United States
Environmental Protection
Agency
Office of
Noise Abatement Control
Washington, D.C. 20460
EPA 550/9-79-255
August 1979
NOISE
Regulatory Analysis
Supporting the
General Provisions for
Product Noise Labeling
Noise
Reduction
r-k j.-
Rating
DECIBELS
(WHEN USED AS DIRECTED)
THE RANGE OF
FOR EXISTING
IS APPRO
(HIGH NUMBERS DENC
(Manufacturer)
Noise
Rating
79
DECIBELS
Federal law prohibits
removal of this label
prior to purchase.
(LOWER NOISE RATINGS MEAN QUIETER PRODUCTS)
THE APPROXIMATE RANGE IN NOISE RATINGS
FOR (PRODUCT) IS FROM 55 TO 85 DECIBELS
(Manufacturer)
(Model No.)
Federal law prohibits ,' g*± .
removal of this label } ^*^7
prior to purchase. \. •***•./
LABEL REQUIRED BY
U.S. E.P.A. REGULATION
40 CFR Part 211. Subpart_
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EPA 550/9-79-255
REGULATORY ANALYSIS
SUPPORTING THE
GENERAL PROVISIONS
FOR
PRODUCT NOISE LABELING
August, 1979
U.S. ENVIRONMENTAL PROTECTION AGENCY
Washington, D.C. 20460
This document has been approved for general availability.
It does not constitute a standard, -specification or regulation,
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FOREWORD
This Regulatory Analysis has been prepared by the United
States Environmental Protection Agency in support of the General
Provisions for Product Noise Labeling. The regulation is being
promulgated under the authority of sections 8, 10, 11, and 13 of
the Noise Control Act of 1972.
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TABLE OF CONTENTS
Introduction !
Outline and Summary of the Regulatory Analysis 4
PART I. DEVELOPMENT OF NOISE LABELING GENERAL PROVISIONS
Section 1. Review of Labeling Laws •• 11
Cigarettes • 14
Products Covered by "Fair Packaging and
Labeling Act" ..... 15
Food Covered by "Food, Drug and Cosmetic Act" !•. 16
Products Covered by "Consumer Product Safety Act" 19
Products Covered by Federal "Hazardous Substances Act"... 21
Insecticides, Fungicides and Rodenticides 23
Light Duty Motor Vehicles 25
Passenger Car Tires 27
Non-Prescription Drugs 29
Food 31
Manufactured or Processed Dairy Products 33
Butter 34
Agricultural Seeds 35
Shell Eggs 37
Products Covered by the "Agricultural Marketing
Act of 1946" 39
Livestock, Meats, Prepared Meats and Meat
Products • 40
Cottonseed for Crushing Purposes 41
Workplace Signs (General Requirements) •• 42
Workplace Signs and Markings (Specific
Requirements) 43
Workplace Machinery 45
Gasoline 46
Full-size Baby Cribs 47
Light Duty Motor Vehicles, Heavy Duty
Gasoline Engines 49
Textile Wearing Apparel and Yard Goods 50
Section 2. Noise Labeling-General Approach 51
Type of Labels . • 51
Informational Labeling , 52
Noise Labeling under Section 8 of the Noise
Control Act • 59
Major Characteristics of Labels • 66
Label Content 66
Physical Characteristics 67
Label Location • 76
Rating Schemes 77
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TABLE OF CONTENTS (Continued)
Paqe
Section 3. Noise Labeling - Graphics 80
Background 80
Design Criteria 83
Content 83
Design Characteristics .. 85
Design Description 86
Noise Rating Guide 87
Label Types • 87
Placement 88
Education 88
Section 4. Rating Schemes for Noise Producers 89
Acoustic Characteristics of Products. ... 89
How Sound Behaves 90
Sound Power Level vs Sound Pressure Level 90
Relation Between Sound Power and Sound Pressure
in Various Situations 93
Sound Outdoors 93
Sound Source Out in Space 94
Sound Source Against a Reflecting Surface 95
Sound Indoors 96
Typical User Distances and Label-Noise Rating
Categories . 107
Conclusion 109
Appendix A - Octave Bands that Dominate the A-Weighted
Sound Levels in Equipment Likely to be Labeled... 113
References for Part I 114
Selected Bibliography for Part 1 115
Statutory References for Part I * 117
PART II. DOCKET ANALYSIS
Section 1. General Issues. 121
1.1 Voluntary Labeling Programs 122
1.2 Statutory Authority 127
1.3 Proliferation of Product Labels.... 136
1.4 Aud ience Addressed 137
Section 2. Product Selection Issues 141
2.1 Product Selection Criteria.... 141
2.2 Noise-Reducing Products. 150
Section 3. Label Content 153
3.1 Comparative Acoustic Information ,. 153
3.2 Descriptor * 156
3.3 Manufacturer and Product Identification..* 166
ii
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TABLE OP CONTENTS (Continued)
Page
3.4 Warning Statement about Removal of Label.... 167
3.5 Logo ••••• 168
3.6 Warning Statement about the Effects of Noise 169
3.7 Alternative or Additional Media 171
3.8 Other Items Recommended for Inclusion... 173
Section 4. Label Format and Graphic Requirements. 179
4.1 Space Allocation !79
4.2 Graphic Requirements 179
4.3 Size Requirements. • • l8^
Section 5. Label Type and Location 182
5.1 Label Location •• 1Q2
5.2 Label Permanence... i83
5.3 General Comments I85
Section 6. Rating Schemes and Test Methodologies 186
6.1 Acoustic Parameter I86
6.2 Test Methodologies • 188
6.3 Technique of Rating i94
Section 7. Enforcement 196
7.1 General Issues I96
7.2 Inspection and Monitoring • • 1"
7.3 Exemptions 204
7.4 Testing by the Administrator 208
Section 8. Economic Impact •••• 212
8.1 R'equests for Further Agency Economic Analysis 212
8.2 Submission of Cost Data by Industry... 214
Section 9. Consumer Issues 217
9.1 Problems Experienced in Comparison Shopping 217
9.2 Frequency Distribution of Noise-Related
Complaints About Products. 219
9.3 Effects of Noise 222
References for Part II 225
Appendix A. Definition of Issues from Each Docket Entry 229
Written Comments. • 231
Public Hearing Testimony 382
Washington, D.C • *• 382
Cedar Rapids, Iowa 403
San Francisco, California 426
Appendix B. Index of Written Docket Submission and
Public Hearing Testimony 443
111
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TABLE OF CONTENTS (Continued)
PART III. PERSPECTIVES ON THE PROPOSED NOISE LABELING
PROGRAM: THE GENERAL PUBLIC AND INDUSTRY
Section 1. Analysis of Public Docket Comments 477
Support vs. Opposition 477
Section 2. General Audience Survey 484
Introduction 484
Survey Methodology 484
Data Collection 487
Results of the Interviews 489
The Sample .. 489
Questionnaire Responses. 491
Conclusions 513
Section 3. Test of Noise Label Elements * 515
Introduction 515
Door-to-Door Survey to Evaluate Alternative Means
of Communicating Noise Information on Product Labels.... 517
Objectives 517
Procedures 519
Results 521
Conclusions 529
Focus Group Discussions 533
Objectives 533
Procedures. 533
Results 537
Conclusions 552
References for Part III 554
Consultant's Guide for Part III 555
Appendix A: Questionnaire Used in Telephone
Survey 557
Appendix B: Door-to-Door Survey: Interview Protocol 565
Appendix C: Focus Group: Interview Guide and
Questionnaires 573
Appendix D: Excerpted Focus Group Comments. 587
Appendix E: Public Participation 607
IV
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LIST OF FIGURES
1-1 Federal Trade Commission Awareness Notice.. 54
1-2 Commercial and Government Labeling Brochures.... 55
1-3 Explanation of Cheese Label Contents 56
1-4 Example of a Catalog Ad with Noise Rating 57
1-5 Advertisements for Air Conditioners... 58
1-6 Advertisement Incorporating Noise Claim • • 62
1-7 Example of Labeling Confusion 65
1-8 USDA Seals •: «• • 68
1-9 Seal of the U.S. Department of Health, Education
and Welfare • ? ?°
1-10 Mr. Yuk Warning Label 71
1-11 Typical Auto Brochures 'J
1-12 Example of Complexity in Consumer Display.............. 75
1-13 Rating Process • ^8
1-14 Noise Rating Label J*
1-15 Noise Reductiqn Rating Label, • el
1-16 Noise Rating Guide 82
1-17 Behavior of Sound Outdoors 95
1-18 Behavior of Sound Indoors, Sound Source Out in
Space •••.••••••»•••»••••••• "»
1-19 Behavior of Sound Indoors, Constant-Volume-Velocity
Sound Source on Reflecting Surface.
1-20 Variation in Sound Power Outputs as Source is
Moved Away from Reflecting Wall 103
1-21 Behavior of Sound Source Near a Reflecting Surface..... 103
1-22 Behavior of Sound Indoors, Sound Source Out in Space:
(Difference Between Sound Pressure Level and Sound
Power Level) • • 108
1-23 Preliminary Results of Measurements of Sound
Attenuation vs. Distance in Real Dwelling Rooms 112
3-1 Format for Proposed Label 516
3-2 Sample Noise Label • 5i6
3-3 Decriptor and Comparative Information Variations
for Labels .;.;......... 520
3-4 Label A: Example of a Decibel Label 538
3-5 Label B: Example of a Range Label 538
3-6 Label C: Examples of Range Label Alternatives,........ 540
3-7 Label D: Example of a Decibel Guide Label 541
3-8 Label E: Example of a Decibel Guide Alternative....... 542
3-9 Label F: Example of an "As Loud As" Label 546
3-10 Label G: Examples of "As Loud As" Alternatives... 547
3-11 Consumer Preferences of Label Types..............•••••• 550
3-12 Sample of Recommended Noise Label 553
3-13 Sample Noise Chart or Barometer ••• 553
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LIST OF TABLES
1-1 Federal Agencies Involved in Labeling 12
1-2 Examples of Specific Products and General Categories
Subject to Labeling Laws 13
1-3 Types of Labels/ 52
1-4 Conformance Labeling and Information Labeling 52
1-5 Section 8 of the Noise Control Act of 1972 59
1-6 Section 10 of the Noise Control Act of 1972 60
1-7 Statutory Authority 61
1-8 Additional Examination of Section 8 Authority 63
1-9 Various Meanings of term "Labeling" 63
1-10. Common Factors for Labels 64
1-11 Content of Labels 67
1-12 Requirements for Additional Instructions 72
1-13 Physical Characteristics of a Label 76
1-14 Location of Labels 76
1-15 Example of Explanatory Part of Noise Label 79
1-16 Noise Characteristics of Indoor Household Products 91
1-17 Separation Distances "Close" to a Reflecting
Surface and "Out in Space" 105
1-18 Typical User Distance Category and Appropriate
Label-Noise-Rating Category 110
A-l Octave Bands of Equipment Likely to be Labeled.. 113
2-1 Number of Noise-Related Complaints Made about
Various Products 220
3-1 Percentage of Non-Industry Commenters with
Different Positions on EPA Noise Labeling and
Abatement Activities. 478
3-2 Percentage of Opponents Citing Different Reasons....... 480
3-3 Percentage of Industry Commenters with Different
Positions on EPA Noise Labeling..... 482
3-4 Simple Random Sample Size for Several Degrees
of Precision.. 486
3-5 Result of Dialings 488
3-6 Respondent Sex 490
3-7 Distribution of Respondents by Region 491
3-8 Perception of Noise as an Irritant 492
3-9 Source of Irritating Noise. 493
3-10 Perceived Brand Differences in Noise Levels 493
3-11 Importance of Different Criteria in Purchase
Decision 494
3-12 Willingness to Pay for Quieter Products 495
3-13 Desire for Government Noise Control 496
3-14 Reasons for Government Not to Set Noise Levels 497
3-15 Desire for Noise Information 497
3-16 Sources of Noise Information ;... 499
vi
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LIST OF TABLES (Continued)
3-17 Desire to Have Label Placed on Products .... 499
3-18 Potential Use of Noise Labels.. 500
3-19 Willingness to Pay for the Label |jj"
3-20 Preferences for Type of Label Ul
3-21 Preferences for Rating Scheme
3-22 Knowledge of Rating Terms •••
3-23 Estimates of Decibel Levels...*
3-24 Particular Products as Irritants.....
3-25 products Whose Noise is Irritating
3-26 Products Which Need to be Labeled . 51 u
3-27 Sex of Those Respondents Answering This Question b^
3-28 Race of Those Respondents Answering This Question 522
3-29 Education of Those Respondents Answering •
This Question.......... .•••• ....*... 523
3-30 Income of Those Respondents Answering This Question.... 52J
3-31 Desire to Have Label Placed on Products... 524
3-32 Willingness to Pay for the Label. •••• .524.
3-33 Direction of Scale * J*'
3-34 Question on Nature of Decibel Scale 3JU
3-35 Another Question on Nature of Decibel Scale 5J1
3-36 Ability to Use Labels.... •••• 532
3-37 Age of Participants. ....«....• •••
3-38 Sex of Participants. •
3-39 Education of Participants...
3-40 Race of Participants
3-41 Annual Household .Income of Participants
3-42 Results, of Decibel Level Estimation..
3-43 Most Frequently Cited Decibel Level Examples 548
3-44 General Categories of Examples Provided by
Consumers at the 70, ,80, 90 Decibel Levels... 549
vii
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INTRODUCTION
In the Noise Control Act of 1972 (86 Stat. 1234) Congress
declared that it is the "policy of the United States to promote
an environment for all Americans free from noise that jeopardizes
their health and welfare." Congress further declared that one
purpose of this Act is "to provide information to the public
respecting the noise emission and noise reduction characteristics
of products (distributed in commerce)."
Section 8 of the Act (Labeling) requires that the Administra-
tor of the Environmental Protection Agency shall, by regulation,
designate any product or class of product "which emits noise
capable of adversely affecting the public health or welfare; or
which is sold wholly or in part on the basis of its effectiveness
in reducing noise". Further, the Administrator must require by
regulation that "notice be given to the prospective user (of a
product) of the level of the noise the product emits, or of its
effectiveness in reducing noise, as the case may be." The regu-
lation must specify: "whether such notice should be affixed to
the product or to the outside of its container or to both at the
time of its sale to the ultimate purchaser or whether (it) shall
be given to the prospective user in some other manner"; "the form
of the notice"; and the "method and units of measurement to be
used (in developing the notice)11.
The Agency has, as its basic objectives in the development
and the implementation of a Federal noise labeling program under
Section 8 of the Noise Control Act, the following elements:
1. To provide accurate and understandable information to
product purchasers and users regarding the acoustic pro-
perties of designated products so that meaningful com-
parisons with respect to noise emission or noise reduc-
tion can be made as part of a product purchase or use
decision.
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2. To provide accurate and understandable information, to
consumers with minimal Federal involvement. Minimal
Federal involvement is to be achieved by ensuring that
the Federally-imposed labeling requirements are carefully
analyzed and structured so as to reduce the administra-
tive, economic and technical impacts of the Federal pro-
gram as much as possible.
3. To promote public awareness of product specific contri-
butions to the environmental noise problem and to foster
an understanding of associated terminology and concepts.
4. To promote effective voluntary noise labeling efforts on
the part of product manufacturers and suppliers with the
anticipation that a concomitant reduction in product
noise may occur due to market demands.
The Agency's policy in developing and implementing a noise
labeling regulatory program is to do it in as simplified, yet
effective, a form as is possible. To determine that form, the
Agency reviewed many other labeling programs, both Federal and
voluntary, and collected and analyzed relevant data including
various rating schemes, labeling graphics, and essential label
content. Consumer inputs were obtained by telephone and door-to-
door surveys, and through "focus groups" interviews. Public
comment was carefully considered. These studies and comments
supplied data which helped the Agency develop the format for
a product noise labeling program under the authority of Section
8 of the Act.
The Agency essentially considered two alternative approaches
to a Federal noise labeling program. One was to first issue
a regulation concerning those elements that could be applied
uniformly to all product classes i.e., format and content of
the label, label location, and basic enforcement procedures.
These "general provisions" would then be applied in conjunction
with product specific regulations that would cover those aspects
that are unique to the particular product or product class. The
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other alternative was to issue general labeling provisions for
each specific product or product class on a product-by-product
basis.
In the Noise Control Act, Congress declared that "national
uniformity of treatment" (with respect to noise emission standards
under the authority of Section 6) was essential in controlling
major noise sources (in commerce). Uniformity of treatment with
respect to product noise labeling would be an approach to Sec-
tion 8 that is consistent with the Congressional approach to
Section 6.
The Agency carefully and completely analyzed the implication
of each alternative method of developing a Federal noise labeling
program. It was decided that the first alternative, issuing
general provisions to the noise labeling program, offered a better
assurance of national uniformity of treatment within the program.
Therefore, The Agency proposed that the general provisions of
the product noise labeling program, as a first step in carrying
out the Congressional mandate of Section 8 of the Act, be based on
the first alternative. The general provisions were proposed and
published in the Federal Register on June 22, 1977 (42 FR 31722).
The general provisions covered those elements of the labeling
program that are capable of being applied uniformly across differ-
ent product classes. Regulations specific to a product or class
of products would address those areas where uniformity is not
feasible or where a product's unique characteristics justify
variations from the general provisions.
Public Participation
At the time of publication of the proposal, EPA submitted
written public comment on the General Provisions as well as
other aspects of the Product Noise Labeling Program by means of
direct mailings, of information about the regulation to manu-
facturers, distributers, consumer and environmental groups,
other Federal Agencies, State and local Governments, various
trade associations, newspapers and consumer oriented periodicals,
educational institutions, and others.
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The information provided was in the form of fact sheets,
copies of the proposed regulation, and press releases generally
describing the proposed program. A public comment period of 90
days was established with closing scheduled for September 20',
1977 Public hearings were not initially scheduled. As a result
of the substantial public interest, as evidenced by the large
number of letters received shortly after publication in the
Federal Register, the EPA decided to schedule public hearings,
and extended the comment period to October 28, 1977. Hearings
were held in Washington, D.C. on September 16, 1977; in Cedar
Rapids, Iowa on September 20, 1977; and in San Francisco, Cali-
fornia on September 22, 1977.
To notify the public on the availability of public hearings
in their areas as a means of expressing their opinions on and
suggestions for the program, the Agency arranged television and
radio broadcasts.
In all, the Agency received 735 written comments by the
close of the comment period and took some 1094 pages of oral
testimony from 51 individuals, organizations and businesses at
the three public hearings. A complete list of commenters "is
in Appendix B of Part III. Over 600 of the written comments were
from private citizens. The comments deal with virtually every
aspect of the program. A large majority of the comments were in
favor of the proposed noise labeling program. Most of the
favorable comment came from private citizens, while the majority
of industry commenters were critical of various aspects of the
program.
The public comments and the issues they addressed were
carefully analyzed and considered by the Agency before publi-
cation of the final regulation. This final rule, Product
Noise Labeling, General Provisions, was published in Volume 44 of
the Federal Register in August of 1979. The regulation includes
provisions concerning product applicability, definitions, label
format and content, label graphics, and enforcement provisions
concerning inspection , monitoring and exemptions.
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To provide adequate notice to the public on the provisions
of this final rule, the Agency developed explanatory material in
the form of letters of introduction, fact sheets, questions and
answers, press releases and reprints of the Federal Register.
These items were mailed to manufacturers' and distributers' asso-
ciations, consumer and environmental groups, educational insti-
tutions, other Federal agencies, international organizations,
import/export organizations, newspapers and consumer oriented
media, State and local governments, and any other interested
parties that the agency was able to identify. An abbreviated
list of parties contacted is included in Appendix E of Part
III.
A complete Agency product noise labeling action with respect
to any given product or class of products will consist of the
requirements contained in the general provisions that are appli-
cable to the product along with those contained in the product-
specific noise labeling regulation.
The program and its impacts will be continually evaluated so
that any revisions to the regulatory approach might be made.
OUTLINE AND SUMMARY OF THE REGULATORY ANALYSIS
This document presents the results of studies by the U.S.
Environmental Protection Agency to develop general background
information concerning product noise labeling. Also included is
the analysis of all comments from the public concerning the pro-
posed general provisions regulation.
This report is divided into three main parts. Each part is
further divided into sections. A summary of the Background Docu-
ment is listed below.
PART I: The Development of Noise Labeling General Provisions
Section 1 - reviews other Federal labeling programs.
Section 2 - contains a discussion of some of the major
issues involved in formulating a general
approach to product noise labeling (under
Section 8 of the Noise Control Act).
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Section 3 - presents an aproach to the design graphics as-
sociated with a noise labeling program.
Section 4 - deals with potential technical problems associ-
ated with the development of specific noise rat-
ing schemes. The example used addresses common
household appliances.
PART II: Docket Analysis
Comments received from the public concerning the proposed
general provisions are discussed. Respondents are identified by
their appropriate docket number. The primary function of the
Docket Analysis is to present the Agency's response to all com-
ments and issues raised by the public.
Section 1 - addresses issues concerning the Agency's statu-
tory authority to require product labeling.
Section 2 - addresses issues pertaining to selection of pro-
ducts for noise labeling e.g. criteria, types
of products.
Section 3 - addresses issues that concern what the label
will contain e.g. what information, liabilities
implied by label information and alternatives to
the proposed general provisions.
Section 4 - addresses reasons for the chosen label format,
and problems seen by commenters.
Section 5 - addresses comments concerning the various types
of labeling and location on the packaging.
Section 6 - addresses comments on rating schemes, test meth-
odologies, choice of acoustic parameters, and
the "descriptor" to best convey the noise infor-
mation.
Section 7 - addresses issues pertaining to the general en-
forcement procedures.
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Section 8 - addresses the issues related to an economic anal-
ysis for each product specific labeling action,
the costs such an action would have to the gov-
ernment, and how consumer product preference,
.. , because of the noise label, will be assessed.
Section 9 - presents data on a number of noise related com-
plaints received about various products.
Appendix A presents the definition of issues from each docket
entry, both written comments and oral testimony.
Appendix B is an index of all docket submissions, written and
oral, which allows one to identify the source of different com-
ments where they are not specifically mentioned in the text.
PART III: Perspective on the Proposed Noise Labeling Program
Section 1 - presents the tabulations of public docket com-
ments reflecting either support or opposition
for the proposed noise.labeling program.
Section 2 - presents the results of a nationwide telephone
survey conducted in order to learn how the gen-
eral public feels about noise, noisy products,
product noise labeling and the elements of an
effective noise label.
Section 3 - presents the results of a door-to-door survey
and focus group discussions in order to gather
more in-depth knowledge on the elements of an
effective noise label.
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Appendix A presents the questionnaire used in the telephone
survey. Appendix B presents the interview protocol used in the
door-to-door survey. Appendix C presents the interview guide and
questionnaires used in the focus group discussions, while excerpt-
ed comments from the focus group discussions are presented
in Appendix D. Appendix E is a list of parties reached through
the Agency's active efforts for assuring public participation.
8
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PART I
DEVELOPMENT OF NOISE LABELING GENERAL PROVISIONS
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SECTION 1: REVIEW OF LABELING LAWS
As part of a general study on labeling, an extensive review
of Federal, industry, and private labeling efforts was undertaken.
The review was conducted so that the Environmental Protection
Agency (EPA) might gain insight into its noise labeling program
from existing labeling programs. Of particular Interest were
government agency consumer information labeling programs. Lists
of the agencies and examples of general categories and specific
products reviewed are given in Tables 1-1 and 1-2. This section
contains summaries of 24 significant government labeling efforts.
The summaries are of two types: summaries of labeling regulations
affecting specific products and summaries of labeling requirements
set forth in the mandating Acts.
The reviews are not to be construed as complete, authorita-
tive descriptions of the government labeling programs, but rather
as interpretative summaries that highlight the labeling issues
relevant to EPA.
11
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Table 1-1
Federal Agencies Involved in Labeling
Department of Energy (DOE)
Consumer Product Safety Commission (CPSC)
Department of Agriculture (DOA)
Department of Commerce (DOC)
Department of Defense (DOD)
Department of Justice (DOJ)
Environmental Protection Agency (EPA)
Federal Trade Commission (FTC)
Food and Drug Administration (HEM)
National Highway Traffic Safety Administration (DOT)
Occupational Safety and Health Administration (DOL)
12
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Table 1-2
Examples of Specific Products and General Categories
Subject to Labeling Laws
Tires
Electrically operated toys
Charcoal briquettes
Air conditioners
Lawn darts
Toy caps
Bicycles
Car seats for children
Power amplifiers
Refrigerators, freezers
Textile wearing apparel and yard goods
Full-size cribs
Hazardous substances
Insecticides, fungicides and rodenticides
Gasoline
Cigarettes
Drugs
Food
Light bulbs
Motor vehicles
Electric appliances
Upholstered products
Agricultural seed
Occupational safety equipment
13
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CIGARETTES
A. PRODUCT:
B. AGENCY:
C. PURPOSE:
D. GRADE/RATING:
E. TECHNICAL BASIS/
ORGANIZATION:
F. LABEL CONTENT:
G. PHYSICAL
CHARACTERISTICS:
H. LOCATION:
I. COMMENTS:
Cigarettes: Labeling required under
"Public Health Cigarette Smoking Act"
(P.L. 89-92)
Department of Justice
Information with respect to any relation-
ship between smoking and health
Not graded or rated under the above Public
Laws
No technical basis per se since there is
no grading, but there is a technical basis
behind the Congressional decision to
require a warning on all cigarette pack-
ages
"Warning: The Surgeon General has Deter-
mined that Cigarette Smoking Is Dangerous
to Your Health"
Specified as follows: Conspicuous and
legible type in contrast by typography,
layout or color with other printed matter
on the package
Conspicuously located on every package
This is informational labeling specified
by Congress and administered by the
Department of Justice
14
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PRODUCTS COVERED BY: "FAIR PACKAGING AND LABELING ACT"
A. PRODUCT:
B. AGENCY:
C. PURPOSE:
D. GRADES/RATINGS
E. TECHNICAL BASIS/
CATEGORIZATION:
F. LABEL CONTENT:
G. PHYSICAL
CHARACTERISTICS:
H. LOCATION: i
All products for which labeling Is required
under the "Fair Packaging and Labeling Act:
(15 USC 1451 et. seq.)
Federal Trade Commission (16 CFR 500-503)
Truthful packaging and labeling of products
Not applicable
"name";
1. Statement of Identity:
2. Name and place of business of the manu-
facturer, packer or distributor
3. Net quantity of contents;
4. If the label bears a representation as
to the number of servings, uses, or
application of such commodity, the
label shall bear in Immediate conjunc-
tion therewith, a statement of the net
quantity of each such serving, use or
application.
Specified as follows:
1. Type size must be easily read;
2. Type must be parallel to the base of the
package
Specified as follows:
1. The statement of Identity and the net
quantity must appear on the "Principal
Display Panel";
2. The net quantity declaration shall be
placed 1n the bottom 30 percent of
the area of the label panel;
3. The name and place of business of
manufacturer . . . shall be conspic-
uously located on the package.
15
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FOOD COVERED BY "FEDERAL FOOD, DRUG AND COMESTIC ACT1
A. PRODUCT:
B. AGENCY:
C. PURPOSE:
D. GRADES/RATINGS:
E. TECHNICAL BASIS/
CATEGORIZATION:
F. LABEL CONTENT:
Food: Labeling required under the "Federal
Food, Drug and Cosmetic Act"
(21 USC 301 et. seq.)
Department of Health, Education and Welfare;
Food and Drug Administration
Standards of identity and definition,
quality, and fill of container for the
purpose of promoting honesty and fair
dealing in the interest of consumers
Not graded per se. The Act prohibits the
introduction of adulterated or misbranded
food into interstate commerce. The Act
defines misbranded and adulterated food.
In general terms, adulterated food is
deemed to be any food which "contains any
poisonous or deleterious substance which
may render it Injurious" to health or 1f
it "is otherwise unfit for food."
Food: The following information must
appear on the label:
1. The name and place of business of the
manufacturer, packer or distributor;
2. An accurate statement of quantity
of contents in terms of weight,
measure or numerical count;
3. If the product is an imitation of
another food, the word imitation
(in type of uniform size and pro-
minence) immediately preceding the
name of the food imitated;
4* If the product purports to be or
is represented for special dietary
uses, information concerning its
vitamin, mineral and other dietary
properties;
5. If the product bears or contains any
artificial flavoring, artificial coloring
or chemical preservative, a statement
of that fact;
16
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6. If the product purports to be or is
represented as food for which a defini-
tion and standard of identity has been
prescribed by regulations, the name of
the food as specified in the definition
and standards, and insofar as may be
required by such regulations, the common
names of optional ingredients;
7. If the food purports to be or is repre-
sented, as a food for which a standard
of quality has been prescribed by
regulations and its quality falls below
such standard, a statement that it falls
below such standard (in a manner and form
as such regulations specify);
8. If the food purports to be or is repre-
sented as a food for which a standard or
standards of fill of container have been
prescribed by regulations and it falls
below the standard of fill of container
applicable thereto, a statement that it
falls below such standard (in a manner
and form as such regulations specify);
9 If the product is not subject to the
requirements of item 6, the common or
usual name of the food, if any there be,
and in case it is fabricated from two
or more ingredients, the common or usual
name of each such ingredient;
10. If it is a raw agricultural commodity
which is the product of the soil, bearing
or containing a pesticide chemical applied
after harvest, the shipping container of
such commodity must declare the presence
of such chemical in or on such commodity
and the common or usual name and the
function of such chemical;
11. Labeling must be in conformance with an
applicable regulation issued pursuant
to Section 3 or 4 of the Poison Preven-
tion Packaging Act of 1970.
17
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G. PHYSICAL Specified as follows:
CHARACTERISTICS: 1. All required information must be placed
with such conspicuousness (as compared
with other words, statements, designs
in the labeling) and in such terms as to
render it likely to be read and under-
stood by the ordinary individual under
customary conditions of purchase and
use.
H. LOCATION: Specified:
1. All required information must be prom-
inently located where it is likely to
be read under customary conditions of
purchase and use.
18
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PRODUCTS COVERED BY CONSUMER PRODUCT SAFETY ACT
A. PRODUCT:
B. AGENCY:
C. PURPOSE:
D. GRADES/RATINGS:
E. TECHNICAL BASIS/
CATEGORIZATION:
F. LABEL CONTENT:
All products for which labeling is required
under the "Consumer Product Safety Act"
(15 USC 2051 et. seq.)
Consumer Product Safety Commission
To protect the public against unreasonable
risks of injury associated with consumer
products; to assist consumers in evaluating
the comparative safety of consumer pro-
ducts; to develop uniform safety standards
for consumer products.
The Commission determines if a consumer
product presents an unreasonable risk of
injury to the public. If the product does
present an unreasonable risk, the Commis-
sion then determines whether or not a
safety standard will eliminate the unrea-
sonable risk. If no feasible product safety
standard would adequately protect the public
from the unreasonable risk of injury asso-
ciated with the product, the Commission may
propose and promulgate a rule declaring
such product a banned hazardous product.
Requirements of CPS standards (other than
requirements relating to labeling, warnings
or instructions) shall, whenever feasible,
be expressed in terms of performance
requirements.
For any product which is subject to a
consumer product safety standard:
1. Date and place of manufacture;
2. A suitable identification of the manu-
facturer or the private labeler and
the code mark of the manufacturer
in the case of a private labeler;
3. A certification that the product
meets all applicable consumer product
safety standards and a specification
of the standards which are applicable.
19
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G. PHYSICAL Specified as follows:
CHARACTERISTICS: 1. Such labels, where practicable, may be
required by the Commission to be per-
manently marked on or affixed to any
such consumer product.
H. LOCATION: Specified as follows:
1. The certificate of conformity shall
accompany the product or shall other-
wise be furnished to any distributor
or retailer to whom the product 1s
delivered.
20
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PRODUCTS COVERED BY FEDERAL "HAZARDOUS SUBSTANCES ACT'
A. PRODUCT:
B. AGENCY:
C. PURPOSE:
D. GRADES/RATING:
E. TECHNICAL BASIS/
CATEGORIZATION:
F. LABEL CONTENT:
All products for which labeling Is required
under the "Federal Hazardous Substances
Act" (15 USC 1261 et. seq.)
Consumer Product Safety Commission
Consumer protection
Not graded. A hazardous substance "Is any
substance or mixture of substances (as
determined by the Commission) which Is
toxic, corrosive, an Irritant, a strong
sensitlzer, flammable or combustible, or
generates pressure through decomposition,
heat or other means, if such substance or
mixture of substances may cause substantial
personal Injury or substantial Illness
during or as a proximate result of any
customary or reasonable foreseeable hand-
ling or use, Including reasonably foreseeable
ingestion by children. The tests to deter-
mine if a product 1s a hazardous substance
are set forth 1n the regulations".
1. Name and place of business of the manu-
facturer, packer, distributor or seller;
2. Common or usual name or the chemical
name (1f there be no common or usual
name) of the hazardous substance(s);
3. Signal word "DANGER" on substances
which are extremely flammable, corro-
sive, or highly toxic; the signal word
"WARNING" or "CAUTION" on all other
hazardous substances;
4. An affirmative statement of the princi-
pal hazard or hazards;
5. Precautionary measures describing the
action to be followed or avoided;
6. instructions, when necessary or appro-
priate, for first aid treatment;
7. The word "POISON" for any hazardous
substance which is defined as "highly
toxic";
8. Instructions for handling and storage
of packages which require special
care in handling or storage;
21
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9. The statement "Keep out of the reach
of children", or its practical equiva-
lent, or, if the article is intended
for use by children and is not a banned
hazardous substance, adequate directions
for the protection of children from the
hazard;
10. Specific product labeling statements as
deemed necessary by the Commission as
specified in Section 4 of the Poison
Prevention Packaging Act;
11. On the container of household substances
which do not meet the standards set
under Section 3 of the Poison Prevention
Packaging Act, the following statement:
"This package for households without
young children".
G. PHYSICAL Specified as follows:
CHARACTERISTICS: 1. Written in the English language;
2. Conspicuous and legible type in contrast
by typography, layout, or color with
other printed matter on the label.
H. LOCATION: Location of label not specified.
22
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INSECTICIDES, FUNGICIDES AND RODENTICIDES
A. PRODUCT:
B. AGENCY:
C. PURPOSE:
D. GRADE/RATING:
E. TECHNICAL BASIS/
CATEGORIZATION:
F. LABEL CONTENT:
Labeling of pesticides required under the
"Insecticides, Fungicides and Rodenticides
Act" and related acts, and EPA regulations
at 40 CFR 162
Environmental Protection Agency
Protection of public health through identifi-
cation of hazards
Use classification; other information required
The Act states:
"unreasonable adverse effects on the environ-
ment" i.e., unreasonable risk to man or the
environment, taking into account the economic,
social and environmental costs and benefits
of the use of any pesticide (as determined by
the Administrator of the EPA).
1. Registration number of manufacturing
plant;
2. Directions for use necessary for effect-
ing the purpose for which the product
is intended and adequate to protect
health and the environment;
3. The statement "Keep Out of Reach of
Children";
4. A signal word such as "Danger", "Warning"
or "Caution";
5. Other warning or cautionary statements
as necessary to protect the public;
6. Ingredient statement: name, percentage
designation;
7. Use classification: general, restricted;
8. Name and address of the manufacturer,
packer, formulator, registrant, or
person for whom the product is produced;
9. Name, brand or trademark;
10. Net weight or measure of the content;
11. For pesticides containing any substance(s)
in quantities highly toxic to man:
a. skull and crossbones
b. the word "poison" as well as the word
"danger"
c. a statement of practical treatment
in case of poisoning by pesticides.
23
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ti. PHYSICAL
CHARACTERISTICS:
H. LOCATION;
I. COMMENTS:
Specified as follows:
1. Any word, statement or other Information
required must be placed on the label
conspicuously (as compared to other
words, statements, designs, or graphic
matter In the labeling).
2. Likely to be readable and understood by
the ordinary individual with normal
vision, under customary conditions of
purchase and use.
3. If the word "Poison" is required, it
must be prominent in red on a background
of distinctly contrasting color.
4. Specified are a minimum type size for
warning statements and signal words.
1. All information required by the Act must
be prominently located on the outside
container or wrapper of the retail
package so as to be clearly readable
when presented or displayed under
customary conditions of purchase.
2. Specified are:
a. the location of signal words and the
statement "Keep out of Reach of
Children";
b. location of ingredient statement;
c. location of skull and crossbones
and statement of practical treatment
for poisons highly toxic to man.
The above summary applies to the labeling
requirements as they were developed as of
summer of 1975.
24
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LIGHT-DUTY MOTOR VEHICLES
A. PRODUCT:
B. AGENCY:
C. PURPOSE:
D. GRADE/RATING:
E. TECHNICAL BASIS/
CATEGORIZATION:
Light-duty Motor Vehicles "Voluntary Fuel
Economy Labeling"
Environmental Protection Agency
(39 FR 36890),
Federal Energy Administration
Provide new car fuel economy information
at point-of-sale. The notice states that
the primary goal of the program is to
reduce energy usage in the transportation
sector. Intermediate goals are:
1. To increase public awareness of factors
which influence fuel economy;
2. To influence consumers to purchase
vehicles with good fuel economy;
3. To influence manufacturers to produce
vehicles with improved fuel economy.
Fuel economy is not graded per se. Fuel
economy values are given in miles-per-
gallon, and city and highway values are
listed separately.
The manufacturer presents, in one of two
forms, fuel economy information for the
consumer to use in his evaluation of the
vehicles; this is somewhat analogous to
"energy labeling".
If the "general fuel economy label" is used,
it presents the sales-weighted average of
fuel economy values (by car line separately
for passenger cars and wagons) of all
vehicles with the same engine. The manu-
facturer may also include the range of
data used to derive the sales-weighted
average.
If the "specific fuel economy label" is
used, it presents the EPA-approved fuel
economy values for the specific vehicle
configuration.
1. City fuel economy is derived from the
Federal Emission Test Procedure (40
CFR 85); a separate highway test is
prescribed;
2. Fuel economy values are reported to
the nearest whole mile-per-gallon.
25
-------
F. LABEL CONTENT:
G. PHYSICAL
CHARACTERISTICS:
H. LOCATION:
I. COMMENTS:
Consistent with that indicated in the
illustrative examples published in the
Federal Register (39 FR 36891) specified
are:
EPA logo;
FEA logo;
Statement of authenticity of test results;
Results of tests, as described in Section
D (above) for either the "general" or
"specific" labels;
5. Reminder that actual fuel economy varies;
6. Where to write to receive a copy of
"EPA/FEA 1975 Gas Mileage Guide for New
Car Buyers".
1. The label must be of a reasonable size
and consistent in format with the
illustrative examples published in the
Federal Register.
2- Manufacturers may choose to differentiate
"specific" from "general" labels by
shape, color, size or some other readily
apparent feature.
Label must be prominently displayed either
on the same window as the price sticker or
on the passenger side window or other loca-
tion approved by EPA/FEA.
A manufacturer may use either "General Labels"
or "Specific Labels", on any vehicle configura-
tion in their model line. If a manufacturer
elects to participate in the program he obli-
gates himself to place a label on every car
in his product line.
The labeling program will also include a public
education and information program.
At the present time a study is being conducted
to evaluate the effectiveness of the fuel
economy labels. The important information
from this study is on the effect on consumers
of this type of "awareness" labeling.
26
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PASSENGER CAR TIRES
A. PRODUCT:
B. AGENCY:
C. PURPOSE:
D. GRADE/RATING:
E. TECHNICAL BASIS/
CATEGORIZATION:
F. LABEL CONTENT:
G. PHYSICAL
CHARACTERISTICS:
Passenger Car Tires
National Highway Traffic Safety Administration
(DOT) (49 CFR 575}
Consumer information about tire quality
Treadwear: 2 or 3 digit number
Traction: 0, *, **
Temperature resistance: A, B, C
Treadwear: Projected mileage, based on speci-
fied test and calculation procedure, stated
as percent of 30,000 miles, rounded off to
nearest lower 1Q% value; e.g., for projected
treadwear of 47,000 miles, rating is 150.
Traction: Based on traction coefficient on
two wet skid pads, grade depends on meeting
schedule of values established for both skid
pad surfaces.
Temperature resistance: Tested on a schedule
of increasing speeds under load; grade depends
on highest speed without failure.
1. On sidewall of tire:
a. treadwear grade description and tread-
wear grade;
b. all temperature resistance and trac-
tion grades, with appropriate grades
circled;
2. On tread surface (except original equip-
ment tires on a new vehicle) and for
information furnished prospective pur-
chasers of motor vehicles and tires under
paragraph 575.6(c), an explanation of
performance area, and a history of all
possible grades for traction and tempera-
ture resistance, along with a heading
"DOT Quality Grade11.
1. Sidewall label: permanently molded with
character type, depth and size specified
2. Tread label: not easily removable,
indelibly stamped.
27
-------
H. LOCATION: i. On tire sidewall between tire's maximum
suction width and shoulder;
2. On tread surface (except original equip-
ment on a new tire).
28
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NON-PRESCRIPTION DRUGS
A. PRODUCT:
B. AGENCY:
C. PURPOSE:
D. GRADE/RATING:
E. TECHNICAL BASIS/
CATEGORIZATION:
F. LABEL CONTENT:
G. PHYSICAL
CHARACTERISTICS:
H. LOCATION:
Non-prescription drugs
Food and Drug Administration (HEW)
Content and quality Information
Standards(minimum requirements) are set by
the FDA
Labeling on the "Principal Display Panel":
1. Statement of the Identity of the
commodity (established name of the
drug) and statement of the general
pharmacological categoryties) of the
principal intended action(s);
2. Net quantity of the contents.
Labeling elsewhere on packaging:
1. Name and place of business of the manu-
facturer, packer or distributor
a. Where a drug 1s not manufactured by
the person whose name appears on
the label, the name shall be quali-
fied by a phrase that reveals the
connection such person has with
such drug: such as "Manufactured
for ", Distributed by ",
or any other wording.
2. Statement of Ingredients (as required
by Section 502(e) of the Federal Food,
Drug and Cosmetic Act) shall appear .
together.
Regulation specified:
1. Boldface type In distinct contrast to
other matter on the package;
2. Size of type (relative to other type
on package);
3. Location of net weight statement on
principal panel.
1. Statement of identity and net quantity
must appear on the "Principal Display
Panel".
2. All other required Information must(
appear conspicuously on the product's
container.
29
-------
I. COMMENTS: The most Important point to notice is: the
requirement that all specified (important)
information be prominently and conspicuously
located and that same be placed on the
"Principal Display Panel".
30
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FOOD
A. PRODUCT:
B. AGENCY:
C. PURPOSE:
D. GRADE/RATING:
E. TECHNICAL BASIS/
CATEGORIZATION:
F. LABEL CONTENT:
Food
Food and Drug Administration, HEW
Truthful information on content and quantity
of contents
Grades and standards are determined in
accordance with U.S. Department of Agricul-
ture regulations. These labeling requirements
are in addition to the USDA grades.
Labeling required on the "Principal Display
Panel":
1. Identity of the commodity:
a. name of the commodity;
b. common or usual name of the food;
c. an appropriately descriptive term;
2. For food marketed in various optional
forms, the form must be identified;
3. Net quantity of contents in the measure
specified for the particular product
or type of product (volume, weight,
count, etc.).
Labeling required on the "Information Panel":
1. Name and place of business of manufac-
turer, packer or distributor;
2. If the number of servings appears, a
statement of the net quantity of each
serving;
3. Ingredients:
a. where the proportion of expensive
ingredient(s) present has a bearing
on price or consumer acceptance,
the label of such food shall bear
a quantitative statement of such
ingredient(s);
b. imitation or artificial ingredients -
listed as such.
Labeling permitted on the "Information
Panel":
1. Nutrition information;
2. A statement of cholesterol, fat and fatty
acid content if it conforms with specific
requirements.
31
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G. PHYSICAL
CHARACTERISTICS:
H. LOCATION:
I. COMMENTS:
Specified as follows:
1. Type of letters,
2. Size (relative size) of type (minimum
sizes established),
3. Type must be in distinct contrast to
other matter on the package.
1. Statement of Identity and net weight must
appear on the "Principal Display Panel".
2. All other required labeling must appear
on the "Information Panel".
The most Important point in this labeling
requirement is the stipulation that Important
Information is to be located on the "Principal
Display Panel" and that all other required
labeling Is to be located on the prominently
located "Information Panel".
32
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MANUFACTURED OR PROCESSED DAIRY PRODUCTS
A. PRODUCT:
B. AGENCY:
C. PURPOSE:
D. GRADES/RATING:
TECHNICAL BASIS/
CATEGORIZATION:
LABEL CONTENT:
G. PHYSICAL
CHARACTERISTICS:
H. LXATION:
I. COMMENTS:
Manufactured or Processed Dairy Products
Department of Agriculture
Quality Information
U.S. Grade B, A, or AA or an equivalent
standard of quality for U.S. name grades,
if numerical score grades of a product have
not been established.
Grades are composite ratings of various
factors depending on the product, such as
flavor, appearance and body. The standards
are set forth 1n the code.
1. USDA
2. Grade
3. U.S. Department of Agriculture Inspection
statement.
1. Minimum size for the shield specified
2. Samples of approved shields are given
in the code.
On package, otherwise not specified.
It can be required that the package label,
carton or wrapper carrying official Identifi-
cation be stamped or perforated with date
packed and the certificate number or a code
number to Indicate lot and date packed.
33
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BUTTER
A. PRODUCT:
B. AGENCY:
C. PURPOSE:
D. GRADES/RATINGS:
E. TECHNICAL BASIS/
CATEGORIZATION:
F. LABEL CONTENT:
G. PHYSICAL
CHARACTERISTICS:
H. LOCATION:
I. COMMENTS:
Butter
Department of Agriculture (7 CFR 58 Subpart P)
Quality Information
U.S. Grade AA or U.S. Score 93
U.S. Grade A or U.S. Score 92
U.S. Grade B or U.S. Score 90
U.S. Grade C or U.S. Score 89
General
Flavor is the basic quality factor in grading
butter and is determined organoleptically by
taste and smell. The flavor characteristic
is identified, and together with its relative
intensity, is rated according to the applicable
classification. Body, color and salt charac-
teristics are then noted and any defects are
disrated in accordance with the established
classification. The final U.S. grade is then
established. The standards are set forth in
the code.
Same as for "Manufactured or Processed Dairy
Products".
Same as for "Manufactured or Processed Dairy
Products".
Same as for "Manufactured or Processed Dairy
Products".
Butter is graded on one technical basis
(flavor) and then is disrated for other bases
(body, color and salt) in accordance with
an established scheme, to come up with a
final U.S. grade.
34
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AGRICULTURAL SEEDS
A. PRODUCT:
B. AGENCY:
C. PURPOSE:
D. GRADE/RATING:
E. TECHNICAL BASIS/
CATEGORIZATION:
F. LABEL CONTENT:
G. PHYSICAL
CHARACTERISTICS:
H. LOCATION:
I. SPECIAL:
Agricultural Seeds
Department of Agriculture
(7 CFR Part 201)
Classification and quality Information
Class of seed
Set forth 1n code
1. Name of each kind of seed present;
2. Percent of each kind of seed;
3. Variety of seed;
4. Type of seed;
5. Word "hybrid" if hybrid present;
6. Lot .number of other Identification "I.D.";
7. Origin of seed;
8. Percentage of weed seeds;
9. Percentage of agricultural seeds;
10. Percentage of weight of Inert matter;
11. Percentage of germination for each kind
of type/hybrid;
12. Percentage of hard seed;
13. Month and year germination test was
completed;
14. "Manufacturer" - Full name and address
of either shipper or consignee;
15. Inoculated seed must show expiration
date for Inoculation;
16. Grade - Class of seed.
Not specified
Tag attached securely to the container, or
printed in a conspicuous manner on a side
or the top of the container.
The label may contain Information In addition
to that required by the Act, provided such
Information Is not misleading.
35
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J. COMMENTS: The most Important point to note 1s that
all the required Information is located
on a tag securely attached to the container
or printed In a conspicuous manner on the
top or side of the container.
It is also interesting that Inoculated
seed has something analogous to a useful
life stamped on the product.
36
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SHELL EGGS
A. PRODUCT:
B. AGENCY:
C. PURPOSE:
0. GRADE/RATING:
E. TECHNICAL BASIS/
CATEGORIZATION:
F. LABEL CONTENT:
6. PHYSICAL
CHARACTERISTICS:
H. LOCATION:
Shell eggs
Department of Agriculture (7 CFR 56)
Size and quality Information
Eggs are rated
By Quality (Grademark):
Grade AA (Fresh Fancy)
Grade A
Grade B
Grade C
Dirty
Check
By size:
Jumbo
Extra Large
Large
Medium
Small
Pee Wee
The "quality" grade Is a composite rating
of the shell, air cell, white and yolk.
The standard for Individual egg quality and
U.S. consumer grades are set forth In the
code.
1.
2.
3.
U?s! Grade Wlth1n a Sh1eldi
Size or weight class may appear (If
not must appear prominently on main
panel of carton)
Plant number may appear (If not must
be shown elsewhere oh the packaging
material).
Specified as follows:
1* Samples of approved grademarks are shown
In the code;
2. Size.
The grademark must be printed on the carton
or on the tape used to seal the carton.
37
-------
I. COMMENTS: The grading system uses and does not combine
two grades, one for quality, one for size.
The quality grading requires that certain
requirements all be met to receive a certain
grade. The size grade sets a minimum weight
per dozen, per 30 dozen, and a minimum weight
for Individual eggs at rate per dozen. Letter
codes are used.
38
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PRODUCTS COVERED BY THE "AGRICULTURAL MARKETING ACT OF 1946"
A. PRODUCT:
B. AGENCY:
C. PURPOSE:
D. GRADE/RATING:
E. TECHNICAL BASIS/
CATEGORIZATION:
F. LABEL CONTENT:
G. PHYSICAL
CHARACTERISTICS:
H. LOCATION:
I. COMMENTS:
Processed fruits and vegetables, processed
products thereof, and certain other pro-
cessed food products (requirements under
Agricultural Marketing Act of 1946)
Department of Agriculture (7 CFR 52)
Quality and size information
U.S. Grade A
U.S. Grade B
U.S. Grade C
This is voluntary grading and labeling.
The grade is a composite rating of various
factors such as appearance, ripeness,
texture, taste, etc. Standards are set
forth in the code.
Grade (2 forms of label): "Packed under
Continuous Inspection of the U.S. Depart-
ment of Agriculture - for plants operating
under continuous U.S.D.A. inspection;
Grade - contract in plant inspection;
Officially sampled date - U.S. Department
of Agriculture, Washington, D.C. - con-
tract in plant inspection.
2
3
Specified as follows:
The grade and inspection marks approved for
use are shown in figures in the code.
Not specified
Processed food has* a composite grade, having
a technical basis of both subjective and
physical parameters. Intervals are not
defined in numerical terms. Letter codes
are used. The grading and labeling is
voluntary.
39
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LIVESTOCK. MEATS, PREPARED MEATS AND MEAT PRODUCTS
A. PRODUCT:
B. AGENCY:
C. PURPOSE:
D. GRADES/RATINGS:
E. TECHNICAL BASIS/
CATEGORIZATION:
F. LABEL CONTENT:
G. PHYSICAL
CHARACTERISTICS:
H. COMMENTS:
Livestock, meats, prepared meats and meat
products (labeling as to quality, no yield)
Department of Agriculture (7 CFR 53)
Quality information
The grade is a single word code, "prime",
"choice", "good", "standard", "commercial",
"utility", "cutter", "canner", or "cull";
accompanied when necessary by a class
designation.
The quality grade is based on separate
evaluations of two general considerations:
1. The quality or the palatability -
indicating characteristics of lean,
and
2. The conformation of the carcass or
primal cut.
The standards for these evaluations are
set forth in the code.
"Official identification"
k Grade w1th1n the Sn1eld5
3. Grader's code identification letters
(outside the shield).
Specified as follows:
1. Shield with USDA and grade enclosed
(as shown in Figure 1-8);
2. The code identification letters of
the grader shall appear intermittently
outside the shield.
The composite grading system combines a
number or technical basis, including
maturity, marbling and quality. Quasi-
descriptive single-word codes are assigned
to the ratings.
40
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COTTONSEED FOR CRUSHING PURPOSES
A. PRODUCT:
B. AGENCY:
C. PURPOSE:
D. GRADE/RATING:
E. TECHNICAL BASIS/
CATEGORIZATION:
F.
G.
H.
I.
LABEL CONTENT:
PHYSICAL
CHARACTERISTICS:
LOCATION:
SUMMARY:
Cottonseed for crushing purposes
Department of Agriculture
(7 CFR Part 61)
Quality control (purity, soundness)
Basis grade 100
1. High grades are defined as those above
100;
2. Low grades are defined as those below
100;
3. Grades for American Pima cotton shall
be suffixed by the designation "Ameri-
can Pima" or by the symbol "AP";
4. Below grade 40.0 shall be designated
as "below grade cottonseed" and a
numerical grade shall not be Indicated.
Based on numerical "quantity index" (yield)
and numerical "quality index". These are
multiplied and divided by 100.
Numerical grade on certificate.
Not specified
Not specified
The most interesting point here is the
grading system.
A basis grade of 100 is set and "high" and
"low" grades relate to this. This type of
scale might be useful with a grade of 100
signifying the greatest amount of noise
energy a person can receive without being
fully "Impacted": a low grade cut-off
point is identified.
41
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WORKPLACE SIGNS (General Requirements)
A. PRODUCT:
B. AGENCY:
C. PURPOSE:
D. GRADE/RATING:
E. TECHNICAL BASIS/
CATEGORIZATION:
F. LABEL CONTENT:
G. PHYSICAL
CHARACTERISTICS:
H. LOCATION:
Workplace signs (general requirements)
Department of Labor, Occupational Safety and
Health Administration (29 CFR Part 1910)
To identify hazards
Not applicable
Symbols used should follow recognized practices
(examples given). Wording used Is qualitatively
specified (examples given).
1. Colors
2. Proportions
3. Format
4. Sign shape
5. General construction of sign. All
spelled out and referenced to ANSI or
ASAE standards.
Qualitatively specified, except in cases
of in-plant traffic signs and slow moving
vehicle emblems, which are referenced to
national standards.
42
-------
WORKPLACE SIGNS AND MARKINGS (Specific Requirements)
A. PRODUCT:
B. AGENCY:
C. PURPOSE:
D. GRADE/RATING:
E. TECHNICAL BASIS/
CATEGORIZATION:
F. LABEL CONTENT:
G. PHYSICAL
CHARACTERISTICS:
Workplace signs and markings (specific
requirements)
Department of Labor, Occupational Safety
and Health Administration (29 CFR Part
1910)
Safety
Not applicable
See subheading information below:
Means of Egress (1910.37) Wording and symbol
(arrow) spelled out;
Overhead Conveyors (1910.261) - Specific
wording "or their equivalent" must be used;
Asbestos Air Contaminants - wording specified;
Manlift Instruction and Warning Signs -
(1910.68) - approximate wording given for
instructional signs; legend specified for
visitor warning sign;
Bulk Oxygen Equipment Locations (1910.104) -
Specific words or "equivalent";
Transportation Vehicle Carrying Explosives
(1910.109) - Marked with class of explosive
or oxidizer carried. Additional warning
"Dangerous" for vehicle carrying more than
a specified weight is necessary.
See subheadings below:
Means of Egress - Size, color and design
should be readily visible and distinctive
from other signs;
Overhead Conveyors - must be erected in
accordance with ANSI Z35.1-1968;
Electromagnetic Radiation Warning Symbol
(1910.97) - Color, format, proportions,
location of space (or ancillary informa-
tion specified); ,
Asbestos Air Contaminant Caution Signs and
Labels - Sign size, letter size, style and
spacing specified for caution signs, size
and contrast of letters qualitatively
described for label;
43
-------
H. LOCATION:
I. COMMENTS:
Man!1ft Signs (1910.68) - Letter size and
color specified for Instructional signs;
letter size, shape and illumination required
is specified for top floor warning sign;
letter size, shape and contrast specified
for visitor warning signs;
Bulk Oxygen Equipment Locations - "per-
manently placarded";
Transportation Vehicle Carrying Explosives -
height, stroke, color and format of signs
is specified;
Portable Fire Extinguisher Locations
(1910.157) - means shall be provided to
conspicuously indicate the location and
intended use of extinguishers.
See subheadings below:
Asbestos Air Contaminant Caution Sipns and
Labels - location qualitatively specifiPd;
Transportation Vehicle Carrying Explosives -
Specified locations on vehicle.
