
 from freezing. Keep pesticide in original container.
 Do not put concentrate or dilute into food or draw
 containers. Avoid contamination of feed and
 foodstuffs. Store in a cool, dry place, preferably in a

  DISPOSAL: PRODUCT -Partially filled bottle may be disposed of by securely
  wrapping original container in several layers of newspaper and discard in
  trash CONTAINER -Do npt reuse empty  container. Wrap container and put
  in trash.       •;
                                                                    PRECAUTIONARY STATEMENTS
                                                                    HAZARDS TO HUMANS & DOMESTIC ANIMALS
                                                                    CAUTION: Harmful if absorbed through skin. APPLYING: When applying this
                                                                    product wear goggles or face shield, long pants, long steeved shirt, socks, shoes.
                                                                    and chemical resistant gloves. Wash nondisposabte gloves thoroughly with soap
                                                                    and water before removing. Remove contaminated clothing and launder
                                                                    separately before reuse. Promptly and thoroughly wash hands and exposeo skin
                                                                    with soap and water after using this product Remove saturated clothing as soon
                                                                    as possible and shower.
                                                                      •  .   .  DO not allow others such as children and pets on treatment area
                                                                     Trl  during application or to reenter treated areas until spray has dned.
                                                                     RUST AID: If on skin, wash with plenty of soap and water. Note to Physicians:
                                                                     Emergency Information call 1-8(XHXKHX)00.
                                                                     ENVIRONMENTAL HAZARDS: This product is toxic to aquatic invertebrates. Drift
                                                                     or runoff may adversely affect aquatic invertebrates and nontarget plants. Dp not
                                                                     apply directly to water. Exercise caution when disposing of waste as groundwater
                                                                     contamination may result from careless handling or spills. Do not contaminate
                                                                     water when disposing of equipment washwaters.
                                                                     NOTICE: Buyer assumes all responsibility for safely and use not in accordance
                                                                     with directions.                                     	

                                                                     tfSfc  MrifcilMKintlMCilH-eOO-SS-SSS
                                                                      MM  ftwtelWoniallBiain-MO-555-SSS
                                                                     ®Tn
-------
                                                                                                                                    Front
              sifaatiim
                              Weed Killer
           WMltiilkH
           _ •••	i_   tt_i i .._.._ f
•/fy.'f/iMf /•/*?;•
Kills Weeds - Not Lawn Grasses
            ion Clover Plantain
           s         -
        KILLS: Dandelion, Clover, Plantain,
        Chickweed, Oxalis, Spurge, Henbit,
KILLS: uanaeiion, mover, m
Chickweed, Oxalis, Spurge, He
English Daisy, Wild Onion and
                 ,     ,
        English Daisy, Wild Onion
        Many Other Listed Weeds
             ne Lawns On
        faHvt lnjitiStite
        2. 4-0 (2. J-dcttoncnefloxyiatc Kid.
         (Xnetnyanwie s«) -----------  0.20%
             ----
 . -  .  -               .
 (Xnetnyanwie s«) ----------- 0.20%
MCPA |Z-(2-Me«yt-l-cl*xo[)(io»xy)
 profmofle add. ftmesulanww olt| --- 020%
OOHrtagndintc ........ - ................... 98.18%
OWf nndiaiB ant Water. (Hyonn (to keto
                 .           ---
        OOHrtagndintc ........ - ................... 9
        OWf ngndiaiB ant Water. (Hyonn (to keto
        tntoa Iron treeaig). saUconts do koo
        safcfctf (to teg product orn aoarag.
        soiywi (tes tun 1%, to flssoNt acs«
        ingndensi.preMiviM (less tun 0.1%)   _
        mil ,«.H.....»«.««»»M .......... «..«... 100.00%
        •.(cfetrA(WC
 •2.<.DJOd«iMfl.iSWOTS
 MeiKX! 6575 0.16%
 "MCPA sod eqimalaS: 0 17%
        "MCPA sod eqimalaS: 0 17%

        KEEP OUT OF REACH OF CHILDREN
346
                                                                                          JTi/s label is a representation ot the information seen on real  I
                                                                                           products, but does not accurately duplicate a real brand.   \

-------
                                                                                                                                                                       Back-
                                      Remove sprayer. Pull
                                      cnitlAllTHEWAYOUT.
                               Weed Killer.
                                                                       Insert red plug into spout
                                                                       (on cap) until it clicks.
                                                                                                          Flip up spout Open
                                                                                                          nozzle at end of sprayer.
                               Kills broadleat weeds in lams - mots and all. Kills weeds, not lawn grasses when used according to
                               directions. Ready-to-Use. No Mixing.

KILLS: Bur Clover, Carpetweeds, Chickweeds, Creeping Charlie, Cudweed, Curiy Dock, Dandelion, English Daisy, False Dandelion,
Rlaree, Florida Pusley, HeartleafDrymary, Henbit, Oxalis, Pennywort, Plantains, Purslane, Red Sorrel, Sheep Sorrel. Spurges,
Thistles, Toadflax, White Clover, Wild Carrot, Wild Geranium, Wild Onion.	
DIRECTIONS FOR USE
It is a violation of Federal law to use this product in a manner inconsistent with
its labeling.
READ ENTIRE IABE. USE STRICTLY IN ACCORDANCE WITH LABa
PRECAUTIONARY STATEMENTS AND DIRECTIONS.
HOW TO USE: Turn sprayer nozzle to open. Adjust nozzle to give a coarse spray.
Aim at center of weed and spray to wet. Spray any time weeds are actively
growing. Do not apply when ram or temperatures over 8if F are expected within
24 hours. Hard to control weeds may require repeat application in 2 to 3 weeks.
Weeds in newly seeded lawns may be sprayed after lawn has been mowed
3 times.
IMPORTANT: Do not use this product for controlling weeds in vegetable gardens.
flower beds or around shrubs oromamental plants. Temporary discoloration
may occur on St. Augustine, Centipede, and Bentgrass lawns.

STORAGE AND DISPOSAL
 STORAGE: Flip down'spoutto close. NO NEED
TO DISCONNECT TRIGGER SPRAYER. Close nozzle
 on trigger sprayer. Snap sprayer back in place. Keep
 from freezing. Keep pesticide in original container.
 Do not put concentrate or dilute into food or drink
 containers. Avoid contamination of feed and
 foodstuffs. Store in a cool, dry place, preferably in a
 locked storage area.                     .
 DISPOSAL PRODUCT - Partially filled bottle may be disposed of by securely
 wrapping original container in several layers of newspaper and discard in
 trash. CONTAINER - Do not reuse empty container. Wrap container and put
 in trash.
PRECAUTIONARY STATEMENTS
HAZARDS TO HUMANS & DOMESTIC ANIMALS
CAUTION: Harmful if absorbed through skin. APPLYING: When applying this
product wear goggles or face shield, long pants, long sleeved shirt, socks, shoes.
and chemical resistant gloves. Wash nondisposat* gloves thoroughly with soap
and water before removing. Remove contaminated clothing and launder
separately before reuse. Promptly and thoroughly wash hands and exposed skin
with soap and water after using this product. Remove saturated clothing as soon
as possible and shower.
  • .  .  Do not allow others such as children and pets on treatment area
 TTl  during application or to reenter treated areas until spray has dried.
FIRST AID: If on skin, wash with plenty of soap and water. Note to Physicians:
Emergency Information call 1-80CHKXHXX10.
ENVIRONMENTAL HAZARDS: This product is toxic to aquatic invertebrates. Drift
or runoff may adversely affect aquatic invertebrates and nontarget plants. Do not
apply directly to water. Exercise caution when disposing of waste as groundwater
contamination may  result from careless handling or spills. Do not contaminate
water when disposing of equipment washwaters.
 NOTICE: Buyer assumes all responsibility for safely and use not in accordance
with directions.
          SMttiol MenaBM all 1400-555-5555
          Product Moraafen tin 1-MO-555-5555
 (STnwmam of The Weed Company

 MaruHcuredty
 The Weed Company
 100 Man Street
 Anywntre USA 12345
 EPA Reg. No. 0000000
 EPAEslOOO-AW-1     Ml* h USA
                                                                                                               This label is a represent,
                                                                                                                 products, but does no
                                                                                                                                                       347

-------
                  .
                    Weed Killer
Kills Weeds - Not Lawn Grasses
KILLS: Dandelion, Clover, Plantain,
Chicfoveed, Oxalis, Spurge, Henbit,
English Daisy, Wild Onion and
Many Other Listed Weeds
 KEEP OUT OF REACH OF CHILDREN
                »>iMlf*i«lti
                irriUU««a
                GAL/3.78


                                                                          This label is t representation of the information seen on real I
                                                                           products, but does not accurately duplicate a real brand.   I

-------
                                                                                                                                                                                  Back-
 GflNNE&T
 SfaRTAMER
                                 Kills broadleaf weeds in lawns - roots and all. Kills weeds, not tiwn grasses when used according to
                                 directions. Ready-to-Use. No Mixing.

KILLS: Bur Clover, Carpetweeds, Chiclnveeds, Creeping Charlie, Cudweed, Curly Dock, Dandelion, English Daisy, False Dandelion,
Rlaree, Florida Pusley, Heartleat Drymary, Henbit, Oxalis,  Pennywort Plantains, Purslane, Red Sorrel, Sheep Sorrel, Spurges,
Thistles, Toadflax. White Clover, Wild Carrot, Wild Geranium, Wild Onion.
DIRECTIONS FOR USE
It ts i violation ol Federal law to use mis product in i manner inconsistent with IB labeling.
READ ENTIRELABEL USE STRICTLY HI ACCORDANCE WITH LAia PRECAUTIONARY
STATEMENTS AND DIRECTIONS.
HOW TO USE: Turn sprayer none to open. Adjust nose to owe i coarse stray. Aim it center
ol weed ind spray to wet Spray jny tme weeds ire arawy growing. Do not apply when ram
or temperatures over 85"F are expected within 24 noun hard to control weeds may reouire
repeat application in 2 to 3 weeks. Weeds in newly seeded liwns may be sprayed alter lawn
lias been moved 3 times.
IMPORTANT: Do not use ttiis product lor controlling weeds in vegetable gardens. Dower beds
or around stums or ornamental pants. Temporary discoloration may occur on SI Augustine.
Centipede, and Bentgrass lawns.
STORAGE AND DISPOSAL
STORAGE: Flip down spout to dose. HO MEED TO DISCONNECT
TRIGGER SPRAYER. Close none on Bigger sprayer. Snap
sprayer pack in place. Keep from freezing. Keep pestose in
ongtnaJ container. Do not put concentrate or dilute into rood Of
dnnk containers. Avoid comunmiBon ol feed and foodstuffs.
Store in a cool, dry Place, preferably in a locked storage area.
DISPOSAL PRODUCT - Partially filed bottle may be disposed
ol Dy securely wrapping ongnal container m several livers ol
newspaper and discard in trasn. CONTAINER - Do not raise
empty container. Wrap conaner and put in tnsn.

PRECAUTIONARY STATEMENTS
HAZARDS TO HUMANS* DOMESTIC ANIMALS
CAUTION: Harmful it absorbed trirougn skin. APPLYING: When ipplyng Iris product wear
oogoiKortiasrield.lorflMmlorflSler^sliasoao.srces.j«]amimn!asttit
gloves. Wasn nonosKsitxe gloves moroughiy witn soap and water before removng.
 Remove conannated Botrtng and launder sepinlely Delore reuse. Promptly and tnorougtiV
wisn Hinos and exposed skin wim soap and water after using mis product. Remove saturated
doming as soon as possible and snowsr.
           DonotaowoaierssiiciiJSctildrBijrOMtsontreamEntiraounrfl
           apptaam or to ranter treated ireas until spray tusdned.
FIRST AID: It on skm. wasti wim plenty of soap and water. Note a Pnyslcans: Emeroency
IrtonraBon cat 1-atKMX30-0000.
ENVIRONMENTAL HAZARDS: Tns product is loac ffl muaDc imerteorates. Dntt of tunotf
Exerase caution wnen disposing ol waste is groundwiter conamiuoon may result from cart-
tes randing or splits. Do not contaminate water wnen disposing of eouipmeffl wisttwiters.
NOTICE: Buyer assumes al responsilnlity tor s^ely and use not n accoidance with ureoors.
Artntnoredllrtl:
2.4-D(2.4-rjicrMrooneraiyacetciad.dimei)iylainriesalt| ___   0.20%
                                                                0.20%
                                                              98.60%
Otner mgrediens are Water, glycem (to keep product from treeangi. surtacants (to kseo
me icove ngredoit dispersed r witer). stabiizer (to keep proouct from separating).
solvent (less man tV to Ussorvt lone ingredients), preservative {less man 0.1%)
Titji ________________________ ; _____________________________________ 100.00%
•2.4-0 acid eaiwiloiL isomer specific ty AOAC Metnod 6^7i 0.1 6%
"MCPAlddeqiMWitatTT.
VSy*  Mt«cilMeniataiall1400-555-SSS5
 ••   Pradud Moranboa all 1400-555-5555
STrademiik ot Tne Weed Company
Manufactured by
The Weed Company
100 Main Street
Anywnere USA 12345
EPA Reg. No. 000-0000
EPAEstOOO-AW-1     MidenUSA

                                                                                                                     This label is a reprcsen
                                                                                                                       products, but does m
                                                                                                                                                              349

-------
                                         smss^^^^^^^^^^^^^^^^^sffs^.

                                         e-nfifiawlMtijr '-'*—~-=E=—-—^-..-    -. -^ff.:—:—aa.-jj

afflsafaaagggtEggqac-asis
          'Brffllffl
                   Weed Killer
   Kills Weeds - Not Lawn Grasses
   KILLS: Dandelion, Clover, Plantain,
   Cnickweed, Oxalis, Spurge, Henbit,
   English Daisy, Wild Onion and
   Many Other Listed Weeds
   KEEP OUT OF REACH OF CHILDREN

77i/s label is a representation of the information seen on real  I
                                 \
                                                                products, but does not accurately duplicate a ml bond

-------
                                                                                                                                                                    Back-
    ONNEll
                                     Remove sprayer. Pull
                                     rnrtl Jl I THE WAY OUT.
                                                                      Insert red plug into spout
                                                                      (on cap) until it .clicks.
                                                                                                        Hip up spout Open
                                                                                                        nozzle at end at sprayer.
                              WeedKiller	
                              Kills broadleaf weeds in lawns - roots and all. Kills weeds, not lawn grasses when used according to
                              directions. Ready-to-Use. No Mixing.
KILLS' Bur Clover, Carpetweeds, Chickweeds,  Creeping Charlie, Cudweed, Curly Dock, Dandelion, English Daisy, False Dandelion,.
Filaree Florida Pusley, Heartleat Drymary, Henbit, Oxalis, Pennywort, Plantains, Purslane, Red Sorrel, Sheep Sorrel, Spurges,
Thistles, Toadflax, White Clover, Wild Carrot, Wild Geranium, Wild Onion.	__^_^_^—-^——
DIRECTIONS FOR USE
jt is a violation of Federal law to use this produrt in a manner inconsistent with
its labeling.
READ EHTIRE USB.. USE STRICTLY IN ACCORDANCE WITH LABEL
PRECAUTIONARY STATEMENTS AND DIRECTIONS.
HOW TO USE: Turn sprayer nozzle to open. Adjust nozzle to give a coarse spray.
Aim at center ot weed and spray to wet. Spray any time weeds are actively
growing. Do not apply when rain or temperatures over 85'F are expected within
24 hours. Hard to control weeds may require repeat application in 2 to 3 weeks.
Weeds in newly seeded lawns may be sprayed alter lawn has been mowed
3 times.
IMPORTANT: Do not use this product for controlling weeds in vegetable gardens,
flower beds or around shrubs or ornamental plants. Temporary discoloration
 may occur on St. Augustine. Centipede, and Bentgrass lawns.

 STORAGE AND DISPOSAL
 STORAGE: Flip down spout to close. NO NEED
 TO DISCONNECT TRIGGER SPRAYER. Close nozzle
 on trigger sprayer. Snap sprayer back in place. Keep
 from freezing. Keep pesticide in original container.
 Do not put concentrate or dilute into food or drink
 containers. Avoid contamination of feed and
 foodstuffs. Store in a cool, dry place, preferably in a

 DISPOSAL PRODUCT - Partially filled bottle nay be disposed of by securely
 wrapping original container in several layers of newspaper and discard  in
 trash. CONTAINER - Do not reuse empty container. Wrap container and put
 in trash.
PRECAUTIONARY STATEMENTS
HAZARDS TO HUMANS & DOMESTIC ANIMALS
CAUTION: Harmful if absorbed through skin. APPLYING: When applying this
product wear goggles or face shield, long pants, long sleeved shirt, socks, shoes.
and chemical resistant gloves. Wash nondisoosabte gloves thoroughly with soap
and water before removing. Remove contaminated clothing and launder
separately before reuse. Promptly and thoroughly wash hands and exposed skin
with soap and water after using this product Remove saturated clothing as soon
as possible and shower.
  • .  .  Do not allow others such as children and pets on treatment area
Tr^  during application or to teenier treated areas until spray has dried.
RRST AID: II on skin, wash with plenty of soap and water. Note to Physicians:
Emergency Information call 1-800-000-0000.
ENVIRONMENTAL HAZARDS: This product is toxic to aquatic invertebrates. Drift
or runoff may adversely affect aquatic invertebrates and nontarget plants. Do not
apply directly to water. Exercise caution when disposing of waste as groundwater
contamination may result from careless handling or spills. Do not contaminate
water when disposing of equipment washwaters.
NOTICE: Buyer assumes all responsibility tor safely and use not in accordance
with directions.                	__^__^_^^_

          SMtdlal MociMltai al HOfrBS-5555
          hriud ItfwraalBO aB I-W&S-SSS
 ^Trademark of The Weed Company
 ManulaawKltjy
 The weed Company
 100 Main Siren
 Anywnere USA 12345
 EPA Reg. No. 000-0000
 EPAEslOOO-AW-1    Mad! i) USA
                                                                   •£0-5
                                                                                                              This label is a represents:
                                                                                                                products, but does not
                                                                                  351

-------
                                                                                                                  Front


                     Weed Killer
Kills Weeds - Not Lawn Grasses
KILLS: Dandelion, Clover, Plantain,
Chickweed, Oxalis. Spurge, Henbit,
English Daisy, Wild Onion and
Many Other Listed Weeds
For Home uwns Only
"MCBA aod numieit 3.17%
KEEP OUT OF REACH OF CHILDREN
  E'j.iy.iai
  iv   tn  I
NET CONTENTS 1 GAL/3.78 L
                                                                            ^i ^_ ie_gCM|gaJg: Jagn&*g^sna<
                                                                           TTi/s label is a representation of the information seen on real
                                                                            products, but does not accurately duplicate a real brand.

-------
                                                                                                                                                                     Back-
                              Weed Killer
                              Kills broadleaf weeds in lawns - roots and all. Kills weeds, not lawn grasses when used according to
                              directions. Ready-to-Use. No Mixing.

KILLS- Bur Clover, Carpetweeds, Chickweeds, Creeping Charlie,  Cudweed, Curly Dock, Dandelion, English Daisy, False Dandelion,
Filaree, Florida Pusley, Heartleaf Drymary, Henbit, Oxalis, Pennywort, Plantains, Purslane, Red Sorrel, Sheep Sorrel, Spurges,
Thistles, Toadflax. White Clover. Wild Carrot, Wild Geranium, Wild Oniori	_____^^____
DIRECTIONS FOR USE
It is a violation of Federal law to use this product in a manner inconsistent with
its labeling.
READ ENTIRE LABa. USE STRICTLY IN ACCORDANCE WITH LABa
PRECAUTIONARY STATEMENTS AND DIRECTIONS.
HOW TO USE: Turn sprayer nozzle to open. Adjust nozzle to give a coarse spray.
Aim at center of weed and spray to wet Spray any time weeds are actively
growing. Do got apply when rain or temperatures over 85°F are expected within
24 hours. Hard to control weeds may reauire repeat application in 2 to 3 weeks.
Weeds in newly seeded lawns may be sprayed alter awn has been mowed
3 times.
IMPORTANT: Do not use this product tor controlling weeds in vegetable gardens,
flower beds or around shrubs or ornamental plants. Temporary discoloration
may occur on St. Augustine. Centipede, and Bentgrass lawns.

STORAGE AND  DISPOSAL
 STORAGE: Rip down spout to close. NO NEED
TO DISCONNECT TRIGGER SPRAYER. Close nozzle
 on trigger sprayer. Snap sprayer back in place. Keep
 from freezing. Keep pesticide in original container.
 Do not put concentrate or dilute into food or drink
 containers. Avoid contamination of feed and
 foodstuffs. Store in a cool, dry place, preferably in a
  locked storage area.
  DISPOSAL PRODUCT - Partially filled bottle may be disposed  of by securely
  wrapping original container in several layers of newspaper and  discard in
  trash. CONTAINER - Do  not reuse empty container. Wrap container and put
  in trash.
PRECAUTIONARY STATEMENTS
HAZARDS TO HUMANS & DOMESTIC ANIMALS
CAUTION: Harmful if absorbed through skin. APPLYING: When applying this
product wear goggles or face shield, long pants, long sleeved shirt, socks, shoes.
and chemical resistant gloves. Wash nondisposable gloves thoroughly with soap
and water before removing. Remove contaminated clothing and launder
separately before reuse. Promptly and thoroughly wash hands and exposed skin
with soap and water after using this product Remove saturated clothing as soon
as possible and shower.
  • .  .  DO not allow others such as children and pets on treatment area
 T  Hi  during application or to reenter treated areas until spray has dried.
FIRST AID: It on skin, wash with plenty of soap and water. Note to Physicians:
Emergency Information call 1-8W-000-0000.
ENVIRONMENTAL HAZARDS: This product is toxic to aquatic invertebrates. Drift
or runoff may adversely affect aquatc invertebrates and nontarget plants. Do not
apply directly to water. Exercise caution when disposing of waste as groundwater
contamination may result from careless handling or spills. Do not contaminate
water when disposing of equipment washwaters.
 NOTICE: Buyer assumes all responsibility for safely and use not in accordance
with directions.
 ^k   Predud imwnaUoo all 1-«00-555-5555
 STnOEmirk of Tne Wad Company
 Manufactured by
 TteWeedCompiny
 100 Main StiMl
 Anywnere USA 12345
 EPA Reg. No. 000-0000
 EPAEaOOMW-1    MadeilUSA	
                                       o'^ooooo"

                                                                                                              This label is a represen
                                                                                                                products, but doss n
                                                                                353

-------
                                                                                                                      Front
                      Weed Killer
Kills Weeds - Not Lawn Grasses
KILLS: Dandelion, Clover, Plantain,
Chickweed, Oxalis, Spurge, Henbit,
English Daisy, Wild Onion and
Many Other Listed Weeds
For Home Lawns Only
Z,4-Oi*ii«»iytim«)esir
MCW.SroWiyamoear'
OowtowaJieiS	9960%
             .	.108.MY.
•J.4-0 >od JCUMKnl Bomtf sceofic 6y AOAC
  cnxl&27S,ai§%
"MCM JOS Muvarnt 0.17".
KEEP OUT OF REACH OF CHILDREN
    CONTENTS 1 GAL/3.78


                                                                              77)/s label is a representation of the information seen on real
                                                                               products, but does not accurately duplicate a real brand.

-------
                                                                                                                                                                                   Back-
                                                 Remove sprayer. Pull
                                          Weed Killer.
                                                                                  Insert red plug into spout
                                                                                  (on op) until it dicks.
                                                                                                                     Flip up spout. Open
                                                                                                                     nozzle at end ol sprayer.
                                         Kills broadleaf weeds in lawns - roots and all. Kills weeds, not lawn grasses when used according to
                                         directions. Ready-to-Use. No Mixing.

          KILLS: Bur Clover, Carpetweeds, Chickweeds, Creeping Charlie, Cudweed, Curly Dock, Dandelion, English Daisy, False Dandelion,
          Filaree, Rorida Pusley, Heartleaf Drymary, Henbit, Qxalis, Pennywort, Plantains, Purslane, Red Sorrel, Sheep Sorrel, Spurges,
          Thistles. Toadflax, White Clover, Wild Carrot, Wild Geranium, Wild Onion.                                      	
          DIRECTIONS FOR USE
          It is a violation of Federal law to use this product in a manner inconsistent with
          its labeling.
          READ ENTIRE UBR. USE STRICTLY IN ACCORDANCE WITH LABa
          PRECAUTIONARY STATEMENTS AND DIRECTIONS.
          HOW TO USE: Turn sprayer nozzle to open. Adjust nozzle to give i coarse spray.
          Aim at center of weed and spray to wet Spray any time weeos are actively
          growing. Do not apply when rain or temperatures over 85"F are expected within
          24 hours. Hard to control weeds may require repeat application in 2 to 3 weeks.
          Weeds in newly seeded lawns may be sprayed after lawn has been mowed
          3 times.
          IMPORTANT: Do not use this product for controlling weeds in vegetable gardens.
          flower beds or around shrubs or ornamental plants. Temporary discoloration
          may occur on St. Augustine. Centipede, and Bentgrass lawns.

          STORAGE AND DISPOSAL
          STORAGE: Rio down smut to close. NO NEED
          TO DISCONNECT TRIGGER SPRAYER. Close nozzle
           on trigger sprayer. Snap sprayer back in place. Keep
           from freezing. Keep pesticide in original container.
           Do not put concentrate or dilute into food or drink
           containers. Avoid contamination of feed and
           foodstuffs. Store in a cool, dry place, preferably in a
           locked storage area.
           DISPOSAL: PRODUCT - Partially filled bottle may be disposed of by securely
           wrapping original container in several layers of newspaper and discard in
           trash. CONTAINER - Do not reuse empty container. Wrap container and put
           in trash.
PRECAUTIONARY STATEMENTS
HAZARDS TO HUMANS & DOMESTIC ANIMALS
DANGER: Harmful rl absorbed through skin. APPLYING: When applying this
product wear goggles or face shield, long pants, long sleeved shirt, socks, shoes.
and chemical resistant gloves. Wash nondisposable gloves thoroughly with soap
and water before removing. Remove contaminated clothing and launder
separately before reuse. Promptly and thoroughly wash hands and exposed skin
with soap and water after using this product Remove saturated clothing as soon
as possible and shower.
 i -LI  Do not allow others such as children and pets on treatment area
 T  rt  during application or to teenier treated areas until spray has dried.
HRST AID: If on skin, wash with olenty of soap and water. Note to Physicians:
Emergency Information call 1-8«HXX>-0000.
ENVIRONMENTAL HAZARDS: This product is toxic to aquatic invertebrates. Drift
or runoff may adversely affect aquatic invertebrates and nontarget plants. Do not
apply directly to water. Exerase caution when disposing of waste as groundwater
contamination may result from careless handling or spills. Do not contaminate
water when disposing of equipment washwaters.
NOTICE: Buyer assumes all responsibility for safely and use not in accordance
with directions.
         SlMfeil MonattM alt 1-800-555-5555
         rnduct Montana all 1-800-555-5555
STrUanirk ol The weed Comoirry
Manufiaurtd by
The Weed ComrJjny
100 Main Street
Anywnere USA 12345
EPA Beg. No. OOMOOO
EPAEstOOMW-1    Made n USA
m
                                                                                                                          This label is a represent
                                                                                                                            products, but does nc
                                                                                  355

-------
                                                                                                                    Front-

                                                             31 f^i-S,Vf'I"r -^r""-"fc*S*» **• **^ «iSt^»TB«i 11 m*.^«>''^*'™al
                           WeedKiller
       Kills Weeds - Not Lawn Grasses
        KILLS: Dandelion, Clover, Plantain,
        Cbkkweed, Oxalis, Spurge, Henbit,
        English Daisy, Wild Onion and
        Many Other Listed Weeds
        For Home Lawns Only
        •2.4-0 tot MUMWll sorar SWOSC ty AOAC

        "MCPA ud esumlttt 017%

        KEEP OUT OF REACH OF CHILDREN


356
                                                                                This label is a representation of the information seen on real  I
                                                                                 products, but does not accurately duplicate a real brand.    [

-------
                                                                                                                                                                             Back
                                Kills broadleat weeds in lawns -wots and all. Kills weeds, not lam grasses when used according to
                                directions. Ready-to-Use. No Mixing.

KILLS: Bur Clover, Carpetweeds. Chickweeds, Creeping Charlie, Cudweed,  Curly Dock, Dandelion, English Daisy, False Dandelion,
Filaree, Florida Pusley, Heartleaf Drymary, Henbit, Oxalis,  Pennywort, Plantains, Purslane, Red Sorrel, Sheep Sorrel, Spurges,
Thistles, Toadflax, White Clover. Wild Carrot, Wild Geranium, Wild Onion.
DIRECTIONS FOR USE
It is a violation of Federal law to use this product in a manner inconsistent with
its labeling.
READ ENTIRE USE. USE STRICTLY IN ACCORDANCE WITH UBR
PRECAUTIONARY STATEMENTS AND DIRECTIONS.
HOW TO USE: Turn sprayer nozzle to open. Adjust nozzle to give a coarse spray.
Aim at center of weed and spray to wet. Stray any time weeds are actively
growing. Oo not apply when rain or temperatures over 857 are expected within
24 hours. Hard to control weeds may require repeat application in 2 to 3 weeks.
Weeds in newly seeded lawns may be sprayed after lawn has been mowed
Slimes.
IMPORTANT: Do not use this product for controlling weeds in vegetable gardens.
flower beds or around shrubs or ornamental plants. Temporary discoloration
may occur on St. Augustine. Centipede, and Bentgrass lawns..

