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)
-------
-------
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
-------
-------
TABLE OF CONTENTS
TABLE OF CONTENTS I
LIST OF APPENDICES vii
LIST OF TABLES
**"**"***'"ปซ. I.A.
LIST OF CHARTS
ซปซ.. ....,...,>>ti> J\,L
LIST OF ACRONYMS :::
""***""*"ซ,ป.ซ... 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
-------
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
-------
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
iii
-------
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
-------
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
-------
-------
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
vii
-------
10-1: List of Commentors on the CLI Phase II Report Draft 555
viii
List of Appendices
-------
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
-------
-------
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
xi
-------
-------
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
XIII
-------
-------
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
ป 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;
Forward
xv
-------
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.
xvi Forward
-------
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
Forward
XVII
-------
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.)
xviii
Forward
-------
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.
Forward
xix
-------
-------
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
-------
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;
Executive Summary
-------
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.
Executive Summary
-------
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;
Executive Summary
-------
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.
Executive Summary
-------
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.
Executive Summary
-------
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).
Executive Summary
-------
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."
Executive Summary
-------
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.
Executive Summary
-------
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.
10
Executive Summary
-------
3. Recommend to keep the status quo for storage statements on product labels.
Executive Summary
11
-------
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;
ป 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.
12
Executive Summary
-------
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
Executive Summary
13
-------
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
14
Executive Summary
-------
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.
Executive Summary
15
-------
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.
16 Executive Summary
-------
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
-------
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.
18 Chapter 1: Overview of Phase II of the CLI
-------
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
19
-------
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;
ป 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.
20
Chapter 1: Overview of Phase II of the CLI
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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;
ซ measure consumer comprehension of labels; and
ซ 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
-------
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
-------
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
-------
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
-------
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;
ซ 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:
ซ increase reading and use of labels;
ซ 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
-------
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
-------
-------
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
-------
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.
34
Chapter 2: Quantitative Research
-------
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
-------
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
-------
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.
Chapter 2: Quantitative Research
37
-------
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
-------
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.
Chapter 2: Quantitative Research
39
-------
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
Chapter 2: Quantitative Research
-------
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.
Chapter 2: Quantitative Research
41
-------
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
Chapter 2: Quantitative Research
-------
Mail Questionnaire Outline
The mail questionnaires (see Appendix 2-4) were designed to address the following specific
questions:
ซ 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
ซ 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.
Chapter 2: Quantitative Research
43
-------
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
-------
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")).
Chapter 2: Quantitative Research
45
-------
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
Chapter 2: Quantitative Research
-------
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.
Chapter 2: Quantitative Research
47
-------
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
-------
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
49
-------
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:
ป 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
Chapter 2: Quantitative Research
-------
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
Chapter 2: Quantitative Research
51
-------
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
52
Chapter 2: Quantitative Research
-------
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.
Chapter 2: Quantitative Research
53
-------
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
-------
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
-------
Chart 2-4
ABILITY TO IDENTIFY
PRODUCT CONTENTS OR INGREDIENTS
100%
80%
20%
0%
Indoor Insecticide Household Cleaner Outdoor Pesticide
ฃ] 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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
tyii^iM^ntftliiqin^irt
l{ui{uM{uuffutffuMfAii
ynti|nri{ai:
-fn ' *J
''"<. v v
Ha
I
ri^gnrfn^i
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
-------
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
-------
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
-------
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
VV"VS!
njtfnw&wss&i
t_^_=*_J
- * * ^~
^*friซrf|rirtfrMปrffrปซ^ปซ^ซ
*ซt^
W -jT "W 3T
Disposal
0% 10% 20%
||| Storage
30% 40% 50%
ฃj 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
-------
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*^natynฃiki(nnMn
^
j^fef"
nqpajf
H***\***i
m>
.uAu6i
a
i
n^Ai^Ai(Ai(Ai(Ai(Ai
i**"y<
AiiAi
M * 1
itfmtfai
iintfan
dfiitfl
f^-^~
-X i
uutfurf
Jk 1
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
-------
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
^
ป til
tflinf '
p^M^if'H^.rfi^iii^.fi.^.ni^Mfti^ni^.niiiniir-
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
-------
Chart 2-13
WHAT DO YOU THINK THIS ICON/PICTURE MEANS?
(Plastic Material Code)*
No Answer
Package Made of Recycled Steel - ง
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^
ง
ปs
^
SC^fiF1
{uonuiDu
iwm
^^MB^HBB^MB^BBBJ
unvtfnq
ranrnnr
iHMฃ*M
^fiuajfu
mmm^mmm
P ^
^mmm^fm
IB
^ฃ !ฃ! ^ ^
-I '
mfmmmUmmmfmmmm
\ 1 '
^C**r*"
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
-------
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
-------
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
-------
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
-------
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
-------
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 '
- i
^v^..
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
-------
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."
Chapter 2: Quantitative Research
75
-------
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)
76
Chapter 2: Quantitative Research
-------
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)
Chapter 2: Quantitative Research
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?
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.
78
Chapter 2: Quantitative Research
-------
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.)
Chapter 2: Quantitative Research
79
-------
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]
80
Chapter 2: Quantitative Research
-------
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
Chapter 2: Quantitative Research
81
-------
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.
82
Chapter 2: Quantitative Research
-------
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.
Chapter 2: Quantitative Research
83
-------
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.
84
Chapter 2: Quantitative Research
-------
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:
Chapter 3: Qualitative Research
85
-------
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.
86
Chapter 3: Qualitative Research
-------
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
Chapter 3: Qualitative Research
87
-------
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;
88
Chapter 3: Qualitative Research
-------
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.
Chapter 3: Qualitative Research
89
-------
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
90
Chapter 3: Qualitative Research
-------
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.)
Chapter 3: Qualitative Research
91
-------
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;
ซ 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
92
Chapter 3: Qualitative Research
-------
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.
Chapter 3: Qualitative Research
93
-------
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
94
Chapter 3: Qualitative Research
-------
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)
Chapter 3: Qualitative Research
95
-------
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)
96
Chapter 3: Qualitative Research
-------
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)
Chapter 3: Qualitative Research
97
-------
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.
98
Chapter 3: Qualitative Research
-------
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.
Chapter 3: Qualitative Research
99
-------
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
100
Chapter 3: Qualitative Research
-------
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)
Chapter 3: Qualitative Research
101
-------
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.
102
Chapter 3: Qualitative Research
-------
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
Chapter 3: Qualitative Research
103
-------
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
104
Chapter 3: Qualitative Research
-------
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
Chapter3: Qualitative Research
105
-------
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.
108
Chapter 3: Qualitative Research
-------
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.
Chapter 4: Quantitative and Qualitative Research Conclusions
107
-------
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.
108
Chapter 4: Quantitative and Qualitative Research Conclusions
-------
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.
Chapter 5: First Aid Qualitative Research
109
-------
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."
110
Chapter 5: First Aid Qualitative Research
-------
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.
Chapter 5: First Aid Qualitative Research
111
-------
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).
112
Chapter 5: First Aid Qualitative Research
-------
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.
Chapter 5: First Aid Qualitative Research
113
-------
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
114
Chapter 5: First Aid Qualitative Research
-------
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:
ป Take off contaminated clothing.
> Rinse skin immediately with plenty of water for 15-20 minutes.
ป -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.)
Chapter 5: First Aid Qualitative; Research 115
-------
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)
116
Chapter 5: First Aid Qualitative Research
-------
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.
Chapter 5: First Aid Qualitative Research
117
-------
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
-------
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.
Chapter 5: First Aid Qualitative Research
119
-------
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
-------
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
-------
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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);
ป 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);
ซ 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
-------
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
-------
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
132 Chapter 6: Phase II Sub-Groups Sub-Section 2 - Storage and Disposal Subgroup
-------
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
Chapter 6: Phase II Sub-Groups Sub-Section 2 - Storage and Disposal Subgroup 133
-------
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
134 Chapter 6: Phase II Sub-Groups Sub-Section 2 - Storage and Disposal Subgroup
-------
(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).
Chapter 6: Phase II Sub-Groups Sub-Section 2 - Storage and Disposal Subgroup 135
-------
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
136 Chapter 6: Phase II Sub-Groups Sub-Section 2 - Storage and Disposal Subgroup
-------
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
Chapter 6: Phase II Sub-Groups Sub-Section 2 - Storage and Disposal Subgroup 137
-------
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;
138 Chapter 6: Phase II Sub-Groups Sub-Section 2 - Storage and Disposal Subgroup
-------
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.
Chapter 6: Phase II Sub-Groups Sub-Section 2 - Storage and Disposal Subgroup 139
-------
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
i i
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
140 Chapter 6: Phase II Sub-Groups Sub-Section 2 - Storage and Disposal Subgroup
-------
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
Chapter 6: Phase II Sub-Groups Sub-Section 2 - Storage and Disposal Subgroup 141
-------
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.
142 Chapter 6: Phase II Sub-Groups Sub-Section 2 - Storage and Dilsposal Subgroup
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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 safetyunless 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 additionand more importantly from the point of
consumer educationthey 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;
ซ 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
-------
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
-------
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
-------
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
-------
-------
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
-------
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
-------
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
-------
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.
158 Chapter 7: Partner and Task Force Meetings
-------
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.
Chapter 7: Partner and Task Force Meetings
159
-------
-------
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
-------
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
-------
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
163
-------
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
-------
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.
Chapter 8: Stakeholder Interactions and Comments
165
-------
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
166
Chapter 8: Stakeholder Interactions and Comment:;
-------
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
Chapter 8: Stakeholder Interactions and Comments
167
-------
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.
168
Chapter 8: Stakeholder Interactions and Comments
-------
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.
Chapter 9: CLI Phase II Recommendations
169
-------
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.
170
Chapter 9: CLI Phase II Recommendations
-------
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.
Chapter 9: CLI Phase II Recommendations
171
-------
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
172
Chapter 9: CLI Phase II Recommendations
-------
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.
Chapter 9: CLI Phase II Recommendations
173
-------
3. Recommend to keep the status quo for storage statements on product labels.
174
Chapter 9: CLI Phase II Recommendations
-------
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.
Chapter 9: CLI Phase II Recommendations
175
-------
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
-------
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
Chapter 9: CLI Phase II Recommendations
177
-------
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.
178
Chapter 9: CLI Phase II Recommendations
-------
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).
Chapter 10: Public Review of the CLI Phase II Report Draft
179
-------
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.
180
Chapter 10: Public Review of the CLI Phase II Report Draft
-------
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
Chapter 10: Public Review of the CLI Phase II Report Draft
181
-------
addition, it was suggested that the order of precautionary statements should reflect the importance
of the statements.
182
Chapter 10: Public Review of the CLI Phase II Report Draft
-------
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.
Chapter 11: Peer Review Comments on the Phase II Report Draft
183
-------
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
184
Chapter 11: Peer Review Comments on the Phase II Report: Draft
-------
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
Chapter 11: Peer Review Comments on the Phase II Report Draft
185
-------
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.
186
Chapter 11: Peer Review Comments on the Phase II Report Draft
-------
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.
Chapter 11: Peer Review Comments on the Phase II Report Draft
187
-------
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?
188
Chapter 11: Peer Review Comments on the Phase II Report Draft
-------
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?
Chapter 11: Peer Review Comments on the Phase II Report Draft
189
-------
-------
Consumer Labeling Initiative
Phase II Report
APPENDICES
-------
-------
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
-------
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
-------
-------
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
-------
-------
Appendix 1-2:
List of CLI Task Force Members
199
-------
-------
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
-------
-------
Appendix 1-3:
List of CLI Partners
203
-------
-------
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
-------
I 1'
-------
Appendix 1-4:
List of CLI Stakeholders
207
-------
-------
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
-------
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
-------
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
-------
-------
Appendix 1-5:
Members of the CLI Quantitative Research Subgroup
Core Group
213
-------
-------
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
-------
-------
Appendix 1-6:
Members of Qualitative Subgroup
217
-------
-------
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
-------
-------
Appendix 1-7:
Members of Standardized Environmental Information Subgroup
221
-------
-------
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
-------
-------
Appendix 1-8:
Members of Storage and Disposal Subgroup
225
-------
-------
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
-------
-------
Appendix 1-9:
Members of Consumer Education Subgroup
229
-------
-------
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
-------
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
-------
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
-------
-------
Appendix 2-1:
Quantitative Research Screening Questionnaire
235
-------
-------
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 -ป (Continue) 2 Q No -ป (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 -ป (Continue) t D No -ป (Skip To Qu. 3a)
2b. Indicate age and sex of primary user.
Age: _ yrs. Sex: tฃ] 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 -ป (Continue) j D No -ป (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
-------
-------
Appendix 2-2:
Quantitative Research Telephone Questionnaires
239
-------
-------
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
-------
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) ปvwปc,
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 adequatง"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 QUESTIฐN 11b ASK QUESTION 15b. OTHERWISE, SKIP TO NOTE
" VA^ufRESPO^SES)5601100' ^ dฐ6S "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
QUEฐ TO1NlS) MENTIฐNED IN QUESTION 14b ASK QUESTION 15ซs. OTHERWISE, SKIP TO
mir^Bo wp.si?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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
-------
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
-------
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
ฉ19XXWham
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
-------
-v^^nsthytbM^immotiwcttaidiaW
I "OTHER IN6RBHENT$,.
,
NETWT22FLOZ( 1PT60Z)650ml ;-;TOTALINSREDIEHTS
.WOW
273
-------
274
WHAM M tapes* dnwr dew, teodorins wd tetttOs houjihok) ssrhcei Cits
w*bl^btin^.TOOPฃllATET.raK^^.toSWwS^rm^8ENEI^ClฃAHWa Holing
mob 6 to t ache fan office, tpny MM m, tlun mripe ctปin. Note A oat it nqwid fcr
nrficts in tntt eonact wto hod Do *ot m on rartd wfteซ. BSBlffCllOK: Sjny did
icccrinj to 6ซnl during Dinctioni MEOEW: Pneliin trim, Hwi jpny dnU torooghtif
wstUlปr*Y.BipซtYmHY or wtuninw growth ip()ซปfi
CAUSES BE HfflnATON. Do Mt fit in lyis, n ildn or cMring. Aปok) eontietiwllifiKidj.
Mtfon prate. SIMM! AMD OBPOSW: San in ซK ttKtutUa to ml eMdna Do not
nwป mpty contiMrs. Riwt tewsNy ซd fccrt n to*.
Hut boali is ndi of S% pofl-cawiimr ncytM HOPE plistic.
OUESMNS7 COMMUTST CiU 1-ซH&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 ______ 99ฃ0%
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 ซซed and spw to weL Spray *y Ime weeds ซ a*rty
otwwB. Do irt apply wtw mi or ferapntus ow Hf n eqปcW wSwi
24 hours. Kri to eonW weeds nay require repeal apptabon in 2 to 3 weeks.
Weeds n neซV 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
TODBCOHNฃCTTO66EH: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 wซr. 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-MOซ5ซ55
^m. PndDCtWonnabnani-IOO-5554556
ซ*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
-------
Appendix 2-4:
Quantitative Research Mail Questionnaires
277
-------
-------
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 ปn
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 ปlo=~"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 [[[ ฐO
Name of manufacturer [[[ oD
Phone number for information ..... [[[ oQ
Directions on how to use the product [[[ ซO
Description of what product does .................................................. . ......... osQ
Information about where the product should not be used ....................... ซn
Information about effects on personal and children's health or safety .... o?Q
Information about effects on pets, wildlife or water .............................. ...ซQ
Product contents or ingredients [[[ ซO
Information on how to store product [[[ ซO
Information on how to dispose of product packaging .............................. "D
Information on what to do in an emergency or in case of accident ......... ซฃ]
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 -ป(Continue) 2 Q No -ป(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 ฐ-50 /0
Other Ingredients:
Water...... ., .-. xx-x%
Butane/Propane (4/1) xx.x%
Petroleum Distillate (aliphatic hydrocarbon) x.x%
Polyoxyethylene sorbitan monooleate x-*ป
Sorbitan monooteate XJ"ป
Perfume ซซ%
Sodium Benzoate *-j!'r
TOTAL 100%
ปn 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 80ฐ 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-
ป(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
oป 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
ป D Product brochure
n n Poison Control Center
ป n University or county extension service
ป n Library
ซ Q Environmental group
17 Q Consumer group
11 Q City government agency
it Q County government agency
ป 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
H o
Ul
o.