More important information is specified more
ful ly.
44
-------
WORKPLACE MACHINERY
A. PRODUCT:
B. AGENCY:
C. PURPOSE:
D. GRADE/RATING:
E. TECHNICAL BASIS/
CATEGORIZATION:
F. LABEL CONTENT:
G. PHYSICAL
CHARACTERISTICS:
H. LOCATION:
Workplace machinery - tags for hazardous
conditions, defective equipment
Department of Labor, Occupational Safety
and Health Administration (29 CFR Part
1910.145)
Temporary warning of hazardous conditions
or defective equipment
Not applicable
Symbols are specified for radiation and
biohazards.
Color and format specified for some tags
("do not start", "radiation" and "bio-
hazards").
Location specified for "do not start",
"danger", and "caution" tags.
45
-------
GASOLINE
A. PRODUCT:
B. AGENCY:
C. PURPOSE:
D. GRADES/RATINGS:
E. TECHNICAL BASIS/
CATEGORIZATION:
F. LABEL CONTENT:
G. PHYSICAL
CHARACTERISTICS:
H. LOCATION:
I. COMMENTS:
Gasoline
Federal Trade Commission (16 CFR 422)
Octane information at the pump
A single number octane grade derived by
method set forth in the code and termed
"octane number".
The "octane number" is calculated from the
research octane number and the motor octane
number, which are in turn determined from
tests described in ASTM D439-70 and ASTM
02699 and D2700.
Minimum "octane number" of the motor gaso-
line being dispensed must appear on the
pump.
Specified as follows:
1. Permanently attached
2. Conspicuous
Conspicuously located on the gasoline pump.
The FTC octane number is a combination of
industry standards and a standard set forth
in the code.
PROBLEM: The octane number in car owners '
manuals at the time of the rule-making was
the research octane number. In 1974, the
auto industry came up with a symbol which
indicates the range of octane appropriate
for the vehicle. The symbol is meaningless
to the consumer since it has no obvious
relation to the number that is posted on
the gasoline pump. In 1975, the auto
industry decided to print in car owners'
manuals the research octane number, the FTC
octane number and the octane symbol, making
no mention of which octane rating is found
on the gasoline pump.
46
-------
FULL-SIZE BABY CRIBS
A. PRODUCT:
B. AGENCY:
C. PURPOSE:
i
D. GRADE/RATING:
E. TECHNICAL BASIS/
CATEGORIZATION:
F. LABEL CONTENT:
G. PHYSICAL
CHARACTERISTICS:
Full-size baby cribs
Consumer Products Safety Commission
(16 CFR 1508)
Safety, Warnings and Instructions
Not graded. Safety standards are set forth
in the code.
1. Name and place of business of the manu-
facturer, importer, distributor, and/or
seller;
2. Model number, stock number, catalog
number, item number or other symbol
expressed numerically, in code or
otherwise, such that only articles of
identical construction, composition
and dimensions shall be identical in
markings;
3. The following warning: "Caution" any
mattress used in this crib must be
at least 27-1/4 inches by 51-5/8 inches,
with a thickness not exceeding six
inches or the equivalent statement with
dimensions given in centimeters;
4. Statement of conformanee to applicable
regulations promulgated by the CPSC;
5. Assembly instructions for cribs
shipped other than completely assembled.
The instructions shall also include:
a) cautionary statements concerning secure
tightening and maintaining of bolts and
other fasteners;
b) cautionary statement on maximum height
for child using crib;
mattress size warning statement.
c)
1.
2.
3.
Size of type of warning (minimum);
Style of type of warning;
Warning must contrast sharply with the
background of the label;
Markings on crib shall be of a permanent
nature;
47
-------
5. Markings shall not be readily removable
or subject to obliteration during
normal use or when the article 1s
subjected to reasonably foreseeable
damage or abuse.
H. LOCATION: The label contents (Items 1-4) must be
clearly and conspicuously visible on the
crib under normal conditions of retail
display. The label contents (Items 1-4)
must also be clearly marked on the retail
carton.
I. COMMENTS: The label herein Is primarily for proper
assembly and use of the crib.
It Is Important to note that the code
requires that label content (Items 1-4)
be clearly visible under normal retail
conditions.
48
-------
LIGHT-DUTY MOTOR VEHICLES, HEAVY-DUTY GASOLINE ENGINES
A. PRODUCT:
B. AGENCY:
C. PURPOSE:
D. GRADE/RATING:
E. TECHNICAL BASIS/
CATEGORIZATION:
F, LABEL CONTENT:
G. PHYSICAL
CHARACTERISTICS:
H. LOCATION:
I. COMMENTS:
Light-duty motor vehicles, heavy-duty
gasoline engines
Environmental Protection Agency
(40 CFR Part 85)
Provide emission control maintenance
information
Not applicable
1. Heading - "Vehicle Emission Control
Information";
2. Full corporate name and trademark of
manufacturer;
3. Engine displacement and family;
4. Tune-up specs and adjustment (specified)
along with indication of what the trans-
mission position should be and what
accessories should be operative during
tune-up;
5. A conformance standard (specified).
1. Constructed of plastic or metal that is
permanently attached so that it cannot
be removed without being destroyed;
2. Letter shape, language and color con-
trast specified.
Vehicle-engine compartment; engines-on
engine
This kind of information label provides
not only instruction but also serves to
establish a legal basis for compliance;
hence the contents and stipulations are
pre-established and impressed more vig-
orously than for purely information
labels.
49
-------
TEXTILE WEARING APPAREL AND YARD GOODS
A. PRODUCT:
B. AGENCY:
C. PURPOSE:
D. GRADE/RATING:
E. TECHNICAL BASIS/
CATEGORIZATION:
F, LABEL CONTENT:
G. PHYSICAL
CHARACTERISTICS:
H. LOCATION:
I. COMMENTS:
Textile wearing apparel and yard goods
Federal Trade Commission (16 CFR 423)
Disclosures for care and maintenance
Not graded. Maintenance and care instruc-
tions must be given.
The maintenance and care instructions
required are those necessary for ordinary
use and enjoyment of the article.
1,
2,
Instructions for care and maintenance;
Warnings when normal care procedure
associated with that article will,
in fact, if applied, substantially
diminish the ordinary use and enjoy-
ment of the article.
Permanently affixed to a finished
article of wearing apparel;
Remain legible for useful life of
article;
For yard goods, can be permanently
affixed to finished article using
normal household methods.
Finished article of wearing apparel:
Label must be permanently attached to
article.
Yard goods:
Label must accompany goods.
The care and maintenance labeling program
has had some problems at the consumer
end. At times, finished articles of
clothing, if washed and dried according
to instructions, will shrink or run or
become misshaped. Also, when purchasing
yard goods, it is common not to receive
a care label with the goods.
50
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Section 2. Noise Labeling - General Approach
-------
SECTION 2: NOISE LABELING - GENERAL APPROACH
The labeling of consumer products 1s an area of governmental
regulation that 1s growing. Certain consumer products like motor-
cycles now have several labels, and others are proposed or under
development. Care must be taken to ensure that the consumer 1s
not confused by the clutter of different messages, symbols, and
warnings.
TYPE OF LABELS
Table 1-3 lists the various kinds of labels that are attached
to products for regulatory purposes, putting aside entirely volun-
tary manufacturer labeling. By "regulatory" 1t 1s meant that
the label Is put there In accordance with some established rule or
standard. The regulator need not be the government, nor must use
of the standard be governmentally required. Some examples in the
listed categories are:
o Governmental requirements: mandatory labeling rules
established by EPA, NHTSA, FDA, USDA, FTC, etc.
o Trade association rules: such organizations as BIA
(Bicycles), OPEI (power lawn care equipment), ARI (central
air-conditioners) allow use of seals and labels to Indicate
specific performance measures.
o Others: such magazines as Good Housekeeping and Parents
have approval programs, usually without a publicly
disclosed test basis; the Snell Foundation has a volun-
tary crash helmet standards program.
51
-------
Table 1-3
Types of Labels
LABELS ARE ATTACHED TO PRODUCTS FOR "REGULATORY" PURPOSES UNDER:
• GOVERNMENT REQUIREMENT
• TRADE ASSOCIATION RULES
• OTHER - INCLUDING SEALS OF APPROVAL OF MAGAZINE
PUBLISHERS
INFORMATION LABELING
The various kinds of labeling shown in Table 1-3 can be
further categorized, as shown in Table 1-4, as being either con-
formance labeling or information labeling.
Table 1-4
Conformance Labeling and Information Labeling
CONFORMANCE LABELING - TO CLAIM COMPLIANCE WITH GOVERNMENTAL OR
PRIVATE STANDARDS OF PERFORMANCE REGS
• LABELING OF THIS TYPE, WHICH EPA MAY DO UNDER SECTION 6
OF THE ACT, IS NOT OF INTEREST HERE
INFORMATIONAL LABELING - PROVIDES ESSENTIAL INFORMATION TO PUR-
CHASER/USER
• QUALITY GRADES • PERFORMANCE
• USE INSTRUCTIONS • HAZARDS
• LEGAL REQUIREMENTS RELATED TO THE INFORMATION LABEL
• THIS TYPE OF LABELING IS TO BE DONE UNDER SECTION 8 OF THE
ACT
The goal of information labeling is to say to the prospective
purchaser or user: "Look here for noise information about this
noise producer or noise reducer." This information must appear
to be - and indeed must be - more than self-serving, unregulated
52
-------
advertising. The label should convey the message that the con-
tents are "Government approved" or "Government checked" and thus
trustworthy and unprejudiced.
Table 1-1 listed those agencies whose labeling regulations
have been examined. Many of these agencies are responsible for
labeling more than one product category.
Label requirements have been accompanied by public-informa-
tion campaigns - sometimes undertaken by the regulatory agency
alone, as in the example shown in Figure 1-1.
The public information process Is greatly aided when industry
Itself joins in the effort. Figure 1-2 shows covers to brochures -
the right-hand one published at Government expense by the FDA, the
left-hand one, which makes very effective use of color printing,
by a large retail food chain.
The clarity of the explanations given to consumers varies.
Figure 1-3 shows the label information one should expect to find
on cheese and explains the terms used by the Industry.
Figure 1-4 shows a catalog entry that includes a noise rating
(2.9 sones). However, the explanation headed Ventilator Note is
obscure and confusing to the lay public, and indeed, to a sample
of acoustical engineers.
These same engineers also had difficulty understanding the
advertisements shown in Figure 1-5. The ventilation quietness
rating and the air conditioner sound rating are not on the same
basis and thus no meaningful comparison can be made. Further, the
quietness ratings are not readily related to the sound levels in
decibels, with which the public 1s generally familiar.
53
-------
FTC Buyer's Guide No. 6
LOOK FOR
THAT LABEL
Figure 1-1
Federal Trade Commission Awareness Notice
54
-------
. a"*
We want
youtoknow
about
c
c,
/^"""""^N
)
;
Figure 1-2
Commercial and Government Labeling Brochures
55
-------
BUYING CHEESE
CHECK THE LABEL
The labels of natural cheese, pasteurized
process cheese, and related products carry im-
portant descriptive information. The name of a
natural cheese will appear as the variety such
as "Cheddar cheese", "Swiss cheese", or "Blue
cheese."
Pasteurized process cheese labels will always
include the words "pasteurized process", together
with the name of the variety or varieties of cheese
used, for instance, "pasteurized process American
cheese" or "pasteurized process Swiss ar\d
American cheese".
Cheese food also contains ingredients other
than cheese and therefore is labeled as "pasteur-
ized process cheese food". Cheese spreads have
a different composition from cheese foods and
are labeled as "pasteurized process cheese
spread". All the ingredients used in the prepara-
tion of these products are listed on the respective
label along with the kinds or varieties of cheese
used in the mixture. Also the milkfdt and'moisture
content may be shown.
Coldpack cheese and coldpack cheese food
are labeled in the same manner as other cheese
and cheese foods except that "club cheese" or
"comminuted cheese" may be substituted for the
name "coldpack cheese".
WEIGHT
DISTRIBUTOR
CURING CATEGORY
NAME
QUALITY
Figure 1-3
Explanation of Cheese Label Contents
56
-------
Bathroom Ventilators help clear o
moisture and stale air
3 rocktr twitches
allow UMd light
wid Mower upereMy
or hnlw wMhlighl
•ml/or Mower
Lighted ceiling
Ventilator
with infrared
heater
Cuf'7
Woi
K A comfortable bathroom on cold mornings
without overheating the whole house. Heat
from two 400-watt quartz tube heaters. Light
uses four 40-watt • bulbs (not incl.). Blower
moves 90 CFM*, ventilates bathrooms up to 85
square feet. Grille measures 16%x11% in. Re-
quires 14%x10%-in. opening. Built-in plastic
damper for quiet operation.. rated at 2.9 sones.
White Lexan® plastic grille with gold-color
accent. UL listed; 110-120-v., 60-c. AC. 1020 w.<
Order vent kit from Big Book..
42 R6368-Shipping wt. 13 Ibs. 401...... .Now $02.06
Ventilator
with light
alone
Cuf*S
A Asatleftbutwithoutheat. Control light,
blower together with one light-type
switch or separately with 2 switches
(switches not incl.). UL listed; 110-120-v.,
60-c. AC. 220 w. Sone rating 2.9.
Order vent kit from Big Book.
48 R «4-Shpo. wt 12 Ibs. 8 oz.... Now *ttJ6
VENTILATOR NOTE: Ventilators are quietness
rated In eones (units of sound) by tneasurements
by Sears Laboratory tests. (4 sones twice as loud
as 2.) Noisy bathroom ventilator would be above
6.5 sones.
•CFM - Cubic tact p«r minute. :
Figure 1-4
Example of a Catalog Ad with Noise Rating
57
-------
Now, more than ever, you need an
efficient, quiet central air conditioner.
Now, more than evet; you need GE.
Efficiency Rating
918
Sound Rating
EXECUTIVE
Model
EER iCoil SRN
9.3 B8K 17
9.3 UBS 18
9.8 {8S& 18
DELUXE
Model
EER & Coil SRN
8.1 -BBS 18
8.6
8.1
8.0
8.0
8.0
18
18
18
19
19
STANDARD
Model
EER A Coil SRN
7.1 BBX 19
7.3 ftgft 19
7,2 aJSS 19
7.2 IBffiT 20
7.2 M«SS* 20
"This data is for electric split system, jir-cooled condensing units with coil
alone (type RCU-A-C) listed in the January 1974 Air Conditioning & Refrigera-
tion tnidlute Directory."
Figure 1-5
Advertisements for Air Conditioners
58
-------
NOISE LABELING UNDER SECTION 8 OF THE NOISE CONTROL ACT
The Noise Control Act of 1972 devotes all of Section 8 and
part of Section 10 to labeling. Section 8 is shown 1n Table 1-5.
Table 1-6 Is an excerpt from Section 10.
Table 1-5
Section 8 of the Noise Control Act of 1972
(Public Law 92-574) (Labeling)
(a) The Administrator shall by regulation designate any pro-
duct (or class thereof) -
(1) which emits noise capable of adversely affecting
the public health or welfare; or
(2) which Is sold wholly or in part on the basis of Its
effectiveness in reducing noise.
(b) For each product (or class thereof) designated under
subsection (a) the Administrator shall by^ regulation require that
notice be given to the prospective user of the level of the noise
the product emits, or of its effectiveness 1n reducing noise, as
the case may be. Such regulations shall specify (1) whether such
notice shall be affixed to the product or to the outside of Its
container, or to both, at the time of Its sale to the ultimate
purchaser or whether such notice shall be given to the prospective
user In some other manner, (2) the form of the notice, and (3) the
methods and units of measurement to be used, lections 6(c) (2)
shall apply to the prescribing of any regulation under this
system.
(c) This section does not prevent any State or political
subdivision thereof from; regulating product labelIng or informa-
tion respecting, products In any way not 1n conflict with regula-
tions prescribed by the Administrator under this section.
-------
Table 1-6
Section 10 of the Noise Control Act of 1972
(Public Law 92-574) (Labeling)
(a) Except as otherwise provided in subsection (b), the fol-
lowing acts or the causing thereof are prohibited:
(3) In the case of a manufacturer, to distribute in commerce
any new product manufactured after the effective date of a regu-
lation prescribed under Section 8(b) (requiring information respec-
ting noise) which is applicable to such product, except in confor-
mity with such regulation.
(4) The removal by any person of any notice affixed to a
product or container pursuant to regulations prescribed under Sec-
tion 8(b), prior to sale of the product to the ultimate purchaser.
In Table 1-7, the language of Section 8 is examined in more
detail.
The information necessary to make the determination concern-
Ing adverse effects is available, in part, as contained in the
following EPA publications: "Public Health and Welfare Criteria
for Noise" Document No. 550/9-73-002, July 27, 1973 [1] and "Infor-
mation on Levels of Noise Requisite to Protect Public Health
and Welfare with an Adequate Margin of Safety" Document No. 550/9-
74-004, March, 1974 [2].
' For example, as indicated in Note 2 (Table 1-7), a mass
transit system will expose riders and spectators to noise. Home
air conditioner noise can affect both the owner and his neighbors*
60
-------
Table 1-7
Statutory Authority
SECTION 8(a) THE ADMINISTRATOR SHALL . . . DESIGNATE ANY PRODUCT*
(OR CLASS THEREOF)
(1) WHICH EMITS NOISE CAPABLE OF ADVERSELY AFFECTING THE PUBLIC
HEALTH OR WELFARE^ ..."
(2) OR WHICH IS SOLD WHOLLY OR IN PART3 ON THE BASIS OF ITS
EFFECTIVENESS IN REDUCING NOISE"
1 "Shall'. . . designate any" Note no discretionary authority, as
in Section 6(a)(3) is provided.
2No distinction is made between "prospective users" and "spec-
tators, bystanders".
products sold explicitly for such use or with such use as
a stated possibility.
Figure 1-6 is an example of advertisements for grass seed
which incorporates a noise claim.
Table 1-8 contains an examination of Section 8(b) of the
Statutory Authority.
As indicated in Note 6 (Table 1-8), the legislative history
shows that various and sometimes more specific requirements were
part of the several noise control bills introduced in the Congress
in 1971.
As shown by Table 1-9, labeling means different things to
different people. Most of the differences come from the different
perception of labeling as seen in government, 1n industry, in the
engineering department, or in the graphics or advertising depart-
ment. Labeling is really all of those things.
61
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FYLKING!
WORLD'S FAIR
OFFICIAL GRASS
Architects, for Expo '74 World's Fair picked
0217® brand Fylking Kentucky bluegrass for all
lawn areas because of its outstanding qualities. The
World's Fair theme, "Celebrating tomorrow's fresh
new environment" makes Fylking the natural
choice. Its dense root system knits itself together
to resist weeds, requiring less chemical weed
control. FyIk ing's greater disease resistance means
less disease and little, if any, chemical treatment
for turf grass diseases. It has greater drought
resistance, can be cut low as 3/4 inch (even 1/2
inch) and thrive with less watering. Fylking ab-
sorbs carbon dioxide pollutants, gives off oxygen.
It reduces glare and radiation, cools air by releas-
ing water vapor. It fights noise pollution with
superiorsoundabsgrBiifliL&uaitijes. TyiKing grass
blades trap dyit particles which are eventually
absorbed into the soil. A vital green environmental
shield, ask for the official World's Fair grass seed
or sod, 0217® Fylking Kentucky bluegrass, at
seed and garden supply centers and sod landscape
distributors.
JYLKING KENTUCKY BLUEGRASS
U.S. Plant Paten! 2887
I "mother line product of Jacklin Seed Company
•XDO'74.sH»~uu i4.NMi.i
World's Fair
Figure 1-6
Advertisement Incorporating Noise Claim
62
-------
Table 1-8
Additional Examination of Section 8 Authority
SECTION 8(b) REQUIRES NOTICE* TO THE PROSPECTIVE USERS QF LEVEL
OF NOISED ... OR ITS EFFECTIVENESS IN REDUCING NOISE.
THE REGULATIONS MUST SPECIFY
(1) WHERE (LOCATION) - ON PRODUCT, ON CONTAINER AT TIME OF
SALE TO ULTIMATE PURCHASER - OR IF NOTICE IS TO BE GIVEN
TO THE USER IN ANOTHER WAY
(2) THE FORM
(3) THE METHOD OF MEASUREMENT AND THE UNITS OF MEASUREMENT
Table 1-9
Various Meanings of Term "Labeling"
LABELING CAN MEAN:
o THE WORDS/SYMBOL THAT PROVIDE THE IDENTITY FOR NOISE
LABELING
o THE RATING ITSELF
o THE LABEL ON THE PRINCIPAL DISPLAY PANEL - AND WHAT IS
ON THE INFORMATION (SECONDARY) PANEL
o THE TOTALITY OF THE INFORMATION REQUIRED UNDER A LABELING
STATUTE
4Not necessarily a label
5Th1s 1s not the "ultimate purchaser" defined in Section 3 (4)
6Not necessarily decibels
63
-------
Unfortunately, however, the Informative labeling such as is
being discussed sometimes is lost in the midst of other labeling
as demonstrated in Figure 1-7.
It can be concluded, as shown in Table 1-10, that, on the
basis of investigations of both technical (acoustical) factors and
graphics considerations, some basic development can be common to
labels for noise reducers and noise producers. These common fac-
tors will be described in more detail below.
However, noise reducers do not appear to lend themselves to a
common label grade, and the separation into a sound insulator and
a sound absorber category may be necessary.
Table 1-10
Common Factors for Labels
1. CAN THERE BE A SINGLE "LABEL" FOR BOTH NOISE PRODUCERS AND
NOISE REDUCERS?
Not Completely - But Many Common Elements Are Possible.
2. CAN THERE BE A SINGLE "LABEL" FOR ALL NOISE PRODUCERS?
Appears Possible.
3. CAN THERE BE A SINGLE "LABEL" FOR ALL NOISE REDUCERS?
No - Two Major Categories Appear Possible.
64
-------
en
/K M8HVUSH»K
1 IT MOVE MTEI
(UjTciAOE
f A
VjFANOfJ
TROPICAHA
KEEP REFRIGERATED
w^ FLORIDA
TROPICANA
100% PURE
PASTEURIZED
ORANGE
JUICE
SHAKE WELL BEFORE SERVIN6
JRDPICANA
OUR GUARANTEE
This product contains only
100% Pure Pasteurized
Orange Juice.
It is not made from
concentrate. No water,
sugar or preservatives
are added.
If it isn't in the Orange...
it's not in Tropicana.
P'Od:,c'v me
HETB4FL. OZS.(2QTS.)
ROPICANA
100% PURE
PASTEURIZED
ORANGE JUICE
KEEP REFRIGERATED
_ FLORIDA
TROPICANA
100% PURE
PASTEURIZED
ORANGE
JUICE
MIWTS
M^S&'E&ta.
Ex-eai-o coraunoN i»
DairyPak ^>
Division of
Champion International
MM> 1MB M. J4IH7S11412371
KEEP REFRIGERATED
_ FLORIDA
TROPICAHA
100% PURE
mSTEURIZED
ORANGE
NET 64 FL. OZS.C2QTS.) NET 64 FL. OZS.C2QTS.)
Figure 1-7
Example of Labeling Confusion
-------
MAJOR CHARACTERISTICS OF LABELS
Section 8 Identifies three major characteristics which labels
need to specify. They are:
1. Content
2. Physical Characteristics
3. Location
Each of these will be examined in turn.
Label Content
The content of the label Is of primary Importance. However,
the content of the label is restricted by two considerations:
the limits on the statutory authority and the physical space
limitations for messages of readable size and layout. Table 1-11
lists some of the more important informational elements that
should be considered for Inclusion on a noise label. First, the
noise label must identify Itself. This must be so standardized
that it Is a highly recognizable symbol. It can be a word or two
- STOP has become an International traffic sign symbol, and Is
recognized In the U.N. Convention on road signing for use In non-
English-speaking countries. To gain this near-Instant recognlza-
billty, it must always appear In the same type-face and the same
relationship - both relative size and position - on the label.
The words NOISE RATING or NR can become a symbol for a noise
producing product and Noise Reduction Rating or NRR might likewise
become a symbol for a noise reducing product.
The rating comes next. The discussion to follow later 1n
this section will Indicate the way any valid but highly technical
acoustic measure can be transformed into a simple rating for the
layperson*
Since space 1s at a premium, the next Item should tell where
information essential to getting and keeping the proper product
noise performance can be found, and also the availability of
additional Information for the technically sophisticated buyer.
The manufacturer's name and the product's Identification may
also be of high value on the noise label.
66
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Table 1-11
Content of Labels
1. HEADING - NOISE INFO SYMBOL
2. NOTICE OF PERFORMANCE
o NOISE RATING o NOISE REDUCTION RATING
3. REFERENCE TO PRODUCT INSTRUCTIONS, SPECIFICATIONS
0 USE 0 REPAIR, MAINTENANCE
0 DETAILED TECHNICAL SPECIFICATIONS
4. PROHIBITED ACTS
5. MANUFACTURER'S NAME (NOT TRADEMARK), ADDRESS
6. PRODUCT IDENTIFICATION: MODEL, BATCH
7. GOVERNMENTAL AGENCY OR U.S. GOVERNMENT SYMBOL
A prohibition against removing the label and an Agency seal
could be at the bottom. This authority symbol must be carefully
chosen, for it plays an Important role 1n the reader's mind. Con-
sumer research has shown that the public responds well to "seals
of approval" and other official symbols. As mentioned earlier, it
1s vital that the public see this label 's Information as trust-
worthy and impartially determined.
Physical Characteristics
As demonstrated 1n Figure 1-8, some seals have become well
known to the public through frequent exposure. Even though all
these seals represent the same governmental agency and are all
based on a shield shape, there are significant appearance varia-
tions that can create doubt as to which is the official one. The
EPA seal does not use a shield, and contains several symbolic
elements - none of which has strong connotations of governmental
authority.
In the highly competitive visual world of corporate identity
and product trademark advertising, many governmental agency seals
fare poorly. In the following excerpt from a U.S. Government
publication, the authors note that official seals are often filled
with obscure phrases and symbols.
67
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LAN DO LAKES8
BUTTER
FOUR QUARTERS
Distributed by LandO'Lakes. Inc. Minneapolis. MM 55413
USD/I Grades
Help You Choose
BEEF STEAKS
U5D4
'U.S. EXTRA GRADE)
aOCfSSiO tND KCXEl
tt'R INFECTION Of THE
Zu*I.
\ISDA
I Q'JMITY APPROVE
U.S.DEPT.OF ACRICULTURC
0«»PINC AND
aa/UtTYCOMTROlSERVItt
>U.S. Prime-Highest quality, most
tender, juicy, flavorful
>U.S. Choice—Most popular quality,
very tender, juicy, flavorful
»U.S. Good-Lean, fairly tender, not
as juicy and flavorful
lUSDAi
GOOD
U S.f
• Most tender-rib steaks, tenderloin,
porterhouse, T-bone, strip loin, club,
sirloin steaks.
•Moderately tender-blade chuck,
round steaks
• Least tender-arm chuck, flank
steaks
U.S. Government Printing Office, Wo.hington, O.C.
20402 - Price 10 cent*
CONSUMER AND MARKETING SERVICE
HOME AND GARDEN BULLETIN NO. 145
February 1968
Figure 1-8
USDA Seals
68
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It 1s interesting to read what the U.S. Department of Health,
Education, and Welfare has to say about seals.[3] (The new seal
appears in Figure 1-9.)
t
"Government papers quite commonly have,seals of
various descriptions because one associates seals with
important institutions. But a seal is very rarely read
by anyone."
"Here we have taken the HEW seal which appears on
all letterheads, and we have blown it up to large size.
The first thing we note is that the words on the seal
are exactly the same as those on the letterhead. Then
we find a phrase in Latin, which few of us can read.
Then there is the familiar eagle, the caduceus (a ser-
pent on a rod), which has been the medical symbol for
a long time. It is not clear exactly what the chain
means, but it must have something to do with welfare or
education. The symbolism is not clear, but it doesn't
matter, because the only real function of the seal is to
suggest Government power and status."
Appearance variations in supposedly identical seals and
obscure graphic elements are bad enough when only one governmental
agency is involved. Having various symbols for different agencies
may be even more confusing. In some ways, therefore, it would be
advantageous for there to be one Federal symbol that can achieve
and keep quick recognizabllity, even when restricted to a small
size. This would not prevent the name of the agency from appear-
ing as well. However, no such inter-agency symbol exists at
present.
Ideally, a symbol should have only one meaning, not two. For
example, It was found that the Skull and Cross-Bones "Poison-
label actually attracted children, who associated the symbol with
pirate games and TV cartoons, rather than sickness.
That's why the "Mr. Yuk" symbol shown in Figure 1-10 was
developed; children (and adults) understand it as conveying the
idea of bad taste or repulsion. It is noteworthy that this symbol
(and Its sickly green color) have been copyrighted. This was done
precisely so that It could not be legally used for other than Its
intended purpose, for example, in a game or toy for children.
The information conveyed by the label Itself is not the whole
story.
69
-------
Figure 1-9
Seal of The U.S. Department of Health, Education and Welfare
70
-------
Figure 1-10
Mr. Yuk Warning Label
71
-------
As specified in Table 1-12, additional instructions may need
to be provided to the consumer, perhaps in separate booklets,
instruction sheets, etc.
Education of the consumer about the meanings of the various
ratings is particularly important if he or she is to understand
the full message of the label. This could be done on a secondary
panel on the container, on a separate leaflet packed inside, or in
the instruction book.
The matter of consumer education about the ratings is vital.
In theory, it may be accomplished by point-of-sale displays,
advertising, or booklets. One problem is how readily this addi-
tional information reaches the consumer, and how likely it is to
be understood to the extent it will be used for purchase or use
decisions.
Sales organizations may have little stake in facilitating
consumer access to information that is not directly helpful in
boosting their products.
Table 1-12
Requirements for Additional Instructions
ALSO SPECIFIED BY REGULATION:
REQUIREMENTS FOR ADDITIONAL INSTRUCTIONS. THESE CAN COVER USE,
REPAIR, CONSUMER EDUCATION ABOUT RATING.
o USE OF PRODUCT
o REPAIR AND MAINTENANCE OF PRODUCT
0 CONSUMER EDUCATION ABOUT THE RATING
0 FURTHER TECHNICAL INFORMATION
THIS MAY NOT BE PART OF THE PRIMARY DISPLAY
72
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By Federal regulation, auto manufacturers must furnish braking,
passing distance, and tire load capacity information to buyers and
prospective purchasers. This information must be available to take
from dealer's showrooms. Without exception, manufacturers do not
combine this with their full-color brochures, but present it in a
separate, plain brochure filled with data for different models and
different optional equipment. An example is shown on the left of
Figure 1-11. Neither industry nor government is happy with this
outcome, and there appear to be few buyers who have found this
brochure, and fewer still who found it understandable and useful in
making purchasing decisions.
In contrast, the fuel economy brochure on the right of Figure
1-11 has received wide readership with good reader comprehension.
Cars of many makes are compared and the meaning of the test re-
sults is explained in simple terms. Dealers whose cars do well
often have these brochures prominently displayed in their show-
rooms or use this information in their media presentations.
Unfortunately, as demonstrated in Figure 1-12, some consumer
education literature and displays, although colorful and poten-
tially informative, are so complex that most consumers are not
likely to take the trouble to read them, let alone understand
them.
The educational purpose in Figure 1-12 is largely lost. This
explanation of USDA grading of fruit is almost incomprehensible at
first. Even after the small footnote at lower left Is found, the
diagram is still unclear.
The basic physical characteristics of a label are listed in
Table 1-13. As mentioned previously, the physical characteristics
of the label greatly affect its overall utility.
A later discussion to follow will present more about label
design, and making proper use of these characteristics.
Regulation development must consider the need to specify
physical characteristics, 1n order to ensure both readability
and permanence when exposed to the use environment.
73
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W Z It I- (J UJ O
ORMATION TAB
HICLE: II LOOK A
COUMER
A SPECIFIC
CATE
N LO
EFT
D1ST
AN
DOOR. 21
ABLE CODE
SE LETTERS.
HICLE STOPPI
CELERATION
.
ING
I
T
SE
I
A
DRIVER'
RMATION
BEL. TH
S FOR VE
D. AND
8< Z C
uj o o
2
0
5
S
tf
S
2
Uj
-j
-j
S
U4
«0
O
Q
5
o
Q
Jrf
&
s
§
i
§
o
Uj
Uj
a!
o
o
oc
CQ
Uj*
-J
1979
Gas
Mileage
Guide
Firtt Edition
September 1978
EPA Fuel Economy Estimates
Figure 1-11
Typical Automobile Brochures
74
-------
cnrmw
HtWT
AMNMNMA
RHUBARB
SAUCE
MIWPPU
6LAZI
FOR HAM
GRADE C
APPLESAUCE
CAKE
CITRUS
BELATIN
MOLD
MIXED
FRUIT
GELATIN
MOLD
MIXED
PIECES
AND
SAUCES
22"
DOWN
CAKE
SLICES \ PEACH
AND \ COBILER
SEGMENTS
WHOLE
FRUIT AND
BERRIES
HALVES
AND
REGULAR '
SHAPES
CHERRY
TURNOVER
Mftwr
PANCAKES
BLUEBERRY
MUFFINS
BOVSENBERNV
PIE
PKAi UUJt
m*
Figure 1-12
Example of Complexity in Consumer Display
75
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Table 1-13
Physical Characteristics of a Label
PHYSICAL CHARACTERISTICS OF A LABEL:
o LABEL MATERIAL
0 METHOD OF ATTACHMENT
o SHAPE AND BORDER
0 LETTERING AND SIZE
o COLOR AND FINISH
Label Location
In addition to the physical characteristics of a label, one
needs to consider where it should be placed. There exists a num-
ber of alternatives {Table 1-14), all with a number of advantages
and disadvantages, depend-ing in part on the type and size of pro-
duct, and how it is advertised, bought, and sold or offered for
use.
The location for the primary label and for the additional
information required by regulation will probably need to be con-
sidered for each product or product category. In some cases,
more than one of the locations listed may be used.
Table 1-14
Location of Labels
1. FRONT OF LABELS
2. HANG TAG ON UNPACKAGED PRODUCT
3. DISPLAY AT RETAIL
4. PRODUCT
5. PACKAGE STUFFER
6. HANDOUTS
7. ADVERTISING
8. OTHER
76
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RATING SCHEMES
Mentioned earlier was the necessity of reducing the results
of whatever valid technical test is chosen - on the basis of its
relationship to the informational needs and the accuracy and
repeatability of the procedure - to an easy to understand rating.
The principles of this process, presented in Figure 1-13 for
noise, have been applied to ratings for many familiar products;
for example, butter grades and tire mileage. Although this is
usually thought of as a single, and perhaps simple, process called
grading, it is not.
We start with a measure derived from a particular test; this
test might yield a purely physical measurement with results in
physical quantities like miles, decibels, or % butterfat. The
technical basis might be a physiological or psychological effect,
with results like the dose for a 50% lethal effect, articulation
index of X%, or the fraction of the population that would suffer a
given amount of hearing damage. In each case the result Is a
number on a continuous scale. Not all different values that can
be measured are significant, so the next step is to divide this
continuous scale into intervals that imply significant and notice-
able differences. For tire mileage, this might be 1,000 to 3,000
miles; for ratings of noise producers, this might be 3 or 5 decibels.
Up to this point the rating has retained whatever measurement
units are inherent in the technical basis (miles, decibels of
equivalent sound level, etc.). This absolute measure can be
avoided by use of an established reference point, such as 30,000
miles for tire life. Thus a 15,000 mile tire would become 50 (%)
and a 45,000 mile tire would be graded 150 (%). The reader would
see that 150 meant three times the life of the 50 grade, and the
manufacturer would not be making a statement that implied a specific
tread life under all conditions of use. Finally, one may assign
codes to the various categories, although this latter element is
fraught with considerable difficulties. Is a 90 better than a 60, if
this is a quietness rating? If an A is assigned to the best product
today, what is done when a better one is Invented five years from
now?
77
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RATINGS ARE A RESULT OF A 3-STEP PROCESS
NUMERICAL; ACOUSTIC
PARAMETERS
DESCRIPTIVE, PSYCHO-
ACOUSTIC EFFECT
CATEGORIZATION INTERVAL
REFERENCE FOR
ABSOLUTE MEASURE
ALPHABETICAL (A,B,C, , )
NUMERICAL (I, II , , ,)
(100, 90, 80 , , ,)
SYMBOL (***,,, ,)
(N,N,N , , ,)
(Q,Q,Q , , ,)
TECHNICAL BASIS
CATEGORIZATION
CODINGS
Figure 1-13
Rating Process
78
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Table 1-15 presents a summary of a possible scheme for rating
noise producers In a variety of environments.
Simple numerical coding Is used, to make comparisons easy.
Qualitative explanations of these numerical values are shown, to
make these values meaningful to the lay consumer.
Table 1-15
Example of Explanatory Part of Noise Label
NOISE RATING EFFECT
115 AND ABOVE USE OF STANDARD HEARING PROTECTION
INADEQUATE TO PROTECT HEARING OF OPERATOR
110-115 DAMAGING TO HEARING OF PERSONS EXPOSED
TO NOISE WHO ARE IN THE SAME (TYPICAL) ROOM
OR WITHIN 450 FEET OF THE DEVICE OUTDOORS
85-100 SAME EXCEPT 100 FEET
70-85 SAME EXCEPT 25 FEET
60-70 INTERFERES WITH NORMAL CONVERSATION
OUTDOORS WHEN DEVICE IS WITHIN 4 FEET AND
INDOORS WHEN DEVICE IS IN ADJACENT ROOM
50-60 INTERFERES WITH NORMAL CONVERSATION INDOORS
WHEN DEVICE IS WITHIN SAME (TYPICAL) ROOM
50 AND BELOW (See note below)
Note: Determination necessary as to the capability of products
to adversely affect public health or welfare.
79
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Section 3: Noise Labeling - Graphics
-------
SECTION 3: NOISE LABELING - GRAPHICS
The following discussion contains one possible set of solu-
tions, Illustrated in Figures 1-14, 1-15, and 1-16, to the problem
of designing a label system which will alert and inform purchasers
about the characteristics of noise generators and noise attenua-
tors. It is an attempt to present the types of considerations
necessary in the development of the graphical requirements associ-
ated with product noise labeling.
The primary objective in such development 1s to take the con-
cepts of noise rating discussed above, and to develop the graphics
for a labeling system which would be easily seen, identified, and
comprehended.
BACKGROUND
We are entering an era of environmental and safety labeling.
Some labels warn iis of hazards, from the familiar radiation sym-
bol and skull and crossbones to the less ostentatious Surgeon
General 's statement on a package of cigarettes.
Other relatively familiar labels inform us - the various
shields of the department of Agriculture, for example, are in-
tended to guide the consumer when purchasing meats, cheeses,
vegetables and other foods.
Some labels are new and complex, providing the public with
much needed information about things like emission controls, gaso-
line consumption, tire safety and energy consumption.
All of these labels, as well as other useful information
which may appear on products or packages, must compete with expen-
sive, extensively researched, and well-designed marketing oriented
graphics, and with the whole mass of visual marketing Information
used In the media.
80
-------
Noise
Rating
64
Refer to operating instruc-
tions before use. To main-
tain this rating product must
be kept in repair.
60-75
May interfere with TV listen-
ing in a room adjacent to the
device.
Manufactured by:
Cambridge Corporation
Boston, Mass.
Federal law prohibits
removal of this label.
Environmental Protection
Agency.
Figure 1-14
Noise Rating Label
Noise
Reduction
Rating
35 1
Refer to operating instruc-
tions before use. To main-
tain this rating product must-
be kept in repair.
Manufactured by:
Federal law prohibits /ir\"\
removal of this label. \9K/
Cambridge Corporation
Boston, Mass.
Environmental Protection
Agency.
J
Figure 1-15
Noise Reduction Rating Label
81
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Noise Rating Guide
120 Jet at takeoff at 200 ft.
'^•w Oxygen torch
110 J« flyover at 1,000 ft.
1 'w Rock band
Inside a subway train with
open windows
Gas lawn mower
Newspaper printing press
75 and Potentially damaging to QQ Central business district
above hearing OW (daytime)
Garbage disposal, food blender
"7 Q F reeway at 50 ft. from
pavement edge
TV-audio, vacuum cleaner at 3 ft.
60-75 May interfere with TV listen- g Q Heavy traffic at 300 ft.
ing in a room adjacent to the E lectric typewriter at 10 ft
device.
45-60 May interfere with TV listen- CQ Urban environment
ing in a room adjacent to the (nighttime)
device. Air conditioning unit at 15ft.
45 and May interfere with quiet ^.Q Suburban environment
below activities, as sleep (nighttime)
Bird calls
Environmental Protection
Agency.
Figure 1-16
Noise Rating Guide
82
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DESIGN CRITERIA
The first problem then, is to design a label system which
will stand out, overcoming visual competition. This problem is
particularly difficult in the face of the amount of information
and graphics now .on packages, and in consideration of the diffi-
culties that might be faced in causing packagers to significantly
alter their designs. The system, therefore, should be realistic
and practical.
The next problem to be considered Is the amount of informa-
tion which must be displayed on the label.
To begin with, the noise label would actually serve two sep-
arate .but related functions. For noise generating devices, they
would have to announce a "noise rating". For noise attenuators, a
"noise reduction rating" must be presented. For consistency,, both
these functions should be accommodated in a single graphic system.
A side issue, but nevertheless an important one, is the ques-
tion of whether members of the general public need more Information
than sophisticated commercial buyers. Although many purchasing
agents or plant safety managers might have a better understanding of
rioise problems than the average shopper, a range of differing
considerations would make a general assumption invalid. Thus, we
concluded that the labeling system should assume almost total
ignorance on the part of every purchaser.
CONTENT
The firstcpiece of Information that the label system must
deal with is the announcement of whether the label deals with
noise generation or attenuation.
The next element of, concern is the specific rating for the
item in question.
Tire question of what kind of rating system to use is, of
course, the major element of the label. Let us assume that one
can use numerical ratings, ranging from 40 to 120, for noise
83
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generators, and 0 to 40 for noise attenuators. The numbers would
be clearly displayed, and with the proper explanation, may provide
an effective means for product comparison on the basis of Its
specific noise characteristic.
The explanation would Include the numbers used In the system,
and an explanation of the meaning of each which could be under-
stood by the layperson. For example, the label might explain that
"100 is the level of noise Inside a subway train". It may be true
that many people have never been Inside a subway train; however,
they are able to recognize that the associated noise 1s loud.
Including the rating explanation may not be a problem on
large packages, or on large devices, but 1t can be a problem with
medium size and smaller devices and packages. (For example, there
are noise attenuators which are basically ear plugs, packaged in
containers befitting their size.) Accepting the fact that 6 point
type - which 1s one-twelfth inches high - is about the smallest
readable type, it would be Impossible to get all the Information
we have described on very small packages.
As a result of varying product sizes, consideration must be
given, on a product specific basis, as to the extent of the ex-
planation on the primary label and the possible inclusion of a
separate "Noise Rating Guide."
Several other Items which may merit Inclusion on a basic
label surface are (1) reference to the Instruction sheet or manual
that came with the product, explaining that the rating assigned
to the product was based on It being in proper operating condi-
tion, as expressed In the instruction material, (2) the name and
the location of the manufacturing plant and (3) an EPA Identi-
fication, and a statement prohibiting removal of the label before
sale.
84
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DESIGN CHARACTERISTICS :
The first design characteristic to consider 1s shape - the
Information will have to be presented on some kind of visual field.
The shield, for example, 1s commonly used to project an Image of
"official" communication. The problem Is, however, that because the
shield 1s so over-used, It has lost much of Its effectiveness as a
distinctive form. Stars or other odd shapes come to mind as the kinds
of visual formats which might attract attention. Such shapes are very
Inefficient for containing Information with the usable area being
only a portion of the total area occupied by the shape.
In line with this, the label should be visually separated
from the product or package. It should have a high degree of
contrast so that it will be easily seen, and not be confused with
the manufacturers advertising messages or other Information on
packages.
The size of the label, therefore, 1s relevant to both the
Information to be presented, and to the product or package on
which 1t will appear.
PIacement Is another key consideration. The design not only
deals with the labels themselves, but also the likely location of
the label on the package or product to Insure that 1t will be
readily seen.
Next, there is the matter of color. Color can be an effec-
tive communications tool If used properly. It can help to estab-
lish contrast and visibility, and in certain applications, to
communicate in Itself. A red traffic light, for example, communi-
cates mainly through color, and is very effective.
Typography 1s an important factor in any design, but It has
particular Importance 1n this situation. Whatever Is done must
make use of space most effectively while communicating as clearly
as possible. Type selection, therefore, has to be very precise.
85
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All of these criteria, as well as the problems outlined pre-
viously, play key roles in the development of a label *s design.
T
DESIGN DESCRIPTION
In many ways, we live in a rectangular world. The rectangle
is the most efficient shape there is in terms of information
handling. It can accommodate the maximum amount of type in the
minimum amount of space.
To add a slight note of distinctiveness, to save frayed cor-
ners, and to make handling easier, corners are generally rounded
off.
To emphasize the shape and make.the entire label a more self-
contained image, a narrow border around the label can be added.
The next step is to place the necessary information on the
field that has been created. The following discussion relates
to the development of the noise labels shown in Figures 1-14 and
1-15.
In designing the heading for a label, the question which has
to be answered is "how do you most effectively call attention to
the purpose of the label?" Instead of using gimmicks of any kind,
the answer is to announce the label 's purpose as clearly and sim-
ply as possible.
The terms "Noise Rating" for noise generators and "Noise Re-
duction Rating" for noise attenuators, are simple terms. Through the
use of Helvetica typeface, they are extremely clear. It is a very
contemporary sans-serif typestyle which has come to be accepted as a
standard of clarity around the world. '
The next major piece of information - perhaps the most impor-
tant on. the entire label - is the rating itself. This should be.
displayed in very large type - again using the same clear and easy/
to read typeface.
Continuing wHh the design of the noise labels in Figures
1-14 and 1-15, rules were used to separate the different informa-
tional elements. These rules add to the boldness of the*; overall
image and, at the same time, alert the reader to the fact that
there are separate messages to be read.
86
-------
After ,the rating number, there appears a brief statement
explaining the meaning of the rating appearing on the label. The
reference to the operating Instructions may be the next piece of
Information.
The same standard typeface should be used to Identify the
manufacturer and his location and probably a product identifica-
tion. The use of trademarks here should be avoided, since they
only add visual clutter to the label and create design problems.
The EPA symbol 1s used along with the agency's identifica-
tion. It should be noted that the use of the symbol 1s not in-
cluded as a major component of the label because 1t might be mis-
leading. Although 1t is very pertinent to the natural environ-
ment, It does not telegraph anything relating to noise or noise
control, and could therefore distract the reader from the princi-
pal message.
Again using the standard typeface, the prohibition hot to
remove the label prior to purchase 1s placed near the EPA Identi-
fication to add to the authority of the prohibition.
NOISE RATING GUIDE
The explanation of the rating system might appear in a separ-
ate "Noise Rating Guide" which may be required as a separate sheet
packed with the product, or as an inclusion in the instruction
manual. The various ratings should be prominently displayed, and
their meanings and effects closely related to them, so that there
is no confusion as to what explanations relate to what ratings.
Copies of the noise rating guide might also be designed for dis-
play at retail sales outlets.
LABEL TYPES
• ' j -.
The label can be of several different types dependent on
whether It Is to be affixed directly to the product or its pack-
aging and whether 1t Is to be permanent or temporary (to be re-,
moved .after purchase). The "stick-on" label Is probably the most
87
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common form, followed closely by the "hang tag" type. Labels can
also be directly printed on the product packaging or molded into
the product itself, provided that the design considerations dis-
cussed above are incorporated.
The label might appear In either white with black or black
with white type, depending on which format provides the highest
measure of contrast with the basic package.
For noise generators which produce* uncomfortably or danger-
ously high levels of noise, the label could be required in red and
white instead of black and white.
PLACEMENT
On packages, the noise rating label should appear on the main
(primary) display panel or panels.
To help make sure that the label is not lost on the panel,
it might be required that It be lined up with at least one edge of
the panel and that there be a distance of no less than l/8th of
the label 's height between the label and the edge of the panel.
Specifications on the size of the label with regard to the
overall panel size, should be determined on a product specific
basis.
EDUCATION
The system's ultimate success, as would be true of any de-
sign, depends in great measure on the educational materials and
publicity which surround its Introduction and use.
Through posters, folders, advertisements, TV commercials and
other public awareness programs, the public can be alerted to
the use of noise ratings.
-------
Section 4: Rating Schemes for Noise Producers
-------
SECTION 4: RATING SCHEMES FOR NOISE PRODUCERS
Certain restraints limit the range of choice for a rating
scheme to be used In connection with a Federal noise labeling pro-
gram. Some of these restraints are determined by the acoustical
nature of the kinds of equipment likely to be labeled; others may
depend on the noise ratings already selected by other groups, such
as the national or international standards organizations or equip-
ment manufacturers ' associations.
This section considers (1) the nature of the noise sources
likely to come under Federal noise labeling regulations; (2) how
sound behaves in different kinds of space according to accepted
textbook acoustical theory, (3) typical user distances and label-
noise-rating categories and (4) some possibilities for a rating
scheme.
ACOUSTIC CHARACTERISTICS OF PRODUCTS
We begin by looking at the typical noise spectra of the kinds
of products that might be labeled. In particular, we are inter-
ested in which octave bands of frequency, for each type of pro-
duct, dominate the A-weighted sound level. We next consider the
acoustical characteristics of the kind of space In which the pro-
duct is typically used, whether outdoors or Indoors, and if Indoors,
whether 1t 1s an acoustically "live" or "dead" room.
It turns out that these matters have a strong bearing both on
the selection of a noise rating scheme for labeling equipment and
on the procedure for measuring product noise.
A recent study by EPA evaluated various alternative strate-
gies for noise abatement [4]. A number of appliances and other
household products were assessed In terms of the noise exposure
for people who use the product (primary exposure) and for others
fn nearby areas (secondary exposure). On the basis of their
89
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effective Leq(24) certain products surfaced as potential candi-
dates for labeling. These products are listed In Table 1-16 to-
gether with the octave band of frequency that dominates the A-
welghted sound level, the kind of space 1n which the product Is
generally used, and the type of acoustical radiation that dominates
the noise of the device.
It can be seen that, partly because there 1s strong discrimi-
nation against low frequencies in the A-we1ght1ng but also because
the noise of many of these products Is Intrinsically strong In the
high frequencies, the A-weighted sound levels for these appliances
are determined largely by frequencies of 500 Hz or higher. The
products are about equally divided according to the kind of space
in which they are typically used, and no one kind of acoustical
radiation 1s In the majority; all must be considered. (Monopole
sources tend to behave one way; dipoles and quadrupoles, another.)
HOW SOUND BEHAVES
Sound Power Level vs Sound Pressure Level
Two basic properties of the noise from a source have been
proposed for use 1n rating schemes: sound power level and sound
pressure level. Since the use of each has advantages and dis-
advantages, the acoustic community is sharply divided as to which
1s most appropriate for product labeling.
The advantage of sound power level as a noise rating for a
source, according to the "sound power" proponents, is that it is
fixed and unchangeable. It is said that, if the sound power level
for an appliance 1s known, the sound pressure level at any loca-
tion can be calculated without much difficulty. However, this
"fixed and unchangeable" claim is valid only under certain limited
conditions.
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Table 1-16
Noise Characteristics of Indoor Household Products
Product
Humidifier
Floor Pan
Dehumidifier
Window Fan
Air Conditioner
Toilet
Dishwasher
Vacuum Cleaner
Pood Blender
Electric Shaver
Pood Disposal
Home Shop Tools
Dominant Octave Band
in A-weighted
Sound Level
500 Hz
500 Hz
1000 Hz
500 Hz
250-2000 Hz
1000 Hz
500 Hz
2000 Hz
2000-4000 Hz
4000 Hz
2000-4000 Hz
2000 Hz
Where
Used*
D
D.
L
D
D
L
L
D
L
L
L
L
Type
of
Source*
D
Q
D
Q
D
M
M
D
M
M
M
M,D
*L
M
Live room (A * 30 to 70 sabines): bath, kitchen or workshop;
Dead room (A • 100 to 400 sabines); living room or bedrooms.
monopole (or simple) source; D = dipole, Q = quadrupole.
Note: The octave-band noise spectra for average examples of these
products are given in Appendix A (of Part I of this docu-
ment), along with the same spectra to which the A-weighting
has been applied, in order to show which octave band
dominates the A-level.[5J
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The disadvantage of sound power level as a noise rating 1s
that the human ear does not respond to sound power, but rather to
sound pressure. It Is possible, for example, to make up a table
of the effects of noise on people In terms of sound pressure (or
sound pressure level), but not In terms of sound power. The reason
1s that, although the sound power of a source may be constant, the
effect of the noise on people depends on how close they are to the
source.* Near the source, the sound pressure 1s high and the effect
of the noise may be severe; as the distance from the source In-
creases, the sound pressure decreases and any adverse effects are
diminished; in fact, at great distances the sound will not be audible
at all.
The principle advantage of sound pressure for rating purposes
1s the direct relation this quantity bears to the human effects of
the noise. The disadvantage is that it is not a fixed quantity;
1t depends on such factors as product geometry, use environment,
and distance from the product. As an example, one manufacturer
may rate his product 1n terms of the sound pressure level at a
distance of 3 ft, and another manufacturer might rate his equally
noisy product with the sound pressure level at 4 ft and claim a
better noise rating.
A possible solution Is to report the sound pressure level at
a standard reference distance from the source/preferably a typical
user distance. The selection of a typical user distance for differ-
ent kinds of products, however, is currently a matter of consider-
able dispute among noise standards groups. The various arguments
that figure in this dispute are the background against which the
choice of a rating scheme for labeling must be made.
*S1milarly, although the wattage of a light bulb may be fixed, the
brightness (which our eyes respond to) is greater closer to the
bulb than far away.
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Unfortunately, without a certain amount of technical under-
standing about the behavior of sound sources, seriously wrong
choices might be made. The following discussion presents the
essential technical points to be considered.
RELATION BETWEEN SOUND POWER AND SOUND PRE.SSURE IN VARIOUS
SITUATIONS
Sound Outdoors
Sound power refers to the rate of generating acoustic energy
- i.e., the total amount of acoustical energy radiated by the
source per second. It is measured in watts. Sound power level
(Lw) is the same quantity expressed in decibels* (dB) with respect
to the standard reference power of lO'l2 watts.
w w
Lw = 10 logio TJ- = 10 loqio ig • 10 logio + 120 (1-1)
where W is the sound power of a source in watts, and Lw is the
corresponding sound power level in dB re 10'i2 watts. Doubling
the sound power increases both the sound power level and the sound
pressure level by 3 dB (see below).
The sound power accounts for all the sound energy leaving the
source in all directions. If we imagine the source as suspended
1n free space, the same amount of sound power would pass through
a 1-ft (imaginary) sphere surrounding the source as through a 10-
ft sphere. The power per unit area, however, would be less for
the larger sphere because the same amount of sound energy is
"spread thinner" over the greater surface area of the larger
sphere. The larger the sphere (i.e., the farther away from the
source), the thinner the total energy must be spread. This pro-
accounts for the decrease of sound pressure (which is what
*The decibel scale is a logarithmic scale that compresses the
enormous range of sound power and sound pressure values that
°ccur 1n the environment into a more conveniently manageable
range. The reference quantity should always be stated to avoid
misunderstanding.
93
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the ear responds to) with increasing distance from the sound
source. Sound pressure is measured as a force per unit area,
usually in newtons per square meter (N/sq m). Sound pressure
level is the same quantity expressed in dB but referenced to the
standard quantity of 20 N/sq m:
Lp • 10 loqio j| = 10 logio || = 20 logiQP - 26, (1-2)
where p is the sound pressure at a certain location in N/sq m
and Lp is the corresponding sound pressure level in dB re 20
N/sq m. Doubling the sound pressure increases both the sound
power level and the sound pressure level by 6 dB.
Sound Source Out in Space
In free space (for practical purposes this means outdoors,
away from reflecting surfaces), sound pressure level and sound
power level are related [6J as shown by line A of Figure 1-17.