STORAGE AND DISPOSAL
STORAGE: Rip down spout to close. NO NEED
TO DISCONNECT TRIGGER SPRAYER. Close nozzle
on trigger sprayer. Snap sprayer back in place. Keep
from freezing. Keep pesticide in original container.
Do not  put concentrate or dilute into food or drink
containers. Avoid contamination of feed and
foodstuffs. Store in a cool, dry place, preferably in a
locked storage area.
DISPOSAL: PRODUCT - Partially filled bottle may be disposed of by securely
wrapping original container in several layers of newspaper and discard in
trash. CONTAINER - Do not reuse empty container. Wrap  container and put
in trash.
  PRECAUTIONARY STATEMENTS
  HAZARDS TO HUMANS & DOMESTIC ANIMALS
  CAUTION: Harmful if absorbed through skin. APPLYING: When applying this
  product wear goggles or face shield, long pants, long sleeved shirt, socks, shoes.
  and chemical resistant gloves. Wash nondisposabte gloves thoroughly with soap
• and water before removing. Remove contaminated clothing and launder
  separately before reuse. Promptly and thoroughly wash hands and exposed skin
  with soap and water after using this product Remove saturated clothing as soon
  as possible and shower.
           Do not allow others such as children and pets on treatment area
           during application or to n>enter treated areas until spray has dned.
  RRST AID: If on skin, wash with plenty of soap and water. Note to Physicians:
  Emergency Information call 1-80(MXXM)000.
  ENVIRONMENTAL HAZARDS: This product is toxic to aquatic invertebrates. Drift
  or runoff may adversely affect aquatic invertebrates and nontarget plants. Do not
  apply directly to water. Exercise caution when disposing of waste as groundwater
  contamination may result from careless handling or spills. Do not contaminate
  water when disposing of equipment washwaters.
  NOTICE: Buyer assumes all responsibility tor safely and use not in accordance
  with directions.
 *Sf  «**il mtormjfon CJIM-MO-S55-5SSS
  J^B   PTWudWoraa6noall
 STnoenuft of The Weed Company
 MuulutuitDHy
 The Weed Company
 100 Main Street
 Anywwrt USA 12345
 EPA Reg. No. 0004000
 EPAEstOOO-AW-1     MadenUSA
                                                                                                                                            •SttiSS
                                                                                                                                           EK32*
                                                                                                                              Sfjjjr-y'g.ir '.'xi.yc

                                                                                                                This label is a represent
                                                                                                                  products, but does no
                                                                                   357

-------
                                                                                                               Front -1



                       M^''*r^r**r^'"iJLTt"^Tvar"
               imaim,
                          Weed Killer
       Kills Weeds-Not Lawn Grasses
       KILLS: Dandelion, Clover, Plantain,
       Chickweed. Qxalis, Spurge, Henblt,
       English Daisy, Wild Onion and
       Many Other Listed Weeds
       Fw Home lawns Only
       H-O-dmBr/ammeaJt" -- 020%
       MCTA.4«Kt!iyom»esa" — . 050%
KEEP OUT OF REACH OF CHILDREN
          SHklCtllMlfeMMUtf—
          (nuBliwirrtUMmtUi.

        CAUTION  **>«*""•"'"«"'-"

Hi  NET"CONTENTSTGAL/3.7a


358
                                                                             This label is a representation of the information seen on real  I
                                                                              products, but does not accurately duplicate a real brand.   [

-------
                                 KSIs bmadleaf weeds in lawns - roots and all. Kills weeds, not lawn grasses when used according to
                                 directions. Ready-to-Use. No Mixing.

KILLS: Bur Clover, Carpetweeds, Chickweeds, Creeping Charlie, Cudweed, Curly Dock, Dandelion, English Daisy, False Dandelion,
Filaree, Florida Pusley, Heartiest Drymary, Henbit, Oxalis, Pennywort, Plantains, Purslane, Red Sorrel, Sheep Sorrel, Spurges,
Thistles, Toadflax. White Clover, Wild Carrot, Wild Geranium, Wild Onion.
DIRECTIONS FOR USE
ft is a violation of Federal law 0 use this product in a manner inconsistent with its labeling.
READ ENTIRE LABEL. USE STRICTLY IN ACCORDANCE WITH LABEL
PRECAUTIONARY STATEMENTS AND DIRECTIONS.
HOW TO USE: Turn sprayer nozzle to open. Adjust nozzle to give a coarse spray. Aim
at center of weed and spray to wel Sprav any time weeds are actively growing. Do not
apply when rain or temperatures over 85*F are expected within 24 hours. Hard to con-
trol weeds may require repeat application in 2 to 3 weeks. Weeds in newly seeded
lawns may be sprayed after lawn has been mowed 3 times.
IMPORTANT: Do not use this product for controlling, weeds in vegetable gardens, flower
beds or around shrubs or ornamental plants. Temporary discoloration may occur on
Si Augustine. Centipede, and Bentgrass lawns.

STORAGE AND DISPOSAL
STORAGE- Flip down spout to dose. NO NEED TO DISCON-
NECT TRIGGER SPRAYER. Close nozzle on trigger sprayer.
Snap sprayer back in place. Keep from freezing. Keep pes-
ticide in original container. Do not put concentrate or dilute
into food or drink containers. Avoid contamination of feed
and foodstuffs. Store in a cool, dry place, preferably in a
locked storage area.
DISPOSAL: PRODUCT - Partially filled bottle may be dis-
posed of by securely wrapping original container in several
layers of newspaper and discard in Hash. CONTAINER -
                                                                          • When using this product wear tag-sleeved shin long pants, socks, shoes, and cnerro-
                                                                           cal resistant gloves.
                                                                          • Wear goggles when applying this product
                                                                          • Alter icing this product rinse glows before removing, remove dothing. and launder
                                                                           separately before reuse.
                                                                          • Promptly and thoroughly wash raids and exposed skin with soap and water.
                                                                          • Remove saturated clothing as soon as possible and shower.
                                                                                     Do not allow others such as children and pets on treatment area
                                                                                     during application or to reenter treated areas until spray has dried.
                                                                          RRST AID: If on skin, wash with plenty of soap and water. Note to Physicians:
                                                                          Emergency Information call 1-800-000-0000.

                                                                          ENVIRONMENTAL HAZARDS
                                                                          • This product can kit aquabc insects, shrimp, crabs, crayfish. Do not apply to lakes.
                                                                           streams, nvers or ponds.
                                                                          • Drift or runoff may unrtentionaBy harm fen or plants.
                                                                          • Do not dump leftover pesticide or rinse water into drains or sewers.
                                                                          NOTICE: Buyer assumes al responsibility for safely and use not in accordance with
                                                                          directions.
                                                                                    Medial liUomutioo cill 1-800-555-5555
                                                                                    Product Information oil 1-200-555-5555
                                                                          ©Trademark of The Weed Company
                                                                          Manufactured by
                                                                          The Weed Company
                                                                          100 Main Street
                                                                          Anywhere USA 12345
                                                                          EPA Reg. No. 0000000
                                                                          EPAEslOOO-AW-1     Made in USA
 Do not reuse empty container. Wrap container and put in trash.
 PRECAUTIONARY STATEMENTS
 HAZARDS TO HUMANS 4 DOMESTIC ANIMALS
 • Harmful if absorbed through skin
  Avoid contact with eyes. slon. or clothing.

                                                                                                                      This label is a rtprtsem
                                                                                                                        products, but does nt

-------


 JSsBfcAacagaiatauaMiBiii,. »MHJPIM m
            i"'- • rr.-/if*H^*r^jr* TJj-^r^^iofria

j^SMBgsg;aii5SasPs^^g
      Kills BroadleSf
                        WMttto
     Kills Weeds - Not Lawn Grasses
     KILLS: Dandelion, Clover, Plantain,
     Chiclweed, Oxalis, Spurge, Henbit,
     English Daisy, Wild Onion and
     Many Other Listed Weeds
     KEEP OUT OF REACH OF CHILDREN
     CAUTION SSSSSWSSXS.
     NET CONTENTS 1 GAL/3.78 L
                                                                         777/s libel is a itpresentation of the information seen on real  I
                                                                          products, but does not accurately duplicate a real brand.   I
360

-------
                                                                                                                                                                   Back -'
     \mtrn
                                     Remove sprayer. Pull
                              Weed Killer.
                                                                      Insert red plug into spout
                                                                      (on cap) until it clicks.
                                                                                                        Flip up spout. Open
                                                                                                        nozzle at end ot sprayer.
                              Kills broadleaf weeds in lawns - roots and all. Kills weeds, not lawn grasses when used according to
                              directions. Ready-to-Use. No Mixing.

KILLS: Bur Clover, Carpetweeds, Chickweeds, Creeping Charlie, Cudweed, Curly Dock, Dandelion, English Daisy, False Dandelion,
Hlaree, Florida Pusley, Heartleaf Drymary, Henbit, Qxalis, Pennywort, Plantains,  Purslane, Red Sorrel, Sheep Sorrel, Spurges,
Thistles, Toadflax, White Clover, Wild Carrot, Wild Geranium, Wild Onion.	
DIRECTIONS FOR USE
It is a violation of Federal law to use this product in a manner inconsistent with
its labeling.
READ EHHRE LABR. USE STRICTLY IN ACCORDANCE WITH LABa
PRECAUTIONARY STATEMENTS AND DIRECTIONS.
HOW TO USE: Turn sprayer nozzle to open. Adjust nozzle to give a coarse spray.
Aim at center of weed and spray to wet. Spray any time weeds are actively
growing. Do not apply when ram or temperatures over 85"F are expected within
24 hours. Hard to control weeds may require repeat application in 2 to 3 weeks.
Weeds in newly seeded lawns may be sprayed after lawn has been mowed
3 times.
IMPORTANT: Do not use this product for controlling weeds in vegetable gardens,
flower beds or around shrubs or ornamental plants. Temporary discoloration
may occur on SL Augustine. Centipede, and Bemgrass lawns.

STORAGE AND DISPOSAL
STORAGE: flip down spout to close. NO NEED
TO DISCONNECT TRIGGER SPRAYER. Close nozzle
 on trigger sprayer. Snap sprayer back in place. Keep
 from freezing. Keep pesticide in original container.
 Do not put concentrate or dilute into food or drink
 containers. Avoid contamination of feed and
 foodstuffs. Store m a cool, dry place, preferably in a
 locked storage area.
 DISPOSAL: PRODUCT - Partially filled bottle may be disposed of by securely
 wrapping original container in several layers of newspaper and discard in
 trash. CONTAINER - Do not reuse empty container. Wrap container and put
 in trash.
PRECAUTIONARY STATEMENTS
HAZARDS TO HUMANS & DOMESTIC ANIMALS
CAUTION: Harmful if absorbed through skin. APPLYING: When applying this
product wear goggles or face shield, long pants, long sleeved shirt, sods, shoes,
and chemical resistant gloves. Wash nondisposabte gloves thoroughly witti soap
and water before removing. Remove contaminated clothing and launder
separately before reuse. Promptly and thoroughly wash hands and exposed skin
with soap and water after using this product. Remove saturated ctothing as soon
as possible and shower.
 m*_.  Do not allow others such as children and pets on treatment area
 T  ri  during application or to reenter treated areas until spray has dried.
FIRST AID: If on skin, wash with  plenty of soap and water. Note to Physicians:
Emergency Information call 1-800-OQO-OOOO.
ENVIRONMENTAL HAZARDS: This product is toxic to aquatic insects, crabs and
crayfish. Do not apply to lakes, streams, rivers or ponds. Do not dump leftover
pesticide or rinsewater into drains or sewers. Do not apply in windy conditions.
Pesticides may drift away from application site. Drift or runoff may unintentionally
harm feh or plants. Do not use where product may seep into ground water.
NOTICE: Buyer assumes all responsibility for safely and use not in accordance
with directions.	

 tfSfc  HuStcilll-ornnttwclll 1400-555-5555
 ••.   PitduaWonMllonc»II1400-555--5B
^Trademark lit TiK Weed Company
 Manufactured By
 The Weed Company
 100 Main Street
 AnyWiere USA 12345
 EPA Reg. No. 005-0000
 EPAEstOOO-AW-1     Made n USA
                                                                                                                     i*000
                                                                                                             This label is » represents
                                                                                                               products, but do«s not
                                                                                361

-------
                                                                                                                          Front -


                             Weed Killer
       Kills Weeds - Not Lawn Grasses
       KILLS: Dandelion, Clover, Plantain,
       Chichveed, Oxalis. Spurge, Henbit,
       English Daisy, Wild Onion and
       Many Other Listed Weeds
                 	_	...100 .oa%
        •2.4-0 JOd WVJJC.'. sane sxsic 5y AOAC
        KEEP OUT OF REACH OF CHILDREN
        P AIITI nU  S*1 6ltk B1M| fcr itt&***l
        unU I lUlv  iftfiutiMiryttittWiBtt
          r CONTENTS 1 GAL/3.78 L

362
777/s /2/w/ /s a representation of the information seen on real  I
 products, out does not accurately duplicate a real brand.   |

-------
                                                                                                                                                                                    Back-1i
                                         Remove sprayer. Pull
                                                                              Insert red plug into spout
                                                                              (on cap) until it clicks.
                                                                                                                    Flip up spout- Open
                                                                                                                    nozzle at end ot sprayer.
                                  Weed Killer.
                                  Kills broadleaf weeds in lawns - roots and all. Kills weeds, not lawn grasses when used according to
                                  directions. Ready-to-Use. No Mixing.

KILLS: Bur Clover, Carpetweeds, Chickweeds,  Creeping Charlie, Cudweed, Curly Dock, Dandelion, English Daisy, False Dandelion,
Filaree,  Florida Pusley, Heartleaf Drymary, Henbit, Oxalis, Pennywort, Plantains,  Purslane, Red Sorrel, Sheep Sorrel, Spurges,
Thistles, Toadflax, White Clover, Wild Carrot Wild Geranium, Wild Onion.	
DIRECTIONS FOR USE
IMPORTANT: Fotlmr label inrturtm
It is J violation ol Federal aw to use ms product in a manner inconsistent wim its labeling. Be
sure to read and Mow all lapel directors.
Application Tips
To acnieve tne best results:
•Apply this broductwnen weeds are actively growing.
• Do not water witnm 24 hours after treatment Ramlall alter spraying may result n poor weed

• Do not apply when rain or temperatures after 85T are expected witnm 24 hours.
Rnponsitlt Use
To use responsibly, follow mese guidelines wnen applying Lawn Weed Eliminator:
• Do not allow spray to dntt to oesojle plants or iniury may result. Spray wien me air is
  calm and carefully direct spray at weeds to avoid iniury  to landscape plants.
• Do rat allow people or animais to enter tie treated area until spray nas completeV dried.
• Do not overspray me weec. as mis may cause damage to grasses, such as cenopedegrass.
  Si Augustnegrass. and Floratam.
• Do not use tor controlling weecs m vegetable gardens,  (lower CMS or around shrubs.
 HnrtoUsi
 (mpo/ont Before you begin applying Weed Killer refer to 'Appticalion
 Tips" and 'Responsible Use" move.
 • Turn sprayer nozzle open.
 • Adiust nozzle n give a coatse spray.
 • Spray any tme weeds are growing. Adjust soray node to g« a
  coarse spray stream. Spray tne enure weed unol wet.
 STORAGE AND DISPOSAL
 STORAGE CONDITIONS
 Store in onginai container, out ot the read! of children, preferably n a
 locked storage cabinet. Keep from freezing.
  DISPOSAL
  • Oo not reuse empty Done.
  • Rinse botaetnorougniy.
  • Place empty bottle in trasn.
  Inauoa: It is best to use an ol the product in accordance win label directions. II it s
  necessary to dispose ol unused product please follow all state and local guuMnes.
PRECAUTIONARY STATEMENTS
HAZARDS TO HUMANS AND DOMESTIC WUIULS
CAUTION:
• Harmful if absorbed mrougn skin.
• Avoid contact witn eyes. sun. or clothing.
• When using this product, wear long-sttwd stilt long pants, sods, shoes, and chemcal
 resistant gloves.
• Wear goggles when applying this product
• After using this product rmse gloves betoit removng. remove doming, and launder separately
 before reuse.
• Promptly and tnorougtily wasn lands anl exuosed stai with soap and watet
• Remove saturated dotting as soon is possible and snowec                „_,,,
HRST AID: The table below oescnbes tie first aid procedures tor rodents reoMng Weed Idler.
  "IN THE CASE OF ACCIDENTAL...
        Contact with skin
          IMMEDIATELY...
• Remove contaminated dotnng.
•Wasn affected ston wan soap and watet
 NOTE wnen cailng poson control center, nave ms product B W accessor You may call
 800-OOMOOO for medical emergency rtumabx. Active (igredBiK DimemyUmme Salt of
 2 4-D [CAS f 2008-39-1]. rjimemyBmne Salt of Mecoproo |CAS / 92951-70-5).
 »«• to Biyifcim: No specific antidote s available. Treat me patent sympmmalicalty.
 ENVIRONMENTAL HAZARDS
 • Ths product is BMC to aguatic mtrtebnies. Do not apply directly to water.
 • Do not contaminate water wnen dsposng of eoucment wasnwaters.
 • Do not appty when weather conditions taw drtt from target area.
 NtmcE Buyer assumes atresconsbiHy lor safety and use not naroidance wan directions.
 €5?  MxHcillnforratlwciHI-KIO-SSS-SSSS
 ^^   Pniduetlnlormitim on 14*555-5555
 ®Trademam of The Weed Company  '

 Manufactured by
 The Weed Company
 100 Main Street
 Anywhere USA 12345
 EPA Reg. No. 000-0000
 EPAEstOOO-AW-1     Made ii USA

                                                                                                                          This label is a represcr.
                                                                                                                            products,  but does n
                                                                                        363

-------
                            Weed Killer
      Kills Weeds - Not Lawn Grasses
      KILLS: Dandelion, Clover, Plantain,
      duckweed. Oxalis, Spurge, Henbit,
      English Daisy, Wild Onion and
      Many Other Listed Weeds
      fa Home Lawns On!y
      2,4-0.<)«mmy*n«wsir ___ „ 050%
      MCPA.(Hn«JV»nw>esil»" __ OJHK
      OBWlnjwJiaits --- 99.60%
           ........... ........ „ ..... ....1W.CG%
RSp   KEEP OUT OF REACH OF CHILDREN
r"  PIHTinU  S«liUpiMHiri«ltl«al
       NET CONTENTS 1 GAL/3.78


                                                                                   77)/s /ate/ u a representation of the information seen on real
                                                                                     products, but does not accurately duplicate a real brand.
364

-------
                                                                                                                                                                                     Back-1
 DONNE&Ti
                                 A///S broadleaf weeds in lawns -roots and all. Kills weeds, not lawn grasses when used according to
                                 directions. Ready-to-Use. No Mixing.
KILLS: Bur Clover, Carpetweeds, Chickweeds, Creeping Charlie, Cudweed, Curly Dock, Dandelion, English Daisy, False Dandelion,
Filaree, Florida Pusley, Heartleaf Drymary, Henbit, Oxalis,  Pennywort, Plantains,  Purslane, Red Sorrel, Sheep Sorrel, Spurges,
Thistles. Toadflax, White Clover, Wild Carrot, Wild Geranium, Wild Onion.
DIRECTIONS FOR USE
It is a violation of federal law to use this product in a manner inconsistent with its labeling.
READ ENTIRE LABEL. USE STRICTLY IN ACCORDANCE WITH LABEL PRECAUTIONARY
STATEMENTS AND DIRECTIONS.
HOW TO USE:
1. Follow directions above lor ouick cornea sprayer
2. Turn sprayer nozzle to open
3. Adjust nozzle 10 give a coarse soray
4. Aim it center ol ween ana spray to wet
ADDITIONAL INFORMATION:
• Soray anytime weeds are actively growing
• Do not apply when rain or temperatures over 85 Degrees are expected within 24 hours
• Haw to comrai weeds may reouire repeat application in 2-3 weens
• Wee* and newly seeoed lawns may be sprayed after lawn has been mowed ttiree times
IMPORTANT:
• Do not use this product lor control weeds in vegetable gardens, (lower beds or around
  snrubs or ornamental plants.
• Temporary discoloration may occur St Augustine, Centipede, and Bentgnss lawns.

STORAGE AND DISPOSAL
STORAGE: Rip down spout to dose. NO NEED TO DISCON-
NECT TRIGGER SPRAYER. Close node on tngger sprayer.
Snao sprayer bacit in place, Keeo Irom freeing. Keep pesti-
cide in original container. Do not put concentrate or dilute
into food or dnnk containers. Avoid contamination of feed
and foodstuffs. Store in a cool, dry place, preferably m a
lotted storage ana.
DISPOSAL: PRODUCT - Partially tilled bottle may be dis-
posed ol by securely wrapping onginal container in several
layers of newspaper and discard tn trash. CONTAINER - Do
 not reuse empty container. Wrap container and put in trash.
PRECAUTIONARY STATEMENTS
HAZARDS TO HUMANS i DOMESTIC ANIMALS
CAUTION: Harmful if absorbed through skm. APPLYING: When applying this product wear
goggles or face shield, long pans, long sleeved shirt soos. shoes, and chemical resistant
gloves. Wash nondisposable gloves thoroughly with seas and water before removing.
Remove contaminated clothing and launder separately :etore reuse. Promptly and thor-
oughly wash hands and exposed skin with soap and water after using this product
Remove saturated clothing as soon as possible and snower.
           Do not allow others such as children and oes on treatment area
           during application or to reciter treated areas until spray has dried.
RRST AID: If on skin, wash with plenty ct soap and water. Note to Physicians: Emergency
Information call 1-BOO-OOO-OOOO.
ENVIRONMENTAL HAZARDS: This product is tone to acuatc invertebrates. Drift or runoff
may adversely affect aouatc invertebrate.'! and nontarget :ans. Do not apply direcrjy to
water. Exerase caution when disposing of waste as grouncwater contamination may result
from careless handling or spills. Do not contaminate water wnen disposing ot equipment
wasnwaters.
NOTICE: Buyer assumes all  responsibility for safely ano use not In accordance with
directions.
          M«tal Information an UOO-555-5555
^Trademark of The Weed Company
Manufactured by
The Weed Company
100 Main Street
Anywhere USA 12345
EPA Reg. No. 000-0000
EPAEstOOO-AW-1     Made n USA


                                                                                                                       This label is a npresentatn
                                                                                                                         products, but does not a
                                                                                         365

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                                                                                                                    Front -'

                          Weed Killer
      Kills Weeds - Not Lawn Grasses
          .- Dandelion, Clover, Plantain,
      Chtckweed, Oxalis, Spurge, Henbit,
      English Daisy, Wild Onion and
      Many Other Listed Weeds
      KEEP OUT OF REACH OF CHILDREN
      CAUTION  "*»'k''«"«"«lli«"
var.CTt i          i--:;t     "_  ^^^j-^jpiigggSagjjgS

366
TOs /ate/ /s a representation of the information seen on real  I
 products, but does not accurately duplicate a real brand.    [

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SfBWAMElR
                   Weed Killer
                   Lawn Weed Killer
                   Kills weeds in your lawn - won't harm lawn grasses.
                   Singles out weeds, enters through leaves and moves inside the
                   weed to the root.
  KILLS WEEDS
Dandelion, Clover. Chickweed plus additional broadleaf weeds
  WHERE TO USE
ON LAWNS without harming grasses
  READY TO USE
No mixing required
                   Questions, Comments or Medical Information call 1-800-000-0000
                   http://www.weedcompany.com
THIS PRODUCT CONTAINS:
Active Ingredients
2,4-D, dimethylamine salt*	   0.20%
MCPA, dimethylamine salt**	   0.20%
Other Ingredients	     99 60%
Total	100.00%
*2,4-D acid equivalent, isomer specific by AOAC Method 6.275:0.1 S°/<
"MCPA acid equivalent: 0.17%
Manufacted for The Weed Company
EPA Reg. No XXX-XXX
EPA Est. XXX-XX-X
Made in USA

                                                                                                          Back -1
                                                                    This label is a represent
                                                                     products, but does nc.
                                                                         367

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                              Lawn Weed Killer
                              Kills weeds in your lawn - won't harm lawn grasses.
                              Singles out weeds, enters through leaves and moves inside the
                              weed to the root.
            KILLS WEEDS
Dandelion, Clover, Chickweed plus additional broadleaf weeds
            WHERE TO USE
ON LAWNS without harming grasses
            READY TO USE
No mixing required
                              Questions, Comments or Medical Information call 1-800-000-0000
                              http://www.weedcornpany.com
           THIS PRODUCT CONTAINS:
           Active Ingredients
           2,4-D, dimethylamine salt*	   0.20%
           MCPA. dimethylamine salt"	   0.20%
           Other Ingredients	  99.60%
           Total	100.00%
           '2,4-D acid equivalent, isomer specific by AOAC Method 6.275: 0 16%
           "MCPA acid equivalent: 0.17%
           Manulacted for The Weed Company
           EPA Reg NoXXX-XXX
           EPA Est. XXX-XX-X
           Mitte 10 USA


                                                                                                                    #12-B;
                                                                                                                     Bookh
368
                                                                                  This label is a representation of the inlomalion seen on real
                                                                                   products, but does not accurately duplicate a real brand.