D
Q
gg g g ggg gg
gggg
gg g g ggg gg
gggg gggggg
gg g g ggg gg gggg gggggg
gg g g ggg gg gggg gggggg
gg g g ggg gg
gggg gggggg
iMililit
53*111 Sii
"5 = ^*2 *
-------
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
indicatewhether 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 , jjioaปo 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) iฃZ
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
ฃ
5
d
d
d
d
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
Paซt 12 Months 12 Months
Flying insect spray 'D 'D
Ant and roach spray d d
Ant and roach baits d d
Indoor loggers ซD 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-ป(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
ซD 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
.ฃ
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
ซn
^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?
O
J
H
1
aTl
dd
dd
dd
dd
|
d
d
d
d
d
ddd
ddd
ddd
dd
d
>n
d
d
ddd
ซC
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
d d
d d
O d
d d
d d
fe
if
-ll
d
d
d
d
d
d
d
d
d
d
d
0
o
= 1||
d
d
d
d
d
d
d
d
d
d
d
d
X
"c ซ
d
d
d
d
d
d
d
d
d
ปD
d
d
ll
*!
ซn
d
d
d
d
d.
d
d
d
d
d
d
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" ซ
-------
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 dฐ 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 ฐ" We As^pSsl^ef9'"9 dฐ VฐU "^ 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*
-------
S.
ui
g
1
S
o.
I
a ngn g g ggg
gggg gggggg
g ggg g g ggg
gggg gggggg
o
f
i
-------
cL_ * tomowi touch pease
andifirt
' "i"5 Household jenns
MM 10 USE Uป WHAM1* dun, awfect.!* **ปซ">& n
Nnu> touuMU utau Ha nenwM en Md taxi
etKCMNS m US I ซ I ซam d hซnl In n n ut ปซUi > i
BOTH ซunHซ ซซ u tt** 6OBW1 OE1MM MO ROOBS
UuMcMtoidMftmiif to ira^ nปm mgi fintMr n
SMI Hi Ftr IMI tarn. ซnv a MM irt in* fa in nip
. w U emaA id tnt mmttftn "tlu ซy w
SNNMUS&MCSflCMMJUS
WMNING Rt MtUT 0ป M * ซa hr HIMO ซw
" t ซ iMd HIS1 ซ0 I en
ปwซ*ซป.ca.ซwmfwmcAioซcieซai
M2MD tmt *OT ปw ซซ. ปซt) mi w> STOUttOISnUI. J1WUW Sot n i
tMCvni COMUBOrireiM.pgMnMiKvnunn'WnHi
11 CMonr n mvซi IMVI ft mawcr ซtf *Kปrd M ntt MOOUCT
asnui. um m r* ปm * if* ซปMI
rMuateonotf kป>ซซur Ooซ
Package #R24
ffl"5
DKCIUIS KM USฃ Add I/I cup Hr 9'*"1"' *"ur For no-
wuttooa0"V iซ 4kซJ Forean lougli cbs-iBtWiortngei
IM nisi ntmMiittV Not nconiiMnded for uu on wood for
pined uriicu. testป 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
liซi 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: Heซmie ttt MMK ortictMO. clw*B|
Mkmrrtt. teaw n >>ซeซtinii
: TO
~- OtSfOSt Uu uo. gn ซw>v or (xx-
I; unused prodrcl down dnm end Hush
{tSgH? wmwmr
UM BvIHฃ"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 ปR24 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
ปn
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 -ป(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 Nฐtat 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 tฃ
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 iฃ
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 -ซ(Continue)
zQ No-ป(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 ป C
n Q Product brochure n C
ป D Poison Control Center a C
ป Q University or county extension ป 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):
Dฐ 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
-------
3 UJ
s.
O
o
CO
*
CO
!< o
s"
o
o.
CD
O
f
o
o
cp
CO
ll
M
i
e x
II
gg g g ggg gg gggg gggggg
0 Q ggg gg
gggg gggggg
UJ
gg g g ggg gg
gggg gggggg
g ggg gg gggg gggggg
gg g g gg-g gg gggg gggggg
ซfl
IP1
fit'
jSg
M 5
!i|
) S E
! ซ
; ฃ
> CO
ซ
5 r,
iff
rl
15,
ID *
!-i
Mi
wซ
5
a ฃ
ฐ-ฃ
?
%- a
?Z ฃ
i^ง
_ uj _
S
^f -i
^Si ง1|
* 1=
J8_ g -
IJIgll
f ss~-
pifll p! till
If Hi 11 III s tl!|
|s
" w
5&
: CD
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 productCD 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
S$
S3
fcJ2
ฃ5
11
O
zD
*^_J
ปD
2n
l__J
|
I
3D
3D
3D.
l_J
3D
L_)
"B"
Directions
For Use
i
O
il~i
'L_J
l!~~l
o
L_J
n
SS
I*
ฃ5
??
0
2n
*l J
aPl
*L_J
zi~n
,r\
5
3D
3n
di_i
aFl
"*l J
.-.n
-C"
Storage &
Disposal
t>
ฃ
-D
,n
'i *
in
L_J
il~l
L_J
in
ฃฃ
*t
>- ซ
I5
To
Z"Z
2D
'
sF"!
-[""I
sn
J
ง>
J2
3D
3n
*! 1
sTl
*T__)
3l~l
4L_J
3n
-D"
Precautionary
Statements
o
1
D
'
lP~l
in
LปJ
,n
IS
ฐ>S>
*s
55
II
0
,n
*L J
_r~~]
2] |
sn
ซ
5
3D
3n
ฐi__ i
3d
"t__t
3n
**L_J
3n
"E"
First Aid
8
O)
D
i[~l
>L_j
lf~~l
,n
L_J
in
gฃ
S3
feJ2
ฃ5
II
0
ปD
sD
ปD
-F"]
8
O)
D
3D
3D
3D
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) ซD 4D
Concentrates (mixed with water before
using) >O 5D
Product Type Lawn herbicide eD ซD
Fruit/Vegetable insecticide or fungicide ?D 7D
Tree/Shrub insecticide or fungicide *D ซO
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
* ' * ปVSป 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.
303
-------
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
July 7,1998
-------
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?
The Newman Group, Ltd.
305
-------
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
July 7,1998
-------
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
-------
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
-------
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
The Newman Group, Ltd.
309
-------
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
< ซ* :!!:,i !:!ป!. I
-------
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
-------
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
-------
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
-------
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 Yeง. 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
-------
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
-------
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
-------
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
-------
-------
Appendix 3-2:
Qualitative Research Discussion Guides for
Indoor Insecticides, Household Cleaners, and Outdoor Pesticides
319
-------
-------
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
-------
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 ฃ . , . . 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
-------
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
-------
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
-------
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
-------
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
-------
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 inufซ*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
-------
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
-------
-------
Appendix 3-3:
Signal Meter Mock Label
337
-------
-------
339
-------
340
-------
Appendix 3-4:
Outdoor Pesticides Mock Label
341
-------
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&ซ; /s ซ repmstnation of the Mentation seen on real I
products, but does not accurately duplicate a nal brand. \
342
-------
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.
ซN*ol WKnlM al HOH5WHS
rn*d UraM nO 1-M4S-BS
8TnOBrart ol TM Weed Coraany
Mvuboumlfr
ThsWMdtareuny
lOOMwSme
ซflyMmUSAt2M5
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.
-------
ฃCTngซgKS%m^ai^'Mc=aSa=Mซai.:rrฑarSsacgrac=aM^-S
l*isฃ?i&ฃ&lฃ*ฃฃZ**sฃiS
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
ฎTn
-------
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 sซ) ----------- 0.20%
----
. - . - .
(Xnetnyanwie sซ) ----------- 0.20%
MCPA |Z-(2-Meซyt-l-cl*xo[)(ioปxy)
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 acsซ
ingndensi.preMiviM (less tun 0.1%) _
mil ,ซ.H.....ปซ.ซซปปM .......... ซ..ซ... 100.00%
.(cfetrA(WC
2.<.DJOdซiMfl.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
ป>iMlf*iซlti
irriUUซซa
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.jซ]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* MtซcilMeniataiall1400-555-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
ฃ0-5
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 85ฐF 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-ซ00-555-5555
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*iiซปiytimซ)esir
MCW.SroWiyamoear'
OowtowaJieiS 9960%
. .108.MY.
J.4-0 >od JCUMKnl Bomtf sceofic 6y AOAC
cnxl&27S,aiง%
"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 1-8ซHXX>-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*ป ** **^ ซiSt^ปTBซi 11 m*.^ซ>''^*'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 ซ**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.4ซKt!iyomปesa" . 050%
KEEP OUT OF REACH OF CHILDREN
SHklCtllMlfeMMUtf
(nuBliwirrtUMmtUi.
CAUTION **>ซ*"""'"ซ"'-"
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
ฉTrademark 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,. ปMHJPIM 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
. PitduaWonMlloncปII1400-555--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 ป represents
products, but doซs 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 gซ 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).
ปซ 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
ฎTrademam 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.<)ซmmy*nซwsir ___ 050%
MCPA.(HnซJVปnw>esilป" __ OJHK
OBWlnjwJiaits --- 99.60%
........... ........ ..... ....1W.CG%
RSp KEEP OUT OF REACH OF CHILDREN
r" PIHTinU SซliUpiMHiriซltlซal
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.
Mซtal 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
-------
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 "*ป'k''ซ"ซ"ซlliซ"
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. [
-------
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 Sฐ/<
"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
-------
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 ซl USA
-------
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
-------
Appendix 3-5:
Household Cleaners Mock Label
371
-------
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
-------
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
-------
.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
-------
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
-------
.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
-------
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:ปyou 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
-------
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
-------
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
-------
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
-------
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
-------
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%
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
394
ACTIVE INGREDIENTS:
Ajkyl|C12ซQ%;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
-------
IF ii ซ!"ป V" li" i1' ฅ ""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
-------
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
-------
,-*'
ALL'
URpOSE
CLEANS"
"'^ฃ-1
. lซa~<*ซw*>
..&'
./ /
.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
-------
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 norie6to8mcheslTonisiซf8ce.spny soiled area.then woe dean
Note: Annse is rawed for surfaces ซi 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 ซ* 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
-------
-------
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
ฉ19XXWham
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
-------
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
-------
INGREDIENTS #1
Kills fast
for up to
6 weeks
Fresh Scent
12.2 aiOilonietlmytl Zf-ti
B.2IK
fifimaiitsiatHeteauial .................................... ป.sn
OTHffl/WCHฃD/ฃซ7S: ......................................... U.45%
Otmriegreiliciitttrc:Witcr.Bซtim/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%tปl%;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/wปww 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
ฉWXXWham
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- ซE*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: ........................................ ป.ซ*
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 .................................... ซป*
.....
FttnteimOtstiUtttttlifMicMmafiui)
firiune.
&Nffซnf 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 01develops. IFmHUฃD:
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 ............................................... ซ.ซ%
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
ฉWXXWham
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 ,;'ป. '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
ฉWXXWham
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/wtimoiuinฃCAifnaiaiir
UttUIIUN. srm*Bnsontปcx
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 ฃ6
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 XซJ
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
ฉ19XXWham
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
ฐ 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*ซttjrttertp*f/io/msttjfcป*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
ฉWXXWIum
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
ฉWXXWham
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
ฉ19XXWham
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*
ปซ"
omnuiewtBns:
. Klip out of raach ot children.
8- '!..ง> Harmful or fatal II twallmad or ibtortud through skin.
^ ซ 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
ฉ19XXWham
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&iwxtuu-f*s*uMm
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.
sฃe aw!y fmm heat orฐl>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
lฃnp 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:
...............................................
[[[ ฃ??
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
ฉ19XXWham
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 MGRฃDIฃHTS:
fenoetmn (USX
2-(1-MctWttlair)ii!nKlmetlirtarttmttt J.5IX
0.01%
f.H%
B.2B%
tiOoiiili tet*ป/ซ/. 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? >^(งix
Call 800-12M567 /SSซฃ&
Weekdays 9-9 . Yซ^^ซY
Eastern time
ฉ19XXWham
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
-------
COMBINE PROP #16
Kills fast
for up to
6 weeks
Fresfi Scent
Petmtiiiia
2-(1-M*tlirlปthoir)tliiปeliTaeiyleMtimtte 0.5W4
Tnlametririn
ii-taittMeปriป
PmtiaiiB
Rferattfltatiiidetultaieil. fl.50%
OTHEHIHGReaiBUS:. ซซ*
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.
-------
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
-------
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 ฉ19XX 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
-------
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.
' -<ซo 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
ฎ13XX'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
-------
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 ฉ19XX 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
-------
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"' ' ป 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 .
-------
447
-------
-------
Appendix 3-8:
Open-ended Questions on Consumer Label Preference
449
-------
-------
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
-------
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
-------
/ 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
-------
-------
Appendix 5-1:
Pesticide Labeling Under the Federal Insecticide,
Fungicide and Rodenticide Act (FIFRA)
455
-------
-------
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 ง 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
-------
described below are taken from the 40 CFR ง156.10. 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
-------
"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 ง 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
-------
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
-------
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 ง 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
-------
. .
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
-------
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
-------
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 ฐF, if there is a flashback at
any valve opening.
Flash point above 20 ฐF and not over 80 ฐF 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 130ฐF 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
130ฐF 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 130ฐFmay
cause bursting.
(B) NON-PRESSURIZED CONTAINERS
At or below 20ฐ F
Above 20 ฐF and not over 80 ฐF
Above 80ฐF and not over 150ฐF
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 ง156.10
;:. ';: v; , ป,, , ; 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
-------
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
-------
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
-------
Appendix 5-2:
First Aid Qualitative Research Participant Screener for 1-on-1 Interviews on
Household Cleaners, Indoor Insecticides, and Outdoor Pesticides
467
-------
-------
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
-------
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
ป 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.
ป Floater will be paid $50.
|
I
Other Details
> Refreshments will be offered to participants.
ป The identity of the participants will remain confidential.
14
470
-------
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
-------
7.
8.
9.
10.
11.
12.
13.
If
What is your ethnic background?
African American
ซ Asian
Caucasian
">',. Hispanic
Native American
ซ 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?
Yescontinue
No-proceed to question 10
Could your employer be described as any of the following?
* A professional cleaning serviceterminate
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
Yesterminate
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
-------
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
-------
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
I ilililllii,! ,:i.|i i. in liililllit, j,i, i: Ililiili j, i.,i,,ii.i .::;;,li,li!,.i I!! lilliili :, illllill. i .iliil. liili. ,,, ..ill ..! ,::i,' liiftillti i'tfiliiil n 1 I. .1.,:. Hi ill.,!. ,1 ...it.;.! j;: ;.. liH;! ii.;,' lluol iillltii I ! :! l!v iilMln! liiiiiHiLi'Li.,! ;,ซ iSiiiiiir .,!, ,; ill ' .;^lillli!lll:^i!|llil;::l!llllilllll, ;i! i, . ;1
-------
Appendix 5-3:
First Aid Qualitative Research Discussion Guide,
Consumer Comprehension of the Proposed First Aid Statement Language
475
-------
-------
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
-------
-------
Appendix 6-1:
North American Hazardous Materials Management Association (NAHMMA)
Storage and Disposal Questionnaire for States
479
-------
-------
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
-------
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
[ ' -;!;: -ซ! .,;.!', . t," i II '
482
-------
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.
ป 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
-------
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
-------
Si 1 .iii i:i, /.I,,; iiilii : i.,, . IB kฃ ii;> iLif! id, titJUtt Jiiilit,, i; iiitii ,!. .iii'i::!:)-!.'! iii!.!::; sti iiif
I. i ,:iiij! t ; i,,, ailiif ฃ AiJ^ ii i,,ii, 'Ji.il f iiiJii.l,;,!;:; i-, ซ!'...'. IJiiihii :., L ...i,: j ' ,,1L, I :i
-------
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.
lull . * i,.,,,| I,,, , ,| ,,,1,4, , ' , . , i, ". IN , ; , : i !!', .IF , i. i
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.
ji"i;',:, ' n tjl ' '.,f! . , ;!,,., ^ , ij ' i i- .; '" i
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
ill ,,;, Mi !t > .,
sill.; i a;!, ..; :ฃ,,,,! ,i::,;',i,,,!ij i .ซ s.. ..L1' .i.'.:
i, !lillili!U llJlt'J',!