Line A corresponds to the equation
d-3)
where W is the sound power of the source in watts, z is a quan-
tity called the characteristic acoustic impedance of the air
(400N"sec/m3) Q represents the directivity of the source (1 for
a point source, 3 for a dipole in the axial direction), and r is
the distance in feet from the center of the sound source (assumed
to be small, essentially a point). The decibel equivalent of
Eq. 1-3 is
Lp = Lw + 10 'logio jj- + 10, (1-4)
where Lp is the sound pressure level in dB re 20 N/m2 and Lw 1s
the sound power level in dB re 10*12 watts. The sound source
1s assumed to produce a sound power of 0.01 watts, corresponding
(see Eq. 1-1) to a sound power level of 100 dB re 10~12 watts.
Note that the sound pressure level decreases at the rate of 6 dB
for each doubling of distance from the center of the source.
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Lp-Lw + 10log I—2__\ +1Q
\ 4*r /
with Lp in dB re ?.
and Uu in dB re 10'12 wans
With W - 0.01 a; and Q - 1, the
sound pressure level equals the
sound power level at a distance
from the center of the source of
0.39 feet (- 10.7 in.) (Curve A>,
.outdoors.
50
0.1
0.2 0.3
1 235 10
Distance, r From Point Source (ft)
100
Figure 1-17
Behavior of Sound Outdoors
Sound Source Against a Reflecting Surface
Suppose the source were resting on the hard ground (or against
a reflecting surface), Instead of up 1n the air, and were still
radiating an amount of sound energy W = 0.01 watts. The radiated
energy would be spread over only a hemisphere Instead of an entire
sphere. This change In directivity of the source Increases the value
of Q to 2 and doubles the value of p2 (Eq. 1-3), corresponding to a
3-dB Increase In sound pressure level (Eq. 1-4). This behavior 1s
shown by Line B 1n Figure 1-17. The sound pressure level again drops
off at 6 dB per doubling of distance.
In fact, the sound energy radiated by real sound sources j_s
actually changed by the presence of a nearby reflecting surface,
such as the ground [7^8]. Many real-life sources behave like
"constant volume-velocity sources" (meaning that the motion of
the vibrating surface of the equipment 1s unaffected by the
95
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surrounding); for such sources, the sound power 1s doubled when
the source Is moved directly against a large, rigid reflecting
surface. In this case, the source and Its reflected Image exactly
coincide and the energy of the source Is added to the energy of Its
reflected Image, exactly in phase, so the sound power is 0.02 watts.
Therefore, in addition to the 3-dB Increase in sound pressure level
due to the changed directivity of the source when placed against the
ground, there is another 3-dB Increase, because the presence of the
ground doubles the power output. This behavior 1s shown by Line C
in Figure 1-17; Lp in this case is 6 dB higher at all distances
than with the source "out in space".*
If the source were moved away from the reflecting surface,
the source and its Image would not coincide and their two energy
components would combine less effectively, with a time lag. When
the source is more than about a sound wavelength away, the re-
flecting surface has little effect on the radiated power. This
is generally referred to as the "far field."
Other types of sound sources (some kinds of fans, for ex-
ample), react to the presence of a nearby reflecting surface with
a decrease of output [£]; this change could effectively cancel
the increase due to the directionality of the sound from the
source.
In general, then, it is clear that the sound power level is
not "fixed and unchangeable".
Sound Indoors
o Sound Source Out in Space
Sound from a source out in the center of a room behaves, 1n
the region very close to the source, just as it behaves outdoors.
The room boundaries are so far away that they do not Influence
*An even greater change, both In source directivity (+6 dB) and
power output (+6 dB), occurs when the source is moved into the
right-angle corner between the ground and a large wall, and
still a greater change (+9 dB In both cases), if it is moved
into a trihedral corner (right-angle Intersection of three
planes). Here, we confine our discussion to a single plane
reflecting surface.
96
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the local sound behavior. As the observation points move away
from the source, the sound pressure level decreases, just as 1t
does outdoors, at 6 dB per doubling of distance.
Indoors, however, the sound energy from the source 1s con-
fined by the boundaries of the room; 1f there were no sound absorp-
tive material at all In the room, the sound energy would continue to
accumulate Indefinitely, leading to higher and higher sound pressure
levels. In fact, however, some sound absorption 1s always present,
and the sound pressure builds up only to the point where as much
energy 1s being lost to the sound absorptive room boundaries as 1s
being supplied by the source. The more sound absorption 1n the room,
the lower the built-up sound pressure level.
The behavior of sound Indoors, thus, Is different from out-
doors. Near the source (the so-called "direct field"), the be-
havior Is like outdoors; the sound pressure level 1s determined
by the sound power of the source, the directionality of the source,
and the distance of the observer from the source. The sound pressure
level decreases with Increasing distance from the source (at 6 dB per
double distance), until It equals the level of the built-up sound
confined in the room. Beyond that "equalpoint", the sound pressure
level is no longer determined by the direct field, which continues to
decrease with Increasing distance.
Instead, In the region beyond the equal-point (the so-called
"reverberant field"), the sound pressure level Is more or less
the same everywhere; It Is due to the accumulated confined energy
and 1s determined only by the sound power of the source and the
amount of sound absorptive material 1n the room, not by the dis-
tance from the source or the directionality of the sound from
the source.
This two-region behavior Is Illustrated In Figure 1-18 for
three rooms containing different amounts of sound absorption.*
*Sound absorption is measured 1n sabines: the symbol Is A. One
sabine 1s roughly equivalent to 1 sq ft of open window through
which incident sound is assumed to pass and be lost to the room.
A 4-sq ft patch of material that absorbs just half the Incident
sound energy 1s said to have a sound absorption coefficient of
0.5 and to contribute 2 sabines of sound absorption to the room.
97
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100dB. Q= 1 A = 30
with Lp in dB re
and Lw in dB re 10"12 warts
50
0.2 0.3
0.5
1 235 10
Distance, r From Point Source (ft)
20 30
50
100
Figure 1-18
Behavior of Sound Indoors, Sound Source Out in Space
The upper curve corresponds to a very "live" room, containing
only 30 sabines (units of sound absorption) which might be typi-
cal of a bathroom where the sound absorption might be 25 to 45
sabines). The second curve 1s for a room with 70 sabines, typi-
cal of a kitchen where sound absorption ranges from about 50 to
75 sabines. The third curve 1s for a living room with 300 sabines.
Living rooms and bedrooms, which are usually more heavily furnished
with absorptive furniture and materials than other rooms, are rather
"dead", acoustically; typical absorptions range from 180 to 500
sabines. The lowest curve represents the level of direct-field
outdoor sound, which is masked by the reverberant sound at distances
greater than about 5 ft.
98
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The curves of Figure 1-18 correspond to the equation
= Wz
The first term is the direct sound, already encountered in Eq.
1-3 in the discussion of sound behavior outdoors; the second term
accounts for the reverberant sound in the room. If the absorp-
tion in the room is very great, the second term tends to zero,
and the sound behaves as If it is outdoors; if the distance from
the source is very great, the first term tends to zero and the
reverberant sound dominates. The decibel equivalent of Eq. 1-4
is
Lp = Lw + 10 log — - + + 10 • (1-6)
Note also that the boundary between the regions of the direct and
the reverberant sound fields, where the curve levels off, lies
somewhat nearer the source for a live room than for a dead room;
when there is lots of sound absorption in a room, the "outdoor
behavior" persists to greater distances.*
0 Sound Source Mounted in Hole in Wall
Suppose now that the sound source (for example, a window
fan) is mounted in a hole in the wall, so that it radiates half
*ts energy outdoors and half Indoors; in this case, there is no
reflected image of the source.
*Acoustics textbooks sometimes point out the fact that in real
rooms- the sound level Is not always so uniform as Is indicated
*>y the horizontal portions of the curves at the right of Fig.
1-18 and 1-19. Indeed, It is true that for narrowband sources
there will be fluctuations of sound level (up to +5 dB for pure
tones) around those curves as averages in the reverberant sound
field. However, for broadband noise spectra, for which the
use of A-welghted sound levels is appropriate, such fluctuations
are negligible. If pure tones, which would tend to increase
the spatial fluctuation of the sound level, are present, they
would also disqualify the use of the A-we1ghted sound level for
rat1ng the noise.
99
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Viewed from outdoors, the effective sound power is half the
original total sound power: W = 0.005 watts, Lw = 97 dB. Be-
cause this energy is radiated into only half a hemisphere, the
directivity is doubled (Q = 2), as when the source was resting on
the ground in the example above; but halving the sound energy
corresponds to a decrease of 3 dB. The net result is that the
sound outside the building behaves just as In free space, accord-
Ing to Line A of Figure 1-17; the presence of the building makes
no difference.
Inside the room, the sound power is also 0.005 watts, and
Q = 2, so the direct field sound pressure level will be the same
as outdoors (Line A of Figure 1-17) and also the same as the lowest
curve of Figure 1-18. However, halving the energy radiated into the
room decreases the reverberant sound pressure levels by 3 dB;
doubling the directivity does not compensate for this decrease,
because the directivity of the source has no effect on the rever-
berant sound pressure level at values 3 dB below the values shown In
Figure 1-18.
o Constant-Volume-Velocity Sound Source on the Wall or Floor
If, instead of being mounted In a hole in the wall, the source
is entirely within the room and against a hard room boundary, the
radiation is once more into a hemisphere, so Q = 2; but now the
source again coincides with its reflected image, and the sound power
is doubled: W = 0.02 watts and Lw = 103 dB.
The direct sound field (indoors or outdoors) behaves accord-
ing to Line C of Figure 1-17; it lies 6 dB above the curve for
"source out in space" at all distances.
The curves in Figure 1-18 of the reverberant field sound
pressure level for the three rooms now lie 3 dB higher, because
twice as much energy is being radiated into the room. This be-
havior for "constant-volume-velocity source against a reflector"
is shown in Figure 1-19; this figure, for the "source against a
reflector", should be compared with Figure 1-18 for the "source
out in space."
100
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W-0.02W, Lw = 103 dB, Q - 2 A = 30
/ Q 4 \
Lp- Lw + 10log I -+ —I-MO
x 4 rr r A '
with Lp in dB re
and LW in d8 re 10'IJ wans
60
20 30 50 100
Figure 1-19
Behavior of Sound Indoors, Constant-Volume-
Velocity Sound Source on Reflecting Surface
101
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Again, for the two live rooms, the sound pressure level equals
the sound power level within 2 1/2 dB, provided that the sound power
was actually measured with the source against a reflector, so that
the energy doubling 1s properly taken Into account.
o How Close Is "Close"?
The discussion so far has assumed small "point" sources and
the possibility that when a source Is "on" a reflecting surface,
It virtually lies 1n the surface and coincides with Its reflected
Image. This assumption 1s the theoretical requirement for hemis-
pherical directivity and energy-doubling when a source lies against
a reflecting surface. Actual noise makers have finite size, however,
and the effective source of the sound cannot be placed directly on a
reflecting surface. The question thus arises as to how close such
real sources must be to a reflector 1n order to realize the In-
creased directionality and energy doubling discussed above.
Figure 1-20 shows the variation in sound power output for a
single frequency, as sound sources of various types are moved
away from a large reflecting surface. Figure 1-21 shows that
the behavior 1s not much different for broadband noise spectra.
These theoretical results have been experimentally verified by
measurements of the reverberant sound levels in a reverberation
room. Note that the power output drops off rapidly as the source
moves away from the reflector: For monopole sources, when the
separation 1s 1/4 of a wavelength (1/4 ), the power 1s down to
the "out In space" value; at about 1/3-wavelength separation, the
power has fallen considerably below Its normal value. When the
separation exceeds a wavelength, the sound power has essentially
Its "out In space" value - I.e., W/WQ » 1.
The levels 1n decibels on Figure 1-20 refer to the sound
power level relative to the value with the source directly on
the reflecting surface; the reverberant sound field 1n the room
would follow these levels, as the source Is moved away from the
surface. For the reverberant sound pressure level to be within
102
-------
2.0
1.5
W/W0 1.0
0.5
\\ /
\ y \ Dipole
\ /\ \ Axis Parallel to Wall
A\ x
\ \ \ ^—^ /
N
Monopole Dipole
Axis Normal to Wall
•12d6
1 d8
0.2
0.4
0.6 0.8
1.0
Distance of Source from Wall
(Wavelengths, x/ M
Figure 1-20
Variation in Sound Power Outputs as Source
is Moved Away From Reflecting Wall
w/w,.
2.0
1.6
1.2
I J
A
0 8 U Assymptote
Forx/X»1
' .' '
Octave Band
1 - 1 - 1
0.2
0.4
x/\
0,6 0.8
Figure 1-21
Behavior of Sound Source Near a Reflecting
Surface. Not much changed by averaging over frequency,
103
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1 dB of the "source on surface" value, the source must be at a
distance less than 1/5-wavelength from the surface. The direct
sound field, however, is affected by both the energy output of
the source and its directivity; the changes in direct-field sound
pressure level would therefore be twice as great. For the direct-
field sound pressure level to be within 1 dB of the "source on
surface" value, the source must actually be within 1/10 of a
.wave-length of the surface.
Note that these observations have implications for the steady-
state test method that measures the absorption in a room by compar-
ing the nearfield sound pressure of a small source with the farfield
(reverberant) sound pressure, with the distance from the source for
the near measurement carefully fixed. The assumption underlying the
steady-state method is that the difference between nearfield and
farfield pressures depends only upon the amount of absorption in the
test room, once the method is calibrated by decay measurement of the
absorption for one room's conditions.
We have just seen, however, that the direct-field and rever-
berant sound pressures depend in different ways upon the distance
of the source from the nearest reflecting surface. Therefore,
the nearfield-farfield difference, for a given room absorption,
also depends on the distance of the source from the reflecting
surface. Not only must the distance from the source be carefully
controlled for the near measurement, but also the distance of the
source from large reflecting surfaces must be kept the same as
for the calibration of the method. The safest procedure would
be to keep the source well "out in space", away from any room
boundaries.
Returning to the kinds of equipment likely to be subject to
EPA labeling, it is of interest to determine the separation from
a reflecting surface corresponding to 1/10-wavelength for the
octave band that governs the A-we1ghted sound level. Only if the
effective center of the sound source of the equipment Is located
this close or closer to a surface will the hemispherical direc-
tivity and the energy-doubling occur. Table 1-17 gives those
104
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Table 1-17
Separation Distances "Close" to a Reflecting Surface
and "Out In Space", (ft.)
Product "Close to Surface" "Out 1n Space"
Humidifier 1.7 27
Floor Fan 2.7 27
Dehum1d1f1er 1.35 13.5
Window Fan 2.7 27
A1r Conditioner 0.6 to 5.4 6 to 54
Toilet 1.35 13.5
Dishwasher 2.7 27
Vacuum Cleaner 0.6 6
Food Blender 0.3 to 0.6 3 to 6
Electric Shaver 0.3 3
Food Disposal 0.3 to 0.6 3 to 6
Home Shop Tools 0.6 6
separation distances within which power doubling occurs (Figure
1-19) as well as the separations beyond which the source Is effec-
tively "out 1n space" (Figure 1-18). It Is clear that these pro-
ducts will hardly ever be used In such circumstances that hemispher-
ical directivity and energy-doubling will occur. Even in the case
of vacuum cleaners and lawn mowers that necessarily operate against
a surface, the surface 1s highly sound absorptive 1n the frequency
range that governs the A-welghted sound level.
Note that for low frequencies it may be Impossible for in-
door sources to get far enough away, from the room boundaries for
the energy-boosting effect to disappear entirely. It 1s often
found that the low-frequency sound power output of a product Is
substan tlally different when measured outdoors (or in an ane-
Cho1c room) than when measured in a reverberant room. This dif-
ference represents a -true difference 1n sound power output, due
to the reaction of the room upon the source. The difference
105
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may be positive or negative, depending on whether the source Is
of the "constant-volume-velocity" type (more power indoors) or
"constant force" type (less power Indoors).
At high frequencies, however, where the wavelength is small
compared to the room dimensions, so long as we confine ourselves
to broadband noise sources (no prominent single tones), there is
no significant room reaction on the source at distances more than
a wavelength or so from the boundaries. In other words, the acous-
tic impedance presented to a broadband source, in a room whose
dimensions are large compared to the wavelength, 1s the same as that
encountered outdoors.
o Inherent Directivity of the Source
The discussion so far has assumed a monopole ("simple" or
"point") source that radiates sound equally in all directions,
so long as 1t is "out in space"; for such a source, the intrinsic
value of Q is 1, and this value changes only when the source is
near a reflector. Sound sources of higher order (dipoles or qua-
drupoles, for example) have an intrinsic directivity: for a given
sound power, the sound pressure at the user *s ear depends on the
direction in which the source is pointing; the reverberant-field
sound pressure, of course, is the same as for a monopole source
of the same power.*
For such a sound source, the horizontal portions of the curves
at the right of Figure 1-18 would always be the same, as shown, but
the direct-field portion of the curve would move up or down, depen-
ding on whether the beam of the source Is pointed toward or away from
the observation point.
In practice, therefore, this difference is of concern only
for equipment for which the typical user's location is In the
direct field - I.e., equipment that Is hand-held or operator-
attended. Such products are typically moved about in use, so
*Gosele has studied a variety of hand-held products and has deter-
mined that the large majority represent source types between
simple monopoles and di poles [HI].
106
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that the sound pressure at the user's ear Is sometimes greater
and sometimes less than the average. Thus, for noise-rating pur-
poses, we can assume that the effective sound pressure, as 1t
affects the user, Is approximately the same as for a monopole
source having the same sound power, and we can continue to use
monopole curves such as those of Figure 1-18.
o General Curves Relating Sound Power Level and
Sound Pressure Level
Figure 1-18 Is not a very convenient form for general use,
because (1n order to simplify the earlier discussion) It was plotted
for a specific value of sound power level, Lw = 100 dB re 10~12
watts. (The same 1s true of Figures 1-17 and 1-19.) Therefore, we
have replotted Figure 1-18 1n general form In Figure 1-22, which
shows on the vertical scale the difference between the sound pres-
sure level and the sound power level. So long as the sound power
level 1s measured with the product 1n a location with respect to
reflecting surfaces that are typical of actual use, Figure 1-22 will
give the correct sound pressure level. No assumption 1s needed
about the effect of nearby reflecting surfaces on the relation
between sound power and sound pressure, because those effects con-
cern only the direct field of the sound source; the sources for
which the user's ear will be In the direct field are not likely
to be used "close" to a reflecting surface, as defined earlier.
TYPICAL USER DISTANCES AND LABEL-NOISE-RATING CATEGORIES
We now consider typical user distances for the various kinds
of products likely to be labeled. Such products fall Into three
categories:
A. Products used on or about the head, such as the various
electrical grooming devices;
B. User-operated tools that are hand-held or controlled
within arm's length;
C. Fixed equipment that Is not operator-attended.
107
-------
10
•10
CO
J -20
•30
-40
-50
10log ( ;
\ 4 TT r
with Lp indB. re20MN/m:
.and Lw indB re 10"11 watts
01
02 03 0.5
1 235 10
Distance, r From Point Source (ft)
20 30 50 10f
Figure 1-22
Behavior of Sound Indoors, Sound Source Out
1n Space: (Difference Between Sound Pressure Level
and Sound Power Level.)
For products In Category A, the user is always 1n the direct
sound field; for Category C, the Indoor user is practically always 1n
the reverberant field, while the outdoor user 1s usually far enough
away that the question of labeling 1s of little significance. For
Category B, the indoor user is 1n the transition region between
direct and reverberant fields; but, as can be seen from Figure 1-22,
at distances from 1 ft and an arm's length, the sound pressure level
at the user's ear is nearly the same as in the reverberant field.
108
-------
Further Inspection of Figure 1-22 reveals that, so far as the
sound pressure at the user's ear Is concerned, practically all
equipment falls Into only two label-noise-rating categories:
1. Products for which the sound pressure level is about
equal (+2 dB) to the sound power level; this includes Category A
and all of Categories B and C that are used in "live" rooms, such
as baths, kitchens and workshops.
2. Products for which the sound pressure level is about
8 dB (+2 dB) lower than the sound power level; this includes all
outdoor products in Category B and all indoor products in Cate-
gories B and C that are used in "dead" rooms, such as living rooms
and bedrooms.
Table 1-18 indicates the typical user distance category for
the kinds of products considered earlier and shows the label-
noise-rating category that would be appropriate.
For all products in Label-Noise-Rating Category 1, the num-
ber that appears on the label would be the sound power level; for
equipment in Category 2, the number on the label would be the
sound power level minus 8 dB. The sound power level In question
1s the value measured with the product in Its typical location
with respect to reflecting surfaces.
In all cases, the number of the label represents the actual
sound pressure level at the typical user's ear; thus, It may be
used to estimate the human effect of the noise, in terms of speech
interference, annoyance, etc.
CONCLUSION
At first sight, the variety of product types and the com-
plexities of sound behavior in different kinds of situations sug-
9«st formidable problems in formulating a meaningful noise rat-
Ing for labeling purposes. It turns out, however, that a con-
sideration of the manner and the locations In which the product
actually be used In practice can lead to great simplification
109
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Table 1-18
Typical User Distance Category and Appropriate
Label-Noise-Rating Category
User Distance Label-Noise-Rating
Equipment
Humidifier
Floor Fan
Dehumidifier
Window Fan
Air Conditioner
Toilet
Dishwasher (Note 1)
Vacuum Cleaner
Food Blender (Note 2)
Electric Shaver (Note 3)
Food Disposal
Home Shop Tools
Category*
C
c
C
c
c
c
c
B
B
A
B
B
Category
2
2
2
1
2
1
1
2
1
1
1
1
*A - equipment used on or about the head; b - operator-attended
equipment, used at convenient working distance, less than an
arm's length; C - equipment that is fixed and not operator-
attended.
Note 1: Includes clothes washers and driers.
Note 2: Includes all other portable food preparation equipment,
such as electrical mixers, slicers, grinders, etc.
Note 3: Includes all other personal grooming equipment, such
as barber's clippers, hair driers and stylers, electric tooth-
brushes, oral lavage, etc. Possibly, electric shavers should
occupy a special class, since they can be used very close to the
ear, and thus, according to the curve of Fig. 1-22, could impose
sound pressure levels that exceed the sound power level by 5 or
6 dB.
110
-------
It 1s, In fact, possible for a (single) number on a label to relate
directly both to the sound power output of the device and to the
human effect of the noise In terms of the sound pressure level at
the user 's ear.
The consumer needs only to be educated to know that the num-
ber on the label relates to the typical sound pressure level at
his ear, as he uses the product. Technical people, who are likely
to find the sound power level useful, will know from the text of the
labeling regulation how to relate the number on the label to the
porresponding sound power level 1n each case.
The conclusions stated above are valid only to the extent
that sound 1n real rooms in dwellings behaves according to the
acoustical theory presented 1n textbooks/1.e., there exists a
"direct" sound field near a point source, where the level diminishes
at the rate of 6 dB per doubling of distance, and a "reverberant"
field filling most of the rest of the room, where the level 1s
almost uniform. In fact, however, most kinds of products that will
be considered for labeling are large enough that within the direct
field they are not "point" sources; the attenuation with distance 1s
•"ore like 3 dB than 6 dB per distance doubled. Moreover, at
distances far from the source, real rooms do not behave like the
classical reverberant rooms of theoretical acoustics, but more like
lined ducts; again, there Is an attenuation of 3 dB per distance
doubled, rather than a uniform sound level without significant
spatial dependence.
The behavior of sound in real rooms can be Illustrated by
the preliminary measurements shown 1n Figure 1-23. These data
come from typically furnished living rooms, bedrooms, bathrooms,
kitchens, and laundry rooms, only one or two 1n each case. The
same data are plotted In two ways: once with the sound pressure
!evels for all the devices normalized to be equal at 1 ft from
the source and then with the levels normalized to be equal at 2
ft. Note that only for the electric shaver 1n the bathroom does
tne sound behave like that of a point source (6 dB per distance
doubled) and only 1n one of the bedrooms and the laundry room
does the sound level tend to a constant value at large distances.
Ill
-------
3.
8
01
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90
80
70
60
50
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• Air C
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Kitch
Hand
Blend
Windc
Clothe
Dishw
Humk
3nditioner (Bfl)
r(B) '
sn Hood Fan (K)
Mixer (K)
Br(K)
w Fan (BR)
'$ Washer (Laundry)
asher (K)
lifier(LR)
0.1 0.2 0.3 0.5 1 235 10
Distance, r From Point Source (ft)
20 30
50
100
Figure 1-23
Preliminary Results of Measurements of Sound
Attenuation vs Distance In Real Dwelling Rooms
(Using Household Devices as Sources of Sound)
Instead, on average, there Is, for most of the cases, a steady
attenuation of 3 dB per distance doubled at all distances. Since
the power level of the sources was not known, It Is not yet possible
to state a relation between sound power level and sound pressure
level similar to that of Eq. 1-3 or Eq. 1-4.
112
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APPENDIX A:
OCTAVE BANDS THAT DOMINATE THE A-WEIGHTED SOUND
LEVELS IN EQUIPMENT LIKELY TO BE LABELED
(DOMINATING LEVELS ARE UNDERLINED).
Table A-l
Octave Bands of Equipment Likely to be Labeled
Equipment
Humidifer
A-weighted
Floor Fan
A-weighted
Dehumidif ier
A-weighted
Window Fan
A-weighted
Air Conditioner
A-weighted
Toilet
A-weighted
Dishwasher
A-weighted
Vacuum Cleaner
A-weighted
Pood Blender
A-weighted
Electric Shaver
A-weighted
food Disposal
A-weighted
Shop Tools
A-weighted
Frequency
63
44
18*
50
24
40
14
57
31
52
26
(50)
(24)
63
37
48
22
45
19
42
16
60
34
53
27
125
60
44
55
39
58
42
65
49
. 70
54
60
44
68
52
53
37
50
34
38
22
72
56
58
42
250
60
52
52
44
45
37
61
53
63
55
70
62
66
58
54
46
55
47
36
28
58
50
63
55
500
59
48
4_5_ -
44
41
58
5_5
58
55
68
65
63
60
55
52
55
52
46
43
53
50
68
65
1000
52
52
44
. 44
43
11
53
53
55
55.
68
68.
57
57
58
58
59 ,
59
51
51
55
55
72
72
200
49
50
40
41
40
41
50
51
54
I5.
66
67
51
52
59
65
66.
59
60
55
56
76
II
4000
41
42
33
34
30
31
44
45
48
49
60
61
45
46
52
53
65
66
60
61
55
56
72
73
kA-weighting -26 -16
-8
-3
113
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REFERENCE FOR PART I
1. "Public Health and Welfare Criteria for Noise" EPA Document
No. 550/9-73-002, July 27, 1973.
2. "Information on Levels of Noise Requisite to Protect Public
Health and Welfare with an Adequate Margin of Safety" EPA
Document No. 550/9-74-004, March, 1974.
3. "How to See," U.S. Department of HEW (Social Security Admin-
istration) Publication (SSA) 73-10063.
4. K. M. Eldred and T. J. Schultz, "Comparison of Alternative
Strategies for Identification and Regulation of Major Sources
of Noise," February 1975.
5. "Noise From Construction Equipment and Operations, Building
Equipment and Home Appliances," EPA NTID 300.1, December 31,
1971.
6. Leo L. Beranek, Noise Reduction. McGraw-Hill Book Company,
Inc., New York 1960, p. 241, Fig. 11.9.
7. Richard V. Waterhouse, "Output of a Sound Source in a Rever-
beration Chamber and Other Reflecting Environments," J.
Acoust. Soc. Am. 30(1): 4-13 (1958). ~
8. Harry F. Olson, Acoustical Engineering. D. Van Nostrand Com-
pany, Inc., Princeton, 1975, pp. 30-31.
9. T. J. Schultz, "Sound Power Measurements in a Reverberant
Room," J. Sound Vib. 16 (1):119-129, F1gs. 8 and 9.
10. K. Gosele, "Berechnung der Luftschallabstrahlung von Maschi-
nen aus ihrem Korperschall," VDI-Berichte. Bd. 135:131-134
(1969); see also Theodore J. Schultz, "Outlook for in situ
measurement of noise from machines," J. Acoust. Soc. Am.
54(4): 982-984 (1973).
114
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SELECTED BIBLIOGRAPHY FOR PART I
Salcedo, Rodalpho N., et. al. "Improving the Communication Ade-
quacy of Pesticide Labels ~ Summary Report," under contract to
Pesticides Regulation Division, U.S. Department of Agriculture,
by University of Illinois, College of Agriculture, Champaign-
Urbana, Illinois, November 1970.
Poprlk, Maryclare and Staff. "Consumer Perception of Safety ~
A Survey," ACPE Report 1, Food and Drug Administration.
Poprlk, Maryclare and Staff. "Consumers and Food Labeling," OPE
Study, Food and Drug Administration, April 1975.
"Proceedings of the First National Symposium on Pesticide Label-
ing," sponsored by the Office of Pesticide Programs, Environ-
mental Protection Agency, June 1974.
"Preliminary Staff Study (Precis): Self-Regulation — Product
Standardization Certification and Seals of Approval," Federal
Trade Commission, Task Force on Industry Self-Regulation, 1972.
"Report to Congress; Pursuant to the Public Health Cigarette
Smoking Act," Federal Trade Commission, December 1972.
"Report to Congress; Pursuant to the Public Health Cigarette
Smoking Act," Federal Trade Commission, December 1973.
"Report to Congress; Pursuant to the Public Health Cigarette
Smoking Act," Federal Trade Commission, December 1974.
Nicholls, Charles A., and Morrison, Margaret. "Consumers Talk
About Labeling," FDA Consumer: 4-7, February 1974.
Janssen, Wallace F. "Warning: Hazardous to Children," FDA Con-
sumer: 16-23, March 1973.
Parkinson, Thomas L. "The Role of Seals and Certifications of
Approval in Consumer Decision-Making," The Journal of Consumer
Affairs; 1-14, Summer 1975.
Phone conversation with and miscellaneous written material from
Ml^ Richard Garber, National Poison Center Network, Pittsburgh,
Pa. (topic: "Mr. Yuk").
Tapanis, Alphone. "Words, Words, Words," Human Factors 7; 1-17,
February 1975.
115
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SELECTED BIBLIOGRAPHY FOR PART I (Continued)
Stessin, Lawrence. "The Hazards of Label Phrasing," New York
Times, Sunday, August 17, 1975.
"Delays 1n Establishing a Uniform Quality Grading System for
Motor Vehicle Tires," Comptroller General of the United States,
RED-75-344.
Spooner, Herbert, The Visible Word. Hastings House, New York,
1969.
Markowtiz, J., and Dietrich, C. VI. "An Investigation of the
Design and Performance of Traffic Control Devices," Bolt, Beranek
and Newman Report No. 1726.
Klnkade and Van Cott. Human Engineering Guide to Equipment
Design, McGraw-Hill Book Co., New York, 1972.
McGuire, B. J., and Vadelund, E. A. "Voluntary Labeling for
Household Appliances and Equipment to Effect Energy Conserva-
tion: Annual Report for Calendar Year 1974," National Bureau
of Standards, NBSIR 75-660, February 1975.
Dietrich, C. U. "Development of EPA Noise Labeling Regulations:
General Approach", Bolt, Beranek and Newman Report No. 3195.
Schultz, T. J. "Development of EPA Noise Labeling Regulations:
Rating Schemes for Noise Producers", Bolt, Beranek and Newman
Report No. 3196.
Fano, P. C. and Jokel, C. R. "Development of EPA Noise Labeling
Regulations: Review of Twenty-five Labeling Laws", Bolt, Beranek
and Newman Report No. 3198.
"Draft Background Document for Product Noise Labeling: General
Provisions" EPA Document No. 550/9-77-253, April, 1977.
116
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STATUTORY REFERENCES FOR PART I
P.L. 92-574 "Noise Control Act of 1972" 86 Stat. 1234
P.L. 89-92 "Public Health daarette Smoking Act"
15 USC 1261 Et. seq. "Federal Hazardous Substances Act"
15 USC 1451 Et. seq. "Fair Packaging and Labeling Act"
15 USC 2051 et. seq. "Consumer Product Safety Act"
21 USC 301 et. seq. "Federal Food, Drug and Cosmetic Act"
7 CFR: Parts 52, 53, 56, 58 Subpart P, 61, 201
16 CFR: Parts 423, 1508
21 CFR
29, CFR: Part 1910
40 CFR: Part 85
49 CFR: Part 162
39 FR 36890
117
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PART II
DOCKET ANALYSIS
-------
SECTION 1: GENERAL ISSUES
INTRODUCTION
On June 22, 1977, the Environmental Protection Agency (EPA)
published a proposed rule in the Federal Register (42 PR 31722)
to establish a product noise labeling program under the authority
of and as required by Section 8 of the Noise Control Act of 1972
(42 USC 4907).
At the time of publication, the EPA solicited written public
comment on the proposed general provision as well as all other
aspects of the proposed product noise labeling program. Public
hearings were not initially scheduled. The public comment period
for the proposed rule was originally set at 90 days with closing
scheduled for September 20, 1977. As a result of the large number
of letters received shortly after publication, the Agency decided
to schedule public hearings on the proposed rule and extended the
comment period to October 28, 1977. Hearings were held in Wash-
ington, B.C. on September, 16, 1977; in Cedar Rapids, Iowa on
September 20, 1977? and in San Francisco, California on September
22, 1977.
In all, the Agency received 735 written comments by the close
of the comment period. Ten additional comments were received
after the close of the comment period, but were pertinent, and
were considered in the analysis. The Agency took oral testimony
from 51 individuals, organizations and businesses at the three
Public hearings. Over 600 of the written comments were from pri-
vate citizens.
The oral and written comments dealing with the proposed
general provisions were each assigned a "docket" number prefixed
by 77-8. For example, entry 77-8-415 refers to the 415th comment
received by the Agency. Numbers were assigned consecutively by
121
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time and date of receipt. Comments numbered 1 through 745 refer
to written comments, while comments numbered 901 through 955 refer
to those received at the public hearings. For simplicity, only
the last three digits of each docket entry are used in this docket
analysis.
The number in parentheses following each reference to a com-
ment or commenter is the docket number.
Appendix A of this Part identifies the issues and statements
made by each commenter.
Appendix B of this Part is a complete index of all docket
entries, including the docket number, name of the person, and the
organization represented (if any).
1.1 VOLUNTARY LABELING PROGRAMS
Several commenters recommended that the Environmental Protec-
tion Agency (EPA) encourage industry to develop voluntary labeling
programs. Most of these recommendations came from manufacturers
or trade associations. The Briggs and Stratton Corporation (624)
supported voluntary programs, because of their minimum disruption
to the market mechanism, lower costs, and limited government in-
volvement. They felt that manufacturers would report noise
ratings as accurately as other product information. J. I. Case
Company (Case) (526) and Deere and Company (930) also urged
consideration of voluntary approaches, which they preferred and
would support. J. I. Case (924) testified that EPA enforcement
would not be necessary and neither would independent auditing of
test results. The company felt industry self-policing was suf-
ficient - at least in the case of his company's competitors. Case
also cited two examples where the company either received or
sent a letter complaining about the inaccuracy of noise-related
product claims. Kodaras Acoustical Laboratories (647) praised the
labeling effort but also opted for a program undertaken in the
private sector, recommending The Air Conditioning and Refrigera-
tion Institute's voluntary program as a model.
122
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The Air Conditioning and Refrigeration Institute (ARI) (729,
707, 901), emphasized the utility of the voluntary approach. ARI
suggested quite strongly that EPA should work with industry by
providing guidance for the development of voluntary labeling
actions and by offering a public education campaign to promote
understanding of the voluntary programs. Another recommendation,
offered as an alternative to mandatory labeling, was for periodic
monitoring by EPA of a voluntary industry sound-rating certifica-
tion program. ARI also explained the operation of its voluntary
labeling program.
The Home Ventilating Institute (HVI) (740) explained its
sound rating certification program at length, noting its wide
acceptance in both public and private sector circles. In HVI's
opinion, its linear scale and overall features achieve all of
EPA's major objectives for the labeling program.
The International Snowmobile Industry Association (ISIA)
(905), felt that voluntary industry labeling was the most effec-
tive means for achieving EPA's goals with a minimum of government
involvement. In order to stimulate voluntary industry efforts,
ISIA recommended various inducements: (1) dropping voluntarily-
labeled products to the bottom of the list of products subject to
mandatory labeling; (2) urging government to favor these products;
(3) providing these manufacturers with access to EPA testing
facilities; (4) supporting joint EPA-industry financing of sound
control research; and (5) positive publicity for cooperative
industries. Other ISIA comments describe their current voluntary
sound emission certification program (611) and their recent adop-
tion of a new voluntary noise labeling program (548).
Comments made by the above parties - either submitted in
writing or in response to questions at the three public hearings -
Point up certain problems affecting voluntary labeling actions.
pirst, spokesmen for ARI and ISIA indicated that certain manu-
facturers do not participate in their programs (902, 611), thereby
Penalizing cooperating manufacturers and resulting in the disrup-
tion of the market forces which will hopefully result in quieter
123
-------
products. Second, several comments about the practices of inde-
pendent testing laboratories cast doubt on the overall credibility
of a labeling program that is not tightly enforced, or at a mini-
mum, monitored by the Federal government. The prevalence of
inaccurate test results due to fraudulent activities or manipu-
lated measurements was mentioned by acoustical consultants and a
public official in the noise control area (952, 953, 954).
A third problem in the purely voluntary approach is the pos-
sibility that manufacturers will provide noise ratings in bro-
chures that are not available at the point-of-sale (902) or will
not provide the specific noise levels on labels but merely state
that the product's noise emission does not exceed a certain level
(905).
Response;
The Agency's intention to consider the possibility of volun-
tary labeling actions on a product-by-product basis is reflected
in two of the objectives of the labeling program, which are:
• "To provide accurate and understandable information
to consumers with minimal Federal involvement.
Minimal Federal involvement is to be achieved by
ensuring that the Federally imposed labeling
requirements are carefully analyzed and structured
so as to reduce the administrative, economic and
technical impacts of the Federal program as much as
possible."
• "To promote effective voluntary noise labeling ef-
forts on the part of product manufacturers and
suppliers with the anticipation that a concomitant
reduction in product noise may occur due to market
demands."
Section 8 of the Noise Control Act of 1972, however, makes
it clear that the Agency is required to promulgate regulations
designating and labeling ". . . any product (or class thereof)
which emits noise capable of adversely affecting the public health
or welfare" and ". . . any product (or class thereof) which is
sold wholly or in part on the basis of its effectiveness in reduc-
ing noise." While the Agency will consider voluntary labeling
action as a potential alternative to the implementation of this
non-discretionary duty, a voluntary program would have to satisfy
124
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the Agency's important goals before it could be accepted as a
feasible alternative to Federally-mandated labeling. Lack of
label uniformity, noncompliance by a large segment of an industry,
inter-industry variations in noise rating schemes, and the prob-
lems raised by commenters represent some of the possible limita-
tions of a voluntary labeling program as a vehicle to accomplish
the two other objectives of the program:
• "To provide accurate and understandable information
to product purchasers and users regarding the
acoustic properties of designated products so that
meaningful comparisons with respect to noise
emission or noise reduction can be made as part of
purchase or use decisions."
• "To promote public awareness of product specific
contributions to the environmental noise problem
and to foster an understanding of associated ter-
minology and concepts."
Nevertheless, the EPA continues to fully support the develop-
ment and implementation of voluntary noise labeling by product
manufacturers. The final rule encourages the development of
voluntary labeling programs and deliniates the minimal elements
that the Agency considers essential to any voluntary noise label-
ing program. These elements are not intended to be a comprehen-
sive outline for the structure of a voluntary program that EPA
would definitely accept as a substitute for Federal labeling.
Rather, the list presents the basic requirements that the Agency
believes should be in an effective voluntary noise labeling pro-
gram if it is considered as an alternative to Federal labeling.
The Agency will consider a voluntary labeling program in lieu
°f mandatory noise labeling requirements for a particular product
a case-by-case basis.
Major Elements of Adequate Voluntary
Noise Labeling Programs
Participation - Uniform participation by all manufacturers
or by a high percentage of the total market of a particular
product.
125
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2. Measurement Methodology - A uniform methodology which gives
accurate and meaningful data.
3. Acoustic Descriptor
A. Noise Emitting Products - Sound pressure in dBA at 1
meter in 1 dB increments (may be obtained by converting
sound power levels or sound level data taken at other
distances using a recognized standard method).
B. Noise Reducing Products - Meaningful numerical rating of
product's noise attenuating or absorbing capability.
4. Minimum Label Content
A. The term "Noise Rating" or "Noise Reduction Rating"
B. Acoustic Descriptor
C. Comparative Information - supplied by the industry, com-
piled from manufacturer's periodic data reports (depend-
ing on the product)
(,.
5. Label Format and Graphics
A. Prominence of acoustic descriptor and the term "Noise
Rating" or "Noise Reduction Rating".
B. A label shape dissimilar to the EPA noise label.
C. An Industry-wide uniform label shape for a particular
product or class of products.
6. Label Placement and Size - Readily visible to consumers at
time of sale, taking into consideration various ways in which
the product may be marketed.
7. Compliance Program - Incorporating product testing and the
review of test reports, labels and associated marketing
literature, and provisions for rectifying improper labeling.
8. Reports - Periodic reports (depending on the product) to the
EPA which 'include the status and effectiveness of the program
and a compilation of the labeled values for all labeled
models.
9. Availability of Data - Availability to the EPA of all data/
test reports, and other documentation related to the program.
126
-------
The EPA encourages product manufacturers or trade associa-
tions to communicate with us to discuss any aspects of voluntary
noise labeling, and will assist industry in developing those
programs.
1.2 STATUTORY AUTHORITY
1.2.1 Questions Concerning the issuance of General
Provisions before Product-Specific Regulations
An industry (622) (General Motors), a trade association
(590), and a private citizen (621) questioned the appropriateness
of promulgating the general labeling provisions before the prod-
uct-specific regulations. One argument was that this sequence of
actions was illogical. The Outdoor Power Equipment Institute
(590) seemed to feel that both the general provisions and product-
specific regulations must be considered in tandem, and therefore
no useful purpose is served by issuing the general provisions
before the product-specific regulations. The commenters wanted to
be certain they could comment on the General Provisions and also
on product-specific regulations, if the Agency proposed specific
Product regulations affecting their industry. The General Motors
Corporation (622) indicated that its comments on the General
Provisions should be considered in future product-specific rule-
making. General Motors also claimed there were difficulties
in selecting a label format before deciding upon the product and
the relevant information to be included on the label.
One commenter (621) felt that the proposed standards create
confusion and procedural dilemmas when implemented for a particu-
lar product, since they neither apply to a specific product nor
to all products in general. He also was of the opinion that each
Product had to be considered separately in terms of its noise
emission properties, applicability to testing procedures, etc.
A second argument was that EPA had no authority to issue the
General Provisions. The commenter (621) maintained that Section
8 gave the Administrator authority to promulgate labeling regula-
tions only with respect to products which emit noise "capable of
127
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adversely affecting the public health and welfare, or which are
sold on the basis of their effectiveness in reducing noise." He
asserted that until such product-specific regulations were pro-
mulgated, no authority exists to require labeling. A similar
position was adopted by a major industry (622), which thought
specific products had to be chosen before labeling requirements
were enacted.
Response;
The Agency believes that the issuance of these General Provi-
sions for product noise labeling is logical and advantageous both
to the general public and to industry. The Agency did not wish
to re-propose many of the same regulatory elements in each of its
product-specific labeling actions, and so it decided to propose a
set of labeling requirements that would apply to all products that
might be labeled in the future. Since a product-specific regula-
tion will clearly delineate any exceptions to the General Provi-
sions, there should be no confusion in using the General Provi-
sions and product-specific regulations in tandem.
The Agency's also intended the General Provisions to provide
guidance to the general public as well as to all potentially
affected parties as to the general nature and intent of the
proposed noise labeling program. The response to the docket
attests to the success in generating comments from the public and
numerous potentially affected industries. These comments have
helped the Agency to shape its overall noise labeling regulatory
program to be both effective and reasonable, and to anticipate
many of the technical problems that may occur in the development
of product-specific labeling regulatories. At the same time/
product manufacturers and suppliers are afforded additional time
to prepare for possible Federal noise labeling action and to
consider the formulation of voluntary labeling programs.
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Another rationale for issuing the General Provisions concerns
the need for label uniformity in order for the program to be
effective. The Agency believes that consumers will be more likely
to notice the labels and to learn how to use them effectively if
they are similar in format and require the use of approximately
the same cognitive skills across different product classes.
Regulatory provisions that are not amenable to generalization
across all products, such as testing methodologies, have not been
specified in the General Provisions and will be addressed in prod-
uct-specific regulations.
The General Provisions were proposed concurrently with prod-
uct-specific labeling provisions for hearing protectors. Both of
the proposed regulations appeared in the same issue of the Federal
Register.[11 The General Provisions were proposed as Subpart A to
40 CFR 211, and the product-specific hearing protector require-
ments as Subpart B. The General Provisions were proposed and will
exist, therefore, as part of the regulatory requirements for the
labeling of hearing protectors.
The Agency's authority for their proposal and promulgation
clearly exists within the authority granted the EPA in Section 8
(a) and (b) for the labeling of products "... sold wholly or in
Part on the basis of (their) effectiveness in reducing noise."
In the case of future product-specific regulatory actions,
industry and the general public will have the opportunity to com-
ment on all aspects of the regulation affecting a given product.
1-2.2. Determining if a Product is Capable of Adversely
Affecting the Public Health or Welfare
Several commenters representing manufacturers or trade asso-
ciations expressed different concerns about the process of deter-
mining what products were capable of adversely affecting the
Public health or welfare.
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One comment appeared to reflect some confusion about what
kind of impact constituted an adverse effect on the public health
or welfare. The contention made by Deere and Company (Deere)
(930) and the Compressed Air and Gas Institute (CAGI) (910) was
that the legislative history of the Noise Control Act demonstrates
that Congress wanted to focus attention on those products poten-
tially damaging to health or hearing. Two auto manufacturers -
Renault and Peugeot (262, 278) - asserted that passenger car noise
does not constitute a health hazard, and thus the labeling program
can only be directed at the level of comfort of the occupants -
which is impossible to evaluate in relation to interior noise.
Other commenters reiterated this concern about the interpre-
tation of "adversely affecting public health and welfare." The
Association of Home Appliance Manufacturers (AHAM) (629) doubted
if Section 8 of the Act gave EPA the authority to require labeling
on a product which might constitute a hazard to hearing only when
evaluated "in the context of cumulative exposure," which it deemed
to be a vague phrase. AHAM, the Hoover Company, and Kirby Vacuum
Cleaners (629, 648, 906) - each claiming their products cannot be
shown to adversely affect public health or welfare - implied EPA
was overstepping its authority by requiring labels on products
which emit noise that is only occasionally annoying. Deere and
Company expressed a great deal of concern about the difficulty of
establishing the meaning of "health and welfare," and about the
possibility of EPA's selecting products for regulation when an
adverse impact could not be demonstrated. Deere maintained that
this latter situation requires factual evidence that a (product's)
capability for adverse effects exists (930). Deere (738) also
expressed concern that the language of the General Provisions
could be used to move beyond EPA's labeling authority in selecting
products. Deere urged that the Preamble be written to clearly
narrow EPA's product selection discretion.
Another question raised with respect to this issue area is
the type of proceeding required to make this determination about a
product. According to the Ford Motor Company (Ford) (907) and the
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Vacuum Cleaner Manufacturers Association (VCMA) (651), the deci-
sion about whether or not a product "adversely affects the public
health and welfare" requires a rule-making proceeding. VCMA made
reference to the Administrative Procedure Act, 42 U.S.C. Section
4905(c)(2) and 4907 (b), while Ford cited the statutory language
of Section 8 as the basis for this observation. In the opinion of
the Hoover Company and VCMA (648, 651), the outcome of any future
proceedings could be prejudiced by the negative publicity given to
vacuum cleaners in the public hearings and in EPA's published list
of appliances considered for labeling.
Response;
In accordance with the statutory language in Section 8
governing noise-producing products, the Agency will make a fac-
tually-supported decision as to the capability of a product's
noise to adversely affect public health or welfare before promul-
gating final regulations. The Agency will, in fact, make this
determination in a rule-making proceeding - namely, the notice of
Proposed rule-making for each individual product.
In deciding whether or not a product is capable of affecting
the public health or welfare, the EPA will rely in part on the
factual evidence in the following documents published by the
Agency: "Public Health and Welfare Criteria for Noise," EPA
550/9-73-002 [2]; and "Information on Levels of Noise Requisite to
Protect Public Health and Welfare with an Adequate Margin of
Safety," EPA 550/9-74-004 [3] . The Agency disputes the conten-
tion or implication that the public health or welfare can only be
adversely affected by noise at a level where hearing damage
is produced. It is evident that this definition of public health
and welfare is overly restrictive. The Agency believes a more
aPpropriate definition is afforded by the World Health Organiza-
tion, which states that health and welfare is "... complete
Physical, mental and social well-being and not merely the absence
°f disease and infirmity." [4]
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Based on this definition and findings in the above studies,
it is clear that noise-induced annoyances, such as interference
with sleep, speech, and excessive cumulative noise exposure can be
considered adverse effects on the public health or welfare. It is
also evident from the statutory language in the Noise Control Act,
as well as its legislative history, that Congress did not intend
to restrict the labeling program only to products capable of
producing hearing loss.
The above claims as to whether or not the noise from a par-
ticular product is capable of adversely affecting public health or
welfare cannot be addressed at this point but will be considered
in any product-specific regulatory action taken with respect to
those products. Finally, the Agency does not agree that negative
comments made about a product's noise properties at the public
hearings unfairly prejudices future proceedings, because one pur-
pose of the public hearings was, in fact, to solicit the public's
feelings about what products disturbed them most. The Agency also
disputes any charge that its public information activities have
unfairly prejudiced the determination of a product's capability to
adversely affect the public health or welfare, since this deter-
mination will be made using objective health effects data and
studies.
1.2.3. Relationship Between Actions Taken Under
Section 6 and Section 8
Several commenters, representing major industries, made
assertions about the implementation of Sections 6 and 8 with
respect to the same product. Counsel for the Compressed Air and
Gas Institute (910) expressed the opinion that once a product fell
under Section 6 emission standards, it would be "inappropriate" to
proceed to Section 8 mandatory labeling, except in the cases of a
few products with high noise-emission levels. The Chrysler Cor-
poration (672) felt that labeling could not be required for prod-
ucts designated under Sections 5 and 6, because they had already
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been rendered safe by the latter action - the mandatory emission
standards. The Ford Motor Company (907) expressed a different
concern - that Section 8 could be used to impose regulatory
enforcement and to avoid the procedures for identifying a product
as a major noise source under Section 6. Deere and Company (738)
suggested that labeling under Section 8 would be appropriate for
products identified as major (Section 5) noise sources in the
event a noise emission standard (Section 6) was deemed infeasible.
Response;
There is no statutory language in the Noise Control Act to
support the argument that Section 6 and Section 8 are mutually
exclusive with respect to EPA implementing regulations governing a
given product. The Agency believes the Act and its legislative
history demonstrate conclusively that EPA's authority to regulate
products under each Section is independent of the other. There-
fore, there is no reason to believe that a product cannot be
subjected both to noise emission regulations under Section 6 and
labeling action under Section 8. In fact, implementation of both
Sections might be quite rational for certain products where Sec-
tion 6 action (as limited by technological feasibility) lowers
the emission level to the point where the danger of immediate
hearing loss to operators is reduced but not eliminated. In these
cases, Section 8 labeling may be necessary to inform potential
Purchasers/users that there _rs this danger of immediate hearing
loss with use of the product. For this reason the Agency dis-
agrees with the assertion that the implementation of mandatory
emission standards under Sections 5 and 6 renders a product safe
and therefore makes labeling under Section 8 unnecessary. The
noise emission standards established under Section 6 are often
determined by available technology and the costs of product noise
abatement, and therefore the product may not necessarily have been
rendered safe and could still be capable of adversely affecting
the public health or welfare.
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1.2.4 General Criticisms of EPA for Exceeding its Authority
A number of industries (622, 671, 672, 745) commented that
the proposed General Provisions went beyond the authority set
forth in Section 8 of the Noise Control Act, and were in conflict
with the intentions of Congress. The Industrial Safety Equipment
Association (ISBA) (745) argued that the provisions were legally
unsound and may be unconstitutional under Section 10 of the
Administrative Procedure Act (5 USC 706) (2).
Response;
The statutory language in Section 8 of the Noise Control Act
of 1972 is fairly clear on the authority and the duty of the
Agency to promulgate regulations requiring the labeling of "...
any product (or class thereof) which emits noise capable of
adversely affecting the public health or welfare" and M . . . any
product (or class thereof) which is sold wholly or in part on the
basis of its effectiveness in reducing noise." The Agency feels
the proposed General Provisions are within the purview of Section
8 and are consistent with the intent of Congress as expressed in
the legislative history of Section 8.
1.2.5 Miscellaneous Issues
Three other issues were raised by comments from the Ford Motor
Company (643), the Compressed Air and Gas Institute (910), and
Deere and Company (930).
• Ford contended that Section 8 applies only to new prod-
ucts according to the Act's wording and its legislative
history. The Draft Background Document (EPA 550/9-77-
253) [5J, however, stated that the product need not be a
new product.
Response;
The Noise Control Act includes definitions for .the
terms "product" and "new product". Both terms are used
throughout the Act with apparent discrimination. Al-
though the prohibitions of Section 10 apply, with
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respect to labeling, to "new" (unsold) products (title
never transferred to ultimate purchaser), the language
of Section 8 explicitly uses the term "product" (any
manufactured article or goods or component thereof).
The Agency believes that its authority to require
labeling under Section 8, therefore, is not necessarily
limited exclusively to new products.
• CAGI considered it inappropriate for EPA to propose
noise regulations for those products that are exclu-
sively produced for use in environments subject to
existing Occupational Safety and Health Administration
(OSHA) noise regulations, preferring action under Sec-
tion 4(c)(2) of the Noise Control Act.
Response:
The EPA has and will continue to coordinate its noise
regulatory activities with OSHA and other Federal
agencies so as to eliminate conflicting and redundant
actions. It must also, however, evaluate the need for
regulatory activity for particular products based on all
relevant factors, particularly those involving protec-
tion of the public health or welfare. It is the feeling
of the EPA, therefore, that it is totally inappropriate
for it to preclude consideration of a product, as is
suggested, based solely on the fact that that product is
the focus of another agency's actions.
• Deere and Company felt that EPA was over-extending its
authority by possibly justifying the selection of pro-
ducts on the basis of individual ('the public') percep-
tions.
Response:
Section 8 is quite clear as to the EPA's authority -
and nondiscretionary duty - to promulgate regulations
requiring the labeling of noise-emitting products
capable of adversely affecting the public health or
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welfare. Notwithstanding the broad product selection
authority, the Agency must obviously use additional
criteria to determine which particular products, already
within the Agency's authority to label, should be con-
sidered first for labeling action. The Agency believes
that public attitudes toward a product's acoustic
performance definitely represent one of many important
product selection criteria affecting this decision.
1.3 PROLIFERATION OF PRODUCT LABELS
A number of commenters expressed concern about the prolifera-
tion of labels on products (197, 648, 940, 949, 622, 629, 621,
907). The General Motors Corporation (General Motors) (622) and
the Association of Home Appliance Manufacturers (AHAM) (629) were
particularly concerned about safety labels being over-shadowed by
noise labels. General Motors felt that individual products should
be examined prior to requiring that a label be placed on a product
to determine whether space is available for a noise label.
Numerous groups stressed the need for some coordination be-
tween different agencies' labeling programs (589, 590, 907, 949).
The Ford Motor Company (907) urged "EPA to become the lead agency
in proposing and establishing a Federal Interagency Product Label-
ing Review Committee with responsibility for achieving the neces-
sary simplification and coordination of the assorted labeling
requirements for motor vehicles." Whirlpool Corporation (589)
wondered if the government would be able to coordinate and priori-
tize the total labeling effort.
Response;
Aware of the problems that could result from different
Federal labeling actions affecting the same product, the Agency is
looking into possible labeling conflicts and the problem of label
proliferation. Of course, the seriousness of this problem is a
function of the particular product, and so the Agency's analysis
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of this matter will occur on a product-by-product basis. Where it
is possible to avoid these problems without sacrificing the impor-
tant goals of the Noise Control Act, the Agency will include
appropriate language in the product-specific subparts.