-------
 Kills broadleaf weeds in lawns - roots and all. Kills weeds, not lawn grasses when used according to
 directions. Ready-to-Use. No Mixing.
 KILLS: Bur Clover. Carpetweeds, Chickweeds, Creeping Charlie, Cudweed, Curfy Dock, Dandelion, English Daisy,
 False Dandelion, Rlaree, Florida Pustey. Heartleaf Drymary, Henbit, Oxalis, Pennywort, Plantains, Purslane,
 Red Sorrel, Sheep Sorrel, Spurges, Thistles, Toadflax, White Clover, Wild Carrot. Wild Geranium,  Wild Onion.
I DIRECTIONS FOR USE
 USE ONLY AS DIRECTED ON THIS LABEL
 HOW TO USE:
 • Follow directions above for quick connect sprayer
 • Turn sprayer nozzle to open
 • Adjust nozzle to give a coarse spray
 • Aim at center of weed and spray to wet
 ADDITIONAL INFORMATION:
 • Spray anytime  weeds are actively growing
 • Do not apply when rain or temperatures over 85 degrees are expected within 24 hpurs
 • Hard to control weeds may require repeat application in 2-3 weeks
 • Weeds and newly seeded lawns may be sprayed after lawn has been mowed three times
 IMPORTANT:
 • Do not use this product for control weeds in vegetable gardens, flower beds or around shrubs or ornamental plants.
  • Temporary discoloration may occur St. Augustine. Centipede, and Bentgrass lawns
                                                                                                                      PRECAUTIONARY STATEMENTS
                HAZARDS TO HUMANS
                & DOMESTIC ANIMALS
  CAUTION:
  Harmful if absorbed through skin
 ADDITIONAL INFORMATION
 Applying:
 • When applying this product wear goggles or face shield, long pa
 • Wash non-disposable gloves thoroughly with soap and water bet
 • Remove contaminated clothing and launder separately before rei
 • Promptly and thoroughly wash hands and exposed skin with soa
 • Remove saturated clothing as soon as possible and shower
 Reentry:
 • Do not allow others such as children and pets on treatment area
  STORAGE AND DISPOSAL
  STORAGE
  Flip down spot to close
  No need to disconnect trigger sprayer
  Snap sprayer back in to place
  Keep from freezing
  Keep pesticide in original container
  Avoid contamination of feed and foodstuffs
  Store in a cool dry place, preferably in a locked storage area
  DISPOSAL
  Product:
  Partially filled bottle may be disposed of by securely wrapping onginal container in several layers ol newspaper and discard in trash
  Container
  Do not reuse empty container
  Wrap container and put  in trash
  ENVIRONMENTAL HAZARDS
  • This product is toxic to aquatic invertebrates
  • Drift or run-off may unintentionally harm fish or plants
  • Do not apply directly to lakes, streams, rivers, or ponds
  • Do not dump leftover pesticide or rinse water into drains or sewt
  • Exercise caution when disposing ol waste as ground water conta
  NOTICE:
  Buyer assumes all responsibility lor safety and use not in accordar
 	   Medieil Information call 1-800-555-S555
 •BB   Product Intonation till 1-MO-555-SSS5
^Trademark of The Weed Comoiny
Manufactured 6y
The Weed Company
lOOMamStteel
AnywtKrt USA 12345
EPA Reg No. 0000000
EPABIOOO-AW-I    Made «l USA

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                                         HAZARDS TO HUMANS
                                         & DOMESTIC ANIMALS
English Daisy,
 Purslane,
, ma (Mm.
H on skin wash with plenty of soap and water.
Note to Physician: Emergency information call 1-800-000-0000
CAUTION:
Harmful H absorbed through skin
                           ADDITIONAL INFORMATION

                           • Whenapplying this product wear goggles or face shield, long pants, long sleeve shirt, socks, shoes and chemical resistant gloves
                           • Wash non-disposable gloves thoroughly with soap and water before removing
                           • Remove contaminated clothing and launder separately before reuse
                           • Promptly and thoroughly wash hands and exposed skin with soap and water after using this product
                           • Remove saturated clothing as soon as possible and shower
                           • Donot allow others such as children and pets on treatment area during application or to reenter treated areas until spray has dried
                            • This product is toxic to aquatic invertebrates
                            * Drift or run-off may unintentionally harm fish or plants
                            • Do not apply directly to lakes, streams, rivers, or ponds
                            • Do not dump leftover pesticide or rinse water into drains or sewers
                            - Exercise caution when disposing of waste as ground water contamination may result from careless handling or spills
                            NOTICE:                                                      .   .
                            Buyer assumes all responsibility for safety and use not in accordance with directions
                           AnfMxrc USA 17345
                           EPARaj NoOXHWX)
                           EMEslOOO-WI    MjOenUSA
                                                                                                                                                                   #12-BACr|
                                                                                                                                                                     Booklet
                                                                                                                        This label is a representation of the information seen on real
                                                                                                                          products, but does not accurately duplicate a real brand
                370

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                Appendix 3-5:
Household Cleaners Mock Label
                       371

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KEEP OUT OF REACH               ACTIVE INGREDIENTS:
OFCHILDREN                     Alkyl|C1240%;C1450%;C16IO%)
CAUTION: See back panel for           dimethyl benzyl ammonium chloride.. J.3%
additional precautionary statements.      OTHER INGREDIENTS		.99.7%
NETWT22FLOZ(1PT60Z)650ml     TOTAL INGREDIENTS
                                                                                           Control

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                                                                                                                              Control
  WHAM™ All Purpose Cleaner cleans, deodon'zes and disinfects household surfaces. Cuts
  grease and grime, removes stains. Kills Staphylococcus. Streptococcus and Salmonella
  bacteria. DIRECTIONS FOR  USE: It is a violation of Federal law to use this product in a
  manner inconsistent with its labeling. TO OPERATE; Turn nozzle to "Spy" or  "Stream"
  GENERAL CLEANING: Holding nozzle 6 to 8 inches from surface, spray soiled area, then wipe
 clean. Note: A rinse is required for surfaces in direct contact with food. Do not use on marble
 surfaces. DISINFECTION: Spray until thoroughly wet. Let stand 10 minutes before wiping or
 rinsing. For heavily soiled surfaces, preclean according to General Cleaning  Directions.
 MILDEW: Preclean surface, then spray until thoroughly wet. Let air dry. Repeat weekly or when
 new growth appears.
 PRECAUTIONARY STATEMENTS: HAZARDS TO HUMANS AND DOMESTIC ANIMALS.
 CAUTION: CAUSES EYE IRRITATION. Do not get in eyes, on skin or clothing. Avoid  contact with
 foods. FIRST AID: In case of eye contact, flush with plenty of water for at least  IS minutes. Call a
 physician if irritation persists. STORAGE AND DISPOSAL Store in areas inaccessible to  small
 children. Do not reuse empty containers. Rinse thoroughly and discard in trash.
 Contains no phosphates.
This bottle is made of 25% post-consumer recycled HOPE plastic
 QUESTIONS? COMMENTS? Call 1-800-S5-5S5
 EPA Reg.No 555-55. EPAEst No.555-XX-l, YY-2.ZZ-3
 MADE BYTHE WHAM COMPANY, 100 Main Street
 Anywhere, USA. 12345. SATISFACTION GUARANTEED: If you are
 not fully satisfied, with this product, please call or write to tell us
 why. When writing, please include the bar code numbers and
  code printed on this package.
                                                       ">4460610062"811
                                                                                                                373

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                                                                                                      .vx
                                                                                                        •>.:. .\
                                              •••'•y^        -   /
                                           -KEEP OUT OF REACH'
                                            OF CHILDREN
                                            CAUTION: See back panel for
                                            additional precautionary statements.
                                            NETWT22FLOZ(1PT60Z)650ml
ACTIVE INGREDIENTS:   	~"
/Ulcyl(Ci240%;Cu50%;Ci6lO%)
dimethyl benzyl ammonium chloride —0.3%
OTHER INGREDIENTS:  \
Deionized water	__.„.„_ _~.._J(XX%
Etftylene giycol monobutyl ether	XXJ(%
Polyoxyettiylene octadecylphenol _.... J00(%
N,N,-Dimethylcapramide	J(XX%
Sodium Ettiylenetriaminetetraacetate ._JCX%
Perfume		XJC%
CI Direct Blue 86    	XX%
TOTAL INGREDIENTS	100.0%
374
                                                                                                                                           Version  1

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                                                                                                                         Version   1
                   /
  WHAM™ All Purpose Cleaner cleans, deodorizes and disinfects household surfaces. Cuts
  grease and grime, removes stains. Kills Staphylococcus. Streptococcus and Salmonella
  bacteria. DIRECTIONS FOR USE: It is a violation of Federal law to use this product in a
  manner inconsistent with  its labeling. TO OPERATE: Turn nozzle to  "Spray" or "Stream*.
  GENERAL CLEANING: Holding nozzle 6 to 8 inches from surface, spray soiled area, then wipe
 clean. Note: A rinse is required for surfaces in direct contact with food. Oo not use on marble
 surfaces. DISINFECTION: Spray until thoroughly wet. Let stand 10 minutes before wiping or
 rinsing. For heavily soiled surfaces, preclean according to General Cleaning Directions.
 MILDEW: Preclean surface, then spray until thoroughly wet Let air dry. Repeat weekly or when
 new growth appears.
 PRECAUTIONARY STATEMENTS: HAZARDS TO HUMANS AND DOMESTIC ANIMALS.
 CAUTION: CAUSES EYE IRRITATION Do not get in eyes, on skin or clothing. Avoid contact with
foods. FIRST AID: In case of eye contact, flush with plenty of water for at least 15 minutes. Call a
physician if irritation persists. STORAGE AND DISPOSAL Store in areas inaccessible to small
children. Oo not reuse empty containers. Rinse thoroughly and discard in trash
Contains no phosphates.
This bottle is made of 25% post-consumer recycled HOPE plastic.
QUESTIONS? COMMENTS? Call 1-SB-5S-55S
EPA Reg. No 555-55. EPA Est No. 555-XX-1, YY-2, ZZ-3
 MADE BYTHE WHAM COMPANY, 100 Main Street
 Anywhere, USA. 12345. SATISFACTION GUARANTEED: If you are
 not fully satisfied, with this product, please cat or write to tell us
 why. When writing, please include the bar code numbers and
  code printed on  this package.
                                                         i44'(5fJOlOb'6281111 0
                                                                                                                 376

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                                              .KEEP OUT OF REACH
                                                OF CHILDREN
                                                CAUTION: See back panel for
                                                additional precautionary statements.
                                                NETWT22FLOZ(1PT60Z)65Qml
ACTIVE INGREDIENTS:
AlkyllCi240%;Ci450%:Ci6lO%)
dimethyl benzyl ammonium chloride —0.3%
OTHER INGREDIENTS:		917%
Other ingredients are: Deionized water,
solvent (to dissolve grease), surfactants
(cleaning agents), Sodium EDTA (aids cleaning
in hard water), perfume, blue colorant
TOTAL			100.0%
376

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                                                                                                                        Version  2.
".  .•-'    ,•'     /

  WHAM™ All Purpose Cleaner cleans, deodorizes and disinfects household surfaces. Cuts
  grease and grime, removes stains. Kills Staphylococcus, Streptococcus and Salmonella
  bacteria. DIRECTIONS FOR USE: It is a violation of Federal law to use this product in a
  manner inconsistent  with its labeling. TO OPERATE: Turn nozzle to "Spray" or "Stream".
  GENERAL CLEANING: Holding nozzle 6 to 8 inches from surface, spray soiled area, then wipe
 clean. Note: A rinse is required for surfaces in direct contact with food. Do not use on marble
 surfaces. DISINFECTION: Spray until thoroughly wet. Let stand 10 minutes before wiping or
 rinsing. For heavily soiled surfaces, preclean according to General Cleaning Directions.
MILDEW: Preclean surface, then spray until thoroughly wet Let air dry. Repeat weekly or when
new growth appears.
PRECAUTIONARY STATEMENTS: HAZARDS TO HUMANS AND DOMESTIC ANIMALS.
CAUTION: CAUSES EYE IRRITATION. Do not get in eyes, on skin or clothing. Avoid contact with
foods. FIRST AID: In case of eye contact, flush with plenty of water for at least 15 minutes. Call a
physician  if irritation persists. STORAGE AND DISPOSAL Store in areas inaccessible to small
children. Do not reuse empty containers. Rinse thoroughly and discard in trash.
Contains no phosphates.
This bottle is made of 25% post-consumer recycled HOPE plastic.
QUESTIONS? COMMENTS? CalH-aJO-555-5555
EPA Reg. No 555-55, EPA Est No. 555-XX-I, YY-2, ZZ-3
MADE BYTHE WHAM COMPANY, 100 Main Street,
Anywhere, USA, 12345.  SATISFACTION GUARANTEED:»you are
 not fully satisfied, with this product, please caS or write to tell us
 why. When writing, please include the bar code numbers and
  code printed on this package.                              _
                                                       ~144600"0062811
                                                                                                                   377

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378
                                      KEEP OUT OF REACH
                                      OF CHILDREN
                                      CAUTION: See back panel for
                                      additional precautionary statements.       NET WT 22 FL OZ11PT 6 OZ1650 ml
                                                                                                                        Version  3

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                                                                                                                           Version  3
    WHAM™ All Purpose Cleaner cleans, deodorizes and disinfects household
    surfaces. Cuts grease and grime, removes  stains. Kills Staoiiylococcus,
   Streotococcus and Salmonella bacteria.
   DIRECTIONS FOR USE: It is a violation of Federal law to use this product in a manner
   inconsistent with its labeling. TO OPERATE: Turn nonle to "Spray" or "Stream". GENERAL
   ttEANINO: Holding nozzle 5 to 8 inches from surface, spray soiled area, then wipe clean. Note: A
  rinse is reouired for surfaces  in direct contact with food. Do not use on marble surfaces
  DISINFECTION: Spray until thoroughly wet let stand 10 minutes before wiping or nnsing. For heavily
  soiled surfaces, pteclean according to General Cleaning Directions. MILDEW: Preclean surface, then
  spray until thoroughly wet Let air dry. Repeat weekly or when new growth appears.
  PRECAUTIONARY STATEMENTS: HAZARDS TO HUMANS AND DOMESTIC ANIMALS.
 CAUTION: CAUSES EVE IRRITATION. Oo not get in eyes, on skin or clothing. Avoid contact with foods. FIRST
 AID: in case of eye contact, flush with plenty of water for at least 15 minutes. Call a physician if rotation
 persists. STORAGE AND DISPOSAL: Store in areas inaccessible to small children  Do not reuse empty
 containers. Rinse thoroughly and discard in trash.
 Contains no phosphates. This bottle is made of 25% post-consumer recycled HDPE plastic.
 ACTIVE ING'REDIENTS:Afcyl(Cn40%;CH50%;Ci6lO%l
 dimethyl benzyl ammonium chloride	03%
 OTHER INGREDIENTS:	99.7%
 Other ingredients are: Dekxiized water, solvent (to dissohe
 grease), surfactants (cleaning agents), Sodium EDTA (aids
 cleaning in hard water), perfume, blue colorant
.TOTAL	100.0%
 QUESTIONS? COMMENTS? Ml 1-SB-55H5S5
 EPA Reg.No 555-55, EPA EstNo.555-XX-t.YY-2.ZZ-3
  MADE EVTHEWHAM COMPANY, 100 Main Sired
  Anywhere. USA, 12345. SATISFACTION GUARANTEED: If you are
  not fully satisfied, with ths product, please call or wnte to tell us
   why.VI/henwnting,pleaseincludei!iebarcorJenumbersani)	
                                                         o 11144600*00628
                                                                                                                           379

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380
                                         KEEUT OF REACH
                                                                        ACTIVE INGREDIENTS:
                                                                                  ;C1450%;C1610%)
                                                                        dimethyl benzyl ammonium chloride ....0.3%
                                                                        OTHER INGREDIENTS	99.7%
                                                                        TOTAL INGREDIENTS	100.0%
CAUTION: See back panel for
additional precautionary statements.
NETWT22FLOZ(1PT60Z)650ml
                                                                                                                                   Version 4

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                                                                                                                        Version  A
.   WHAM™ All Purpose Cleaner cleans, deodorizes and disinfects household surfaces.
   Cuts grease and grime, removes stains. Kills Staphylococcus,  Streptococcus and
  Salmonella bacteria.  DIRECTIONS FOR USE: It is a violation of Federal law to use this
  product in a manner inconsistent with its labeling. TO OPERATE: Turn nozzle to 'Spray* or
  'Stream*. GENERAL CLEANING: Holding nozzle 6 to 8 inches from surface, spray soiled area,
 then wipe clean. Note: A rinse is required for surfaces in direct contact with food. Do not use
 on marble surfaces. DISINFECTION: Spray until thoroughly wet. Let stand 10 minutes before
 wiping or rinsing. For heavily soiled surfaces, preclean according to General Cleaning
 Directions. MILDEW: Preclean surface, then spray until thoroughly wet. Let air dry. Repeat
weekly or when new growth appears.
PRECAUTIONARY STATEMENTS: HAZARDS TO HUMANS AND DOMESTIC ANIMALS.
CAUTION:
•Causes eye irritation.
• Do not get in eyes, on skin or clothing.
•Avoid  contact with foods.
FIRST AID: In  case of eye contact flush with plenty of water for at least  IS minutes. Calt a
physician if irritation persists. STORAGE AND DISPOSAL Store in areas inaccessible to small
children. Do not reuse empty containers. Rinse thoroughly and discard in trash.
Contains no phosphates.
This bottle is made of 25% post-consumer recycled HOPE plastic.
QUESTIONS? COMMENTS? Call 1-800-555-5S5
EPA Reg. No 555-55, EPA Est No. 555-XX-1, YY-2,22-3
MADE BYTHE WHAM COMPANY, 100 Main Street,
 Anywhere, USA, 12345. SATISFACTION GUARANTEED: If you are
 not fuly satisfied, with this product, please call or write to tell us
  why. When writing, please include the bar code numbers and
   codeprimedonthispackage.                            o " 44600lo6~62"8
                                                                                                                    381

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382
                                                                                                                                  Version  5
                                                                                                    "•-'1
                                                                                                \
                                                                                             •- -— i. .*_ A.
                                      •KEEP OUT OF REACH
                                       OF CHILDREN
                                       CAUTION: See back panel for
                                       additional precautionary statements.
                                       NETWT22FLOZ(1PT60Z)650nil
ACTIVE INGREDIENTS:
Alkyl(C124fl%;C1450%;C1610%)
dimethyl benzyl ammonium chloride ..-0.3%
OTHER INGREDIENTS	99.7%
TOTALINGREDIENTS	100.0%

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                                                             Version  5
  WHAM™ All Purpose Cleaner cleans, deodorizes and disinfects household surfaces. Cuts
  grease and grime, removes stains. Kills  Staphylococcus, Streptococcus and  Salmonella
  bacteria. DIRECTIONS FOR USE: Use only as directed on this label TO OPERATE: Turn nozzle to
  "Spray" or "Stream". GENERAL CLEANING: Holding nozzle 6 to 8 inches from surface, spray
 soiled area, then wipe clean. Note: A rinse is required for surfaces in direct contact with food. Do
 not use on marble surfaces. DISINFECTION: Spray until thoroughly wet. Let stand 10 minutes
 before wiping or rinsing. For heavily soiled surfaces, preciean according  to General  Cleaning
 Directions. MILDEW: Preciean surface, then spray until thoroughly wet. Let air dry. Repeat weekly
 or when new growth appears.
 PRECAUTIONARY STATEMENTS: HAZARDS TO HUMANS AND ANIMALS.
 CAUTION: CAUSES EYE IRRITATION. Avoid contact with eyes, skin or clothing. Avoid contact with
foods. FIRST AID: In case of eye contact flush with plenty of water for at least 15  minutes. Call a
physician  if irritation persists. STORAGE AND DISPOSAL Store in areas  inaccessible to small
children. Do not reuse empty containers. Rinse thoroughly and discard in trash.
ENVIRONMENTAL INFORMATION: Contains no phosphates.
This bottle is made of 25% post-consumer recycled HOPE plastic.

 QUESTIONS? COMMENTS? Call 1-800-555-5555
 EPA Reg. No 555-55, EPAEst No. 555-XX-1. YY-2.ZZ-3
 MADE BYTHE WHAM COMPANY, 100Main Street,
 Anywhere. USA, 12345. SATISFACTION GUARANTEED: If you are
  not fu8y satisfied, with this product, please call or wme to tell us
  why. When writing, please include the bar code numbers and
   code printed on this package.                           <
44600B00628
                                                           383

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                                                                                                                      Version  6
                                    KEEP OUT OF REACH
                                   •OFCHILDREN  S
                                   NETWT22FLOZ(1PT60Z)650ml
                                                              ACTIVE INGREDIENTS:

                                                              Alkyl|C12405S;C1450%;C16IO%)
384

-------
                                                                                                                    Version   6
 WHAM™ All Purpose Cleaner cleans, deodorizes and disinfects household surfaces. Cuts
 grease and grime, removes stains. Kills Staphylococcus, Streptococcus and Salmonella
 bacteria. DIBECTIONS FOR USE It is a violation of Federal law to use this product in;
 manner inconsistent with  its labeling. TO OPERATE Turn nozzle to  "Spray" or "Stream".
 GENERAL CLEANING: Holding nozzle 6 to 8 inches from surface, spray soiled area, then wipe
 clean. Note: A rinse is required for surfaces in direct contact with food. Do not use on marble
 surfaces. DISINFECTION: Spray until thoroughly wet.  Let stand 10 minutes before wiping or
 rinsing. For heavily soiled surfaces, preclean according to General Cleaning Directions.
 MILDEW: Preclean surface, tlien spray until moroughly wet. Let air dry. Repeat weekly or when
 new growth appears.
PRECAUTIONARY STATEMENTS: HAZARDS TO HUMANS AND DOMESTIC ANIMALS.
CAUTION: CAUSES EYE IRRITATION. Do not get in eyes, on skin or clothing. Avoid contact with
foods. FIRST AID: In case of eye contact flush with plenty of water for  at least 15 minutes. Call a
phvsician if irritation persists. STORAGE AND DISPOSAL Store in  areas inaccessible to small
children. Do not reuse empty containers. Rinse thoroughly and discard in trash.
Contains no phosphates.
This bottle is made of 25% post-consumer recycled HOPE plastic.
 QUESTIONS? COMMENTS? Call 1-800-555-5555
 EPA Reg. No 555-55, EPA Est No. 555-XX-1, YY-2.ZZ-3
 MADE BY THE WHAM COMPANY, 100 Main Street,
 Anywhere. USA. 12345. SATISFACTION GUARANTEED: If you are
 not fully satisfied, with this product please call or write to tel us
 why. When writing, please include the bar code numbers and
  code printed on this package.                              ,..,...	,	  „
                                                     o" 44600'00628"  0
                                                                                                                   385

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386
                                     -KEEP OUT OF REACH
                                      OF CHILDREN
                              ACTIVE INGREDIENTS:
                              Alkyl(CI240%;C1450%;C1610%l
•fiuiiL'KawABHiHGi DANGER i      dimethyl bufizyl smmoniutn chloride .....0.3%
                                          t                          OTHER INGREDIENTS.		99.7%
                                      NET WT 22 FL OZ (1PT 6 OZ) 650 ml    TOTAL INGREDIENTS		100.0%
                                                                                                                                Version 7

-------
                                                                                                                        Version  7
  WHAM™ All Purpose Cleaner cleans, deodorizes and disinfects household surfaces. Cuts
  grease and grime, removes stains. Kills Staphylococcus, Streptococcus and Salmonella
  bacteria. DIRECTIONS FOR USE: It is a violation of Federal law to use this product in a
  manner inconsistent with its labeling. TO OPERATE: Tarn nozzle to "Spray" or "Stream".
 GENERAL CLEANING: Holding nozzle 6 to 8 inches from surface, spray soiled area, then wipe
 clean. Note: A rinse is required for surfaces in direct contact with food. Do not use on  marble
 surfaces. DISINFECTION: Spray until thoroughly wet Let stand 10 minutes before wiping or
 rinsing. For heavily soiled surfaces, preclean according to General Cleaning Directions
 MILDEW: Preclean surface, then spray until thoroughly wet Let air dry. Repeat weekly or when
 new growth appears.
 PRECAUTIONARY STATEMENTS: HAZARDS TO HUMANS AND DOMESTIC ANIMALS.
CAUTION: CAUSES EYE IRRITATION. Do not get in eyes, on skin or clothing. Avoid contact with
foods. FIRST AID: In case of eye contact, flush with plenty of water for at least 15 minutes. Call a
physician if  irritation persists. STORAGE AND  DISPOSAL Store in areas inaccessible to small
children. Do  not reuse empty containers. Rinse thoroughly and discard in trash.
Contains no phosphates.
This bottle is made of 25% post-consumer recycled HOPE plastic.
QUESTIONS? COMMENTS? Call 1-SOOTHS
 EPA Reg. No555-55,EPA Est No.555-XX-1,YY-2.2Z-3
 MADE BYTHE WHAM COMPANY, 100 Mam Street
 Anywhere, USA,  12345. SATISFACTION GUARANTEED: If you are
 not fully satisfied, with this product please cal or write to tell us
 why. When writing, please include the bar code numbers and
  code printed on this package.
                                                                                                                     387

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                                       KEEP OUT OF REACH •>'
                                       OF CHILDREN   ,,
                                                                                                                                  Version  8
                                                                      ACTIVE INGREDIENTS:
                                                                      Alkyl (C124fl%;C1450%;C1610% I
                                       CORROSIVE1 Ciuscspminentiysdimige        dimethyl benryl ammonium chloride .....0.3%
                                                                      OTHER INGREDIENTS	99.7%
                                       NETWT22FLOZI1 PT60Z)650ml    TOTAL INGREDIENTS	100.0%
388

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                                                                                                                      Version  8
  WHAM7" All Purpose Cleaner cleans, deodorizes and disinfects household surfaces. Cuts
  grease and grime, removes stains. Kills Staphylococcus. Streptococcus and Salmonella
 bacteria. DIRECTIONS FOR USE: It is a violation of Federal law to use mis product in a
 manner inconsistent  with its labeling. TO OPERATE: Turn nonle to  'Spray' or 'Stream'.
 GENERAL CLEANING: Holding nozzle 6 to 8 inches from surface, spray soiled area, then wipe
 clean. Note: A rinse is required for surfaces in direct contact with food. Do not use on marble
 surfaces. DISINFECTION: Spray until thoroughly wet Let stand 10 minutes before wiping or
 rinsing.  For heavily soiled surfaces, preclean according to General Cleaning Directions.
 MILDEW: Preclsan surface, then spray until thoroughly wet Let air dry. llepeat weekly or when
 new growth appears.
 PRECAUTIONARY STATEMENTS: HAZARDS TO HUMANS AND DOMESTIC ANIMALS.
 CAUTION: CAUSES EYE IRRITATION. Do not get in eyes, on skin or clothing. Avoid contact with
foods. FIRST AID: In case of eye contact, flush with plenty of water for at least 15 minutes. Call a
physician if  irritation persists. STORAGE AND  DISPOSAL Store in areas inaccessible to small
children. Do not reuse empty containers. Rinse thoroughly and discard in trash.
Contains no phosphates.
This bottle is made of 25% post-consumer recycled HOPE plastic
 QUESTIONS? COMMENTS? Call 1-800-BHS5
 EPA Reg. No 555-55, EPA Est No. 555-XX-1, YY-2. ZZ-3
 MADE BY THE WHAM COMPANY, 100 Main Street,
 Anywhere. USA,  12345. SATISFACTION GUARANTEED: If you are
 not fully satisfied, with this product please call or write to tell us
 why. When writing, please include the bar code numbers and
  code printed on this package.
                                                                                                                      389

-------
390
                                       •"   <^*-J       --•?      -•  ; •
                                       *-'^ -J   ..',*"*    *S   '
                                         KEEP OUT OF REACH
                                         OF CHILDREN
                                                                                                                                   Version  9
                                                                        ACTIVE INGREDIENTS:
                                                                        Alkyl(C1240%;Cl450%;CI6IO%)
                                                       .rujms            dimethyl benzyl ammonium chloride ...0.3%
                                                       Baraii*           OTHER INGREDIENTS	99.7%
                                         NET WT 22 FL OZ11PT6 OZ) 650 ml     TOTAL INGREDIENTS	100.0%

-------
                                                                                                                         Version  9
  WHAM™ All Purpose Cleaner deans, deodorizes and disinfects household surfaces. Cuts
  grease and grime, removes stains. Kills Staphylococcus, Streptococcus and Salmonella
  bacteria. DIRECTIONS FOR USE: It is a violation of Federal law to use this product in a
  manner inconsistent with its labeling. TO OPERATE: Turn node to 'Spray' or 'Stream*.
  GENERAL CLEANING: Holding nozzle 6 to 8 inches from surface, spray soiled area, then wipe
 clean. Note: A rinse is required for surfaces in direct contact with food. Do not use on marble
 surfaces. DISINFECTION: Spray until thoroughly wet. Let stand 10 minutes before wiping or
 rinsing. For heavily soiled surfaces, preclean  according to General Cleaning Directions.
 MILDEW: Preclean surface, then spray until thoroughly wet. Let air dry. Repeat week,1/ or when
 new growth appears.
 PRECAUTIONARY STATEMENTS: HAZARDS TO HUMANS AND DOMESTIC ANIMALS.
 CAUTION: CAUSES EYE IRRITATION. Do not get in eyes, on skin or clothing. Avoid contact with
 foods. FIRST AID: In case of eye contact, flush with plenty of water for at least 15 minutes. Call a
 physician if irritation persists. STORAGE AND DISPOSAL Store in areas inaccessible to small
children. Do not reuse empty containers. Rinse thoroughly and discard in trash.
Contains no phosphates.
This bottle is made of 25% post-consumer recycled HOPE plastic.
QUESTIONS? COMMENTS? Call 1-&O555-5555
 EPA Reg. No 555-55, EPA Est No. 555-XX-I, YY-2,ZZ-3
 MADE BY THE WHAM COMPANY, 100 Main Street.
 Anywhere. USA, 12345. SATISFACTION GUARANTEED: If you are
 not fully satisfied, with mis product, please cal or write to tell us
 why. When writing, please include the barcode numbers and
  code printed on this package.
                                                        " •44600I0"662
                                                                                                                    391

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                                                                                                                               Version  10
                                       ,KEEP OUT OF REACH               ACTIVE INGREDIENTS:
                                        OFCHILDREN                     Alkyl|C1240%;C1450%;C1610%)
                                        CAUTION: See back panel for          ^m^ ^nif\ ammonium chloride -.0.3%
                                        additional precautionary statements.     OTHER INGREDIENTS	.99.7%
                                        NETWT22FLOZI1 PT60Z)650ml     TOTAL INGREDIENTS	100.0%
392
                      I1 III i ill i    iilllini'il
                                                                                                                                        i,,,,'in,!i'.!' |, 'Mil"  'i!;l:

-------
 ' WHAM™ All Purpose Cleaner cleans, deodorizes and disinfects household surfaces.
  Cuts grease and  grime, removes stains. Kills Staphylococcus, Streptococcus  and
  Salmonella bacteria.
  DIRECTIONS FOR USE: Use only as directed on this label.
                                                                                                                        Version  10
 10 OPERATE
 • Turn rjme to 'Spray' or 'Stream'.
 GENERAL CLEANING.
 • Hold icnie 6 to 8 inches ta surface
 • Spray soned area
 •Woe clean.
 Note: A nnse is required for surfaces in
direct contact wnti food. Do not use an
marble stmaces
                                      DISINFECTION
                                      •Spray until thoroughly weL
                                      • Let stand 10 minutes cefore wiping or raising
                                      • For heavily soiled surfaces, precfean
                                       according to General Cleaning Directions.
                                      MILDEW
                                      • Preclean surface
                                      • Spray until thoroughly wel
                                      • Let air dry. Repeat weedy or when new growth appears.
PRECAUTIONARY STATEMENTS: HAZARDS TO HUMANS AND ANIMALS.
CAUTION: CAUSES EYE IRRITATION. Avoid contact with eyes, skin or clothing. Avoid contact with
foods. FIRST AID: In case of eye contact, flush with plenty of water for at least 15 minutes. Call a
physician if irritation persists. STORAGE AND DISPOSAL Store in areas inaccessible to small
children. Do not reuse empty containers. Rinse thoroughly and discard in trash.
ENVIRONMENTAL INFORMATION: Contains no phosphates.
This bottle is made of 25% post-consumer recycled HOPE plastic.
QUESTIONS? COMMENTS? Call 1-800-555-5555
EPA Reg. No 555-55, EPA Est No. 555-XX-1, YY-2,2-3
MADE BY THE WHAM COMPANY. 10) Mail Street,
Anywhere. USA, 12345. SATISFACTION GUARANTEED: If you are
 not fully satisfied, with this product, please call or write to tell us
  why. When writing, please include the bar code numbers and
   code printed on this package.                           t
                                                                                                                        393