-------
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
-------
T
"O
: i
; ง
! =ป'
1 "0
, 5-
! i
I CD
ฎ S.
* 3'
ฃr . CO
T s-
^ Q>
^ 3
(Q
CD
CA
,
^
ould better meet
o
o
nsume
3
3
CD
CD
CL
T
o
letermine what, if
ID
55"
cr
CD
O
CD
CO
CD
(A
saie piuuuu u&e
environmental, hea
Er
Co
0}
^
ง
3
ซ-*
o'
T
H
est overall compr
CD
ension
o '
55"
cr
cp_
o
3
i
General Leai
^
5'
CQ
O
^CT
C).
<"
CD
CO
-n
CD
CT
Q)
_->J
CO
CO
oo
1
*
9
^tf
If
*
1
__^_
il
li
!
D
c
Q)
"~ *
5T
ป-t-
0
"D
0)
co
CD
^^^M
<^
Q)
"%
ฃ
(D
CO
CD
03
-r
O
o
ZJ
CO
c
""^
3
cr
5[
55"
f
' * :,;:;
: j {i!!iii.
i :i:''
f
cr =- CD
CO
CD
O
^h
o'
7s
CD
CD
Q)
(Q
CD
a
CD
c
e/j
_co
0
CD
p^
1
* 55'
* 1
^ 9.
^^^v TJ
^^P ^j
0.
c/>
(A
Ql
(D
^^-
&
o
o
CA
CD
^^>
S
c"
Q.
3
CD
CD
CO
CD
-n"
3
CD
Q.
(/)
T
if
c ^o
CD "3
CA
" CD
C^
0)
o
S
Q.
C
a
5T
cr
cp_
(A
o
3-
CD
-o
O
Q.
C).
Q)
CT
~
C
' i
T>
O
CO
CD
11
502
-------
CO
Q)
3
i
j
i
i
1
j
!
' J
lij
*
i
* :
t!
!
j
i
1
i
T
o
CO
0?
&T
CT
a
8.
CO
Q.
to
M_
i.
3
CO
1
a.
CD
1
i
u
09
to
i
Itten questionnaire
8
CD"
5T
Q.
,5J
TJ
0
T3
zr
one questionnaire
ง
o_
ฐ-
ซ<"
5"
c?
1
i
T
33
CD
5"
0.
_,
T
TJ
CD
CD
a
.a
-0 CO
S S" i- 3'
< TJ . ST C
1 2-^1
t^s-S
8- ฎ 2. 3
o "R co ฃi
ฃ i. ST"^ j
= o S i
a S- g-;
2. 5- a ;
3 o- w
O ซT
2. o :
CD ?^
CO Os
O
CD
O
a-
Q)
CT
0
>
i
i
ซ
f
Written questio
3
CO
3'
3'
0
Q>
CD
QL
CD
cp_
O
T3
CD
3O
-a
O CD
O 3
g 1
CD. CD
SSL
c
Sf.
-a
o
CD
o.
52.
Q.
a
o
CA
3'
D.
Q.
CD
CD
3
Q.
CD
O
An instruction l<
CD
T
:o
.espondents v
i.
1
CD
D)
52-
3-
0
3
CD
Q)
2.
0
CO
0
0)
O
O
0
CO
CQ'
^j
12
503
-------
!
m
*
if
,
CO
*
D
CD
1
3
TJ
rr
8*
*ป
a
key words/phrases ]
3
cr
CD
Q.
ZJ
I
i
consumers' opinion
Q)
en
7T
CD
Q.
=J>
CO
ro
"
Comprehension o
Q)
CO
1=
D)
CQ
CD
cr
CO
CD
o
* *
o'
consumers' opinion
sections
o
CD
CO
CO
CD
a
5
Q.
(Q
_
accuracy of finding
8
a
CO
CD
a
o'
CO
rn
to
CO
CD
a
o
1
CO
of
*<
of
cr
JL
CO
CD
a
o
CO
"0
IT
O
13
CD
D
c
CD
5"
13
13
Q)
3'
O
ฃ
iqp
0
cr =ป
cp_
co 3"
~* CD
rj o>
CD Q.
CD CO
8-a
P- w
CD
CO
O
O
O
m
X
Q)
-g_
CD
0
o
03
cr
CD
. meaning, what actions
<$ o
i:
^^ o7
W^ PC
^ S
rr
to
CD
rsi
a
ง
T3
1
en
tn
. Other sources of producl
3"
o1
O3
cr.
o
n
O
*.
CD <
D> S
CD
X
a
CD
a
o"
rsi
Q.
5'
o
n
5T
cr
cp_
rr
o'
rr
3
Q"
r>
Q.
3
o
w
. Most/least important infi
u
5"
S"
8
(A
CD
~"
A
o"
s
g.
CD
i.
(Q
O.
o
=J
CD
01
p.
rr
r>
"*
ro
. Where/How often read s
CD
&
O
U>
O
sr
ff
ซ
_i
. Overall satisfaction with
o
CD
5"
cr
CD
5T
|
I
CD
C/>
o'
13
13
0)
ซ.
(B
0
c
~
Z3
CD
*
If
^^^
M
CD
01
. CD
U>
' o>
i
1 3
o
s-
: cr
cp_
Completed by the consumers at
^
CD
-n*
CD"
w'
^
CD
Interviewer then instructs them t
survey
o
8
o
2.
<5
3.
CD
r>
T
.Approximately 10-12 minutes
Written
ii
M
CD
V)
to
O
5T
cr
SL
. Conducted first by a trained inte
j
i
CD
esearch Components
Phone
Questionna
^ซ
CD
13
504
!l(,l I Hi"!' "ii , liitliL i, .. li,,,:1 ]< Illll'l1
fsiilH! Ii:!,::!!;, lib: JituB:!' ,', :l;iai lllilLi;, .'lii:; { UtiAin,, iillliilH^^^^^^^
li , i :,nli ,:,; 1 li !i ni
, ,,,:,;', i.Mti. .. i,,, (:!!
liiiliii Jtiiiiiiiii1., ililitlilK iiJi ;l .a'.!!!!!!;!.!
-------
1
*
ฎ
^
1
<
CD
(D
(D
o
CD
a
rii
3
Q.
a
CO
f
CO
g
3-
&
D)
t to find most easily
i
<
CD
1
ect to find information on lab
CD
""
Co
1
^
O
CD
0)
CA
important information to con
CO
c
3
CD
T
< <.
ft
X
a
CD
3
3
Q)
Q.
CO
O
a
o
CO
a
to
cr
CD
CO
T 1
^n
m 3-
to o
co 3
I
CD'
03
B
CO
m
X
o
CD
a
CD
Q.
O
8
_
o
1 _
i
CD
Q)
3.
3
(Q
O
.Cr
CD"
I
K>
CO
O
J
II
1 1
C O
i. 5
a. =
co| CA
CD co"
/A 211,
w 5?
8- S-.
o o
C. 3
53" S.
cr 5
-P
S ง
a s>
5j ซj
o ปป
3 if
CD
CA
i
i
T T
< ' IJ
^ m 3-
3: Q) O
^
o"
8
Zฑ"
CO
CD
57
or
SL
CO
CD
a
o
CO
5g
II
1 (/)
^ป w* r^
g C" CD
^* ^| ซ^
9ฐ o* 3
83 3
-i w
o" J?
I'"8
CD
O
O
CD
3
CL
W
o"
5ฐ
CA
0
^^
0)
CO
! fo
. X
i $D
-n
: ฐ
,
CO
i m
X
a
. CD
; a
CD
a.
o"
; s
; o"
CD
0)
CQ
0
ฃT
I.
CD
N>
CO
8
O
I
&
CA
(D
ฃ:
i^ 1 o
i 3
A i ">
W j 3
! CD
ifc> i CD
P* ! CL
* i i.
^ 1
; CD
! ^^
' Mk
1 CD
*
to
i o"
: f>
8
3
CA
CD
-i
3
CD
(D
Q.
TJ
1
CL
CD
CO
CD
3
CD
^ป
0)
5"
TJ
C
^^
o
j r*
o o
C 3
i w
i ff
* -o
S" w
cr
CD
O)
m
CD
^
^^*
3
ft
5'
CQ
g.
^
CD
S-
8
3^
CD"
CD
x.
C/j
^2ป
3
(Q
oT
cr
CD
CO
o
c
3
t situation n
w
0)
I*
0
CO
0)
Eฑ.
t.
0)
a.
o
3
5
0)
3
(Q
o
1
CD
14
505
-------
!
i
I
<
; JQ
i o c
""*ป CD
i *~^ CO
! ZT r-l-
CD o"
CO 3
z?
CD S.
?) cB
^^ ซ"J **!fc
* cE i
i- o g.
T jz ง:
"o 5
: 54. CO
< co
% CD
CO Q)
^ o
ZT
1
__
f
CO
CD
a
^T"
o'
ZJ
CO
o
r-t-
0
4
1
! ป ป
i acddent experience
i current storage/disposal/recy
> incidence of category use am
label confusion
$-A'
^ o- Q.
^^ 3 3"
2 CQ
T3
C E3
3 a
r? 8
S M
Q.
C
CD
o"
> products used
ซA
Habits & practices
o
. Attitude statements
. FIFRA and alternate wording
CO
*
Paired preference statements
p
2
3
G
T-
T
I
O
CD
^-^
DC
Q
CD
ฃD
3
CD
O
3
1
>' <
1 ^^
'ritten Questionnaire
O
&
^^
ZJ
CD
O
O
ZJ
>
T O
ป
" CD i> ^
33 31 S * = ง ' O
llit|!ป,ง
Its &?f *| ?
งll?il"!-
og-^cc-oi 'r-
S tifii? s
? l|s|&ป ;3
< i
* & 1 1 1 1 : g
SfiSi f
3 Q. S 8:
o 1 8L s
* S S, M
"o5 ง
cr>
a
CD
CO
15'
CD
<_
O
. I
: 9L
1 Co
3-
CD
0 s>.
'^ 5
^ i
o1
en
yo
CD
I
o
m to standardized information
o
3
in
to
CD"
10
CD
CJ1
D
3
CD*
ง
8
31
-n
-n
5
cl
1
4i
71
?
i
O
o
^
tension of label language
w
5T ^
o" J
CD CD
CD1
information is expected to be f
o
c
Q.
O
CD
X
CD'
3
3
hy of importance of basic labe
_
5"
31
3
o'
3"
& content of existing labels
;
O
1
t situation relative to satisfactic
7.
CD
1
CD
03
3
Z>"
CQ
0
*cF
<~k
3 1 r4-
l! i'
?i 8
CD
506
i!; ! ';;:,!,;,!,*:;,; i; ฃ1
-------
/
i TJ
i CD.
CD
Q.
o
1
*j 8
S"
^ i
CD
^^ to"
i
-FIFRA/nc
v^
I
TJ
1
TJ
8
C?
ง
o
CD
- Likes/disI
ikes about
0>
cr
2.
CO
CD
a
o
CO
i
T T
li
c? Q
3 CD
0)
CD
ฃ
CD"
CO
o
^5
o
<"
TJ
8
CD*
O
CD
%
TJ
TI
^
<
M
0
TJ
TI
5
CD
0)
3.
CO
o
^g-
CQ
CD
^^
CO
CD
Q.
o'
O
o
TJ
^^
CD
CO
o'
0
^^N
5T
cr
CD_
5T
^
(Q
C
Q)
CQ
0
MMM
CD
Q)
3
13*
CQ
0
f^J
%cb"
Q:
^^
CD
ซ
If
the store, bef
emergency
^j
"^
CD
CO
O
3*
O
0)
CO
CD
Q,
"*!
organizing inl
0
91
o'
CD
3
CD
CD
CL
CD
5"
CO
Make format
3
commendations,
v>
c
o
Q)
to
NJ
Make word cl
_j
CD
inges where poss
cr
CD
sections are ;
<-ป
sferred to FIFRA
o
tion Steps
Quantify whe
5
CD
0
TI
5T
cr
CD
Preference f
o
TI
TI
3
O
3
TJ
TI
5
CD
Q)
i
CO
Objective 5 con
ซ-
CO
Recommend word changes
$**
* *^"s
f
CD
CL
CO
3-
O
C
Q.
cr
CD
c
CO
CD
P-
0)
CO
0)
T3
o
S
-o
sT
CD"
consumers to understand wl
j
SI
CD"
1
o
0
(O
ro
Recommend additional qual
^y
rl
CD
$
O
7T
^
Er
difficult to understand
- >
:tion Steps
Identify terminology that con
to
1
Ct>
CO
T"
^
CL
O
omprehension of label
ZJ
CQ
0)
(Q
CD
Learning Objective '
-*^
O
o
ZJ
ซ--
16
507
-------
!
i
Where expect to find
most easily
. Where expect recydil
" i to ='
1 o 'go
t ! s
O QJ
T3 |
"S ง
Q) ^ซ-
; o"
1 ml
5
1 CL
i
Most/least important i
=ป
3"
Q)
ST.
O
. Where/How often rea
Q.
M
CD
a.
0
w
a
m
cr
CD
CO
T T
Phone
.Ease of locating key 1
Written
O
cr
cp_
CO
CD
a
o
CO
T|
O
21
o"
O
S3-
o'
-J
o
""^
5*
21
6'
>^i'
CO
TJ
CD
0.
ง
~t
W-
0)
O)
t
ro
. Make format (location)
recommendation:
'"I!
could be standardized
-* >
0
30
2 =
ฃ co
CD $
0. TO
r
o
o
e
pes of information
,
rr
which want to find mo
-Where/How often reai
J3.
CD CD
a 8!
ง^
IA
O
^i
5"
cr
jp_
O)
i
CD
5
CD
g
8
^^
0
=11
Q.
information on lab
CD'
~~
cฐ
T
Written
-Most/least important
information to con
to
c
3
fl>
c
se, environmental,
fio
rr
(D
E.
??
5'
S1
J
^3
&>
sฑ
o
3
SJ
O
r\t
tction to standard!:
zed informatio
o
3
(0
fi)
&
r-
o
3
5"
(Q
O
,cr
o
ง:
CD
*
*
tflj
*
If
^^^
^^
Draft Analysis
(_
c
3
CD
_a
CO
Data Avaiiaoie
c_
c
3
CD
Ol
Field questionna
cB
^3
a
Pilot questionnai
CD
v>
a
_v
Field screener
a;
23ป
M
Questionnaire in
from stakeholdei
task force
-*1
o IT
U CD
ง8
CD ^
ซ g
? T
ง CD
-n O
&2
^
cซ
Activity
v.
5>
o
^
CD
i
i
! ^
1 ^
o
: ,
! 3'
i CD
1 r^
; ฎ
T3~
T
O
urrently exploring a
igredient informatioi
'1
n consumers w<
1-d-A'
^^ 13.
o"
5"
o
s
Iternatives on h
1
o
fi)
o.
Q.
(5
in
5
SI
.
Attitude statement;
wซ
.
FIFRA/non-FIFRA
a
-n
(D
O
at
,
Where expect to fli
a.
5'
p"
3"
o'
1
o"
91
Q.
3
o
52-
(D
O)
en
.
Most/least importai
it information
.
..
Where/How often r
(D
0>
Q.
(A
(D
a
0
CO
E1
?
T
^
Comprehension of
/ritten
language by se
a
o
3
3
(D
3
T
i TJ
o"
1
CO
5'
formation
5"
(Q
CD
CL
CD'
ZJ
55"
O)
TJ
CD
O
SL
ET
CD"
CD
ry>
<-*
B
0)
*
17
508
-------
DRAFT
February 9, 1998
Background Paper on the Standardization of Environmental Information
on Product Labels
PURPOSE: To explore issues related to standardizing environmental information on labels and to
engage stakeholders in framing the debate.
The U.S. Environmental Protection Agency (EPA) and others have sought to improve consumer
access to and understanding of environmental information related to the products they purchase
and use. The underlying objective of such standardization efforts, as well as labeling in general, is
to enable consumers to make informed choices. Thus, the marketplace, through the collective,
informed decisions of consumers, compliments governmental regulations in setting public policy.
EPA and others have considered standardization of information through a number of activities
including, for example: EPA's ongoing Consumer Labeling Initiative, the development of labeling
standards by the International Standards Organization (ISO), and the Federal Trade Commission's
guidelines for environmental marketing claims. In the U.S., the most common and well-known
example of standardized label information and format designed for individual consumers is the
food nutrition label.