1.4 AUDIENCE ADDRESSED
Comments concerning the intended audience stemmed predomi-
nantly from industry. Confusion was expressed about the use of
the words "prospective user" and "ultimate purchaser" in Section 8
of the Act. Certain industries seemed particularly concerned
about EPA's interpretation and its effect on subsequent regula-
tions. Deere and Company (738) offered the opinion that, since
the user is most often the purchaser, EPA can direct the program
at the purchaser without violating statutory language.
1.4.1 Question of Labeling Individual Products Sold
in Bulk to Industry
Bilsom International, Inc. (380), felt that, with respect to
their hearing protector product, the label requirements repre-
sented a distortion of the intended audience since 95 percent of
their purchases are made by large companies who buy products for
their employees and not by the individual end-user. Thus it is
the company representative who needs noise information the most.
These persons tend to purchase ear protectors on the basis of
sales literature, consequently a noise label on the product would
be of relatively little use. Bilsom also argued in favor of re-
Placing the word "label" in the regulation with the word "notice,"
allowing greater flexibility in how the information is dissemi-
nated.
In contrast, an official of the Environmental Noise Program
of Metropolitan Washington Council of Governments (901) stated,
with respect to hearing protectors, that it was important to
educate both the purchaser and the user.
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Response;
The Agency realizes the need to relate its labeling require-
ments to the methods of marketing and distribution for a partic-
ular product. It is also fairly clear that there may be problems
caused by the applicability of certain labeling requirements to
products sold in bulk to industry. Therefore, the Agency may
adjust (on a product-by-product basis) labeling requirements for
a particular product or class of products in order to most effec-
tively use existing marketing and distributing procedures.
1.4.2 Imbalance Between Audience Sophistication and
Acoustic Information on Label
An acoustical expert (952) stated that present noise labels
showing laboratory derived ratings on certain noise attenuating
products such as construction materials are useless to engineers
or designers in light of the difficulties of rating the many
different products. An EPA developed uniform rating method would
certainly help (also see Section 3.2 of the Docket Analysis.) In
relation to some sound-reducing materials, the average homeowner
does not constitute a sizable portion of the market. He noted
that in some circumstances, such as ceiling tile, a single number
rating might, however, be beneficial to the individual consumer.
Response;
It is apparent that the information on the label, including
the noise rating, must be based on the nature of the audience and
the ability to convey useful information to the purchaser of the
product. These concerns will be of primary consideration in the
Agency's formulation of product-specific labeling requirements.
The Agency may at times require that notice of a product's noise
level be given to the ultimate purchaser in a form other than a
label, either in lieu of or in addition to a label. The Agency
is not interpreting the word "label" narrowly.
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1.4.3 Duration of Notice Requirement/The Case of Rental Equipment
The Chrysler Corporation (672) discussed the issue of the
thrust of the original Act with respect to the intended audience:
"It appears that the Act was not intended to cover noise labels
notifying prospective users for an indefinite period of time after
purchase by what may well be a third party." Their arguments are
that "prospective user" and "ultimate purchaser" are used inter-
changeably in Section 8, and that the only prohibited act pursuant
to Section 10(a)(4) is removal of the label prior to the sale of
the product to the ultimate purchaser. The noise label should
thus be necessary only for the ultimate purchaser. They also
asserted that EPA should not be allowed to require the inclusion
of maintenance information or "tampering" warnings with the pro-
duct, for the obvious reason of the label's limited duration.
The American Rental Association (552, 908) expressed similar con-
cerns with respect to the confusion of ultimate purchaser and
Prospective user. For their products, the two terms refer to dif-
ferent persons. The equipment rental business is the purchaser,
but is the user only if such term refers to the use of equipment
as rental inventory. This is clearly an important issue in the
case of rental equipment, since this would affect the form a noise
label must take. Continued use of their products will lead to
label destruction. (Issue of temporary versus permanent labels
discussed in Section 5.2 of the Docket Analysis). Based on Section
10 of the Act, in which Congress only prohibited the removal of
the label prior to sale, they argue that Congress did not intend
for each prospective user to receive notice of the product's noise
level.
Responset
The EPA recognizes there is a need for further clarification
concerning the distinction between the "ultimate purchaser" and
"prospective user" as these terms apply to the intended audience
for the labels of certain products. The EPA believes that the
terms "prospective user" and "ultimate purchaser" were used with
discrimination in Section 8 of the Act, and that the Congressional
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intent was to require that notice be provided to the users of the
labeled product; users being those subject to the noise emitted by
the product, or those realiz.ing the effects of the products' noise
attenuating capability. Recognizing this distinction, the EPA
will pattern requirements for label form and label placement on
a product-by-product basis, taking into consideration the possi-
bility that the ultimate purchaser and the prospective user may
not be the same person. Where this is the case for particular
products, labeling provisions may be specified which call for a
permanent label, to ensure that the prospective user is in fact
provided the notice intended by Congress in Section 8. in imple-
menting this policy the EPA recognizes the limitations present in
the prohibitions of Section 10 of the Act as to the responsibility
to comply with the labeling requirements, and the prohibitions
concerning removal of labels.
1.4.4 Distribution of High Noise Level Products
The Compressed Air and Gas Institute (910) also expressed
concern about the intended audience, particularly with respect to
products producing a high noise level but which are sold in very
few numbers.
Response;
The product population is one factor that the EPA will con-
sider in selecting products for labeling action. Of course, the
Agency's approach to a high noise-emitting product of which only
a few units are sold is also affected by the number of persons
impacted. In cases where there are considerable third-party
adverse impacts, emission regulations under Section 6 might be
more appropriate than Section 8 labeling action.
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SECTION 2: PRODUCT SELECTION ISSUES
This section addresses those comments to the docket which
directly or indirectly suggested criteria or considerations that
should govern the selection of products for the labeling program.
Of course, the statutory authority for noise-producing products
requires the Agency to determine the capability of a product's
noise to adversely affect public health or welfare. This separate
issue, though mentioned here, was discussed in Section 1.2.2.
This section explores comments about criteria or factors
that the Agency should consider in deciding which particular
Products should be labeled first. EPA cited sixteen regulatory
decision factors in the Supplementary Information to the General
Provisions Notice of Proposed Rulemaking (NPRM) [6], Of the
nearly sixty separate comments in the public docket that are con-
cerned with product selection criteria, well over half could be
included within these sixteen factors.
Some individuals suggested specific products or product
classes for labeling action rather than objective criteria.
These comments are aggregated within the product-complaint tabu-
lation shown in Section 9.2. Caution must be exercised, however,
in interpreting the results of that tabulation.
2.1 PRODUCT SELECTION CRITERIA
2.1.1 Product Noise Level
Five comments were received on the use of the product noise
level itself as a criterion for including the product in the pro-
gram. A retired Bell system engineer and coauthor of a county
noise pollution ordinance (227) suggested that all products
emitting noise above 45 dB(A) be required to have noise labels.
Citizens Against Noise (903) recommended that louder products be
given priority for selection. A physician (950) at the Orange
County Hearing and Speech Center noted the special importance of
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considering the noise levels of products to which children are
exposed, since their threshold of hearing damage is lower than
that of adults. General Motors Corporation (622) asserted that
actual noise levels rather than annoyance factors form the basis
for product selection, and AHAM (629) urged that the Title IV
report, "Report to the President and Congress on Noise", be used to
assist in product selection.
Response;
Considering the definition of health and welfare according
to the World Health Organization [4] (complete physical, mental
and social well-being and not merely the absence of disease and
infirmity), and the legislated requirement that the Agency desig-
nate and then label any product "which emits noise capable of
adversely affecting the public health or welfare", the fact that a
product emits noise means it may be considered for regulation.
The Agency intends to use the noise level of a product as an aid
in determining if a product should be selected for product noise
labeling.
The Agency will study the noise levels of products and the
health and welfare impact of these levels on a product-by-product
basis.
However, other factors such as usuage patterns, affected
parties, the numbers of products in use, and others, will be con-
sidered when selecting products for regulation which are capable
of affecting the public health or welfare. This is further dis-
cussed in Section 2.1.7 of this Docket Analysis.
2.1.2 Product Usage Characteristics
Characteristics of product usage received considerable atten-
tion from those commenting on product selection criteria. Four-
teen respondents alluded to the duration and frequency of a prod-
uct's operation as an important factor in the selection process.
Most of these comments suggested that products in use continu-
ously, such as refrigerators and heat pumps, be given priority for
labeling over products used only intermittently, such as vacuum
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cleaners and hair dryers. The UAW (540) recommended that EPA con-
sider industrial equipment because of the length of the exposure
to the individual. AHAM (629) emphasized that home appliances are
operated at the discretion of the family member, and "that a
direct interaction occurs between consumers and home appliance
manufacturers."
Four respondents cited the location of the product as a fac-
tor. Two of these mentioned the distinction between stationary
and movable products (456,953), while Congressman Elford A.
Cederberg (R-MI) (568) suggested that noise outside the home
rather than that of household appliances be the major target of
governmental activity.
A few comments referred to the number of people affected as
being a selection criterion. The Compressed Air and Gas Institute
(910) cited the low exposure levels of some of the products of its
members, and the Orange County Hearing and Speech Center (950)
emphasized concern with noisy products to which many children are
exposed. (Also see 59, 176, 235, 504, 529, 553, 633, 953.)
The Metropolitan Washington Council of Governments (COG)
(901) also thought that the number of persons exposed to a prod-
uct's noise should affect product selection. In addition, COG
mentioned the noise level, frequency of use, useful life, and
Product cost as other important factors. In other words, COG
feels the product which is used and heard by more people, has a
higher noise emission level, is used for longer periods of time,
will last a greater number of years, and is more expensive should
represent a higher priority for labeling action.
Response;
The Agency will consider product use characteristies such
as: product location; extent of population exposure to its noise;
operating life and so forth, as aids in selecting products for
regulation under Section 8.
These factors all develop information that aids in determin-
ing the capability of a product to adversely affect the public
health or welfare.
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These factors, among others, are further discussed in Section
2.1.7 of this Docket Analysis.
As mentioned in Section 2.1.1, the Agency uses the World
Health Organization [4] definition of health, and does not intend
to limit its regulation of produces to only those that may produce
hearing damage.
2.1.3 Effects of Noise Emissions
Comments regarding the effects of noise were frequently
raised relative to product selection. Most of these centered on
the need for EPA to keep health and welfare matters at the fore-
front in its deliberations, with particular attention granted
those products which might have harmful noise levels. Respondents
in the health professions often voiced such concerns, noting the
need for health warnings on some products and pointing out the
secondary effects of chronic tension and psychological disturbance
caused by some noise sources (211, 579, 913, 927). (See Section
9-3.) A number of industry representatives including The Hoover
Company, The Kirby Vacuum Cleaner Company, the Vacuum Cleaner
Manufacturers Association (VCMA), the Home Ventilating Institute
(HVI), and the American Rental Association (648, 906, 651, 740,
908), argued that products they deal with had not been proven
hazardous to the public health or welfare; therefore, they should
not be included in the labeling program. Other commenters
stressed the need for EPA to focus on products having adverse
health and welfare effects (622, 910). Sears Roebuck and Company
(709) felt that only those products whose noise level is detri-
mental to health or welfare be included because of the undue
burden otherwise placed on the manufacturer.
Reponse t
This issue was responded to in Section 1.2.2.
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2.1.4 Public Attitudes
The Outdoor Power Equipment Institute (OPEI) (590) directly
objected to the use of public attitudes toward product noise as a
selection criterion, contending that attitudes are too "emotional"
and "subjective." OPEI opted instead for scientific measurements
of noise levels. Deere (738) felt that the variability and sub-
jectivity of public attitudes would render their application as
a criterion difficult. The VCMA (651) expressed concern over the
negative publicity given to vacuum cleaners in the EPA public
hearings, fearing that this publicity would adversely affect
public attitudes on the need for noise labeling their products.
The Hoover Company (648) cited industry surveys showing little
concern with noise by prospective purchasers of vacuum cleaners.
Response;
Because the protection of the public health and welfare is at
the forefront of the noise labeling program, public attitudes and
reactions regarding the noise levels of products represent solid
and important criteria for EPA's product selection, EPA agrees
that product noise levels alone mean little when isolated from
their health and welfare effects.
2.1.5 Voluntary Actions by Industry
Several industries suggested that EPA not choose products
for mandatory labeling if the industry has an ongoing voluntary
labeling program or proposes an effective program for the future.
International Snowmobile Industry Association (ISIA) (905) and
The Air Conditioning and Refrigeration Institute (ARI) (902) each
explained their respective industry's voluntary noise testing pro-
grams which, they asserted, could serve as examples of adequate
voluntary noise programs with minimal EPA alteration and involve-
ment.
Response;
The Agency's position on voluntary labeling programs was
Discussed previously in Section 1.1.1.
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2.1.6 Third-Party Effects
Eight comments addressed the problem of product noise effects
on third parties as it relates to the choice of labeling a product
or regulating its noise emission properties. The Minnesota Pollu-
tion Control Agency (953) testified that EPA should categorize
products into those affecting: "the user only," "the receiver
only," and "both". Several citizens supported the idea that prod-
ucts whose noise significantly adversely affected third parties
should be subject to regulation rather than labeling (107,
344, 425, 504, 535, 935).
ARI (902), referring to the Draft Background Document for
Product Noise Labeling - General Provisions (EPA 550/9-77-253)
[5], questioned whether its industry's products were considered
the type in Category C that might affect third parties and thus be
considered for noise regulation instead of labeling.
Response;
Since the decision on whether a product should be subjected
to noise labeling action or not-to-exceed noise emission regula-
tions involves a careful analysis taken on a product-by-product
basis, the Agency cannot state what products will be considered
for each type of action in the future. Therefore, the Agency
struck from this Background Document the erroneous generalization
included in the Draft Background Document (EPA 550/9-77-253) [5],
that "Outdoor equipment in Category C ... is not a candidate for
labeling; if it were very noisy, it would be a possible candidate
for standard-setting regulation."
2.1.7 Other Considerations
This subsection summarizes a number of comments that per-
tained either directly or indirectly to the selection of products
for labeling.
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The Compressed Air and Gas Institute (CAGI) (910) argued
that no useful purpose would be served in individually labeling
products used in a work place already subject to OSHA standards
for noise at the worker's ear, a standard that incorporates the
whole work environment.
CAGI and ISIA (910, 905) urged EPA to set forth clear cri-
teria in the regulations for product selection. John Deere and
Company (930), while not specifying selection criteria, recom-
mended consideration of products on a case-by-case basis. Deere
(738) later urged the development of objective criteria, prefer-
ably quantitative, but it could not specify classes of products
appropriate for labeling. Similarly, an attorney (621) urged
individual consideration of products in terms of noise character-
istics, testing procedures and labeling susceptibility in lieu of
general criteria.
One citizen (247) took the broad view that all products with
electric motors should have noise labels. The Acoustical Society
of America (ASA) (333) suggested that products with sound-level
controls, such as TV's and stereos, should not be labeled.
Two academic hearing specialists, commenting jointly (405),
suggested that EPA delay labeling products with particular charac-
teristics, such as tonal components and intermittency.
Several respondents, mostly from industry, indicated that
products which are components of other products or which operate
in varying contexts or environments pose special problems and
should not be subject to noise labeling (660, 907, 922, 952). An
acoustical consultant (952) suggested a phased program of label-
ing, selecting the more easily-rated products such as household
Appliances first, and moving on to complex and component products
later. An official from the Minnesota Pollution Control Agency
(953) preferred a strong program with only a few products being
labeled to a weak one covering many products.
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Response;
The Agency's consideration of these and other product selec-
tion criteria does not involve questions of its statutory author-
ity. It is evident from Section 8 of the Noise Control Act that
the Agency has a nondiscretionary duty to designate and label
noise-producing products found to be capable of adversely affect-
ing the public health and welfare, and any products sold on the
basis of their effectiveness in reducing noise. The original
16 factors cited in the Notice of Proposed Rulemaking (NPRM) (42
FR 31723, published June 22, 1977) [6], and those suggestions
offered in the public docket, have been assessed, rewritten, and
augmented. There are now at least 20 criteria that EPA will use
in deciding which products it will consider for noise labeling
among all those products within its authority to label.
While the Agency will consider these and other factors in
selecting products for labeling action, there will be no firmly
established criteria. Since the decision to label could be made
on any one factor, a mathematically precise formula to determine
if noise labeling of a product will or will not be required is
virtually impossible. The Agency welcomed the above comments and
will give them due consideration in the process of determining
what products should be labeled first.
The following list represents those factors which the EPA
will use in deciding on the products it will consider for possi-
ble noise labeling regulatory action.
Criteria for Selecting Products as Initial Candidates
for Noise Labeling
(The order in which these factors are listed does not necessarily
represent their relative importance in the selection process.)
1. (For noise producing products) Is the product noise level
sufficiently high to be potentially capable of producing
an adverse health or welfare impact?
(For noise reducing products) Does the product have a noise
reducing capability and is the product sold wholly or in
part on the basis of this capability?
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2. is the product used in a location or in a manner that makes
an. adverse health or welfare impact possible?
3. is there a potential for the product to be misused? (e.g.,
aerosol operated horns in a crowed, decorative ceiling tile
used as sound absorbing ceiling tile).
4. Does the product noise affect a large number of people?
5. is the noise from the product likely to impact more non-users
(i.e., third parties) than purchasers/users?
6. Is the product used by the purchaser or household members,
and does the adverse noise impact of the product fall pri-
marily on the purchaser or household members?
7. Are there large numbers of the product types in use?
8. Are there large numbers of the product types being manufac-
tured/sold?
9. Is there a significant range in the acoustic performance from
model to model?
10. is there a high frequency of purchase so that purchasers have
the opportunity to use the labeled noise information often
in making a purchase decision?
Hi Do the future trends in the product's population, design, or
use suggest noise labeling benefits?
12. Do purchasers desire a quieter noise producing or more effec-
tive noise reducing product?
13. Can the acoustic performance of some or all models of the
product be improved?
14. is there currently a lack of acoustic information?
15, Would Federal labeling be a significant improvement on any
existing product noise labeling?
16. Would labeled noise information be useful to.purchasers/
users, and Federal, State and local noise ordinance enforce-
ment organizations?
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17. Is it desirable for EPA to augment existing or planned noise
emission/noise attenuation standards by labeling a product
with noise information?
18. Are the acoustic data necessary to the development of product
noise emission/attenuation standards currently available?
19. Would the prospect of Federal labeling promote voluntary
labeling by manufacturers?
20. Is there a readily available measurement methodology for the
product types?
The EPA will conduct pre-regulatory studies to develop data
information concerning these factors for the products or product
classes that it selects as potential candidates for labeling.
2.2 NOISE-REDUCING PRODUCTS
Although noise-reducing products are discussed in other sec-
tions in conjunction with various issues, there are certain
matters raised by commenters concerning these type of products
which are not addressed elsewhere.
Only a few commenters actually suggested noise-reducing prod-
ucts for labeling action. Products mentioned and the number of
respondents are listed below.
Acoustic tile (2)
Ear protectors (2)
Barrier devices (1)
Walls in new homes (1)
Wallboard (1)
Acoustical doors (1)
Aluminum doors and windows (1)
A number of commenters cited problems in developing a de-
scriptor, rating scheme, or testing methodology for specific
product classes. Manufacturers of acoustic tile, mufflers, and
fiberglass (641, 652, 631) - as well as acoustical engineering
firms (147, 952) - strongly emphasized the difficulties involved
in using a single descriptor to characterize the noise reduction
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capabilities of a product. One factor cited was the differences
between two descriptors presently used by the construction indus-
try, the NRC (Noise Reduction Coefficient) and the STC (Sound
Transmission Class) in the properties they described, and thus the
impossibility of choosing one over another. A new descriptor
would create more confusion considering the acceptability of these
two descriptors, according to one commenter (641); and one manufac-
turer (631) contended that the average purchaser could not even
judge the significance of these two common descriptors or the
noise isolation class (a single number rating of noise reduction).
A second factor mentioned as working against the concept of a
single descriptor is the interdependence between noise-reducing
products and their environment (743). A spokesman for Kodaras
Acoustical Laboratories (647) expressed serious reservations about
labeling a product whose acoustical performance can vary signifi-
cantly depending upon its installation. Owens-Corning Fiberglas
Corporation and Johns-Manvilie Corporation (631, 692) also stres-
sed the need to consider the total system in which the product is
fitted or used, and advocated the labeling of finished systems.
Walker Manufacturing, and the Automotive Exhaust Systems Manufac-
turers Committee (AESMC) (652, 710), commenting specifically on
the implications of labeling their products, felt that a single
descriptor for replacement exhaust systems was impossible, because
each muffler is designed to be used with various makes and models
°f automobiles - thereby resulting in varying noise reduction
capabilities. The Walker Manufacturing Company recommended a
"statute sound level1* approach for exhaust system parts rather
than confuse the car owner with label information. Commenters
(610, 710) discussed other problems and prospective solutions
associated with exhaust system acoustic evaluation in great
detail.
While recognizing the shortcomings of existing noise-reduc-
tion ratings (due to manipulation of measurement methodologies
and the intervening environmental variables), a partner in an
acoustical consulting firm (952) admitted such information would
b® useful for the individual consumer in the case of some products
(e.g., acoustic tile).
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Certain comments pertained to the measurement methodologies
employed in rating noise-reducing products. Accepted American
National Standards Institute and the American Society for Testing
Materials standards were recommended for testing purposes by two
commenters (631,647), one of whom urged close consultation between
EPA and the National Bureau of Standards (NBS) regarding the
development of rating schemes and test methodologies. The spokes-
man for AESMC (652) maintained that muffler labeling could not
proceed until a test procedure for determining a noise reduction
rating was developed and agreed upon. The spokesman for the Noise
Control Products and Materials Association (743) noted that a
single number would not adequately describe its members products'
noise reducing properties. He urged EPA to consult with a number
of established associations in the field t'o develop suitable
rating methodologies.
A final comment relating to noise-reducing products is the
assertion that the acoustic tile marketed today are in compliance
with the 1972 Noise Control Act, since they have labels providing
noise rating information (641).
Response;
These recommendations and observations will prove useful to
the Agency in its consideration of labeling actions for noise-
reducing products. Of course, the issue of whether or not a prod-
uct is in compliance with the 1972 Noise Control Act is meaning-
less until regulations affecting that product are promulgated.
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SECTION 3: LABEL CONTENT
3.1 COMPARATIVE ACOUSTIC INFORMATION
The concept of including of comparative acoustic information
on the label elicited strong reactions, both negative and posi-
tive. Many private individuals and local government officials
expressed support for the proposed range data or some other com-
parative information, and several persons recommended revisions
or additional material to improve on the proposed format. A num-
ber of persons felt the comparative information was essential
i
to the label's success. In contrast, most industries expressed
serious reservations about the use of the range or any other
i
comparative information.
Persons supporting the inclusion of a range indicator usually
did so because they felt the noise rating could not stand by it-
self. Some sort of a scale was often considered necessary to give
meaning to the rating. Specific suggestions as to the exact
nature of this component of the label varied widely.
One recommendation entailed the construction of schemes uti-
lizing comparisons between dissimilar products (942) (although
most commenters endorsed the concept of comparing only within a
given product class). The Environmental Management Agency of
Santa Clara County (942) and a citizen commenter (706) urged that
the noise rating be contrasted with the noise level of another
Product with which the consumer is likely to be familiar (e.g., a
quiet refrigerator). The Secretary of the Illinois Department of
Transportation (198) and the President's Office of Consumer Af-
fairs (623) suggested the use of visual effects such as an actual
spectrum of noisy products with an indication of where a particu-
lar product falls, or the use of a color-coded description which
Provides a range.
Both the Iowa Department of Environmental Quality (926) and
the California Department of Health (948) suggested that the
range be related in some fashion to the health and welfare of the
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consumer. The latter urged that the label cite the values at
which certain effects could be expected to occur. A private indi-
vidual (537) agreed with this, arguing that the level at which
speech interference occurs should be clearly indicated on the
label.
Recommendations on how the currently proposed range scheme
could be improved included (a) the addition of the average noise
rating to compensate for extreme values within a product class
(166, 623) and (b) the clarification of which pole of the spectrum
was "better," or quieter (198). Sears, Roebuck and Company (709)
urged that EPA establish a comparative basis fair to all manufac-
turers involved. The Department of Commerce (745) recommended
consideration of its comparative approach in the Voluntary Energy
Labeling Program, and suggested that EPA acknowledge its responsi-
bility for maintenance of range data.
Manufacturers and representative trade associations were for
the most part very opposed to the incorporation of comparative
information on the label. The Compressed Air and Gas Institute
(910), Chrysler Corporation (672), and the Motorcycle Industry
Council (713) objected to the provision of such information basic-
ally because they believe that the EPA has no statutory authority
to require the manufacturer to provide this information. The
Chrysler Corporation based this argument on Section 8(b), which
requires that notice be given of "the level of noise" the product
emits. They also felt the rating would force manufacturers to
advertise competitive products and could lead to antitrust expo-
sure in certain cases.
A number of companies expressed concern with the difficulties
in ascertaining what constitutes a product class. The Ford Motor
Company (907) indicated that EPA must establish "suitable" cri-
teria concerning what constitutes a product class before product
comparisons that are meaningful can be made. The Counsel to the
Power Tool Institute (PTI) (565), Black and Decker Manufacturing
Company (577) and the Outdoor Power Equipment Institute (OPEI)
(590) all felt that classifying products according to type was
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very difficult. OPEI particularly stressed the importance of
defining the range so that it included products which were truly
comparable. The Computer and Business Manufacturers Association
(662) argued that all products in a class must have identical
functions. They felt they "would not be in a position to define
appropriate product classification within (their) industry because
of the complexity of product types." The General Motors Corpora-
tion (622) mentioned various problems with a noise range, such as
the lack of information about the distribution of products across
the range, the type of products being considered, the cost of
products, and the meaning of the size of the range.
, Concerns were also expressed about the general validity of
noise information or the ability to update the information at the
rate that products are produced and altered. Hilti Fastening Sys-
tems, Inc. (671) stated that for their products, roughly "the
average time between major product class changes is about the same
as the average time for manufactured products to reach the con-
sumer," so that the information can never be up to date. The
International Snowmobile Industry Association (548) argued that a
range was inappropriate for their products because testing methods
are not precise enough and the range is really quite small. The
J. I. Case Company (526) felt that requiring a range on the noise
label would unnecessarily increase the cost burden on the manufac-
turer. Other concerns were varied with respect to the effective-
ness of the range on the consumer's ability to make decisions.
The General Motors Corporation (622) observed that the range gives
no indication of the distribution of the products within that
range, and Rapistan, Inc. (166) supported the inclusion of the
average value for the product classes for that reason. The J. I.
Case Company (924) and the Air Conditioning and Refrigeration
Institute (902) expressed concerns about the range as misleading
fche consumer with respect to the availability of products in his
area and giving disproportionate weight to a factor (noise) not
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central to the product's function. Hilti Fastening Systems, Inc.
(671) stated that the range "will tend to mislead the unwary or
the lazy, who may use it as a crutch in making a poor decision,
ignoring more important factors...."
The General Motors Corporation (622) urged that space be left
on the label to allow for clarifications in cases where it might
be necessary, because "a noise rating set into a noise range will
not by itself convey an unmistakable message for all products."
Response;
EPA will retain the comparative acoustic information in the
program, although its exact format will be determined on a prod-
uct-specific basis. Inclusion of this comparative range is
essential for a clear understanding of the noise level rating and
EPA will endeavor throughout the program to provide the best
possible acoustic information to the consumer. Inclusion of the
comparative acoustic information lies within EPA's authority for
the program. The statutory language of Section 8(b) of the Noise
Control Act of 1972 sets forth the minimal requirements for notice
of the level of noise of designated products and, further, the
range information is considered implicit in such "notice." EPA
will address the issue of what comparative information is appro-
priate for a particular product or class of products at the time
EPA proposes and/or promulgates a labeling regulation for that
product. Should the Agency require comparative information on a
label, EPA will provide such comparative information to the manu-
facturers and periodically update the information, generally
after monitoring and analysis of the non-proprietary data in the
reports manufacturers submit as part of their compliance require-
ments.
3.2 DESCRIPTOR
There was little criticism of the use of a descriptor on the
label or of its proposed location. However, a major trade associ-
ation (902), felt that the possibility of re-rating products fol-
lowing compliance testing made it potentially expensive to include
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the actual noise measurement on the product rather than in a
directory. Fasco Industries (197), argued for a warning on danger-
ous products instead of a rating.
The general characteristics thought to be important for a
descriptor among the respondents were uniformity across product
classes, simplicity, and understandability. One manufacturer
(924), thought that uniformity across product classes, because of
product differences, would be of little comparative value - though
he stressed the critical need for descriptor uniformity within a
class. Despite this agreement on characteristics, there were
different opinions as to the kind of descriptor that best fulfills
these requirements.
Several acoustic descriptors were recommended for possible
inclusion on the label. In some instances, the respondent (espe-
cially in cases of manufacturers) was basically concerned with the
descriptor to be used for his particular product, rather than the
general utility of a given descriptor. The suggested descriptors
are noted below, with the number of respondents suggesting each
one given in parentheses. It should be noted that in some cases
e.g., sound pressure level, the respondent is referring to the
acoustic parameter used to derive the descriptor rather than the
descriptor itself.
"Numerical" (5)
Decibels (10)
Noise Power Emission Level in bels (3)
Product Noise Rating in decibels (1)
Sones (2)
Leq (2)
Rating scale, 1-5 or 1-10 (3)
Symbols (2)
Narrative descriptions (3)
Color code (8)
STC and NRC for sound-reducing products (2)
Sound pressure level and sound power level (1)
A-weighted sound power level (1)
"Perceived noise" decibels (1)
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The vast majority of commenters supported some type of scale
involving numbers which truly showed the capability of the prod-
uct. There was little support for using symbols, word descrip-
tions, or a 1-10 rating scale.
Response;
None
3.2.1 Decibels or dB(A)
The most popular descriptor seemed to be the basic unit of
noise measurement - decibels - with many persons suggesting the
A-weighted scale, or dB(A). Manufacturers and private citizens
alike were of this opinion. For example, ARI (729) suggested the
use of dBAs for home consumer products (Sound Pressure Level at
1 meter), while the Power Tool Institute and Black and Decker
(565, 577) advocated the use of bels, the parameter being the
Sound Power Emission Level. The Chairman of the Subcommittee on
Noise Standards for the Acoustical Society of America (555) argued
in favor of the Product Noise Rating (PNR) expressed in decibels,
defined as the space average of A-weighted sound level at a dis-
tance of one meter from a noise source over a reflecting plane.
The Ford Motor Company (907), Outboard Marine Corporation (660)/
Sears, Roebuck and Company (709), and the Home Ventilating
Institute (740) felt the major disadvantage to using dB(A) (or
decibels) is the public's lack of knowledge about this unit of
measurement.
Two audiologists (405), who suggested using sones, mentioned
a number of reasons why dB(A) should not be used as a descriptor:
• The A-weighted decibel is measured on a logarithmic
scale that would be difficult for the public to use and
understand.
• The A-weighted decibel captures subjective responses to
noise more poorly than other calculation schemes.
• The public will have to be further educated about dB(A)
or any other rating system and thus a more appropriate
descriptor might just as well be used.
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• The consumer does not own a sound level meter and is
not directly involved in monitoring and enforcing regula-
tions - thereby making it superfluous to increase (their)
sophistication concerning dB(A).
• It would be difficult to incorporate in this (noise mea-
surement) unit refinements made in measuring subjective
effects of noise.
In contrast to these criticisms of decibels, there were posi-
tive points ascribed to their use. First, several persons men-
tioned that the public already knows about decibels, and any
public education campaign would be building on a foundation of
knowledge, albeit quite limited. The Chairman of the Acoustical
Society of America Subcommittee on Noise Standards (555) claimed
we are becoming "a noise conscious people, with frequent contact
with A-weighted sound levels of various devices and machines,
such as automobiles, trucks, aircraft, etc." An expert in the
acoustics field (909) stated that the public could learn to deal
with the logarithmic scale - the major problem area in using
<3B(A)s. A professor commented that the dB(A) rating is already
meaningful and could easily be assimilated by the population and
that his students quickly learn how to use A-weighted sound level
in units of dB.
Second, a descriptor using decibels provides the uniformity
needed to permit consumers to learn from individual purchasing
experiences across different product classes, whereas a 1-10
rating system would presumably have different dB(A) ranges asso-
ciated with identical numbers in the case of different product
classes.
A third advantage was cited by individuals responsible for
enforcement at the state or local level (941, 953). They asserted
that having the noise level of a product printed in decibels on
the label would help enforcement officials, who need to know the
exact noise level and not the range within which the product is
located (as would be provided by a 1-10 scale or by symbols).
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A fourth advantage of using decibels is that the consumer
already knows the actual noise level of the product, albeit under
certain testing conditions. However, if another rating scheme
such as a 1-10 scale were used, the person would need to know the
mechanics of that scale to calculate the actual noise level.
Two people commented that the use of decibels by consumers
in their purchasing decisions would help in making them more
knowledgeable about noise and more noise-conscious (951, 731).
Another commenter (953) stressed the fact that ratings for noise
reduction products (e.g., Sound Transmission Class (STC) and
Noise Reduction Coefficient (NRG)) can be translated to dB(A)
quite easily, and that environmental noise is measured with dB(A)
schemes (e.g., equivalent level sound (Leg) and day-night sound
level (Ldn)). Thus', use of the dB(A) can assist in furthering
knowledge about these other descriptors, as well as providing
greater flexibility in how the product ratings can be used.
Response;
None.
3.2.2 Color Code
The Office of Consumer Affairs (623), the Citizens Against
Noise (903, 940), and several persons speaking in a private capac-
ity suggested a color code for the label. A color scheme was
thought to be important to facilitate comparison shopping by
consumers, and was primarily viewed as an adjunct to a numerical
rating, such as in units of dB. one comment (952) referred to the
fact that a color scheme would communicate the "noise" message at
first glance, rather than requiring a thorough understanding of
noise. Several color schemes were suggested, each of which in
some way related to the "traffic-light" system of red-yellow-green
(928, 903, 940). Two schemes offered are noted below:
1. Red = +70 dBA
Yellow = 50-70 dBA
Green = -50 dBA
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2. Scarlet = +85 dBA
Orange = 80-84 dBA
Yellow = 75-79 dBA
Blue = 70-74 dBA
Green = -69 dBA
The advantages of a color code are implied in the above
comments - namely, the ease with which it can communicate the
message. Several commenters noted problems with a color code,
however. One person (940) said there could be a problem where two
ratings were needed - one at the operator's ear and another some
distance away. The Chairman of the ASA Subcommittee on Noise
Standards (555) criticized the use of any "disguised rating"
(i.e., color or 1-5 scale) - at least when used alone - because
the public can and should learn more about noise measurement,
because any system using ranges penalizes products at the lower
end of the range for which a certain rating is given and unjustly
rewards the noisier product, and because the best available infor-
mation should be given. Disadvantages of color codes or other
categorized schemes cited by two experts in audiology (405) were
the loss of information, the lack of incentives for noise reduc-
tions within categories, and the multiplicity of color schemes
required for different product classes plus the resulting confu-
sion.
Response;
None.
3-2.3 Other Suggested Descriptors
Besides color codes, other categorized schemes recommended
were rating scales, symbols (though none were specifically men-
tioned), and word descriptions such as "loud-irritating-quiet" or
"very noisy-noisy-etc." (329, 451, 466, 475). The advantages and
Disadvantages of these descriptors that were mentioned in the
Docket were basically the same as those cited with respect to
°olor codes.
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Another possible descriptor mentioned was the sone (405,
740), which was recommended because:
• The scale is linear and absolute and thus avoids the
problem of consumer understanding posed by a logarithmic
scale.
• The measure is internationally accepted.
• It would promote understanding of direct measures of the
subjective effect of noise.
It was stated, however, that less is probably known about the sone
than the decibel.
There seemed to be support from some industries for using
commonly accepted descriptors where possible. Thus, the' Air-
Conditioning and Refrigeration Institute (729 and 707) suggested
the SRN (Sound Ratirtg Number) for unitary air conditioners, STC
(Sound Transmission Class) for construction materials, and NRC
(Noise Reduction Coefficient) for sound absorbing construction
materials, noting that consumers could understand a limited vari-
ety of descriptors. The Celotex Corporation (641), a manufacturer
of acoustic ceiling products, said that any new descriptor would
only add confusion in light of the use of accepted indicators. A
member of the Acoustical Society of America (333) also gave indus-
try acceptance as the rationale for using STC, NRC, and SRN.
Response
None.
3.2.4 Single or Multiple Descriptor(s)
Besides the choice of a descriptor, another issue is whether
or not a single number (or symbol) will be sufficient to accu-
rately rate certain products' noise emission levels. The Automo-
tive Exhaust Systems Manufacturers Committee (652) commented that
a single rating for replacement exhaust systems was not possible,
because of the complex array of variables affecting noise reduc-
tion. The Owens-Corning Fiberglas Corporation (631), a manufac-
turer of glass fiber sound control materials, said a single number
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would be meaningless for its products, without information on the
mounting and construction technique. He said there are problems
even when the standard descriptors, such as NRC, STC, and NIC
(Noise Isolation Class), are used because each describes a differ-
ent property of noise-reduction performance. Mercury Marine Cor-
poration (281) raised the same issue with respect to pleasure
boats. They wondered if a single rating would be based on
"passby" or "interior" noise.
In contrast to these specific references to products, an
acoustics engineer (909) described a general case where two
descriptors might be needed. He noted that the A-weighted sound
level is the most useful descriptor, but where noise exposure
would vary significantly depending on the product's environment,
the noise power emission should also be used and could be ex-
pressed in bels to avoid confusion. He mentioned a fire alarm as
a product where the sound power emission level would be a more
accurate indicator of loudness. Another instance where multiple
numbers may be needed is the case of variable speed products, such
as blenders, where the operating range may be important. Johns-
Manville Corporation (692) also recommended against the use of a
single indicator.
Response;
None.
3.2.5 Criticisms of Proposed Descriptor Format
Two other descriptor-related issues concern perceived limita-
tions with the proposed label. Two comments (147, 193) stated
that the label did not clarify whether a higher number represented
a more noisy or less noisy product. The Office of Consumer Af-
fairs (623) commented that the noise rating must be explained.
TWO companies noted that the word "noise" on the descriptor label
has a negative bias (709, 740); the substitution of the word
"sound" was suggested.
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Response to 3.2.1 through 3.2.5
The Agency decided that as a matter of policy in implementing
the noise labeling program, it will use the A-weighted decibel
(dB(A)) as the acoustic descriptor for noise emitting products.
We believe that its current widely accepted use as a descriptor
for sound, coupled with other positive aspects such as uniformity
and the ease and accuracy of comparison, outweigh whatever unfa-
miliarity the public may currently have with this term.
An issue closely related to the acoustic descriptor is the
acoustical parameter that the decibel represents; that is sound
pressure or power level. Current Federal noise emission standards
are in terms of an energy averaged sound pressure level at a
designated distance from the noise source. While the A-weighted
sound pressure level is an accurate representation of the inten-
sity of noise as it is experienced by the human ear, it is gener-
ally unique to the location at which it is measured. The% sound
power level of a product is the rate at which it releases acoustic
energy to the environment and is therefore independent of loca-
tion. Sound power is calculated from sound pressure measurements
at multiple locations around the product.
In keeping with the Agency's intent to provide uniform acous-
tic descriptors across all product lines, we have adopted sound
pressure level at one meter (approximately 3 feet) from the source
as the acoustic parameter for noise emitting products. However,
we recognize that there will bo> product-specific situations where
a single value noise rating is best obtained under test conditions
which favor the determination of sound power and the subsequent
calculation of sound pressure. The Agency will determine, on a
product-specific basis, the most appropriate technique for obtain-
ing a single value product Noise Rating in terms of A-weighted
sound pressure.
The acoustic parameter and descriptor that best characterizes
the noise reducing qualities of a product is very much design and
application dependent.
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Noise reducing products will, in general, be characterized
by different acoustic parameters and descriptors than those ap-
plicable to noise emitting products. Sound transmission loss and
sound absorptioh are two of the more widely used acoustic param-
eters. Their respective acoustic descriptors are the decibel
and the sabin. However, there are other possible acoustic param-
eters and descriptors that may be more suitable on a product-
specific basis.
The choice of a noise emission or noise reduction descriptor
is not specified as a regulatory requirement in the General Provi-
sions for noise labeling. However, there will be a Noise Rating
(NR) or Noise Reduction Rating (NRR) for every product designated
for noise labeling. The choice of the acoustic parameter and
descriptor will be included as a regulatory requirement on a prod-
uct-specific basis in future subparts to this rule.
One important aspect of the EPA noise label is that the
Noise Rating or Noise Reduction Rating is to be determined by a
Federally specified and uniform test method. In many cases, the
test methods will not be able to simulate the wide variety of
actual environments in which the products will be operated, and
therefore, the noise levels shown will not necessarily be those
which users will actually experience.
The levels will, however, provide an accurate indication of
the relative noisiness of similar products when they are tested
in a uniform environment that best reflects those important
aspects of their acoustic performance.
The EPA believes that the positive aspects of this choice,
namely the uniformity, ease, and accuracy of comparison it will
afford, outweigh whatever unfamiliarity the public may currently
have with this term. The Agency also believes that the use of
Decibels will accustom the public to the concept of sound level
and the use of the decibel notation, the most widely accepted
Descriptor for sound.
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3.3 MANUFACTURER AND PRODUCT IDENTIFICATION
Eight comments were received from industry concerning two
general iss.ues: the inclusion of any manufacturer in product
identification information and the form of the disclosure. Flents
Products Company (904), Industrial Safety Equipment Association
(697), Black and Decker Manufacturing Company (577), and Counsel
to the Power Tool Institute (565) all objected to requiring
identification of the manufacturer and product on the label if
it duplicated information found elsewhere on the product. Aural
Technology (949) felt that duplication was no problem.
The International Snowmobile Industry Association (548)
objected to the inclusion of any of this information because of
the added expense this would cause in the printing and applica-
/
tion of the label.
Other docket entries raised the issue of whose name should
be on the label, the distributor or the manufacturer. The Associ-
ation of Home Appliance Manufacturers (629) suggested the use of
the brand reseller's name on the label. Aural Technology (949)
indicated that identification of the company introducing the
product into commerce was sufficient, since records kept by this
company could be used to locate the original manufacturer.
The Environmental Protection Officer for the City of Boulder/
Colorado (951) set forth the difficulties with this issue across
product classes. For motorcycles, where component parts such as
the exhaust system are manufactured separately, he differentiated
between stock items and after-sale items. For stock items the
name of the distributor introducing the product into commerce was
sufficient because his records could be used to trace the original
manufacturer. For after-sale items it would be necessary to
include the manufacturer's name, in addition to the name of the
manufacturer of the motorcycle for which the part was intended.
Hilti Fastening Systems, Inc. (671) expressed concern about
including more than one name on a label. Including both the
distributor and the manufacturer on the label would cause market-
ing problems, they felt, though in some cases the distributor's
name is more appropriate for a product.
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Two comments from industrial concerns (904, 910) raised
the issue that the present Act's definition of manufacturer is
unclear. Imported products were cited as a problem area by one
person, who was concerned about the label format and the difficul-
ties that excessive information might cause. The other industry
representative suggested EPA designate a number code that identi-
fied manufacturers, so that only a number would appear on the
label. An alternative would be to hold the private labeler
responsible for the label, rather than the manufacturer, so that
private labelers would continue to have control over the label.
Response:
The Noise Control Act of 1972 defines "Manufacturer" as mean-
ing "any person engaged in the manufacturing or assembling of new
Products, or the importing of new products for resale, or who acts
for and is controlled by, any such person in connection with the
distribution of such products."
For many products, there are diversities that occur in the
Packaging, or perhaps even final assembly of the product from its
point of origin to the point of sale to the ultimate purchaser.
For all products that are required to be labeled under the author-
ity of Section 8 of the Act, the party labeling the product or its
packaging will be identified on the label and will be accountable
for the accuracy and completeness of information that is required
on the label. To the extent that normal commercial practices
apply, such as, another party tests the product and provides the
test information to packagers of the product, the packagers should
Protect themselves through legally binding contracts or warranties.
3.4 WARNING STATEMENT ABOUT REMOVAL OF LABEL
Two respondents dealt specifically with the location, format,
°r existence of the warning statement: "Federal law prohibits
removal of this label prior to purchase." The Industrial Safety
Equipment Association (744) contended that there is no statutory
basis for the requirement that the label contain this statement
and maintained Congress would have stated it clearly if that were
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its intention. Sears, Roebuck and Company (709) feared that such
a statement might be read by the consumer to mean that other
labels on the product, such as warning or warranty statements,
could be safely removed.
Response;
It is the Agency's opinion that the warning statement is a
necessary and appropriate means to ensure that all parties in a
product's distribution chain are aware of the labeling require-
ment and to further the objective of informing prospective users
of a product's acoustical properties. The Agency believes that
the inclusion of this statement stands on its own merits and
should not be affected by the unjustified assumption that it will
affect consumer's removal of other labels. In addition, the
Agency notes that the Noise Control Act, in stating the EPA's
mandate in terms of giving notice as to a product's level of
noise, was simply setting forth the minimal requirements of the
program, and that the prohibition of section 10{a)(4) clearly
justifies the inclusion of such a statement.
3.5 LOGO
Six respondents dealt specifically with the EPA logo. One
industry (197) opposed, the use of the logo entirely, stating
that they wished to promote their own company and not the EPA.
The Compressed Air and Gas Institute (910) suggested the logo
as one possible element that could be eliminated if the label
became too large. The Industrial Safety Equipment Association
(745) felt the Agency did not have the authority to require
information other than that needed to give notice of a noise-
reducing product's effectiveness in reducing noise.
Three of these docket entries noted the ramifications behind
use of the EPA logo. Aural Technology (949), for example, sup-
ported use of the logo but observed that with its use the EPA was
implicitly endorsing the information on the label and the product.
A member of the Minnesota Pollution Control Agency (953) agreed
with this assertion, and suggested substitution of a statement
such as "for information purposes only" on the label, so that no
EPA endorsement was implied. If the EPA logo was included on the
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label, he stressed the importance1 of maintaining the accuracy of
the information on the label through the use of effective enforce-
ment procedures.
The French Laboratory (727) expressed the view that use of
the EPA logo was not justified if the EPA did not conduct the
tests.
Response;
Since the product noise labeling program implements a non-
discretionary statutory requirement that is imposed upon the
Administrator of the EPA by the Noise Control Act, the presence of
the EPA logo on the label indicates that the program is Federally
mandated and administered. Although the Agency does not itself
test products and develop the data for labeling products, the
Agency does have clear responsibility for enforcing the overall
labeling program; consequently the logo must appear on the label
so that the potential purchaser/user will know that EPA is ulti-
mately responsible for the label. The logo lends authenticity to
the data on the label since consumers generally recognize that EPA
has the authority and procedures to compel manufacturers to ensure
that their labels are accurate.
In addition, the logo on product noise labels is intended to
inform consumers that the information provided on a label for a
specific product class is, in fact, uniformly applied to all prod-
ucts of the same class.
The logo does not imply that EPA prefers certain products,
for all labels will state that it is the Agency that requires that
a certain product or class of products be labeled.
In response to the concerns about EPA endorsement of the
Actual -levels indicated on the label, the label has been changed
to read "Label required by U.S. Environmental Protection Agency".
3.6 WARNING STATEMENT ABOUT THE EFFECTS OF NOISE
The docket contained some discussion of whether or not spe-
cific warnings should be included on the label, relating the level
°f noise produced by the product to the health of the consumer.
Industries (197), the only industrial commenter, stated that
labels are only valid for products that exceed a certain
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level. Those products should not have a rating, but rather a
warning which indicates potential adverse effects.
A number of individuals generally supported the use of some
type of warning statement on the labels of products whose noise
levels are dangerous (126, 159, 238, 255, 322, 929, 931 plus
those listed below). Five persons suggested a specific type
of warning, four of whom recommended the use of warnings similar
to those found on cigarette packages (273, 461, 927, 947). A
physician, Dr. Kos (927), stated his support of this alternative
due to the difficulty in predicting for different individuals
precisely when hearing is endangered. One individual suggested
that specific instructions be given in the warning statement, such
as "Caution: Hearing protectors should be worn when using this
product," if the product emitted noise above the danger level
(145).
Recommendations were made to put warning statements on spe-
cific products, such as stereos (947). An audiologist (950) ex-
pressed particular concern with the noise level of children's
toys. Infants, he maintains, are much more sensitive to noise
than adults. For children, hearing damage begins at 65 dBA, thus
noisy toys should be labeled with a warning to indicate that fact.
A rough example of a warning was given: "Beware of the fact that
infant's hearing is very sensitive and can be damaged by toys that
make a lot of noise, such as this one."
Other persons recommended the inclusion of warning statements
concerning the effects of noise on health, but felt this could be
accomplished through alternative means. A member of the Environ-
mental Noise Program of the Metropolitan Washington Council of
Governments (901) felt this could be done through educational
materials. A certified industrial safety consultant (399) urged
that warnings be included in an instruction booklet provided with
a product.
Response;
While EPA has not made a decision to generally include health
warnings on the noise labels, such warnings might be adopted as
part of the comparative acoustic information for products whose
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properties warrant it. This would be determined on a product-
specific basis as a particular need for a health warning was
ascertained. Among the factors to be considered by the Agency
in deciding on the need for such warnings are the product's noise
level and its use characteristics, particularly the degree of
likely exposure to those groups of individuals highly susceptible
to hearing damage such as infants.
3.7 ALTERNATIVE OR ADDITIONAL MEDIA
A number of industries did not explicitly reject the notion
of providing consumers with noise level information on their
products, but felt that labels may not be appropriate media for
doing this. In such cases, they recommended alternative media.
Bilsom International, Inc. (380) indicated that Section 8
emphasized limited Federal involvement as well as limited adminis-
trative, economic and technical impact in the accomplishment of
the Act's goals. The label, they suggest, is too inflexible a
format to accomplish these goals. The form of this notice should
°e contingent upon the nature of the market, the product, and
the consumer. The presently proposed labels, Bilsom observes,
are going to cause particular problems with respect to their
Product, hearing protectors.
Whirlpool Corporation (589) and Amana (936) suggested alter-
native means of providing consumers with information on noise.
Amana stated that noise information for their air conditioners
is already available on the product specification sheets. They
assert this is sufficient for this particular product since the
consumer (who is usually a builder rather than a homeowner)
Purchases the air conditioner through the specification sheet.
Whirlpool Corporation urged the provision of this information in
the use and Care Guides rather than through a label.
Deere (738) expressed the opinion that a brochure format
m*ght have greater value for the consumer than a fixed label,
since it could be carried while comparison shopping.
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Other industries argued that additional information about
noise was required, which would not be easily provided on the
present label due to space limitations. Bethlehem Steel Corpora-
tion (401) stressed the importance of environmental conditions, a
factor that should be mentioned in supplementary material provided
to the purchaser. They recommended that the label or some supple-
mentary material be required to contain information on how the
noise reduction ratings can be used to determine the actual noise
level resulting from specific installation conditions. Aural
Technology (949) suggested that additional information for their
products is necessary and could be made available through accom-
panying literature and a display case at the store.
The Computer and Business Equipment Manufacturing Association
(662) emphasized the necessity of providing information on the
test procedures and installation conditions. They advocated keep-
ing this material on public record and referring to its existence
and location on the label.
The provision of additional information on noise ratings
for products was also advocated by six non-industrial respondents,
though there was no suggestion made among these respondents that
labels should not be used. Three of these respondents (520, 556,
943) argued that additional information is needed to explain to
the consumer the meaning of the ratings, the effect of various
noise levels on health, the methodology used to obtain the noise
rating and examples of dangerous cumulative noise exposure. The
California State Department of Health (94.8) recommended including
several noise ratings, such as a rating obtained near the source,
under specified installation conditions, and at a specified dis-
tance as well as ratings of similar products. All of these
respondents suggested that such information could be made availa-
ble through brochures.
Other suggestions were made regarding use of additional media
which would help to publicize the program. Hawaii Citizens
Against Noise (940) urged that noise information be required on
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-advertisements. The Environmental Noise Program of the Metropoli-
tan Washington Council of Governments (663) suggested that a list
of product noise ratings and manufacturers be published.
Two respondents suggested that other media be substituted in
place of the proposed noise label. One respondent (621) felt that
for products with many labels already attached, noise information
could be provided in a hang-tag or in the owner's manual. The
other expressed concern about the materials used in the construc-
tion of a label in terms of additional pollution of the environ-
ment. This person suggested that noise information be included
on the labels already present on the product (608).
Response:
EPA intends to attain the goals of the program in the manner
best suited to the particular acoustical, marketing, and distri-
bution characteristics of the products identified. In some in-
stances, this might involve giving notice of the product's noise
level through additional and alternative media. The Agency will
not become fixed on a single label content when circumstances war-
rant a more flexible approach, although maximum uniformity of
label format and information across product classes should rein-
force the program's acceptability and understanding with the
intended audience. EPA will closely consider the need for infor-
mation and/or formats other than those specified in the General
Provisions as it assesses those products that are potential candi-
dates for noise labeling.
3.8 OTHER ITEMS RECOMMENDED FOR INCLUSION
3.8.1 Maximum Noise Levels/Noise Standards
One individual (324) suggested that EPA recommend the maximum
noise level for all products in a class, indicating this level on
the label.
Pour individuals either suggested or assumed that EPA would
establish noise standards for individual products which should
be referred to on the label. One individual (940) urged that the
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label include specifically an indication of that point at which
a hazardous threshold is crossed*
Response:
The appropriate provision of the Noise Control Act that
relates to the establishment of noise emission regulations is
Section 6. Under Section 8 the Agency has the authority to label
products but not to promulgate maximum noise levels. Therefore,
the EPA cannot reference emission regulations on the Section 8
label unless the product has also been the subject of action under
Section 6. Regulatory actions under Section 6 of the Act include
a labeled notice of the regulatory action taken, and the Agency
will carefully consider combining the labeling requirements into
a single format for those products identified under both Sections
6 and 8.
3.8.2 Test Methods/Records
Four commenters suggested that some reference be made on
the label to the testing methodology used to arrive at the noise
rating. Rapistan, Inc. (166) urged that the label refer directly
to the parameter used. The Computer and Business Equipment Manu-
facturers Association (662) felt it was necessary to have public
records to back up the data on the label, and that the label refer
to the existence of such data. The J. I. Case Company (526, 924)
felt that EPA approval of the testing methodology should be
clearly stated on the label. A state noise control official (953)
observed that inclusion of a statement on the label to the effect
that EPA stipulates the test procedures will lead consumers to
assume that the rating is certified by EPA. He expressed concern
for EPA's credibility. A member of the Acoustical Society of
America (333) made the suggestion, with respect to the testing
methodology, that distance factors be incorporated in the label.
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Response;
EPA believes that an important factor for the success of the
program is the simplicity and readability of the label. Inclusion
of references to the testing methodology could unduly overcrowd
the label while imparting information of little utility to much of
the consuming population. However, EPA also recognizes the impor-
tance of the ready availability of information on the testing
methodology used to obtain the labeled noise rating. The Agency
will insure access to such information through media supporting
the label or by reference to EPA offices. The exact format of and
means of access to this information will be determined by EPA on a
product-specific basis.
3.8.3 Effect of Repairs
Two commenters noted that repairing a product might change
its noise level, a factor that should be acknowledged on the
label. The French Laboratory (954) expressed particular concern
about this problem. They stated a change in the noise level of a
Product due to repairs will most likely lead to an inaccurate
noise rating on the label.
Response;
The Agency believes the inclusion of information on the pos-
sible effects of product repair would result in a label containing
excessive information. Nevertheless, the EPA may find it neces-
sary in some cases to require such information, as for example if
sxperience shows a product's acoustic performance to be especially
vulnerable to repairs that occur frequently and soon after the
time of purchase.
3.8.4 Product Degradation
Several persons noted that the noise level of products is
Hkely to increase with age, either because of natural product
Degradation or because persons have altered products intentionally
after purchasing them. The latter instance was mentioned in rela-
tion to exhaust systems. Several commenters recommended that some
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sort of acoustical assurance period be given for the noise rating
(935). Two audiologists (405, 605), recommended that noise mea-
surements be taken after a specified period of use. Aural Tech-
nology (949) emphasized the importance of stating the likely
degradation of the attenuation capabilities of hearing protective
devices. The Minnesota Pollution Control Agency (953) recommended
that EPA bypass this issue at the present time, due to its com-
plexity.