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394
                                                                       ACTIVE INGREDIENTS:
                                                                       Ajkyl|C12«Q%;CI45Q%;C1610%)
                                                                       dimethyl benzyl ammonium chloride ...0.3%
                                                                       OTHER INGREDIENTS	99.7%
                                                                       TOTAL INGREDIENTS	100.0%
                                                                                                                             Version  11

-------
                                                                                                                       Version   11
  WHAM™ All Purpose Cleaner cleans, deodorizes and disinfects household surfaces. Cuts
  grease  and  grime, removes stains. Kills Staphylococcus. Streptococcus and Salmonella
  tacteria. DIRECTIONS FOR USE- Use only as directed on this label.
  1. TO OPERATE: Turn nozzle to "Spray" or "Stream".
 2. GENERAL CLEANING: Holding nozzle 6 to 8 inches from surface, spray soiled area, then wipe
 clean. Note: A rinse is required for surfaces in direct contact with food. Do not use on marble surfaces.
 3. DISINFECTION: Spray until thoroughly wet Let stand 10 minutes before wiping or rinsing. For
 heavily soiled surfaces, preclean according to General Cleaning Directions.
 4. MILDEW: Preclean surface, then spray until thoroughly wet Let air dry Repeat weekly or when
 new growth appears.
 PRECAUTIONARY STATEMENTS: HAZARDS TO HUMANS AND ANIMALS.
 CAUTION: CAUSES EYE  IRRITATION. Avoid contact with eyes, skin  or clothing. Avoid contact with
foods. FIRST AID: In  case of eye contact, flush with plenty of water for at least 15 minutes. Call a
physician if irritation persists. STORAGE AND DISPOSAL Store in  areas inaccessible to small
children. Do not reuse empty containers. Rinse thoroughly and discard in trash.
ENVIRONMENTAL INFORMATION: Contains no phosphates.
This bottle is made of 25% post-consumer recycled HOPE plastic.
QUESTIONS? COMMENTS? Call 1-9004554555
 EPA Reg. No 555-55, EPA Est No. 555-XX-l, YY-2, ZZ-3
 MADE BY THE WHAM COMPANY, 100 Main Street.
 Anywhere. USA, 12345. SATISFACTION GUARANTEED: If you are
 not fully satisfied, with this product, please call or write to tell us
  why. When writing, please include the bar code numbers and
   code primed on this package.
                                                                                                                   395

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IF ii •«„!"» V"    li"       i1' ¥ ""i" " i"'i 11 ill." I'"  i  in   	  ': ."'"'	11
                                                                                                                                                         Version  12
                                                                                            ACTIVE INGREDIENTS:
                                                                                            AlkyHCi240%;Ci<50%;Ci6lO%)
                                                                                            dimethyl benzyl ammonium chloride —.0.3%
                                                                                            OTHER INGREDIENTS:	.917%
                                                                                            Other ingredients are: Deionized water,
                                                                                            solvent (to dissolve grease), surfactants
                                                                                            (cleaning agents), Sodium EDTA (aids cleaning
KEE'pluT OF REACH
OF CHILDREN
                                                           CAUTION: See back panel for
                                                                                            in hard water), perfume, blue colorant
                                                           additional precautionary statements,
                                                          NETWT22Ft.OZ|lPT60Z)650nil
               396

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                                                                                                                     Version  12
  WHAM™ All Purpose Cleaner cleans, deodorizes and disinfects household surfaces. Cuts
  grease  and grime, removes stains. Kills Staphylococcus, Streptococcus and Salmonella
  bacteria. DIRECTIONS FOR USE: It is a violation of Federal law to use this product in a
  manner  inconsistent  with its labeling. TO OPERATE: Turn nonle to "Spray" or "Stream".
  GENERAL CLEANING: Holding node 6 to 8 inches from surface, spray soiled area, then wipe
 clean. Note: A rinse is required for surfaces in direct contact with food. Oo not use on marble
 surfaces. DISINFECTION: Spray until thoroughly wet. Let stand 10 minutes before wiping or
 rinsing. For heavily soiled surfaces, preclean  according to General Cleaning Directions.
 MILDEW: Preclean surface, then spray until thoroughly wet. Let air dry. Repeat weekly or when
 new growth appears.
 PRECAUTIONARY STATEMENTS: HAZARDS TO HUMANS AND DOMESTIC ANIMALS.
 CAUTION: CAUSES EYE IRRITATION. Do not get in eyes, on skin or clothing. Avoid contact with
 foods. FIRST AID: In case of eye contact flush with plenty of water for at least 15 minutes. Call a
physician  if irritation persists. STORAGE AND  DISPOSAL Store in areas inaccessible to small
children. Do not reuse empty containers. Rinse thoroughly and discard in trash.
Contains no phosphates.
This bottle is made of 25% post-consumer recycled HOPE plastic.
 QUESTIONS? COMMENTS? Call 1-800-S5-555
 EPA Reg. No 555-55. EPA Est No. 555-XX-1, YT-2, ZZ-3
 MADE BYTHE WHAM COMPANY. 100 Main Street.
 Anywhere, USA. 12345.  SATISFACTION GUARANTEED: If you are
 not fully satisfied, with this product, please call or write to tel us
 why. When writing, please include the bar code numbers and
  code printed on this package.
                                                                                                                      397

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                                  ,-*'
                                              ALL'
                    URpOSE
                                                                   CLEANS"
                                                 "'^£-1
                                                . l«a~<*«w*>
                                           ..&'
                                               ./   /
.•KEEP OUT OF REACH
 OF CHILDREN
 CAUTION: See back panel for
 additional precautionary statements.

 NET WT 22 FL OZ 1 1 PT6 OZ ) 650 ml
                                                              Km INGREDIENTS:
                                                              Allcyl(C1240%;C1450%;C1610%)
                                                              dimett)y| ben2y| ammonium chloride .. J.3%
                                                              OTHER INGREDIENTS ._ ......... ________ 39.7%
                                                              TOTAL INGREDIENTS ----------- ....... -.100.0%
                                                                                                            Version 13
398

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                                                                                                                    Version  13
   WHAM™ All Purpose Cleaner cltrans, deboonzes and disinfects
   household surfaces. Cuts grease and gnrce, removes stains. Kills
   Staotiylococcus, Streptococcus and Salmonella bacteria.
  DIRECTIONS FOB USE. Use only as directed on this label.
           TO OPERATE
      GfflBALClKNIK.


          DBKFKTION

              MILDEW
  PRECAUTIONARY STATEMENTS. HAZARDS TO HUMANS AND ANIMALS
  HUMAN HEALTH
            Garni
            liffe
  STOMGE4 DISPOSAL
Turn norieto "Spray" ot "Stream"
Ho!*g norie6to8mcheslTonisi«f8ce.spny soiled area.then woe dean
Note: Annse is rawed for surfaces «i direct contact** food.Qo not USB
cnmaitlesudicu
Spray uml ftiirauglily wet Let stand 10 unites bstore wrong ornnsrg. for
heavily soled suites, oreclejn jccortnj K Generjl Cleaning OITKOOIU
Preclein surface, ta spray urc! ftoroujhly wet Let nr iliy
Repeat weekly or wtenneBgrowtti appears	
PiicaMJois
Keep oat ot reach otcMoren.
Oonotgetonslraorclotning.
Avoid contact wtfi foot
Causes eye intaton.
Avoid contact «* eyes.
Sim*
Store narejsraccesaole
to small children
Frt.W

Hush with plenty of waterfor at least
IS mnites. Call a pnvsain if million petsias.
DWCMl
Oo not reuse empty contaners.
Riue MmghV and discird in trasn
ENVinONMENTALINFORMATlON: Contains nophosphates
This oorte is made of 25% post-consumer recycled HOPE plastic
QUESTIONS? COMMENTS? Call HCO-555-5555
EPA Reg. No 555-55, EPA Est No. 555-XX-l, YY-2, ZZ-3
MADEBYTHEWHAMCOMfANY, 100Mam Street
 Anywhere, USA, 12345. SATISFACTION GUARANTEED: If you are
 not fully satisfied, wi* this pfoduct. please call or write to tell us
  wny When writing, please include the bar code numbers and
   code pnnted on this package
                                                                                                                       399

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-------
               Appendix 3-6:
indoor Insecticides Mock Label
                        401

-------
                                                                                  CONTROLA
402
                                              Kills fast
                                              for up to
                                              6 weeks
                          Fresh Scent
                                                        . ^
                         PtniieUiia [[[ 0.211%
                         2-11-HttiiittttirlfliiialiMthrletrliiaiHe ..................... 0.5B%
                         Tnlemeairia .................................................. O.m%
                         iftmaii Monte ttttoial.
                         OTHER 1HGREOIENTS:
                         coattint ftMtma dittillitts
                                                        O.U%
                          KEEP OUT OF REACH OF CHILDREN
                              CAUWNi^'SSr^
                             NETWT.11.50Z.(326g)
                                                                             This label is a representation
                                                                             of the information
                                                                             seen on real products, but
                                                                             does not accurately duplicate

-------
                                                                                                     CONTROL A
Kills fast in two ways: (1) it kills bugs fast-on contact
and (2) it keeps on killing with residual action even
after you spray, for up to 6 weeks.
DIRECTIONS FOR USE:
It is a violation oi Federal Law to use this product in a manner inconsistent with
its labeling.
FOR HOUSEHOLD USE SHAKE WELL BEFORE EACH USE. hold container
upright. Do not spray up into air. Apply to surfaces only. Point spray opening
toward surface to be sprayed and press button firmly. Hold about 12' from
surface being sprayed. Spray until surfaces are wet Avoid excessive wetting of
asphalt, tile, rubber and plastic materials. More frequent application will be
required to maintain control on olvwood surfaces. Repeat treatment as
necessary. ROACHES. PALMETTO BUGS, WATERBUGS, CRICKETS,
SILVEHFISH, KHO SPIDERS: Spray directly on insects when possible.
Thoroughly spray cracks, baseboards, underneath kitchen shelves, and other
places  where insects habitate. ANTSAHD EARWIGS: Spray door sills, wood
frames, outside foundations and porches. Spray directly on ant hills. FUES,
MOSQUITOES, GNATS, WASPS: Apply on screens, walls, doorand
window frames, and other surfaces where insects congregate.	
 STORAGE: Store away from heat or open flames, in an area inaccessible to
 children. DISPOSAL This container may be recycled in the tew       __
 but growing number ol communities mere aerosol can         rn
 recycling is available. Before ottering for recycling, empty       W   "u
 the can oy usingthe product according to the laoei         7P--.CTE F L^
 (DO NOT PUNCTURE!) It recycling is not available, replace    VT*' ~Lf
 cap, wrap in several layers of newspaper and discard in trash.
 PRECAUTIONARY STATEMENTS
 HAZARDS TO HUMANS AND DOMESTIC ANIMALS:
 CAUTION: Harmful it swallowed or'absorbed through the stin. Avoid breathing
 spray mist. Avoid contact with sldn or clothing. Wash thoroughly with soap and
 water after handling. Provide adeauate ventilation of area being treated. Do not
 apply to humans, pets, plants or contaminate feed. food stufts. dishes or utensils.
 Cover and avoid spraying fish aquariums. Cover or remove exposed food, dishes,
 utensils andtood handling equipment. Keep out at reach of children.
 FIRSTAIO	
 IF SWALLOWED: Call doctor or Poison Control Center immediately. Gastric
 lavage is indicated it material was taken internally. I Do not induce vomiting).
 IF IN EYES: Flush with plenty of water. IFONSKIN: Wash promptly with soao
 and water. Get medical attention it irritation persists or develops. IF INHALED:
 Remove victim to fresh air. Apply artificial respiration it indicated. NOTE TO
 PHYSICIAN: This product contains a cholinesterase inhibitor. It symptoms of
 cholmesterase inhibition are present, atropine is antidotal.
                        „    PHYSICAL OR CHEMICAL HAZARDS:
                              FLAMMABLE, CONTENTS UNDER
                              PRESSURE. Keep away from heat,
                              sparks, open flame or pilot lights. Do
                              not puncture or incinerate container.
                              Exposure to temperatures above 130'
                              may cause bursting.
                              Questions? Comments?
                              Call 800-123-4567
                              Weekdays 9-9
                              Eastern time
                              ©19XXWham
                              Company
                        _    EPAfieg.No.0000-000
                        0    EPAEst.No.OOOO-XX-0
                                                                                     This label is a representation
                                                                                     of the information
                                                                                     seen on real products, tut
                                                                                     does not accurately duplicate
                                                                                     a real brand.
                                                                                                     403

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                                                                             CONTROL B
                                           Kills fast
                                           for up to
                                           6 weeks
                         Fresh Scent
                       ACTIVE mGHBUBtTS:
                       fcnwft/fu
                       2- 11-MetWetlnit) tliemi noOr/iarlitiatte
                       Tnlomethrin
                       i-tatsMetMa
                       ornament wans.-
                       coatiias fettalmm iitBllttis
                                                    3t-S4%
                         KEEP OUT Of REACH OF CHILDREN
                             CAUTIONSS'SZr™'
                           NETWT.11.50Z.(326g)
404
                                                                         This label is a representation
                                                                         of the information
                                                                         seen on reaf products, but
                                                                         does not accurately duplicate
                                                                         a real brand.

-------
                                                                                                    CONTROL B
Kills fast in two ways: (1) it kills bugs fast-on contact
aid (2) it keeps on killing with residual action even
ifter you spray, for up to 6 weeks.
DIRECTIONS FOR USE:	
t is a violation of Federal Law to use this product in a manner inconsistent with
its labeling.
FOR HOUSEHOLD USE: SHAKE WELL BEFORE EACH USE. Apply to surfaces
only. Hold container upright. 12' from surface and spray. Spray iill surfaces are
vet. Amid over wetting asphalt tile, rubber and plastic materials. Repeat
treatment as necessary. ROACHES. CRICKETS, SILVERFISH, SPIDERS: Spray
directly on insects when possible. Thoroughly spray cracks, baseboards,
underneath kitchen shelves, and other places where insects habitate. ANTS,
EARWIGS: Spray door sills, wood frames, outside foundations and porches.
Spray directly on ant hills. FUES, MOSQUITOES, GNATS, WASPS:
Apply on screens,  mils, door and window frames, and other suilaces where
insects congregate
STORAGE: Store away trom heat or open flames, in area inaccessible to children.
DISPOSAL This container may be recycled in the few
out growing number of communities where aerosol can
recycling is available. Before offering tor recycling, empty
can by using product according to ihe label.
(DO NOT PUNCTURE!) If recycling is not available, replace
cap. wrap in several layers of newspaper and discard in trash.
PRECAUTIONARY STATEMENTS
HAZARDS TO HUMANS AND DOMESTIC ANIMALS:
CAUTION: Harmful if swallowed or absorbed through the skin. Avoid breathing
spray mist. Avoid contact with skin or clothing. Wash thoroughly wth soao and
water after handling. Provide adeguate ventilation of area being treated. Donot
aopfy to humans, pets, plants or contaminate feed, food stuffs, dishes or utensils.
Cover and avoid spraying fish aquariums. Cover or remove exposed food, dishes.
utensils and food handing equipment Keep out of reach of children.
FIRSTAID           	.	
 IF SWALLOWED: Call doctor or Poison Control Center immediately. Bastnc
 lavage is indicated if material was taken internally. IDo not induce vomiting).
 IF IN EYES: Flush with plenty of water. IF ON SKIN: Wash promptly witfi soao
 and water. Get medical attention if irritation persists or develops. IF INHALED:
 Remove victim to fresh air. Apply artificial respiration it indicated. NOTE TO
 PHYSICIAN: This product contains a cholinesterase inhibitor. If symptoms of
 cholinesterase inhibition am present, atropine is antidotal.

                             PHYSICAL OR CHEMICAL HAZARDS:
                             FLAMMABLE, CONTENTS UNDER
                             PRESSURE. Keep away from heat,
                             sparks, open flame or pilot lights. Do
                             not puncture or incinerate container.
                             Exposure to temperatures above 130'
                             may cause bursting.
                             Questions? Comments?
                             Call 800-123-4567
                             Weekdays 9-9
                             Eastern time
                             &19XXmam
                                             .
                             EPA Reg. No. 0000-000
                             EPAEst.No.OOOO-XX-0
                                                                                    This label is a representation
                                                                                    of the information
                                                                                    seen on real products, tut
                                                                                    does not accurately duplicate
                                                                                    a real t rand.
                                                                                                    405

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                                                                                   INGREDIENTS #1
                                                  Kills fast
                                                  for up to
                                                  6 weeks
                             Fresh Scent
                            12.2 aiOilonietlmytl Zf-ti
                                                            B.2IK
                           fifimaiitsiatHeteauial .................................... ».sn
                           OTHffl/WCH£D/£«7S: ......................................... U.45%
                           Otmriegreiliciitttrc:Witcr.B«tim/Pn>fme(ttnrfn>tillnl),tttnilimi-totul
                           talmtlto tfteo/M Ktiie iageaiiats). emtltilisis (la laef fiatut torn
                                ), je/ftme. comssea Mtoitat (stop an hem nofiftf
                             KEEP OUT Of REACH OF CHILDREN
                                 CAUTION:%%S%t»l%;r'am
                                NETWT.11.50Z.(326g)
406
                                                                                   This label is a rtpresentation
                                                                                   of the information
                                                                                   seen on real products, but
                                                                                   does not accurately duplicate
                                                                                   a real brand.

-------
                                                                                        INGREDIENTS #1
W//s fast in two ways: (1) it kills bugs fast-on contact
md (2) it keeps on killing with residual action even
ifteryou spray, for up to 6 weeks.
DIRECTIONS FOR USE:
(/ isa violation ot Federal Law to use this product in a manner inconsistent with
its labeling.
fOR HOUSEHOLD USE: SHAKE WELL BEFORE EACH USE. Apply to surfaces
only. Hold container upright. 12' from surface ant spray. Spray till surfaces are
wet. Avoid over wetting asphalt tile, rubber and plastic materials. Repeat
treatment as necessary. ROACHES, CRICKETS, S1LVEHF1SH, SPIDERS: Spray
directly on insects when possible. Thoroughly spray cracks, baseboards.
underneath kitchen shelves, and other places where insects hsbitate. AHTS,
EARWIGS: Spray door sills, wood frames, outside foundations and porches.
Spray directly on ant hills. FUES, MOSQUITOES, GNATS, WASPS:
Apply on screens, walls, door am) window frames, and other surfaces where
insects congregate.
STORAGE: Store away from heat or open flames, in area inaccessible to children.
DISPOSAL This container may be recycled in the few
but growing number of communities wnere aerosol can
recycling is available. Before offering for recycling, empty
can by using product according to the label.
(DO HOT PUNCTURE!) If recycling is not available, replace
can, wrap in several layers or newspaper and discard in trash.
PRECAUTIONARY STATEMENTS
HAZARDS TO HUMANS AND DOMESTIC ANIMALS:
CAUTION: Harmful it swallowed or absorbed through fte skin. Avoid breathing
spray mist. Avoid contact with skin or clothing. Wash thoroughly with soap and
water after handling. Provide adequate ventilation of area being treated. Donot
apply to humans, pets, plants or contaminate feed, food stuffs, dishes or utensils.
Cover and avoid spraying fish aquariums. Cover or remove exposed food, dishes.
utensils and food handling equipmenL Keep out ot reach of children.
FIRST AID
 IF SWALLOWED: Call doctor or Poison Control Center immediately. Gastric
 d/fU Hdici. uci ttiGutttQi aucniHJii ii itniaiiuti f/w»ww ui utfthiupt;. ii i
 Remove victim to fresh air. Apply artificial respiration if indicated. NOTE TO
 PHYSICIAN: This product contains a cholinesterase inhibitor, llsymptomsot
 cholinesterase inhibition are present, atropine is antidotal.

                             PHYSICAL OR CHEMICAL HAZARDS:
                             FLAMMABLE, CONTENTS UNDER
                             PRESSURE. Keep away from heat,
                             sparks, open flame or pilot lights. Do
                             not puncture or incinerate container.
                             Exposure to temperatures above 130'
                             may cause bursting.
                             Questions? Comments?
                             Call 800-123-4567
                             Weekdays 9-9
                             Eastern time
                             ©WXXWham
                             Company
                             address ooooo
                             All Rights Reserved.     -uumeat
                             EPA fieg. No. 0000400   vwm
                             EPAEst.No.OOOO-XX-0
                                                                                   This label is a representation
                                                                                   of the information
                                                                                   seen on real products, but
                                                                                   does not accurately duplicate
                                                                                   a real brand.
                                                                                                    407

-------
                                          Kills fast
                                          for up to
                                          6 weeks
                        Fresh Scent
                        KEEP OUT OF REACH OF CHILDREN
                            rni ITinAI- «E*H>™*U ncuimoHjmr
                            1/nU I f I/IV. i
                                    , STATBUHTSCHUCK
                          NETWT.11.50Z.(326g)
408
                                                                      INGREDIENTS #2
This label is a representation
of the information
seen on teal products, out
does not accurately duplicate
a real brand.

-------
                                                                                                  INGREDIENTS #2
Kills fast in two ways: (1) H kills bugs fast-on contact
and (2) it keeps on killing with residual action even
after you spray, for up to 6 weeks.
 DIRECmiHSFORIJSE:
 It is a minion ol federal Law to use tins product in a manner inconsistent with its landing.
 nRHOUSCHOLD USE: SHm WELL BEFORE EACH USE. Apply to surfaces only. Hold
 container upright. 12' from surtax and spray. Spray til surfaces an wet Avoid over
 wetting asphalt tile, rubier and plastic materials. Repeat treatment as necessary.
 ROACHES, CRICKETS. SILVERFISH,  SPIOERS: Spray directly on insects when possible.
 Thoroughly spray cracks, taseboards. underneath kitchen stakes, and otter places where
 insects habrute. AHTS, EARWIGS: Spray door sills, wood tames, outside foundations and
 porches. Spray directly on ant hills. FLIES, MOSQUITOES, GNATS, WASPS: Apply
 onsoeens, walk door and window frames, and other surfaces where insects congregate.
 STORAGE: Store nay from heat or open flames, in area inaccessible to children. DISPOSAL
 Tnis container may be recycled in the lew but growing number of communities where aerosol
 can recycling is available. Before offering for recycling, empty
 can by using product according to the label. (DO NOT PUNCTURE)
 II recycling is not available, replace cap, wrap in several layers of
 newspaper and discard in trash.
 HAZARDS TO HUHAHSAHODOHCSTICAHIMMS:
 CAUTION: Harmful if swallowta or absorbed through the skin. Avoid breathing spray mst.
 Avoid contact with Stan or clothing. Wash thoroughly with soap and water after landing.
 Provide adequate vHtbtnn olarea being treated. Do not apply to humans, pets, plants or
 conarmate teed, foodstuffs, dishes or utensils. Cover and avoid spraying fish aquariums.
 Cover or remove exposed food, dishes, utensils and tood fondling equipment. Keep out of
 teach of children:
 flRSTAlO	
 IF SWALLOWED: Call doctor or Poison Control Center immediately. Gastric lavageis
 indicated if material was taken imcnatt/. (Do not induce vomiuig).
 IF IN EYES: Flush with plenty of water. IF DM SB* Wash promptly with soap and water.
 Gitmedkal attention if irritation persists or develops. IF INHALED: Remove victim to
 fresh air. Apply artificial respiration if indicated. NOTE W PHYSIQAH: This product contains
 a cnoHixstenst inhibitor. II symptoms ol cholinesterase inhibition are present, atropine is
 antidotiai                                       	
                             .
  12,2 titaeroettnail) 2.2-aimetlrrlcrcloiropmartiojtyltte
 Prretirios
 Pitemarltettaiilittaaial
 OTHER IHBRCOICHTS: ........................................ ».«*
 Otter ingredients in: Witer, ttrtmtPropise Itpay frofeltnit), fetraln
 solvent llo dissohn ittm iagedients), emutsi/iers fto keep product Iran
 seccntiagi, perfume, camaxa insiiitor
-------
                                                           ".iFi'i ill1 • ,  " i.  Ni| " "i
410
                                             Kills fast
                                             for up to
                                             6 weeks
                          Fresh Scent
                         Pittnwltattuiilctitiuial .................................... «•»*
                                  .....
                         FttnteimOtstiUtttttlifMicMmafiui)
                         firiune.
                         &Nff«nf unite.
                         rani-
                                                      . uff.
                          KEEP OI^OFRF^CHJ^CJjLEm^^
                              CAUTION' snwiBnsmuai
                             NETWT.11.50L(326g)
                                                                            INGEDIENTS #3
                                                                           IJiis fcfle/ is a representation
                                                                           of the information
                                                                           seen on real products, but
                                                                           does not accurately duplicate
                                                                           a real brand.
                , KIHi	F	I: A I	 :, .ilifcii;	Illll'!;;,,!.!'; UiLliliii; Ja;	ill	illii

-------
                                                                                                   INGED1ENTS #3
                                       teh Scent
Kills fast in two ways: (1) it kills bugs fast-on contact
and (2) it keeps on killing with residual action even
after you spray, for up to 6 weeks.
 DIRECTIONS FOR USE
 Itisa violation of Federal Law to use this product in a manner inconsistent with
 its labeling.
 FOR HOUSEHOLD USE: SHAKE WELL BEFORE EACH USE. Apply to surfaces
 only. Hold container upright, 12' from surface and spray. Spray till surfaces are
 wet. Avoid over wetting asphalt tile, rubber and plastic materials. Repeat
 treatment as necessary. ROACHES. CRICKETS, SILVERFISH, SPIDERS: Spray
 directly on insects when possible. Thoroughly spray cracks, baseboanls,
 unaerneath kitchen shelves, and other places where insects habitate. ANTS,
 EARWIGS: Spray door sills, wood tomes, outside foundations and porches.
 Soray directly on ant hills. FLIES, MOSQUITOES, GNATS, WASPS:
 Aooiy on screens, walls, door and window frames, and other surfaces where
 insects congregate.	
 STORAGE: Store away from heat or open flames, in area inaccessible to children.
 DISPOSAL: This container may be recycled in the tew
 nut growing number of communities where aerosol can
 recycling is available. Before ottering for recycling, empty
 can bv using product according to me label.
 ,00 HOT PUNCTURE!) II recycling is not available, replace
 can. wrap in several layers ot newspaper and discard in hash.

 PRECAUTIONARY STATEMENTS
 HAZARDS TO HUMANS AHD DOMESTIC ANIMALS:
 CA UTIOH: Harmful if swallowed or absorbed through the skin. Avoid breathing
 sow mist. Avoid contact with skin or clothing. Wash thoroughly with soap and
 v/aier after handling. Provide adequate ventilation of area being treated. Do not
 aunty to humans, pets, plants or contaminate feed, food sfirffe. dishes or utensils.
 Cover and avoid spraying fish aquanums. Cover or remove exposed food, dishes,
 utensils and food handling equipment. Keep out ot reach of children.

 FIRSTAID	
  IFSWALLOWEO: Call doctor or Poison Control Center immediately. Gastric
  iavaae is indicated if material was taken internally. IDo not induce vomiting).
  IF IN EYES: Flush with plenty ot water. 1FOHSUN: Wash promptly with soao
  and water. Get medical attention ifirritation persists 01•develops. IFmHU£D:
  Remove victim to fresh air. Apply artificial respiration if Indicated. Him TO
  PHYSICIAN: This product contains a cholinesterase inhibitor, tt symptoms of
  cnoiinesterase inhibition are present atmpine is antidatial.
                              PHYSICAL OR CHEMICAL HAZARDS:
                              FLAMMABLE, CONTENTS UNDER
                              PRESSURE. Keep away from heat,
                              sparks, open flame or pilot lights. Do
                              not puncture or incinerate container.
                              Exposure to temperatures above 130'
                              may cause bursting.
                              Questions? Comments?
                              Call 800-123-4567
                              Weekdays 9-9
                              Eastern time
                              enaxxwham
                              Company
                              address ooooo
                              All Rights Resetted.
                              EPAReg.No.OOOtHHO
                              EPAEsLNo.OOOO-XX-0
                                                                                    This label is a representation
                                                                                    of the information
                                                                                    seen on real products, but
                                                                                    does not accurately duplicate
                                                                                    a real brand.
                                                                                                             411

-------
412
                       W&tffi
                                             Kills fast
                                             for up to
                                             6 weeks
                          Fresh Scent
                        ACTIVE INGREDIENTS:
                        Pumetixin [[[ O.XIX
                        Tnlomethrin .................................................. 0.MX
                        d-tnm/UleUuia ............................................... «.«%
                        Pynttiriia [[[ H.U%
                        Plpermftlittaiitlstectiiiicil. ................................... 9.59%
                        OTHER INGREDIENTS:. ........................................ U.54%
                        eaaiits fetmlion dttUllitts
                          KEEP OUT OF REACH OF CHILDREN
                             CAUTION:^fS^'SSraMr
                            NETWT.11.50Z.(326g)
                                                                        PRECAUTIONARY #4
                                            iiJ.i 1 ,; !''!". .|	i'.,, I, .ililJiiiiiiPII, !'	ill'liJIili: Hlliyi'llri	•'	Urtlllia Bii,,illm! """"iff'..!, ll rli'iili Mi,;

-------
                                                                                  PRECAUTIONARY  #4
Kills fast in two ways: (1) it kills bugs fast-on contact
and (2) it keeps on killing with residual action even
after you spray, for up to 6 weeks,
 DIRECTIONS FOR USE:
 Use only as directed on this label.