This paper examines the possibility and limitations of standardizing environmental information,
specifically that information required by environmental statutes, such as FIFRA, for household
consumer products. The focus of this paper is to help identify the issues and frame the debate on
standardizing the format, type and text of existing information, not altering the content and not
including additional information which is not presently gathered. The paper is meant to be a
starting point for EPA's discussions with a wide range of stakeholders. The views presented here
do not represent EPA policy positions. EPA emphasizes the importance of stakeholders,
including consumers, in shaping and guiding any investigations into this topic.
Unlike the nutrition label and hazard warning labels, presenting product-specific environmental
information to consumers is particularly challenging for a number of reasons:
the information is complex (ranging from application instructions which, when followed, can
reduce threats to the ecosystem to recycled content of the container which relate to the waste
minimizations efforts of the manufacturer);
often, consumers cannot readily perceive the environmental attributes of a product during
purchase, use and disposal; .
ป estimating possible impacts (as part of a life cycle analysis) require assumptions regarding
chemical fate and transport, exposure, etc.; and
each consumer places a unique set of values on the many environmental and other product
attributes (such as, price, quality and availability).
Standardization is expected to offer consumers real benefits in making information more
accessible and allowing useful product comparisons. Among the-questions facing policy makers
and researchers are: Is such standardization technically feasible? What, if any, regulations would
have to be changed? and, Would the benefits exceed the costs? This initial paper is limited in
scope -- it examines a number of issues related to questions of feasibility only.
18
509
-------
DRAFT
February 9, 1998
While ISO efforts call for most labeling efforts to be based on an evaluation of the full life cycle of
products, this approach is not feasible. Some of the product categories within the scope of CLI
|re subject to FIFRA, which establishes, by rule, the information to be presented on labels for
such products. The FIFRA-required information covers not only the product itself (based on the
evaluation of the product formulation and its active ingredients) but also the package or container.
The resulting information for the product includes: ingredients, precautionary statements, signal
words, first aid, physical and safety hazards, environmental and human health hazards. The
packaging information typically related only to instructions concerning disposal. Additional
information about the package (e.g., its recycled content or recyclability) and product (e.g.,
contains no phosphates) regularly appears and is already presented in a standardized format by
one company" However, expanding the type of information to include natural resource use, and
production-related impacts as part of a life cycle analysis (LCA) is beyond the scope of
information currently available. To require such additional information on FIFRA-regulated
products would involve revisions to guidance and regulations.
Another issyg tojje considered is whether some of the information currently presented
qualitatively in text form could be presented quantitatively. For example, toxicological
Ijifbrma^pii (e.g., LDJOs) could be presented quantitatively. Information for each of the five
hazard categories might be presented in a matrix or just the primary hazards (along a I to VI
s'cale). Presenting such complex toxicological information may, in fact, overwhelm consumers
and cannot be considered without extensive market research. In addition, such a format might
also be used to present the attributes of a product relative to those of other similar products or to
the ftill range of4 values. For example, additional context might be provided for the signal words if
CAUTION->WARNING->DANGER scale appeared with the appropriate word highlighted.
Alternatively, a scale (e.g., numbered 1-10) with a product-specific mark could be used to replace
the signal word. While the previous examples of quantitative information are possible using
foisting information, this information is not currently presented on labels.
Including icons was considered as part of CLI research but was tabled as top complicated to
investigate at this time along with wording comprehension and preferences. Several researchers
fjaye expressed concern about using icons to replace the content of current text because there is
little consensus on consumer benefit and little experience in the U.S. with using icons to represent
such environmental information, However, icons and/or graphics might be included to augment
label information -- e.g., assist consumers in finding the environmental, health and safety portion
of the label and to identify particular topics (e.g., precautions concerning exposure to domestic
animals/pets, telephone numbers and first aid).
While ease pCusj and ready understanding are goals of standardization, it should be stressed that
ijis critical Ifeat consumers still bง directed to read the entire, label, Revisions that increase the
rjs.k of skipping sections of the label will jeopardize the labeled guidance that products are "safe if
used as directed!"
510
19
-------
DRAFT
February 9, 1998
In addition to the limitations of standardization noted above, any such changes to current labeling
requirements must not depart from the current regulatory requirements. Standardization would,
at a minimum require that regulatory guidance be revised substantially. For example, font size
and phrasing are established by a combination of regulation and guidance.
Examples 1 and 2 are provided to aid in thinking and are not intended to be proposed formats.
Example 1 is a compilation of facts that might be used for quick reference. Example 2 is a
compilation of most of the information currently on labels and may facilitate product-to-product
comparisons.
20
511
-------
DRAFT
Standardization Example 1:
February 9, 1998
PRODUCT FACTSY *'" * T **,/,; ; , / ,
Active Ingredient(s)
Chemical Identification No.
Chemical Category
Other Ingredients
Use
Hazard Category
Principle Hazard to User(s)
Precautions
Treated Area can be entered
Environmental Hazards
Environmental Precautions
Other:
Cyfluthrin Imidacloprid
CAS # 12590-57-3 . CAS# 34569-98-5
synthetic pyrethroid chloronicotinyl
Water, Glycerin (to keep from freezing)
Emulsifiers
Multipurpose insect control on lawns, flowers,
specified vegetables, trees, shrubs,
groundcovers.
IV (minimal)
None
Keep out of reach of children. Wash hands
after use. If product gets on clothing, wash
before rewearing.
After use.
Toxic to fish, aquatic insects, bees
Do not- spray or allow product to drift into
water. Do not use when bees are active.
READ ENTIRE LABEL FOR USE DIRECTIONS, INCLUDING PROPER
STORAGE AND DISPOSAL
'" ' 1 11 ! , !| ' '!', ' |TJ| , , 1 " ,,| i M I! .. . I'll 'i ' , ' ' "" i '
1 !|i , , '
':' I1"'!" ,,'n ' " ' ' ", i , ' j, ' ?; , ; f, '
512
21
-------
DRAFT
February 9, 19%8
Standardization Example 2:
FOR SAFE AND EFFECTIVE USE, PLEASE READ THE ENTIRE FRONT AND BACK LABEL
HUMAN HEALTH
If swallowed
'If in eyes
If inhaled
Precautions
Keep out of reach of children.
Do not let children on treated
areas until material has been
sprinkled and the grass is dry.
Do not contaminate feed or
foodstuffs.
Do not breathe dust.
First Aid
Call a physician or Poison Control Center
immediately. Induce vomitting by giving victim
1 or 2 classes of water and touching the back of
throat with finger. Do not induce vomitting or
give anything by mouth to an unconscious or
convulsing person.
Flush eyes with plenty of water. Get medical
attention.
Remove victim to fresh air. Apply artificial
respiration if indicated. Get medical attention
immediately.
Please READ the entire Directions for Use and Storape and Disposal sections for other precautions. Do not
let children on treated areas until material has been sprinkled and the grass is dry.
ENVIRONMENT
Water
Air
Animals
Possible Effects and Precautions
Do not apply directly to water, or areas where surface water is present or to
intertidal areas below the.mean high water mark
None listed.
This product is toxic to fish, birds, and wildlife. Do not use treated areas for feed
or forage. Do not let pets on treated areas until material has been sprinkled and the
grass is dry.
Please READ.the ^tire Directions for Use and Storape and Disposal sections for other precautions. Do not
contaminate water by cleaning of equipment or disposal of wastes.
STORAGE &
DISPOSAL
Product
Package/Container
Storage
Store in its original container in a
cool, dry, locked place out of reach
of children.
Disposal
Wastes resulting from the use of this
product may be disposed of at an approved
waste disposal facility.
Completely empty container into
application equipment. Then dispose of
bag in a sanitary landfill.
More text if needed.
22
513
-------
Consumer Label Initiative
Label Standardization
Nutritional Labeling "Box" concept
Utilize existing label information
Standard format will aid consumers in
product selection
Consumer Label Initiative
Label Standardization
Hierarchy of information/content can be
determined from quantitative study
Can achieve objective of putting
information where consumers expect to
find it
Less "clutter" on labels
514
23
-------
Consumer Label Initiative
Label Standardization
Addition information can be developed
in the future
"Eco-profiles" used in other consumer
product
Perhaps solicit inputs on how
assessments can be done from group
like SCS (Green Cross)
Consumer Label Initiative
PRDDUCTfACTfit , , " , ' - ,"," -' '*' '
Aefe* lnsoป4ซrtK<. lซซ. *"*ซ. tmntoann.
lll(Si(M)
Eyซ MWkn: Pc^M* *ป MปK"
Wnt> tandi ซt ซ IM. ป pradud a*t OB doซHng.
MMA vnyhat dftod.
Taclc lo Mi. nutf e knmi. kซM
Oolซซปปer^loซpm*lซปlซ. Done*
UM whซn b*ซซ ara *c^ซ.
READ ENTIRE IABEL FOR USE DIRECTIONS. WCUMXNO PROPEd STORAGE AND
DISPOSAL
24
515
-------
OPP Arthritic. ซn
Inert Ingredients
Cuneo G. Smoot
Policy and Regulatory Service Branch
Office of Pesticide Programs
Background
' OPP Listing Policy
In 1917. EPA took new ateps to reduce the potential for
advene effects from the we of pesticide product! containing
toxic inert ingredient!. The inert ingredients were
categorized into four lists.
List I ingredients, "inert* of lexicological concern," are
chemicals found to produce cancer, adverse
reproductive or developmental effects, or other adverse
chronic health or environmental effects.
inerts are "potentially toxic with a high priority
for testing."
Background (continued)
LuL2 are "inerts of unknown toxicity."
LilLd"incns of minimal concern" are divided into two
groups: 4A covers minimal hazard inerts (e.g., cookie
crumbs), and Lisl4B represents ingredients where there
is "sufficient information to conclude that their current
use patterns in pesticide products would not adversely
aflect public health and the environment" (e.g..
polyethylene glycol).
The I9!7 policy also identified a "base set" for testing
of inens.
The policy requires disclosure of List 1 inerts on the
product libel,
Impact of the 1987 Policy
List I
Pesticide manufacturers have cither reformulated -or
discontinued products containing most List 1
ingredients.
Of the 1330 products initially containing List 1 inert
ingredients, less than 70 products continue to contain a
List 1 ingredient
List 2
Of the original 64 ingredients on List 2. about 15 have
been deleted.
Impact eflht 1987 Policy (continued)
Lm3
This list has grown significantly. Generally because the
original list was comprised of categories of ingredients
Once more information was identified, each individual
inert substance was listed.
LIB 4
Number has increased because of reclaisification from
Lm 3
Current Activities
Managing the Listing of Inerts
One of OPP goals is to reclassify inert ingredients into either
List 1 or List 4. To accomplish this, OPP is focusing on
obtaining additional health and safety data. The primary
strategy for obtaining this information is:
identification and evaluation of additional data
close examination of the potential loxicity and actual use
of a substance
516
25
i : '
-------
New Screening Methodi
Of the approximately 2500 inert ingredients, the largest
number, about 1900. are on List 3. Since full lexicological
data bates are not available for these substances. OPP
developed a screening mechanism that would prioritize
this group by:
Structure activity relationships
Estimated potential exposure
In 1995 OPP-was able to reclassify 146 substances from
List 3 to List 4B (60 FR 35396. Juty 7.1995). OPP is
working hard to reclassify more this year.
Efforts to expand access to Ingredient Information
Over the past several yean OPP has been encouraged to expand
access to ingredient information:
Public FOIA requests for ingredient information have
significantly increased. New E-FOIA law requires Agency's to
respond electronically if requested to do so. Agency policy
requires posting responses to repeat inquires on the Internet.
NCAP v. Browner case brought to light inefficiencies in the
internal CBI process.
Electronic information processing: internally to meet new
deadlines of FQPA; externally OMB exerts a strong push for
electronic processing of all government information.
Enhancing Availability of Inert Ingredient Information
OPP is-committed to enhancing public availability of information
on inert ingredients while working within the mandates of the
FIFRA and related Confidential Business Information concerns.
Some of the areas under investigation are:
Reviewing FIFRA'and other regulatory frameworks to provide
new tools for enhancing ingredient information:
-breadth of disclosure under of FIFRA
-FDA labeling approach
Reviewing proposals for revised label disclosure
-NCAP and the State Attorneys General petitions
Anticipating CLI efforts to provide insight into consumer needs
and how to express them
26
517
-------
Consumer Labeling Initiative
Consumer Education Program
Julie Spagnoli, Bayer Corp.
Sally Patrick, MPCA
Mary Dominiak, EPA
ya % '3 a .
Consumer Education Program
i Recommended by CU Phase I Report
i Immediate and long term components:
'Read the Label' campaign to get people
to focus on the label to help in buying the
right product and using and disposing of it
safely.
Subsequent additions to campaign to:
alert people to changes in labels
help them understand and interpret label
information
il
a
j
tt
"Read the Label" Campaign
Create a common logo (i.e., MPCA's
eye) that all groups - government,
industry, and public interest groups -
can incorporate freely into advertising
and other messages.
Keep it simple: 'Read the Label" base
message, always accompanied by a
reason why reading the label is to the
consumer's advantage.
a a j a ,
"Read the Label" Campaign
i 'Reasons Why" - Be Smart, Be Safe,
Do The Right Thing, Feel Good
Be safe: labels tell you how to store and use
product so you, kids', and pets will be safe
Save money: labels say what and how much to
use; when you don't waste, you save money
Help environment: buy the right thing, just enough
for your needs, prevent pollution .
What things mean: signal words, symbols, etc.
ป a a jta
"Read the Label" Campaign
i Avenues to convey message:
Product advertising
television, print, radio, label, posters, brochures
Public service anouncements/print ads
solo, shared sponsorship, multi-purpose
Tie-in to existing information campaigns
local government waste/recycfing/health
programs
information distribution by government,
environmental and public interest orouos;
newsletters; websites * * * u a J *
"Read the Label" Campaign.
Target to specific audiences
pediatrician offices
veterinary offices
schools
hardware/retail store displays for
consumers
hardware/retail store/nursery salespeople
master gardeners
27
518
-------
"Read the Label" Campaign
Schedule
Adopt concept; approve strategy - 2/98
Contribute to quant, research -11/97-3/98
Workgroup develops communications strategy to
target selected audiences, develop logo, and
place message for deivery-2/98-3/98
Contractors develop message scripts/graphics;
reviewed & approved by workgroup, Steering
Cmte, EPA; solicit existing program tie-ins - 4196-
6/98
Final approval and campaign launch-7/9
"Read the Label" Campaign
Issues for resolution
u Commitment to program
People, resources, and agreement to
implement in existing corporate, government,
and other programs
n Precisely who does what to make it work
n Reality check on schedule
n Strategies for measuring effectiveness
n Plan to build future components of
campaign
28
519
-------
HB" f. II
Consumer Label Initiative
. EPA's CLI Goals
Foster Pollution PravanUon
Empower Consumer Choice
Improve Consumer Understanding of
-Safe Use
-Environmental and Health Information
Consumer Label Initiative
Benefit for Industry Partners
Learn how to provide clear Information
so consumers can make Informed
choices based on their needs and
values, and use chosen products safely
as directed
Consumer Education
Program
Objectives for Public Education:
Promote CLI's objectives by
encouraging by the reading of labeling
Informed Product Choices
Proper/safe use, storage and disposal
Consumer Education
Program
Public Education: Current Industry
Activities
Best Management Practices - Safety: Apply
It First
ACPA School programs(Benny Broccoli&
friends)
Ambassador Programs: ACPA and RISE
. Wnh SHttn X. I Ink*
Consumer Education
Program
Objectives for Public Education
Public Service Announcements: Written
and other media
Product Advertising
Point of purchase materials
School programs / ambassador programs
Consumer Label Initiative
Benefit for Industry Partners
team how to provide clear Information
so consumers can make Informed
choices based on their needs and
values, and use chosen products safely
as directed
29
520
-------
consumer Education
Program
Benefits for Industry Partners
Customer Satisfaction
ปmore likely to repeat purchase
ปfewer complaints
Fewer adverse incidents
Promote label improvements
PR/Customer Relation
Consumer Education
Program
Public Education: Industry Roles
Promotion of campaign and use of logo
> in print ads & Web Sites
ป Point of purchase materials: Posters, brochures
ป School programs
ป Ambassador Programs
Consumer Education
Program
What Industry Partners Can Provide
PR/Advertising Expertise
ป parallel to research efforts
Distribution of educational materials
Sponsor Public Service
Announcement^)
521
30
-------
IIP II
STORAGE AND DISPOSAL
PRESENTATION
TO
CLI PARTNER/TASK FORCE MEETING
February 18, 1998
tea of Subgroup Hembtrt
Philip Dickey Washington Toxics Coalition
Rachel Donnette Public Health & Social Svi Dept,
OlympiaWA
Dana Duxbuiy Waste Watch Center
Jim Hanna King Cty, WA: Dept of NaturalResources
Brian Johiuon Environmental Programs Div,
City of Santa Monica
Brigid Klein Chemical Specialty Manufacturers Assoc.