Response;
The question of product noise degradation with time is of
particular concern to the EPA. Product noise emission regula-
tions, issued under the authority of Section 6 of the Act, specify
a minimum period of time that the product must continue to meet
the specified standard, provided it is properly used and main-
tained. This period has been designated the "Accoustical Assur-
ance Period" or AAP. In the case of labeling, the manufacturer
is not required to meet a Federally mandated noise level. Thus,
the imposition of an AAP for labeled products, would require a
more complex compliance monitoring program by the Federal govern-
ment for noise labeled products than for Section 6 regulated
products due to the possible multiplicity of noise emission/reduc-
tion ratings for a given product class.
EPA will monitor products selected into the program for the
possibility of unexpectedly rapid deterioration of the product's
labeled noise rating, in the event an individual manufacturer
might attempt to reduce a product's noise level only temporarily
to achieve a better noise rating. If this problem arises the
Agency will take appropriate actions to remedy the situation.
3.8.5 Frequency
The American Speech and Hearing Association (913) and two
other commenters indicated that the frequencies associated with a
product's noise level represents an important factor in determin-
ing its effect on persons (708) and should be noted on the label
(939).
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Response;
EPA has found that inclusion of frequencies associated with
a product's noise level in addition to the noise level rating
would entail a technically complicated procedure and might result
in confusion on the part of the intended audience, as well as a
label with an excessive amount of information. The Agency will
consider, on a product specific basis, the need/benefit of requir-
ing frequency information and the most effective media for presen-
tation.
3.8.6 Installation Conditions
A number of docket commenters observed that the noise level
is often affected substantially by installation conditions, but
the noise rating does not account for this. The California State
Health Department (948) suggested that this is particularly
significant in the case of mufflers, and that some indication
should be developed to describe the total noise reduction when
Products are used in combination. With products such as air
conditioners and pool filter pumps, he suggested a multiplicity of
ratings, including ratings in specific installation conditions.
The Computer and Business Equipment Manufacturers Association
(662) suggested that the label indicate the installation condi-
tions conducive to less noise. Bethlehem Steel Corporation (401)
suggested that the label include information necessary to allow
the user to predict the noise level of a product once it was
installed.
Three commenters dealt with the personal use of noise attenu-
ation devices and the effect of how they are used on the noise
reduction rating of those devices, urging that information on this
topic be included on the label. The OSHA Division of the Kentucky
Department of Labor (414), the French Laboratory (954), and Aural
Technology (949) all suggested that the label on hearing protec-
tive devices contain instructions on the proper use of such
devices, as well as an indication that improper use will result in
Poor performance. The French Laboratory also observed that con-
sumers often do not know what constitutes a proper fit.
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Response;
Because of the variation in noise levels for many products
under differing installation conditions, EPA cannot require
labels reflecting the noise levels for all possible installations.
Products within a class will be tested under specified uniform
conditions, so that valid comparisons of the noise properties of
similar products can take place. The Agency acknowledges that the
labeled noise ratings, while useful for such comparisons, are not
necessarily an accurate representation of a product's acoustical
performance under a limitless range of possible installation
conditions.
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SECTION 4: LABEL FORMAT AND GRAPHIC REQUIREMENTS
4.1 SPACE ALLOCATION
Though many suggestions and criticisms were submitted con-
cerning individual elements contained on the label, only a few
persons remarked about the general format of the proposed label;
that is, the general layout of the elements contained within the
label. General Motors Corporation (622) stated that EPA's deci-
sion to allocate 65 percent of the space on the label to the
noise rating was impractical since no data was offered to support
this choice, while the Industrial Safety Equipment Association
(744) thought the amount of information proposed for the label was
"excessive." However, the overall layout and shape of the label
as proposed received general support from persons submitting com-
ments to the docket. An acoustical consultant (952) remarked that
"the proposed type of label is very well done."
Response;
In response to comments concerning the allocation of space
to the noise rating, the Agency believes that one of the primary
goals of any label is visibility of the key information. It was
on this basis that space was allocated on the proposed label.
4.2 GRAPHIC REQUIREMENTS
Industries were the principal commenters with respect to the
graphic requirements of the label. In general, the comments
expressed the desire of manufacturers to maintain control over the
Packaging of their products. General Motors Corporation (622)
argued against the stipulation in the proposed rules that the
colors used in the label must contrast both with each other and
with the material surrounding the label, a practice which "does
not conform to usual label practices, and is restrictive of prod-
u<=t design." The Industrial Safety Equipment Association (745)
felt that contrast is unnecessary if the label is legible. Both
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Charles Machine Works, Inc. (627) and General Motors Corporation
(622) stated that the specification of Helvetica Medium as the
required character style is too restrictive and would increase
costs for manufacturers if they must purchase new type. The
Charles Machine Works, Inc., stated that other styles are equally
legible and almost indistinguishable from the specified style.
Response;
The Agency has concluded that the objectives of label visi-
bility and uniformity justify, respectively, the stipulation
about color contrast and the specification of Helvetica Medium
as the required character style. The Agency has not received
evidence that these requirements will place undue burdens on manu-
facturers with respect to printing or packaging considerations.
4.3 SIZE REQUIREMENTS
Concern was expressed about the label size requirement by
Flents Products Company (904) and the Compressed Air and Gas
Institute (910). The Flents Products Company was particularly
concerned about the size requirements with respect to their prod-
uct, ear plugs; large labels would mean larger and more costly
packaging.
Both General Motors Corporation (622) and the Compressed Air
and Gas Institute (910) felt that specification of the label for-
mat should be made on a product-by-product basis. General Motors
stated that "the general approach of a common label format for all
products to be labeled is desirable," but felt that this is not
possible at present. They requested that the format not be dealt
with in isolation from the message the label is to convey, a
decision, they believe, that must be based on the product choice.
Response:
The label size requirement will be considered by the EPA on
a product-by-product basis and with a conscious regard for the
manufacturer's interest in reducing costs. However, the Agency
believes it is essential that the label be readily visible and
readable. In addition, the consumer should be able to identify at
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a glance the presence of a noise rating; this is best achieved
through the use of a common label format for all products. While
certain product characteristics may require some deviation from
the standard format, these cases are expected to be few in number
and can be handled in the product-specific regulations by excep-
tions to the General Provisions.
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SECTION 5: LABEL TYPE AND LOCATION
5.1 LABEL LOCATION
A number of commenters emphasized that the label should be
highly visible and generally preferred that it be affixed directly
to the product, rather than to the package (275, 901, 916). One
person (940) believed the label should be required in all adver-
tisements.
The requirement that labels for hearing protectors be affixed
to the individual devices or their carrying cases - though issued
in a separate Notice of Proposed Rulemaking (NPRM) [7] - brought
forth a number of comments which were also germane to the docket
on the General Provisions. Flents Products (904), a manufacturer
of hearing protectors, objected to this requirement because many
of the firm's sales were to industry consumers, in which case the
protectors were shipped in bulk. The firm suggested that EPA dif-
ferentiate between protectors marketed for individuals and those
sold in bulk to industry, where the end-user has little choice
about the hearing protector he will use. In addition, Flents
objected to the double labeling that might be required in some
instances on both the packaging and the insert or its carrying
case.
Another hearing protector manufacturer, Bilsom International
(380), stated that since the Agency's labeling system seeks to
provide information to the average shopper and since the average
consumer of hearing protectors is the commercial purchaser and not
the end-user, the regulations should allow for flexibility in
the means of giving notice. They believed that for hearing pro-
tectors, the provision of information in sales literature would
have a greater impact on the real consumer and would be more
likely to achieve the statutory responsibility set forth by Con-
gress. Bilsom recommended substituting the word "notice" for
"label" in paragraphs 211.1.4-8.
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Response;
EPA has adopted a flexible position on the issue of the loca-
tion for affixing the label. The matter will be addressed on a
product-specific basis with requirements that a label be affixed on
the product, its packaging, or both. EPA will designate the meth-
od(s) best suited to the product's marketing and distribution
features, given the goals of clear visibility, availability, and
readability of the label. Insofar as possible to maintain the
overriding goals of the program, EPA will give careful consideration
to the burden on the manufacturer such label placement may have.
5.2 LABEL PERMANENCE
Those commenters who addressed the question of label permanency
were almost unanimous in favoring a permanent over a temporary
label. Commenting on the issue as it pertained to their large
agricultural and construction vehicles, the J..I. Case Company (526)
felt that "reasonably" permanent labels would make the noise emis-
sion levels of a product known to "employees," "operators," and
"potential purchasers". Several public officials involved in noise
control activities at the state and local level (915, 941, 951)
stressed the benefits of a permanent label for facilitating local
enforcement efforts, particularly with reference to mufflers and
construction equipment. In the case of products which last a long
time and are sold as used products, an obvious advantage is the
notice provided to the second-hand purchaser.
The permanent label did have one problem, according to one
commenter (901) who asserted that permanent labels may not be
Practical for household appliances, noting the cosmetic problem
assoc1ated with affixing permanent labels on kitchen appliances. A
second commenter (940) disputed this contention, however, by claim-
1r*g that most appliances are only in full view during their' normal
operation and that there are plenty of inconspicuous places on a
Product where a label could be affixed.
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One particular product thought to require a permanent label
is the automobile muffler, since this would assist enforcement of
local ordinances during vehicle inspections. However, the problem
of label life is especially acute for this product. One solution
mentioned by a local noise control official (941) was that the
label information be stamped on the muffler, with the numbers or
lettering protruding outward to foil counterfeiting. If a color
code was desired, heat-resistant paint could be used.
The Chrysler Corporation (672) felt the lifetime of the label
should be restricted to the time-of-purchase by using "prospective
user" and "ultimate purchaser" interchangeably in the regulations.
An equipment rental company (908) mentioned a major problem in
using a label to satisfy the Section 8 requirement that notice be
given to the prospective user. Because of continued use, repair
and rehabilitation, and'resale of certain tools, noise labels
would frequently be destroyed. He wanted assurance that rental
agencies would not be required to maintain the labels.
Counsel for the American Rental Association (552) further
articulated this concern, contending that the regulation is un-
clear about the difference between ultimate purchaser and prospec-
tive user; that Section 8 gives the Administrator authority to
decide whether notice to the ultimate purchaser is sufficient; and
that Congress never intended to require notice to every person
who might operate a piece of machinery but only to the ultimate
purchaser. If notice to each user was required, then the label
would have to be a permanent, embossed metal label. "Periodic
reattachment" of paper or plastic labels by the supplier would be
impractical.
Response;
Section 8(b)(a) of the Act is explicit in its direction to
the Administrator of EPA to "require that notice be given to the
prospective user of the level of the noise the product emits . • "
The Agency will make a determination, on a product or product
class specific basis, as to the permanence of the required label'
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5.3 GENERAL COMMENTS
One manufacturer (904) noted the lower costs entailed in
printing label information directly on the product or its packag-
ing, in contrast to pasting a separate label on the product. He
thought the proposed regulations and background information did
not clearly address this question.
Other comments concerned the type of label and its location.
A member of a regional planning body (901) opposed the substitu-
tion of a salesroom display for a label as a means of giving
notice about a product's noise properties. A spokesman for a
trade association (590) recommended that additional data (besides
the required label information) be provided on a hang-tag attached
to the product, while another industry representative (910)
believed the choice of label type should be determined on a case-
by-case basis. One individual (608) suggested using the existing
label, warranty card, or packaging for presenting the noise
information instead of mandating the production of "wasteful"
labels.
Response;
EPA will determine the precise type of label required on a
product-by-product basis, leaving options open for alternative
media where EPA finds them best for achieving the goals of the
'Program. In many cases, a label printed directly on the product
°* package would be acceptable; for other products, a hang-tag
could possibly represent the preferred alternative. EPA will
carefully examine suggestions for label type on a product-by-
Product basis and make allowances for special circumstances; it
intends to preserve the overall uniformity of the label type,
format and location insofar as feasible.
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SECTION 6: RATING SCHEMES AND TEST METHODOLOGIES
6.1 ACOUSTIC PARAMETER
One commenter (166) expressed concern about the product-by-
product analysis and the possibility of multiple acoustic param-
eters, claiming that one parameter for noise-emitting equipment
and one for noise-reducing equipment would be sufficient. In his
opinion, product-by-product differentiation would cause difficul-
ties for both engineers and consumers.
Among the various possible acoustic parameters are sound
pressure level, sound power level, loudness and noisiness. The
first two parameters received the greatest level of support from
the public comments. Some individuals, the Acoustical Society of
America (333) and Rapistan, Inc. (166) suggested the use of either
parameter - i.e., sound power level or A-weighted sound level -
without articulating the conditions under which they should be
used.
Other commenters mentioned their advantages (and disadvan-
tages). The primary advantages reported for SPL (Sound Pressure
Level), when A-weighted, were (1) its simplicity of measurement,
(2) its relationship to the actual sound heard by the consumer,
and (3) its recognition and acceptance by at least some of the
public. Two disadvantages mentioned were (1) its inappropriate-
ness for products where exposure varies significantly because of
movement of the product, extremely different installation condi-
tions, or other environmental factors; and (2) the less than
desirable availability of testing labs with anechoic rooms (400)-
Several commenters recommended using the PWL (sound power
level) (166, 333, 358, 400, 909). A representative of a testing
lab (400) stated that in contrast to SPL, the sound power measure-
ment would be more practical in terms of the availability of
testing labs, since the test can be conducted in a reverberant,
anechoic or semi-anechoic room. An acoustical consultant (909)
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suggested using the sound pressure level in most cases, but felt
both parameters would be needed if exposure varies significantly.
The two parameters could be distinguished on the label by expres-
sing the power emission level in bels and the SPL in dBA. In his
opinion, by using noise classes and a simple methodology with a
reasonable number of microphones, the sound power level can be
determined by manufacturers without excessive testing costs. The
Acoustical Society of America (555), is in favor of the Product
Noise Rating in decibels as the descriptor, which combines the
accuracy and reproducibility of a sound power measurement with the
"consumer relatability" of an A-weighted sound level measurement
in decibels.
Several commenters emphasized the importance of adopting
an acoustic parameter that incorporates in some manner the subjec-
tive quality of sound (946, 405, 940, 941). Loudness in sones was
suggested as a possible parameter (400, 405). Two audiologists
(405) recommended the following procedures for calculating loud-
ness: (1) American National Standards Institute Standard (ANSI
Std.) S3.4 (Procedure for the Computation of Loudness of Noise);
(2) Part B of the International Standards Organization Standard
(ISO Std.) R-532 (a Procedure for Calculating Loudness Level); and
(3) (ISO Std.) R507 (Procedures for Describing Aircraft Noise
Around an Airport). One advantage of these methods, according to
the comments, is their capacity for being refined to allow incor-
poration of subjective effects due to tonal components and sound
intermittency.
Two commenters suggested the use of dB(A) sound level read-
ings at a specified distance for most products (951, 953). Ac-
cording to two individuals, the NPRM was erroneous in implying
that dBA was a measure of sound pressure level, which they said
was not contained in the weighting (953, 281). The advantage seen
by a local official (953) in using a "straight dB(A) versus dis-
tance scheme" is that enforcement officers can more easily use
that information and can help EPA in monitoring the accuracy of
Product noise ratings.
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Response;
The selection of an appropriate acoustic parameter, that is,
the quantity measured during testing (not necessarily the quantity
presented on the label, i.e., the descriptor), will be made on
the basis of that which best characterizes the acoustic properties
of the product and which can be determined reasonably by a simple
yet accurate test method. This parameter may vary from product
to product, but the labeled descriptor will be the sound pressure
level in "decibels" at 1 meter unless another distance, i.e., oper-
ator ear, is more meaningful to the user/purchaser of the prod-
uct. (See also the discussion of the related issue of descriptors
in section 3-2).
6.2 TEST METHODOLOGIES
Much of the commentary on test methodologies did not bear
directly on the General Provisions of the Noise Labeling Program,
but rather focused on product-specific considerations that would
become important, should the Agency decide to subject those prod-
ucts to labeling action. Rather than list all of these product-
specific comments, we have extracted from them general issues
pertaining to the program-at-large. The Agency will, however,
consider all other relevant methodological issues in the process
of formulating product-specific regulations.
6.2.1 Use of Standard Test Methods
There was overwhelming consensus among manufacturers and
trade associations that the Agency should adopt standardized
methods which have already been developed and are accepted by
industry and other knowledgeable parties. One industry spokesman
(631) appraised favorably the NPRM's reference to American Na-
tional Standards Institute (ANSI) standards, recommended the
American Society for Testing Materials (ASTM) as another source ot
measurement methods, and urged close EPA-NBS (National Bureau ot
Standards) interaction regarding rating schemes and test method-
ologies. Besides offering a similar suggestion about the use
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of consensus standards, Kodaras Acoustical Laboratories (647) con-
tended that specific product regulations should reference these
standards but not cite them as federal standards, so that they
can be kept current without necessitating amendments to the regu-
lations.
In a number of cases, commenters discussed specific standards
- either in the context of offering critical analysis or else
suggesting one of them as a suitable method for a particular
product class. Listed below are some of the products discussed
and the appropriate docket identifications. The particular com-
ments may be found in Appendix A.
Pleasure motorboats (281)
Lawnmowers (590)
Snowmobiles (548)
Automotive exhaust systems (424, 610, 652)
Hearing protectors (666)
Power tools (565, 577)
Small noise sources (555)
General - calculating loudness (405)
Response;
Establishing the test methodology to be used in determining
the required acoustical data and for compliance testing will be
accomplished on a product-by-product basis. In establishing an
appropriate test methodology, the Agency will give particular at-
tention to simplicity, accuracy, and repeatability. The Agency
*ill, where possible, specify existing consensus standards such as
ANSI, SAE, ASTM, etc. Where consensus standards are lacking or
inappropriate, the EPA will solicit the assistance of industry,
trade associations, standard setting institutes and other knowl-
e<3geable organizations in developing an appropriate test meth-
odology.
6-2.2 Test Facilities
Two distinct issues surfaced in relation to the test facili-
ties, or laboratories, that will be necessary to obtain the re-
tired noise measurements. Kodaras Acoustical Laboratories (647)
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asked who would determine the acceptability of a laboratory, and
what criteria would be used in making that judgment. Kodaras
recommended the National Voluntary Testing Program and ASTM
Standard E548 (Recommended Practice for Generic Criteria) as
methods of evaluating testing agencies.
The Outdoor Power Equipment Institute (OPEI) (590) was con-
cerned that manufacturers would have to use (only) EPA-designated
test facilities. OPEI suggested that manufacturers be allowed
to test products at either EPA-designated testing laboratories
or their own facilities, if certified by the Agency. Without
such flexibility, they feared excessive duplication of tests,
since manufacturers will still perform their own tests. Johns-
Manville Corporation and the Noise Control Products and Materials
Association (NCPMA) (692,743), raised similar concerns.
Response;
The EPA does not intend to certify test facilities capable
of conducting the required acoustic measurements. Rather, the
Agency is placing the responsibility for ensuring that the re-
quired acoustic data is generated in accordance with EPA-specified
test methodology, on the manufacturers. Therefore, the manufac-
turer is free to use his own facilities or an independent testing
laboratory, as long as the Federally specified test methodology is
followed. The EPA will rely either on its own test facility or
designate an independent laboratory to perform Agency testing*
6.2.3 Simulation of Use-Environment and Related Problems
Two commenters (520, 197) urged that the noise rating reflect
the "in-use" noise level and not the level emitted by the product
in a "special" laboratory environment. Other commenters (281*
647, 652, 902) cited difficulties in achieving this goal, due to
variations in product-use environments. For example, the labora-
tory ratings for sound reducing building materials do not reflect
the actual room environment; and according to one expert (952);
they really cannot unless the entire system in which the product
is placed is known.
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Similar problems in achieving a realistic test environment
were mentioned by various industrial commenters. The Outdoor
Power Equipment Institute (590) questioned the feasibility of
realistically testing products with various attachments and
variable speeds (e.g., lawn and garden tractors). Additional
considerations pertaining to this product entail decisions about
what loads and operations would constitute a realistic test
environment for a multi-functional vehicle. OPEI cautioned
the Agency against a repetition of the problems involved in the
public's interpretation of EPA gas mileage ratings. Mercury
Marine (281) gave another example of this general problem, citing
the problem of rating the noise level of the engine, without con-
sidering the characteristics of the boat on which it is mounted
(outboards) or installed (inboards).
Response;
Where the simulation of the use-environment is deemed to
be critically important or when it is easily accomplished, the
Agency will specify the particular test environment. However,
the simulation of use-environment is not a primary goal of the
labeling program. The noise rating on the label is intended to
facilitate comparative shopping on the basis of products' acousti-
cal performance as determined through a uniform test methodology.
The Agency acknowledges that installation or in-use environments
can influence the acoustic performance of a product and therefore
the rating may not be totally accurate in describing the product's
noise-emitting or noise-reducing properties.
6.2.4 Incorporation of Subjective Noise Characteristics
A number of commenters believed it was vital for the noise
Eating to reflect other factors besides simply the noise emission
level. Such factors might be tonal components or duration of the
noise (see Sections 3.8.5 and 6.1). Two audiologists (405)
discussed this issue and suggested that the labeling program be
Delayed for products where these and other subjective factors
result in an extremely annoying noise source. They believe that
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there is presently not sufficient information to correct noise
ratings for temporal factors (duration and intermittency), and
tonal components. But they also note that because usage time is
often inherent in the product (e.g., washing machines) and all
products within that class require approximately the same time for
completion of the function, duration of noise is not really a
critical factor for labeling purposes, since the relative values
of products would not change appreciably.
Despite the methodological problems barring incorporation of
these psychoacoustic properties within the meaning of the noise
rating, the two audiologists recommended methods that capture the
subjective effects of noise. To inform the consumer about how the
noise will affect him or her, they feel the best approach is to
employ a "calculation system" which translates physical measures
of acoustic properties into reliable measures of the subjective
magnitude of sound. (See Section 6.1 for references to methods of
calculating loudness.)
Response;
The Agency will strive to use objective measures of a prod-
uct's acoustical characteristics. Where subjective factors pose a
significant problem insofar as the product's impact on the public
health and welfare is concerned, and where appropriate noise mea-
surement methods are available, the EPA will seek to establish a
methodology capable of capturing the relevant acoustic properties.
For example, tone corrections will be incorporated in the EPA-
specified method when tonal components associated with the noise
emitted by a product are considered significant with respect
to their capability to adversely affect public health or welfare.
6.2.5 Miscellaneous Issues
The question of how to arrive at a single value from a series
of measurements using different product samples elicited responses
from several commenters. One manufacturer (924) believed that the
mean value should be used, with some indication of anticipated
variation in acoustic performances. Other manufacturers (590/
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910) supported the establishment of a reasonable margin of error
in individual product compliance with the noise rating. On the
other hand, two commenters (940, 941) supported the use of the
maximum value of a series of tests so as to provide a margin of
safety, compensate for products displaying considerable noise
emission variability among units, and assist in local enforcement
of noise ordinances.
The Outdoor Power Equipment Institute (590) criticized the
requirement that noise ratings be derived from product samples and
not from pilot production units. The charge was that this pro-
cedure would force expensive production delays, since the assembl-
ing and packaging of production units would have to wait until
testing was completed and labels were delivered. OPEI claimed its
members experienced a lead time of one to two months to obtain
labels and contended the delay would cause "severe disruption of
inventory and distribution systems."
One industry representative (910), expressed his opposition
to testing each product off the assembly line and his preference
for using a sample of products. Once the Agency has been satis-
fied that the test was conducted in an accurate manner, the Agency
should not be able to order compliance testing based on products
that appear to exceed the established noise level, unless there
have been changes in the production process.
Response;
Whether a manufacturer may use production samples or pilot
Production units for determination of label noise levels will be
addressed on a product-by-product basis. To specify at this time
that a manufacturer may use one or the other, or both, would
restrict the Agency's ability to tailor the testing requirement to
the nature of the industry being regulated in future subparts of
part 211. The Agency will, of course, consider the OPEI (590)
comment when it promulgates regulations for specific products.
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The comment of the industry representative (910) is based on
the belief that each product off the assembly line must be tested.
This is not true. In the product-specific subparts of Part 211,
the Agency's present strategy will require limited testing (in
most cases, one test) to determine noise label values. However/
because it requires very limited testing initially, the Agency
must have the ability to monitor the manufacturer's continued
compliance with the regulation. This ability will be provided
in product specific subparts of Part 211 through the use of com-
pliance audit testing which is based on the testing of a statisti-
cal sample of production units.
6.3 TECHNIQUE OF RATING
Technique of rating means the manner in which the determined
acoustic information is transformed into the appropriate acoustic
descriptor. Because many comments that touched upon this issue
have been discussed in relation to other topics, such as the
translation of dB (decibel) values into color codes or the use of
maximum test values for rating purposes, there are few submissions
remaining that focus solely on the techniques of rating. Thus, no
major issues are identified in this particular section.
There were, however, comments to the effect (1) that differ-
ent rating techniques for different products would only confuse
the consumer (520); (2) that rating schemes using comparisons
between dissimilar products would be "worthless" (943); (3) that
descriptors based on collapsing decibel values into classes based
on ranges of decibels would achieve very little in terms of the
public's comprehension of the program, while costing consumers a
great deal in terms of lost information (405, 555); and (4) that
multiple indicators be used (692).
Response;
Although the Agency admits that different rating techniques
for different products may confuse the consumer, the broad scope
of the labeling program, and the incorporation of many different
products within its statutory reach, means that variations in
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rating techniques may be necessary. Likewise, while the use of
comparisons between dissimilar products may appear confusing,
certain situations can be imagined where comparative information
can best be conveyed in this manner. Finally, the Agency agrees
that the use of noise classes in lieu of the actual units of
measurement sacrifices a great deal of information and should be
avoided to the maximum extent possible. These matters will be
addressed in the product-specific regulations.
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SECTION 7: ENFORCEMENT
7.1 GENERAL ISSUES
Issues related to EPA enforcement of the noise labeling re-
gulations drew comments from citizens, noise-related interest
groups, federal and local government officials, and industry
representatives in particular.
Most of the citizen comments in this area called upon EPA to
strictly enforce the program and impose strong penalties on indus-
tries found in violation of its provisions. Nine comments lent
support to tight and rigid enforcement by EPA; none of those orig-
inated from industry sources.* In several of these cases it is
difficult to determine if the strict enforcement being endorsed
refers to the noise labeling program in particular or noise con-
trol in general, but the direction of the messages is unmistak-
able. The Metropolitan Washington Council of Governments (COG)
(901) spoke to the need for government oversight of the reported
noise ratings, but did mention the possibility of industry self*
policing as well. Citizens Against Noise (903) urged that penal-
ties proportionate to the size of the audience affected be imposed
for violations of the labeling regulations. A Minnesota state
pollution official (953) opted for a strictly enforced program
with required labeling for a few products over a weak program with
labeling requirements for many products.
On the other hand, four commenters (64, 147, 629, 904) - two
from industry, one acoustical engineer and one physician - called
for EPA to implement and enforce the program slowly or cautiously
to allow sufficient lead time for easy industry compliance. The
J. I. Case Company (392) contended that strict enforcement by
EPA would not be necessary, since industry protocol and competi-
tion would be sufficient incentives for compliance. They sug-
gested that EPA's involvement consist of occasionally checking a
*The entries not cited in the text are: 60, 77, 382, 384, 940
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product's noise level rating. Johns Manville Corporation (692)
suggested that EPA work closely with industry in formulating
enforcement rules.
The U. S. Department of Commerce (744) urged EPA to make ex-
plicit its intentions regarding effective dates of the provision
of the labeling program.
A professor of physics at Northern Illinois University (546)
suggested an enforcement method that would reimburse the purchaser
one-half the purchase price if a product subject to noise labeling
had no label or had an incorrect label. The Director of the Divi-
sion of Air and Hazardous Materials of the Commonwealth of Massa-
chusetts (637) believed that the Federal government should handle
noise labeling and emission standards, while jurisdiction over reg-
ulation of noise-emitting equipment should rest with the states.
A number of comments, predominantly from industry, addressed
some aspects of EPA's ge'neral enforcement scheme as set forth in
the NPRM. Ford Motor Company (907) objected to much of the en-
forcement plan as similar to that of the "cumbersome" regulations
for medium and heavy truck noise, currently under litigation.
Ford expressed a preference for a more flexible certification pro-
gram for muffler noise such as those in the states of Florida and
California. Chrysler Corporation (672), also citing the truck
noise regulation litigation arguments, contended that EPA lacked
the authority for the proposed enforcement scheme, calling for
minimal EPA involvement under Section 8 of the Noise Control Act
°f 1972. The Industrial Safety Equipment Association (745) as-
serted that the proposed enforcement provisions magnify the manu-
facturers' requirements as stated in Section 13 of the Noise Con-
trol Act, by requiring manufacturers to admit EPA officers to
various facilities, by permitting these officers to conduct in-
spections, and by requiring the submission of irrelevant data.
International Snowmobile Industry Association (905) suggested
that instead of going far afield with all-encompassing regula-
tions, enforcement should focus on the manufacturer's capability
to perform the required tests, the results of the noise emission
tests, and the auditing of these tests.
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The Compressed Air and Gas Institute (CAGI) (910) expressed
the view that finding a single product in excess of its labeled
noise rating should not constitute a violation of the regulations,
and in a similar vein. The Outdoor Power Equipment Institute (590)
asserted that EPA should allow a reasonable margin for error in
individual product compliance with its labeled noise rating. CAGI
preferred the approach in the EPA gas mileage program in which
each individual product need not attain its labeled value.
A final general comment was made in reference to the respon-
sibility for maintaining labels. A representative of a group of
retailers (591) contended that they should not be held responsible
for labels damaged in transit to their businesses.
Response t
Issues concerning specific areas of enforcement are addressed
in the following subsections.
However, to answer the above comments, in determining the
effective date of any labeling action, the Agency will consider
the lead time each individual industry needs to economically bring
their products into compliance with the labeling requirements.
Lead time adequate to assure product compliance with the require-
ments will be included in the effective date of an individual
labeling regulation, consequently, there is no need for additional
lead time preceding Agency enforcement.
The Agency will actively pursue enforcement of each product
labeling regulation. However, the Agency's noise labeling program
has been developed to use industry competition as an incentive to
manufacturers to comply with product labeling requirements for
their industry. EPA has, and will, work with industries being
studied for possible labeling action; and will study the effective
date, test procedures and enforcement provisions separately for
each regulated industry or product.
While the General Labeling Provisions are expected to apply
to all labeled products, the Agency will make adjustments within
an individual product regulation where a general labeling provi-
sion, in the Administrator's judgment, should not be applicable
to a certain product or industry.
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Once noise labeling regulations have been promulgated, the
Agency is required under the Act to enforce those regulations.
Section 10(a) of the Act makes it clear that the distribution of
"any new product . . . except in conformity ..." with the ap-
plicable regulation is a violation. The Administrator may initi-
ate court action for certain types of violations or may issue
administrative orders in other cases.
Concerning the comment about the Agency's enforcement scheme,
the basic enforcement plan for Product Noise Labeling is the same
as that of the medium and heavy duty truck and portable air com-
pressor regulation. It is focused to interfere as little as pos-
sible with the manufacturer's business and still give the Agency
reasonable assurance of compliance.
Concerning the comment about labels damaged in transit, the
Person responsible for damage to a Federally mandated label is
responsible for tampering.
7.2 INSPECTION AND MONITORING
The inspection and monitoring aspects of the enforcement pro-
visions (Section 211.1.9) elicited a number of comments, including
fifteen from industry, one from an acoustical consultant, and one
from a Minnesota state official (953). The majority of these
comments took issue with EPA's proposed inspection provisions,
deeming them unauthorized, unwarranted, or excessive in some
wanner.
The Compressed Air and Gas Institute, Industrial Safety
Equipment Association, Chrysler Corporation, Ford Motor Company
and General Motors Corporation (910, 745, 672, 643, 622) each
stated that EPA lacked the statutory authority for the proposed
inspection and monitoring scheme/Both Ford arid Chrysler (643,
672) cited their objections to the truck noise inspection regula-
tions under litigation, which they hold to be similar to those of
noise labeling standards. Rockwell International (633) simi-
expressed doubt about the legality of the proposed EPA entry
inspection of facilities and the requirement for shipping
Products to a central test facility.
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Hilti Fastening Systems, Inc., and Bilsom International, Inc.
(671, 380) stated that the provision for on-site inspection of
facilities is unreasonable, the latter citing the proprietary na-
ture of the firm's products. Charles Machine (627) called for EPA
to limit access to manufacturer's facilities to areas relevant to
the investigation, with these areas to be specified in writing
prior to the inspection period.
The Association of Home Appliance Manufacturers (AHAM), Fasco
Industries, and The Air Conditioning and Refrigeration Institute
(ARI) (629, 197, 902) each objected to the 24-hour notice require-
ment as unreasonably disruptive and requested a longer period of
notice. As far as the International Snowmobile Industry Associa-
tion (ISIA) (905) was concerned, their major concern with the 24-
hour notice provision was its failure to state specifically that
this period was to be one normal business day. ISIA also urged
that the provision be clarified to assure that oral notification
is used "sparingly" and only given to "responsible management per-
sonnel." Rapistan, Inc., (166) suggested that inspection without
the 24-hour notice should only be authorized by the Assistant Ad-
ministrator for Enforcement "if there is evidence that improper
manufacturing and testing procedures are being employed by a com-
pany." Motorcycle Industry Council, Inc. (713) also suggested
that reference to "oral" notice be deleted.
The Association of Home Appliance Manufacturers (629) argued
that only finished products should be photographed and inspected
for compliance, while The Air Conditioning and Refrigeration
Institute (902) objected to EPA's photographing products alto-*
gether because of the possibility of a competitor securing the
information through a Freedom of Information Act request. The Air
Conditioning and Refrigeration Institute also argued that a rela-
tively long notice period should be required when EPA informs a
manufacturer that a specific product is to be tested or that a
specific test facility is to be used for an EPA-monitored test/
because products may be "built to order." Other ARI objections
were directed at the tight scheduling of test facilities and the
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required retention of test records. The Industrial Safety Equip-
ment Association and the Motorcycle Industry Council also ex-
pressed their concerns about the recordkeeping requirements (745,
713). The Association of Home Appliance Manufacturers (629)
expressed the opinion that manufacturers should not be liable for
the costs of EPA investigations of the test methods employed by
test facilities.
Bilsom International, Inc. (380) commented that Section
211.l.9(b) overreaches EPA's extraterritorial authority and sug-
gested that EPA need not enter foreign facilities to fulfill the
purpose of the regulations. - Flents Products Company (904) com-
mented on the lack of clarity in the definition of "manufacturer"
for importation purposes (Sections 211.1.1 and .9). The question
Posed was: Does "manufacturers" encompass "assemblers"?
A state pollution control official (953) opposed parts of the
Proposed enforcement scheme, asserting they were too lenient. He
objected to both the 24-hour notice period before entering a manu-
facturer's facilities, and the need for a "substantial" infraction
before remedial action is taken.
Several comments related directly to the Administrator's
authority to order a manufacturer to cease distribution of certain
Products in commerce - Section 211.1.9(f)(1). General Motors
Corporation (622) argued that this provision stands in conflict
with Section ll(d)(l) of the Noise Control Act of 1972, since it
does not limit the Administrator's cessation authority to orders
"necessary to protect public health or welfare". Ford Motor Com-
Pany (643) expressed an almost identical position. Flents Prod-
u°ts Company (904) suggested language be added to the cessation
section vesting authority for a "cease to distribute" order
clearly and exclusively in the Administrator. Charles Machine
^orks, inc. (627) emphasized its belief that the Noise Control Act
°f 1972 grants EPA no authority to issue a product recall even if
product is in violation of the regulations. The Compressed
and Gas Institute (910) believes that the power to issue
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"cease to distribute" orders properly rests with the Federal Dis-
trict Courts and not with the Agency. The Outdoor Power Equip-
ment Institute (590) went further in calling for deletion of the
"cease to distribute" provisions, arguing that EPA lacked the
statutory authority to issue such orders. The Industrial Safety
Equipment Association (745) said the provisions may be unconsti-
tutionally vague, in that the grounds for a cessation order are
ill-defined and especially the term "substantial."
Response;
The inspection and monitoring scheme was authorized by the
inspection and monitoring provisions of Section 13(a) of the Act
and were included in the proposed Noise Labeling Standards -
General Provisions on June 22, 1977 (40 CPR Part 211). Both
inspection and monitoring provisions were based in part on the
legal interpretation of EPA that the Agency was not required to
obtain judicial warrants in instances where the manufacturers did
not willingly consent to the entrance by EPA enforcement officers
upon regulated manufacturers' facilities.
On May 23, 1978, the Supreme Court delivered a decision in
Marshall v. Barlow, Inc.,436 U.S. 307, (1978). In that decision/
the Court held that administrative agencies must ordinarily
obtain search warrants to enter private property for regulatory
purposes, absent consent of the property owner.
Accordingly, EPA has revised subsections (b) and (e) of Sec-
tion 211.1.9 concerning inspection and monitoring provisions to
make it clear that an EPA enforcement officer may enter a facil-
ity only upon consent of the manufacturer unless the enforcement
officer first obtains a warrant authorizing such entry. The
final rule also provides that it is not a violation of the Act or
the regulation if a manufacturer refuses entry to an enforcement
officer who does not have a proper warrant.
Provisions of the regulations which define the scope of the
inspector's proper investigation are retained, to assure the manu-
facturers that both consensual and judicially warranted searches
are subject to reasonable limitations.
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Another revision to subsection (e) clarifies the Administra-
tor's right, as contemplated by Barlow1s, to proceed ex parte
(without the other party's knowledge) to obtain a warrant, with or
without a prior refusal by a manufacturer to permit entry.
Paragraph (c)(3) was revised to eliminate the mandatory as-
pects of consent. Those provisions in paragraph (c)(3) that ap-
plied to foreign manufacturing facilities have been eliminated,
since EPA no longer requires domestic manufacturers to consent to
entry. It is still incumbent upon foreign manufacturers, however,
to work with EPA to assure that the testing that is performed by
such manufacturers is performed in accordance with the regulatory
requirements. The EPA cannot satisfy itself of the validity of
manufacturers' tests if it cannot monitor them in some manner.
Subsection (f), which specified that the Administrator may
issue cease to distribute orders when EPA Enforcement Officers are
refused entry or denied reasonable assistance, has been removed
from the final rule. Should a manufacturer deny entry where the
EPA enforcement officer has obtained a warrant, the Act and this
regulation will have been violated, and the Administrator will
consider it an option to use the enforcement authorities granted
him in section 11 of the Act.
Regarding limited EPA access to manufacturer's facilities,
EPA has no interest in entry into developmental laboratory areas
°r areas not concerned with a manufacturer's activities under the
Noise Control Act of 1972. The Director of the Noise Enforcement
°ivision, may request that a manufacturer subject to this Part
admit an EPA Enforcement Officer to examine records of tests con-
ducted on label verification products and on product tests under
compliance audit testing (CAT); to inspect areas where testing is
conducted, where regulated products are stored prior to testing,
a*d to inspect those portions of the assembly line where the
regulated products are being assembled.
The provision requiring 24-hour notice has been removed from
the regulation since inspections and investigations may only be
°arried out with the consent of the manufacturer or under a war-
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The manufacturer concerned with how EPA's photographing of
either finished or unfinished products may affect his interests
will be able to file a request under section 2.203 of the EPA
procedures for Confidentiality of Business Information (40 CFR
Part 2 Subparts A and B). The Agency will determine at the time
of the request whether the information requires confidential
treatment. At this time the manufacturer is given the opportunity
to comment on why the material should be treated as business
confidential (i.e., proprietary).
As to a manufacturer's liability for inspection and investi-
gation costs, the EPA does not expect any major cost burdens to be
imposed on the manufacturers pursuant to inspections and investi-
gations carried out under the final regulation.
7.3 EXEMPTIONS
Of the ten comments that dealt specifically with the provi-
sion for exemptions (Section 211.1.10), nine came from industry
representatives and one from a noise-related public interest
group. All of these comments offered suggestions for changes in
exemption provisions or were critical of some aspects of the
proposed exemptions.
The Motorcycle Industry Council (713) believed this Section
lacked clarity and should be reworded or explained.
7.3.1 Products for Export, Promotion, Demonstration, or Prototype
Both The Association of Home Appliance Manufactuers (629) and
The Air Conditioning and Refrigeration Institute (902) objected to
the exemptions to be granted for promotional, demonstrator or pro-
totype products not intended for commerce (Section 211.1.10-l(f))r
because of improper use that could be made of such products in
advertising or display settings. Presumably, the promotional
abuse of such untested products could lead to unfair competitive
advantages based on inaccurate claims about noise levels.
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A representative of the Hawaii chapter of Citizens Against
Noise (CAN) (940) testified in opposition to the exemptions for
demonstrator and training products, as well as products for ex-
port. CAN-Hawaii urged, in effect, that the program be imple-
mented at the early stages of product development.
The Outdoor Power Equipment Institute (590) objected to the
requirement that industry apply for an exemption for prototype
Products due to possible delays in the process. They suggested
instead that this issue of exemptions would be more properly ad-
dressed in the product-specific regulations. Similarly, Hilti
Fastening Systems (671) suggested an automatic exemption for all
qualified products not intended for general commercial use. Hilti
also believed that the exemption procedure needed clarification as
to whether a product under development must be exempted, and at
what stage in the development process an exemption must be ob-
tained.
Two commenters (629, 902) objected to the exemption to be
granted for promotional, demonstrator or prototype products not
intended for commerce because of improper use that could be made
°£ such products in advertising or display settings.
.Response;
The only products that would require exemptions under this
section are those that are distributed in commerce. The manu-
facturer need not apply for exemption under these regulations
for products that are not distributed in commerce (i.e., do not
leave the manufacturer's premises), and need,not fullfill any of
the requirements of Subparts A or other Subparts promulgated
Pursuant to 40 CFR Part 211.
Manufacturers who request an exemption under these regula-
tions for promotional, demonstrator, or prototype products, to be
Distributed in commerce, will be required to demonstrate suffi-
cient necessity, appropriateness, and reasonableness of the.
request.
Any exemptions granted by the Agency for demonstrator or
ning products are authorized by the Noise Control Act. The
specifically authorizes the Administrator to exempt products
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for the purpose of research, investigations, studies, demonstra-
tions, or training, or for reasons of national security.
The Administrator has the discretion to grant exemptions upon
such terms and conditions as he may find necessary to protect the
public health and welfare.
The Administrator is not given any discretion under the Noise
Control Act in granting exemptions for products intended for ex-
port only. No request for exemption for such products is required
by the Act; however, they must be labeled or marked to show that
they are manufactured solely for use outside the United States.
Application for exemption for prototype products should not
lead to delays. Industry need only apply for exemptions for
prototype products that will be introduced into commerce. If
prototype products are introduced into commerce by the manufac-
turer in the ordinary course of business for a valid exemption
purpose such as product development, assessing a production
method, or as a market promotion, no delays in granting the exemp-
tions should be expected. Where the program does not involve
lease or sale of the products, the manufacturer need only state
the nature of the product's use, number of products involved and
demonstrate that adequate record keeping procedures for control
purposes will be employed.
At this time no automatic exemptions will be granted in the
regulations for any products distributed in commerce except for
products intended solely for export. The Noise Control Act
requires the Administrator to take into account the public health
and welfare in setting the terms and conditions of the exemption.
Therefore, it will be necessary for the Administrator to take
into account the public health and welfare considerations based
on information supplied to him by the manufacturer for the par-
ticular product under consideration. However, if the Agency finds
during the enforcement of this program that it is advisable to
grant an industry-wide exemption for one or more purposes, this
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exemption and its terms and conditions will be set out and sup-
plied to all manufacturers. Only after gaining some experience
in administering this program will the Agency consider whether
to grant such an "automatic11 exemption.
As to products under development, any non-complying product
requires an exemption when it is distributed in commerce. Manu-
facturers are in the best position to know the time of distribu-
tion, and should apply for an exemption at least a month in
advance.
7.3.2 Exemptions from; Labeling vs. Testing
Ford Motor Company (643) suggested that an automatic one-year
exemption be granted a product should the Administrator fail to
respond to the manufacturer's exemption application within 15
working days. Ford and General Motors-Corporation (GM) (622)
urged EPA to eliminate the automatic retroactive rescission of the
export exemption (Section 211.1.10-3(c)) in the event the product
is introduced in domestic commerce. To realize this objective, GM
suggested that the cited paragraph be changed in keeping with a
Proposed alteration in the Truck Noise Emission Regulation (pro-
Posed amendments to truck regulation, Section 205.5-5(c): 42 PR
27622, May 3, 1977).
The International Snowmobile Industry Association (ISIA)
(905) believed that Section 211.1.10 should be rewritten to cover
situations where an exemption "from labeling" is warranted, rather
than an exemption "from testing," since the regulations establish
"labeling" requirements.
Bilsom International, Inc. (380) also focused on the "label-
ing" versus "testing1' exemption aspect of the provisions, suggest-
ing that EPA delete the condition requiring a label for an exempt
Product "setting forth the nature of the exemption" (Section
211.1.10-4(a)). In their view, this labeling condition would
negate the value of the exemption, since the costs of label
Preparation, which are high, would still have to be incurred.
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Response;
The condition requiring a label on an exempt product "setting
forth the nature of the exemption", serves a two-fold purpose.
First, it puts the consumer on notice that the product is not
required to be labeled according to its noise emitting or noise
attenuating characteristics. Second, it also notifies State and
local officials who may be charged with enforcement of labeling
provisions at the consumer level, that the product is not in
violation of an applicable EPA regulation.
7.4 TESTING BY THE ADMINISTRATOR
Eight industry spokesmen raised objections to some aspects of
the provisions for testing by the Administrator (Section 211.1.11).
Several of them were concerned primarily with the costs of the
required testing; others focused on the extent of the Administra-
tor's authority to mandate compliance testing.
In addition to these comments, a number of industries (e.g.,
the Compressed Air and Gas Institute (CAGI), ISIA, and Rockwell
International) (910, 905, 633) expressed concern about Section
211.1.11(a)(1) for requiring that products be shipped to a testing
facility specified by EPA.
Fasco Industries (197) suggested that the regulation spell
out what direct and indirect testing costs would be reimbursed by
EPA, while Bilsom (380) requested assurances that EPA would bear
the cost of any testing required by the Administrator. CAGI (910)
desired full reimbursement of costs for shipping products to EPA
testing facilities.
The Association of Home Appliance Manufacturers (AHAM) (629)
suggested that the Administrator be required to provide the manu-
facturer with sufficient advance notice of a decision of mandatory
product compliance testing under Section 211.1.11(a)(1) and (2).»
Ford Motor Company (643) recommended a revision to limit the Ad-
ministrator's discretion to require manufacturers to provide prod-
ucts for testing, in keeping with a compromise reached in the
litigation on the truck noise regulation. Ford also felt that the
208
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manufacturer should be allowed to observe EPA testing and to con-
test an adverse EPA determination on the acceptability of the
manufacturer's test facilities.
Johns Manville Corporation (692) recommended the use of
industry facilities for testing purposes.
To avoid duplication, the Outdoor Power Equipment Insti-
tute (OPEI) (590) suggested that testing occur at either EPA-
designated facilities or at the manufacturer's, facilities certi-
fied by EPA with the choice left to the manufacturer. In the
International Snowmobile Industry Association's (ISIA) (905) view,
Section 211.1.11 should be rewritten to conform to statutory
language regarding the requirement to make products available for
testing? ISIA also doubted the legal authority of EPA-personnel to
operate a manufacturer's private test facility under Section
2l1.1.11(a){2).
The Compressed Air and Gas Institute (CAGI) (910) questioned
the lack of clarity concerning testing of premarket products,
fearing that a requirement for EPA supervision of such testing
would impede new product development and introduction.
Response;
The cost of required testing under Subpart B (Noise Labeling
Requirements for Hearing Protectors) (such as label verification
°r compliance audit testing) or any of the other product-specific
Subparts will be borne by the manufacturer. The cost of testing
when it is conducted by EPA under section 211.1.11, Testing by the
Administrator, will be borne by the Agency except: .
• When the EPA requires the manufacturer to ship products
to a particular test facility for label verification
testing, because the manufacturer has not label verified
within a reasonable amount of time. The amount of time
considered reasonable will be defined in the product
specific regulation;
• When EPA has reason to believe, that products would not
pass at an EPA designated facility even though they pass
at a manufacturer's facility;
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• When a notice of nonconformance of the manufacturer's
test facility is effective until the facility has been
re-qualified; and
• Whenever EPA requires shipment of products to a desig-
nated test facility because the manufacturer refused to
allow EPA Enforcement Officers with a warrant to monitor
a test.
EPA will generally not specify a test facility under any
required compliance audit testing unless it has reason to believe
that products which pass at the facility used by the manufacturer
would not pass at an EPA designated facility. Under these cir-
cumstances, the Administrator will provide the manufacturer a
statement of his reasons.
When the Administrator designates testing is to be conducted
at an EPA facility (or facility under contract to EPA), EPA will
pay for all direct testing costs including personnel, equipment,
preparation, test site, etc. However, in most cases the manufac-
turer will be required to pay shipping costs of the products to
the EPA designated site.
When testing under 211.1.11 is designated to be conducted
at the manufacturer's facility, EPA personnel will conduct such
testing using Agency equipment. It is not expected that any
direct testing costs will be incurred by the manufacturer under
these circumstances.
A manufacturer is always allowed to observe any EPA testing
required by this regulation whether it be conducted at an EPA
facility, or at a facility under contract to EPA. A manufacturer
is also provided the opportunity to request that the Administrator
reconsider his determination on the acceptability of the test
facility, based on data or information which indicates that
changes have been made to the test facility and such changes have
resolved the reason for disqualification.
Section 2 11 .1.11(a)(2), concerning the operations of EPA
personnel at a manufacturer's private test facility, has been
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changed to state that the Administrator, when testing at a manu-
facturer's test facility, will use Agency equipment.
Revisions limiting the Administrator's discretion in the
number of products to be tested under Section 211.1.11 of the
regulation are amenable to EPA. However, limits that will be
Placed on the Administrator's discretion will be based on particu-
lar industry characteristics such as number of manufacturers,
total number of products distributed in commerce by manufacturers
and other characteristics which the Administrator may see as ap-
propriate. These limits will, because of their nature, be re-
quired to be placed under the individual product-specific Subparts
°f Part 211. Consequently, Subpart A, section 211.1.11 will not
changed at this time but may be amended in other Subparts.
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SECTION 8: ECONOMIC IMPACT
8.1 REQUESTS FOR FURTHER AGENCY ECONOMIC ANALYSIS
A number of oral and written comments to the public docket
focused on the issue of the labeling program's economic impact.
Specifically, 41 commenters* were concerned about higher prices
for labeled products, or increased taxes due to administrative
costs.
Several individuals who supported the labeling program com-
mented on the topic of higher costs for consumers. One commenter
(919), a factory worker and union official, stated that he would
rather see these increased costs passed on to the consumer than to
the worker, since quieter machinery is a cost of production that
should not be born by the employee.
Several manufacturers (589, 590, 629, 907, 910) called for
extensive economic studies by the Agency to determine the labeling
program's costs to industry and consumers, in lieu of immediate
implementation of the program. The Ford Motor Company (907)
stated they could find no evidence in the Draft Background Docu-
ment [5] or in the Notice of Proposed Rulemaking (NPRM) [6] that
the Agency planned to consider the increased costs to the consumer
in assessing the expected health and welfare benefits from the
labeling program. Therefore, Ford urged a comprehensive cost-
benefit analysis of each proposed product labeling action before
mandating such action. Ford contended that such an analysis
(of impacts on consumers) is required on the basis of Executive
Order 11821, as extended by Order 11949 'and as construed by OMB
Circular No. A-107. Their concern seemed to result from their
reading of the NPRM statement that the economic analyses "will not
address potential market effects that may be produced as a result
of the information provided on the Federally required label...."*'
*(008, 027, 028, 029, 042, 043, 057, 068, 070, 072, 094, 142, 167,
214, 252, 253, 299, 301, 328, 356, 360, 370, 373, 404, 426, 454,
468, 572, 575, 592, 597, 603, 614, 621, 639, 681, 697, 914, 922,
923, 933)
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This concern was also expressed by the Outdoor Power Equipment
Institute (OPEI) (590) along with the Compressed Air and Gas
Institute (CAGI) (910). In addition, OPEI thought the Agency's
analysis should consider recordkeeping costs.
The Association of Home Appliance Manufacturers (AHAM) (629)
claimed the Agency should consider "potential market effects",
since the (labeling) program could have a serious adverse impact
on manufacturers who not only label their products but also make
them quieter. AHAM contended that all economic impacts should be
addressed before publication of any proposed rule-making.
General Motors (622) combined their concern about increased
consumer prices with several recommendations for minimizing costs:
"(1) keep the label simple; (2) avoid change in range reference
(if adopted), and (3) allow the manufacturer freedom in the label
design and application to his product."
A different approach to cost/benefit analysis was taken by
the Director of the Office of Consumer Affairs of the Department
°f Health, Education and Welfare (623), who believes there should
be an experimental stage where a, few products are initially
selected for labeling and cost/benefit analyses of these actions
Precede further product selections.
Finally, an economist (955) turned the focus of attention
toward the costs of noise, arguing that on-the-job accidents,
disability claims, and general loss of productivity
to lack of sleep, annoying work conditions, etc., represent
excessive costs to society that often can be attributed to noise
Pollution. He alpo felt the problem of excessive noise was
increasing due to urbanization and that the labeling program would
help to make the market mechanism operate more effectively. The
overall implication was that the net costs of labeling might be
e*tremely small, or even negative, if noise is reduced through use
°f the label information.
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Response;
The economic impacts of the Agency's Section 8 noise labeling
program will be addressed within the product-specific labeling
actions to be proposed in the future and not for the total pro-
grammatic effort. The intent of Congress to establish the label-
ing program and to require the labeling of noise-producing and
noise-reducing products is evident in Section 8 of the Act and
does not warrant a comprehensive cost/benefit analysis.
The analysis of the economic impact of the product-specific
regulations will entail a determination of the manufacturer's costs
in complying with the labeling requirements. The analysis will
therefore focus on testing costs, recordkeeping costs, and product
packaging/labeling costs.
In response to the criticism concerning the failure to ana-
lyze "potential market effects," the Agency reemphasizes that it
will assess the impact of the labeling requirements on manufac-
turers and product prices that result from the costs listed above/
but will not consider possible price increases or decreases due to
redesigning of products to attain a lower noise rating or to
market shifts produced by the information on the labels. The
rationale for this approach is that the noise labeling program
does not require any changes in products' acoustical performance
or in their markets but simply provides information that may
facilitate more informed voluntary market choices by product
purchasers.
Finally, the Agency does not believe that an experimental
stage is warranted nor permitted by the statutory language of
Section 8, which clearly assigns EPA a nondiscretionary mandate to
label noise producing and noise reducing products.
8.2 Submission of Cost Data by Industry
Though manufacturers expressed a great deal of concern about
the costs associated with the labeling program, very
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submissions included specific cost data. Listed below are brief
references to these limited cost figures and the relevant docket
entry numbers.
• The American Rental Association (908) said a noise label
they developed for an air compressor costs $5.00 per
label.
• Outboard Marine (660) gave the following cost estimates:
Testing and certification = $3,000 per year
per model
One-time process engi-
neering changes = $2,000
Labels and application
costs • $9/000 per year
• Aural Technology (949) stated that a pressure sensitive
label would cost three cents per unit, while a sample
brochure with the label information printed on it would
cost 1 1/2 cents per unit. Costs for graphics and
preparation of camera-ready copy were $10,000, of which
$7,500 were non-recurring expenses.
• Air-Conditioning & Refrigerator Institute (ARI) (902).
cited an estimated labeling cost of $1.00 per unit.
• The International Acoustical Testing Laboratories (400)
said the standard fee for conducting a sound power test
in accordance with ANSI SI.21 is $300 but this figure
would be reduced to $200 if fewer frequency bands were
taken. A single-number sound power level test would
cost around $150.
• Flents Products (904) said an (ANSI) attenuation test
costs about $2,000 and added that labeling would add 80
percent to the costs of some of their containers.
In relation to testing costs about which several manufactur-
complained, one acoustics expert (909) felt the labeling
would eventually result in lower fees, given rapid
advances in technology induced by new economic incentives.
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Response
The Agency appreciates the submission of these data on test-
ing and labeling costs and welcomes any additional documentation.
These cost data will be given due consideration in the Agency's
product-by-product economic analysis.