 FOR HOUSEHOLD USE: SHAKE WELL BEFORE EACH USE. Apply to surfaces
 only. Hold container upright, 12' from surface and spray. Spray till surfaces are
 wet. Avoid over wetting asphalt tile, rubber and plastic materials. Repeat
 treatment as necessary. ROACHES, CRICKETS, SILVERFISH, SPIDERS: Spray
 directly on insects when possible. Thoroughly spray cracks, baseboards.
 underneath kitchen shelves, and other places where insects hanitate. ANTS,
 EARWIGS: Spray door sills, wood frames, outside foundations and porches.
 Spray directly on ant hills. FUES, MOSQUITOES, GNATS, WASPS:
 Apply on screens, walls, door and window frames, and other surfaces where
 insects congregate.	'
 STORAGE: Store away from heat or open flames, in area inaccessible to children.
 DISPOSAL This container may be recycled in the tew
 but growing number of communities where aerosol can
 recycling is available. Before ottering for recycling, empty
 can bv using product according to the label.                    .rr,^
 (DO (IOT PUNCTURE!) II recycling is not available, replace   7Jf-$TEEL^
 cap, wrap in several layers of newspaper and discard in trash. VL       •  "
 PRECAUTIONARY STATEMENTS                        %
 HAZARDS TO HUMANS AHD ANIMALS:
 CAUTION: Harmful if swallowed or absorbed through the sliin. Avoid breathing
 sprav mist. Avoid contact with skin or clothing. Wash thoroughly with soap and
 water after handling. Provide adequate ventilation of area being treated. Do not
 apply to humans, pets, plants or contaminate teed. food stufls. dishes or utensils.
 Cover and avoid spraying fish aquariums. Cover or remove exposed food, dishes,
 utensils and food handling equipment. Keep out of reach ot children.
 FIRST AW
 IF SWALLOWED: Call doctor or Poison Control Center immediately. Gastric
 lavageis indicated if material was taken intemaltv. (Do not induce vomiting).
 IF IN EYES: Flush with plenty of water. IF OH SKIN: Wash promptly with soap
 andwater. Set medical attention if irritation persists or develops. IF INHALED:
 Remove victim to fresh air. Apply artificial[respiration if indicated. HOTE TO
 PHYSICIAN: This product contains a cholinesterase inhibitor. It symptoms of
 cholinesterase inhibition are present, atropine is antidotal.

                             PHYSICAL OR CHEMICAL HAZARDS:
                             FLAMMABLE, CONTENTS UNDER
                             PRESSURE. Keep away from heat.
                             sparks, open flame or pilot lights. Do
                             not puncture or incinerate container.
                             Exposure to temperatures above 130'
                             may cause bursting.
                             Questions? Comments?
                             Call 800-123-4567
                             Weekdays 9-9
                             Eastern time
                             ©WXXWham
                             All Rights Reserved.
                             EPA Reg. No. 0000000
                             EPAEst.No.OOOO-XX-0
                                                                                  This label is a representation
                                                                                  of the information
                                                                                  seen on real products, but
                                                                                  does not accurately duplicate
                                                                                  a real brand.

-------
      414
                                                Kills fast
                                                for up to
                                                6 weeks
                              Fresft Scenf
                            2- 11-HtKrHOMUjf) filial raethfleirtmite ..................... 0.50%
                                                         0.01%
                                                         3-50%
                              KEEP OUT OF REACH OF CHILDREN
                                 CAUTION^^^TST™
                                NETWT.11.50Z.p26g)
                                                                        PRECAUTIONARY #5
TWs label is a representation
of the information
seen on real products, but
does not accurately duplicate
a teal brand.
iliS, i  	1 'i     ill	1! ',1	,,,Ji,/  ,:,llii!" , I	Ili.
                                                      I!, -:l!!i ,;'•». 'M-'"'1 ii!vk,

-------
                                                                                  PRECAUTIONARY #5
Kills fast in two ways: (1) it kills bugs fast-on contact
and (2) it keeps on killing with residual action even
after you spray, for up to 6 weeks.
 DIRECTIONS FOR USE:
 Use only as directed on this label.
 FOR HOUSEHOLD USE SHAKE WELL BEFORE EACH USE. Apply to surfaces
 only Hold container upright, 12'from surface and spray. Spray till surfaces are
 wet Avoid over wetting asphalt tile, rubber and plastic materials. Repeat
 treatment as necessary. ROACHESWICKETS, SILVERFISH, SPIOERS: Spray
 directly on insects when possible. Thoroughly spray cracks, baseboards,
 underneath kitchen shelves, and other places where insects haiitate. ANTS,
 EARWIGS: Spray door sills, wood frames, outside foundations and porches.
 Spray directly on ant hills. FUES, MOSQUITOES, GNATS, WASPS:
 Apply on screens, walls, door and window frames, and other surfaces where
 insects congregate
 STORAGE: Store away from heat or open flames, in area inaccessible to children.
 DISPOSAL This container may be recycled in the few
 but growing number of communities where aerosol can
 recycling is available. Before offering for recycling, empty
 can by using product according to the label.
 (DO NOT PUNCTURE!) It recycling is not available, replace
 cap, wrap in several layers of newspaper and discard in trash.
  PRECAUTIONARY STATEMENTS
  HAZARDS TO HUMANS AND ANIMALS:
  CAUTION:
   • Harmful if swallowed or absorbed through the skin.
   • Avoid breathing spray mist.
   • Avoid contact with skin or clothing.
   • Wash thoroughly with soap and water after handling.
   • Provide adequate ventilation of area being treated.
   • Do not apply to humans, pets, plants or contaminate teed, food stuffs, dishes
    or utensils.
    Cover and avoid spraying fish aquariums.
    Cover or remove exposed food, dishes, utensils and food handling equipment
    Keep out of reach of children:    	.	
  FIRST AID
  IF SWALLOWED: Call doctor or Poison Control Center immediately. Gastric
  lavaoeis indicated if material was taken internal*/. I Do not induce vommng).
  IF IN EYES: Flush with plenty ol water. IF ON SKIN: Wash promptly with soao
  and water. Get medical attention H irritation persists or develops. IF WHALED:
  Remove victim to fresh air. Apply artificial respiration if Indicated. NOTE TO
  PHYSICIAN: This product contains a cholinesterase inhibitor. It symptoms of
  cholinesterase inhibition are present, atropine is antidotial.
                         O    PHYSICAL OH CHEMICAL HAZARDS:
                               FLAMMABLE, CONTENT,, UNDER
                               PRESSURE. Keep away from heat.
                               sparks, open time or pilot lights. Do
                               not puncture or incinerate container.
                               Exposure to temperatures above 130'may
                               cause bursting.
                               Questions? Comments?
                               Call 800-123^567
                               Weekdays 9-9
                               Eastern time
                               ©WXXWham
                               Company                	
                               address ooooo         mm. REGULATIONS
                               All Rights Reserved.   PROHIBIT CFCPROPSIAHTS
                               EPA Reg. No. 0000400
                               EPA Est. No. 0000-XX-O
                                                                                     This label is a representation
                                                                                     of'the information
                                                                                     seen on real products, tut
                                                                                     does not accurately duplicate
                                                                                                     415

-------
                                                                          USE INSTRUCTIONS #6
                                                 Kills fast
                                                 for up to
                                                 6 weeks
                            Fresh Scent
                          ACTIVE INBREDIEHTS:
                          Petmetorin
                          2-11-Mcthylcthory) ptiisol rnethfinrtimitt	0.50%
                          rn/omefArin	l.M%
                          it-tons AUHMa	0.05%
                                                           OJO%
                              l tetaildi teelmial.	0.50%
                          OTHER INGREDIENTS:	91.54%
                          eoatiiat ptholnm distill ties
                            KEEP OUT OF REACH OF CHILDREN
                                f*/tllTinti.sE/wtimoiuin£CAifnaiaiir
                                UttUIIUN. srm*Bnsont»cx

                               NETWT.11.50L(326g)
416
                                                                                 This label is a representation
                                                                                 oftheinfornution
                                                                                 seen on real products, but
                                                                                 does not accurately duplicate
                                                                                 a real brand.

-------
                                                                            USE   INSTRUCTIONS £6
Kills fast in two ways: (1) H kills bugs fast-on contact
and (2) it keeps on lolling with residual action even
after you spray, for up to 6 weeks.
DIRECTIONS FOR USE:
It is a violation ot Federal Law to use this product in a manner inconsistent with
its labeling.
FOR HOUSEHOLD USE:
   SHAKE WELL BEFORE/EACH USE. Apply to surfaces only.
   Hold container uprigfit, 12'from surface and spray.
   Spray till surfaces are wet. Avoid over wetting asphalt tile, rubber and
   plastic materials.'
   Repeat treatment as necessary.
POACHES. CRICKETS. SILVEHF1SH. SPIDERS: Spray directly on insects when
possible. Thoroughly spray cracks, baseboards, underneath otchsn shelves and
other places where insects habitate. ANTS, EARWIGS: Spray door sills, wood
frames, outside foundation and oorches. Spray directly on ant hills. FLIES,
MOSQUITOES, GNATS, WASPS: Apply on screen, walls, door and window
femes, and other surfaces where insects congregate.
 STORAGE: Store awav from heat or open names, in area inaccessible to children.
 DISPOSAL This container may be recycled in the few
 but growing number of communities where aerosol can
 recycling is available. Before offering for recycling,  empty
 can bv using product according to the label.               fflS
 (DO HOT PUNCTURE!) II recycling is not available, replace    X«J
 cap, wrap in several layers of newspaper and discard in trash.    ^
 PRECAUTIONARY STATEMENTS
 HAZARDS TO HUMANS AND DOMESTIC ANIMALS:	\
 CAUTION: Harmful if swallowed or absorbed through the skin. Avoid breathing
 spray mist. Avoid contact with skin or clothing. Wash thoroughly rat/i'soap and
 water after handling. Provide adequate ventilation of area being treated. Do not
 apply to humans, pets, plants or contaminate teed, food stuffs, dishes or utensils.
 Cover and avoid spraying fish aquariums. Cover or remove exposed food, dishes.
 utensils and food handling equipment. Keep out of reach of children.!
 FIRSTAID
 FIRSTAID	
 IF SWALLOWED: Call doctor or Poison Control Center immediately. Gastnc
 lavage is indicated it material was taken internally. Wo not indues vomiting).
 IF IN EYES: Flush with plenty of water. IF ON SttN: Wash promptly with soap
 and water. Get medical attention if irritation persists or develops. IF INHALED:
 Remove victim to fresh air. Apply artificial respiration if indicated. NOTE TO
 PHYSICIAN: This product contains a cholinesterase inhibitor. If symptoms ot
 cholinesterase inhibition are present, atmpine is antidotial.
                        0   PHYSICAL OR CHEMICAL WIZARDS:
                             FLAMMABLE. CONTENTS UNDER
                             PRESSURE. Keep away from heat,
                             sparks, open flame or pilot lights. Do
                             not puncture or incinerate container.
                             Exposure to temperatures above 130'
                             may cause bursting.
                             Questions? Comments?  •=••'
                             Call 800-123-4567
                             Weekdays 9-9
                             Eastern b'me
                             ©19XXWham
                             Company
                             address ooooo
                             EPA Reg. No. 0000000
                             EPAEstNo.OOOO-XX-0
                                                                                   This label is a representation
                                                                                   of the information
                                                                                   seen on real products, tut
                                                                                   does not accurately duplicate
                                                                                   a real brand.
                                                                                                 417

-------
418
                                                  Kills fast
                                                  for up to
                                                  6 weeks
                             Fresh Scent
                           ACTIVE INCREMENTS:
                           I- I1-Mettiyletlio*y) pluiml me^etiiimite ..................... 0.50%
                           Tnlomettrin .................................................. jjj%
                           tS-tnnsUlelMii ............................................... O.OS7.
                           Pyrtthriis ........... . ........................................ OJB%
                           Pipennyl liatoiide technical. ................................... t.50%
                           OTHIRWGREDIEHTS:. ........................................ U.54%
                           contiins filielimn tlsKllitts
                            KEEP OUT OF REACH OFCHILDREH
                                            ssonxmiui wuimaum
                                 pyi I IT7/1 Kl •
                                 UnU I IUN.

                               NETWT.11.50Z.(326g)
                                                                           USE INSTRUCTIONS #7
This label is a representation
of the information
seen on real products, but
does not accurately duplicate
a real brand.

-------
                                                                             USE  INSTRUCTIONS #7
                                       f^h Scent
Kills fast in two ways: (1) it kills bugs fast-on contact
and (2) it keeps on killing with residual action even
after you spray, for up to 6 wee/Its.
DIRECTIONS FOR USE:
It is a violation ol Federal Law to use this product in a manner inconsistent with
to labeling.
FOR HOUSEHOLD USE:
 I SHAKE WELL BEFORE EACH USE. Apply to surfaces only.
 2. Hold container upright, 12" from surface and spray.
 3. Spray till surfaces are wet. Avoid over wetting asphalt tile, rubber and
   paste materials.
 4. Repeat treatment as necessary.
ROACHES, CRICKETS, SILVERFISH, SPIDERS: Spray directly on insxts when
possible. Thoroughly spray cracks, baseboards, underneath kitchen shelves and
other places where insects habitats. ANTS, EARW1SS: Spray door sills, wood
frames, outside foundation and porches. Spray directly on ant hills. fUES,
MOSOUITOES. GHATS, WASPS: Apply on screen, walls, door and window
frames, and other surfaces where insects congregate.
 STORAGE: Store am from heat or open flames, in area inaccessible to children.
 DISPOSAL This container may be recycled in the tew
 but growing number of communities where aerosol can
 recycling is available. Before offering for recycling,  empty
 can by using product according to we label.
 (DO NOT PUNCTURE!! If recycling is not available,  replace
 cap, wrap in several layers or newspaper and discard in tiash.
 PRECAUTIONARY STATEMENTS
 HAZARDS TO HUMANS AHO DOMESTIC ANIMALS:
 CAUTION: Harmful if swallowed or absorbed through the skin. Avoid breathing
 soray mist. Avoid contact with skin or clothing. Wash thoroughly with soap and
 water after handling. Provide adequate ventilation of area being treated. Do not
 apply to humans, pets, plants or contaminate teed, food stuffs, dishes or utensils.
 Cover and avoid spraying fish aquariums. Cover or remove exposed food, dishes,
 utensils and food handling equipment. Keep out ol reach of children.
 FIRSTAID	
 IF SWALLOWED: Call doctor or Poison Control Center immediately. Bastric
 lavageis indicated if material was taken internally. (Do not induce vomiting).
 IF IN EYES: Flush with plenty of water. IF ON 5mH: Wash promptly win soao
 and water. Get medical attention if irritation persists or develops. IF INHALED:
 Remove victim to fresh air. Apply artificial respiration if indicated. MUTE TO
 PHYSICIAH: This product contains a cholinesterase inhibitor. Itsymptomsol
 cnolinesterase inhibition are present, atropine is antidotal.
                       „   PHYSICAL OR  CHEMICAL HUARDS:
                             FLAMMABLE, CONTENTS UHDER
                             PRESSURE. Keep away from heat,
                             sparks, open flame or pilot lights. Do
                             not puncture or incinerate container.
                             Exposure to temperatures above 130'
                             may cause bursting.
                             Questions? Comments?
                             Call800-123-4567
                             Weekdays 9-9
                             Eastern time
                             @l9XXWham
                             Comoanv
                        _    EPA Reg. No. 0000-000
                        °    EPAEst.No.OOOO-XX-0
                                                                                   This label is a representation
                                                                                   of the information
                                                                                   seen on real products, but
                                                                                   does not accurately duplicate
                                                                                   a real brand.
                                                                                                   419

-------
                                                                                           SIGNAL WORD #8
420
                                                        Kills fast
                                                        for up to
                                                        6 iveeArs
                                 Fresh Scent
                               ACTIVE INGREDIENTS:
                               ftnwftra	0.111%
                               H7*«ttjrttertp*f/io/msttjfc»*iiMfc	0.50%
                               Talmeltiria	0.01%
                               d-trmtAlliOiiia	0.05%
                               Pmthrias                      	OJO%
                               Wperaiixfititorirfeteeto/cj;.	 B.SO%
                               OTHER HtBREDKHTS:.	91.54%
                               Krtiiaspetraliemdittinttts
                                •  Hinntul II mllmnd or
                                  itnorttd Uraugti ikin.
                                        KEEP OUT OF REACH OF CHILDHEN
                                            nminini:l.saiaartmiim(amx
                                            CAUIIUN. aaaanmua

                                    NETWT.11.50Z.(326g)
                                                               ,,,|.	iJl|,| „ ,[,'„,Jj! ilLlLnh .
                                                                                            This label is a representation
                                                                                            of the information
                                                                                            seen on real products, but
                                                                                            does not accurately duplicate
                                                                                            a real brand.
                                                                                                    'nl'lii!; i, '.II; rEiiiiiSiiiili..;..!!!! ..iiftin.!!

-------
                                                                                          SJGNAL  WOPD  #8
                         Mf&IfflW
Kills fast in two ways: (1) it kills bugs fast-on contact
and (2) it keeps on killing with residual action even
after you spray,  for up to 6 weeks.
 DIRECTIONS FOR USE:
 It is a violation ol Federal Law to use this product in a manner inconsistent wit
 FOR HOUSEHOLD USE SHAKE WELL BEFORE EACH USE. Apply to surfaces
 only. Holt container upright, 12' from surface and spray. Spray till surfaces are
 wet. Avoid over wetting asphalt tile, rubber and plastic materials Repeat
 treatment as nedessary. ROACHES. CRICKETS, SILVERFISH, SPIDERS: Spray
 directly on insects when possible. Thoroughly spray cracks, baseboards
 underneath kitchen shelves, and other places where insects habitate. ANTS,
 EARWIGS: Spray door sills, wood frames, outside foundations and porches
 Spray directly on ant hills. FUES, MOSQUITOES, GNATS, WASPS:
 Appty on screens, walls, door and window frames, and other surfaces where
 insects congregate.	'
STORAGE: Store away from heat or open flames, in area inaccessible to children
DISPOSAL This container may he recycled in the few
Out growing number of communiies where aerosol can
recycling is available. Before ottering tor recycling, empty
can by using product according to the label.
IDO NOT PUNCTURE!) II recycling is not available, replace
cap, wrap in several layers of newspaper and discard in trash.
PRECAUTIONARY STATEMENTS
HAZARDS TO HUMANS AND DOMESTIC ANIMALS:
CAUTION: Harmful if swallowed or absorbed through the sldn. Avoid breathing
spray mist Avoid contact with skin or clothing. Wash thoroughly with soap and
water after hand/ing. Provide adeouate ventilation of area being treated Do not
apply to humans, pets, plants orcontaminate feed, foodstuffs, dishes or utensils
Cover and amid spraying fish aquariums. Cover or remove exposed food dishes
utensils and food handling equipment Keep out of reach of children.
FIRSTAID
IF SWALLOWED: Call doctor or Poson Control Center immediately. Gastric
lavage is indicated if material was taken intemallv. fDo not induce vomiting).
IF IN EYES: Flush with plenty of water. IF OH SKIN: Wash promptly withsoao
and water. Get medical attention if irritation persists or develops. IF INHALED:
Remove victim to fresh air. Apply artificial respiration if indicated. HOTE TO
PHYSICIAN: This product contains a cholinesterase inhibitor. If symptoms of
cnolinesterase inhibition are present, atropine is antidotial.
                            PHYSICAL OR CHEMICAL HAZARDS:
                      O
                      O
                      O
                     p

                      O
                      O
                      O
                      O
                      O
FLAMMABLE, CONTENTS UNDER
PRESSURE. Keep away from heat,
sparks, open flame or pilot lights. Do
not puncture or incinerate container.
Exposure to temperatures above 130'
may cause bursting.
Questions? Comments?
Call 800-123-4567
Weekdays 9-9
Eastern time
©WXXWIum
Company
addressooooo
All Rights Reserved.
EPA fieg. No. 0000-000
EPAEst.No.OOOO-XX-0
                                                                                  This label is a representation
                                                                                  of the information
                                                                                  seen on real products, but
                                                                                  does not accurately duplicate
                                                                                  a real brand.
                                                                                                 421

-------
422
                                                    Kills fast
                                                    for up to
                                                    6 weeks
                           ACTIVE INCREDIEHTS:
                                         	fl.29%
                                         meUiflejrtimtti	g,so%
                                  ................................
                           O-tntsAllitiiria .............................. _ ............... fl.05%
                           Pmlloitx [[[ 0.20%
                           cotiiia fitraliam ditlillttcs
                                  KEEP OUT OF REACH OF CHILDREN
                                NETWT.11.50Z.(326g)
                                                                                      SIGNAL WORD #9
This label is a representation
of the information

-------
                                                                                          SIGNAL WORD #9
Kills fast in two ways: (1) it kills bugs fast-on contact
and (2) it keeps on lolling with residual action even
after you spray, for up to 6 weeks.
 DIRECTIONS FOR USE:
 It is a violation ot Federal Law to use this product in a manner inconsistent with
 its labeling.

 FOR HOUSEHOLD USE: SHAKE WELL BEFORE EACH USE. Apply to surfaces
 only. Hold container upright, 12' Iron surface and spray. Spray till surfaces are
 wet. Avoid over wetting asphalt tile, rutjtjerand plastic materials. Repeat
 treatment as nedessary. ROACHES, CRICKETS, SILVERHSH, SPIDERS: Spray
 directly on insects when possible. Thoroughly spray cracks, baseboards.
 underneath kitchen shelves, and other places where insects habitate. AHTS,
 EARWIGS: Spray door sills, wood frames, outside foundations and porches.
 Spray directly on ant hills. FUES, MOSQUITOES, GNATS, WASPS:
 Apply on screens, walls, door and window frames, and other surfaces where
 insects congregate.
 STORAGE: Store awav from heat or open flames, in area inaccessible to children.
 DISPOSAL This container may be recycled in the few
 but growing number ol communities where aerosol can
 recycling is available. Before offering tor recycling, empty
 can by using product according to the label.
 (DO NOT PUNCTURE!) It recycling is not available, replace
 cap, wrap in several layers of newspaper and discard in trash.
 PRECAUTIONARY STATEMENTS
 HA2ARDS TO HUMANS AND DOMESTIC AHIMALS:
 CAUTION: Harmful it swallowed or absorbed through the skin. Avoid breathing
 spray mist. Avoid contact with skin or clothing. Wash thoroughly with soao and
 water after handling. Provide adequate ventilation of area being treated. Do not
 apply to humans, pets, plants or contaminate feed, food stuns, dishes or utensils.
 Cover and avoid spraying fish aquanums. Cover or remove exposed iood. oishes,
 utensils and food handling equipment Keep out ot teach ot children.
 F1RSTAID	
 IF SWALLOWED: Call doctor or Poson Control Center immediately. Gastnc
 la/age is indicated if material was taken internally. [Do not induce vomiting).
 IF IN EYES: Flush with plenty ot water. IF OH SuN: Wash promptly witSsoao
 andwater. Get medical attention il irritation persists or develops. IF'INHALED:
 Remove victim to fresh air. Apply artificial respiration it indicated. HDTE TO
 PHYSICIAN: This product contains a cholinesterase inhibitor. If symptoms ot
 cholinesterase inhibition are present, atropme is antidotial.
                             PHYSICAL OR CHEMICAL HAZARDS:
                             FLAMMABLE. CONTENTS UNDER
                             PRESSURE. Keep away from heat.
                             sparks, open flame or pilot lights. Do
                             not puncture or incinerate container.
                             Exposure to temperatures above 130'
                             may cause bursting.
                             Questions? Comments?
                             Call 800-123-4567
                             Weekdays 9-9
                             Eastern time
                             ©WXXWham
                             Company
                             address ooooo
                             All Rights Reserved.
                             EPA Reg. No. 0000400
                             EPAEst.No.OOOO-XX-0
                                                                                    This label is a representation
                                                                                    of the information
                                                                                    seen on real products, but
                                                                                    does not accurately duplicate
                                                                                    a mat brand.
                                                                                                      423

-------
                                                    Kills fast
                                                    for up to
                                                    6 weeks
                              Fresh Scent
                            ACTIVE INGREDIENTS:
                            Pimtthtin	OJO%
                            Z- (1-Httltfletlazy) ftmal mtthrluitinute	g.50%
                            TrUmethriii	B.01%
                            
-------
                                                                                        SIGNAL WORD #10
Kills fast in two ways: (1) it kills bugs fast-on contact
and (2) it keeps on killing with residual action even
after you spray, for up to 6 weeks.
 DIRECTIONS FOR USE:
 It is a violation of Federal Law to use this product in a manner inconsistent with
 its labeling.

 FOR HOUSEHOLD USE: SHAKE WELL BEFORE EACH USE. Apply to surfaces
 only. Hold container upright, 12'from surface and spray. Spay till surfaces are
 wet. Avoid over wetting asphalt, tile, rubber and plastic materials. Repeat
 treatment as necessary. ROACHES, CRICKETS, SILVERFISH, SPIDERS: Spray
 directly on insects when possiUs. Thoroughly spray cracks, baseboards.
 underneath kitchen shelves, and other places where insects habitats. ANTS,
 EARWIGS: Spray door sills, wood frames, outside foundations and porches.
 Spray directly on ant hi/Is. FUES, MOSQUITOES, GNAT3, WASPS:
 Apply on screens, walls, door and window frames, and other surfaces where
 insects congregate.	
 STORAGE: Store away from heat or open flames, in area inaccessible to children.
 DISPOSAL This container may be recycled in the few
 out growing number of communities where aerosol can
 recycling is available. Before pfienng for recycling, empty
 can by using product according to the label.
 100 NOT PUNCTURE!) II recycling is not available,  replace
 cap. wiap in several layers ot newspaper and discard in trash.
 PRECAUTIONARY STATEMENTS
 HAZARDS TO HUMANS AND DOMESTIC ANIMALS:
 OANSER: Fatal if swallowed or absormtl through the skin. Do not get in eyes, on
 sldn or on clothing. V/ear protective clothing and rubber gloves. Avoid breathing
 spray mist. Wash thoroughly with soao and water after handling and before eating,
 annting or using tobacco. Removt contaminated clothing and wash clothing
 betore use. Provide adequate ventilation of area being treated. Do not apply to
 numans. pets, plants or contaminate feed, food stuns, dishes orutensils.'Cover
 and avoid soraying fish aquariums. Cover or remove exposed food, dishes.
 utensils and food handling equipment. Keep out of reach ot children.
 FIRSTAID
 IFSWALLOWED: Call doctor or Poison Control Center immediately. Gastnc
 lavage is indicated if material was taken internally. IDo not induce'vomiting).
 IF IN EYES: Flush with plenty of water. IF ON SION: Wash promptly witf soao
 and water. Get medical attention if irritation persists or develops. IF 'INHALED:
 Remove victim to fresh air. Apply artificial respiration if indicated. HOTE TO
 PHYSICIAN: This product contains a cholinesterase inhibitor. If symptoms of
 cholinesterase inhibition are present, atropme is antidotal.


                              PHYSICAL OR CHEMICAL HAZARDS:
                             FLAMMABLE, CONTENTS UNDER
                             PRESSURE. Keep away from heat,
                             sparks, open flame or pilot lights. Do
                             not puncture or incinerate container.
                             Exposure to temperatures above 130'
                             may cause bursting.
                             Questions? Comments?
                             Call 800-123^567
                             Weekdays 9-9
                             Eastern time
                             ©19XXWham
                             Company
                             addressooooo
                             All Rights Reserved.
                             EPA Reg. No. 0000400
                             EPAEst.No.OOOO-XX-0
                                                                                    This label is a representation
                                                                                    of the information
                                                                                    seen on real products, out
                                                                                    does not accurately duplicate
                                                                                    3 real brand.
                                                                                                    425

-------
                                                 Kills fast
                                                 for up to
                                                 6 weeks
                            Fresh Scent
                           Jattmtma	JJJ*
                                                          »•«"
                           omnuiewtBns:
                                 . • Klip out of raach ot children.
                            8- '•!..§••> • Harmful or fatal II twallmad or ibtortud through skin.
                                 ^ « Sn additional precautionary itataiMiits on back.

                                KEEP OUT OF REA CH OF CHILDREN
                               NETWT.11.50Z.(326g)
                                                                            SIGNAL WORD #11
426
                                                                                This libel is a representation
                                                                                of the information
                                                                                seen on real products, but
                                                                                does not accurately duplicate
                                                                                a real brand.

-------
                                                                                        SIGNAL WORD
Kills fast in two ways: (1) it kills bugs fast-on contact
and (2) it keeps on killing with residual action even
after you spray, for up to 6 weeks.
 DIRECTIONS FOR USE:
 It is a violation ol Federal Law to use this product in a manner inconsistent with
 its labeling.