Janet Kreizman Household & Institutional Products
Information Council
John Owens SC Johnson Wax
Lilt of Subgroup Uonbtrt
Richard Pantages Alameda Cty HHW. Alameda CA
Sally Patrick Minnesota Pollution Control Agency
Leigh Scott Triangle I Council of Governments. NC
Marie Steinwachs Outreach & Extension, Univ. Of Missouri
Kathie Tryson United Industries
Jan Wcngler Reckitl & Colman
Leearme Wooden Seattle Public Utilities. HHW Section
EPA Staff Lead
Amy Brecdlove, Office of Pesticide Programs
PROJECT* PHASE 1 HISTORY
Phase I found, among other things:
- consumers aren't reading the storage and disposal instructions
- they are frequently recycling the plastic containers, and
- existing disposal language often conflicts with existing State
or local laws or practices.
Phase I Report suggested a group be formed to examine this issue
and produce a white paper for inclusion in the Phase D Report
PROJECT COAL
Investigate product and container storage and disposal issues to
better understand State. Local, and consumer perceptions and
needs for storage and disposal information on the label. Revise
label language as necessary.
STRATEGY
Form a Subgroup of Partners and Task Force (PTF) members
interested in storage and disposal issues.
Research to determine the status quo regarding state and local
storage and disposal regulations and practices.
Coordinate and meet with CLI Subgroup to determine critical
issues and develop recommendations to address those issues
Meet with CLI Partner/Task Force in Feb 98 to solicit ideas
and get approval for a proposed course of action.
31
522
-------
STRATEGY (eoal'd)
- Hold addition!! meetings, as needed, with Sute/Loeปl
disposal/recycling program representatives and work with
Regions to address issues.
- Have Abt prepare an initial paper summarizing results of the
literature search and NAHMMA survey results for review and
comment. Paper will be published in the Phase H Report.
- Prepare additional papers addressing issues and/or containing
recommendations, including information from the quantitative
survey.
MILESTONES TARCETDATES
Organisational: Jซn-Feb
Form Subgroup of Partners/TF Members
Conference calls/working meetings
Fart-Finding: Feb-Apr
Provide ad hoc input to development
of quantitative research
Research on status quo and other issues
Hold additional meetings with Regional/Sttte/Local program reps
MILESTONES
TARCETDATES
Apr-Jul
Analytic:
Review and analyze quantitative findings
Analyze collected data
Develop and test recommendations
Develop and circulate, for comment, position papere
Documentation:
Develop final Recommendations Paper
Assist in Phase II Report Writing
Jul - Aug
WORT DONE TO DATE
- Attended NAHMMA meeting
' Conference call with members
- Abt completed literature search and initial contact calls
- NAHMMA distributed our questions to NAHMMA members
we received responses in Feb 98
have begun initial analysis of responses
POTENTIAL TOPICS TO ADDRESS AND RESOL VE
1. Understanding the status quo
2. Determining Recycling Policies. Issues, and Practices
3. Address triple rinsing of containers
4. What's our message?
5. How do we refer to the various state/local authorities
POTENTIAL TOPICS (amfd)
6. Should we use a central phone number
7. Are there barriers to remove
8. Cleaners - do they have their own issues
9. Motivation/Behavior Change/Education
32
523
-------
LINKS WITH QUANTITATIVE SURVEY
Phone Survey asks 2 questions on location and cue of finding
informttion
Mail Survey will determine:
- when/where they read this info
where h falls in their hierarchy of importance
preferred location for this info
- whether there's sufficient info, info is confusing, etc.
- whether they prefer FIFRA or non-FIFRA presentation
- in the attitude battery, there are S more questions about
storage and disposal behavior and opinions
TOPIC 1- THE STATUS QUO (eont'i)
- Sanitation laws are arcane and enforced irregularly
- California often interprets HHW more strictly than elsewhere
Local regulations often prohibit what state codes allow
* Majority of programs are "collection days*
- There's a perception that "local laws can't be more strict than
FIFRA" and that this often causes problems for localities
TOPIC 2 - RECYCLING ISSUES (cont'd)
Policies vary by container type, recycling programs, product
uiers
Policies are often vendor specific
- Michigan uses same collection facilities for agric and
households
- More and more places have "rc-use/swap" areas but many tread
lightly regarding pesticides
Some want "oiler for recycling" left on the label
TOPIC I- UNDERSTAND THE STATUS QUO
List all points, decide which are disposal and which are consumer
education issues
- Find out what consumers are storing because they aren't throwing
it away
- Dealing with two categories-cleaners and pesticides-is difficult
- Banned products need to be addressed in any solution
TOPIC 3 - RECYCLING ISSUES
- What's the existing potential for recycling plastic pesticide or
cleaner containers
- What's the existing potential for recycling aerosol pesticide or
cleaner containers
are they realty empty
ปlocal puncturing capability
- If recycling isn't an option, is putting it in the trash an'oplion?
TOPICS- TRIPLE RINSING
Triple rinsing
An agricultural requirement already
Not yet determined by EPA whether it will be a requirement
for households
If required by households
will they actually do it
education issue?
how would we enforce it re: recycling
524
33
ii n ill i ill nil
-------
TOPIC 4 - WHAT SHOULD THE MESSAGE BEf
Whit'i our Message? (for product; for containers)
- Buy the least amount/Use It Up
- Use it Up/Give it away
- Dispose of Properly/Wisely
- Recycle It
- Bring It In (and let the experts worry about itt)
- Save It UP (for the next HHW collection event)
TOPIC 4 - MESSAGE (eatt'i)
.' The more specific, the less the impact (need to test)
. Should be consistent and simple
- Use "manage/dispose" vs recycle
- Don't use "dispose," encourages wrong behavior
- Need to decide on criteria for determining "disposal"
action/rules
- Some programs now use the signal words
TOPIC 5 - DESIGNATION OF AUTHORITIES
Should we refer consumers elsewhere for guidance?
Where do we refer consumers for guidance?
- the product manufacturers
- a central phone number
. avoid appearance of giving people the runaround
What do we call the "appropriate authorities"?
- Hazardous waste and solid waste managed by a very
diverse group of agencies
TOPIC 6 - CENTRAL PHONE NUMBER
- Is use of an 800* a good idea
- can it be sufficiently funded (by whom?)
- is it do-able (from available information standpoint)?
TOPIC 7-BARRIERS
Inconsistent Information/Messages
- Confuses people
- "Wrap in Paper"
Seen as a barrier to proper recycling/disposal
Originally to protect garbagemen from exposure
Can we lay it to rest?
TOPIC 8 - CLEANERS
Seem to be handled differently in some locations
- Should there be different requirements for them
thnn for other pesticides?
34
525
-------
TOPIC t - MOTIVATION/BEHAVIOR CHANGE/EDUCATION
- What'* the lituilion now
- What we step* we can take to improve
- What cut we ailc education group to do for us
Hard to .quantify change
- Movers need good recommendations on what to do with these
products
NAHMMA SURVEY
Sent to over 300 NAHMMA members
- Questions were discussed at NAHMMA meeting in November
- To date, nave received input from 12 organizations
8 State organizations
(Texas. Minnesota Agric and Pollution Control Agencies.
Michigan. Wisconsin. New York. New Mexico. Oregon)
I County organization
(Sonoma, California}
3 City organizations
(Lawrence. Kansas; Indianapolis: Walla Walla, Washington)
SUMMARY OF QUESTIONS AND ANSWERS TO
NAHMMA SURVEY
OVERVIEW
Are there Stale programs for recycling and disposal of 1)
product and containers: 2) for pesticides and cleaners. 3) for
plastics and 4) for aerosols
- Do local programs diverge from Slate requirements
Do the State defer to the localities to develop the programs
Levels of consumer participation/interest in hazardous waste
pickup and/or recycling events
Are there any storage requirements mandated for consumers
SUMMARY OF QUESTIONS AND ANSWERS TO
NAHMMA SURVEY
OVERVIEW (cont't)
A few states have statutes dealing with disposal of wastes, most
didn't; 2 had localities with different requirements than the state
Most of the states defer to the localities to develop programs, but
not the requirements. There was a wide variety of responses on
variation between local and state programs
Recycling was usually voluntary but strongly encouraged, but
pesticides and hard surface cleaners often not specifically
mentioned. Criteria for recycling was market availability for hair
the respondents
I!
SUM MAR Y OF QUESTIONS AND ANSWERS TO
NAHMMA SURVEY
OVERVIEW (cant'd)
Out of 6 respondents, only 1 locality had different recycling
requirements
Most states responded that many of the localities recycled
aerosols, but only one State has a state program for aerosols
All 12 respondents fell citizen response or interest in hazardous
waste pickup is very high Participation in plastics recycling was
higher or mote prevalent than for aerosols.
There arc no specific storage requirements for consumers other
than what's on the label in any state or locality
WHERE DO WE CO NEXT?
Obtain Partner/Task Force okay to continue
Abt finishes their initial research report
- Subgroup members take on specific issues to address
526
35
' ri"
-------
Appendix 7-3:
Highlights from CLI Partners and Task Force Meeting, Ramada Old Town,
Alexandria, VA, Appendix: September 23 and 24,1998
527
-------
-------
Appendix 7-3: Highlights from CLI Partners & Task Force Meeting
Ramada Old Town, Alexandria,VA
September 23 and 24,1998
List of Attendees (alphabetized by company
Susan Altman, Abt Associates Inc. (contractor)
Srabani Roy, Abt Associates Inc. (contractor)
Bob Hamilton, Amway Corporation and Chemical
Specialties Manufacturers Association
Brian Johnson, City of Santa Monica
Mike Hilton, Bayer Corporation
Julie Spagnoli, Bayer Corporation
Terry Bedell, The Clorox Company
Jim McCabe, The Clorox Company
Donna Moramarco, Cornell Cooperative Extension
Brigid Klein, Chemical Specialties Manufacturers
Association
Bob Ochsman, Consumer Product Safety
Commission
Janice Frankle, Federal Trade Commission
Janet Kreizman, Household and Institutional
Products Information Council
Jim Hanna, King County (Washington State) Dept. of
Natural Resources
Sally Patrick, Minnesota Pollution Control Agency
Dennis Ward, Monsanto Company
Jan Newman, The Newman Group, Inc. (contractor)
Gary Shiffiliti, Olin Corp.
Maureen Howard, Procter & Gamble
Karen Smith, Procter & Gamble
Joey Richardson, PROSAR International Poison
Control Center
name):
Ellen Brown, Reckett & Colman
Steve Rosenberg, Reckitt & Colman
Jan Wengler, Reckitt & Colman
Allen James, RISE (Responsible Industry for a
Sound Environment)
John Boomsma, S.C. Johnson and Son, Inc.
Chip Brewer, S.C. Johnson and Son, Inc.
Stuart McArthur, S.C. Johnson and Son, Inc.
John Owens, S.C. Johnson and Son, Inc.
Paula Bodey, The Scotts Company
Greg Keferl, The Scotts Company
Jim Larkin, The Scotts Company
Kathie Tryson, United Industries Corp
Arthur Getz, World Resources Institute
Linda Arrington, U.S. EPA
Amy Breedlove, U.S. EPA
Nicole Christian, U.S. EPA
Christine Cinalli, U.S. EPA
Mary Dominiak, U.S. EPA
Mark Dow, U.S. EPA
Jim Downing, U.S. EPA
Jean Frane, U.S. EPA
Deborah Hartman, U.S. EPA
Karen Lannon, U.S. EPA
John Shoaff, U.S. EPA
Annette Washington, U.S. EPA
Julie Winters, U.S. EPA (moderator)
Introduction
Julie Winters of the U.S. EPA's Office of Pollution Prevention and Toxics moderated the meeting. She
began with brief introductory remarks, thanking all participants for their high level of commitment and
participation, and stressing that the project could not have achieved what it has without them. She
summarized the goals of the meeting as follows:
Present highlights of Phase II research and other work, and ensure understanding of participants.
Develop possible recommendations and action steps arising out of Phase II work.
Make policy recommendations when possible and appropriate.
Recommend label changes and tradeoffs in going forward.
Recommend further research when necessary (with estimation of tradeoffs).
I.
2.
3.
4.
5.
Julie Winters thanked all the participants for their hard work and commitment to the CLI. She noted that
many CLI participants representing many different interests served on multiple subgroups and
provided important continuity and balance. Due to their efforts, approximately 100-200 product labels
have changed since September 1997, and a First Aid Pesticide Registration (PR) notice announcing
recommended changes in this section of product labels is in process currently. Also, several different CLI
Updates have been posted on the CLI website and sent to about 1200 recipients, who have sent them on
to many others, so the outreach of the project has been substantial.
529
-------
Highlights of each presentation are provided below, and appendices include the full written presentations
that participants received at the meeting.
ItJ! , .if . i. I1, ', ill ' ' . i . ":. ' 1 - .' " . ' 'i. -: ' ' '[ ' ' ' ; '<
Quantitative Research Highlights
Presenters: Maureen Howard, Bob Hamilton, Mike Hilton
This research was performed to obtain quantitative, verifiable, statistically valid information about
consumers' attitudes, preferences, and behaviors regarding the labels on three categories of products:
hard-surface cleaning products, indoor insecticides, and outdoor pesticides. The Quantitative Research
research, which was funded through RISE (Responsible Industry for a Sound Environment) The
Quantitative Research subgroup designed the research; located and worked with a contractor to perform
the research; created mock-labels; sought input constantly from Partners, other subgroups, and
stakeholders; fielded (administered) the surveys; and exhaustively compiled and analyzed the data.
A total of about 850 surveys in each product category were completed and analyzed during Spring and
Summer 1997. The research addressed the following areas: how easily consumers can locate information
on labels, why they read labels, their understanding of storage and disposal information, their
comprehension of signal words and ingredient information, their preferences for label language and text
formats, and the sources they use to obtain more information about these products. Results for each
section are highlighted below, and discussion questions/issues brought up by participants at the meeting
follow the highlights for each research topic.
i
Overall, most consumers expressed satisfaction with current labels (more than 60% were extremely or
Very satisfied). Only about 4% expressed being not at all or not very satisfied. However, when presented
with specific options for possible changes to labels, most consumers indicated that some positive changes
could be made to labels.
Each section is numbered for ease of reference. The sections were not presented in this order. (The
agenda reflects the order of presentation of information.)
II'"': i '! ,ปซPiL:90% of time) could correctly find sections on labels, and they appeared to
comprehend the information in answers to open-ended questions.
* Information generally was where consumers expected it to be, for all three product categories.
However, information on where NOT to use product was hard to find, as were a few other types
of information.
These results imply that certain sections of labels can and should be improved so that consumers
pan fjpd the information they need more easily and quickly.
CONSUMERS READ LABELS:
Most consumers who read labels in the store prior to purchase looked for brand, directions for
use, product function, where not to use the product, and health precautions.
Outdoor pesticide labels were read most often, followed by indoor insecticides, and last by
cleaners. This may imply that consumers do not use outdoor pesticides as often and so do not
assume they know the information on the label, whereas they use cleaners the most often and
may assume they know the label information.
Consumers stated that the most important information on labels includes directions for use,
product function, where not to use the product, and health precautions, arid first aid information.
Consumers responded that environmental (positive) claims, manufacturer's name, disposal and
storage information, ingredients, phone number, and environmental effects are the least
530
-------
important items on labels.
Discussion/Implications:
Stakeholders pointed out that it is important to distinguish between what people SAY they do
(regarding label-reading behavior) and what they actually do. Outcomes between attitudinal
surveys and behavior are often quite different.
A stakeholder mentioned that the surveys did not ask whether the label is the right place to put
environmental information; maybe this issue should be investigated.
3. STORAGE & DISPOSAL (S&D):
Storage & disposal information was less important to cleaner users than to outdoor pesticide
users. Consumers responded that they already know this information or "just do not read it."