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SECTION 9: CONSUMER ISSUES
9.1 PROBLEMS EXPERIENCED IN COMPARISON SHOPPING
The labeling program presumes that consumers will consider
the factor of noise in their purchasing decisions, if given the
opportunity to do so by having access to information on products'
noise ratings.
A number of commenters who were critical of the labeling
program maintained that they were capable of exercising their
own independent judgment when purchasing products.(a) Some
expressed the opinion that they could individually determine the
quieter product without noise level data on a label (122, 128,
217); while others felt the market mechanism was sufficient to
Produce less noisy products, if in fact consumers desired such
products (113, 284, 356, 412, 434). One businessman stated that
consumers who care about the noise level of products can ask for
demonstrations at the point-of-sale (88).
A number of commenters were in disagreement with these
general positions. Many commenters supported the program on the
basis that it would permit greater consumer choice and would
facilitate comparison shopping.("> Others asserted that they
would use the noise-related information to comparison shop if it
were provided (448, 601, 617, 931, 943).
According to many commenters, information on product noise
levels is generally unavailable. Some persons cited cases where
they experienced difficulties in shopping for quiet products.(c)
Others (505, 564) stated that they would not have purchased cer-
tain noisy products if the package had contained a label indicat-
ing the noise characteristics. One commenter (667) who had con-
siderable experience in the acoustics field, claimed that despite
(a>(43, 123, 177, 217, 364, 591, 923).
(b)(30,238, 363, 595, 730).
(c)(403, 456, 499, 534, 553, 609, 618, 638, 667, 669, 901,
903, 932, 937, 943).
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his expertise, he confronted major problems in comparative shop-
ping for quiet products. A consumer (943), who testified at the
public hearing in San Francisco, complained that she spent con-
siderable time trying to research the topic of household noise
but could not find information on the noise levels of certain
products. The Ford Motor Company (907) also admitted that, even
though the company's advertising in some cases stresses the quiet
quality of its cars, interior noise level data are not provided to
consumers.
Another point brought out in the docket is that even where
industries have developed a voluntary noise labeling program, con-
sumers still are presented with obstacles hindering intelligent
purchasing decisions. For example, the International Snowmobile
Industry Association (611) explained that their certification
program does not, at the current time, provide consumers with
specific information about noise levels at the operator's ear*
Oral testimony given on behalf of the Air Conditioning and Refrig-
eration Institute (ARI) (902) indicated the problems a consumer
would confront in trying to determine the noise emitted by an air
conditioner certified by ARI. The ratings are provided in a
directory which costs several dollars. Since ARl's address is not
on the label, most consumers would not even know where to go to
obtain the directory, if in fact they knew one existed.
Two commenters (431, 644), who expressed support for the
labeling program, suggested that merchants be required to demon-
strate products on the salesroom floor, thereby providing some
direct information about product noise levels. Other commenters
(470, 901, 937), however, mentioned the major problem in utilizing
this approach - namely, the unreliability of demonstrations due to
the effect of the storeroom environment on a product's noise emis-
sion properties. Besides noting the impossibility of realistic
product demonstrations in storerooms, a Program Manager for an
areawide environmental noise program (901) mentioned that product
comparisons between stores are meaningless due to variations in
ambient levels and a person's inability to recall or remember the
precise noise levels of products he listened to previously.
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An issue related to the problems consumers face when compari-
son shopping is the extent to which there exists misleading
advertising about product performance with respect to noise prop-
erties. Complaints about misleading or false advertising were
made by a number of commenters (4, 41, 189, 403, 547). In addi-
tion, several professionals in the noise control or acoustic field
(952, 953, 954) claimed that some testing laboratories frequently
engage in fraudulent or unethical activities designed to cast
their clients' products in the best possible light with respect to
noise emissions. An acoustics consultant (952) commented at
length about the manipulation of measurement methodologies by
testing laboratories and recommended that the labeling program
include as one of its objectives the elimination of false, unsub-
stantiated noise-related claims of manufacturers.
Response;
None required.
9.2 FREQUENCY DISTRIBUTION OF NOISE-RELATED
COMPLAINTS ABOUT PRODUCTS
Many commenters,* in their letters or oral testimony, identi-
fied products which they consider noisy and which they believed
should be labeled or otherwise regulated with respect to their
noise emission. A tabulation of these products is presented in
Table 2-1 for information purposes only. Excluded from this tabu-
lation were comments made on behalf of potentially affected indus-
tries or trade associations.
While it would be helpful to have an exact count on the num-
ber of persons who actually recommended that a certain product be
labeled, many persons simply listed a series of noisy products.
Consequently, the tabulation cannot be interpreted as an endorse-
ment for labeling the specified products. However, in most
instances the respondent who mentioned noisy products was support-
ive of noise control.
*Entries 687 through 720 and 731 through 745 were received too
late for inclusion in this frequency distribution.
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Table 2-1
Number of Noise-Related Complaints
Made About Various Products
Household Appliances
Appliances
kitchen appliances
appliances with electric
motors
small appliances around
the face
Clothes washers
Coffeemakers/grinders
Dishwashers
Electric brooms
Electric scissors
Electric shavers
Fans
electric table fan
exhaust or hood fan
floor fan
window fan
Hearing and Cooling Systems
Air blowers
Air conditioners2
Dehumidifiers/humidifiers
Furnaces
forced-air heating units
furnace fan
heat blowers
23(26)1
1
1
25
6
47
3
1
1
14(22)
11
5
11
1
3
77
3
2(9)
4
2
1
Floor polishers
Fluorescent lamps
Freezers
Garbage disposals
Hairdryers
Meat grinders
Mixers
Refrigerators
Sewing machines
Trash compactors
Typewriters
Vacuum cleaners
Water softening device
Heat pumps
Ventilation equipment
Products with Sound-Producing Function
Bird-frightening devices"2Tape Recorders
1 Televisions
3 commercials
10 P.A. systems
11 School bells
16 Sirens
CB radios
Musical equipment
Musak
Radios
Stereos
Toys
Air horns
"Big Wheels"
Electric trains
1
7
1
Firecrackers
Model boats/planes
Toys
2
5
2
10
41
1
19
71
1
1
6
106
1
4
2
16(30)
14
2
1
2
1
3
3
^-Numbers in parentheses represent the total number of complaints
for a product class, or the sum of the general product references
(e.g., fans) and the specific references (e.g., floor fan, exhaust
fan, etc.)
20nly five individuals specified central or room air conditions.
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Table 2-1 (Continued)
Number of Noise-Related Complaints
Made About Various Products
Surface and Air Transportation
Airplanes
Concorde
Military
Bulldozers
Buses
Freight trains
Whistles
Helicopters
Motorboats
outboard motors
Jet-ski
Motorcycles
Mufflers
Lawn and Garden Equipment
Blowers ~
Compost grinders
Garden tillers
Hedge trimmers
Lawn and garden equipment
Power Tools
Chain/ power saws
20(26)
3
3
1
13
5(9)
4
1
8(15)
6
1
138
11
5
1
2
1
26
36
5
Passenger cars
mufflers on cars
horns
foreign cars
hot rods/race cars
Recreational vehicles
snowmobiles
motor/trail/minibikes
dune buggies
Tires
Tractors
Trucks
garbage trucks/
compactors
Vans
Lawn edgers
Lawnmowers
Tree cutters
Tree, limb and leaf
shredders
Power tools
Illness/Indus trial/Commercial Equipment
Ai*. 2 Highway construction
1 equipment
--. compressors
Bridgeport
Coding tower
Computerized cash registers
Computers
Construction equipment
Drop forge
MsceUaneous
•ftiectric irrigation pumps
cream vendors
1
1
1
4
1
1
2
1
Industrial equipment
Jackhammer
Lathe
Mill
Transformers
Pool filter pumps
Vending machines
46(68)
12
1
3
6
2(41)
16
21
2
1
5
41(48)
7
1
1
86
1
23
2
5
2
1
1
1
3
1
221
-------
Other interesting situations were provided by commenters who
opposed labeling but supported noise emission regulations for a
particular product, and by the few individuals who complained
about a source of noise but opposed Federal action.
The particular products mentioned are grouped into several
general classes (e.g., household appliances, heating and cooling
systems, etc.). Some general product references such as appli-
ances were recorded in certain instances, but not in the case of
complaints about the noise of "traffic," "urban life," or similar
generalities. In the case of "motor vehicles," the complaint was
recorded under "cars" and "trucks." In many instances there were
general references to a product class (e.g., passenger cars) and
specific references to types within a class or components (e.g.*
foreign cars, hot rods, auto mufflers, etc.) Complaints were
tabulated separately for both general and specific references; the
total number of complaints for a particular class is shown in
parentheses in Table 2-1.
Although this list cannot be interpreted in terms of the per-
centage of the public supporting labeling of a product, it does
offer some guidance about perceived noisy products. Of course/
an intervening variable affecting the number of complaints about
certain products was the mention of possible candidates for label"
ing in the news stories that may have generated some of the re-
sponses. All such news stories, however, did not include refer-
ences to possible candidate products.
Response;
None required.
9.3 EFFECTS OF NOISE
The issue of determining whether or not a product is capable
of adversely affecting the public health or welfare is discussed
in Section 1.2.2. That discussion included a review of manufac"
turers1 claims that their products did not have this capabilit:^
and—at their worst—could only be described as annoying.
222
-------
comments summarized in this section offer a different perspective
in that they represent complaints about the effects of noise
pollution. Some of these comments refer to environmental noise in
general, while others cite specific products. (For a list of all
product complaints, see Section 9.2).
Of the approximately 45 commenters who made reference to
the effects of noise on people, 35 cited some aspect of harmful
effects from product noise, either physical, psychological, emo-
tional, social, or some combination.*
The extent and variety of harmful effects attributed to noise
by these commenters varied widely as did the sources of noise
which they claimed to cause these effects. Six of the commenters
were from medical doctors, some of whom specialize in audiological
areas of medicine (64, 211, 579, 913, 927, 950). The physicians
noted such factors as chronic tension for those persons confined
to the home, caused by some noise sources, the possibilities of
hearing loss (especially in the high frequencies), and the special
health problems noise can cause for the very young, the elderly,
the nervous and the sick. Several of the physicians—as well
as some non-medical commenters—also pointed out that different
People react differently to noise; what might be a harmful noise
level in some way to one person might have no harmful effect on
another. Two of the doctors (913, 927) cited the difficulty in
establishing a causal relationship between hearing loss and noise,
a point also made by an Iowa State University professor (922)
about physiological damage with respect to household noise. One
Physician (927) stated, however, that experiments to establish
such relationships could be conducted.
**elevant comments not cited elsewhere in thet section are:
119, 262, 278, 281, 410, 471, 485, 502, 514, 529, 537, 556, 586,
589; 612! 645; 674; 675, 678, 680, 901, 903, 906, 916, 923, 938,
940, 944, 949.
223
-------
On the degree of the harmful effects of noise, a Kirkwood
Community College consumer education specialist (929) testified
that an estimated 14 million Americans have suffered some type of
hearing loss and that many of these cases might be attributed to
noise pollution. A representative of a local Iowa education
association (939) stated that 7 percent of their districts' stu-
dents had hearing problems, 40 percent of which are of the serious
high frequency type. He asserted that there is a direct relation-
ship between noise exposure and hearing loss in children. Several
commenters from the educational professions (485, 939, 916, 929)
cited the distracting effect of noise to students' study abilities
and its disruption of classroom activities.
Members of the American Association of Retired Persons (AARP)
(917) and various trade unions (742, 918, 919, 920), testified to
the dangers of factory noise exposure for workers. An AARP repre-
sentative (917) stated that between 20 and 30 percent of those
over 55 seeking employment through AARP have some degree of
hearing loss arising from factory noise exposure.
One individual (52) noted the very special effects of en-
vironmental noise on professional musicians, requiring adjustments
in playing style and in instrument tuning. Commenters (922, 937)t
citing the harmful effects of noise, emphasized its less obvious
impacts of increased stress and tension in daily life.
A number of commenters (211, 471, 502, 514, 529, 645, 6741
675, 916, 938, 944) noted adverse effects attributed to particular
products, including air conditioners, refrigerators, dishwashers*
vacuum cleaners, office equipment and chain saws. Most of
adverse effects noted consisted of annoyance or interference
conversation or thought, but possible physical hearing loss
cited by physicians for operators of chain saws (913), snowmo-
biles, tractors, saws, diesel trucks (for mechanics), air compres-
sors and shredders (950).
Response;
None required.
224
-------
REFERENCES FOR PART II
M] Federal Register, Vol. 42, No. 120 - Wednesday, June 22, 1977,
pp. 31722 throuqh 31728; 31730 through 31738.
[2] Public Health and Welfare Criteria for Noise. EPA 550/9-73-
002, July 27, 1973.
[3] Information on Levels of Environmental Noise Requisite to Pro-
tect Public Health and Welfare with an Adequate Margin of
Safety. EPA 550/9-74-004, March 1974.
[4] "Constitution of the World Health Organization", 1948, 1211
Geneva 27, Switzerland.
[5] Draft Background Document for Product Noise Labeling: General
Provisions.EPA 550/9-77-253, April, 1977. pp. 2-15, 4-24.
[6] Notice of Proposed Rulemaking. Noise Labeling Standards:
General Provisions Federal Register, Vol. 42, No. 120 - Wednes-
day, June 22, 1977, pp. 31722 through 31728.
[7] Notice of Proposed Rulemaking. Hearing Protectors: Noise
Labeling Requirements Federal Register, Vol. 42, No. 120 -
Wednesday, June 22, 1977, pp. 31730-31738.
225
-------
APPENDIX A
DEFINITION OF ISSUES
FROM EACH DOCKET ENTRY
-------
APPENDICES
-------
WRITTEN COMMENTS
Docket Number, Name,
Affiliation
Comments
77-8-001
Larry Woods, Attorney
1. Asked to be notified about time and place of
public hearings.
2. Suggested standards be set on interstate highway
construction noise and planned to suggest products
for labeling at a later date.
-002
Leona and Karl Wilhelinsen
1. Suggested standards be set on motorcycles, and
snowmobiles.
2. Mentioned chain saws and lawn mowers as
noisy products.
•003
Richard Grunow
1. Expressed cynicism about public leaders* com*
mitment to environmental protection.
-004
Horace MacMahan
1. Suggested labeling of hairdryers, lawnmowers,
window fans, washing machines, refrigerators,
and air conditioners and noted misleading
advertising claims about noise.
2. Expressed support for program.
-005
tors. Peter Hullin
1. Expressed support for program.
2. Expressed concern over lawnmower noise.
•006
fcbonda Beasley
1. Expressed support for program.
2. Expressed concern over noise from air
conditioners.
•007
Bl»rt Fisher
1 Expressed opposition to program as an en-
croachment on individual freedom.
231
-------
Docket Number, Name,
Affiliation
Comments
77-8-008
John Statler
1. Expressed opposition to program and concern
over its cost.
•009
Vann Ellis, Attorney
1. Expressed support for program.
2. Expressed concern over pesticide pollution
from Reserve Mining Corporation.
-010
Joe Aspitarte
1. Requested information on standards for road
equipment.
-Oil
Jack Cirrencione
1. Requested information on program.
-012
Archie Frank
1. Expressed support for noise abatement,
expecially freight trains, race cars, unmuffled
, motors, and motorcycles.
-013
Chester and Edna Darnell
1. Expressed concern over motorbike noise and
lack of local noise enforcement protection.
2. Included a letter fromTexas Environmental
Coalition on same problem.
-014
Mrs. W. W. Lynch
1. Expressed concern over noise from motorcycles*
trucks and cars, seemingly unmuffled.
-015
Mrs. Arthur Klavans
1. Expressed approval of program.
2. Expressed concern over noise from musical
equipment, T.V., and trucks.
232
-------
Docket Number, Name,
Affiliation
Comments
77-8-016
Charles Wilson
1. Expressed approval of program,
2. Suggested standards be set on motorcycle noise.
•017
Helen Williams
1. Expressed concern over all forms of environmental
noise, especially motorcycles, trucks, radios and
stereos.
2. Expressed disillusionment with government
inaction over problem.
-018
Phyllis Roberts
1. Suggested that raising public consciousness
of the noise problem should be a first priority.
2. Suggested standards be set for air conditioners.
•019
Charlotte Ackley
1. Suggested we worry more about noise from
factories than about lawnmowers.
•020
Qfeen Kiringer
1. Expressed opposition to program.
•021
Paries Ladd
1. Expressed concern over noise from major highways,
citing ineffective mufflers.
•022
Schrader
1. Suggested labeling and reducing noise from
motorcycles.
•023
John Cutshall
1. stated that except for motorcycles and heavy
trucks, Augusta, Georgia is a quiet town.
2. Expressed disillusionment with local law enforce-
ment inaction concerning motorcycle noise.
233
-------
Docket Number, Name,
Affiliation
Comments
77-8-024
Jon Helberg
1. Expressed concern over motorcycle noise.
-025
Robert Northrop, Civil Engineer,
City of Trenton
1. Requested information on product noise labeling
rules
-026
Kenneth Piercy
1. Expressed interest in noise abatement and concern
over local railroad noise, particularly horns on
diesel engines.
-027
Dennis Kortman
While approving concept of program, expressed
opposition to noise labeling because of:
a. increased cost to consumer,
b. increased government cost to implement
program,
c. educational problem of teaching public to
understand decibel ratings.
Expressed view that there are far more pressing
problems facing our country than informing con-
sumers of product noise level.
-028
Dodie Wheeler Haus
Expressed view that it is not the product, but
the unreasonable user that causes greater noise
pollution and no amount of labeling is going to
prevent the noise problem. Also cited costs to
taxpayers and industry.
-029
James Mogan, Ted Richardson
Expressed opposition to program because of
cost to taxpayers.
-030
Mrs. E. G.Koch
Expressed support for program which would permit
consumer to weigh cost and noise level when
purchasing a product
234
-------
Docket Number, Name
Affiliation
Comments
77-8-031
Freda Bertaghali
1. Expressed concern over noise from "computer*
cash registers made by NCR.
-032
Dan Olsen
1. Expressed approval of program.
2. Expressed concern over noise from motorcycles
and trucks, washing machines and suggested
labeling them.
-033
Ruth Jubach
1. Expressed concern over motorcycle noise.
-034
Edward Golick
1. Suggested standards be set on motorcycle noise.
-035
Joseph Shepherd, Former Safety
Chairman, Union and Management,
GAP Corporation, Linden, N.J.
1. Expressed support of any noise abatement program.
2. Expressed concern over auto horn noise, and
suggested EPA action.
3. Included newspaper articles on the subject
-036
Thomas Evans
1. Expressed approval of program.
-037
Thomas Eridson
1. Expressed approval of the setting of standards
for noise emission levels.
2. Suggested standards be set for motorcycles and
snowmobiles.
3. Expressed disillusionment over state of Minnesota's
delay in setting noise standards for snowmobiles.
235
-------
Docket Number, Name
Affiliation
Comments
77-8-038
Allan Callauder, Material's Engineer
Astrocom Electronics
1. Requested information on the program.
-039
E. R. Milholen
1. Expressed concern over motorcycle noise.
-040
L. Risnain
1. Expressed concern over noise from buses.
-041
Emmett Joseph
1. Expressed approval of program.
2. Expressed concern over noise from motorcycles,
loud cars, and lawnmowers, which have mis-
leading advertisements about noise emission.
•042
Disgusted Citizen
I. Suggested attention be focused on noise from
airplanes, trucks and motorcycles, rather than
appliances.
2. Expressed disillusionment with money spent
on programs that are never carried out
-043
A concerned, and over-
protected consumer
Expressed disapproval of program because of
cost to taxpayers and because he/she feels that
he/she can make decisions for his/herself.
Expressed concern over truck and motorcycle
noise.
-044
Reba Roberts
Suggested labeling of vacuum cleaners,
airconditioners and refrigerators.
Expressed view that major source of noise is from
motorcycles, cars with double mufflers and
lawnmowers.
236
-------
Docket Number, Name,
Affiliation
Comments
77-8-045
C. Schuster
1. Suggested rapid passage of noise abatement
legislation.
2. Expressed view that major noise sources are
motorcycles, lawnmowers and vacuum cleaners.
3. Expressed "whole-hearted" support for EPA.
-046
W. M. Wilson
1. Expressed support for noise labeling and abatement.
-047
Mary O'Neal Broida
(Insert into Docket 77-5)
1. Requested information about effective hearing
protectors.
-048
Frank Ecklin
1. Suggested attention be devoted to abating motor-
cycle and auto noise, rather than appliance noise.
-049
Joe McCartney
1. Expressed view that labels will not be effective.
2. Suggested enforcing noise levels after products
are sold.
3. Expressed concern over motorcycle noise.
•050
Larry Bernstein
1. Expressed approval of program.
2. Expressed concern over noise from hairdryers.
3. Suggested standards be set for motorcycle noise.
237
-------
Docket Number, Name
Affiliation
Comments
77-8-051
Morris Tenenbaum
(Insert into Docket 77-5)
1. Expressed approval of program.
2. Expressed concern over noise from lawnmowers,
radios, stereos, TV's, air conditioners, trucks,
motorcycles, autos, dishwashers, garbage dis-
posals, washers, and dryers, vacuum cleaners
and furnaces.
3. Noted a NILECJ, LEAA publication on ear
protectors on firing ranges.
-052
John Connolly
(Insert into Docket 77-5)
1. Expressed support for noise labeling.
2. Expressed support for labeling of hearing protectors.
3. Noted effects of noise on professional musicians.
-053
Patrick Holychuck
1. Requested information.
-054
John Race
1. Expressed concern over noise from outboard
motors and "Jet Ski."
-055
Robert Casper
1. Expressed concern over lawnmower noise.
-056
Jack Ruefseaun
Expressed interest in reducing all noise especially
that produced by motorcycles, cars and planes.
-057
Leonard Hemog
Expressed opposition to noise labeling because
it is costly and unwanted.
238
-------
Docket Number, Name
Affiliation
Comments
77-8-058
James Bogar
(Insert into Docket 77-5)
1. Expressed opposition to program because it is
"ridiculous."
2. Questioned procedures.
3. Also opposed to labeling hearing protectors.
•059
Mrs. David Butler
1. Suggested we look into the "M-4 Scare Away" -
a machine that is designed to produce thunder-
clap explosions to drive away birds.
-060
France Ledford
1. Suggested penalties on manufacturers of products
that create noise pollution.
2. Expressed disbelief that noise can be controlled
on local level.
-061
Anna Moss
1. Expressed support of noise abatement
2. Expressed particular concern for loud TV com-
mercials and loud background noise on TV shows.
•062
Mrs. R. A. McDonald
1. Expressed concern over auto noise.
-063
Daniel Shoemaker
1. Suggested elimination of general din (e.g.,
lawnmowers).
2. Suggested development of better mufflers
-064
Hunter Healhy.M.D.
Mayo Clinic, Rochester, Minn.
1. Expressed approval of noise labeling program.
Although he believed there is too much govern-
ment regulation of private industry, he favored
noise labeling because his experience as a
physician made him aware of the effects of
noise.
239
-------
Docket Number, Name
Affiliation
Comments
77-8-064 (Continued)
2. Suggested implementing requirements slowly
in order to avoid disruption of industry.
3. Suggested giving industry some incentive to
offer labeling on their own.
4. Suggested a 1-10 rating scale.
-065
Raymond Mahr
1. Expressed support for the program.
2. Suggested we concentrate on noise sources
most objected to by individuals, namely
motorcycles.
-066
Earl Benham
1. Suggested noise labeling of motorcycles,
airplanes, lawnmowers, vacuum sweepers,
and power saws.
-067
E. A. Pahlke
1. Suggested action be taken to lower noise level
of TV commercials.
-068
Shiryl Mastalesh
1. Expressed opposition to labeling because of
costs.
2. Suggested abating airplane and motorcycle noise
and enforcement of other pollution laws.
-069
Mrs. Vemon Wafl
(Insert into Docket 77-5)
1. Expressed interest in program and concern
over all environmental noise.
2. Requested information on effective hearing
protectors.
3. Discussed ineffective hearing protectors.
240
-------
Docket Number, Name
Affiliation
Comments
77-8-070
J. E. Lilly
1. Expressed opposition to noise labeling because
of cost to consumers and because of belief that
public will not understand the ratings.
-071
Unsigned
1. Suggested action on auto and motorcycle noise.
-072
Lawrence Bates
1. Expressed view that noise from appliances is not
disturbing, but some auto mufflers and his type-
writer are.
2. Opposed the program because of increased costs
to the consumer.
•073
Velma Bredberg
1. Expressed approval of noise labeling.
2. Expressed concern over noise from her vacuum
cleaner and kitchen mixer.
-074
George Christensen
1. Suggested strict control of motorcycle noise.
-075
John Betzo
1. Expressed opposition to noise labeling.
•076
Dorothy Stewart
1. Suggested labeling of: washers and dryers, fans,
vacuum cleaners, blenders, air conditioners,
stereos, hand tools.
2. Suggested stronger action on noise from motorcycles,
trucks and buses.
3. Expressed view that labeling will require strict
enforcement by local authorities.
4, Expressed full support for noise program and for
EPA in general.
241
-------
Docket Number, Name,
Affiliation
Comments
77-8-077
Dr. Audrey Oaks
Oklahoma State University
1. Expressed support for any efforts that will
lower environmental noise.
2. Suggested more rigid controls than now in effect.
-078
Anita Rhein
1. Expressed support for noise abatement efforts.
2. Cited motorcyles and truck-mounted trash com-
pactors as noise offenders.
-079
James Dickey
1. Expressed support for noise labeling.
2. Suggested labeling of cars, trucks, and buses.
-080
Mrs. Alice Banner
1. Expressed support for stricter controls on motor-
cycle noise.
-081
Mary Zaehringer
1. Expressed support for noise abatement
2. Suggested lowering of television noise.
-082
Clifford Root
1. Expressed support for labeling program.
2. Suggested labeling of: vacuum cleaners, air
conditioners, typewriters, clocks, fluorescent
light fixtures, power drills and saws, electric
trains, blenders and dishwashers.
3. Suggested housing developers disclose the noise
reducing characteristics of the walls in new
dwellings.
4. Suggested public hearings in Binghampton, N.Y.,
inside a shopping mall so consumers can participate.
5. Wanted to be kept informed on program.
242
-------
Docket Number, Name,
Affiliation
Comments
77-8-083
Mrs. Douglas Nock
1. Expressed support for noise labeling.
2. Suggested labeling of blenders.
-084
E. M. Dunbar
1. Suggested abatement of highway noise.
-085
Unreadable
Unreadable
•086
Harley Reabe
I. Expressed support of noise labeling.
2. Expressed concern about motorcycle, power-
tool, lawn and garden equipment, chain saws,
and snowmobile noise.
3. Suggested strict noise standards on all above
named products with strong penalties for
tampering with noise control.
•087
B. M. Rathbun
1. Requested information on the program.
•088
James V. Neely, President
James Neely Nuclear Power
Consultants, Inc.
1. Expressed opposition to noise labeling program
because it would increase cost of products un-
necessarily. Suggested, that consumers who care
about noise levels can ask for a demonstration
of a product prior to purchase.
-089
George Morgan
1. Asked for help with local airport noise.
243
-------
Docket Number, Name,
Affiliation
Comments
77-8-090
Esther Schneider
1. Expressed concern over noise from trucks,
motorcycles and cars instead of household
appliances.
•091
Marietta Smith
1. Expressed concern over noise from trucks,
teenager's cars and lawnmowers.
-092
Paul Gritchel
1. Expressed view that noise labels are not needed
until other noise and pollution laws are enforced.
-093
Violet Taylor
1. Requested action be taken to abate noise from all
electric appliances, especially air conditioners,
refrigerators and lawnmowers.
-094
John W. Griffiths
1. Expressed opposition to program as a waste of
time and money.
2. Suggested studying motorcycle noise.
-095
Syma Talertic
1. Expressed concern over noise from car radios and
motorcycles.
2. Expressed displeasure at the existence of many
electric appliances.
-096
Philip Reitter
1. Expressed support for noise abatement efforts.
2. Suggested that highway noise be abated by:
a. appropriation of more funds for noise
research efforts;
b. adoption of a policy that all Federally
funded highways be designed with noise
control as a major construction
priority; and
c. reducing the speed limit for trucks.
244
-------
Docket Number, Name,
Affiliation
Comments
77-8-097
Dr. Stephen Konz
Professor of Industrial Engineering
Kansas State University
1. Suggested adoption of dBA as the noise rating
measurement.
2. Included two articles on appliance noise.
•098
Sam Earl Esco, Jr.
1. Expressed support of program.
2. Requested any action to quiet neighbors' lawn-
mowers and air conditioners.
-099
Lloyd Doyle
1. Expressed disillusionment with local law enforce-
ment's lack of action to quiet motorcycles and
cars.
-100
Sherwin Wood
1. Expressed support for "all kinds of noise abatement."
2. Expressed concern over noise from air blowers
on his gas furnace, chain saws, ice cream vendors,
and lawnmowers.
-101
Lester Moore
1. Expressed the view that the Agency was not
authorized by law to establish noise regulations.
-102
Hinsdale
1. Expressed the view that noise from motorcycles,
hot rods and minibikes should receive greater
attention than household noise.
-103
Herbert Layman
1. Expressed approval of noise labeling.
•104
L- C. Veterseher
I. Requested that the Agency influence manufac-
turers to produce quieter motorcycles, RVs,
chain saws, lawnmowers, dishwashers, powerboats.
245
-------
Docket Number, Name,
Affiliation
Comments
77-8-105
Unsigned
1. Commented negatively about the proposed
labeling program.
-106
Eilean Brain
1. Suggested that motorcycles be considered for
labeling.
2. Requested more rigid standards for all types of
pollution in order to protect her rights.
-107
Fernando Curth
1. Suggested that the dividing line between what should
be labeled and what should be regulated is
whether the noise has third-party effects.
2. Suggested standards be set on noise from lawn and
garden equipment
-108
Norman Quinn
1. Requested stronger noise abatement action.
2. Supported noise control projects.
-109
Phil Brown
1. Expressed approval for noise labels.
2. Requested action on railroad horn noise.
-110
Leola Edgerton
1. Suggested labeling of refrigerators with particular
reference to an Amana model.
-Ill
Mildred Guinessy
1. Expressed support of noise labeling and suggested
labels on air conditioners, lawnmowers, and vacuum
cleaners.
246
-------
Docket Number, Name,
Affiliation
Comments
77-8-112
Mrs. dark
1. Expressed concern over noisy mufflers and
office noise.
-113
Joseph Anderson
1. Expressed opposition to noise labeling in the
belief that the market place will take care of
noise standards.
-114
Margarette Gallagher
1. Expressed concern over noise from cars, motor-
cycles, and the kitchen in her retirement hotel.
-115
A.Mauk
Michigan State Police
1. Expressed view that concern over the noise
levels of dishwashers and air conditioners is
nitpicking.
2. Suggested action to quiet motorcycles, snow-
mobiles, outboard motors, chain saws, trucks,
drop forges and airplanes, in that order.
-116
Morris Barnes
1. Asked if motorcycle and R.V. noise has been
considered.
-117
Albeit Mastee
1. Expressed concern over noise from a local factory
and disillusionment that local pollution control
center will take no action.
-118
Paul Did, Editor
Outdoors Magazine
1. Expressed view that noise labels are ludicrous
in light of motorcycle noise.
-119
Ann Hutton
1. Expressed support for the program.
2. Noted deleterious effects of noise on the quality
of life.
247
-------
Docket Number, Name,
Affiliation
Comments
77-8-120
David Benforado, Supervisor
Enviommental Legislation and
Regulations, 3M Company
1. Requested information on program and Office of
Noise Abatement and Control.
-121
Mr. and Mrs. F. Miller
1. Suggested hair dryers b labeled.
-122
C. B. Link
1. Expressed opposition to noise labeling because
of bureaucratic waste and belief that consumers
can now buy quiet produ> ts using their own
intelligence.
-123
Kenneth Young
1. Expressed opposition to all regulations because
he is now capable of making an informed decision
in the marketplace and because noise level of
products makes no difference.
-124
Susan Britt
1. Suggested noise labeling of lawnmowers and
blowers.
2. Asked what can be done on the local level about
noise.
-125
William Hering
-126
Mrs. Norman Solomon
1. Expressed disillusionment over local government
unwillingness to do anything about motorcycle
and chain saw noise.
1. Expressed support for noise labeling.
2. Expressed view that manufacturers should contr°
noise or put warnings on products.
3. Requested correspondence about noise issues
with the Agency.
248
-------
Docket Number, Name,
Affiliation
Comments
77-8-127
John Critchley
1. Expressed support for noise labeling.
2. Requested action be taken to quiet: motorcycles,
snowmobiles, outboard motors and hot rod cars.
-128
Harry Freeman
1. Expressed view that consumer can now decide
noise levels of products and that environmental
protection should be limited to control of en-
vironmental conditions over which individuals
have no control.
•129
Dorothy (Illegible)
1. Expressed opposition to noise labeling.
-130
Theresa Wright
1. Expressed support for noise labeling.
-131
Mary Neuman
1. Suggested that motorcycle noise be abated.
-132
M. L. Brubaker
1. Requested information.
-133
Arthur Simpson
1. Expressed concern over motorcycle noise.
-134
Harry Rocco
1. Expressed belief that nothing can be done about
the noise problem because it is a local problem
and local government is corrupt.
-135
F- Schoelich
1. Inquired if the proposed requirements will apply
to instruments used by rock bands.
249
-------
Docket Number, Name,
Affiliation
Comments
77-8-136
Mrs. J. O'Brien
1. Expressed approval of noise labeling.
2. Suggested greater control of noise from hi-fi sets.
-137
Kathleen Canzaro
1. Expressed approval of noise labeling.
2. Expressed concern over neighborhood noise, such
as lawnmowers and motorcycles.
-138
MarcPrass
1. Suggested that air conditioners be labeled.
-139
John Gardner, M.D.
1. Suggested labeling on refrigerators, air conditioners*
central air conditioning units, and forced air
heating units.
2. Suggested that ratings be in decibels.
3. Suggested that label state whether product meets
EPA's noise standards.
-140
Mrs. George (Illegible)
1. Expressed support for noise control and labeling.
-141
Burt Collins
Lt. Col. USAF (Ret.)
Requested information on a wide variety of
noise matters.
-142
Ray Chapman
Expressed opposition to noise labeling program
because of cost to consumers, and his disbelief
that it would be of aid to consumers.
250
-------
Docket Number, Name
Affiliation
Comments
77-8-143
J. M. Freiburger
1. Expressed support for noise labeling.
2. Expressed concern over noise from room
air conditioners.
3. Suggested labeling of the normal noise range
of operation and of the maximum decibel
level.
-144
AnneBalas
1. Expressed concern about noise from airplanes,
air conditioners (Chrysler Airtemp and Emerson
Quiet Kool), lawnmowers, motorcycles and
background music.
2, Requested Agency take some action to abate
noise.
-145
Robert D. Barnes
1. Suggested that labels cany a warning "Caution:
Hearing protectors should be worn when using
this product," if the dB(A) level exceeds 90.
2. Commented that the noise labeling program is a
good idea.
-146
L. Hastueau
1. Requested that existing noise laws be enforced.
•147
Allen H. Shiwer, P.E.
Shiwer Associates
Acoustical Engineers
1. Commended the Agency for proposing noise
labeling program.
2. Suggested that the labels say whether higher
numbers are quiet or loud.
3. Suggested that the labeling program be imple-
mented with caution.
4. Suggested labeling of wallboard.
5. Noted the interdependence of acoustical systems,
e.g., ceiling tile or mufflers.
251
-------
Docket Number, Name,
Affiliation
Comments
77-8-148
Lee Nolte
1. Requested information.
2. Expressed concern over noise from her neighbors'
air conditioners.
-149
Rodger Ringham,
International Harvester
-150
-151
G. Bailie
Deputy Director of Environmental
Health, Cotswood Dist. Council
Glouster, England
1. Requested information.
Transferred to Hearing Protector
Docket: 77-5-37
1. Requested information as to whether outboard
motors are labeled.
-152
Mrs. Hugh McKenna
Illegible.
-153
H. W. White, President
Overlay Mfg. Co.
1. Suggested the Agency label acoustical doors
for sound transmission loss and include the
words "Noise Reduction Rating" on the label.
2. Expressed support for the program.
-154
Unsigned
1. Opposed program as an insult to intelligence.
•155
Hazel Spitzi
1. Requested Agency abate lawnmower noise.
2. Expressed support-for noise labeling.
252
-------
Docket Number, Name,
Affiliation
Comments
77-8-156
Louise Green
1. Expressed support for noise abatement including
the Concorde.
2. Expressed concern over noise from motor bikes,
lawnmowers, chain saws, and mufflerless cars.
•157
Dorothy Brohe
1. Requested noise standards be set on appliances,
particularly vacuum cleaners and room air
conditioners.
•158
Henry Hayes
1. Expressed support of noise control efforts.
•159
Mary Deysher
1. Expressed complete support of noise labeling,
in the belief that it would induce greater compe-
tition in developing quieter products.
2. Suggested warning labels be placed on products
whose repeated use could damage a person's hearing
such as power tools, lawn equipment, chain saws,
outboard motors, motorcycles, and guns.
3. Requested information about public hearings.
•160
Smith
1. Expressed concern over noise from television
commercials.
-161
Omission due to misnumbering.
T -162
Joanne Gerety
1. Expressed concern about fire sirens (stationary
emergency signalling devices) in residential areas.
2. Wanted information on this problem.
253
-------
Docket Number, Name
Affiliation
Comments
77-8-163
Mis. Albert Haber
1. Expressed support for noise abatement efforts.
•164
Mrs. Anne Plucks
1. Expressed concern over noise from children's
tricycles that have plastic wheels (apparently
"big wheels" type).
-165
Mrs. D. Fisher
1. Expressed support for noise abatement
2. Expressed concern over noise from motorcycles.
-166
E. J. Kozminski
Noise Analyst
Rapistan, Inc.
1. Suggested use of one parameter for noise emitting
equipment and one for noise reducing equipment*
rather than choosing parameters on product-by-
product basis.
2. Sound power level, or sound pressure level at a
specified position, or loudness in sones at a
specified position could serve as a measure for
noise emitters, while transmission loss or noise
reduction coefficient could be used as a measure
of noise reduction effectiveness.
3. Criticized label's lack of reference to rating
parameter used.
4. Suggested that label include average value of all
products in the class being labeled, in addition
to the range. Otherwise, range information is
misleading.
5. Suggested that inspection without 24-hour notice
should only be authorized by the Assistant Admin**
strator for enforcement "if there is evidence
that improper manufacturing and testing pro-
cedures are being employed by a company."
254
-------
Docket Number, Name,
Affiliation
Comments
77-8-167
R- J. Roney
1. Expressed opposition to noise control efforts
as a waste of tax money.
-168
Mrs. W. Marshall
1. Expressed concern over motorcycle noise.
-169
Mrs. Roger Balgard
1. Expressed disapproval of noise labeling because
there already is .too much government inter-
ference in her life.
-170
Lucille Williamts
1. Requested that lawnmower and blender noise be
abated.
-171
Mrs. Herman LaDay
1. Requested regulation of noisy appliances and
lawnmowers.
-172
Michael Percy
Senior Urban Planner
Qty of Mountain View, CA
(Insert also into Docket 77-5)
1. Suggested that dBA rating be used on labels,
because the-consumer wQl be confused by a
separate number system which would require
referral to additional charts and information
for interpretation.
-173
Gina Powell
1. Requested control of noisy appliances.
•174
Koszeurski
1. Expressed disapproval of noise labeling because
of its'burden on industry and because the govern-
ment is reaching into every aspect of daily life.
•175
Kathrine Rudolph
1. Expressed concern about noise from a local
mining industry and the local zoning board's un-
willingness to help her with it. Requested that
the Agency lend her a noise meter so she can mea-
sure the sound level she is exposed to and show the
zoning board.
255
-------
Docket Number, Name,
Affiliation
Comments
77-8-176
Willard Stingier
1. Suggested that noise labeling priority be given to
constant noise sources in the home (i.e., central
air blowers, refrigerators) instead of intermittent
sources (i.e., vacuum cleaners).
-177
Ellen Taylor
1. Expressed disapproval of noise labeling because
the government is taking responsibility for aspects
of life that individuals should take responsibility for
-178
June Lautt
1. Supported noise labeling of household appliances.
-179
J. A. Rombough
1. Expressed opposition to noise labeling because
it is unnecessary government control.
-180
Warren Cast, President
Cast Mfg. Co.
1. Letter on compressors. Referred to proper
docket.
-181
Virginia Stilo
1. Urged approval of noise labeling regulations.
-182
Mrs. M. B. Commons
Expressed support for anything that would reduce
noise, particularly that produced by motorcycles.
cars, model airplanes and vacuum cleaners.
-183
Unreadable
Requested that the Agency do whatever it can
to control noise in the home.
-184
Mrs. J. Cripe
1. Expressed support of noise labeling.
256
-------
Docket Number, Name,
Affiliation
Comments
77-8-185
B. E. Patterson
1. Expressed support of noise labeling.
-186
Stella Olekra
1. Expressed concern over noise from lawnmowers,
refrigerators, noisy cars, air conditioners and
wind-up clocks.
-187
Unsigned
1. Requested the Agency abate noise from motor-
cycles and trucks rather than lawnmowers and
appliances.
2. Expressed opposition to appliance labeling
-188
Jeanne Allen
1. Expressed support for noise labeling and noise
pollution control in general.
-189
Mildred Knobloch
1. Expressed support of noise labeling program.
2. Expressed particular concern over lawnmower
noise (Lawnboy).
3. Mentioned a noisy floor fan, (incor-
rectly advertised as quiet) and stove fan.
4. Also concerned with TV commercial loudness.
-190
Mrs. Frank Nultner
1. Expressed concern over noise from refrigerators
and U. S. motorcycles.
-191
Draza Kline
1. Expressed support of noise labeling.
2. Expressed concern over noise from motorcycles
and foreign cars.
257
-------
Docket Number, Name,
Affiliation
Comments
77-8-192
Nel Jones
1. Expressed support for noise labeling.
-193
Edgar Lion
Planning Director
Lafayette, CA
1. Expressed support for noise labeling program.
2. Suggested the labels indicate whether a high
number indicates a greater or lower noise level
to facilitate public understanding.
-194
Mrs. Walter Kruger
Suggested that motorcycle noise receive attention
before household noise abatement.
-195
Evelyn Kaye
1. Requested abatement of loud television commercials
-196
R. S. Morgan
1. Informed us that motorbike noise is the only
noise that he finds irritating.
-197
A. Gerald Reiss
Director of Corporate Administration
Fasco Industries
1. Based on reading of Section 8, proposed that only
products that exceed a certain threshold noise
level be required to contain a label which has no
rating but that warns the user of potential adverse
effects.
2. Criticized proliferation of labels.
3. Opposed use of EPA logo on label.
4. Suggested that simulation of "use environment" be
a primary objective in setting standards. For exampl
noise from air conditioners is not extremely
annoying if everyone has windows closed.
5. Suggested that the regulation state what testing
costs, direct and indirect, will be reimbursed by the
Agency.
6. Requested a longer notice period for admittance
to manufacturer's premises.
258
-------
Docket Number, Name,
Affiliation
Comments
77-8-198
John D. Kramer
Secretary of the Illinois
Department of Transportation
1. Suggested that the label contain a visual scale
showing the range in noise ratings and indicating
the "quiet" and "noisy" poles of the spectrum.
-199
Virginia Smith
1. Expressed concern with a number of household
appliance noise levels, citing lawnmowers,
refrigerator, air conditioner, dishwasher, sweeper,
electric can opener, blender, hair dryer, TV and
outside motors.
-200
Sarah Leach
1. Expressed support of noise labeling.
2. Requested action on TV commercial noise.
3. Requested information
-201
David Rankin
1. Suggested that the labels contain accurate and
understandable information.
-202
Unsigned
1. Expressed concern over airplane and RR noise,
and lack of concern about bus and truck noise.
-203
Margaret Lockner
1. Requested information.
-204
George Hunt
(Replaced by 77-8-329)
1. Requested that the Agency take a stronger
stand against industry and act as the people's
advocate, publicizing the issue.
-205
Richard Bolin
1. Requested the Agency regulate the Carbide
Cannon, a noise gun that scares away birds.
2. Suggested use of color scheme in labeling and
a 1-10 scale.
259
-------
Docket Number, Name,
Affiliation
Comments
77-8-206
Hany Barter
Department of Fine Arts
Maiyville College
1. Expressed approval of noise labeling but
requested that the Agency abate noise from
outside the home as well.
-207
Mr. and Mrs. Paul Rorda
1. Expressed support of noise labeling.
2. Informed us that their city council will not
consider the model noise ordinance because
of industry pressure and wants a mandatory
nationwide noise law.
-208
Helen Pratt
1. Expressed concern over noise from blenders and
vacuum cleaners.
•209
Florence Kumichi
1. Requested that the Agency abate lawnmower noise-
-210
John Brubaker
1. Suggested that motorcycles be considered for
the first product labeled.
2. Proposed that any rules include penalties for
modification of noise control devices.
-211
Irving Rank, M.D.
Rosanne Frank, RN
1. Expressed approval of noise labeling, particularly
refrigerators, vacuum cleaners, water softening
devices and exhaust fans, because they create
chronic tension in the individual who is confined
to home.
2. Requested that the noise level of music in restaurant"
and other public places, where the general public tf
a captive audience, be restricted.
3. Suggested educational efforts to minimize the risk
involved in exposure to "raucous rock music."
260
-------
Docket Number, Name,
Affiliation
Comments
77-8-212
Phillistt Rosenthal
1. Requested abatement of noise from lawnmowers
and grass blowers.
-213
Glover Weiss
1. Requested control of noisy auto mufflers.
-214
Robert Bogan
Suggested that this inflationary project be
dropped unless the EPA is able to demonstrate
some clear economic benefit in excess of the
potential costs.
-215
. McAndrews
Expressed support for noise abatement, particularly
of electric lawnmowers and motorcycles.
-216
Mrs. Eugene Emerson
Suggested any action which could abate household
noise.
•217
Mrs. William Person
1. Expressed opposition to noise regulation because
of burden on manufacturers and because she
believes that consumers should exercise discrimi-
nation in purchasing.
-218
Mrs. Arthur Smith
1. Expressed support for noise labeling.
2. Expressed concern about truck noise.
-219
Sylvia White
1. Suggested labeling of appliances.
2. Requested information.
-220
Michael Saija
1. Expressed concern over a local swimming pool noise
enforcement problem.
261
-------
Docket Number, Name,
Affiliation
Comments
77-8-221
S. Pelletier
1. Expressed support for noise abatement espe-
cially on appliances.
-222
Joanne Flock
1. Requested any action to abate appliance noise.
-223
R. Lansky
1. Expressed support for noise labeling.
-224
Dawn Weiss
1. Requested information.
-225
Les Bradley
1. Expressed support for noise labeling, especially of:
dishwashers, washing machines, dryers, blenders,
hair dryers, vacuum cleaners, radio and TV re-
ceivers, electric power drills, lawnmowers, and
typewriters.
2. Requested some other noise abatement effort to
control garbage trucks, tree limb and leaf shredders,
jack hammers and air conditioners.
-226
Rachel Riley
1. Expressed concern over noise from a nearby
factory.
-227
Harold Taylor
1. Suggested that all products above 45 dBA list
their noise level.
•228
Bob Londergan
1. Expressed support for noise labeling.
262
-------
Docket Number, Name,
Affiliation
Comments
77-8-229
David Sullivan
1. Expressed support for noise labeling, particularly
of blenders and lawnmowers.
•230
W.Cox
1. Expressed support for noise labeling, especially
of lawnmowers.
-231
John Moore
1. Expressed concern over motorcycle noise.
-232
Mrs. D. E. Coward
1. Expressed concern over noise from her garbage
disposal, dishwasher and kitchen fan.
-233
Mr. and Mrs. Theodore Adams
1, Requested noise from autos and motorcycles be
abated.
-234
Prof. Richard Moore
Kansas State University
Department of Family Economics
1. Stated that noise standards are past due and that
noise is one environmental area that has been
neglected.
-235
Wilhelmia Smith
1. Expressed support for noise labeling, especially
of "continuous noise" products such as fans, air
conditioners and refrigerators.
-236
. Camen
1. Requested that more be done to eliminate noise
from vacuum cleaners, electric brooms, air con-
ditioners, hair dryers, lawnmowers, refrigerator
motors and blenders.
-237
P. Geauque
1, Expressed concern over household noise, including
lawnmowers.
263
-------
Docket Number, Name,
Affiliation
Comments
77-8-238
Tom Meshan
1. Stated that noise labeling is a positive action
because consumers need to make an informed
decision.
2. Suggested standards be set on household products
in addition to labeling.
3. Suggested labels that state a health warning.
4. Mentioned products which subject consumer to
"harmful levels" of noise: Vacuum cleaners,
air conditioners, shop tools, blenders, hair
dryers, washing machines, lawnmowers, and other
household appliances.
-239
Kathleen Johnson
1. Expressed support for noise labeling, particularly
of vacuums, air conditioners, and lawnmowers.
-240
Thelma Coren
1. Expressed support for noise control.
-241
John D. Hopkins
1. Expressed support for noise labeling.
2. Expressed disapproval of Federal action to limit
motorcycle noise because he believes that motor
vehicle muffler laws can be improved on the state
level.
-242
Mrs. D. Klompus
Expressed concern over noise from pipes and
heaters in her apartment.
-243
Laurance Conti
Expressed concern over bus noise and wanted
information on controlling it.
-244
Mr. and Mrs. Mike Main
1. Expressed support for noise labeling.
264
-------
Docket Number, Name,
Affiliation
Comments
77-8-245
Joseph Famulary
1. Expressed concern over noise from motorcycles
and hot rods.
-246
Lois Segal
1. Expressed support for noise labeling with particular
reference to vacuum cleaners.
-247
Michael Ramage
1. Suggested that any item powered by an electric
motor have a noise label indicating the operating
decibel level.
2. Suggested that radio and TV have volume limits.
3. Expressed support for the program.
-248
Mrs G. Miller
1. Expressed support for labeling of air conditioners,
vacuum cleaners, refrigerators and lawnmowers.
2. Suggested that Agency control noise level of
television.
-249
H. Shillon
1. Expressed support for noise labeling.
•250
Unreadable
Expressed concern over noise of huge garbage
vehicles, grocery delivery trucks, lawnmowers,
vacuum cleaners, airplanes, and power tools.
-251
Claire Pichette
Informed us of a local "rock band" noise problem
growing out of zoning.
265
-------
Docket Number, Name,
Affiliation
Comments
77-8-252
Gabor Usbau
Mechanical Engineer
1. Expressed disapproval of noise labeling because:
a. It is an attempt at people control.
b. It would add another level of bureaucracy.
c. It would increase prices, red tape and aggravatic
d. Take away business freedom.
e. It would waste tax dollars.
-253
Helen Von Ehrenkrook
Expressed disapproval for noise labeling because
consumer protection costs consumers money.
-254
Ms. Kuniko Sato
Environment Agency
Tokyo, Japan
1. Requested information.
-255
Mrs. Paula Schreiner
1. Expressed support for noise labeling, including
health hazard warnings.
-256
Unreadable
1. Expressed concern over noise from a host of
sources, including vacuum cleaners, dishwashers,
motorcycles and TV commercials.
-257
Chuck Howell
1. Expressed support for noise labeling.
2. Suggested products for labeling, including all
"electrical equipment."
3. Requested information.
-258
Mr. and Mrs. Harry Oldinburg
1. Requested information.
-259
Priscilla and Eugene dialled
1. Expressed concern over motorcycle noise.
766
-------
Docket Number, Name,
Affiliation
Comments
77-8-260
Mrs. John Simoni
1. Expressed support for the labeling program.
-261
Zane Saunders, M.A.
Director, Speech Pathology and
Audiology
Newington Children's Hospital
1. Requested copies of proposed rules and any
other relevant information.
-262 1.
Francois Louis
Manager, Safety and Environmental 2.
Regulations, Renault, USA
Commented on automobile noise standards.
Stated that interior passenger car noise is a comfort
consideration rather than a health matter, and
the level of comfort is hard to measure in an
objective fashion.
-263
Dorothy Shannon, Ph.D.
Chief, Speech and Hearing
Sinai Hospital of Baltimore
1. Expressed support for the program.
2. Requested further information beyond the
summary of the notice of proposed rule making.
-264
F. W. Hetman
President
DeVal, Inc.
1. DeVal, a manufacturer of high performance
aluminum windows and doors, expressed the
opinion that all window systems should have
sound transmission ratings.
2. Enclosed other letters and articles in support
of this view.
-265
Jane A. Baran, Director
Audiology/Aural Rehabilitation
Indianapolis Speech and Hearing Center
(Insert also into Docket 77-5)
Expressed support for the labeling program,
as outlined in both the general labeling provisions
and labeling standards for hearing protectors.
-266
The Rev. Henry M. Biggin
1. Requested the information on local community
noise standards as described on the today show.
267
-------
Docket Number, Name,
Affiliation
Comments
77-8-267
Mrs. Lester Wiggins, Chairman
Oklahoma Health Committee
1. Requested copies of proposed rules.
-268
Roy W. Muth
Director, Technical Services
International Snowmobile Industry
Association
1. Requested the opportunity to testify at the
Washington, D.C. hearing.
-269
Beth A Brown
Clearinghouse Manager
Aspen Systems Corporation
1. Requested information on the Washington,
D. C. hearing and related publications.
•270
Mr. and Mrs. Larry Pinkston
1. Expressed full support for the program.
-271
Maria Henesah
1. Expressed support for the program.
2. Suggested labeling of electric fans, air conditioners*
and refrigerators.
-272
Raymond F. Anderson
1. Expressed the opinion that noise labeling is a
"lost cause."
2. Suggested a local noise abatement publicity
effort through bumper stickers and mailing labels.
-212(Misnumbered)
Michael E. Paul, Sr.
1. Cited the worthiness of investigating noise
labeling.
2. Suggested warning labels as appear on cigarette
packages.
268
-------
Docket Number, Name,
Affiliation
Comments
77-8<2)73 (Misnumbered)
All Ragle
1. Expressed full support for the program, especially
with respect to shop tools and garden equipment
-(2)74 (Misnumbered)
David and Eileen Garland
1. Expressed concern over lawnmower noise.
-275
Eloise Grossman
1. Expressed interest in home noise abatement and
support for labeling program.
2. Suggested noise labels affixed to packages or
preferably directly on appliances.
-276
Judith Schlager
1. Expressed support for noise labeling, especially of
dishwashers and lawnmowers.
-277
Mahlon E. Sipe
1. Suggested that noise control efforts be directed
at motorcycles rather than household appliances.
•278
M. Grossman
U. S. Factory Representative
Peugeot
1. Commented on automobile noise standards.
2. Stated that interior passenger car noise is a comfort
consideration rather than a health matter, and the
level of comfort is hard to measure in an objective
fashion.
-279
Mrs. Roy Higdon
1. Expressed support for noise abatement for
all household equipment, lawn care equipment,
air conditioners and transportation vehicles.
-280
Martha Mathews
1. Expressed support for noise abatement for
all household equipment, lawn care equipment,
air conditioners and transportation vehicles.
969
-------
Docket Number, Name,
Affiliation
Comments
77-8-281 1.
Joe Swift
Executive Director, Environmental Affairs
Mercury Marine 2.
3.
4.
5.
6.
Commented on EPA's noise labeling standards
as applied to marine engines in pleasure boats.
Suggested use of dB(A) for measurement and
stated this is a measure of sound level and
not sound pressure level as EPA document stated.
Noted that SAE J34a and SAE JXXX must be
used for measuring pleasure motorboat
sound levels, with Leq being the most logical
descriptor.
Cited need for a testing facility for comparative
measurement (reverberant rather than anechoic),
or alternatively, the SAE "standard boat approach."
Wondered if a single rating number would be based
on "passby" or "interior" noise, and doubted that
pleasure boats constitute a noise health hazard,
yielding passby noises in the 70-80 dB(A) range.
Expressed the opinion that the motor can be
rated only in combination with the boat, posing
measurement problems.
-282
Donna McCord Dickman, Ph.D.
Metropolitan Washington COG
Mentioned her intention to testify at the
Washington, D. C. hearing.
-283
Lt. Jim Anderson
Traffic Division
Rapid City Police Department
Requested a copy of the Ringelmann Chart in
connection with development of local exhaust
noise level ordinance.