 FOR HOUSEHOLD USE: SHAKE WELL BEFORE EACH USE. Apply to surfaces
 only. Hold container upright, 12" from surface and spray. Spray till surfaces are
 wet. Avoid over wetting asphalt tile, rubber and plastic materials. Repeat
 treatment as nedessary. ROACHES, CRICKETS. SILVERFISH, SPIDERS: Spray
 directly on insects when possible. Thoroughly spray cracks, baseboards,
 underneath kitchen shelves, and other places where insects hahitate, ANTS,
 EARWIGS: Spray door sills, wood frames,  outside foundations and porches.
 Spray directly on ant hills. FLIES, MOSQUITOES, GNATS, WASPS:
 Apply on screens, walls, door and window frames, and other surfaces where
 insects congregate.	
 STORABE: Store away trom heat or open flames, in area inaccessible to children.
 DISPOSAL: This container may be recycled in the few
 out growing number of communities where aerosol can
 recycling is available. Before offering lor recycling, empty
 can by using product according to the label.
 100 NOT PUNCTURE!) If recycling is not available, replace
 cap, wrap in several layers of newspaper and discard in trash.
 PRECAUTIOHARY STATEMENTS
 HAZARDS W HUMANS AND DOMESTIC ANIMALS:
 CAUTION: Harmful if swallowed or absorbed thmugh the skin. Avoid breathing
 spray mist. Avoid contact with skin or clothing. Wash thoroughly Mfft soap and
 wateratter handling. Provide adequate ventilation of area being treated. Do not
 aoply to humans, pets, plants or contaminate teed, food stuffs, dishes or utensils.
 Cover and avoid spraying fish aquariums. Cover or remove exposed food, dishes.
 utensils and food handling equipment. Keep out of reach of children.
 FIRSTAID
 IF SWALLOWED: Call doctor or Poison Control Center immediately. Gastric
 lavage is indicated if material was taken internally. [Do not induce vomiting).
 IFINEYES:Fiushwithplentyofwater.lFONSaN:WashpromptlywitnsoaD
 and water. Get medical attention if irritation persists or develops. IF'INHALED:
 Remove victim to fresh air. Apply artificial respiration if indicated: HOTE TO
 PHYSICIAH: This product contains a cholinesteose inhibitor. Itsymptoms of
 cholinesterase inhibition are present, atropine is antidotal.
                              PHYSICAL OR CHEMICAL HAZARDS:
                              FLAMMABLE, CONTENTS UNDER
                              PRESSURE. Keep away from heat,
                              sparks, open flame or pilot lights. Do
                              not puncture or incinerate container.
                              Exposure to temperatures above 130'
                              may cause bursting.
                              Questions? Comments?
                              Call 800-123-4567
                              Weekdays 9-9
                              Eastern time
                              @1SXXWham
                              Company
                              addressooooo
                              All Rights Reserved.
                              EPA Reg. No. 0000-000
                              EPAEst.No.OOOO-XX-0
                                                                                    This label is a representation
                                                                                    of the information
                                                                                    seen on real products, but
                                                                                    does not accurately duplicate
                                                                                    a real brand.
                                                                                                     427

-------
428
                                            Kills fast
                                            for up to
                                            6 weeks
                         Fresh Scent
                        ACTIVE INGREDIENTS:
                        ftnwttm [[[ 0.10%
                                                     0.50%
                                                     0.81%
                                                     0.05%
                                                     0.50%
                              KEEP OUT OF REACH OF CHILDREN
                                 CAUTION:
istamauimaimmun
aaaamimua
                            NETWT.11.50Z.(326g)
                                                                       SIGNAL WORD #12
                                This label is a representation
                                of thB inlorwation
                                seen on teal products, but

-------
                                                                                      SIGNAL WORD #12
                         Ktt!lER\f**>> Scent
Kills fast in two ways: (1) it kills bugs fast-on contact
and (2) it keeps on lolling with residual action even
after you spray, for up to 6 weeks.
 DIRECTIONS FOR USE:
 It is a minion of Federal Law to use this product in a manner inconsistent with
 its labeling.
 FOR HOUSEHOLD USE: SHAKE WELL BEFORE EACH USE. Apply to surfaces
 only. Hold container upright, 12' from surface and spray. Spray till surfaces are
 wet. Avoid over wetting asphalt tile, rubber and plastic materials. Repeat
 treatment as nedessary. ROACHES, CRICKETS, SILVERFISH, SPIDEHS: Spray
 directly on insects when possible. Thoroughly spray cracks, baseboards,
 underneath kitchen shelves, and other places where insects habitate. ANTS,
 EARWIGS: Spray door sills, wood frames, outside foundations and oorches.
 Spray directly on ant hills. FlIES, MOSQUITOES, GNATS, WASPS:
 Apply on screens, walls, doorand window frames, and other surfaces where
 insects congregate.
STORAGE: Store away from heat or open flames, in area inaccessible to children.
DISPOSAL This container may be recycled in the few
but growing number of communities where aerosol can
recycling is available. Before offering tor recycling, empty
can by using product according to the label.
(DO NOT PUNCTURE!) It recycling is not available, replace
cap. wrap in several layers of newspaper and discard in trash,
PRECAUTIONARY STATEMENTS
HAZARDS TO HUMANS AND DOMESTIC ANIMALS:
                                                     ^p*^
                                                    f   jr
 CAUTION: Harmful if swallowed or absorbed through the skin. Avoid breathing
 spray mist. Avoid contact with skin or clothing. Wash thoroughly with soap and
 water after handling. Provide adequate ventilation of area being treated. Do not
 apply to humans, pets, plants or contaminate feed, food stuffs, dishes or utensils.
 Cover and avoid spraying fish aquariums. Cover or remove exposed food, dishes,
 utensils and food handling equipment. Keep out of reach of children.
 FIRSTAIO	
 IF SWALLOWED: Call doctor or Poison Control Center immediately. Gastric
 lavageis indicated if material was taken intemal/v. /Do not induce vomiting).
 IF IN EYES: Flush with plenty of water. IF ON SKIN: Wash promotly with soap
 andwater. Get medical attention if irritation persists or develops. IFItlHALED:
 Remove victim to fresh air. Apply artificial respiration if indicated. NOTE TO
 PHYSICIAN: This product cormms a cholinesterase inhibitor. If symptoms of
 cholinesterase inhibition are present, atropine is antidotal.
                             PHYSICAL OR CHEMICAL HAZARDS:
                             FLAMMABLE, CONTENTS UNDER
                             PRESSURE. Keep away from heat,
                             sparks, open flame or pilot lights. Do
                             not puncture or incinerate container.
                             Exposure to temperatures above 130'
                             may cause bursting.
                             may bduac vuioiuiy.
                             Questions? Comments?
                             Call800-123-45B7
                             Weekdays 9-9
                             Eastern time
                             ©19XXWham
                             Company
                                             .
                             EPA Reg. No. 0000-000
                             EPAEst.No.OOOO-XX-0
                                                                                   This label is a representation
                                                                                   of the information
                                                                                   seen on real products, but
                                                                                   does not accurately duplicate
                                                                                   a real brand.
                                                                                                   429

-------
430
                                                  Kills fast
                                                  for up to
                                                  6 weeks
                            Fresh Scent
                          ACTIVE INGREDIENTS:
                          PetmeOirin
                          2-(1-MettiytttlHur)phsinlinetlirlaitinute
                          Tnlmetltrin	0.01%
                          a-taosAHsMa	0.05%
                          Pmttiiias	ft***
                          PifenafttsKtideltclinial.	0.50%
                          OTHER INGRCDIENTS:.	91.54%
                            KEEP OUT OF REACH OF CHILDREN
                                nniiTinM-s&iwx™tuu-f*s*u™Mm
                                UnUIIUN. STATCHBirSOHUCK

                               NETWT.11.50Z.(326g)
                                                                                            BOX #13
This label is a representation
of the information
seen on real products, but
does not accurately duplicate
a real brand.

-------
                                                                                                            BOX #13
 Kills fast in two ways: (1) it kills bugs fast-on contact
 and (2) it keeps on killing with residual action even
 after you spray, for up to 6 weeks.
 DIRECTIONS FOR USE:
 It is a vioMon of Federal Law to use this product in a manner inconsistent with
 its labeling.

 FmHWEHOLDUSE:SHAKEWELLBEFOREFJtCHiJSE.Appr/tosurlaces
 only. Hold container upright. 12" from surface and spray. Spay till surfaces are
 wet Avoid over wetting aspnaS tile, rubber and plastic materials Repeat
 treatment as necessary. ROACHES, CRICKETS, SILVBIFISri, SPIDERS: Spray
 directly on insects when possible. Thoroughly spray cracks, baseboards
 underneath kitchen shelves, and other places where insects liabitate. Am,
 EARWIGS: Spray door sills, wood frames, outside foundations and porcnes
 Spray directly on ant hills. FLIES, MOSQUITOES, GNATS, WASPS:
 Apply on screens, walls, door and window frames, and other surfaces mere
 insects congregate.
          s£e aw!y fmm heat or°l>ett temes''" w* inaccessible to children.
 DISPOSAL: This container may be recycled in the few
 out growing number of communities mere aerosol can
 recycling is available. Before offering for recycling,  empty
 can by using product according to me label.
 (DO NOT PUNCTURE!) If recycling is not available,  replace
 cap, wrap in several layers o) newspaper and discard in trash
 PRECAimOHARY STATEMENTS                       	p
 HAZARDSTOHUMAHSAHDDOHESTICAHIHALS:
 CAUTIOH: Harmful if swallowed or absorbed through the skin. Avoid breathing
 spray mist. Ami contact with skin or clothing. Wash thoroughly with soao and
 rater after handling. Provide adeouate ventilation of area being treated. Do not
 apply to humans, pets, plants or contaminate feed, foodstuffs, ilishes or utensils.
 Cover ami avoid spraying fish aquanums. Cover or remove exposed food, disnes.
 utensils and food handling equipment Keep out of reach of children.
FIRST AID
IF SWALLOWED: Call doctor or Poison Control Center immediately. Gastric
l£np is indicated if material was taken internally. (Do not induce vomiting).
IF IN EYES: Flush with plenty at water. IF OH SKIN: Wash promptly with soao
and water. Get medical attention if irritation persists or develops. IF INHALED-
"imove victim to fresh air. Apply artificial respiration if indicated. MOTE TO
PHYSICIAN: This product contains a cholinesterase inhibitor. If symptoms of
cholinesterase inhibition are present, atropine is antidotial.
                            PHYSICAL OH CHEMICAL HOARDS:
                            FLAMMABLE, COHTEHTS UNDER
                            PRESSURE. Keep away from heat.
                            sparks, open flame or pilot lights. Do
                            not puncture or incinerate container.
                            Exposure to temperatures aiove 130'
                            may cause bursting.
                            Questions? Comments?
                            Call 800-123^567
                            Weekdays 9-9
                            Eastern time
                            
-------
                                          Kills fast
                                          for up to
                                          6 weeks
                        Fresh Scent
                      ACTIVE WGflHHCTTS:
                             ...............................................
                           [[[ ••£??
                       ctmtiiajHtoHiimiliitillitts


                        ^POiTfOFREACH^Fmom^


                          Nnm.1t50Z.T326g)
432
                                                                            BOX #14
                                                                     This libel is a representation
                                                                     of the information
                                                                     seen on real products, but
                                                                     does not accuntely duplicate

-------
                                                                                                            BOX #14
Kills fast in two ways: (1) it kills bugs fast-on contact
and (2) it keeps on killing with residual action even
after you spray, for up to 6 weeks.
 DIRECTIONS FOR USE:
 It is a violation of Federal Law to use this product in a manner inconsistent with
 its labeling.

 FOR HOUSEHOLD USE: SHAKE WELL BEFORE EACH USE. Apply to surfaces
 only. Hold container upright, 12'from surface and spray. Sprsy till surfaces are
 wet. Avoid over wetting asphalt Vie. rubber and plastic materials. Repeat
 treatment as necessary. ROACHES, CRICKETS, SILVERFISH, SPIOERS: Spray
 directly on insects when possible. Thoroughly spray, cracks, baseboards:
 underneath kitchen shelves, and other places where insects habitate. ANTS,
 EARWIGS: Spray doorsills, wood frames, outside foundations and porches.
 Spray directly on ant hills. FUES, MOSQUITOES, GNATS,  WASPS:
 Apply on screens, walls, door and window frames, and other surfaces where
 insects congregate.
STORAGE: Store away from heat or open flames, in area inaccessible to children.
DISPOSAL: This container may be recycled in the lew
but growing number of communities where aerosol can
recycling is available. Before offering for recycling, empty
can by using product according to we label.
(00 NOT PUNCTURE!) If recycling is not available, replace
cao. wrart in several layers of newspaper and discard in trash.
PRECAUTIONARY STATEMENTS
HAZARDS TO HUMANS AND DOMESTIC AHIMALS:
CAUTION: Harmful if swallowed or absorbed through the skin. Atvid breaming  •
spray mist. Avoid contact with skin or clothing. Wash thoroughly with soap and
water alter handling. Provide adequate ventilation of area being treated. Do not
aoply to humans, pets, plants or contaminate teed, food stuffs, dishes or utensils.
over and avoid spraying fish aquariums. Cover or remove exposed food, dishes,
utensils and food handling equipment. Keep out of reach of children.
FIRST AW
IF SWALLOWED: Call doctor or Poison Control Center iriimedialely. Gastric
lavage is indicated it material was taken internally. IDo not induce vomrSng).
IF IN EYES: Flush with plenty of water. IF ON SUN: Wash promptty with soap
andwater. Bet medical attention if irritation persists or develops. IF INHALED:
Remove victim to fresh air. Apply artificial respiration if indicated. HOTE TO
PHYSICIAN: This product contains a cholinesterase inhibitor. It symptoms of
cholinesterase inhibition are present, atrorjineisantJdotial.
                      O
                      O
                      O
                      O
                      p

                      O
                      O
                      O
                      O
                      O
PHYSICAL OR CHEMICAL HAZARDS:
FLAMMABLE, CONTENTS UNDER
PRESSURE. Keep away from heat,
sparks, open flame or pilot lights. Do
not puncture or incinerate container.
Exposure to temperatures above 130'
may cause bursting.
Questions? Comments?
Call 800-123-4567
Weekdays 9-9
Eastern time
©19XXWham
Company                 —
address ooooo      ..nrairaurois
                                            .
                            EPA fieg.'No. 0X0400
                            EPAEst.No.OOOO-XX-0
                                                                                   This label is a representation
                                                                                   of the information
                                                                                   seen on real products, tut
                                                                                   does not accurately duplicate
                                                                                  a real brand.
                                                                                                   433

-------
                                                                                         BOX #15
                                                 Kills fast
                                                 for up to
                                                 6 weeks
                            Fresh Scent
                           ACTIVE MGR£DI£HTS:
                           fenoetmn	(USX
                           2-(1-MctWttlair)ii!nKlmetlirtarttmttt	J.5IX
                                                          0.01%
                                                          f.H%
                                                          B.2B%
                               tiOoiiili tet*»/«/.	ftSSX
                                                          M.54%
                            KEEP OUT OF REACH OF CHILDREN
                                /tMIITinKi.ssADonmuinEuuiiauiir
                                IfAUIIUN. smoamoHtux

                               NETWT.11.50Z.(326g)
434
                                                                                This label is a representation
                                                                                of the information
                                                                                seen on real products, but
                                                                                does not accurately duplicate
                                                                                a real brand.

-------
                                                                                                         BOX #15
                         KILLER} I*** Scent
Kills fast in two ways: (1) it kills bugs fast-on contact
and (2) it keeps on kitting with residual action even
after you spray, for up to 6 weeks.
 DIRECTIONS FOR USE:
 It is a violation of Federal Law to use this product in a manner inconsistent with
 its labeling.
 FOR HOUSEHOLD USE: SHAKE WELL BEFORE EACH USE. Apply to surfaces
 only. Hold container upright, 12'from surface and soray. Spray till surfaces are
 wet. Avoid over wetting asphalt tile, rubber and plastic materials. Repeat
 treatment as necessary. ROACHES, CRICKETS, S1LVERFISH, SPIDERS: Spray
 directly on insects when possible. Thoroughly spray cracks, baseboards,
 underneath kitchen shelves, and other places where insects habitats. ANTS,
 EARWIGS: Spray door sills, mod frames, outside foundations and porches.
 Spray directly on ant hills. FUES, MOSQUITOES, GNATS, WASPS:
 Apply on screens, walls, door and window frames, and othersurfacts where
 insects congregate.
STORAGE: Store away from heat or open flames, in area inaccessible to children.
DISPOSAL This container may be recycled in the few
but growing number of communities where aerosol can   •
recycling is available. Before offering for recycling, empty
can bv using product according to me label. -.
(DO HOT PUNCTURE!) If recycling is not available, replace
cao. wrap in several layers of newspaper and discard in trash.
 PRECAUTIONARY STATEMENTS
 HAZARDS TO HUMANS AHD DOMESTIC ANIMALS:
 CAUTION: Harmful if swallowed or absorbed through the skin. Avoid breathing
 spray mist. Avoid contact with skin or doming. Wash thoroughly with soap and
 water after handling. Provide, adequate ventilation otarea being treated. Do not
 apply to humans, pets, plants or contaminate feed. food stuffs, dishes or utensils.
 Cover and avoid spraying fish aquariums. Cover or remove exposed load, dishes,
 utensils and food handling equipment. Keep out of reach of children.   	
 FIRST AID
  IN THE CASC PRODUCT:
       •lsnallomd_

       •Bets ineres	

       •Btttitttian
           IHHEDUTfLr
•CHI incur or PamicnmlCvittrirTmtttt/tly.
•Do not mince mamg.	•

•Ruth mini plenty of wtir.
                         • Set nwfcal atom it /mown Penan or Ontfops.
                         •Bamemtmatmnitr'.'
 mtatuanoasm. imomisinttHita.
                            PHYSICAL Off CHEMICAL HAZARDS:
                            FLAMMABLE, CONTENTS UNDER
                            PRESSURE. Keep away from heat,
                            sparks, open flame or pilot lights. Do
                            not puncture or incinerate container.
                            Exposure to temperatures above 130'
                            may cause bursting.
                            Questions? Comments?  >^(§ix
                            Call 800-12M567    /SS«£&
                            Weekdays 9-9  .     Y«^^«Y
                            Eastern time
                            ©19XXWham
                            Company
                            address ooooo
                            All Rights Reserved.
                            EPA Reg. No. 0000^00
                            EPAEst.No.OOOO-XX-0
                                                                                 This label is a representation
                                                                                 of the information
                                                                                 seen on real products, but
                                                                                 does not accurately duplicate
                                                                                 a real brand.
                                                                                                 435

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                                                                            COMBINE PROP #16
                                                 Kills fast
                                                 for up to
                                                 6 weeks
                            Fresfi Scent
                          Petmtiiiia	
                          2-(1-M*tlirl»thoir)tlii»eliTaeiyleMtimtte	0.5W4
                          Tnlametririn	
                          ii-taittMe»ri»	
                          PmtiaiiB	
                          Rferattfltatiiidetultaieil.	fl.50%
                          OTHEHIHGReaiBUS:.	«•«*
                          caitiits fetnliam titSllttss
                            KEEP OUT OF REACH OF CHILDREN
                                /* A11Tln M- ueaonmiu. nBuunuum
                                UAUIIUN. SMTBUMSWMOr

                               NETWT.11.50Z.(326g)
436
                                                                                 This label is a representation
                                                                                 of the information
                                                                                 seen on real products, but
                                                                                 does not accurately duplicate
                                                                                 a real brand.

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                                                                                 COMBINE PROP
                        KILLER} F"*h Scent
Kills fast in two ways: (1) it kills bugs fast-on contact
and (2) it keeps on killing with residual action even
after you spray, for up to 6 weeks.
 D1RCCHOHS FOR USE:
 FM HOUSEHOLD USE:

 •  SHMeWEU.8ffO

 •  HMccnums/!nght,irtrtirrisariaaan
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                                                                                                                                          INTEGRATED #1
                                            Kills fast in two ways: (1) it kills bugs fast-on contact
                                            and (2) it keeps on killing with residual action even
                                            after you spray, for up to 6 weeks.
                                             DIRECTIONS FOR USE
                                             Use only is directed on Otis label

                                             FOR HOUSEHOLD USE:
                                             I  SHAKE \VELL BEFORE EACH USE. Apply to surfaces only.
                                             2.  Hold cornier upright 12' from surface and spray.
                                             J.  Sony t>3 surfaces are mi Avoid over wetting asphalt tile, rater and
                                                p&sftc xsiemis.
                                             •!,  Repeat lament as necessary.

                                             ROACHES. CRICKETS, SILVERFISH. SPIDERS: Spray directly on insects when
                                             ;osable. Thoroughly spray cracks, baseooards. unnemeath kitchen sneives and
                                             •Merpixis -mre insects habitate. ANTS, EARWIGS: Spray door sills, wood
                                             'fames, oosxi foundation and larches. Spray directly on ant hills. FUES.
                                             MOSQUITOES. GNATS. WASPS: Aoplv on screen, walls, doorandwmdow
                                             'fames, sra other sunaces mere insects congregate.
                                             STORAGE: Store away from neat or ooen times, in area
                                             .nacxssxa :o children. DISPOSAL: This container may be
                                             •KVC/M.YJ communities mere aerosol can rending is
                                             •vitiate. Omy recycle emotycan. (DO HOT PUNCTURE!}
                                             It recycling* nut available, replace cao, map in several layers
                                             cinewsssarandoiscardintrasn.
                                            PRECAUTIONARYSTATEHEHTS
                                            HAZARDS TO HUMANS AND DOMESTIC ANIMALS:
                                             CAUTION: .-iarmlul il swallowed or absorbed through skin. Avoid breathing spray
                                             mist. Avoo csntact with sum or clothing. Wash thoroughly with soap and water
                                             snir handing. Provide aaeeuite ventilation ot area being treated. Do not apuy to
                                             numans. :ns. plants or contaminate feed. tood stuffs, dishes or utensils. Cover
                                             iioavaasirawglishaauanums. Cover ot remove exposed food, dishes.
                                             census sr.c food nandUng eQUiDment.Keeooutot reach ot children.
                                            FIRSTiM
                                              IN THE USE PRODUCT:

                                                  •lsfntimtt_

                                              	• Gets iii eyes _

                                                  • Sets an stiii
           IMMEBUTn
•Horn: Mutt vom
•till Paste Cmia
•telPtyacai
• WKR onijioov wrtft soip M voter.
                                                                     aimntvamtalransr.
                                                          J	-tiny into* mamm it it
                                                                            aMtotor. tlsmftaaaaloamseaa
                                                                       PHYSICAL OR CHEMICAL HAZARDS:
                                                                       FLAMMABLE. CONTENTS UNDER
                                                                       PRESSURE. Keep away from heat.
                                                                       sparks, open flame or pilot lights. Do
                                                                       not puncture or incinerate container.
                                                                       Exposure to temperatures above 130'
                                                                       may cause bursting.
                                                                       Questions? Comments?
                                                                       Call 800-123-45B7 Weekdays 9-9
                                                                       Eastern time ©19XX Wham Company
                                                                       address onooo All Rights Reserved.
                                                                       EPAReg.No.Oomm
                                                                       EPA Est No. OOOO-XX-0
                                                                                                                          This label is a representation
                                                                                                                          of the information
                                                                                                                          seen on real products, but
                                                                                                                          does not accurately duplicate
                                                                                                                          a real brand.
438

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                                                                                                     INTEGRATED #2
                                        f^h Scent
Kills fast in two ways: (1) it kills bugs fast-on contact
and (2) it keeps on killing with residual action even
after you spray, for up to 6 weeks.
 DIRECTIONS FOR USE:
 Use ony as directed on this lapel.
 I.  SHAKE 'JVELL BEFORE EACH USE. Apply to surfaces only.
 2.  HoW container upright. 1? from surface and spray.
 3.  Soray till surfaces are wet. Amid over wetting asphalt fie, rvoberand
    plastic natenals.
 •i.  Repeat ireatment as necessary.
 ROACHES. CRICKETS. SIL VERFISH. SPIDERS: Spray directly on insects when
 cosao/fi. Thoroughly soraycraclss. baseboards, underneath Kitchen siielves snd
 ste' o/aces mere insects hatntate. AHTS. EARWIGS: Spray door sills, wood
 trams, outsioe foundation and oorches. Spray directly on ant hills. FLIES,
 MOSQUITOES. GNATS, WASPS: Apply on screen, walls, door and window
 irames. sno ower surfaces vnere insects congregate.	
 STORAGE: Store away from neat or ooen names, in area
 .naccessicle :o children. DISPOSAL: This container may
 3recycled in communities -mere aerosol can
 nc.-ciino s available. Onlv recycle empty can.
 •00 NOT PUNCTURE!) If reeling is not available, replace
 KD •yrao m several layers oi newspaper and oiscard in trash.
 PRECAUTIONARY STATEMENTS
 HAZARDS TO HUMANS AND ANIMALS:
 CAUTION:
  • riarmiui if si/allowed or absorbed through tie skin.
  • Avoid breathing spray mist
  • Avoid contact with skin or clothing.
  • Wasn sioroughly with soap and water after handling.
  • Proves adequate ventilation of area being treated.
  • So not apoly to humans, pets'plants orcontamirate teed, food stuffs, dishes
    oroensiis.
  •Cover and avoid spraying Ssh aquariums.
  • Cover or remove exposed food, dishes, utensils and food handling equipment.
 ' • -<«o cut of reach of children	
 FIRSTAIO
 IF SWALLOWED: Call doctor or Poison Control Center immediately. Gastric
 iavaoe is moicated if material was taken internally. (Do not induce vomiting).
 IF Ik EYES: Flush with plenty of water. IF ON SUN: WashpromOly with soao
 ano water. Set medical attention if irritation persists or develops. IF INHALED:
 Remove victim to fresh air. Apply artificial respiration if indicated. NOTE TO
 PHYSICIAN: This product contains a cholinesterase inhibitor. If symptoms of
 snoiinesterase inhibition are present, atropme is antidotial.
                             PHYSICAL OH CHEMICAL HAZARDS:
                             FLAMMABLE, COHTEHTS UNDER
                             PRESSURE. Keep away tram heat,
                             sparks, open name or pilot lights. Do
                             not puncture orinoncott container.
                             Exposure to temperatures alxn/c 130'may
                             cause bursting.
                             Questions? Comments? Call 800-123-4567
                             WteMavs 9-9 Eastern time
                             ®13XX'Wham Company
                             address ooooo
                             All Rigms Reserved.
                             EPAReg.No.OOOMW
                             EPAEstNo.moO-XX-rj
                                                                                    This label is a representation
                                                                                    of the information
                                                                                    seen on real products, tut
                                                                                    does not accurately duplicate
                                                                                    a real brand.
                                                                                                           439

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                                                                                                                                           INTEGRATED #3
                                           Kills fast in two ways: (1) it Idlls bugs fast-on contact
                                           and 12) it keeps on killing with residual action even
                                           after you spray, for up to 6 weeks.
                                           DIRECTIONS FOH USE
                                           Usioniyas sinned on this label
                                           FOR HOUSEHOLD USE:
                                            !, SHAH* 'OBJ. BEFORE EACH USE. Apply to surfaces only.
                                           2, Holdixntaincrupngnt Whom surface and stay.
                                           3. Sam ;;l surfaces are mt Avoid over wetting asphalt fife, rubber anil
                                              piisic-atcnals.
                                           1. Reoczyeamcnt as necessary.
                                                                                           shelves and ottitr
                                                                 .,
                                           GHATS. WASPS: Aooiy on screen. walls, door and window fames, ana other surfaces
                                           mere uisxs congregate.
                                           STORAGE: Store away from neat or ooen limes.- in area
                                           iniKtss;;,; so cmldr'en. DISPOSAL This container may be
                                           reetctei :.i ^immunities wnereaerosol can recycling!!
                                           availaoe. Cnyrec/tie empty can. IDO HOT PUNCTURE!)
                                           II recvc:~s.s not available, reoiacecap. wrap in several layers
                                           a newsczsrana discara in trasn.
                                           PRECAUTIONARY STATEMENTS
                                           HAZARDS TO HUMANS AND DOMESTIC ANIMALS:
                                           CAUflOH: -.smiul il swallowea or assomed through skm. Avoid breathing sprav mist
                                           Ami c:r.z~ with sKin or dotting. Wasn ttmugnlv with soao and water afar handling.
                                           P'ovme ;:;cnate ventilation of area oeing treateo. Oo not apply to immms. pets, plants
                                           cr CC/IS-CTS teed. fooo starts, aisncs or utensils. Cover ana avoid spraying tish
                                           aauam-s. Cover or remove exoosed food, disnes. utensils and food handling
                                           !tniiomer,i out of reacnot children.
                                           FIBSTAID
                                            m me use rnooucfr
                                                                   •Domt
• Is swallmed_
• Getsincyes_
• Gets on skin

•Isinaaled
                                                                   'CHIPosioiCmra
                                                           1	•_Cjllftysean_ __
                                                                                    r, wtun fofinutj is oit file.
                                                                   •Hionvim nontyctiottr.
                                                                   • flMMW vicsni is tttsh aw.
                                             'SiCyn- ^m Draw coma i caamsanse nssMor, it smmna of anmamu
                                             MCI it sitscm. jireofw is nosaoi.
                                          ACTIVE INGREDIENTS:
                                          IPumttmnZ- fl-Mcthylitlnuyi phenol methylartimtte, Tnlomtttrin,
                                          i-tnts Allethrin. Pyittnrins. Piperonyl butoiide technial)
                                          OTHER INGREDIENTS:	SI.S4X
                                          contains petroleum distillates
                                                                      PHYSICAL OR CHEMICAL HAZARDS:
                                                                O
                                                               ;o
                                                                a
                                                                a
                                                               P
                                                                o
                                                                o
                                                                o
                                                                o
                                                                a
                     FLAMMABLE, CONTENTS UNDER
                     PRESSURE. Keep away from heat.
                     sparks, open flame or pilot lights. Do
                     not puncture or incinerate container.
                     Exposure to temperatures above 130'
                     may cause Bursting.
                     Questions? Comments?
                     Call 800-123-4567 Weekdays 9-9
                     Eastern time ©19XX Wham Company
                     address ooooo All Rights Reserved.
                                                                            ..
                                                                      EPAEsLNo.OOOO-XX-0
                                                                                                                          This label is a itpnsentation
                                                                                                                          of the information
                                                                                                                          seen on real products, but
                                                                                                                          does rot accurately duptiute
                                                                                                                          a real brand.
440

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                               Appendix 3-7:
Drafts of "Read the Label FIRST!" Campaign Logo
                                        441

-------
      442





Design-1

-------
           THE
         LABEL
             THE •
            LABEL
                        443
Design-2

-------

            READmE
            LABEL
            FIRST
                  t	;;.; '
             READim
              .UEAOn.
              ^ LABEL
              FIRST
  444


Design-3


-------
                 Read
                 Label
         First
             lead
             The
             Label
          First
 ead
The
Label
                     Label
                             445
Design-4

-------
  11 Ml" "I!" ; ' • 'I'1"' ' » HIS  	TO
                                  the Label
                            IheUbel
  446
Design-5
           INI  	mill -.(• r' • MI I'i'i;1: '/Hit. <
                                         'l.iir; ..... ;,i .lililB iii. „:,.'',, V , Ilia1-:/
                                                  I.M. '..H.^iH ' , .: !iiH. >, -, .;. .Jill '' ''Biiil ..... I'll!! .ifllE .