Most consumers did not understand what the HOPE icon on certain product labels indicates.
(This icon specifies only that the container contains high-density polyethylene, but consumers
may assume that this icon indicates that they can recycle the container. Recyclabi.lity, however,
depends upon the regulations and practices of the specific locality, as well as upon the content of
the container.)
Most consumers disposed of pesticide and cleaner product packages in trash (although the survey
did not ask consumers whether the containers were completely empty at time of disposal). Few
consumers indicated that they disposed of products down the drain or diluted and used them up,
but cleaning products users did state that they found it acceptable to put these products/residues
down the drain.
Consumers recycled cleaning product containers more frequently than indoor insecticides or
outdoor pesticides.
More consumers (but <10% of respondents overall) disposed of outdoor pesticide containers (not
specified whether completely empty) through special collections.
Virtually no consumers called for advice most.containers say to wrap in paper and throw in
trash, and apparently most consumers do this.
Discussion/Implications:
One stakeholder pointed out that calling for advice is a learned behavior requiring outreach.
Stakeholders agreed that S&D is a low priority for consumers and will not be important to them
without extra work. A stakeholder noted that consumers equate recycling with being "an
environmentalist." This perception needs to be adjusted so that consumers do the right things, not
just think they do. Another stakeholder commented that consumers' perception is their reality,
and that this must be addressed when educating them.
Stakeholders discussed that consumers are probably misreading other icons as well as HOPE. A
lot of S&D questions depend on who you are and where you live as to whether the answer is
right or wrong. It is very hard to interpret the survey responses correctly or draw implications
from them. However, some stakeholders felt that the right answer was not listed in the surveys,
which may have affected the responses.
4. SIGNAL WORDS:
Consumers appeared to understand the hierarchy of signal words independent of product labels
(danger = most acute toxicity, warning = middle, caution = least toxicity). However, this did not
translate to understanding the hierarchy in the context of the label. Consumers thought the signal
word chosen for the label was at the discretion of the manufacturer and interchangeable with
other similar words.
Consumers did understand, however, that all three words convey some level of concern, and the
use of a statement referring readers to the back label for more information did get many
531
-------
consumers to turn to the back of the label.
No consumers used signal words to find out what harmful effects are associated with products.
Discussion/Implications:
Stakeholders discussed that if the purpose of signal words is to convey the need to read the
precautions, signal words may be doing enough. If the intention is to convey the hierarchy, more
education/different approach is needed.
5. INGREDIENTS:
About 90% of consumers found ingredient information on labels where they expected it to be.
Non-FIFRA cleaner label ingredients information is often on the back label, and cleaner users
found. th.i.s.information.harder to locate. Most consumers still found it, however.
A Many consumers said they do not read ingredients because they do not understand them.
ฐy About 40% of consumers stated that they look for ingredient information. Those who looked did
so for product comparison or personal health reasons. Only 3% of consumers asked for
"complete" listing of ingredients (although exactly what this meant was not specified).
When given choice of format and content, 75% of all consumers surveyed chose an option other
than "full disclosure". Stating categories of ingredients and the purpose of the category [e.g.,
''surfactants (cleaning agents)"] was preferred by the most consumers.
s Environmental claims (e.g., no phosphates) usually are not read.
Consumers stated that putting ingredient information- in tabular form on the front label made it
easiest to find and read. This allowed consumers to use the information for product comparison.
,;, , '.':.' :' ,;"' ! , : ; :: : '; j , .
Discussion/Implications:
Stakeholders noted that consumers perceive cleaners differently than pesticides.
' Several stakeholders pointed out that full disclosure of all ingredients is not needed to satisfy
mosfconsumers. '''.', " , ' ,' ',., ^' '.,,'"'"' 1 ป,' '..'"', '. "'. '' . . . .
The fact that; some consumers read ingredients for personal health reasons may imply that they
are using this to find information about product hazards, which is not preferred.
6. FORMATS/LANGUAGE PREFERENCES:
In tests of alternate wording, people preferred specific, simple language, and wanted to know
why they were being told to do something. These findings seemed consistent across all product
' - categories. '" ' . :
Consumers liked the use of boxes to make information stand out.
Over half of the cleaner category respondents preferred the FlFRA label, although that label
looks harder to read.
Discussion/Implications:
Revised (simpler and more specific) language would increase comprehension. Software tools
exist to help manufacturers determine appropriate reading levels.
Standardized formats may help consumers to read and understand labels.
Stakeholders discussed that FIFRA label provides more information; maybe that is why
consumers preferred it. Consumers also want specific information, especially about ingredients,
where FIFRA label scored highest.
"' A few stakeholders requested flexibility for manufacturers not having to test everything, being
able to use common sense in writing label language, etc.
I'"''1' ' ' 'jiV. > '; .' ' i ' , ., ' '. :,:./,
7.
INFORMATION SOURCES:
Consumers look to sources that are "right at hand" for information about these products.
I'
532
-------
including store displays, TV ads, friends/family/co-workers, product brochures, and magazine
ads.
About 20% of consumers stated that they do contact a university or county extension service for
product information.
Discussion/Implications:
Stakeholders noted that some tools that have been used to educate consumers (e.g., Internet) are
not reaching enough of them.
Stakeholders discussed the possible need for more consumer education about
availability/expertise of extension agents, and education of extension agents about actively doing
outreach to consumers rather than waiting for consumers to just come to them. It was suggested
that CLI involve organizations that have experience working with extensions (e.g., Soap &
Detergent Association) to try to reach out to consumers.
One stakeholder mentioned that it would be valuable for CLI to form alliances with the Ad
Council and other organizations that have links to consumers and can help educate them.
Qualitative Research
Presenter: Jan Newman
Qualitative research (consisting of 27 small focus groups) complemented the quantitative research. (The
EPA funded this research.) The Qualitative Research Subgroup chose The Newman Group to design and
run the focus groups. The subgroup designed the research; helped The Newman Group get up to speed on
the quantitative research; communicated with other stakeholders about the research; participated in the
research design process; and helped to analyze the findings.
Virtually all consumers said they read something on a label, though sometimes not on cleaners or
on a regular basis: Labels for products that people perceive "kill something alive" are read more.
Consumers said that they read labels mainly to find directions for use, product function, health,
safety, and ingredients.
When asked what might happen if they do not read labels, consumers mentioned safety concerns,
use of the wrong product, misuse of the product, not knowing when to use the product, damage to
possessions, improper disposal, and a few other concerns.
All focus group participants had trouble with the signal word concept of a hierarchy of acute
toxicity concerns. Some consumers tended to reject the concept, although others wanted to know
more about it once they understood. Some focus group participants said that "Danger" should be
on all labels because this is "strongest." Others said they would not buy a product that said
"Danger."
Consumers stated that they prefer simple, specific, direct information that explains why they
should do what the label says without talking down to them.
Consumers preferred the use of bullets, no wrapping, use of numbers for sequenced directions,
simple language, more white space, boxes for highlighting important information, 800 number
for emergencies, highlighted headings, larger font, color for caution hierarchy.
Consumers stated that improved formats might encourage them to read labels more often,
provide quicker access to information, make it easier to re-find information, and improve the
public image of manufacturers (by making them appear more honest with consumers).
Consumers were shown six logo designs for the CLI "Read the Label FIRST" Campaign, and
asked for their opinions. They preferred the stop sign shape because it was associated with "stop
sign meaning." Most felt that these logo designs did not link to the reasons consumers would
read labels (e.g., safety).
533
-------
Discussion:
, , , , , , ,, , , ,, , II ,
Stakeholders noted that a lot more work needs to be done to get consumers to understand the
signal word concept.
* Stakeholders expressed concern that consumers who learn about the hierarchy may just buy
products with a signal word that sounds less toxic, rather than doing any other work (e.g., reading
labels)
ป Some stakeholders expressed concern that developing a graphic representation of signal words
(e.g., a meter indicating level of toxicity) could just confuse people further.
* It was pointed out that many label changes can be made without any regulatory changes.
It was noted that any label change must be coupled with education, to teach consumers how to
view it.
Qualitative and Quantitative Research Conclusions .'. .. ..
Following the qualitative and quantitative presentations, the meeting participants discussed the overall
highlights of the findings, which included the following:
* There does not appear to be a single strong consumer motivator for change in labels.
Whe,n given options for changes, consumers agreed that language and format of labels could be
improved to make them more simple, specific, and provide a rationale.
j for ฐptr?lfnป '*.is Importantto use m?dia tnat consumerง dp not have to work hard to access (TV,
store displays, etc.) Also, other "influences" (e.g., cooperative extension contacts) may be
appropriate and should be given information about labels to share with consumers who contact
them.
* ^s'n| m8fec*'ent categories to communicate more information may be appropriate, as well as
possibly keeping ingredients on the front panel.
I, I" ' , ii'llli tili'iiii I ' '.'' I1 : ' ' ! ' ' , , 'j'1/ ':;i I '' i
Storage and Disposal Presentation
Presenters: Amy Breedlove, Jim Hanna, John Owens, Kathie Tryson
Presenters reviewed all work done to present by this CLI subgroup, and then highlighted certain results
|>f the research. They noted that most consumers surveyed do not read S&D information. Subgroup
members agreed on the following:
ซ revised wording of disposal instructions for empty containers.
there is no need to change storage instructions.
* there is no need to require rinsing of empty containers.
V recycling should be encouraged.
? evalugtipj/educatjpn about material identification symbols should be recommended.
ป disposal data should be forwarded to NAHMMA.
other follow-on work is recommended for this committee.
adding a central 800 number would be ineffective at this time.
Other issues were also mentioned:
There was substantial subgroup disagreement on instructions for partially filled containers. Some
subgroup members presented information that label language on S&D ("throw in trash") is illegal
in many localities and causes trouble for many Household Hazardous Waste (HHW)
management organizations. This may lead to state efforts to change laws. Other members
disagree with this assessment.
One subgroup member, speaking for cleaners and indoor insecticides only, added that there is no
room for more S&D text on labels, and most consumers do not read it anyway. This person also
felt that some HHW programs communicate misinformation and mischaracterize products as
HHW when they may not be, and that HHW programs can be a very expensive method of
534
-------
disposal.
Another subgroup member noted that the number of consumers using a HHW center does not
convey information about the need for the facility (e.g., if 4% use the facility but only 4% have
items for the facility, that constitutes 100% use).
Another subgroup member, speaking for outdoor pesticides only, mentioned a few misstatements
on the Outdoor Pesticide Industry slide: (1) The products are "different" in that they are all
consumer products, regulated under same set of regulations. There IS a great diversity of
products, however. (2) No one thinks these products should be disposed of down the drain. (3)
Manufacturers do not think outdoor pesticides are HHW (e.g., a product that is 99.9% water).
Discussion:
One stakeholder wanted to know where individuals who work for HHW centers and agencies that
provide HHW information get information about products to decide if they are HHW. Another
stakeholder responded that this information is often conveyed through a variety of intensive
training options.
Another stakeholder said that there is no national guidance about what is HHW, so many
agencies decide that all pesticides are HHW, whereas manufacturers do not agree with this
assessment.
Consumer Education
Presenter: Mary Dominiak (EPA)
This session provided an overview of the "Read the Label FIRST!" campaign development and materials.
The current focus includes developing an initial message, four draft brochures that will go out to
everyone for information; identifying venues for distribution and possible spokesperson, and a logo
design. Mary Dominiak stated that exposure to the logo over time will cause people to associate values,
etc. with the logo, and that because of this she was not surprised that focus group participants did not feel
strongly about any logo.
She also asked about policy issues regarding education: Should CLI educate consumers about signal
words, ingredients, disinfection? She discussed next steps: selecting a logo, colors, finalizing brochures,
making materials available to all, targeting placement venues, developing print and TV PSAs, deciding
about a national campaign spokesperson. She asked participants to provide examples of successful
consumer education campaigns.
Discussion:
A stakeholder suggested looking for advertising agencies that specialize in consumer outreach,
especially about environmental issues.
A stakeholder mentioned the "Stop, Drop, and Roll" campaign for how to respond to fires.
One stakeholder expressed concern over the speed and scope of campaign, suggesting that the
subgroup slow down and re-examine the logo in particular for its appropriateness to
manufacturers.
Day 2 Discussions:
On the second day of the meeting, participants developed potential recommendations and discussed them
as a group. Those that participants could agree on were adopted as CLI Recommendations to be
presented to the EPA and considered by the Agency for possible adoption. (See Appendix for
Recommendations.)
535
-------
Ingredients:
T^'s^ssion focused pn introducing flexibility into labeling requirements for ingredients.
(FI|RA regulations take an "all or nothing" approach to listing ingredients.)
? One stakeholder suggested keeping trade secret considerations in mind when addressing what
and how to disclose ingredients information on labels.
Onฎ stakeholder asked what benefits consumers would receive from more or different disclosure
of ingredients, especially in the area of medical needs.
One, stak?holder asked what full disclosure means, A very small percentage (3%) of consumers
in the quantitative research asked for "full disclosure" (although what this means was not
specified in open-ended research questions). Most consumers, however, when asked, reacted
Pos'tively to a different type of disclosure than on FIFRA productsespecially to some version
of ingredients by category, along with a purpose statement for each.
Signal Words and Hazard Hierarchy:
Stakeholders discussed whether consumers need to understand the hierarchy. The EPA needs to
think about what the Aงency wants to accomplish with signal words. Is the purpose to make
PfฐPle use products with care? If so, status quo probably okay. If EPA wants to establish a
hieEarchy in PeฐPle's minds> an education program is needed. Rethinking the entire signal word
concept is very unlikely.
It was suggested that a signal word be highlighted on products, and that other means be used to
educate consumers about the hierarchy.
!t waf mlntioned that a r'5k assessment concept for hierarchy would require much additional
research.
One person asked about including some form of graphical representation/icon on product labels
Other stakeholders responded that they do not have enough information yet. Adding a signal
word "mgter" would just confuse people.
* The concern about possible impact of word changes on consumers was mentioned if labels
create fright, is that wanted?
A suggestion was made to include the signal word plus bulleted information that explains why
(e.g? eye irritant), with a fuller explanation on back, or repeating the SAME information about
siSnal words on back as well as front. If the EPA wants to push education on hierarchy, CLI can
exPjore researcn about impacts of various changes on consumers. One participant asked if
spotting information between front and back would help or hurt. If this is done, folks may not
look at back label. Research is needed to find out hp,w to get people to look at back.
Add>ng more information below signal word on front panel would crowd the front so flexibility
would be helpful.
> Participants discussed whether the education subgroup should do consumer education associating
signa! word with health concerns. The discussion included the following: What about
distinguishing between category 3 and 4 products? Delete signal word on category 4 products?
The signal words are regulatory, not statutory, so they could be changed. The EPA could
consider how it designates category 3 and 4 products. There is a reason why category 4 products
do n;ฐt m?ntiฐn a route of exposure. To make up something that says nothing does not serve
consumers.
'ip.ii i '' ' iivllli IE, in1!, If 111 I ' . i ,,,! : "1! ' I , ' " ' ,:,;'.' " ", t .'" , ' " ,i ' J' I " ,,,||,!"" !,' :''',', , '' ! I' I '
One stakeholder expressed concern that some participants appear to want to block consumers'
understanding of product labels.
Storage and Disposal:
I This subgroup was unable to reach consensus about one direction in which future action should
be taken. One label recommendation was accepted.
* Ptnel recommendations centered on needs for future research and communication with
536
>;:: 11;; i,,, <
-------
appropriate organizations about possible steps they might wish to take.
The EPA will consider making a policy decision about how to handle partially filled containers.
Format/Language:
FIFRA regulates some "format" issues, but flexibility exists.
Consumers like standardized formats, and consistent order of elements might help them find
product description, use, and safety information more easily. Regulations do not require certain
order; might be helpful to develop standard order of elements and get consumer feedback. Does
consumer research imply a preferred order?
Putting first aid section in box would help consumers find it easily. If including 800 number for
emergency/safety information, could it be put in first aid section?
FIFRA regulations specify minimum of 6 points type. Should that be increased? Size
perception/legibility involves more than size, depends significantly upon typeface. Could labels
be evaluated for readability issues?
Tell consumers that is acceptable to open booklets in store and read label.
Graphic icons: More research is needed. Companies would like icons for some things but this can
be too much. Adding icons would involve exhaustive testing with consumers. Icon research issue
was tabled. (This does not imply that icons cannot be used.)