-284
Richard M. Snyder
Expressed opposition to the program, preferring
to rely on the free enterprise system.
270
-------
Docket Number, Name,
Affiliation
Comments
77-8-285
George M. Gorman
1. Expressed general support for abatement of
environmental noise.
•286
Emma Niemann
1. Requested that priority be given to control
of motorcycle noise.
-287
John P. Reardon
Director of Government Affairs
Air Conditioning and Refrigeration
Institute
1. Requested opportunity to testify at the
Washington, D. C. hearing.
•288
M. L Downs
1. Stated that noise levels of motorcycles should
be reduced.
•289
G. C. Simpson
1. Expressed concern over noise from bulldozers,
trucks, motorcycles and buses.
-290
Sue Vogelsanger
1. Requested available reports on the subject of
noise pollution.
•291
Jules A. Kaiser
1. Cited an attachment from the Philadelphia
Inquirer.
-292
. K. Foster
1. Expressed support for noise abatement for
all household equipment, lawn care equipment,
air conditioners and transportation vehicles.
•293
Leila Aiken
1. Expressed support for noise abatement for
all household equipment, lawn care equipment,
air conditioners and transportation vehicles.
271
-------
Docket Number, Name,
Affiliation
Comments
77-8-294
Winston L. (Illegible)
1. Suggested noise labeling of motorcycles, chain
saws and trucks.
2. Suggested federal maximum noise levels.
-295
Esther Mary Lippard
1. Expressed concern over loud background music on
TV.
-296
Toshio Kitamura
Deputy Director of General Affairs Div.
Machinery and Information Industries
Bureau
Ministry of International Trade and
Industry
Japanese Government
1. Requested further information.
-297
T. J. McCann
1. Suggested that radios, PA systems, televisions,
and music amplifiers be included in the program.
-298
Vincent Argondezzi
1. Complained of two noisy bulk flour pumps located
near his residence and requested a source of relief.
-299
G. M. Hoch
1. Expressed opposition to the program because
of possible inflationary effects.
-300
Mrs. Arthur Klavans
1. Expressed support for the program, citing
noisy air conditioners in particular.
-301
James P. O'Donnell
1. Expressed opposition to the program because of
increased costs to consumers.
272
-------
Docket Number, Name,
Affiliation
Comments
77-8-302
Jerry Boyle
President, Honda of Piqua (Ohio)
While generally approving of EPA activities,
requested that more time be given before the
setting of noise standards.
-303
James E. Wingert
I. Expressed concern over motorcycle noise.
-304
John R. Race
1. Because of industry and user lack of concern,
suggested that snowmobile, chain saw, outboard
boat and trail bike noise be abated rather than
labeled.
-305
John J. Hughes
State Lobster Hatcher and Research
Station (Massachusetts)
1. Expressed approval of action under Section 8 of
the Noise Control Act and suggested motorcycles
be given priority.
2. Suggested a flyer describing dB(A)'s and their
measurement for public education.
-306
Gerald E. Starkey, P.E.
Noise Abatement Specialist
County of Santa Clara
1. Announced intent to attend San Francisco
hearing.
2. Requested further information as it becomes
available.
-307
P. E. Powers, Jr.
1. Suggested the labeling of all motor vehicles with
standards for sports cars and motorcycles.
2. Noted that skateboards and escalators need
not be labeled.
-308
Leona and Karl Wilhelmsen
1. Suggested labeling of household equipment, lawn-
mowers and shop tools and abating the noise
of motorcycles and snowmobiles.
273
-------
Docket Number, Name,
Affiliation
Comments
77-8-309
Emmett Joseph
1. Expressed support for the program.
2. Suggested noise regulations be set for motorcycles,
lawnmowers and power saws.
-310
L. K. Lepley
1. Requested information on the program and the
opportunity to participate.
-311
Ronald Junck, President
Prince Manufacturing Corporation
1. Questioned if the public were aware of the
increased consumer cost that the program would
cause.
-312
John G. New, Chairman
Biology Department
SUNY, Oneota
Expressed support of program for simple
comparative noise labeling of power shop tools,
powered garden equipment, vacuum cleaners,
mixers, dishwashers, air conditioners, and electric
shavers.
Wished to see motorcycles, snowmobiles and
off-trail vehicles covered also.
-313
Burt B. Fisher
1. Expressed opposition to the program because of
.excessive government interference in citizens' lives.
-314
L. F. Hendricks
1. Suggested that computer equipment be included
in EPA noise abatement efforts.
-315
Stuart M. Low
Flent's Products Company
Correspondent, a hearing protector manufacturer,
requested the opportunity to testify on the general
provisions at the Washington, D. C. hearing.
-316
Lang D. Woods
Woods and Woods Law Offices
Requested information on the submission of
written comments on behalf of clients.
274
-------
Docket Number, Name,
Affiliation
Comments
77-8-317
Leo Pazavis
1. Requested abatement of general street noise.
-318
A. C. Roller
1. Suggested abatement of motorcycle noise.
-319
Hope Nissenbaum
1. Expressed concern with appliance noise, such as a
blow hairdryer and a blender.
-320
Mrs. Geraldine Graf
1. Expressed support for the program.
2. Included two newspaper articles, one by the
correspondent on the subject of environmental
noise.
•321
Irma M. Bennet
1. Expressed support for the program.
-322
Marjoria Ackerman, RN
and audiometrist
Expressed support for noise control and
labeling of vacuum and rug cleaners, hair dryers,
and electric mixers, and all tools and machinery.
Suggested that the labels carry a health warning
as well as the decibel leveL
Suggested that the label note that repairs would
increase the stated decibel level of the product.
Suggested that stereos be labeled with a green-
yellow-red color scheme.
275
-------
Docket Number, Name,
Affiliation
Comments
77-8-323'
E. S. Mott
Mott Corporation
1. Expressed opposition to the program as a
"consumer rip-off."
2. Suggested that bureaucrats be required to have
5 years of practical experience in private industry.
-324
R. Lowens
1. Expressed support for the labeling program and
suggested the inclusion of attic fans, heat pumps,
refrigerators, washers, dryers, vacuum tools, and
powered lawn and garden equipment.
2. Suggested the EPA establish a recommended
maximum noise level to be indicated on the
label.
3. Suggested EPA enter the field of airplane
noise levels because of FAA and CAB's inaction.
-325
Ruth Jabach
1. Expressed support for the program.
2. Expressed concern over motorcycle noise.
-326
S. J. Alson
1. Suggested that motorboats and outboard
motors be considered.
-327
Gloria J. O'Reilly
Expressed concern with noise from: children's
street toys, amplified "music," lawn care machines*
home care machines, blenders, vacuums, mixers,
can openers, refrigerators, floor polishers,
electric shavers, hair blowers, air conditioners,
fans, and motorcycles.
-328
Robert Z. Breakwell
Expressed opposition to the program because of
increased costs to the consumer.
276
-------
Docket Number, Name,
Affiliation
Comments
77-8-329
George H. Hunt
1. Requested his earlier submission, 77-8-204, be
replaced with this correspondence.
2. Requested information on opportunities in the
field of noise pollution.
3. While favoring the labeling program, suggested
use of direct language instead of codes or numbers.
4. Suggested a seal of approval for low-noise products.
5. Cited a number of major noise polluters.
-330
Betty Jacques
1. Requested abatement of motorcycle, air conditioner
refrigerator, and general appliance noise.
-331
Mrs. Mary E. Neumann
1. Expressed support for the program and conceni
over motorcycle noise.
•332
Norman 0. White
1. Requested labeling and abatement of motorcycle
noise.
-333
Richard J. Peppin
Virginia Regional Coordinator
Coordination Committee for Environ-
mental Acoustics
Acoustical Society of America
1. Suggested use of existing rating "labels," e.g.,
STC, NRC, SRN, because of industry acceptance.
2. Suggested that labels incorporate the distance
factor, especially for "outdoor" products.
3. Suggested that products with sound-controlling
devices (e.g., TV's and radios) not be labeled.
4. Suggested use of the sound power level and the
A-weighted sound pressure level for rating purposes.
5. Requested to be kept informed of developments
in the program.
277
-------
Docket Number, Name,
Affiliation
Comments
77-8-334
Marcia Macdonald
1. Expressed wholehearted support for the program.
2. Requested stricter enforcement of motorcycle
noise control.
-335
Robert S. Jackson M.D.
Assistant Commissioner
Department of Health
Commonwealth of Virginia
1. Expressed support for the program.
-336
(Mrs.) Frances Oatley
1. Expressed concern over several sources of neigh-
borhood noise including air conditioners, lawn-
mowers, sirens, tree-cutters, hi-fi's and
garbage trucks.
-337
William J. Stephens
General Counsel
American Rental Association
1. Requested the opportunity to testify at the
Washington, D. C. hearing.
-338
{Catherine M. Reilly, M.D.
Audiologist, Marin General Hospital
1. Requested current information on standards and
requirements related to Dockets 77-5 and 8.
-339
Mrs. M. L. Branchaud
1. Requested complete information on No. 77-8.
-340
Anthony Kelly
1. Expressed concern over shooting range
activities and suggested such noise be abated.
278
-------
Docket Number, Name,
Affiliation
Comments
77-8-341
Mr. and Mrs. William Woodhouse
1. Expressed support for noise control.
2. Expressed concern over noise from a neighbor-
hood tavern, motorcycles and snowmobiles.
-342
A. H. Krieg, President
Widder Corporation
1. Commented that levels of 5 0-55 DB's for
industrial products are unrealistic.
2. Noted that noise reduction would have an adverse
impact on efficiency and thus on energy con-
sumption.
•343
Mrs. E. K. Swartz
1. Suggested that traffic noise be given priority over
appliances.
-344
Mr. John G. Kovash
1. Expressed support for the program but preferred
maximum levels.
2. Noted the problem posed by involuntary third
party listeners for the labeling project
-345
Henry Kaye
1. Expressed concern over loud TV and radio
commercials.
-346
Florence Shatter
1. Expressed concern over noisy mufflers, foreign
cars and motorcycles.
•347
J. Peppin
County Acoustical Engineer
Montgomery County, Maryland
1. Expressed strong support for the program and
suggested the labeling of air conditioners, power
tools, lawnmowers, power boats, ceiling tiles, big
wheel bikes, and minibike/off-road vehicles.
279
-------
Docket Number, Name,
Affiliation
Comments
77-8-347 (Continued)
Noted use of the NRC for ceiling tile
but cited its lack of indication of transmission
loss capability.
Requested the results and summaries of the hearings
when available.
-348
Roy Ruuska
1. Expressed serious concern with local motorcycle
noise and requested a response.
-349
Mayda L. Lyons
1. Expressed doubts about the possibility of
controlling a variety of environmental noise
sources.
-350
Singapore Institute of Standards and
Industrial Research
(Also 77-5-021)
1. Requested a copy of the proposed regulations
and to be kept informed of further developments.
-351
David Fishken, Ph.D.
Department of Psychology
Northeastern University
1. Requested all available information on Nos.
77-5 and 8.
-352
Joseph P. Fieri
1. Expressed concern over air conditioner and
motorcycle noise.
-353
Mary Davey Schambach
Technical Coordinator
John L. Price and Associates
Environmental Analysis and Consultation
1. Expressed support for the program.
280
-------
Docket Number, Name,
Affiliation
Comments
77-8-354
Marilyn B. Noyes
Family Resource Management
Cooperative Extension Service
Utah State University
1. Expressed support for noise labeling if costs
could be kept low, but expressed opposition to
mandatory restrictions on noise levels.
-3.55
LeRoy J. Pahmiyer
1. Expressed opposition to the program because
individuals can take more effective action through
direct contact and the courts.
-356
Leonard Feuerstein
1. Expressed opposition to the program because
of the ineffectiveness of existing regulations
which are not enforced, increased cost, and
effectiveness of competition.
-357
Mrs. Sylvia L. White
1. Expressed support for the program, citing
blenders, air conditioners, cake mixers, and
vacuum cleaners.
-358
Rudolf Donninger
Ostereichisches Normungsinstitut
1. Requested further background information,
particularly on the choice between the noise
power level or the noise pressure level for
labeling purposes.
2. Suggested use of the noise power level of the
International Standards Organization for ratings.
3. Noted that Austria intends to issue similar regu-
lations and thus wished to be kept informed.
-359
J°seph P. Shepherd, Jr.
1, Expressed support for the program and com-
mented on general environmental noise.
281
-------
Docket Number, Name,
Affiliation
Comments
77-8-360
Kenneth Young
Expressed opposition to the program because of
increased costs and excessive government meddling.
-361
Mr. W. J. Perney
1. Requested copies of the hearings.
-362
(Dr.) Bessie Chronaki
1. Suggested decibel labels on the volume controls
of radios, TV's and stereos.
2. Suggested control of sounds from "Musak" in
public places because of its "escapist" qualities.
•363
A, Stephan Bozun, Jr.
1. Expressed support for the program to allow
for comparative shopping on noise levels.
2. Noted the noisiness of vacuum cleaners, dishwashers
and lawnmowers.
3. Suggested that the labels be kept simple and that
the decibel levels be designated.
-364
James M. Farrell
Expressed opposition to the program because of
the capability of consumers to make their own
decisions.
Suggested that EPA's efforts be confined to requests
from local government.
. -365
R. A. Mahr
1. Cited a Washington State Ecology Department
survey showing citizen concern for control of
motorcycle noise.
-366
David W. Clark
1. Expressed concern over motorcycle noise.
282
-------
Docket Number, Name,
Affiliation
Comments
77-8-367
Larry J. Hall, M.D. PSC
1. Noted that, with a scale A meter, a Kitchenaid
dishwasher generated 80 dB at six feet and a
Westinghouse heat pump generated 70 dB at three
feet from an air duct. Levels deemed to be
detrimental by the writer.
2. Expressed concern with U. S. Navy ship noise
and suggested that Federal agencies be required
to lead the way in noise abatement.
-368
Marvin Bing
1. Suggested noise control and labeling of all
items, such as refrigerators and trucks.
•369
W. E. Schwieder
Ford Motor Company
1. Accepted invitation to testify at the Washington,
D. C. hearing.
-370
Melvin D. Furman
1. Expressed opposition to the program because
of lack of public understanding of dBA levels and
because of increased costs to consumers.
•371
Mrs. J. Lamb
1. Expressed concern over barking dogs and loud
music during the night
-372
Joi Anne Garrett
1. Expressed general support for the labeling program.
•373
A. Hyland
1. Expressed opposition to the program because of:
(a) increased costs and inferior products,
(b) public satisfaction with current noise levels,
(c) adverse effects on the economy, as in the
recent "depression" caused by EPA's auto-
mobile emission standards,
(d) lack of clarity of proposed noise level labels,
(e) decrease of individual freedom.
283
-------
Docket Number, Name,
Affiliation
Comments
77-8-374
Charles V. Anderson, Ph.D.
Associate Professor of Audiology
University of Iowa
Requested the opportunity to testify on behalf
of the American Speech and Hearing Association
and the Iowa Council on Speech, Hearing and
Language Disorders at the Cedar Rapids hearing.
-375
Kenneth Truce
1. Requested information on the Cedar Rapids hearing.
-376
Constance (Mrs. George) Bell
1. Expressed disagreement with an editorial in
Monistown, N.J. Daily Record which opposed the
program as excessive governmental regulation
(included copy of the editorial).
2. Expressed concern with general environmental
noise makers such as lawnmowers, chain saws
and vacuum cleaners (Kenmore).
3. Noted use of noise from fans and air conditioners to
drown out more irritable noise and requested
that these products remain loud.
-377
Patrick C. Welsh
Principal Environmental Specialist
Municipality of Anchorage, Alaska
1. Expressed support for the program, citing the
noise of blenders; hairdryers and trash compactors.
2. Suggested that glass or steel packed mufflers be
banned from public use unless they emit less
than 76 dB(A) at 25 feet after 500 hours' use.
3. Requested placement on the mailing list for
further information on the program.
-378
James W. Klimes
Product Safety Department
,:Deere and Company
1. Requested the opportunity to testify at the
Cedar Rapids hearing.
284
-------
Docket Number, Name,
Affiliation
Comments
77-8-379
Dick Almy
1. Expressed opposition to the program because
of lack of concern with noise if the product
performs satisfactorily.
-380
Roland Westerdal
President, Bilsom International, Inc.
(Insert also into 77-5)
1. Bilsom International, a manufacturer of
personal hearing protective devices, noted that
the proposed labels are aimed too heavily at
the end user rather than the purchaser of the
product, distorting the intended audience.
2. Suggested greater flexibility in the means of
giving notice beyond affixing a standardized
label, and suggested substitution of the word
"notice" for "label" in paragraphs 211.1.4, 5,
6,7, and 8.
3. Suggested that reference to labeling conditions
be deleted from paragraph 21 l.l.l(H(a) to
preserve the value of the testing exemptions.
4. Asserted that the provisions of paragraph 211.1.9(b)
overreached the agencies authority for extra-
territorial jurisdiction and suggested that EPA
need not enter foreign facilities to fulfill the purpose
of the regulations.
5. Expressed the opinion that the inspection and
monitoring provisions for access to facilities were
unreasonable in light of the proprietary nature of
the linn's products, and suggested accordingly
that subsection b(lX3) of 211.1.9 be deleted. In
addition, subsection c should be amended to
allow inspection and monitoring noise testing where
conducted in the U. S.
6. Suggested changes in wording to assure that
EPA bears the cost for any testing required by
the administrator.
285
-------
Docket Number, Name,
Affiliation
Comments
77-8-381
diet Pitek
1. Expressed concern over highway noise near
his residence and asked for remedial suggestions
for abatement of this noise.
-382
John E. Gitshall
1. Expressed (a) the opinion that government should
regulate private industry and (b) support for gov-
ernment effort to regulate noise.
-383
Mrs. Josephine (Illegible)
1. Expressed concern for the enforcement of muffler
laws for motorcycles.
-384
Unreadable
1.. Expressed concern over noise, especially that of air*
planes and trucks, as a cause of social disorders.
2. Expressed support for the program and for strict
enforcement of EPA regulations in general.
-385
Jenny L. Armour
1. Expressed concern over hairdryer noise and
wanted such products tested for noise
levels.
2. Requested information on the results of the
hearings.
-386
J, C. Cornelius
1. Expressed concern over noise from motorcycles,
small cars, and trucks, especially U. S. Postal
Service trucks.
-387
Lois (Mrs. Robert S.) Green
1. Expressed support for the program.
2. Expressed concern over enforcement of noise
controls on motorcycles and hot rods, which
should be at a higher priority than abating noise
from construction equipment.
286
-------
Docket Number, Name,
Affiliation
Comments
77-8-388
day Gerken
1. Suggested the noise labeling of vacuum cleaners
and dishwashers.
-389
Hen L. (Mrs. John) McCamish
1. Expressed support for noise abatement efforts.
citing noisy refrigerators, chain saws and
lawnmowers.
-390
Theodore Berland
President, Citizens Against Noise
1. Requested the opportunity to testify at the
Washington, D. C. hearing.
-391
(Name is Illegible)
MacMurray Pacific Wholesale
Builders' Specialties
1. Noted the San Francisco hearing and requested
more information on the subject
-392
Darrell E. Wolbers
J.I. Case, Tenneco
1. Informed EPA of Case representative to testify
at the Cedar Rapids hearing.
-393
High School Students
Expressed concern over the loud music at
parties and wondered what could be done.
-394
H.J.Wise
W. H. Brady Company
As a manufacturer of nameplate and labeling
products, requested copies of proposed regulations
for their review and comment
-395
Spessard
1. Expressed support for the program, citing
vacuum cleaners and blenders, in order to make
intelligent choices.
•396
&arlene Davis
1. Expressed concern over noise from blenders,
mixers, refrigerators, motorcycles and snowmobiles.
287
-------
Docket Number, Name,
Affiliation
Comments
77-8-397
Mrs. Lillian E. Burns
1. Expressed concern over noise from newer
appliances (e.g., a refrigerator, a mower, and
cars) relative to older, more noise-free
appliances.
-398
Cherie Larson
1. Expressed support for the program, citing
lawnmowers, vacuum cleaners, washers, motor-
cycles, and piped in music at shopping centers
and restaurants.
-399
Charles E. Speiser
Certified Hazard Control Manager
Expressed concern over chain saw, lawnmower
and "weed eater" noise, which he has measured
at 106 dB(A) and strongly suggested labeling
of these products.
Suggested instructions on the label or in sales
information which advised user of above products
to wear hearing protectors.
-400
Richard 0. Thomalla
International Acoustical Testing
Laboratories, Inc.
1. Expressed support for the labeling program.
2. Discussed his company's sound rating procedures
and specific costs. Standard fee for conducting a
sound power test in accordance with ANSI SI.21 &
$300 but cost could be reduced to S200 or less if
fewer frequency bands taken, while a single number
sound power level test would cost around $150.
3. Suggested that cost of testing and lab availability b*
major considerations when devising a rating schem*-
While simplest rating would involve a sound
pressure reading, availibility of testing labs with
anechoic room is less than desirable. A more
practical approach is a sound power measureme^1'
because sound power data is corrected for whateve
environment it is measured in.
288
-------
Docket Number, Name,
Affiliation
Comments
77-8-401
David M. Anderson
Bethlehem Steel Corp.
1. Criticized lack of requirements for providing infor-
mation on how "noise reduction ratings" can be used to
determine the actual noise levels when the product
is installed in a specific environment.
2. Asserted that a small additional amount of informa-
tion could allow user to predict resulting noise level
when installed.
3. Suggested inclusion of requirement that this
information be included on the label or in
supplementary material provided to purchaser.
-402
Pearl Michaelson
1. Expressed support for noise control program.
2. Listed noisy appliances: dishwasher, washing
machine, clothes dryer, refrigerator, lawnmower,
air conditioners, and garbage disposal.
-403
Louis H.Bieler
1. Complained about noise of a new air
conditioner.
2. Noted that the manufacturer, when contacted,
had no concern about the noise level.
3. Suggested that there had been false advertising.
•404
C. Worthington
1, Expressed opposition to the noise labeling program,
suggesting that it is a waste of taxpayers' money.
•405
na Hellman
P«Pt. of Speech Pathology and Audiology
B°ston University
and
Seharf
Auditory Perception Laboratory
Northeastern University
1. Suggested rating based on a computational proce-
dure instead of a weighted physical measure such as a
dBA, because the former includes subjective psycho-
acoustic methodology, provides a linear measure,
allows for incorporation of refinements relating to
tonal components and sound intermittency, and
involves costs that are lower than those required
for standardized sound-level measurements.
289
-------
Docket Number, Name,
Affiliation
Comments
77-8-405 (Continued)
2. Mentioned calculation systems: (1) American
National Standard S3.4 Procedure for the
Computation of Loudness of Noise; (2) Part B
of R-532 of the International Standards Organi-
zation (a Procedure for Calculating Loudness Level);
and (3) 150 R507, Procedures for Describing Aircraft
Noise Around an Airport.
3. Discussed technical and cost-related advantages
and disadvantages of dB(A).
4. Mentioned that although the public is aware of deci-
bels, sound ratings could not easily be related to them,
and any rating system will be new to the public
anyway. Also, increasing public understanding of
dB(A) would not be of great benefit, since con-
sumers are not involved in monitoring or measuring
noise levels.
5. Argued in favor of using sones as a means of
expressing noise level on the label because:
a. The scale is linear and absolute.
b. The measure is internationally accepted.
c. It would promote understanding of direct.
measures of the subjective effect of noise.
6. Supported numerical ratings versus categories.
7. Commented on problem of taking into account
aging of noise-producing product, suggesting an
average of measurements taken after a period of
simulated use.
8. Mentioned problems associated with temporal
factors, including overall duration, intermittency,
and tonal components; and recommended a delay
in labeling products whose noise qualities reflect
these problems.
9. Advocated the creation of a federally-sponsored
but independent laboratory which would test
products, advise manufacturers, and perform
relevant research.
290
-------
Docket Number, Name,
Affiliation
Comments
77-8-406
Charles W.Hyer
The Marley Corporation
1. Requested information on the hearings, indicating
that he wished to attend and offer comments.
-407
Mrs. Gregory Brill
1. Expressed concern over television noise.
•408
Lewis K. Hosfeld
1. Expressed concern over noise from trail cycles.
-409
Claude Shirai
Japan Machinery Federation
Requested information on proposed noise labeling
standards.
-410
Frances J. Babon
1. Expressed support for noise labeling program.
2. Suggested that her family's health is adversely
affected by noise.
3. Suggested products to be labeled: Hair dryers,
vacuum cleaners, food blenders, shop tools, lawn
and garden equipment, chain saws, remote con-
trolled airplanes and boats.
-411
Archie L. Spratt
Instamatic Corporation
1, Expressed opposition to noise labeling regulatory
program, especially as applied to roof-top
air conditioners on RV's due to:
a. high cost of testing procedures,
b. lack of public complaints about noise of
their products,
c. the fact that noise reducing features will
reduce efficiency.
•412
F. Renneberg
1. Expressed opposition to the program, stating
that the market mechanism is sufficient to solve
the noise problem, if it exists.
291
-------
Docket Number, Name,
Affiliation
Comments
77-8-413
Melvin W. Talbott
1. Expressed support for noise labeling program,
mentioning cars, trucks and vans as prime
candidates for labeling.
2. Expressed concern about loud traffic noise.
-414
Larry Potter
Kentucky Department of Labor
Occupational Safety and Health
(Insert in Docket 77-5)
Suggested that on the labels of noise reduction
products, it should be stated that the attenuation
values are affected by improper fitting or wearing,
and that these values are determined under ideal
conditions.
-415
Mrs. F. J. Hammond
Expressed concern about the noise of kitchen
blender.
-416
Stan Dudek
1. Expressed concern about traffic noise.
-417
Thomas A. Dobbelane
Suggested that labeling will not solve the noise
problem and that regulation is necessary because
people like noisy products.
Complained about noise of chain saws, lawnmowers,
trail bikes, motorcycles, cars, TV commercials,
and motorboats.
Dr. and Mrs. Ronald L Hall
1. Expressed support for labeling program.
2. Suggested these products for labeling: air conditioners
(window units), hair dryers, fans, dishwashers, and
vacuum cleaners.
-419
Alberta J. McAlamey
1. Expressed concern about the noise level of Hoover
vacuum cleaner and motorcycles.
292
-------
Docket Number, Name,
Affiliation
Comments
77-8-420
Le Ann Price
1. Expressed support for labeling program.
2. Listed noisy appliances: stove exhaust fan,
hand mixer, lawnmowers, hair dryers, vacuum
cleaners and refrigerators.
-421
Edward J. Reilly
1. Expressed support for the noise regulation
program.
2. Complained about the noise of public transportation
vehicles and cars.
•422
William C. Legg
1. Expressed support for noise regulation program.
2. Noted that vehicles, particularly trucks, are
excessively noisy.
3. Suggested that factories should not be located
in residential areas.
-423
Frances Szablewski
1. Expressed support for noise labeling program.
2. Listed noisy appliances: dishwasher, washing
machine, lawnmower, coffee grinder, vacuum
cleaner.
•424
Francois Louis
Renault, USA
(Insert in Docket 77-9)
I. In connection with possible noise labeling of
vehicles and mufflers, suggested methodology
for measuring certain noises associated with cars,
specifically exhaust noise, engine noise, exterior
and interior noise, and difficulties associated with
each technique.
293
-------
Docket Number, Name,
Affiliation
Comments
77-8-425
P. D. Southgate
1. Expressed support for noise labeling program.
2. Suggested that in the case of products when a
third party is affected, labeling is not sufficient
and regulation is needed.
3. Suggested that state regulation is not sufficient
when a product is nationally marketed, but Federal
regulation is necessary.
-426
L. Lamar Black
1. Expressed opposition to the labeling of household
appliances.
2. Criticized EPA actions because of increased prices
for consumers.
3. Asserted that manufacturers are capable of regulating
themselves through competition
-427
Rachel Corbin Riley
1. Complained about the noise of a factory near
her house.
-428
Mr. and Mrs. John R. Sheeley
1. Expressed support for noise abatement program.
2. Listed noisy appliances: vacuum cleaners, chain
saws, power mowers, dishwashers.
-429
Robert J. Entwisle
Automatic Switch Company
1. Requested information concerning labeling program
and specific products that will require labels.
•430
M. F. Crabtree
1. Requested assistance with a specific noisy appliance,
an air burning furnace in their mobile home.
294
-------
Docket Number, Name,
Affiliation
Comments
77-8-431
Mis. Marie S. Griffin
1. Expressed support for labeling program.
2. Suggested that merchants be required to demon-
strate their products in the store so that consumers
can hear the noise level.
3. Expressed concern about the noise level of
dishwashers, in addition to lawnmowers and
television commercials.
-432
Mrs. James H. Watson
1. Listed noisy products: vacuum cleaner, hand and
large mixer, electric razor, lawnmower, hand
skill saw, gas driven saw, hair dryer.
•433
Mrs. Dorothy Chapin
1. Expressed support for the labeling program.
2. Suggested that the noise level of electrical pumps
used for irrigation be regulated.
•434
Warren E. Cast
Cast Manufacturing Corp.
1. Expressed opposition to the labeling program,
stating that it is unnecessary and will not influence
purchasers' decisions.
2. Expressed the opinion that as consumers begin
to look for quieter products, manufacturers will
make quieter products.
-435
Mrs. Buddy E. Arbuckle
1. Expressed concern about the noise levels of
dishwasher and hood fan.
•436
Mrs. L. J. McNeill, Jr.
1. Listed noisy products: vacuum cleaner,
hand-held hair dryer and vehicle motors.
295
-------
Docket Number, Name,
Affiliation
Comments
77-8-437
Family Finance Class
Fordland High School, Missouri
1. Listed noisy appliances: garden tillers, garbage
disposals, lawnmowers, blenders, hair dryers,
electric mixers, washing machines, dryers, vacuum
cleaners, refrigerators, sewing machines, air
conditioners, fans, telephones, dishwashers.
2. Suggested a rating scale from 1 to 10.
-438
Andrew Aitken
1. Suggested that trucks do not obey current noise
regulations, and that noise checks be integrated
with speed checks conducted by the state police
2. Suggested that trail bikes be made so that mufflers
cannot be removed since enforcement of regulations
in that case is virtually impossible.
-439
Theonie Lilmore
1. Expressed support for the labeling program.
2. Suggested that retailers who sell noisy appliances
also sell hearing protectors.
-440
S. Ditz
1. Expressed concern about the noise of a vacuum
cleaner.
-441
Helen M. Schmidt
Listed noisy products: vacuum cleaners, air
conditioners, kitchen vent fans, mixers, tele-
visions, lawnmowers, power tools, motorcycles
and trucks.
Suggested that by requiring labeling, manufacturers
will be forced to think about noise.
-442
Eunice B. Quids
1, Suggested that motorcycle noise should be strictly
regulated, with heavy fines for violations of noise
ordinances.
296
-------
Docket Number, Name,
Affiliation
Comments
77-8-443
Louise Wilson
1. Listed noisy products: vacuum cleaner, refrigerator,
and central heating unit.
•444
K. O. looker, Pros.
Plasticast Laboratories, Inc.
(Insert in Docket 77-5)
Indicated that sound attenuation of custom molded
ear protectors will vary from one individual to
another depending on stiffness of ear tissue
and other factors. Tests have indicated attenu-
ation varying from 18 to 22 decibels in the range
of 300 to 1000 Hertz and from 28 to 35 decibels
in the range of 3000 Hertz and beyond.
-445
Carol Seamon
1. Expressed support for a labeling program.
2. Suggested that mandatory noise limits be set for
vacuum cleaners, lawnmowers and shop tools.
3. Suggested that a numerical rating system be used,
rather than symbols.
•446
Unsigned
1. Listed noisy products: vacuum cleaners, hair
dryers, electric mixers, lawn mowers, chain saws.
motor cycles.
•447
The Veresh's
1. Listed noisy appliances: hair dryer and vacuum
cleaner.
•448
Sam and Laura Robbins
1. Listed noisy products: Lawnmowers, motorcycles,
air conditioners, pool filter pumps, indoor and
outdoor vacuum cleaners, autos, trucks, hair
dryers.
2. Requested information on the noise level of
different pool filters and vacuum cleaners so that
they can comparison shop.
297
-------
Docket Number, Name,
Affiliation
Comments
77-8-449
Max 0. Bflfft
Listed appliances needing labels: vacuum
cleaners, refrigerators, air conditioners, hair
dryers, heater blowers, shop tools, dishwashers,
exhaust fans, washing machines and dryers,
power boats, toys.
-450
J. C. and Dorothy Kenyon
Expressed concern about the noise level of
boats and trucks.
•451
Unsigned
Rank-ordered noisy products: lawn and garden
equipment, shop tools, air conditioners, vacuum
cleaners and floor waxers, dishwashers and
washing machines, blenders, hair dryers, and
electric fans.
2. Suggested use of symobls for noise rating descriptor.
-452
Eleanor Culberson
1. Expressed support for labeling program.
2. Mentioned need for quiet dishwashers, vacuum
cleaners, and washing machines.
•453
Allison Titus
1. Complained about danger of vacuum cleaner's
retractable cord.
-454
Unsigned
1. Opposed labeling program viewing it as a
waste of money.
-455
Mrs. A. William Eutler
1. Complained of noise emitted by a vacuum
cleaner.
298
-------
Docket Number, Name,
Affiliation
Comments
77-8-456
Mrs. Bill Joe Austin
1. Complained about neighbor's air conditioning
ana heat pump system.
2. Suggested heat pump, because of stationary
position and continuous use, be given priority
for noise control.
3. Empnasized that neighbor was not informed about
noise level at time of purchase.
-457
Mrs. Ralph Moffet
1. Complained about noise of refrigerator
^58
Roger D. Smith
1. Requested placement on mailing list for product-
specific regulations.
2. Asked if regulations exist covering laboratories
that provide compliance testing services.
•459
Yvonne Brunstad
1. Expressed support for labeling program.
-460
Elizabeth McCutchen
1. Complained about noise emitted by vacuum
cleaner.
•461
Mrs. A. P. Lovato
1. Expressed support for noise abatement program.
2. Suggested a warning be placed on labels and ads
similar to Surgeon General's cigarette-smoking
warning.
-462
John L. Warner
1. Believed labeling of motorcycles and exhaust
systems will be ineffective but supports maximum
noise levels and fines for altering the system.
299
-------
Docket Number, Name,
Affiliation
Comments
77-8-463
Mrs. R. J. Gelhar
1. Complained about noise of vacuum cleaners,
hair dryers, and washing machines.
-464
Geraldine Greig
1. Expressed support for program.
2. Referred to computers and business machines
as a source of noise.
-465
Shirley W. Valin
1. Expressed support for labeling program.
2. Sources of noise mentioned as annoying are
vacuum cleaners, shop tools, power mowers and
gardening equipment.
-466
Muriel Cowing
Ann Smith
1. Expressed support for labeling program.
2. Referred to vacuum cleaners as major noise source.
3. Preferred symbols to numbers as noise rating
descriptors.
1. Expressed support for labeling program.
2. Stated that numerical rating would be better
than a symbolic system.
3. Requested information on different types of
noise pollution (e.g., Concorde, rock music).
-468
Unsigned
1. Opposed program due to increased costs and
restrictions on individual freedom.
300
-------
Docket Number, Name,
Affiliation
Comments
77-8-469
Frederick G. Crocker, Jr.
Vice President and General Manager
Safety Products Division
Norton Company
(Insert Into 77-5)
SONIC EAR VALUS and SONIC II protectors
cannot be tested using ASA STD 1-1976/ANSI
Sec. 3.19-1974 and thus cannot be assigned an
NRR number.
Commented on Sec. 211.2.5 concerning
exceptions to rating system.
a. Second sentence should be limited to
devices not already on the market. Alter-
native procedure should be used for those
products already on the market. Application
process for a "suitable alternative rating
system" should allow a year after promulga-
tion date to run tests and to prepare application.
b. "Suitable" is not defined in phrase "suitable
alternative effectiveness rating." Submitted that
a "suitable" alternative rating system for a
device for which NRR is not an accurate indi-
cator can be independent and unrelated to
NRR system.
c. Sec, 211.2.5(c) does not define what constitutes
"conclusive scientific test data" (suggested language)
Changes proposed are designed to permit continued
marketing during testing and processing of application.
•470
Mrs. Don E. Van Meter
Complained about noise of vacuum cleaner.
Model S3073).
Noted that demonstration on sales floor did not
effectively indicate true noise level in home.
-471
Mrs. George W. Moor
1. Support ed noise labeling program.
2. Complained about air conditioner's interference with
speech.
301
-------
Docket Number, Name,
Affiliation
Comments
77-8-472
Mrs. Carl Bostick
1. Supported abatement of noise emitted by appliances.
2. Noisy products listed include vacuum cleaners,
fans, food mixers, blenders and powered lawn and
garden equipment.
-473
Shirley K. Jensen
1. Complains about noise emitted from air conditioner,
vacuum cleaner, hair dryer, food blender, dishwasher,
and coffee grinder.
-474
Mrs. Bill MacLean
1. Complained about "canned music" in various
public places.
•415
Mrs. David J. Lukens
1. Expressed support for labeling program.
2. Commented on excessive noise of washing
machine.
3. Supported a rating scheme which uses descriptions
of "very loud," "loud," etc.
-476
Vera Kurkus
1. Complained about noise emitted by blender,
meat grinder, vacuum cleaner, hair dryer, and
lawn mower.
R. J. Smith
Pearl Harbor Survivors Association
1. Claimed that two extremely noisy products are
vacuum cleaners and gasoline-powered lawnmowers.
-47B
Mrs. H. N. Kelly
1. Supported noise abatement program.
2. Mentioned a vacuum cleaner, exhaust fans,
and school bells as extremely noisy products.
302
-------
Docket Number, Name,
Affiliation
Comments
77-8-479
Mrs. Gretchen Ogle
1. Supported noise labeling program.
2. Commented on excessive noise emitted by a
vacuum cleaner.
-480
Kathryn Kennedy
1. Supported noise labeling program.
2. Cited garbage disposal, electric broom, and
vacuum cleaners as noisy appliances.
•481
Mr. and Mrs. Anthony P. Burasz
, Complained about noise emitted by "Big Wheel"
tricycles.
•482
Roy C. Patrick
Hearing Aid Consultant
1. Recommended making illegal any modification
of automobile or motorcycle exhaust system
that produces greater noise emission.
-483
Mrs. Anthony B. Manera
1. Considered household appliance labeling as un-
necessary but supported noise abatement actions
directed at lawnmowers, motorcycles, and blowers.
-484
Unreadable
1. Complained about noise of a hair dryer.
-485
Phyllis A. W. Jamison
Complained about disruptions in her elementary
school classes caused by aircraft based at Oceana
Naval Air Station.
-486
Laurence B. Ritter
Listed noisy products: hairdryer, diswasher, oven
fan, washing machine, and electric workshop tools.
303
-------
Docket Number, Name,
Affiliation
Comments
77-8-487
Paul L. Young
1. Supported strong emission regulations for
motorcycles and especially trail bikes.
2. Expected EPA to notify him of its position and
action.
-488
Ursula Stanton
1. Commented on excessive noise produced by a
dishwasher.
-489
Eliana Woodford
1 • Supported noise abatement controls for a vacuum
cleaner, blender, and hair dryer.
-490
Unreadable
1. Supported labeling of electric appliances, men-
tioning dishwashers and vacuum cleaners.
-491
W. L. Bolyard
1. Supported noise abatement actions targeted at
motor bikes, heavy duty trucks, and chain saws.
-492
Mrs. Albert E. Montague
1. Mentioned major noise offenders: vacuum
cleaners, refrigerators, dehumidifiers, TV
commercials, motorcycles, and lawnmowers.
-493
M. M. Walker
Complained about noise emitted by lawn and
garden equipment, vacuum cleaners, and
household appliances in general.
-494
Ms. Olive H. Kennedy
Complained about noise emitted by a vacuum
cleaner.
-495
Mr. Allen D. Slater
1. Supported product noise labeling for electric appli-
ances, especially vacuum cleaners, hair dryers, dish-
washers, and air conditioners (window units).
2. Preferred a numerical rating system.
304
-------
Docket Number, Name,
Affiliation
Comments
77-8-496
Margaret Carrico
1. Expressed opinion that ONAC should focus
on TV commercials.
-497
E. C. Blackburn
1. Supported noise l?beling program.
2. Mentioned vacuum cleaner, digital clock, radios,
and hair dryer as major offenders in his home.
-498
Mrs. Vernon Alvord
1. Commented on excessive noise emitted by a
refrigerator.
-499
S. Smith
1. Complained about noise of a hairdryer.
2. Mentioned that he had not been aware of its
noise emission qualities at time of purchase.
-500
Unsigned
1. Complained about noise emitted by a vacuum
cleaner and refrigerator.
•501
Mrs. R. LeRoy Rollins
1. Suggested that many household products are
too noisy.
2. Listed noisy appliances: vacuum cleaner,
air conditioner, and food processor.
-502
E.Bailly
1. Stated that noise invades his privacy.
2. Listed noisy products: stereos, radios, televisions,
tape recorders, CB radios, PA systems, vehicle ex-
haust systems, lawnmowers, power saws, motor-
cycles, aircraft, recreational vehicles such as dune
buggies and snowmobiles.
3. Urged that national regulation is necessary rather
than state control.
305
-------
Docket Number, Name,
Affiliation
Comments
77-8-503
Mrs. Delbert Christiansen
1. Expressed support for the labeling program.
2. Complained about the noise level of a refrigerator,
central air conditioner, a vacuum cleaner and
refrigerator.
-504
Dr. Sharon L. Scholl
1. Stated that local police have been no help in
keeping down the noise level of motorcycles,
thus it is necessary to get manufacturers to
reduce noise.
2. Listed noisy products: air conditioners, vacuum
cleaners, garbage disposals, blenders, electric scissors.
3. Noted the importance of such factors as duration
of use, as is the case with air conditioners, and
cases where one is not controlling the source of
noise, as is the case with motorcycles.
-505
Pat Newport
Complained about the noise of her vacuum
cleaner.
Stated that a label containing noise level information
on the vacuum cleaner would have altered her
purchase decision.
-506
H. Malcolm Lewis
Westside Building
Materials Company
1. Expressed support for noise control program.
2. Urged action on the noise of cement trucks,
several of which are located in a plant next to
their showroom.
-507
D. Roman
Listed noisy products: an air conditioner and
an electric broom.
Observed that her 10-year-old air conditioner
cools faster and is quieter than her new one.
306
-------
Docket Number, Name,
Affiliation
Comments
77-8-508
Mrs. Herbert Bergam
1. Complained about the noise level of her coffee
maker.
-509
W. A. Hyland
2.
3.
Disagreed with idea that products need to be
noise level labeled. Manufacturers will try to
harvest lowest noise levels and end up pro-
ducing inferior products costing more.
Stated that labeling will increase cost of products.
Felt that the proposal numbering of noise
levels could be confusing to people.
-510
G. A. O'Brien
Representative,
17th District, Illinois
Requested information on response to
Docket #77-8-011
-511
M. D. Furman
Stated that equipment to be noise labeled
is not used by people who understand decibels;
(labeling) is stupid and costly.
-512
H. Hoffman
1. Requested information on noise regulations.
307
-------
Docket Number, Name,
Affiliation
Comments
77-8-513
Mrs. J. V. Johnson
Expressed annoyance about the small motorcycles
ridden by children as well as the full-sized motor-
cycles.
-514
Mrs. Thomas Williams
1. Expressed support for noise abatement legislation.
2. Stated that their rights are being infringed upon by
lawnmowers and motorcycles operated by others.
-515
Harry Hughes
Listed disturbing products whose noise comes
from the exhaust pipes: automobiles with
"High Performance" mufflers, motorcycles, jet
aircraft, propeller driven planes, helicopters
with rotor slap and diesel locomotives.
Stated that noise pollution is as much of a health
hazard as exhaust fumes.
-516
William Andersen
1. Urged noise regulations for lawnmowers.
2. Expressed the opinion that both the older and
the newer lawnmowers have the same noise level.
-517
A Concerned Citizen
1. Expressed support for noise regulation of motor
bikes.
-518
Thomas R. Houck
1. Complained about the military aircraft that
constantly fly over his vacation home in South
Carolina.
308
-------
Docket Number, Name,
Affiliation
Comments
77-8-519
Allen O. Kundtson
-520
F. Macenko, Chief
Noise Control Division
Environmental Protection of Canada
1. Complained about the noise that issues constantly
from the boiler smoke stacks of a packing plant
in Wisconsin.
2. Suggested that this noise drowns out other
undesirable noises.
1. Expressed support for the labeling program.
2. Stated the opinion that labeling, if used in
conjunction with an adequate public information
program, can help to minimize public exposure to
excessive noise.
Urged that the Noise Rating number reflect
"in-use" noise rather than noise in a free running
state.
4. Urged the use of Leq to help facilitate comparisons
between products on the part of the consumer.
5. Noted that the use of different rating schemes for
different products would be of minimal use to
the consumer.
6, Suggested that products which have a similar
function be given comparable noise ratings (such
as a hand saw and a power saw).
7. Suggested that either a label or flyer be included
with the product to explain the purpose and meaning
of the label and the rating, as well as containing
examples of noise exposure which should not be
exceeded during the average day.
-521
Marilyn Wilkins Samuelson
1. Complained about the noise of her hair
dryer.
2. Expressed support for labels on all appliances with
electric motors.
309
-------
Docket Number, Name,
Affiliation
Comments
77-8-521 (Continued)
3. Suggested that noise levels be expressed in decibels.
4. Suggested that measurements be taken at the
distance of six inches or less.
-522
Ruth Lynn
1. Listed motorcycles and stereos as being excessively
noisy.
2. Suggested that "reason and sense" be exercised
in noise control actions.
-523
Edwin W. Abbott
Air Transport Association of America
Stated that the Air Transport Association has no
comments about the general provisions of the
product noise labeling regulatory program.
-524
Mrs. Grace Norris
Complained about a recreational flying club near
her home.
-525
Mrs. Richard Frazak
1. Expressed support for noise abatement.
2. Expressed support for noise labeling of vacuum
cleaners.
-526
Lawrence H. Hodges
Vice President
J. I. Case Co.
1. Supported reasonable labeling of products.
2. Viewed labeling as a "viable alternative" to unneces-
sary and unreasonable noise emission standards.
3. Commented on proposal:
a. Recommended permanent label.
b. Opposed use of label information on range
of noise labels for a product class, due to costs,
importance of other factors in purchaser's
decision, and possible regional differences in
product availability.
c. Suggested that statement about measurement
methodology be placed on label.
310
-------
Docket Number, Name,
Affiliation
Comments
77-8-526 (Continued)
d. Recommended a noise rating in dB(A) versus
an acoustic rating descriptor.
e. Preferred manufacturer's self-certification.
4. Submitted letter from Case to Dawes and Moore
with respect to noise abatement (in order of
preference): (1) voluntary labeling, (2) man-
dated labeling without noise standards; and
(3) mandated labeling with minimal noise standards.
5. Submitted into record "Comments to Dawes and
Moore regarding Labeling Noise Levels of Wheel
and Crawler Loaders and Dozers," which:
a. Expressed support for voluntary product label-
ing as a viable alternative to emission standards.
b. Described University of Nebraska information
on tractor noise and how the publication of
this data supposedly produced a demand for
quieter vehicles.
c. Proposed sample label for wheel/crawler
loader/dozers which contains a maximum
noise level certification.
-527
Mrs. Charles Koofmans
1. Expressed support for noise labels on appliances.
2. Listed noisy appliances: vacuum cleaners, hair
dryer, exhaust fan, air conditioners, cars and tractors.
-528
Kelly Bright
1. Expressed support for noise labeling program.
2, Noted loud noise level of a vacuum cleaner
and blender.
3. Observed that noise level is not necessarily related
to efficiency.
311
-------
Docket Number, Name,
Affiliation
Comments
77-8-529
Bruce Nordquist
Public Health Environmentalist
1. Expressed support for noise labeling program.
2. Listed noisy appliances he is aware of due to
his field experience: air conditioner, workshop
tools, powered lawn and garden equipment.
3. Noted that the danger of the above stems from
the long periods of use.
4. Noted that industry has improved many products
by solid construction, better balanced motors
and muffler exhaust systems.
5. Listed other noisy products: children's toys such
as tricycles with hollow plastic wheels, vacuum
cleaners, dishwashers, hair dryers, clothes washers
and dryers, and food mixers.
-530
Mrs. Elizabeth Adamson
1. Expressed support for labeling programs.
2. Listed noisy appliances: a vacuum cleaner,
hair dryer, garden and shop tools.
3. Stated that her dishwasher is extremely
quiet.
-531
Mrs. Patricia Cole Blake
1. Expressed support for the labeling program.
2. Suggested that federal action is necessary for a
successful fight against noise as local police
and health departments are powerless or disinterested.
3. Suggested that cars and motorcycles need to be labeled.
312
-------
Docket Number, Name,
Affiliation
Comments
77-8-532
Nada Yanshak Brillante
1. Stated that both brands of refrigerators she
owns are quite noisy.
2. Urged that refrigerators be considered for
labeling even before dishwashers, because
they are constantly running.
3. Stated that for her, the noise a refrigerator
makes is of greater importance than its price,
size or features.
•533
Mr. and Mrs. R. Robert Wells
1. Listed noisy appliances: a vacuum cleaner
and electric lawn edger.
2. Questioned why products couldn't be manu-
factured to operate more quietly.
-534
William Sorber, Sr.
Complained about the noise of their refri-
gerator, stating that it keeps them awake
at night.
Stated that they have received only negative
responses from the manufacturer, who is un-
sympathetic to noise complaints.
-535
Greg Serafina
1. Complained about noise pollution in general.
2. Argued that power lawn and garden equipment
are the worst offenders because they are used
outdoors and are more easily heard by others
(third party disbenefits).
-536
oenig
1. Expressed support for controlling the noise level
of motorcycles, which are louder than jet planes
near his home.
313
-------
Docket Number, Name,
Affiliation
Comments
77-8-537
Mrs. Ruth L. Levine
Suggested that a comparative noise level standard
be developed, so that personal or phone conver-
sation can be carried on in the same room, or a
doorbell or telephone ring can be heard from
another room.
-538
Mrs. J. W. Hunter
1. Suggested appliances for labeling program: air
conditioners, vacuum cleaners, mixers, blenders
and anything with a gas or electric motor. Mentioned
specifically her own refrigerator.
2. Suggested that quieter appliances of the same
type were made in the past, stressing her experience
with refrigerators.
-539
Charles S. Carlyle
1. Expressed support for noise control; stating that
noise is as much of a problem as air or water
pollution.
2. Expressed the opinion that labeling is not a useless
idea, but should have low priority.
3. Observed that it is not possible to legislate the
sensitivity of one's neighbors.
4. Complained about the noise of barking dogs and
recreational vehicles, particularly snowmobiles
and trail bikes.
5. Suggested that the solution is to tax luxury
vehicles, in addition to regulating them.
6. Stressed the greater importance of reducing the
noise levels of rural areas as .opposed to urban areas.
314
-------
Docket Number, Name,
Affiliation
Comments
77-8-540
Douglas A. Fraser, President
International Union, UAW
Stated that the UAW receives more complaints
about noise than any other occupational hazard.
Expressed support for labeling and noise regu-
lation program.
Emphasized the importance x>f regulating the
noise of industrial machinery, because of
length of exposure for the individual.
Suggested that it is easier to reduce the noise
level of industrial machines at the time of pro-
duction, rather than using OSHA or labor contract
procedures on a plant-by-plant basis.
-541
Aurella Worrell
Listed noisy appliances: air compressors and
air conditioners.
-542
Mrs. W. M. Bingham
Complained about the noise level of television
commercials and previews.
Listed products that need labeling: lawn mowers,
vacuum cleaners, garbage trucks, and railroad tracks.
-543
Mary Wright
1. Expressed support for noise rating program.
2. Requested the noise ratings of heaters, electric
fans and air conditioners.
•544
Ruth Kuper Levine
1. Expressed support for noise labeling program.
2. Noted the particularly high level of noise in
urban areas.
315
-------
Docket Number, Name,
Affiliation
Comments
77-8-545
11m Mueller
Suggested products for labeling: fans, air con-
ditioners, dehumidifiers, humidifiers, dishwashers,
refrigerators, freezers, clocks, mixers, stove
exhaust fans, vacuum cleaners, can openers, lawn-
mowers, chain saws, hedge trimmers, and motor
vehicles.
Suggested using a decibel level as a rating scale,
along with a comparison to give the rating meaning.
-546
Thomas D. Rossing
Professor of Physics
Northern Illinois University
1. Expressed support for noise labeling program.
2. Suggested labeling all powered appliances, including
power tools, fans and pumps.
3. Suggested an enforcement method whereby a
purchaser would be able to recover one-half of
the purchase price if the product had no label or
carried an incorrect label.
-547
Mrs. C. E. Lighter
1. Complained about the noise level of an air
conditioner.
2. Stated that this air conditioner is advertised as
quiet.
3. Stated that the air conditioner they have is
also noisy.
-548
M. B. Doyle, President
International Snowmobile Industry
Association
This entry included:
1. List of average sound emissions of all 1977
model snowmobile produced by seven participate
manufacturers, tested by United States Testing
Company, Inc.
2. Operational Sound Level Measurement Procedure
for Snow Vehicles-SAE Jl 161 and SAE J192a.
316
-------
Docket Number, Name,
Affiliation Comments
77-8-548 (Continued) 3. Sample copy of the Snowmobile Safety and
Certification Committee Sound Rating Label.
4. News release issued by the International Snow-
mobile Industry Association on September 19,1977.
a. Announced the adoption of a voluntary sound
emission labeling program for all new snow-
mobiles.
b. Discussed a labeling procedure whereby each
snowmobile will bear a label showing its
sound rating.
c. Noted that the industry had achieved a
94 percent reduction in sound emissions of
snowmobiles since 1968-a voluntary reduction
due, in part, to EPA's actions.
5. Document describing the labeling program, which
discusses the emissions standards.
a. Noted that the emission rating consisted of two
parts, a maximum sound emission at wide open
throttle and a typical sound emission at IS mph.
A good deal of variation between these two
measures can be present due to size of machine.
1 b. Observed that variations in temperature, humidity,
elevation and surface conditions can produce a
sizable error in measurement, which is compen-
sated for by a 2dB(A) tolerance in the measure-
ment.
c. Indicated that it would be inappropriate to
include the range of snowmobile ratings on a
label, because of the lack of precision in the
measurement and the clustering of all models
around a single sound level.
d. Suggested that it is difficult to produce a range
of snowmobile ratings until the end of the
year since snowmobiles are produced all year.
e. Recommended against putting the manufacturer
and model number on the label, stating that such
action meant added expense and logistical prob-
lems, since other procedures are available to
guard against misuse of labels.
f. Provided details of labeling process.
317
-------
Docket Number,. Name,
Affiliation
Comments
77-8-549
Elisabeth G. Garrison
1. Expressed support for noise abatement.
-550
Rhea A. Bahlion
1. Suggested a "numbering system" as an appro*
priate noise level rating as it would be easy to
understand.
2. Listed noisy appliances: shop tools such as skill
saws, jigsaws, electric drills, mills, bridgeports and
lathes; garden tools such as tillers and lawnmowers;
dishwashers, blenders, electric coffee grinders and
refrigerators.
3. Suggested that attention also be directed to heavy
trucks, motorcycles, snowmobiles and chain saws.
-551
Mrs. Elizabeth E. Bricks
1. Listed sources of noise: blowers in public restrooms,
vacuum cleaners, cars, motorcycles, airplanes, plumbing
in the walls.
-552
Roy R. Morris, representing
American Rental Association-
supplement to oral testimony by
Howard W. Burnett, in Washington,
D. C. on September 16,1977
1. Encouraged careful consideration of the economic
impact that any action might have on a product's
manufacturer or the purchaser, particularly for
small manufacturers.
2. Expressed support for the determination of the
feasibility of the regulation, specifically, can the
noise level of a product be meaningfully and
accurately measured?
3. Urged consideration of the utility of noise labeling.
4. Suggested that noise labeling is of little utility, as their •
members have noted little, if any, demand for "silenced"
equipment, especially if this makes it more expensive.
5. Noted that the labeling noitce regulation is unclear and
ambiguous with respect to the differences between "u-***
mate purchaser" and "prospective user" (Sec. 8), a factor
particularly pertinent in the case of rental equipment.