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447

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                                  Appendix 3-8:
Open-ended Questions on Consumer Label Preference
                                         449

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I would like to get your reaction to some language for the direction for use
section on a label.

Please read each statement  Put a star in front of the one that you like the
best. Write your reasons for liking or not liking each statement in the place
provided.

Use safely. Read  the label first before use.
Use* only as directed on label.
For safe and effective use, read the label first.
                                                                        451

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    Please read the next two statements. Put a star in front of the one that you
   ' like the best. Write your reasons for liking or not liking each statement in
    the place provided.

    Repeat as needed.
                                                         ~T
    Apply no more than "X" treatments per week.
    Please read the next two statements. Put a star in front of the one that you
    like the best Write your reasons for liking or not liking each
    statement in the place provided.
    Keep children or pets out of treatment area for "X" minutes.


Do not allow children or pets to contact treated areas.


!

1
452

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/ would like to get your reaction to some language far the following statements found
on the label
Please read each statement  Put a star in front of ithe one that you like the best
Write your reasons for liking or not liking each statement in the place provided.

This pesticide is toxic to wildlife.
This pesticide can kill wildlife.
Please read each statement.  Put a star in front of the one that you like the best
Write your reasons for liking or not liking each statement in the place provided.

This pesticide is toxic to wildlife and domestic animals.
This pesticide may harm pets and wildlife.
 Please read each statement.  Put a star in front of the one that you like the best
 Write your reasons for liking or not liking each statement in the place provided.

 Da not apply where runoff can occur.
 Do not use on sloped areas when heavy rain is expected.
                                                                             453

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                                Appendix 5-1:
Pesticide Labeling Under the Federal Insecticide,
          Fungicide and Rodenticide Act (FIFRA)
                                        455

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  Appendix 5-1: Pesticide Labeling Under the Federal Insecticide, Fungicide, and
                                  Rodenticide Act (FIFRA)

Introduction

The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), first enacted in 1947 and subsequently
amended, requires the registration of pesticides and pesticide producers with the US Environmental
Protection Agency.  Pesticides, as defined by FIFRA, are substances designed to prevent, destroy, repel,
or mitigate any pests, or to regulate, defoliate, or desiccate plants.

Each of the 600-odd pesticide active ingredients in use today must pass a set of health and safety
standards in order to be approved for registration, or in the case of chemicals registered before 1984, a
re-registration. (Tweedy et al., 1991). As part of registration or reregistration, the labeling of each
product is reviewed and approved by the Agency.

Program Summary

Under EPA's Consumer Labeling Initiative (CLI), EPA  and several stakeholders are evaluating the need
for improvements to FIFRA labels for pesticides and household cleaners. See the write-up on CLI in this
section for details.

FIFRA requires labels to appear on the containers of every pesticide product sold in the US, and imposes
standards and restrictions regarding the wording and format (40 CFR § 156.10).  As outlined  in the Code
of Federal Regulations (CFR), a pesticide label must clearly and prominently display the following
information:

    a) The name, brand, or trademark under which the product is sold;
    b) The name and address of the producer, registrant, or person for whom produced;
    c) The net contents (weight or measure);
    d) The product registration number;
    e) The producing establishment number;
    f) An ingredient statement;
    g) Warnings and precautionary statements;
    h) The directions for use; and
    i) The use classification(s) (restricted use).

All required label text must be set in 6-point type or larger, and must appear in English. The Agency,
however, may require additional text in other languages  if it is considered necessary in protecting the
public health.

The Office of Pesticide Programs (OPP) at EPA reviews each pesticide label individually to ensure
appropriateness and accuracy. (Frane, 1993) The particular environmental or health effects of a pesticide
may prompt EPA to require additional warnings or messages to be included on its label (e.g.,
groundwater advisory statements, chronic hazard warnings).

The various components of the label are discussed in more detail below. Label requirements as
                                                                                         457

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  described below are taken from the 40 CFR §156.10. The regulations set only broad guidance on label
  cpntent. In practice, the Agency has wide latitude to require, or accept, statements that deviate from the
  regulations, and many statements that are accepted reflect variations based on product type and use.

      A.     Name, brand, or trademark: The name that appears on the label must be registered with the
             EPA, and not be false or misleading.
   .  ,         ...   „              ...    .   .   .  .      ,   ..... ,.,...,  ., ^  . |

      B.     Name and address of the producer, registrant, or person for whom produced: If the
             registrant's name that appears on the label is not the producer of the pesticide, it must be
             qualified by appropriate wording such as "Packedfor *'**," "Distributed by ***," etc.

      C.     Net contents (weight or measure): The net weight or measure, exclusive of wrapping
             materials, must be stated as an average content unless explicitly stated as  a minimum
             quantity.

             Product registration number: The EPA registration number (often abbreviated to "EPA Reg.
             No.") assigned to the pesticide product at the time of registration must appear on the label.
               Mi  •,	       i . . ., :       '   '          ••••..,:,: ..'   , i.,  \ ...   .  .
             Producing establishment number: The producing establishment number, preceded by the
             phrase "EPA Est.," must appear on the label or on the immediate container.
D.
E.
      F.
       Ingredients statement: The ingredients statement is normally required on the front panel of
       the label.  If there is an outside container or wrapper through which the label cannot be read,
       then the ingredient statement must also appear on that container or wrapper.
  The label of each pesticide product must bear a statement that contains the name and percentage by
  weight of each active ingredient, and the total percentage by weight of all inert ingredients. Each
  ingredient may be referred to by its accepted common name, if there is one. If no common name has
  been established, then the chemical name must be used.  Trademarked names not accepted as common
  illfnes are
   '
  Pesticide products that contain one or more chemical components that change significantly over time
  must also include a statement that reads: "Not for sale after [date]."

      G.     Warning and precautionary statements:
  Required warning and precautionary statements regarding toxicological hazards to humans fall into two
  groups: those required on the front panel and those that may appear elsewhere.  The child hazard warning
  and the appropriate human hazard signal word (see below) must appear on the front panel of a pesticide
  label.  The human hazard signal word also appears elsewhere on the label. Other warnings and
  messages, including the first aid or statements of practical treatment (except in cases of extremely toxic
  products), health and environmental precautionary statements, and physical and chemical hazard
  statements, may appear elsewhere on the label.

  1 . Child hazard warning
                                                                            i
  Except for those products deemed safe for use on children or infants, or where the possibility of contact
  with children is exceedingly small, all pesticide product labels must  bear on the front panel the warning
458

   I
   ill i
                                                                                           , :i  '(•. liwi	

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"Keep Out of Reach of Children"

2. Toxicity Categories

The text required on the front panel of the label is determined by the Toxicity Category of the pesticide
product. A pesticide is assigned a Toxicity Category based on its highest hazard potential in any of the
following indicators listed in Table 1:
Table 1 : Toxicity Category Definition
Hazard Indicators
Oral LD50
Inhalation LC,0
Dermal LD50
Eye Effects
Skin Effects
Toxicity Categories
I
up to and including
50 mg/kg
up to and including
0.05 mg/liter
up to and including
200 mg/kg
Corrosive
(irreversible
destruction of
ocular tissue) or
corneal
involvement or
irritation persisting
for more than 21
days
Corrosive (tissue
destruction into the
derm is and/or
scarring)
II
from 50 thru 500
mg/kg
from 0.05 thru 2
mg/liter
from 200 thru 2000
mg/kg
Corneal
involvement or
irritation clearing in
8-21 days
Severe irritation at
72 hours (severe
erythema or edema)
III
from 500 thru 5000
mg/kg
from .5 thru 2
mg/liter
from 2000 thru
20,000 mg/kg
Corneal
involvement or
irritation clearing in
7 days or less
Moderate irritation
at 72 hours
(moderate
erythema)
IV
greater than 5000
mg/kg
greater than 2
mg/liter
greater than 5,000
mg/kg
Minima] effects
clearing in less than
24 hours
Mild or slight
irritation (no
irritation or slight
erythema)
NOTES: LD50 is the lethal dose at which 50 percent of the animals in lab testing die. LD,0 is measured in mg
pesticide per kg bodyweight. LC50 is the lethal concentration at which 50 percent of the animals in lab testing
die. LC,0 is measured in mg pesticide per liter of air.
SOURCE: Consumer 's Research, July 1 992; 40 CFR § 1 56. 1 0
 3. Human Hazard Signal Words

 Pesticide labels must bear specific signal words, depending on the pesticide's assigned Toxicity
 Category.

 A pesticide that meets the criteria of Toxicity Category I must bear the signal word  "Danger" on the
 front panel of its label.  In addition, if the product was assigned to Toxicity Category I based on its oral.
 inhalation, or dermal toxicity, the label must also bear the word "Poison " in  red on  a background of
 distinctly contrasting color and the skull and crossbones symbol must appear in close proximity to the
 word "Poison."
                                                                                            459

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 A pesticide meeting the criteria of Toxicity.Category II must bear the signal word "Warning" on the
 front panel of its label.

 A pesticide meeting the criteria of Toxicity Category III or IV must bear the signal word "Caution " on
 the front panel of its label.

 4. First Aid (Statements of Practical Treatment)

 For pesticides in Toxicity Category I, a first aid statement (or statement of practical treatment) is
 normally required on the front panel, although in practice reasonable variations are permitted by EPA.
 For other pesticides, first aid statements are not required on the front panel, but must appear elsewhere on
 the label.

 5. Other Required Warnings and Precautionary Statements

 Other appropriate warnings and precautionary statements must appear on the label under the general
 heading of "Precautionary Statements," and under the subheadings of "Hazard to Humans and Domestic
 Animals," "Environmental Hazard,'* and "Physical or Chemical  Hazard."
            •'1	•' "-'SI
  Typical precautionary statements indicating hazard to humans and domestic animals are listed in Tables
  2 through 8 below, and are arranged by Toxicity Category.  Other statements are also used — there is
  considerable variability in hazard statements.

  If a pesticide is found to be potentially hazardous to non-target organisms (excluding humans and
  domestic animals), the text on its label must include precautionary statements describing the nature of the
  hazards and the appropriate precautions to avoid problems.  For example, for a pesticide intended for
  outdoor use, which contains an agent with an acute oral LD50 of 100 or less, the label  must read, "This
  Pesticide is Toxic to Wildlife. " Other statements address toxicity to birds, fish, and aquatic organisms.

  Finally, for chemical or physical hazards, the required precautionary statements are listed below in Table

               '                   '           *"
      H. Directions for use
tf  ,     '•   if  '1           ,       . •                ,,    •  •  ,  • ?:••.
  All pesticide labels must have printed on them detailed use instructions or references to accompanying
  instruction leaflets.
460

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Table 2: Hazard to Humans and Domestic Animal Precautionary Statements
Toxicity
Category
1
II
HI
IV
Precautionary statement by Toxicity Category
Oral, inhalation, or dermal toxicity
Fatal (poisonous) if swallowed [inhaled or
absorbed through skin]. Do not breathe [vapor,
dust or spray mist]. Do not get in eyes, on skin,
or on clothing [Front panel statement of practical
treatment required].
May be fatal if swallowed [inhaled or absorbed
thru the skin]. Do not breathe vapor [dust or
spray mist]. Do not get in eyes, on skin, or on
clothing [Appropriate first aid statements
required.]
Harmful if swallowed [inhaled or absorbed thru
the skin]. Avoid breathing vapor [dust or spray
mist]. Avoid contact with skin [eyes or
clothing]. [Appropriate first aid statements
required.]
[No precautionary statements required.]
Skin and eye local effects
Corrosive, causes eye and skin damage [or skin
irritation]. Do not get in eyes, or skin, or on
clothing. Wear goggles or face shield and
rubber gloves when handling. Harmful or fatal
if swallowed. [Appropriate first aid statement
required.]
Causes eye [and skin] irritation. Do not get in
eyes, on skin, or on clothing. Harmful if
swallowed. [Appropriate first aid statement
required.]
Avoid contact with skin, eyes, or clothing. In
case of contact immediately flush eyes or skin
with plenty of water. Get medical attention if
irritation persists.
[No precautionary statements required.]
SOURCE: 40 CFR § 156. 10.
Table 3: Acute Oral Toxicity Study*
Toxicity
Category
I
II
HI
IV
Signal Word
DANGER
Skull & Crossbones
required
WARNING
CAUTION
CAUTION
Precautionary Statements and Personal Protective Equipment
Fatal if swallowed. Wash thoroughly with soap and water after
handling and before easing, drinking, or using tobacco.
May be fatal if swallowed. Wash thoroughly with soap and
water after handling and before eating, drinking or using
tobacco.
Harmful if swallowed. Wash thoroughly with soap and water
after handling.
No statements are req'uired. However, if the registrant chooses
to use category III labeling that is acceptable.
'Products Containing 4% or more of methanol: Add the following to the precautionary statements:
"Methanol may cause blindness."
                                                                                                  461

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•• . . 	
Table 4: Acute Dermal Toxicity Study
Toxicity
Category
1
II
III
IV

Signal Word
DANGER
Skull & Crossbones
required
WARNING
CAUTION
CAUTION
Precautionary Statements and Personal Protective Equipment
Fatal if absorbed through skin. Do not get in eyes, on skin, or
on clothing. Wear protective clothing and gloves (specify
protective clothing and type of gloves). Wash thoroughly with
soap and water after handling and before eating, drinking, or
using tobacco. Remove contaminated clothing and wash before
reuse.
May be fatal if absorbed through skin. Do not get in eyes, on
skin, or on clothing. Wear protective clothing and gloves
(specify protective clothing and type of gloves). Wash
thoroughly with soap and water after handling and before eating,
drinking or using tobacco. Remove contaminated clothing and
wash clothing before reuse.
Harmful if absorbed through skin. Avoid contact with skin,
eyes or clothing. Wash thoroughly with soap and water after
handling.
No statements are required. However, if the registrant chooses
to use category III labeling that is acceptable.
i
Table 5: Acute Inhalation Toxicity Study
Toxicity
Category
1
II
III
IV
Signal Word
DANGER
Skull & Crossbones
required
WARNING
CAUTION
CAUTION
Precautionary Statements and Personal Protective Equipment
Fatal if inhaled. Do not breathe (dust, vapor, or spray mist).
[Identify specific respiratory protective device approved by the
Mine Safety and Health Administration and the National
Institute for Occupational Safety and Health.]" Remove
contaminated clothing and wash clothing before reuse.
May be fatal if inhaled. Do not breathe (dust, vapor or spray
mist).* Wear a mask or pesticide respirator jointly approved by
the Mine Safety and Health Administration and the National
Institute for Occupational Safety and Health. Remove
contaminated clothing and wash clothing before reuse.
Harmful if inhaled. Avoid breathing (dust, vapor or spray
mist).' Remove contaminated clothing and wash clothing before
reuse.
No statements are required. However, if the registrant chooses
to use category III labeling that is acceptable.
            * Choose the word which appropriately describes the product during use.
            ** Refer to Section to determine the specific respirators' protective device. This section can be used for both WPS and
            Non-WPS products.
462

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Table 6: Primary Eye Irritation Study
Toxicity
Category
I
II
III
IV
Signal Word
DANGER
WARNING
CAUTION
CAUTION
Precautionary Statements and Personal Protective Equipment
Corrosive." Causes irreversible eye damage. Do not get in eyes or on
clothing. Wear protective eyewear (goggles, face shield, or safety glasses)."
Wash thoroughly with soap and water after handling. Remove contaminated
clothing and wash clothing before reuse.
Causes substantial but temporary eye injury. Do not get in eyes or on
clothing. Wear protective eyewear (goggles, face shield, or safety glasses)."
Wash thoroughly with soap and water after handling. Remove contaminated
clothing and wash clothing before reuse.
Causes moderate eye irritation. Avoid contact with eyes or clothing. Wash
thoroughly with soap and water after handling.
No statements are required. However, if the registrant chooses to use
category HI labeling that is acceptable.
"The term "corrosive" is not required if only eye irritation (redness) was observed during the study and was still present
at day 21.

"Use the term "safety glasses" in the precautionary labeling for residential use products.
Table 7: Primary Skin Irritation Study
Toxicity
Category
I
11
III
IV
Signal Word
DANGER
WARNING
CAUTION
CAUTION
Precautionary Statements and Personal Protective Equipment
Corrosive. Causes skin burns. Do not get in eyes or on clothing. Wear
protective clothing and gloves (specify protective clothing and type of
gloves)*. Wash thoroughly with soap and water after handling. Remove
contaminated clothing and wash clothing before reuse.
Causes skin irritation. Do not get on skin or on clothing. Wash thoroughly
with soap and water after handling. Remove contaminated clothing and wash
clothing before reuse.
Avoid contact with skin or clothing. Wash thoroughly with soap and water
after handling.
No statements are required. However, if the registrant chooses to use category
III labeling that is acceptable.
'The need for rubber (homeowner products) or chemical-resistant gloves must be determined on an individual basis.
Some products cause blistering if confined under clothing.
                                                                                                      463

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Table 8: Dermal Sensitization Study
Study Results
Product is a sensitizer or is
positive for sensitization.
Product is not a sensitive or is
negative for sensitization.
Precautionary Statement
Prolonged or frequently repeated skin contact may cause allergic reactions in
some individuals.
No labeling is required for this hazard.
Table 9: Physical or Chemical Hazard Precautionary Statements
Flash Point
Required Text
(A) PRESSURIZED CONTAINERS
Flash point at or below 20 °F, if there is a flashback at
any valve opening.
Flash point above 20 °F and not over 80 °F or if the
flame extension is more than 1 8 in long at a distance of
6 in from the flame.
All other pressurized containers.
Extremely flammable. Contents under pressure. Keep
away from fire, sparks, and heated surfaces. Do not
puncture or incinerate container. Exposure to
temperatures above 130°F may cause bursting.
Flammable. Contents under pressure. Keep away
from heat, sparks, and open flame. Do not puncture or
incinerate container. Exposure to temperatures above
130°F may cause bursting.
Contents under pressure. Do not use or store near heat
or open flame. Do not puncture or incinerate
container. Exposure to temperatures above 130°Fmay
cause bursting.
(B) NON-PRESSURIZED CONTAINERS
At or below 20° F
Above 20 °F and not over 80 °F
Above 80°F and not over 150°F
Extremely flammable. Keep away from fire, sparks,
and heated surfaces.
Flammable. Keep away from heat and open flame.
Combustible. Do not use or store near heat or open
flame.
SOURCE: 40 CFR §156.10
 ;:.            ';:  v;           •                        ,             »,,    ,  ;  I
 The directions must appear under the heading "Directions for use, " and include the following:

    a)      the statement of use classification (see section I, below);
    b)      the statement, "// is a violation of Federal law to use this product in a manner inconsistent
            with its labeling:"
    c)      the sites of application (e.g., crops, lawns, etc.), or objects to be treated;
    d)      the target pests;
    e)      the dosage rate;
     f)      the method of application;
     g)      the proper frequency and timing of application;
     h)      the reentry statement (if needed), which specifies the length of time that must pass before
            people can reenter a treated area;
     i)      the disposal  directions; and
     j)      any use limitations or restrictions required to prevent unreasonable adverse effects.
464

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    I. Use classification

Every registered pesticide has one or more EPA-designated uses. Each of these uses is evaluated for
hazard potential and may be classified for restricted use if necessary to protect human health or the
environment.

1. General Use Pesticides

Unclassified products, with one exception, do not bear the term "General Use" as discussed in 40 CFR
15.160. The one exception involves products containing the active ingredient, chlorine gas. These
products are the only products which bear the classification "General Use."

2. Restricted Use Classification

Products designated for restricted use only must include the words "Restricted Use Pesticide " on the
front panels of their labels. A statement describing the nature of the restrictions and the reason for the
restriction must appear directly below the above statement.  For example, "Due to oncogenicity," "For
retail sale and use only by Certified Applicators or persons under their direct supervision and only for
those uses covered by the Certified Applicator's certification."  For each specific pesticide, other
additional restriction statements may be required by EPA.

Enforcement

According to FIFRA Sec. 2(q) and 12 (Federal Environmental Laws, 1988), failure on the part of the
pesticide producer or registrant to comply with labeling requirements may be considered "misbranding"
of the pesticide.  Sales or distribution of a misbranded pesticide constitutes an unlawful act.  The
Environmental Protection Agency may then cancel the registration, or bring criminal and/or civil charges
against the registrant or producer of the pesticide.

References

Code of Federal Regulations, 40: PARTS 150 to 189. Revised as of July 1, 1992.

Committee on Scientific and Regulatory Issues Underlying Pesticide Use Patterns and Agricultural
Innovation, Board on Agriculture,  and the National Research Council (US), 1987.  Regulating Pesticides
in Food: The Delaney Paradox. National Academy Press, Washington D.C.

Consumers' Research,  1992. How to Read Pesticide Labels, July, pp 34-36.

Federal Environmental Laws,  1988 Edition, 1988. West  Publishing Co., St. Paul, MN.

Frane, Jean, US EPA, OPP, 1993.  Personal Communication with Abt Associates.

Hurst, Peter, Alastair Hay, and Nigel Dudley, 1991.  The Pesticide Handbook, Journeyman Press,
London, Concord, MA.
                                                                                          465

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Tweedy, B.G. et al. eds., 1991. Pesticide Residues and Food Safety: A Harvest of Viewpoints, American
Chemical Society, Washington D.C. pp 324-332.
" " ,„ ' "         „ ' „    "...    " i         ...         , • ^    .        |      i
US EPA, undated. Simazine Re-registration Guidance Document.
 466

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                                                        Appendix 5-2:
First Aid Qualitative Research Participant Screener for 1-on-1 Interviews on
         Household Cleaners, Indoor Insecticides, and Outdoor Pesticides
                                                                 467

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Attachment 1
         Participant Screener for
 1-on-l Interviews on Household Cleaners,
Indoor Insecticides, and Outdoor Pesticides
Recruiting Goals
•      The participants shall be adults over the age of 18.
•      The groups shall include people from several cultural or ethnic backgrounds (e.g.
       Caucasian, African American, Hispanic, Asian, etc.).
•      Each group will be composed of a mix of participants who reside in urban and suburban
       areas.
•      15 participants (5 per product type) will have a high school education or less.
•      2-3 male participants will be included for each product type (maximum 7 males).
•      Up to 2 participants over age 65 may be included for each product category.
•      All participants must be able to read and understand English.
•      People living in retirement homes or assisted living facilities will be excluded.
•      Each group will be composed of a mix of participants who have children and those who
       have no children; of those with children, the participants will be a mix of those who have
       children under age 8 and those who have children age 8 and over.
•      Persons who work in the following occupations shall be excluded: professional lawn
       service providers, cleaning service providers, landscapers, farmers, exterminators, and
       health care professionals..
•      Participants shall not have participated in a focus group or other qualitative research
       study during the past year (with the exception of telephone surveys).

Product Use Criteria
•      All participants must have used or purchased a commercially available household
       cleaner, indoor insecticide, or outdoor pesticide within the past 6 months with 8
       participants selected for each type of product.
•      For this study, indoor insecticides include sprays, baits, foggers, fumigators, bug bombs,
       powders (boric acid), gels, or chalk.
•      Outdoor pesticides include any chemical or biological agent that kills, mitigates, prevents
       or repels any pest (unwanted insects, worms, rodents, weeds, fungi or micro-organism).
       Included in this classification are insecticides, herbicides, and fungicides intended for
       outdoor use (in lawns and gardens).
•      Persons who use only fertilizers in their yard will be excluded.
                                                                                    469

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 Scheduling
 The schedule for the interviews follows:
 July 7, 1997
 Morning
 9:00-9:30 a.m.
 9:40-10:10a.m.
 10:20-10:5^ a.m.
 ll:00-ll:30a.m.
 Il:40a,m.-Ji2:10p.m.
 12:20-12:40 p.m.
Evening
4:30-5:00 p.m.
5:10-5:40 p.m.
5:50-6:20 p.m.
6:30-7:00 p.m.
7:10-7:40 p.m.
7:50-8:30 p.m.
 JulyS, 1997
 Morning
 9:00-9:30 a.m.
 9:40-10:10a.m.
  10:20-10:50 a.m.
'' 11:00-1 IdOalin.
  ll:40a.m.-12:10p.m.
  12:20-12:40 p.m.
Evening
4:30-5:00 p.m.
5:10-5:40 p.m.
5:50-6:20 p.m.
6:30-7:00 p.m.
7:10-7:40p.m.
7:50-8:30 p.m.
  Incentive
  »•     Participants will be paid $25 for their participation.
  Floaters
  A total of 4 floaters will be needed, 1 for the morning and 1 for the evening of each day.
  »•      Floater will be paid $50.
                                                                   |
                                                                   I
  Other Details
  >      Refreshments will be offered to participants.
  »•      The identity of the participants will remain confidential.
                                            14
470

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Hello Sir/Ma'am, my name is
                                	and I'm calling from Olchak Market
Research'"wcare presently working with Macro International, a research and consulting firm,
on a research project about consumer use of common household and garden products. Could I
ask you a few short questions for this survey?
                                 Screening Questions

 1 .     Are you the male or female head of the household?
       •     Male head of household
       •     Female head of household
             Not head of household — request to speak with head of household (if not
             available, terminate)
       Recruit 2-3 mate participants for each product type (maximum total of 7).

 2.    In the past 6 months, have you used or purchased, an indoor insecticide, an outdoor
       pesticide, or a household cleaner?
       •      Indoor Insecticide
       •      Outdoor Pesticide
       •      Household Cleaner
       If 'yes' to any of the above, continue. Note the positive responses for use in question
        14
        If'no'to all of the above, ask to speak with the person who is primarily responsible for
        most of the cleaning, lawn care, or indoor insect control (if not available, terminate)

 3.     In the past year, have you or anyone in your household participated in any market
        research study? [Participation in telephone surveys is allowable.]
        •      Yes — terminate
                  — continue
        I'm going to read a list of age groups to you. Could you please tell me which group you
        are in?
        •      under 18 — terminate
        •      18-25 — continue
        •      26-35 — continue
        •      36-50 — continue
        •      51-65 — continue
         •      over 65 — continue
         Recruit up to 2 participants over age 65 for each product category.

         Do you live in a retirement home or an assisted living facility?
         •     Yes — terminate
         •     No — continue
                                            15
                                                                                   471

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     7.
     8.
    9.
    10.
    11.
    12.
    13.
                                                         If
  What is your ethnic background?
  •      African American
  «      Asian
  •      Caucasian
  ">',.     Hispanic
  •      Native American
  «      Other please specify)
  fS^e'fi Sty of ethnic groups representative of the local population for each of the
  three product groups.

 Are you currently employed?
 •      Yes—continue
 •      No—-proceed to question 10

 Could your employer be described as any of the following?
 *      A professional cleaning service—terminate
 •      A pest exterminator —terminate
 "      A landscape or lawn care company —terminate
 •      A market research or advertising company —terminate

 Do you or anyone in your household work as a farmer, or in the health care field (nurse
 doctor, other health care professional)?                                          '
        No
 •      Yes—terminate

 Would you describe the area where you live as urban or suburban?
 [Include a mix of participants that is representative of the local population.]
       Urban                                                          J
  , ,   •       ""   i                 ,,      ;    .     ',i,|, ,	II 	ii,                 , i •
 •     Suburban
Do you have children that live with you?
•,..:   Yes       '   ,           ;
•      No	proceed to question 12
   t    •;                           .  .     	     ..'  .  '  :
Are your children 8 years old or younger?
       Yes
       No        '              '  '                \	

Which of the following best describes your level of education?
•      Some high school
•      High school graduate
•      Some college
•      College graduate
                                             16
472

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14.    How often have you used [pskfor each product tvue chosen in Np, 2} in the past 6
      months?
15.   We would like to invite you to participate in a one-on-one interview with a researcher
      from Macro about products used around the home and yard. The interview will take
      place on [Monday/Tuesday], July [7/8] at Macro's offices in Maryland just off the
      Beltway. It will last about 30 minutes, and during the interview, you will be asked to
      read and comment on some information. You will be paid $25 in cash for your time.
      Would you like to participate?
      •      No — terminate
             Yes
      #15 should be altered when recruiting floaters to indicate that floaters will be needed
      from 9:00 a.m. to 12:40 p.m. or 4:30 p.m. to 8:30 p.m. on a given day.