Use of consumer-preferred formats (e.g., bullets, more white space, no text wraps) would require
reducing words by 30-40% to fit on available label space. This will require very careful work. It
will be hard to bullet long precautionary statements. Improving labels will require "give and
take."
Some statements that consumers reviewed as alternatives to current label language violate FIFRA
regulations (e.g., "Use safely") and need to be adopted as appropriate rather than fully. The
EPA's upper management will work to ensure that manufacturers will be able to implement
preference statements as much as possible.
The EPA should work on ways to simplify precautionary statements overall, and get feedback
from other agencies that have contributed complexity to precautionary statements; remove
language not appropriate to consumers from precautionary statements.
Participants agreed to replace the "violation of federal law" statement with different wording.
Consumer Education:
Two logo concepts were discussed, which represented the "finalists" after several months of logo
development and testing, including discussion of 6 different concepts with the focus groups. The CLI
meeting talked about the concept, intent, and scope of the logo; whether the logo concepts presented are
ready for use; possible testing of messages and logo concepts; creating alliances with organizations that
could help publicize the education campaign; and differences between education and advertising. Some
highlights of the discussion were:
The logo is intended to appear in a variety of places, such as product stickers or a part of a label,
as well as in brochures, posters, PSAs, and other venues not associated with labels directly.
Several people thought the current logo concepts are not appropriate to the needs of product
manufacturers. A few felt the logo concept should create more positive response by consumers.
Others said that the logo should not be expected to excite consumers at this point, that
developing associations with the logo is the purpose of the educational campaign, and that
positive associations will be built up over time.
One stakeholder suggested that the concepts of the campaign should be solidly in place before
the logo is designed.
Some stakeholders wanted all messages, graphics, and concepts to undergo more or less
extensive market-testing before use.
Some stakeholders felt that consumer label educational materials should meet the same criteria as
537
-------
|; i, 'M ;:!! , . , , . , i .. ,: Ih , , .: ,. .-,
profe5SIOnal advertisinS' whereas others felt that education has different goals and that some
subSฃฐuP participants have substantial experience doing consumer education.
O"estakeholder suggested using alliances to ensure CLI works with people that will be expected
to implement the campaign. Rely on compelling motivations of consumers to get them to accept
the messageit will not happen unless consumers want it.
One stakeholder suggested involving corporate communications professionals in the subgroup
work and campaign.
The group was unable to clarify whether the logo concept will be reconsidered from scratch, and
the issue qf proceeding with the logo concept was deferred for future consideration.
Attachment:
Approved Recommendations from Partners and Task Force Members, Note: For all Recommendations,
WOW-smithing will be done later by subcommittee or a drafting committee (to be set up).
ซj ' - \. ] I;* i'Vil : '. ' i ii' '. '. , ; : . . ' : . : I' '' , ;i- I:,' '' : :'", .'.;
Background Documents (available upon request):
1,
2.
3.
4.
5>
g:
7.
8.
ii
Meeting Agenda
Quantitative Research Learning Questions
Qualitative Research Learning Questions
Quantitative Research Presentation (copy of slides)
Qualitative Research Presentation (copy of slides)
Draft CLI Quantitative Preliminary Findings, Implications, and Conclusions
Consumer Education Program (copy of slides)
Storage and Disposal Presentation (copy of slides)
Two designs for a "Read the Label FIRST!" logo
-------
Appendix 7-4:
Summary of the Partners and Task Force Meeting, April 7-8,1999, Alexandria, VA
539
-------
-------
Appendix 7-4: Consumer Labeling Initiative
Summary of the Partners and Task Force Meeting
April 7-8,1999, Alexandria, VA
Immediate Action Items
Revise and distribute final approved text of fliers/brochures (completed; attached).
ConEd conference call to decide how the logo design will be produced: April 22, 1999,
3:00-5:00pm EST (Call-in number 202 260-8330; Access code 7890 followed by the pound #
sign).
Meeting Conclusions
The main points raised by the Partners and Task Force (P&TF) members regarding each of the topics
discussed at the meeting are presented below. The meeting presentations and P&TF discussions are
summarized in the sections that follow these meeting conclusions.
PHASE II REPORT
The Partners and Task Force strongly stated the importance of EPA quickly completing the
Phase II report.
P&TF decided against preliminarily displaying the Phase II results on the CLI web site.
MEDIA EVENT
The presenter of the CLI media message should be chosen based on the content of the media
message.
The media message should accomplish the following goals: consumer awareness, promotion of
CLI (e.g. What is the partnership and what is it doing?), promotion of the "Read the Label First!"
campaign, and promotion of future label changes.
Messages for the media event were revised;
OPP IMPLEMENTATION OF LABEL CHANGES
Suggestions were made to designate a pilot project, in the spirit of reinvention, in which a single
or a couple of product managers handle the proposed label changes submitted as a result of the
CLI Phase I and II changes.
It was requested that the issue of ingredient placement be currently considered as a label change
requiring discussion with a Project Manager (instead of a change that cannot be made at this
time).
CONSUMER EDUCATION MESSAGE
The message content of the brochures/fliers was finalized and agreed upon by the P&TF.
It was decided that the only information that can be added into the brochures/fliers is local
contact information and "distributed by" information.
Stakeholders requested confirmation that they will be able to add their logos onto the
brochures/fliers.
EPA will look into the issue of listing the EPA logo alongside brand-identifying information on
the brochures/fliers.
Disposal instructions have been removed from the outreach brochures/fliers until the storage and
541
-------
MESS;
LOGO
Isposal issue is resolved, with the exception that the gardeners brochure will specify that lawn
id garden products should never be poured down the drain.
[hen the "Read the Label FJKST!" logo is ready, it will then be added to the brochures
hE PLACEMENT
bre was general agreement to use a public relations firm (possibly doing pro bono work from a
F members' company) to help design the placement strategy.
placement work will still be done by EPA resources with assistance from the P&TF.
rketing people from the P&TF volunteered their expertise to help with placement activities.
decision on how to create a logo design will be made during the next consumer education
Inference call on April 22, 1999, 3:00 - 5:00pm EST (Call-in number - 202 260-8330 Access
Ide - 7890 followed by the pound # sign).
In8 County> WA Department of Natural Resources will explore using $5,000 - 6,000 of its
prketing contract to assist with logo design.
pwever the logo designs are achieved, the ConEd group will present the top options to the
Itire P&TF for a vote, and the majority winner will be adopted by everyone as the RtLF! logo.
Partner
Jennifer
:Bob Hire
Julie Spa
Tim Man
Laurie Fl
John Altc
Amy B
Nicole Cl
|jm Dowi
and Task Force Members in Attendance
.ndrews Abt Associates Inc. Annette Washington
(contractor)
Iton
noli
ichen
nagan
dlove
ristian
ing
Mary Doi u'niak
Jean Fran?
Michael Glikes
Amway Corporation
Bayer Corporation
Bayer-Pursell LLC
D.C. Legislative &
Regulatory Services
(for Scotts & Pursell)
U.S. Environmental
Protection Agency
(EPA)
EPA
EPA
EPA
EPA
EPA
EPA
Deborah Hartman EPA
Judy Nelson EPA
Julie Winters EPA
Topics Covered
Introductions
Pliase II Report
Update of CLI Activities
Media Event
OPP Implementation of Label Changes
Storage and Disposal
Proposed Ingredients Activities
Colleen Tressler
Janice Podell Frankle
Janet Kreizman
Jim Hanna
Dennis Ward
Joey Richardson
Maureen Howard
Sandy Simon
Heidi Carter
Janet Wengler
Elizabeth Lawder
[ ! ,::
Stuart McArthur
Therese Adkins
Kathie Tryson
EPA
Federal Trade Commission
Federal Trade Commission
Household & Institutional
Products Information Council
King County, WA
Monsanto
National Poison Control Center
Procter and Gamble
Pursell Industries
Pursell Industries
Reckitt and Coleman
Responsible Industry for a Sound
Environment
S.C. Johnson and Son, Inc.
The Clorox Company
United Industries
542
-------
Consumer Education
- Message Development
- Message Placement
- Logo Design
INTRODUCTIONS
Julie Winters (EPA) welcomed the Partners and Task Force (P&TF) to the meeting. Each of the
meeting participants introduced themselves and summarized their involvement with the CL1.
PHASE II REPORT
Julie Winters updated the P&TF on the status of the CLI Phase II Report. The report has been delayed
due to funding problems within the Agency. A copy of the report out-line was handed out at the meeting.
Most of the report has been written, but there is still a lot of work left to do. The contractor writing the
report (Abt Associates) has estimated that it will take two months from when the funding is approved to
when the report is ready for distribution.
Some of the characteristics of the report were explained. For example, it will be written to tell the story
of Phase II of the CLI. The raw data collected during Phase II will be available in the administrative
record and will not be in the report itself. The EPA recommendations to be mentioned in the report will
include the recommendations made up to the point of when the report is finalized.
Discussion
The Partners and Task Force strongly stated the importance of EPA quickly completing the
Phase II report.
It was suggested that the Phase II report should include as much as possible.
The possibility of preliminarily displaying some of the findings from the Phase II research on the
CLI EPA web site, while the Phase II report is being completed, was raised for discussion.
However, Stakeholders thought that the findings will not make sense if they are offered alone
without any larger context and they may create more questions than answers. Stakeholders
suggested that it would be better to expend energy and resources on finishing and distributing the
report than on displaying it on the web prematurely.
UPDATE ON CLI ACTIVITIES
Julie Winters updated the P&TF members on activities that took place after the last P&TF meeting in
September, 1998.
In early February, Mike Hilton (Bayer Corporation) and Bob Hamilton (Amway Corporation)
presented CLI findings at an EPA meeting. Susan Wayland and Marcia Mulkey, as well as over
100 people, attended. EPA employees in attendance v/ere generally receptive to the CLI
recommendations presented.
MEDIA EVENT . ,
Amy Breedlove (EPA) and John Alter (EPA) updated the P&TF on options for the upcoming CLI media
event. (See the attached slides to view the presentation on the media event.)
The idea for the media event came out of a meeting that the EPA CLI Team had with Marcia Mulkey
(EPA) and others, in which Amy was instructed to prepare a paper outlining potential options for a CLI
media event. The timing goal is June 1999 and depends on the interest and availability of the proposed
543
-------
presenters. Separate options for the event are being proposed for consideration by Vice President Al
Pore' Carol Browner (EPA) and Susan Wayiand (EPA). EPA staff, P&TF and Stakeholders will also be
included. Depending on the presenter, potential event locations include the White House Rose Garden,
Arboretum, Observatory, National Press Building, a major Hardware Store, and the EPA. The media
event will be the kick-off of the CLI consumer education campaign. The target audience of the media
event isthe:^n?ral Public> the trade press, community newspapers, and lifestyle magazines. The internal
EPA suggestion for major publicity about the CLI (e.g. Al Gore as a potential presenter) indicates strong
internal EPA support for CLI.
I'L.i-i : . ' I I I) is ,1, }| i. . : . i , ". ;.ป, . .
During the P&TF meeting, the EPA hoped to develop agreed-upon messages for the media event,
determine P&TF and Stakeholder level of interest in participating in the event, and determine P&TF
willingness to provide "before and after" mockups of the label changes (if these visual aids were deemed
necessary).
Discussion
Stakeholders provided the following comments on varying aspects of the media event.
Goals of the Media Event
The P&TF decided to clarify common goals that the media event should accomplish. Goals suggested bv
the P&TF included the following:
Maintaining EPA and manufacturer credibility.
Gaining continued support for the CLI.
? Letting the world know what the CLI has accomplished.
Informing the public that labels are changing and what to expect.
* Promot'ng the consumer education campaign, including the potential "Read the Label First!"
logo competition.
Prom,ot!nS consumer awareness of the importance of reading label information and using
products correctly.
Making consumers aware that industry and government are working together to improve labels
for the public.
The P&TF agreed together that the media message-should accomplish the following goals:
!;. " 1,. Consumer awareness. , . .. . ,
2. Promotion of CLI ( What is the Partnership? What is it doing?).
3. Promotion of the "Read the Label First!" campaign.
4. P|omo|ion of future label changes.
\jPotential Presenters
* The following additional people were suggested as potential presenters of the media message:
Hi!ajy 91!nton' Martha Stewart, Oprah Winfry, Barney, Ron Hazelton, Tom Bosley, and Wilford
Brimly.
Th? media event presenter should be chosen based on the content of the media message. For
SXaQjjple, if the media message focuses on consumer safety, it makes sense to have a
spokesperson who is associated with consumer safety issues.
The large retail chain, Walmart, was brought up as a potential location for the media event.
Timing of the Event
The message of the media event might not be as effective if the event takes place before the
Pr9^H,ct?,,^''^ .labels reflecting CLI label- changes are on the shelves. It was suggested that there
be another media event once label changes had been implemented on products. Also, it was
suggested that the media event take place sooner rather than later, keeping in mind the
availability of the proposed presenters.
f Concern was expressed at the short amount of time between now and the proposed June date.
m
! .!":!!;
544
! I
-------
The development of the "Read the Label First!" logo was discussed as a variable affecting the
timing of the event. The importance of linking the logo with the media event was cited as a
reason for staging the media event after the logo is developed.
Stakeholder Participation
P&TF members agreed that while they will likely participate in the media event, their level of
interest will depend on who the speaker is.
Messages for the Media Event
The P&TF discussed potential messages to be conveyed at the proposed media event. Stakeholder
comments, listed below, refer to the draft, written by Amy Breedlove, that was handed out to meeting
participants.
.Messages should be tailored to the presenter of the message (e.g. if VP Al Gore, then focus on
government reinvention).
Message 1: Voluntary partnership/reinvention/making information available - This message
should highlight the point that government and industry are listening to consumers and making
changes.
. Message 2: Importance of labels - This message should focus less on the reasons current labels
are confusing and more on the information on labels that is important. As it is written, message
two is more a statement of the need for label change than of label importance.
Message 3: Consumer education campaign - This message should not focus on the specific
introduction of a logo, since a logo by itself is not a newsworthy event, but should be written
more broadly to inform the public about the nationwide campaign.
, Message 4: Label change recommendations - This message should not contain detailed
information on the label changes, but instead state that labels have been simplified. A separate
document chronicling the exact nature of the label changes could be developed- for people who
want more detailed information.
Message 5: Implementation process for label changes - Although questions arose regarding the
importance of this message, it was noted that this message was necessary to inform the public
that the CLI is continuing.
. Message 6: Phase II report - It was suggested that the information about the Phase II report be
combined with message one (government reinvention process). Additionally, there was
discussion on whether or not the resources used during Phase II should be quantified (e.g. money
spent, hours spent, number of people interviewed).
Combine messages four and five.
Other important highlights to capture in the media message include: the difference in the old and
new first aid statements, chemical name changes, and format changes. The media message
should also state that the same information will be presented on the new labels, although it will
appear in a different form.
One Stakeholder stated discomfort with the content of the messages since they have not yet been
worked on by the consumer education sub-group.
Amy Breedlove will re-write the media messages, taking the Stakeholder comments into
account, and distribute them to the P&TF.
OPP IMPLEMENTATION OF CLI LABEL RECOMMENDATIONS
Jean Frane, of the Office of Pesticide Programs (OPP) at EPA, presented the EPA's plan for
implementing CLI recommendations and led a discussion on this issue. (To view her presentation, see
attached slides.)
OPP will circulate an internal guidance memo to forewarn EPA product managers about the type
of paperwork to expect coming from companies making the label changes recommended by the
CLI. The memo will cover label changes that can be approved now, changes that will be
545
-------
considered on a case-by-case basis, and changes that will not be considered at present. While the
memo is intended as internal correspondence, it will be available to P&TF members who wish to
see it, after it is circulated.
* Tke 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 by April 30, 1999.
PR Notices for all recommendation topics will be issued after the guidance memo, in May/June
1999. Some PR Notices will be issued as "final" notices without a time period allotted for public
comment, while others will be issued "for comment."
Label changes will apply to all regulated products, not just pesticides and household cleaners.
ป Sometime in the future, all of the PR notices will be incorporated into EPA regulation.
Companies should submit requests for label changes now.
Discussion/Proposals
5 Stakeholders proposed the consideration of designating a pilot project, in the spirit of
reinvention, in which a single or couple of product managers handle the proposed label changes
submitted as a result of the CLI Phase I and II changes.