I would like to schedule your interview and send you a confirmation letter and directions to the
facility. In order to do so, could you please tell me your mailing address and give me a phone
number where you can be reached:
       NAME: 	
       ADDRESS:
       CITY:
STATE:
ZIP:
       PHONE: (H)
                (W).
       Which day and what times are convenient for you?

       DATE OF INTERVIEW:	   TIME:
        We are inviting only a few people, so it is very important that you notify us as soon as
        possible if for some reason you are unable to attend.  Please call	at
        [phone] if this should happen. We look forward to seeing you on [date] at [time]. If
        you use reading glasses, please bring them with you to the interview.
                                           18
                                                                                 473

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                                                                                                         I
                               Recruit at least 5 participants who are high school graduates or have less than a high
                               school education for each product type (total of IS).
                                                                             17
                   474
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                                                    Appendix 5-3:
                     First Aid Qualitative Research Discussion Guide,
Consumer Comprehension of the Proposed First Aid Statement Language
                                                             475

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                                Discussion Guide
                   Consumer Comprehension of the Proposed
                          First Aid Statement Language
Research Objective: Determine consumer comprehension of the proposed new first aid statement
language.

1. Greet Panelist, Introductions — Find out about family, products used, etc.

Then ask panelist if s/he has ever had the occasion to read the first aid information on the back
of any products s/he uses. If so, ask for an overall opinion of the information provided there.

2. Introduce Topic

Today we are getting people's reactions to the information provided on many products
about what to do in an emergency or if first aid is needed. I'm going to give you a number
of statements to read and I'd like for you to tell me in your own words what you think they
mean you should do.

For each statement, the interviewer will give the statement to the consumer to read to
him/herself. (The interviewer will not read the statement aloud to the consumer). After the
consumer has read the statement, the interviewer will listen to the consumer describe what it
means. The interviewer will probe, if necessary, for clarity, to make sure we understand what
the consumer thinks the statement means.

 Then the interviewer will ask, Is there anything about the statement that's not clear, or that
 you would have questions about what you were supposed to do? Is there any information
 here that you think might not be necessary? Is there any information that's missing — that
 you would need to have in addition to what is here?

 All statements will be seen by all consumers. Order will be randomized to minimize the
 "learning" effect.

 3. After all statements have been discussed, thank consumer and close.
                                         19
                                                                               477

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                                                    Appendix 6-1:
North American Hazardous Materials Management Association (NAHMMA)
                        Storage and Disposal Questionnaire for States
                                                            479

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   Appendix 6-1: North American Hazardous Materials Management Association
              (NAHMMA) Storage and Disposal Questionnaire for States

When answering the following questions please keep in mind that we are only interested in
requirements/practices for consumer uses of pesticides and hard surface cleaner containers and unused
product, not commercial, agricultural, or industrial uses.

I)     Please describe your state's requirements/policies/programs for disposing pesticides and hard
       surface cleaner containers and unused product.

       If available, could'you send me a copy of these requirements/policies/programs?

       Are you  aware of local requirements/policies/programs that are different?

       Does your state generally defer to the localities to develop these requirements/policies/programs?


       How do  they vary?

       Do you know of someone at the local level that I might talk to (where
       requirements/policies/programs are very different from the state's)?

 2)     Please describe your state's requirements/policies/programs for recycling pesticide and hard
        surface cleaner containers.

        What criteria do you use to determine what can be recycled?

        If available, could you send me a copy (requirements/policies/programs and criteria)?

        Are you aware of local requirements/policies/programs that are different?

        Does your state generally defer to the localities to develop these requirements/policies/programs?

        How do they vary?

        Do you  know of someone at the local level that I might talk to(where
        requirements/policies/programs are very different from the state's)?

 3)     Does your state, or localities within your state, have a program for recycling aerosol containers?

        If yes, can you describe it?

 4)     To what extent do consumers participate in, or react to, local hazardous waste pick up
        days/amnesty programs, etc. for containers and unused product in your state (particularly
        pesticides and cleaners if you know)?

  5)     To what extent do consumers participate in, or react to, recycling programs for aerosol containers
        and plastic containers in your state?
                                                                                          481

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              Ihli I!!"!  IJ" '
I
             6]      Can you describe any requirements or common practices related to storage of pesticides and hard

                     surface cleaners in your state?


                     If available, could you send me a copy of the requirements or common practices?
              if1        .     ;:: il   w           '                  '          '        ' ',T' •  1      II      .1
              [  '          -;!;:   -«!  .,•;.!'•,                       •.     t,"    i  ••      II    •• •'
            482

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                Appendix 7-1:
    CLI Kick-off Meeting Notes,
Crystal City, VA, March 20,1997
                       483

-------
'I   iff
'I  .I1!'1

-------
                              CLI Kick-off Meeting Notes
                                    Crystal City, VA
                                    March 20,1997

EPA Staff opened the day. The Phase I Report was distributed in March, so everyone should
already have one.  The report has also been downloaded extensively from EPA's web site.

They mentioned that the CLI project has been well received by management.  CLI is now a line
item of EPA's 1998 budget request to congress, and may be mentioned in the media, probably
under the general category of the Children's Health or the Kalamazoo Initiatives. $500,000 was
requested for this project for FY98.

Phase I - Wrap-Up, Steve Morrill - EPA
The key points coming out of Phase I were reviewed to set the stage for the Phase II work. Steve
Merrill's slides summarized the presentation. Please refer to Attachment E, presentation slides.

Phase II - The Big Picture, Steve Morrill
Steve Morrill presented an overview of several  parts of Phase II: the Interim Label
Improvements, Quantitative Research, Education Task Force, Policy Issues, and the Project
Schedule. Please refer to presentation slides for details.

The question was asked as to whether the goal of "pollution prevention" continued to be part of
this project. EPA staff confirmed that that was still a goal, although very difficult to measure.
An industry representative did not want anything to imply that current products and their use
were contributing to pollution unless there was support for that position.

It is not EPA's intent to generate data regarding potential adverse evidence on the impact of
products.  Rather, pollution prevention is just one of several goals and is included in the spirit of
better consumer relations and re-inventing government.  Nor does EPA expect that any direct and
specific measurements will ever be attempted to show reduction in pollution as a result of the
CLI. The focus of this project is primarily to make sure that consumers have and can use the
information they want and need.

Quantitative Research Proposal (Phase II), Mike Hilton - RISE/Bayer;  Kathy Wurth - SC
Johnson Wax; Carol Berning - Procter & Gamble
Please refer to proposal and presentation slides for content. Overall, the group was supportive of
the research plan. Discussion points included:
 •     We need to be careful that we don't confuse what consumers want vs. what they need.
 •     We need to be clear whether we are identifying label information that is preferred or
       information that leads to recall and understanding.
 •     We need to be clear about whether we are identifying where consumers expect to find
       information vs. where they want to find it.
 •     The group agreed that we should send a mock label (no existing brand) as opposed to a
                                                                                 485

-------
	KB1,!:!1 T":"" Iff!!'  IP1 •!',i'lii
                    branded label for the research.  It was acknowledged that this will be more costly (but not
             v      Educators want to make sure we are measuring the effectiveness of signal words (danger,
                    warning, caution).
             •      It was suggested that we collect information on current habits as a baseline for future
             '       studies.., „,
             *      It was noted that the ideal measurement would be that of behavior change, not
                    satisfaction. However, the group understood the difficulty and long term nature of such
                    measurements.
             ;i;   '    	::iiiil!li  '. "(tl  : '   ...      J '   .       i :          11  :   .     '     , •• I        '       '    '
             *      It was suggested that we collect some data on attitudes, which could also be baseline for
                    future research.
             •      It was noted that companies need to deal with the physical size of labels, and the analyses
                    of research must recognize information limitations due to  label size, even if consumers
                    say fliey want more and more information.
             »      It was noted that information which can't be communicated on the label might be dealt
                    with via education.
             •      FDA mentioned work they had done to measure accuracy  in information transfer by
                    including false information on some labels to determine if consumes were processing
                    infprrnatipn from different parts of the product label.
             *      EPA mentioned that if possible, they would be interested in gathering information on the
                    benefits and drawbacks of using some sort of standardized "eco-facts box." One
                    participant mentioned that some data exist that says consumers focus so much on the
                    nutritional box now that they may underutilize other information on the box.

             Legal and Financial Issues, Mary Dominiak - EPA
             The Paperwork Reduction Act (PRA), the Federal Advisory Committee Act (FACA), and the
             Administrative |pcedures Act (APA) require that EPA do things  differently than the private
             sector. The primary effect will be on EPA's role in the quantitative research program.

             EPA will not require, endorse, or fund the proposed FY97 quantitative research because EPA is
             not sponsoring the research from the PRA perspective. EPA is funding FY97 policy  and
             education activities, will facilitate meetings, provide overall CLI Project management, perform
             data analyses, and prepare the final report. EPA can play no part in the proposed quantitative
             research beyond being a facilitator, consultant, and recipient.
              RISE asked if it might be possible to get a grant from the Environment Stewardship Program.  In
              the past, such grants have been used for consumer education programs.  EPA feels this path
              could put the Agency in a sponsorship position.
              Clorox asked if EPA could act as a funding clearinghouse. The answer was no. The group
              agreed that trade associations seem to be the right group to coordinate all funding of the
              Quantitative research. SC Johnson Wax suggested that one of the environmental or public
              interest groups, or a charitable group associated with environmental issues (i.e., Pew Charitable
              Trust) could also serve this role. This, as well as an invitation to help fund the research, might
              increase trust among CLI participants and might enhance the credibility of non-EPA research
           486

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efforts.  Several ideas were offered about alternative groups which might also supply some
funding for such work.

The meeting participants agreed not to proceed with either questionnaire design or funding
efforts until after a meeting with other interest groups (on April 15) so that their input could be
factored into early consideration. A few companies did commit, through coordination with
RISE, to fund some additional immediate work by NFO to continue to develop the research
proposal.

Partnership Issues, Amy Breedlove - EPA
There will be a meeting on April 15 at Crystal Mall 2, with environmental groups, public interest
groups, and other interested parties, to bring them up to date on the CLI project and introduce the
quantitative research plan. NFO and Kathy Wurth plan to present the preliminary quantitative
research outline on that date. All CLI participants are invited as well. Meeting participants
noted the importance of, and their strong desire for, the ongoing participation of environmental
and public interest groups in the CLI. Please refer to Attachment G and H for the letter of
invitation and a complete list of invitees to the April 15 meeting.

CLI Interim Label Improvements, Steve Morrill - EPA
Please refer to the presentation slides for details about EPA's interim label improvements.

Policy Initiatives
Please refer to presentation slides for details on Ingredients and Health and Safety Information,
and Storage and Disposal Label Issues.

Standardization of Messages Across Product Categories, Julie Lynch - EPA
Some people at EPA are interested in exploring the possibility of an "eco-facts box" on labeling
(like nutrition  box). To the extent possible, this idea will be explored in the quantitative
research. Those involved in ISO 14000's Type III labeling standards are debating a set of
environmental messages which would be standardized acroiss products.  EPA would like to draw
on CLI  findings to help the Agency contribute to the ISO effort. RISE asked whether the scope
of this effort would include Health and Safety as well as environmental issues.  This is not clear
yet.

EPA is learning from FDA's experience with the food nutrition label and recent research on
consumer needs regarding electricity deregulation. In other research, FDA has found that
consumers seem to prefer charts and graphs rather than over simplistic or numerical data. EPA
would not repeat previous work done previously in "Determinants of Effectiveness for
 environmental Certification and Labeling Programs." It was noted that in some of these other
 circumstances, attributes are more consistent across products, in contrast to CLI product
 categories, where many different attributes are relevant. EPA noted that the objective for the
 standardization of messages investigation is to lay out for the Agency what the complexities of
 this issue are.

 CLI Education Initiatives, Sally Patrick - Minnesota Pollution Control Agency
                                                                                  487

-------
  Please refer to presentation slides for details about Minnesota's Consumer Label Education
  Program. A discussion regarding the concept of a "read the label" educational program followed.
  Several manufacturers noted that an educational program should focus on "read the label
  message" rather than focusing on infrequent but real risks of products regulated under FIFRA. A
  "common sense" approach to terminology (e.g. household hazardous waste) was urged as
  Opposed to a strictly statutory interpretation.  One manufacturer suggested that surveying existing
  solid waste management programs to find out where there might be gaps in educational efforts
  might be a good place to start.
488

-------
                                              Appendix 7-2:
Summary of Partner and Task Force Meeting, February 17,18,1998
                                                     489

-------
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-------
           Consumer Labeling Initiative
Summary of Partner and Task Force Meeting
              February 17-18,1998
                 Alexandria, VA
                 March 5, 1998
                                                491

-------
                                      Action Items
Research Items
I.     Sally Patrick of Minnesota will forward the MN booklet on English as a Second Language
f!  '  'toEPA. ""      '        	'              ; \;	      '  I       '   '  \     "  ;'
i.     Partners and Task Force members will consult FDA research on nutrition boxes and other
       labeling research FDA has been involved in.
3,     The Research Core Group will consider biasing issues in ordering the questions in the
f:;    .survey.  ""              '        "     '"               "       "  "     	••
4.     The Research Core Group will add an open-ended question at the end of the survey to
       capture top of mind responses on topics covered in the survey.
5.     Brian Roe of FDA, Bob Hamilton of Amway, Sally Patrick of Minnesota, Bob Ochsman
       of CPSC, and Jim Hanna of King County, WA requested the survey questionnaire.
6.     EPA will provide clarification on and a list of the environmental information to be
       addressed by the research and further considered for standardization for each product
;:;!;  „   tyP6-	,  „	  ,   ,   	        ,  ,.         	     ,  , ..
7.     The Research Core Group will incorporate questions in the survey to identify what
       consumers want to know about ingredients and where they go for this information.
                                                                    j        •     .
Standardization Items
8.     The Research Core Group will quantify if consumers perceive the signal words as
       intended, in what hierarchy, and what primary hazard is posed.
9.     EPA will draft a scoping and limitations description of the quantitative research (review
       draft attached).
10.    The Research Core Group will address:
       a) preiesting the concept of standardized formats (or box) in the quantitative research, and
       b) further qualitative research on format and content options.
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11 •    SallyPatrick will determine if Minnesota can support the standardization research by
       conducting focus groups.

Consumer Education Items
12.    Partners and Task Force members directed the Consumer Education work group to focus
       the message to encourage the consumer to "Read the Label" and inform his/her self.

Storage and Disposal Items
13.    The Storage and Disposal work group will invite the input and/or participation of waste
       haulers and processors.

Project Management and Timeline Items
14.    E'PA will investigate its ability to conduct qualitative work on the presentation of
       standardized information that builds on the findings of the quantitative results.
15.    Partners and Task Force members will meet again in late June or early July when the
       survey results and other project inputs are available.
 492

-------
Partners and Task Force Members Attending the February Meeting
NAME

Rachel Coleman
Andrew Stoeckle
Robert Hamilton
Mike Hilton
Julie Spagnoli
Brigid Klein
Greg Koontz
Janice Podoll Frankle
George Meindl
Brian Roe
Janet Kreizman
Bob Skoglund
JimHanna
Sally Patrick
Laurel Ashbrook
Gary Schifilliti
Matfaew Grayer
Steve Rosenberg
Jan Wengler
Allen James
Alberta Helmke
Stuart McArthur
John Owens
Dennis Ward
Jim Hasler
William McCormick
Lizi Parker
Steve Smith
Maureen Howard
Robert Ochsman
Amy Breedlove
Mary Dominiak
Jim Downing
Jean Frane
Sue Nogas
Cameo Smoot
Susan Wayland
Julie Winters
Kathie Tryson
John Miller
ORGANIZATION

Abt Associates Inc.
Abt Associates Inc.
Amway Corporation/Home Care Products
Bayer Corp.
Bayer Corp.
Chem. Specialties Mftrs Assn. (CSMA)
Chemical Prod. & Distributors Assn (CPDA)
Federal Trade Commission
FMC Corp.
Food and Drug Administration
Household/Industrial Product Info Council
International Poison Center
King County WA Dept. of Natural Resources
Minnesota Pollution Control Agency
NFO Research, Inc.
Olin Corp.
Reckitt & Colman
Reckitt & Colman
Reckitt & Colman
RISE
S.C. Johnson Wax, Inc.
S.C. Johnson Wax, Inc.
S.C. Johnson Wax, Inc.
Solaris Group
The Clorox Company
The Clorox Company
The Clorox Company
The Clorox Company
The Proctor & Gamble Company
U.S. Consumer Products Safety Commission
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
United Industries
Vermont Agency of Natural Resources
                                                                                493

-------
                                       Topics Covered

   Introductions
   Quantitative Research
   Standardization of Environmental Information on Product Labels
   Ingredients
   First Aid
   Other Issues for Consideration
   Remarks from Susan Wayland and general discussion
   Consumer Education
   Stakeholder Involvement
   Storage and Disposal
   0verall Project Management/Timelines
   Introductions
   See attendee list (page 2).

   Quantitative Research
   Mike Hilton, Lizi Parker, and Julie Spagnoli updated Partners and Task Force members on the
   working group's progress and plans for implementing the survey. The group affirmed that the
   survey will address the learning objectives (page 7) defined in Phase I and should result in
   actionable items as outlined in the presentations. A statement explaining the scope of the survey,
   both what it will and will not do will be drafted (review draft attached, page 8).  A schedule for
   completing the quantitative research was approved (last slide on page 17).

   Discussion yielded the following decisions:
          Peer revigw of project methodology will occur once a CLI Phase II draft report is
          available and be included as a chapter in the final report.
          Stakeholders who have expressed interest or commented before will be invited to
          contribute,opinions and input during the data analysis and recommendation phase

   In addition, the working group will:
   4      Revisit question of bias through placement/location of questions
   4      Add open-ended question to capture miscellaneous comments at the end of survey
   •      Address current understanding of signal words
   •      Confer with Jim Downing on lists of environmental effects and ingredients.
494

-------
Standardization of Environmental Information on Product Labels
Julie Spagnoli and Andrew Stoeckle of Abt Associates discussed some of the issues related to
developing a standardized format for the presentation of environmental information. The effort
will focus on information which is already available on labels.  In the future, CLI may investigate
the feasibility of including additional information. .The survey currently includes questions which
will provide data on what information consumers value most, but it: does not test consumers'
preference for format. The group agreed that consumer education would be an important
component of any standardization strategy.

A small group will work further on the following issues:
4     determining whether and how the quantitative survey can be used to learn if consumers
       want a standardized format for environmental information and pretest the concept of a
       standard format (or box).
4     methods, resources and schedule for determining the best format for presenting
      ,. standardized information, including a new qualitative step, based on the findings of the
       quantitative results.

Partners and Task Force members also requested additional direction and clarification from EPA
management.

Ingredients
Cameo Smoot of OPP described efforts by the pesticide program to
       a) provide the public with enhanced availability of information on ingredients, and
       b) further address ingredient categorization.
OPP has not assessed consumers' needs and anticipates CLI's findings to learn what consumers
want and need, and how to express it.

4      It was decided to add a question on what consumers want to  know about ingredients and
        where they go for this information.

First Aid
Amy Breedlove of OPP described the status of CLI work on First Aid. The qualitative results
obtained in Phase I have been extensively reviewed.  Macro International's work will be included
in the Phase II report. The quantitative survey will also contain some questions on First Aid.  A
PR notice will be published in the late spring or summer on the revised First Aid statements.

Other Issues for Consideration
Julie Winters noted that the following issues are not covered in full detail under CLI: multi-lingual
and literacy, icons, signal words, label format (i.e., font and color) and environmental claims.
Partners and Task Force members directed the Quantitative Research group to discuss testing
consumer understanding of the signal words, "CAUTION", "WARNING" and "DANGER" and
the hazard statements associated with them.  Partners and Task Force members also noted that
labels  present only negative information about hazards. Although current regulations generally
prohibit the use of positive statements, the Quantitative Ressearch group will consider using the
survey to test the use of a list of limited exceptions developed by Jim Downing of OPP.
                                                                                   495

-------
                                                             i1!!!:1::!,! "i If!!1'. 1:;,H
  Remarks and Discussion with Susan Wavland. Deputy Assistant Administrator for the Office of
  Prevention. Pesticides and Toxic Substances

  Susan Wayland thanked attendees for their tune, effort and commitment, commended the project
  for going directly to consumers, and asked for input.  Label changes as of this spring attest to the
  ipipact of CLI.  EPA is very interested in information the survey will provide on Storage and
  Disposal issues, Ingredients, First Aid, Standardization, and Consumer Education. Lynn Goldman
  •and Susan Wayland particularly encourage the group to find out what information consumers
  want standardized and how they want that information presented.

  Discussion points included:
  4      EPA is committed to seeking the middle ground in balancing consumers' interest in
         additional information about ingredients with industry's concern for confidentiality. If
        <• con'slinejl don't find complete chemical names useful, all parties might be served by the
         disclosure of ingredient categories.
  4      EPA encourages CLI researchers to obtain data on what environmental information
         consumers want to know as well as how they would like information displayed within the
         original timeframe of Phase II.
  4      Both Sally Patrick (MM) and EPA staff will investigate the feasibility of using focus
         groups to provide qualitative learnings on standardization formats to complement the
         quantitative survey data on information most valued by consumers.
   j.1,;' i  '       I* T  , ,,,'iiii    '                    '  '       .  • 	   '"",
  Consumer Education
  Mary Dominiak, Sally Patrick and Julie  Spagnoli presented the Consumer Education group's
  work plan. The initial campaign will focus on presenting positive reasons to "Read the Label" and
  encouraging the consumer to view labels as a valuable source of information. The message will
  be further refined and targeted toward specific populations as the survey results become available.
  Partners and Task Force members will identify ways their organizations can help.  CLI will also
  seek alliances with organizations such as local Poison Control Centers which  have related
  missions. Partners and Task Force members advised the working group that the goal is to
  encourage consumers to inform themselves rather than conditioning them to choose the least
  hazardous product.

  Additional issues which the Consumer Education group will address include:
   4     the need to measure results  of the educational strategy

   Stakeholder Involvement
  Julie Winters discussed outreach efforts to data. EPA plans to continue efforts to  receive input on
   CLI issues from all stakeholders. All views will be considered, addressed, and documented and
   included in the final report.
496

-------
Storage and Disposal
Amy Breedlove summarized CLI work on Storage and Disposal.  The working group will
continue to assess the extent to which information on labels conflicts with local/state laws.
Partners and Task Force members recommended that the group solicit the input of waste haulers
and processors on this issue. The Abt report will be done by late March or early April.

Overall Project Management and Timelines
Partners and Task Force members approved the project timeline.  A first draft of the survey report
will be available on June 19th, which will allow time for qualitative study on standardization
format for inclusion in the Phase H report.  In addition, by May 30, each of the other sub-project
areas (Storage and Disposal, Consumer Education, Standardization of Environmental
Information, and Ingredients) will have completed their consideration and prepared findings for
input to the Partners, Task Force members and other stakeholders. CLI Partners and Task Force
members will reconvene in late June or early July to consider all learnings and inputs to form
Phase ,11 recommendations.

                                  List of Attachments

4     Learning Objectives Addressed in Questionnaire Design
4     Scoping and Limitations review draft
4     Presentation Slides and Materials
                                                                                  497

-------
                  Learning Objectives Adressed in Questionnaire Design

Survey Questions
Objective
#1
Satisfaction
with Labels
Objective
#2
Hierarchy
of
Information
Objective
#3
Expected
Location of
Information
Objective
#4
Compre-
hension
Objective
#5
FIFRAvs.
Non-
FTFRA
Objective
#6
Standard-
ized
Information
Phone Instrument
Ease of finding sections
-accurate identification
- consumer opinion
Language comprehension
- consumer opinion
- key words/phrases
X

X

X


X





Written Instrument
Overall Satisfaction with
current labels
Where/how often read
sections of the label
Most/least important
information
Expected location of
information
Other sources of
information.
Likes/dislikes about label
sections
Meaning of recycling
symbols
FBFRA/non-FIFRA
preference
Paired preference
statements
Attitude statements
Habits and Practices
X




X






X
X
X


X





X

X












X
X









X

X
X



X
X
X







498

-------
                   Scope and Limitations of Consumer Labeling Initiative's
                                    Survey Instruments

Phase I research, completed in 1996, used primarily qualitative research (one-on-one interviews)
to investigate consumer understanding and to identify problems related to FIFRA-related product
labels.  An Interim Report documents these efforts and the Phase I findings.  The Phase II
investigation (both the issues addressed and research design) builds upon the learning of Phase I.
Phase II will, for example, clarify consumer understanding of particular label elements as well as
quantify the prevalence of problems, attitudes and beliefs that were identified in the one-on-one
interviews.

Guidance for the survey design was provided by the six learning objectives established by the CLI
Task Force and Partners at the start of Phase II.

1.   Determine the current situation relative to consumers' satisfaction with the format and
     content of existing labels.
2.   Determine consumers' hierarchy of importance of basic label information.
3.   Determine where on the label consumers expect to  find particular information, such as first
     aid or ingredients.
4.   Determine consumers' current comprehension of label language.
5.   Determine whether or not a preference exists for non-FIFRA over FIFRA labels (possible for
     Household Cleaners category only).
6.   Determine consumers' reaction to standardized safe use, environmental, health and safety -
     information.

The learning objectives were intended to focus research on a few very specific issues related to
improving labels.  Each is intended to generate research findings which will enable EPA and/or
CLI participants to take immediate and near-term steps towards  label improvements. Some
changes, such as revised guidance and regulations, would be almost entirely under the purview of
EPA.  Others, such as consumer education, would involve many stakeholders and require a longer
time frame.
  Objective 1:  Determine the current situation relative to consumers' satisfaction with the format
  and content of existing labels.
  Action Steps
Limitations
  > If current labels are not meeting consumers'
  needs, provide general input on which
  sections need further revisions.
Results from this objective (consumer
preferences) are directional only. Tactical
actions will come from other objectives.
                                                                                   499

-------
       Objective 2: Determine consumers' hierarchy of importance of basic label information.
       Objective 3: Determine where on the label consumers expect to find particular information,
       such as first aid or ingredients.                           	
       Action Steps
                               Limitations
       > Make format recommendations, such as
       organizing information when needed in the
       store, before use, or in case of emergency.
                               These objectives, in combination with
                               Objective #6, will let researchers identify what
                               consumers want to know and make format
                               (location) recommendations. We will not be
                               designing a conclusive format.  Final format
                               recommendations to OPP will be made after a
                               qualitative study is completed immediately
                               following the quantitative study.	
Objective 4: Determine consumers' current comprehension .of label language.
Action Steps
> Identify terminology that consumers find
difficult to understand.
> Recommend additional qualitative work
with consumers to understand what
terminology should be used, as appropriate.
> Recommend word changes (limited).
Limitations
Every possible wording change cannot be
evaluated. Additional study may be needed to
test alternative text for several sections of the
label.
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Objective 5: Determine whether or not a preference exists for non-FIFRA over FEFRA labels.
•Action Steps
> Quantify whether non-FIFRA label sections
are preferred to FIFRA.
> .Make word changes where possible.
> Make format recommendations, such as
organizing information when needed in the
store, before use, or in case of emergency.
Limitations
Will not be comparing alternative labels side
by side. Will be done for household cleaner
category.
    500

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Objective 6: Determine consumers' reaction to standardized
and safety information.
Action Steps
> Provide direction on types of information
that could be standardized.
•> Make preliminary format (location)
recommendations.
safe use, environmental, health
Limitations
See#2/#3
In addition, there are a number of survey design considerations and assumptions that are
important for reviewers of the survey instruments. The survey design calls for separate surveys
for each of the three CLI product categories: household hard surface cleaners, indoor insecticides
and outdoor pesticides.  Thus, the survey instruments differ slightly for each product category.
Eligible heads of household, identified by a short screening questionnaire, will be sent a package
with an instruction letter, a mock label, and a sealed written questionnaire. The telephone survey
will be conducted by National Family Opinion to test consumer comprehension of label elements
and ease of locating key label sections. Respondents will then complete and return the written
survey (to probe overall satisfaction with current labels, preferences about label sections, attitudes
and behaviors) at their leisure.

The survey, as currently designed, focuses on gathering information related to consumer
interactions and perceptions of current labels. It will also provide direction for the next phase of
work which includes: 1) designing and testing alternative text and formats which are expected to
improve the label's performance in the marketplace and 2)  other CLI work, such as the public
education campaign.

Ingredients

Currently evaluating what can be incorporated in the study to address issues related to full
disclosure.  In general, we will seek to determine what ingredient information consumers desire to
see on the label.
                                             10
                                                                                      501

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