Some stakeholders argued that the ingredients should be listed on the back of the label and
requested that the issue of ingredient placement be currently considered as a label change
requiring discussion with a Project Manager (instead of a change that cannot be made at this
i,;:-i; time).
STORAGE AND DISPOSAL INSTRUCTIONS ON LABELS
Jean Frane briefly summarized recent OPP activities relating to storage and disposal instructions on
product labels, specifically addressing the impasse reached by the sub-group on storage and disposal (i.e.
|he conflict between stated storage and disposal instructions and local/state regulations, policies, or
practices). OPP has met with North American Hazardous Materials Management Association
(NAHMMA) and Chemical Specialties Manufacturers Association (CSMA) and hopes to have a
proposal by early summer 1999. A draft of the proposal will be shared with the P&TF, once it is
developed.
:::,: ' ' ' , , i - '
*L_. ! !l ' If '':*i '." ' . 'i . ,! > ' li ., - i , , " V
Discussion
1 ' I'l'K, (''*;! . ' i .. ': ,.;!.' , , ij. ' 11" ..i \ '! t, .: >'
States have expressed dissatisfaction with advancing the "Read the Label FIRST!"campaign
while there are still outstanding unresolved issues concerning the storage and disposal section of
the label.
lNG^ _' _' .,1'.','. ..!!".'. , ,,,'
"".?ean,^r,a?e,,als,9 i!?cus!ed recent activities regarding the listing of ingredient information on labels. The
issue of disclosure of inert ingredients will be worked through by a sub-committee of
the Pesticide Program bialogue Committee (PPDC). While entirely separate from CLI, P&TF members
who are interested in following the activities of this group may be able to attend the sub-committee
meetings as public observers.
i Ml 1 lUHillJ
IB EDUCATION
Mary Dominiak (EPA) updated the Stakeholders on current CLI activities relating to Consumer
Education (ConEd). (To view her presentation, see attached copy of the slides used.)
Jhe goals of the consumer education presentation were to approve the flier/brochure messages,
lip ,pPPrฐve essage P'acement ?tratesy'to ฐk.tam 'n^'v'^ua! c9mr^'!mSO!sto undertake specific
("placement actions" and to determine the direction in which to proceed with logo design.
11 :J
546
Miif
-------
As recommended at the last P&TF meeting, the ConEd group has been expanded into three working
groups that coordinate with the larger ConEd group.
Message Development
Activities relating to the development of outreach fliers/brochures promoting the "Read the Label First!"
campaign were summarized for the P&TF:
Two layouts (one-page fliers and tri-fold brochures) were developed to present the content of the
outreach brochures (these brochures were drafted last year and have been updated with
comments from the last P&TF meeting and ConEd conference calls). Graphics for the outreach
materials still need to be developed.
State and local programs have expressed concern with the "Read the Label First!" campaign
because it directs consumers to follow storage and disposal information that conflicts with some
state and local regulations. The ConEd group has responded by pointing out that groups can
customize the brochure/flier to include contact information.
Discussion
Restriction of Flexibility to Change the Brochures
The issue of restricting the changes that people are allowed to make on the proposed
brochures/fliers was raised. It was decided by the P&TF that the only information that can be
added into the brochures/fliers is local contact information and "distributed by" information.
Stakeholders requested confirmation from EPA that they will be allowed to add their logos onto
the brochures/fliers, stating that industry would be more willing to fund the brochures if
individual company logos are on them.
EPA will look into the issue of listing the EPA logo alongside brand-identifying information and
logos.
Disposal
It was pointed out that many state and local governments are currently deciding whether or not
they will participate in the consumer education campaign. This decision will be based upon how
the disposal issue is resolved.
In response to this, the P&TF decided to remove all mention of disposal instructions from the
outreach brochures/fliers until the issue has been resolved, with the exception that the gardeners
brochure will continue to include the statement that lawn and garden products should never be
poured down the drain.
Stakeholder Comments on Wording of the Brochures/fliers
Current versions of the fliers/brochures were submitted for input to the P&TF members at the
meeting. Stakeholders made a variety of comments on the wording of the documents.
The message content of the brochures/fliers was finalized and agreed upon by the P&TF.
The newly revised, now FINAL versions of the brochure texts are attached.
Message Placement
Julie Winters (EPA), Annette Washington (EPA) and Nicole Christian (EPA) presented information on
the activities of the message placement group. The goal of the message placement group is to identify
and implement the best ways to distribute ConEd products and messages in order to publicize the "Read
the Label First!" campaign. The presenters described group participants and activities, such as matrix of
placement activities, EPA database. Web site link project, calendar of strategic events, and evaluation.
(See attached copy of presentation slides.)
Discussion
Stakeholders made the following comments:
547
-------
T'm'PS ฐCP'st"butjon.- the P'acement(of Promotiฐnal material) in retail distribution outlets
has already been done for this year. Planning for next year is beginning now and promotional
materials for next year should be ready by this December/January.
: Stakeholders reiterated that the ability to put their companies' logos on the outreach
brochures/fliers would make it easier to promote the brochures to retail outlets.
The Qarden Writers of America, the Home & Garden Cable Network (HGTV),'and the National
Poison Prevention Meeting (in March) were mentioned as potential vehicles through which to
broadcast the consumer education message.
Stakeholders were asked to specify ways in which they could help with message placement.
Stakeholders volunteered to assist with obtaining a list of lawn and garden shows (Bayer-Pursell
LLC) and contacting the National School Board Association (RISE).
It was suggested that the CLI have a public relations firm draft a strategy and calendar for the
message placement activities. A few Stakeholders volunteered to look into the possibility of
their companies' public relations firms working pro bono on strategy development.
Logo Design
Mary Dominiak (EPA) updated the P&TF on logo design activities for the "Read the Label First!"
campaign. The goal of the P&TF meeting with regard to logo design was to obtain P&TF input on logo
development and select an option for designing it. The desire to find an option that included the input of
all P&TF members has made the decision of logo selection method difficult. A list of desirable logo
design criteria was presented (see the attached slides used in the presentation). The goal for logo
completion is August, so that companies have the logo in time to plan promotion for the following
spring.
The following options for funding logo design were presented to the P&TF:
EPA Cooperative Agreement/Grant - The EPA could arrange a cooperative agreement with a
not-for-profit group. |The EPA has compiled a list of potential not-for-profit groups.
Pro: The time-line would be relatively short. The decision would be made by a third
party.
Con: The decision would be made by a third party. The P&TF would have to be
comfortable with this process.
Non- EPA Agreement - An outside group, such as some/all CLI Partners, excluding EPA, could
fund it.
prฐ>? Outside groups do not have the restrictions on contracting that apply to the Federal
government, would be free to set up any type of arrangement that would work for the
group, and would potentially have access to any desired design group.
Con: A group other than the existing EPA core team would have to be organized to
oversee and coordinate the process.
EPA Contract - The EPA could fund it through a government contract.
Pro: Quick if done under small purchase.
Con: Limited access to the types of design groups most likely to produce high quality,
high profile work; extremely difficult to build in opportunities for non-government
groups to influence decision; decision must be made by EPA.
Discussion , ,, , , ,,,,. i,
Method ofLo^o Design
"|he idea of holding a design competition was presented to the P&TF. Stakeholder comments on the
logo competition were as follows:
Students from design and art colleges were recommended as good candidates for logo design. It
548
-------
was pointed out that college classes are almost done for the year, which would affect the timing
of a potential logo competition.
Stakeholders discussed the advantages and drawbacks of a design competition, weighing the
logistical problems of administering such a competition, guaranteeing the quality of submissions,
and timing the contest to be assured of having a final logo by August against the opportunity to
gain additional publicity and fresh ideas.
Some Stakeholders advocated for a design- firm to design the logo. A few Stakeholders
volunteered to think of names of potential firms for pro- bono work.
The matter will be decided upon by the ConEd sub-group in the next conference call on April 22,
1999, 3:00 - 5:00pm EST (Call-in number - 202 260-8330 Access code - 7890 followed by the
pound # sign).
King County, WA, Department of Natural Resources, will explore using $5,000 - 6,000 of its
marketing contract to assist with logo design.
Other Comments
There was discussion about whether the logo should be tested by a focus group before it is
approved. Comments ranged from advising to use focus group information for directionalnot
finalguidance, to pointing out that focus group research on a potential logo design could
highlight aspects of the logo design that the P&TF might not see (e.g. if the logo was scary for
consumers).
A recommendation was made for setting up criteria to define how the logo will be used.
P&TF members at the meeting agreed that, however the logo designs were achieved, the ConEd
group would present the top handful of options to the entire P&TF for a vote, and the design
winning the majority of votes would be adopted as the RtLF! logo which everyone would use.
OTHER INFORMATION
EPA Administrator Carol Browner will be conducting a national town meeting in the near future,
at which she will mention the CLI.
The CLI has been cited as a possible candidate for the Plain English, "no gobbledy-gook award,"
a monthly award given by the Office of the-Vice President for efforts that simplify government
language for the public. CLI will likely apply for the award after the media event, when it has
something tangible to show (e.g. brochures, media message).
BACKGROUND DOCUMENTS (Available upon request)
Slides of EPA Presentation at CLI P&TF Meeting, April 7-8, 1999 (Enclosed)
Proposed Agenda - CLl P&TF Meeting, Aprif 7-8, 1999
Recommended First Aid Statements for Pesticide Products (DRAFT- April 7, 1999)
Older Version/Preferred Statement (CLI label changes)
CLI Media Event Options Paper (DRAFT - April 2, 1999)
CLI Phase II Report Outline
Matrix of Placement Actions (for April CLI P&TF Meeting)
Draft of Messages for CLI Media Event (April 2, 1999)
EPA Fact Sheet, Consumer Labeling Initiative, December 1998
"Read the Label First!" Flier - Household Products
"Read the Label First!" Tri-Fold - Household Products
"Read the Label First!" Flier - Children's Health
"Read the Label First!" Tri-Fold -Children's Health
"Read the Label First!" Flier - Gardeners
"Read the Label First!" Tri-Fold - Gardeners
549
-------
"Read the Label First!" Flier - Pet Protection
"Read the Label first!" Tri-Fold - Pet Protection
550
-------
Appendix 8-1:
List of Stakeholders Contributing Comments on CLI
551
-------
fi" >i !!!'"!!! 3111'
, ,';, ' ซ iiit! ; , , ... ' , 1 ... . i I,-,,; ,'" !!,""" !' I;
Appendix 8-1: List of Stakeholders Contributing Comments on CLI Phase
Final Listing as of March 1997
!"' ''.'. Name
Rose Marie Williams
Susan Mudd
Deborah Siefert Morrill
Jeannine Kerpey
Zoliman, Wa
-------
Tim Pham, Cupertino, CA
Stephanie Christen Serry, Los Gatos, CA
Teresa Gilbertson, Lyon County Hazardous Waste
Regional Program, Lyon County Environmental
Office, Marshall, MN
Betty Colombo, San Jose, CA
Ann Gummy, San Jose, CA
Cleofe A. Malimban, Santa Clara, CA
Nicole Jorgensen, San Jose, CA
Robert A. Nelson, Riverside County Waste
Management Department, Riverside, CA
Ruben J. Mesa, Solid Waste Reduction and Disposal
Program, Oxnard, CA
Sean McDonald, Seattle Public Utilities/Community
Services Division, Seattle, WA
Daphne H. Washington, Kern County Waste
Management Department, Bakersfield, CA
Mark Schleich, Solid Waste and Utilities Division,
County of Santa Barbara Public Works Department,
Santa Barbara, CA
Barbara Morrissey, Pesticide Poisoning Surveillance
Program, Office of Toxic Substances, Washington
Department of Health, Olympia, WA
Barry Connell, Center for Environmental
Communications, Newburyport, MA
Sally Toteff, Solid and Hazardous Waste Section,
Thurston County Public Health and Social Services
Department, Olympia WA
Michelle Arnold, Solid Waste Mgmt Div, Dept of
Water and Waste Management, Thurston County
Public Health and Social Services Department,
Olympia, WA
Nick Pealy, Seattle Public Utilities, Seattle, WA
Kathy Keolker-Wheeler, City of Renton, Suburban
Cities Association Representative, Renton, WA
Jeff Gaisford, King County Solid Waste Division,
Dept of Natural Resources, Seattle, WA
Nancy Hansen, King County Water and Land
Resources Division, King County Department of
Natural Resources, Seattle, WA
Carl Osaki, Seattle-King County Department of
Public Health, Seattle, WA
Jim Roberts, Mayor, City of Sunnyvale, Sunnyvale,
CA
Kim Stempien, Household Hazardous Waste, City of
Redding General Svs Dept, Solid Waste Division,
Redding, CA
Marcia L. Basque, Environmental Services Joint
Powers Authority, Sacramento, CA
Peder A. Larson, Minnesota Pollution Control
Agency, St Paul, MN
Kelly D. Moran, Ph.D., Water Pollution Prevention,
Regional Water Quality Control Plant, Palo Alto, CA
Jim Campbell, County of Yolo, Ping & Public Works
Dept, Division of Integrated Waste Mgmt, Davis, CA
Paul Slyman, Solid Waste Programs and Policy
Development Section, Oregon Department of
Environmental Quality, Portland, OR
Michael S. Chang, Ph.D., City of Cupertino,
Cupertino, CA
Jesse Tanner, Mayor, City of Renton, Renton. WA
Craig Perkins, Environmental and Public Works
Mgmt, City of Santa Monica, Santa Monica, CA
Trent Cave, Napa County Department of
Environmental Management, Napa, CA
Philip Dickey, Washington Toxics Coalition, Seattle,
WA
Peter M. Rooney, California Environmental
Protection Agency, Sacramento, CA
Paul Schell, Mayor, City of Seattle, Seattle, WA
Greg Buzicky, Agronomy and Plant Protection
Division, Minnesota Department of Agriculture, St
Paul, MN
553
-------
Earl tuntland, Cty of Riverside Health Svs Agency,
Dept of Eny. Health, Riverside, CA
Cullen p,' Ifephenson, Solid Waste & Financial
Assistance Program, Washington State Dept of
Ecology, blympja, WA
David Stitzhal, MRP, Full Circle Environmental,
Inc., Seattle, WA
Karen Feeney, Haz Waste Pgm Dir, Gildea Resource
Center, Community Environmental Council, Santa
Barbara, CA
Ken Wells, Sonoma County Waste Management
Agency, Santa Rosa, CA
Douglas A. Johnson, RS, Sioux Falls/Regional
Sanitary Landfill, Sioux Falls, SD
Gina Purity Community Outreach Coordinator,
Marin County Dept of Public Works, San Rafael, CA
Bruce Warner, Regional Environmental
Management, Portland OR
Paul Andre, Missouri Dept of Agriculture, Jefferson
City, MO
Mark Rappaport, Tuolumne County Solid Waste
Division, Sonora, CA
Nancy Simcox, MS, Seattle WA
Ed Ramos, San Jose, CA
'i, , 'i 'fii ' :
Larry Guiffre, San Jose, CA
Michael Benjamin, San Jose, CA
Chemical Specialties Manufacturers Association,
Washington, DC
North American Hazardous Materials Management
Association, Montpelier, VT
554
-------
Appendix 10-1:
List of Commentors on the CLI Phase II Report Draft
555
-------
-------
Appendix 10-1: List of Commentors on the CLI Phase II Report Draft
Name
Bill Chase
Robert W. Hamilton
Jan Newman
Julie Winters
Amy Breed love
Mary Dominiak
Lynn Lawson
Geoff Brosseau
Jane Nogaki
William W. Jacobs
Carolyn F. Brinkley
Organization
Registration and Regulatory Affairs, McLaughlin Gormley
King Company
Amway Corporation
Chemical Specialties Manufacturers Association
Household and Institutional Products Information Council
The Newman Group, Inc.
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
U.S. Environmental Protection Agency
MCS: Health and the Environment
Bay Area Stormwater Management Agencies Association
New Jersey Environmental Federation Pesticide Program
North American Hazardous Materials Management Association
U.S. Environmental Protection Agency
Novartis Crop Protection, Inc.
National Paint and Coatings Association
557
-------
i'H;
-------
-------
#ป 13
CO CD
O 3
O 03
s
o.
C30
I
CD
c
CD
CD
W
CO
I2JE
Is | S
3" CD 0?
13 S CD
g) CO
a
o
I\D
O
O>
O
ฃ|
5!
3
CD
g.
O
CQ
CD
O
-------
|