318
-------
Docket Number, Name,
Affiliation
Comments
77-8-552 (Continued)
6. Noted that the regulations (Section 8) call
for notice to be given to the prospective user and
give the Administrator authority to decide whether
notice to the ultimate purchaser is sufficient or
whether notice should be given to the prospective
user in some other manner.
7. Held that Congress never intended to require
notice to every individual who might operate the
equipment, but only to the ultimate purchaser.
8. Indicated that to require notice of noise to be given
to each user a permanent label, such as are stamped
out of metal, would be necessary to withstand the
types of repeated use their products perceive.
9. Indicated that periodic reattachment of paper or
plastic labels by a rental supplier would be totally
unpractical.
10. Suggested that the regulations be amended so
that the requirements are satisfied when notice
is provided to the ultimate purchaser (the rental
company) at the time of sale, rather than to each
user.
•553
Mrs. Hilbert L. Norton
1. Expressed support for noise abatement in homes.
2. Listed noisy appliances: washing machines, mixers,
dishwashers, vacuum cleaners and refrigerators.
3. Noted that refrigerators are a unique case in house-
hold appliances, since they must run constantly.
4. Complained in particular about her own refri-
gerator, stating that it is much louder than her
old one.
5. Stated that she has contacted the company and
the regional distributor and was ignored.
6. Stated that salesmen in two sales rooms told her
there was no such thing as a quiet refrigerator.
319
-------
Docket Number, Name,
Affiliation
Comments
77-8-554
Carl E. Curet
1. Expressed support for EPA programs and actions
in general.
2. Complained about traffic noise, specifically tractor
trucks, motorcycles, motor bikes, garbage trucks
and diesel buses.
3. Suggested that manufacturers should be regulated.
4. Suggested that elected city officials should be held
responsible for enforcement of noise regulations.
-555
R. S. Gales, Chairman
Subcommittee on Noise Standards
Acoustical Society of America
1. Discussed the Society's scale for expressing the
noise of small noise sources, specifically the
Product Noise Rating (PNR) in decibels-the
space average of A-weighted sound level at a dis-
tance of one meter from a noise source over a
reflecting plane (ASA Std. 4-1975; ANSI S3.17-1975).
2. Argued in favor of this method, as it combines the
accuracy and reproducibility of a sound power
measurement with the consumer relatability of A-
weighted sound level in decibels.
3. Noted that this measurement is particularly
appropriate for home appliances, as it gives the
level in a room with absorbent walls.
4. Argued that a scale in decibels will be useful to
the consumer as it is possible for the consumer
to become familiar with the scale. Mentioned that
we are becoming a noise-conscious society.
5. Opposed use of 1 to 10 rating scheme on a symbolic
scale.
6. Indicated that the best information available should
be presented to the consumer. In other words, use
the actual dB value rather than employing 5dB
steps as classes.
320
-------
Docket Number, Name,
Affiliation
Comments
77-8-555 (Continued)
7. Enclosed reprint of his paper "The Role of
ANSI S3-47(S1) in Coordinating Noise Standards"
presented at the Proceedings of NOISE-CON 75,
pages 259-266,1975.
-556
Ervin Poduska
Professor at Kirkwood
Community College
1. Suggested the use of dBA or some decibel rating
on a label, as it is an absolute standard that is
already meaningful to many which could be
assimilated by the rest of society with a minimum
of public education.
2. Stated that his students easily learn dB(A) measurement
3. Suggested that acoustical tile, ear protectors and
barrier devices be labeled.
4. Suggested that the meaning of noise ratings for
appliances and their effect on one's health be
published, but not necessarily on the label.
-557
Mary Hochman
1. Complained of noise levels of a refrigerator,
noting that sales representative told them it was
normal.
2. Stated that consumers have a right to be aware of
noise levels for refrigerators.
3. Argued that manufacturers should design
quieter refrigerators.
•558
Elinor M. Bowman
1. Complained about her neighbor's power saw.
-559
Douglas A. Fraser, President
hternational Union, UAW
Same as Docket Entry 77-8-540.
321
-------
Docket Number, Name,
Affiliation
Comments
77-8-560
Unreadable
1. Suggested consideration of automobiles and
motorcycles under new regulations.
-561
Earl Hardage
Mrs. Irene Hardage
Celia Turner
Fred Salter
1. Suggested reducing noise on cars, as well as
school bus brakes.
-562
Dr. Joan Stephens
Audiologist
1. Expressed support for the noise labeling program.
2. Stated that she would base her purchase decision
in some cases on noise levels.
3. Suggested labeling ear defenders, vacuum cleaners,
dishwashers, gardening equipment, blenders,
garbage disposals and air conditioners.
-563
Gerald E. Starkey, P.E.
Noise Abatement Specialist
County of Santa Clara
Environmental Management Agency
1. Enclosed comments he presented at the San
Francisco labeling hearings on September 22,1977.
2. Included a list of devices which have caused noise
complaints, as requested by a panel member.
3. Expressed support for the labeling program.
-564.
Anonymous
1. Complained about the noise level of an electric
hair dryer.
2. Stated that if the noise level had been stated on
the package, she wouldn't have purchased it.
322
-------
Docket Number, Name,
Affiliation
77-8-565
Webster and Chamberlain
Counsel to Power Tool Institute (PTI)
2.
3.
Comments
PTI recommended that the acoustic rating
descriptor be Noise Power Emission Level
expressed in bels, or described in ANSI SI.23,
1976. The ANSI standard applicable to the
product being labeled should be used for the
measurement, and if no standard is available,
EPA should work with manufacturers to
develop one.
PTI suggested the comparative acoustic rating
information be deleted due to impracticality
and resulting inequities.
PTI recommended that company name, location,
and model number need not be on the label if they
appear elsewhere on the product.
•566
John P. Reardon
Air-Conditioning and Refrigeration
Institute
Requested extension of public comment period
to November 28,1977, to permit ARI to
incorporate an ARI meeting on November 16
in its Supplementary Statement on the Background
Document.
•567
Melvin F. Kuhn
1. Requested information about "noisy appliances.'
-568
Hon. Elford A. Cederberg
U. S. House of Representatives
1. Expressed skepticism about EPA's concern over
household appliance noise, when it is the outside of
the home that should be targeted.
2. Requested explanation of EPA's activities, especially
as to how they will assist consumer's purchasing
decisions.
323
-------
Docket Number, Name,
Affiliation
Comments
77-8-569
James M. Farrell
(letter forwarded by Sen. Griffin;
reply requested)
Requested the information on surveys which
led to the statement that "the American home is
becoming increasingly noisy," as quoted in the
September 1977 issue of Appliance Manufacturer
(copy attached).
Requested information on the size of the pro-
gram's budget and on "the number of noise com-
plaints that have been received by government
agencies that has caused governmental action."
-570
Mrs. D. D. Fisher
1. Complained about noise made by motorcycles, cars,
and power saws, but asserted that labeling would
be ineffective because many products are made
noisier after being purchased.
2. Proposed that a strong noise nuisance law be
passed and strictly enforced.
-571
Mrs. H. Stovall
1. Complained about noise level of frost-free
refrigerator.
-572
Larry F. Stikeleather, Ph.D.
1. Expressed opposition to the labeling program
because of increased taxes and increased prices.
-573
James Egger
1. Recommended that railroad trains (and their
whistles) be given major attention by EPA in
its noise abatement program.
-574
Jean C. Pressler
1. Praised efforts being made toward noise control.
2. Complained about the loud music that is broad-
cast in shopping establishments and asked for
information about possible solutions.
324
-------
Docket Number, Name,
Affiliation
77-8-575
David P. Reed
1.
Comments
Expressed opposition to the noise labeling
program due to increased costs, higher taxes,
limited effectiveness of similar regulations and
relative quietness of household appliances.
-576
Mrs. Evelyn Beeunas
Requested that EPA "do something about"
the following noise offenders: motorcycles
and motorbikes, "Big Wheels," cars with
bad mufflers, power lawnmowers, large trucks,
automobiles, and vacuum cleaners.
-577
John L. Bennett
Safety Assurance Manager
Black and Decker Manufacturing Co.
1. Black and Decker suggested that acoustic rating
descriptor always be Noise Power Emission Level
expressed in bels as described in ANSI SI.23.1976,
Method for the Designation of Sound Power
Emitted by Machine and Equipment.
2. The NPEL should be measured in accordance
with the ANSI standard applicable to the type
of product to be labeled, and if an ANSI
standard does not exist, EPA and manufacturers
should develop one.
3. Black and Decker suggested deletion of
comparative acoustic rating information.
4. Recommended that company name, company
location, and model number not be required
on label if they appear elsewhere on the product
-578
Haywood Clark Smith
1. Complained about the "waste of taxpayer's money*
on various EPA programs.
•579
Claude A. Frazier, M.D.
1. Expressed support for labeling program, noting its
value for persons with small children, nervous
disorders, or sick people in the house.
2. Referred to article in Ashevitte Citizen and
requested reprints on Noise Pollution.
325
-------
Docket Number, Name,
Affiliation
77-8-580
M. P. Nevotti
Comments
1. Suggested noise standards for motors on appliances,
fans, and the baffles on florescent lights.
2. Stated that home has become noisy and that
emphases on costs and "miniaturization" have
brought about a noisy environment
3. Complained especially about products which
do not operate for short periods of time (e.g.,
refrigerators, air conditioners, and furnace fans).
-581
Nora Priest
1. Complained about noise emitted by neighbors' air
conditioners and expressed support for meaningful
noise control in this area.
-582
Mrs. Helen M. Butter
1. Complained about noise emitted by tools used
by gardeners.
•583
Illegible
1. Expressed concern about the noise level of
mufflers.
2. Indicated that she thought the program was
a waste of time.
-584
Enid M. Johnson
1. Expressed support for efforts to reduce the noise
level of household appliances.
2. Argued that mandatory labeling would result in
long-run noise reduction because of competition.
-585
Edward I. Wolf
1. Expressed support for the labeling program.
2. Expressed support for using decibels for the
noise level rating.
326
-------
Docket Number, Name,
Affiliation
77-8-586
Anonymous
Comments
1. Stated that noise was painful for many persons.
2. Expressed support for labeling products.
-587
Don W. Robinson
1. Suggested terminating the noise labeling and
regulation programs.
2. Expressed objections to federal interference
in the life of the individual.
3. Enclosed a copy of an article which argues
against noise labeling.
-588
Anonymous
1. Expressed support for the labeling program.
2. Stated that noise levels are excessive and can
be eliminated.
-589
Whirlpool Corporation
1. Indicated a shared concern with EPA about the
potential damage caused by noise.
2. Urged EPA to research the effects of noise in
the home as well as the economic costs of labeling
to consumers and manufacturers.
3. Indicated that the marketplace will adequately
dictate the manufacturer's responses to the needs
of the consumer.
4. Questioned the lack of hard data on the adverse
impact of home noise levels.
5. Noted the consumer's belief that sound
and properly functioning equipment are equated.
6. Observed that both dishwashers and vacuum cleaners
fall well below (65 to 67 dBA) the OSHA standard
of90dBA.
327
-------
Docket Number, Name,
Affiliation
77-8-589 (Continued)
Comments
7. Emphasized the short duration of use of
dishwashers (1.14 times per day) and vacuum
cleaners (1 hour per week).
8. Noted that the consumer can choose when he
wishes to run an appliance.
9. Held that the welfare of a consumer is best
protected by his own logical, discretionary use
of appliances.
10. Expressed concern with the plethora of labeling
programs and with the government's abflity to
coordinate and prioritize the total labeling effort.
11. Maintained that the cost of a labeling program
may negate any value the label would have as a
purchase variable.
12. Included several early cost estimates, stressing
the large cost of retooling production facilities.
13. Mentioned a consumer survey done by Better
Homes and Gardens in which "noise was ranked
seventh out often product priorities. Product
durability, less costly repairs, energy efficiency,
price, ease of cleaning and easier operation were
ranked ahead of noise."
14. Suggested EPA recommend the inclusion of sound
information hi the manufacturer's Use and Care
Guides. Such information would increase con-
sumer awareness of noise.
15. Indicated that their toll-free phone line had
received few calls about normal product
noise.
328
-------
Docket Number, Name,
Affiliation
77-8-590
Roderick T. Dwyer
Director of Government Relations
Outdoor Power Equipment
Institute (OPEI)
Comments
1. OPEI preferred a mandatory federal labeling
standard to a mandatory noise level standard
for lawn and garden equipment, though
they still have criticisms of the proposed program.
2. OPEI objected to use of "public attitudes" as
product selection criteria.
3. Criticized issuance of general provisions before
product-specific regulations, since both must
be considered in tandem.
4. Suggested that manufacturers be allowed to
test products at either EPA-designated test
facilities or their own facilities (if certified by
EPA). Otherwise there will be excessive dupli-
cation, since manufacturers will still perform
their own tests.
5. Suggested use of Section 8 of ANSI B71.1 Safety
Standard as test methodology for lawnmowers.
OPEI recommends that EPA either adopt an
existing, well-accepted standard or develop simple
test procedures acceptable on an international
basis.
6. Concerned that EPA's economic analyses will not
extend to the impact of the regulations on the
marketplace or, possibly to the costs of recordkeeping.
7. Emphasized the need for EPA to look at labeling
programs which may be in conflict with noise
labeling.
8. Strongly suggested use of the dBA for testing and
rating system.
9. Recommended that label or brochure contain
information about test methodology.
329
-------
Docket Number, Name,
Affiliation
Comments
77-8-590 (Continued)
10. Mentioned problems of labeling lawn and
garden tractors (which have various attachments
and variable speeds) and simulating realistic test
environment. Other test methods include SAE
XJ11-74 and SAE XJ11-75.
11. Raised questions about the feasibility of Com-
parative Acoustic Rating Range, though OPEI
thinks it is a good concept.
12. Commented on need for aggressive consumer
education campaign and suggested provision
of additional data on a hang-tag.
13. Criticized requirements pertaining to testing
exemptions for products not meant for general
sale.
14. Indicated that there should be a reasonable margin
for error in individual product compliance with
noise rating.
15. Criticized severely the requirement that label
verification be based on product samples. OPEI
noted that this procedure would force delays
in assembly and packaging of production units
until testing and label production was completed.
16. Suggested that the "cease to distribute" provision
be deleted. OPEI does not believe the Noise
Control Act gives such authority to the Adminis-
trator.
17. Recommended periodic internal evaluation of
the program as to its effectiveness in changing
consumer behavior.
330
-------
Docket Number, Name,
Affiliation
77-8-591
C. F. Newburg
Chairman, Government Affairs
Committee
National Association of Truck
Stop Operators
Comments
1. Expressed opposition to the labeling program,
which represents an infringement on freedom
of choice.
2. Complained that sections of the proposed regu-
lations are directed at retailers (e.g., truck stop
operators), who should not be responsible for
the acts of manufacturers. He mentioned that
retailers should not be responsible for labels
damaged in transit.
-592
Sidney J. Flock
1. Expressed opposition to labeling program as a
waste of tax dollars.
-593
Mrs. Susan Alperin
1. Expressed support for labeling program and
mentioned a lawnmower, hairblower, blender,
vacuum cleaner, dishwasher, and motorcycles as
major noise offenders.
-594
Mrs. C. L. Mercer
1. Complained about noise emitted by freezer
and fluorescent light fixture.
-595
Walter Brukwinski
1. Expressed support for labeling program as a
means of permitting greater consumer choice in
the marketplace.
-596
Ruth Moses
1. Expressed support for labeling program and noise
abatement efforts.
2. Commented on excessive noise level associated
with a washing machine, barking dogs, stereos,
and especially background music in public places.
331
-------
Docket Number, Name,
Affiliation
77-8-597
Elbert O. Schlotzhauer
2.
Comments
Though upset with the noise from aircraft,
traffic, and power tools, he asserted that the
labeling program is a waste of money because
most people would still purchase the cheaper,
but noisier product.
Commented on the problems associated with
a product requiring a new muffler.
-598
James W. Butler
1. Requested advice on what legal action he or
EPA could take against the manufacturer of a
tractor, which produces an excessive level
of noise for the operator.
-599
Constance M. Gibson
•600
Charles Painter
1. Expressed support for labeling of household
appliances and for direct noise abatement.
2. Gave vacuum cleaner and mixer as examples
of noisy products.
1. Expressed support for a requirement that manu-
facturers disclose information on product noise
levels.
•601
Mrs. Forrest M. Sullivan
1. Expressed support for the labeling program,
noting that the consumer would welcome the
opportunity to make a choice based on product
noise ratings.
•602
Mr. Evan A. Johnson
(Remarks made in phone conversation
with EPA's Noise Representative,
Region II, as described by the latter.)
1. Stated that manufacturers should make noise
measurement data available to the consumer..
He cited his bad experience with a refrigerator.
332
-------
Docket Number, Name,
Affiliation
77-8-603
H. Bruce Prillaman
Comments
1. Expressed opposition to the labeling program
because it will result in higher costs, will not be
effective in changing consumer preferences, and
is concerned with a problem that is compara-
tively unimportant.
-604
Margaret House
1. Expressed strong support for the labeling program.
2. Complained about the noise produced by a no-
frost refrigerator and the difficulty of comparing
the noise qualities of different models at the time
of purchase.
-605
Mars Gralia, D.Sc.
Suggested that EPA require labeling on all products
(but not specific noise level); that the measurement
be taken where the noise is greatest and after 20
percent of product's estimated life; and that EPA
consider both air- and structure-borne noise.
Expressed support for immediate implementation
of a labeling program.
-606
Miss S. Victoria Krusiewski
Expressed interest in having quieter household
appliances, especially vacuum cleaners, dish-
washers, and blenders.
-607
Martha Murdock
1. Complained about noise of television.
-608
Kathleen C. Harrigan
1. Stated that labels on appliances would have detri-
mental effects on the environment (due to use
of paper, ink, etc.) without having compensatory
benefit.
2. Suggested possibility of conveying information
on packaging, warranty card, or existing label.
333
-------
Docket Number, Name,
Affiliation
77-8-609
Mrs. Charles Ladenberger
Comments
1. Expressed support for product noise labeling.
2. Complained about noise emitted by refrigerator
and failure of store to have demonstrator models
in operation.
-610
Larry J. Eriksson
Vice-President, Research
Nelson Industries, Inc.
1. Submitted two reports that he authored:
a. Power or Pressure—A Discussion of Curren t
Alternatives in Exhaust System Acoustic
Evaluation;
b. Discussion of Proposed SAE Recommended
Practice SJ1207, Measurement Procedure for
Determination of Silencer Effectiveness in
Reducing Engine Intake or Exhaust Sound
Level.
2. First paper (a) discussed various procedures for
evaluation of exhaust system performance, con-
sidered both analytical and experimental techniques,
compared these approaches by using measurements
on actual engine noise, and rank-ordered them on b
basis of accuracy and cost.
a. Mr. Eriksson discussed different modes on
approaches to rating mufflers-i.e., using
the actual level of noise or the difference
between silenced and unsilenced levels.
b. Mr. Eriksson emphasized the importance of
determining whether sound pressure or sound
power offers a more meaningful measurement
He suggested the sound power level, if the lo-
cation of affected persons cannot be clearly
delineated.
c. Mr. Eriksson mentioned various tradeoffs
associated with the selection of a given tech-
nique and said that final muffler evaluation
usually demands an actual engine test
334
-------
Docket Number, Name,
Affiliation
Comments
77-8-610 (Continued)
3.
d. He ranked evaluation methods according to
their accuracy as follows: (1) actual engine;
(2) standard engine, (3) simulated source,
(4) analytical model, and (5) parameter evalu-
ation. The ranking based on costs, with the
least costly first, was: (1) parameter evaluation,
(2) simulated source, (3) analytical model,
(4) standard engine, and (5) actual engine.
Second paper (b) outlined various considerations
and limitations associated with the proposed SAE
recommended practice XJ1207. Two limitations
are the "lack of a direct correlation to other overall
pass-by tests" and the "lack of specification of the
subjective quality of the exhaust or intake noise."
-611
Roy W. Muth
Director of Technical Services
International Snowmobile Industry
Association
1. In this statement, Mr. Muth expanded on his
remarks given orally at the Washington hearings
and provided information in response to requests
from EPA panel members.
2. Acknowledged that at the present time ISIA does
not inform the consumer of the sound levels at
the operator's ear.
3. Stated that because of anti-trust constraints, ISIA
does not become involved in manufacturers'
warranty programs.
4. Mentioned other enclosures submitted into the
record which describe the field audit performed
by the independent test laboratory for the
purpose of assessing safety standards of snow-
mobiles. Manufacturers in the SSCC safety
standards program must test every model pro-
duced every year.
335
-------
Docket Number, Name,
Affiliation
Comments
77-8-611 (Continued)
Asserted that no information was available
on the costs of snowmobile sound level test.
Enclosed a paper explaining the snowmobile
industry's voluntary sound emission labeling
program and several problems affecting snow-
mobile labeling.
a. Noted that most 1977 snowmobiles have
a noise level falling within a 6 dBA margin
of error around the maximum emission
level of 78 dBA.
b. Expressed opposition to the range information.
c. Said that six of the seven manufacturers of
snowmobiles producing mere than 500 units
annually have agreed to participate in the
voluntary program.
d. Outlined the procedures followed by the
independent testing company responsible
for auditing and monitoring.
•612
A. F. Barber, Jr.
Town Office Supply
Hendersonville, North Carolina
1. Complained about noise produced by the business
and household appliances which his company
handles.
2. Expressed support for whatever action is needed
to correct these conditions.
-613
Joyce Pacer -
1. Expressed support for labeling program.
2. Complained about noise emitted by vacuum
cleaners, lawnmowers, trucks, and mixers.
3. Commented on health hazards presented by
noise-makers in the work place.
336
-------
Docket Number, Name,
Affiliation
Comments
77-8-614
Pete Sirois
Expressed opposition to labeling program, and
in particular to the labeling of shop tools which
he uses in his occupation. He complained that
the program would raise the costs of these
tools.
-615
Patricia H. Robinson
Mentioned various noise complaints: (1) military
aircraft from Subic Bay Naval Base; (2) construction
noise; (3) noise in military exchanges; and
(4) motorcycle and automobile noise.
Requested information about noise regulations
for exchanges, about controls on cars and motor-
cycles, and regulations pertaining to noise at
Subic Bay.
-616
Illegible
1. Complained about noise of refrigerator.
-617
Peggy W. Norris
1. Expressed support for the labeling program.
2. Mentioned that she would use the information
to "comparison shop."
3. Suggested that some way was needed to describe
the high-pitched noise made by televisions.
-618
Ms. Areta Powell
1. Complained about noise emitted by frost-free
refrigerator plus the fact that she was not
informed of the product's annoying noise
emission properties by the salesman.
-619
Edith Mitchell
1. Expressed support for the labeling program,
since there is no way to test products before they
are purchased.
337
-------
Docket Number, Name,
Affiliation
77-8-619 (Continued)
-620
Mrs. J. C. Brown
Comments
2. Suggested including on the label the decibel
level as well as certain frequencies such as the
starting and stopping frequency in the case of
refrigerators.
3. Mentioned her noisy refrigerator.
1. Complained about the noise of her washer
and refrigerator and her central air
conditioner.
-621
E. Bruce Butler
Attorney
Argued that the proposed standard creates
unnecessary confusion and difficult procedural
issues when implemented for a particular product,
since it neither applies to a specific product nor
is necessarily appropriate to all products.
Further argued that the noise regulations are
useless because each product must be con-
sidered individually in terms of its noise charac-
teristics, testing procedures and labeling suscepti-
bility.
Noted labeling difficulties in the instance where
an engine is manufactured separately from the
rest of a product.
Noted the absence of generally accepted noise
standards for some products.
Suggested the inclusion of noise information on
hang-tags or in the owner's manual in those
instances where many labels are already on a
product.
Urged the use of cost-benefit analysis, weighing
the cost of testing and labeling a product against
the consumer's desire for noise information.
Stressed the need to examine individual products
according to the nature of the product, the
existing testing procedures, and the existing
labeling requirement.
338
-------
Docket Number, Name,
Affiliation
Comments
77-8-622
E. G. Ratering, Director
Vehicular Noise Control
General Motors Corporation
1. Held that EPA is exceeding its authority in the
proposed Noise Labeling Standards and wanted its
general comments considered in future product-
specific rule-making action.
2. Noted that specific products must be chosen
according to the designated criterion before
the noise labeling requirements are established.
3. Stated that labeling requirements cannot be
established for the purpose of consumer
information unless limited to products capable
of adversely affecting public health or welfare.
4, Suggested that labeling will increase cost, which
will ultimately be absorbed by the consumer.
Made specific suggestions to keep costs down.
5. Expressed concern about labels required by other
programs.
6. Held that Sec. 211.1.9, inspection and monitoring,
and Sec. 211.1.1 l(a)(l), testing, exceed EPA's
statutory authority and violate constitutional
principles.
7. Made specific suggestions for clarification of
Sec. 211.1.10-3(c) on export exemptions.
8. Indicated that Sec. 211.1.9(f)( 1) and Sec.
211.1.1 l(b)(2) which concern the EPA's
authority to issue "cease distribution" orders
are in conflict with Sec. 1 l(d)(l) of the
original Act.
9. Insisted that products be selected on the basis
of actual sound level data and not according to
annoyance levels as expressed in comments for
the public docket.
10. Noted the difficulties involved in selecting a label
format prior to selection of a product and selection
of the significant information for that product.
339
-------
Docket Number, Name,
Affiliation
Comments
77-8-622 (Continued)
11. Made specific recommendations for the label
regarding format color, contrast, and type.
12. Referred to specific problems the consumer might
have in understanding the noise range on the label,
arguing that information is needed to give
meaning to the range.
-623
Frank £. Mclaughlin
Acting Director
Office of Consumer Affairs
DHEW
2.
3.
4.
5.
6.
Expressed support for the noise labeling and
regulatory program with qualifications.
Suggested use of a pilot program to help determine
the degree to which price is affected by the regula-
tions, allowing the costs and benefits to be
evaluated.
Criticized the model label in terms of two compo-
nents: the acoustic rating descriptor and the
comparative acoustic rating information.
Stressed the necessity for additional acoustic
information on the label to facilitate comparisons,
such as a color coded system.
Suggested including not only the range of informa-
tion, but the average value for products of that type.
Urged the development of a consumer information
program consisting of radio and television spots,
magazine feature articles, and brochures so that
explanatory information is widely available.
-624
Igor Kamlukin
Vice President
Environmental Product Engineering
Briggs and Stratton Corporation
Expressed support for a voluntary labeling program,
which would establish consumer interest, allow
operation of the market mechanism with a minimum
of disruption and keep costs and government involve-
ment to a minimum.
Argued that manufacturers would report noise
ratings as accurately as other product information.
340
-------
Docket Number, Name,
Affiliation
77-8-624 (Continued)
Comments
3. Urged EPA to establish and standardize a method
of measuring, rating and reporting the noise of a
product.
4. Suggested that noise reduction should be achieved
with minimal government involvement and minimal
cost to the consumer.
-625
A. K. Forbes
Pilemaster Manager
Terresearch Limited
Foundation Engineers and Contractors
Brought to EPA's attention their Pilemaster
Machine which, according to the enclosed article,
has only a 62 dBA noise level.
Included several articles on the machine as well as
a series of dBA measurements under construction
and nonconstruction conditions.
-626
George Mosher
President
National Business Furniture
1. Expressed support for the EPA's noise control
program.
2. Argued that consumers are willing to pay for
noise control.
3. Stated that quiet can be related to a positive per-
ception of a product, as it has been in cars.
4. Complained about car mufflers, vacuum cleaners
and lawnmowers as sources of noise.
-627
Gerald A. Stangl, Ph.D.
Design Engineer
The Charles Machine Works, Inc.
1. Suggested that EPA consider labeling in lieu of
regulation where possible, allowing the market
to operate to reduce noise.
2. Urged the development and use of a common de-
scriptor and rating scheme.
3. Suggested the use of a multi-sided average of sound
pressure rating at a particular distance and operating
mode for mobile outdoor equipment.
341
-------
Docket Number, Name,
Affiliation
77-8-627 (Continued)
Comments
4. Indicated that EPA's access to manufacturers'
facilities should be restricted to those areas
relevant to the specific investigation.
5. Urged that the areas to be investigated by EPA be
identified in writing prior to the specified time
period.
6. Recommended against specification of character style.
7. Emphasized that the Noise Control Act of 1972 does
not give EPA the authority to require a product
recall even if a product does not comply with the
standard.
-628
Miss B. L. Duncan
1. Stated that amplified record players, guitars and
"rock" music create more noise than household
appliances.
2. Stated the city officials do nothing about this problem.
-629
Guenther Baumgart
President
Association of Home Appliance
Manufacturers
1. Indicated that the noise labeling of home appliances
is inappropriate and unnecessary, as shown by the
data reported in the Title IV report.
2. Suggested that the EPA use the Title IV rcport-
"Report to the President and Congress on Noise*'
(Doc. No. 92-63,92nd Congress, 2nd Session,
Feb., 1972)-to assist in product selection.
3. Doubted if Section 8 gave EPA the authority to
require labeling on a product which might consti-
tute a hazard to hearing only when considered
"in the context of cumulative exposure"-a vague
phase.
4. Included Table 2-19. of the above-mentioned report,
which divides home appliances into categories
according to the effects of their noise levels and
the average conditions of exposure.
342
-------
Docket Number, Name,
Affiliation
Comments
77-8-629 (Continued)
5. Indicated that home appliances are different than
sources of community noise because they are
operated at the discretion of family members and
are products that must meet consumer acceptance.
6. Observed that only 3 percent of the complaints
received by the Major Appliance Consumer Action
Panel in 1976 concerned noise.
7. Maintained that noise labeling may detract from
more important labels involving safety precautions
and energy.
8. Emphasized the importance of a study of market
place effects, since the labeling program could have
a significant impact on certain manufacturers.
These costs include the tax dollars spent on
program administration.
9. Cautioned against the use of comparative acoustic
rating information, because of problems with up-
dating data and because there is the problem of
different product capacities within the same product
class.
10. AHAM suggested EPA publish a detailed document
specifying what information was used in deciding
upon products for labeling and describing the
rationale behind the final decision.
11. Held that EPA has not shown that noise
from household appliances adversely affects the
public health or welfare-a necessary determination
before labeling action is taken.
12. Suggested using the brand name reseller's name
on the label (Sec. 211.1.4(d)).
13. Stressed the need for interagency coordination of
labeling programs. (211.1.5).
343
-------
Docket Number, Name,
Affiliation
Comments
77-8-629 (Continued)
-630
E. J. Halter
Chairman
Industrial Silencer Manufacturers
Association (ISMA)
14. Suggested a longer period of notice before EPA
could inspect factory facilities, because of likely
disruptions (Sec. 211.1.9(b), (e)).
15. Argued that only the finished product should be
photographed and inspected by EPA to determine
compliance (Sec. 211.1.9(c)( 1 )(iv)).
16. Argued that the manufacturers should not be liable
"for the expense of investigation" by EPA of test
methods employed by the facility (Sec. 211.1.9(c)(2)).
17. Expressed concern about EPA's authority to prescribe
where a manufacturing plant is located (211.1.9(3)).
i
18. Objected to the exemption of products used for
market promotion and demonstration, unless pro-
visions are developed which insure truth in adver-
tising (Sec. 211.1 10-1(0).
19. Stated that the Administrator should be required
to give the manufacturer sufficient advance.
notice of the decision to require that a product be
submitted to EPA or that it be tested at the manu-
facturer's facility. (Sec. 211.1.11 (a)( 1), (2))
20. Suggested EPA should give advance warning of
products chosen for labeling and should utilize
measurement methods already available. Sufficient
leadtimes should be granted for manufacturer's
compliance with the regulation.
1. Described ISMA's efforts in developing industrial
silencers test procedures.
2. Enclosed a publicity release describing ISMA
and a copy of a journal article on their recipro-
cating engine silencer test procedures.
344
-------
Docket Number, Name,
Affiliation
Comments
77-8-631
William L. Krentz
Director, Public Affairs
Owens-Corning Fiberglass Corporation
1. Owens Corning commented with respect to its
glass fiber sound control materials that it has
undertaken extensive testing of the sound abate-
ment properties of these materials.
2. Owens Corning suggested that private sector
laboratories be accredited by EPA to carry out
needed testing under the program.
3. Cited its participation in a voluntary testing facility
accreditation program offered by the Department
of Commerce through the National Bureau of
Standards.
4. Urged EPA to focus on noise-labeling of finished
systems rather than individual materials.
5. Noted that a single noise descriptor is meaningless
without having information on the mounting
method and construction technique of the test
also on the label.
6. Suggested close consultation by EPA with the
National Bureau of Standards regarding the devel-
opment of rating schemes and test methodologies.
7. Reiterated its desire for EPA to consider the total
system including installation technique, in noise-
labeling its products.
8. Endorsed EPA's citation of ANSI standards
and commended ASTM as a source for measurement
methodologies.
9. Noted the complexity of the available noise reduc-
tion descriptors, contended that the average pur-
chaser could not judge the significance pf ratings
such as the noise reduction coefficient, the sound
transmission class, or the noise isolation class.
345
-------
Docket Number, Name,
Affiliation
Comments
77-8-632
Mr. and Mrs. D. W. Pfeifer
1. Objected to motorcycle noise and increased
volume in TV commercials.
-633
W. C. Painter, Manager
Product Safety and Certification
Rockwell International Power Tool
Division
1. Expressed the opinion that product noise reduction
could be accomplished only at the loss of other
valued performance parameters, i.e., energy
efficiency, cost, weight, productivity, international
marketability, rendering the focus on noise counter-
productive and wasteful.
2. Considered the noise range deficient because of
difficulties in policing and in taking account of new
products.
3. Expressed doubt about the legality of the proposed
EPA entry for inspection of facilities and of the
requirement for shipping products to a central test
facility.
4. Expressed opposition to the program as misdirected
and unjustifiable in light of its likely effect on other
characteristics of products.
-634
Caroline Jenclowski (?)
1. Expressed support for the program, desiring
reliable information on the noise characteristics
of products she buys.
-635
Miss Marjorie L. Coates
I. Expressed concern over the noise from electric
table fans, window air conditioners, stove fans
and forced air gas furnaces.
2. Wanted information on the noise levels and other
properties of portable non-window unit air
conditioners.
346
-------
Docket Number, Name,
Affiliation
Comments
77-8-636
E. Linn
1. Expressed support for the program as an excellent
idea long overdue, citing noisy vacuum cleaners
and air conditioners.
-637
Anthony O. Cortese, Sc.D.
Director, Division of Air and Hazardous
Materials
Commonwealth of Massachusetts
Expressed support for noise labeling because it would
provide needed data for the state's noise regulatory
program. It would form a basis for comparison, and
it would provide an incentive for production of
quieter equipment.
Suggested the noise labeling of transformers, air
compressors, cooling towers, mufflers, domestic
and commercial air conditioners.
Expressed the opinion that the states should retain
the jurisdiction over regulation of noise-emitting
equipment while the Federal government should
handle labeling and emission standards.
-638
Mrs. Robert G. Rinehart
1. Discussed difficulties in shopping for a refrigerator
on the basis of noise levels and duration of motor
operation resulting in the purchase of a unit which
ran 80 percent of the time.
2. Suggested that a label indicating running time of a
refrigerator would be more informative than one in
decibels or kilowatts.
-639
R. H. Alexander
Suggested that EPA's efforts be directed at abate-
ment of the amplified public noise of modern music
instead of labeling appliances.
Expressed opposition to the program, which will
increase product costs.
347
-------
Docket Number, Name,
Affiliation
Comments
77-8-640
Joan L. Mills
Called for noise abatement or labeling of motors,
including those in dishwashers, clothes washers,
dryers and inside and outside air conditioners.
-641
Michael G. Garland, Manager
Technical Services Department
The Celotex Corporation
Celotex, a manufacturer of acoustic celing products,
expressed opposition to EPA labeling of acoustic
tile because: (a) the acoustic tile marketed today
are in compliance with the 1972 Noice Control
Act in providing noise rating information (NRC)
as shown in attached labels, (b) Any new
descriptor would be confusing in the light of accepted
usage of the NRC and STC, and a single number
descriptor would be misleading.
-642
Everett A. Plaster
Expressed concern over noise from his refri-
gerator and dishwasher.
-643
W. G. Schwieder
Ford Motor Company
Included text of Washington Hearing statement
and corrected transcript.
In supplementing previous comments, included
its initial and reply briefs for Ford Motor Company
v. Environmental Protection Agency, docket No.
76-1582, in reference to the inspection and monitoring
provisions.
Suggested a revision to Sec. 211.1.10-1, to allow
an automatic one-year exemption in the event the
Administrator fails to respond within fifteen working
days.
Suggested that Sec. 211.1.10-3, paragraph c be revised
to eliminate automatic retroactive rescission for
an export exemption breach.
348
-------
Docket Number, Name,
Affiliation
Comments
77-8-643 (Continued)
5. Suggested that Sec. 211.1.11 be revised to
reasonably limit the Administrator's discretion
to require manufacturers' to provide products
for testing, in keeping with a compromise
reached in the truck litigation; that the manu-
facturer be allowed to observe EPA testing, that
paragraph b allow the manufacturer to contest
an adverse EPA determination on its test facilities,
and that a "cease" order be based only on a finding
of necessity for protection of the public health and
welfare.
6. Indicated that Section 8 of the Noise Control
Act applies only to new products, based on legal
interpretation of the Act's wording and analysis
of its legislative history.
-644
John M. Cowart
1. Commented on excessive noise produced by
motorcycles, powerboats and furnace fans.
2. * Expressed support for noise abatement.
-645
Debro Saltzman
1. Ms. Saltzman, a teacher of the deaf, stated that'
the noise of household appliances is both
annoying and damaging to the ear.
2. She asked EPA to cite the negative effects of
noise from vacuum cleaners, dishwashers, and
blenders in the standards or regulations promulgated.
•646
Peggy Jenkin
1. Expressed interest in noise reduction in the
home and commented on the loud noise emitted
by a grinder/salad maker and a vacuum cleaner.
349
-------
Docket Number, Name,
Affiliation
Comments
77-8-647
Michael W. Blanck
Manager, Acoustical Division
Kodaras Acoustical Laboratories
Division of Electrical Testing
Laboratories, Inc.
1. While praising EPA's effort, ETL believes such
a program is best undertaken in the private
sector. Mr. Blanck referred to ARI's voluntary pro-
gram as a model for EPA to follow.
2. Asked: "Who will make the decision as to the
acceptability of a laboratory and what criterion
will be used in determining this?"
3. Recommended National Voluntary Laboratory
Accreditation Program (Federal Register, Vol. 41,
pp. 8163-68, 2/25/76) and ASTM Standard E548
Recommended Practice for Generic Criteria as
methods of evaluating testing agencies.
4. Suggested use of consensus standards for testing
purposes (i.e. ANSI and ASTM). Specific
product regulations should reference standards
but not cite them as federal standards, so that
they can be kept current
5. Expressed concern about labeling a product
whose acoustical performance is dependent
upon its installation and can vary significantly,
i.e., gypsum board.
-648
Fred Tabacchi
President and Chief Operating Officer
The Hoover Company
North Canton, Ohio
1. The Hoover Company criticized EPA's publishing
a list of appliances considered for labeling,
when it has not yet been established that they
emit noise capable of adversely affecting the
public health and welfare.
2. The Hoover Company felt that vacuum cleaners
and clothes washers cannot be shown to adversely
affect public health and welfare. In sum, they
believe "the EPA is vastly exceeding its authority
to require noise labeling on products that emit
noise which is merely occasionally annoying."
350
-------
Docket Number, Name,
Affiliation
77-8-648 (Continued)
Comments
Criticized the higher costs resulting from noise
labeling and the proliferation of labels in general.
Mentioned Hoover and ASTM surveys which demon-
strate that noise receives very little consideration
by prospective purchasers of vacuum cleaners,
who are more concerned with durability, weight,
cleaning ability, etc.
-649
John L. Phillips
Expressed support for the labeling program, which
he regards as a weak, but politically feasible,
alternative to mandatory emission limits.
-650
Madeline Bolbol
1. Complained about noise from kitchen range fan.
•651
George P. Lamb, Jr.
General Counsel
Vacuum Cleaner Manufacturers
Association (VCMA)
1. VCMA expressed opposition to labeling vacuum
cleaners.
2. VCMA felt it is extremely difficult to devise
a rational formula for selection of products for
labeling. Mr. Lamb expressed concern that the noise
made by vacuum cleaners, though extremely short
in duration, might be viewed in isolation and deemed
a justification for labeling in itself.
3. VCMA does not feel that improper labeling of noise
characteristics represents the kind of danger
justifying inspections. Hie Association believes
that the inspection and enforcement provisions-
taken as a whole-are much "too harsh."
4. Mr. Lamb indicated that the determination of whether
or not a product "adversely affects the public health
or welfare" is a decision which must be made
through an orderly rulemaking proceeding. (Reference
is made to the Administrative Procedure Act, 42 U.S.C.
Section 4905(c)(2) and 4907(b).) He asserted that the
negative publicity given to vacuum cleaners in the
public hearings could prejudice the outcome of these
proceedings.
351
-------
Docket Number, Name,
Affiliation
Comments
77-8-652
Ralph W. Van Demark
Executive Director
Automotive Exhaust Systems
Manufacturers Committee
6.
Speaking on behalf of an independent trade
association of automotive exhaust system manu-
facturers, he commented on some of the impli-
cations of the proposed general provisions for re-
placement exhaust systems.
Indicated that it was not feasible to develop
a single number or rating which could guide the
consumer in a meaningful manner, since there
are many complex variables relating to replacement
exhaust systems.
The major problem seemed to be that replacement
exhaust systems are designed to fit a number of
makes and models, so that nationwide distribution
is possible. The process of compromising physical
dimensions is termed "consolidation." He claimed
that a single noise rating was impossible since the
noise level resulting from a replacement system
would vary depending on which make and model
vehicle it was installed. A single number indicative
of the noise reduction capability of the muffler
would not surmount the problem of confusing
the consumer, because a muffler would still be
noisier on one vehicle than on another due to make
and model differences.
Finally, he maintained that muffler labeling could
not proceed until a test procedure for deter-
mining a noise reduction rating was developed and
agreed upon.
Expressed support, however, for regulation of
excessive noise.
Submitted copy -of AESMCs Recommended Sound
Level Standard and Measurement Procedure for
Vehicle Exhaust Noise.
352
-------
Docket Number, Name,
Affiliation
Comments
77-8-653
Ms. Patricia H. Robinson
-654
Mrs. Earl 8. Hampton
1. Expressed support for labeling program and
general noise abatement.
1. Expressed support for labeling program, or any
other means of identifying, measuring, or
"quieting" various appliances.
2. Complained about a noisy refrigerator.
-655
Theodore J. Fister
1. Expressed opposition to labeling program.
•656
Lucy D. Strickland
1. Commented on the excessive noise emitted by a
refrigerator.
-657.
Gene Boyce
1. Complained about noise produced by a refrigerator.
-658
Gordon Tapper
1. Listed noisy products: heavy trucks, tires, motor-
cycles, dune buggies, lawnmowers, other garden
equipment, refrigerators, washing machines, auto-
mobiles, and buses.
-659
Mrs. Gerald N. Plotkin
1. Expressed support for the labeling program, which
will permit comparison shopping.
2. Commented on excessive noise produced by a
vacuum cleaner, electric drills, and blenders.
3. Stated that noise was the first factor he considered
when shopping for a vacuum cleaner.
353
-------
Docket Number, Name,
Affiliation
Comments
77-8-660
Richard H. Lincoln
Manager, Environmental Engineering
Outboard Marine Corporation
Expressed opposition to labeling program, because
consumers will not use the information on the
label but will continue to purchase items on the
basis of brand names.
Criticized promulgation of general labeling pro-
visions before product-specific regulations.
When the need to label has been established, then
regulations should be developed which deal only
with that product—and which are not preceded
by more general provisions.
If EPA decides to label products, even though
there is no need to do so, only the end product
should be labeled and not the components.
Emphasized the importance of an understandable
rating scheme but criticized dBA, Leq, and a
"1 to 5" scale (which would not encourage noise
reduction for products rated with a "1").
Felt that EPA was not giving enough atten-
tion to costs, which he calculated to be about
$11,000 per year, and that his marketing research
demonstrated a lack of public concern about noise.
-661
Steven K. Allsbruck
1. Expressed support for labeling program but hoped
it would be more accurate and understandable
than EPA's gas mileage ratings.
-662
Vico E. Henriques
Computer and Business Equipment
Manufacturers Association
1. Recommended the A-weighted sound power level,
re 1 picowatt, of the product as the best acoustic
rating descriptor.
2. Emphasized the importance of using and/or de-
veloping standardized test procedures.
3. Opposed comparative acoustic ratings because in
some cases products within a class do not have
identical functional characteristics and because of
the problem of updating the range data.
354
-------
Docket Number, Name,
Affiliation
Comments
77-8-662 (Continued)
4. Suggested the need for other information on the
label such as the test procedures used and the
installation conditions conducive to less noise.
Since the label will net-contain much additional
information, he suggested making this data part
of the public record and having a reference to it
on the label.
-663
Donna McCord Dickman, Ph.D.
Program Manager
Areawide Environmental Noise Program
Health and Environmental Protection
Metropolitan Washington Council of
Governments
1. In response to a request for information from
EPA officials at the Washington Hearing, she
reported that the Noise Technical Committee recom-
mended the following products for labeling: small
appliances used around the face, powered gardening
tools, home workshop tools, and kitchen appliances.
2. Recommended a published list of product noise
ratings as a means of effectively publicizing the
program. The lists would be developed for each
product labeled and would also contain the names
of manufacturers.
•664
Mrs. R. H. Pfluger
1. Expressed support for the labeling program.
2. Suggested requiring demonstrations of products in
the store, so that consumers can hear the appliances
in operation.
3. Complained about the noise produced by a dish-
washer.
-665
Arthur L. Herold
and James L. Wilson
Law Offices: Webster and Chamberlain
Counsel to the Power Tool Institute
Duplicate of 77-8-565
355
-------
Docket Number, Name,
Affiliation
Comments
77-8-666
Dr. G. L. Cluff
Director
Tri-Utility Hearing Conservation
Program
(Insert into 77-5)
I. Expressed support for labeling hearing protectors.
2. Suggested that the "R" value associated with a
particular hearing protector be used as the "single
number" attenuation rating for that product.
3. Based upon tests he has conducted with hearing
protectors (data attached), he recommended that
a negative per octave slope of about -6 to -12 dB be
adopted as the standard slope for the determination
of the "R" value. The slope of the noise spectra
significantly affects the "R" value, and the above
slope was chosen because it generally represents the
worst performance of a personal hearing protector.
-667
Dal D. Nesbitt
Mechanical Engineer
-668
Bernard Balmer
1. Expressed strong support for the program,
wishing it were stronger and had come sooner.
2. Noted difficulty as a mechanical engineer trying
to design quieter products and being ordered by
management not to invest funds on noise.
3. Noted problem he faced as a consumer, despite his
experience in the field, in comparative shopping
for quiet products.
1. Expressed support for the program within "reason."
2. Suggested labeling appliances and "noisy machines,"
including those used in industry.
-669
Mrs. E. Dale Petite
1. Expressed support for appliance labeling or
noise control, citing difficulties in purchasing a
quiet refrigerator.,
356
-------
Docket Number, Name,
Affiliation
Comments
77-8-670
Eileene M. Young
1. Expressed concern over noise from a refri-
gerator, which runs too long with an irritating
"hum."
-671
David A. Kloepper
Service Engineering Manager
HILTI Fastening Systems, Inc.
1. HILTI recommended that the "comparative
acoustic rating" be deleted from the label because:
(a) categories of products cannot be suitably desig-
nated; (b) it will cause some consumers to ignore
more important factors; (c) updating will pose
difficulties for EPA; (d) the individual noise rating
will suffice for consumer choice.
2. Suggested use of the Noise Power Emission Level
in bels under the ANSI Standard SI.23-1976 for
the descriptor.
3. Recommended that either manufacturer or distributor
be identified on the label to ensure fairness.
4. Expressed concern over usurpation of power by
EPA in the enforcement provisions, including on-
site inspection of facilities and production and
testing requirements.
5. Expressed the need for clarifying the circumstances
for granting a testing exemption under 211.1.10-1 and
suggested an automatic exemption for products so
qualified.
6. Objected to the concept of Section 8 as an improper
function of a "government of free men" and because
noise is of little importance to buyers.
7. Formally requested EPA to (a) modify the Pro-
posed Rules as suggested and (b) submit the objec-
tions to the concept of the Noise Control Act to
Congress.
357
-------
Docket Number, Name,
Affiliation
Comments
77-8-672
G. L. Teny
Vice President
Public Responsibility and Consumer
Affairs
Chrysler Corporation
1. Expressed the opinion that the Proposed Rules
are a mockery of the intentions of Congress through
a broad expansion of the powers to be exercised
in most areas.
2. Strongly objected to the program as "maximum
Federal intrusion" and an over-broad interpretation
of the Section 8 mandate.
3. Expressed the opinion that labeling could not
apply to products designated under Sections 5
and 6, since these have been rendered safe by
the mandatory standards.
4. Expressed the opinion that "prospective user"
should be used interchangeably with "ultimate pur-
chaser," limiting the lifetime of the noise label to
the time-of-sale.
5. Stated that EPA lacked the authority to require
the comparative noise information, contending
that it would be misleading, outdated and
inaccurate.
6. Indicated that EPA lacked the authority for the
proposed inspection, entry and enforcement pro-
visions, citing the truck noise litigation arguments,
and wanted minimal EPA involvement under
Section 8.
-673
Marcus D. Maatalia
1. Expressed concern over the excessively high
noise level of two products, an electric drill
and a dishwasher.
358
-------
Docket Number, Name,
Affiliation
Comments
77-8-674
Mrs. Pauline Wanker
Expressed concern over noisy kitchen appliances,
citing a dishwasher as especially noisy and
disruptive of conversation and thought.
-675
Frank J. [illegible]
1. Expressed concern over a noisy dishwasher
which interferes with conversation.
-676
Allan M. and Joyce G. Krell
1. Urged EPA to do anything possible to reduce
the noise levels of mechanical devices.
-677
William G. Haley
1. Expressed support for mandatory noise labeling
of household appliances, but objected to Federal
mandatory noise standards.
2. Noted that labeling could lead to consumer compari-
son and reduced noise levels through competition,
endorsing dish- and clothes-washers for the program.
3. Pointed out the complexity of noise ratings,suggesting
use of "perceived noise decibels" rather than just
"decibel" units.
-678
Alice G. Heinz
1. Cited a noisy no-frost refrigerator and a
noisy tank vacuum cleaner, both of which
are disturbing.
-679
Illegible
1. Expressed support for the program as allowing
consumer knowledge.
2. Expressed concern over motorcycle noise and
called for its abatement.
359
-------
Docket Number, Name,
Affiliation
Comments
77-8-680
C. Rodger Blyth
Technical Assistant
Research and Development
The Maytag Company
1. Mr. Blyth (who attended the Cedar Rapids hearing)
noted the noise reduction in the development of
Maytag dishwashers over time.
2. Explained Maytags efforts at lowering dishwasher
noise, but noted the company will not participate
in a voluntary labeling program run by AHAM.
3. Expressed the opinion that noise labels win not
improve consumer satisfaction since.it will provide
a distorted picture of performance characteristics.
4. Noted that dishwasher noise does not consitute a
health hazard but rather an annoyance.
5. Expressed May tag's opposition to noise-labeling
of dishwasher—which is viewed as misleading to
consumers concerned with overall performance.
-681
Unsigned
1. Expressed opposition to the program as raising
business costs, and suggested EPA turn to other
matters.
-682
Mrs. Joseph J. Doyle
1. Expressed concern over the noise from a grill
range fan.
-683
Mrs. Joan Mundel
1. Expressed support for the program as a first step
in reducing noise levels, and wanted to know the
resolution of the question of noise labeling.
-684
Mrs. Marlin Knight
1. Expressed support for the program, citing a
refrigerator and a dishwasher as particularly
noisy.
360
-------
Docket Number, Name,
Affiliation
Comments
77-8-685
Mr. and Mrs. Raymond Peeters,
Mr. Christopher Peeters, Miss Pamela
Peeters, and Mrs. Andrea Peeters Hunt
1. Expressed support for the program, citing noisy
refrigerators and freezers and the possibility of
hearing impairment.
-686
Helen (Mrs. Thomas) Moon
Expressed concern over the noise from a
refrigerator.
-687L
Mrs. B. G. Perrin
Complained about noise from
refrigerators.
-688L
Mrs. Geovanna Gesalti
-689L
Charles M. Fisher
-690L
Mrs. James C. Warren
1. Complained about noise from his refrigerator,
dishwasher, garbage disposal and heat pump,
as well as motorcycles.
2. Expressed support for a noise abatement program.
3. Suggested manufacturers be required to advertise
decibel levels emitted during product operation.
1. Complained about noise from his refrigerator, dish-
washer, garbage disposal and heat pump,
as well as motorcycles.
2. Expressed support for a noise abatement program.
3. Suggested manufacturers be required to advertise deci-
bel levels emitted during product operation.
1. Expressed support for noise labeling program.
-691L
Eva Shun Kwiler
1. Complained that kitchen appliances are too loud.
-692L
John S. Autry
Vice President and Director of
Public Affairs
Johns-Manville Corporation
1. Expressed approval for the intent of the EPA
program, but suggested that EPA utilize the
expertise provided by corporations such as theirs
and by the National Bureau of Standards.
361
-------
Docket Number, Name,
Affiliation
77-8-692L (Continued)
Comments
Recommended that industry laboratory facilities
be used for testing purposes, that finished systems
rather than individual components be considered in
determining labeling requirements, and that a rating
system utilizing more than one indicator be used.
Suggested that EPA work closely with the
industry in designing enforcement rules.
-693L
Robert Kauffman
1. Expressed support for noise labeling program.
2. Complained about a rotary-action airless paint
gun.
-694L
William E. Leuchtenburg
Professor of History
Columbia University
1. Complained about noise created by leaf blowers
and leaf machines.
-695L
Mrs. Edward L. Weimer
1. Complained about noise and television interference
from her refrigerator.
-696L
R. Wood
1. Complained of noise created by freezer.
-697L
George M. Leanan, M.D.
-698L
June Wooder
Expressed opposition to the labeling program,
specifically as applied to electrical appliances,
because of excessive costs.
Complained about noise from electric fans and
air conditioners.
-699L
Robert Hume
Complained about noise made by his freezer
which can only be reduced at considerable
expense.
Expressed support for regulation of noisy
appliances.
362
-------
Docket Number, Name,
Affiliation
77-8-700L
Benedict G. Breitung
-701L
Ira M. Edwards
Biology Storekeeper
Southern Oregon College
Comments
1. Complained of noise created by gas engine
lawn mowers.
1. Complained about noise and inefficiency of an
incubator.
-702L
Phyllis I. Lundquist
1. Complained of noise made by her refrigerator.
-703L
Alinda Heath
1. Complained about noise made by her dishwasher
and refrigerator
2. Supported the noise labeling program.
-704L
Marcella J. Nickerson
1. Complained of noise made by her refrigerator,
dishwasher, washing machine, dryer as well as
other small appliances.
2. Requested that some action be taken to reduce
noise levels of appliances.
-705L
Ross Buhrdorf
1. Complained of noise created by lawnmowers,
dishwashers and air conditioners.
-706L
Robert Schneider
1. Expressed support for the noise labeling program.
2. Recommended that labels compare noise levels
with those of commonly used "gadgets" as well
as reporting decibel levels.
363
-------
Docket Number, Name,
Affiliation
Comments
77-8-707L
John P. Reardon
Director of Government Affairs
Air Conditioning and Refrigeration
Institute
1. Submitted a Supplementary Statement on
proposed noise labeling-general provisions.
2. Expressed the opinion of ARI that with due
consideration EPA need not identify unitary
air-conditioners under either Section 5 or 8
of the noise control act.
3. ARI believed that it should be considered as a
pioneer in the development of industry certifi-
cation programs, obviating the need for EPA
involvement.
4. The ARI Sound Certification Program rating
procedure is based upon an effective auditing by
ARI and certification by manufacturers including
a technically sound numbering system determined
through a methodology acceptable to EPA.
5. The ARI Sound Rating Number (SRN) descriptor
is based upon a numerical single number rating
classification scheme which serves as an accurate
means to differentiate the noise emitted from
similar pieces of equipment.
6. The Sound Committee was concerned with subjec-
tive noise levels so it developed a means of including
a penalty for equipment that may have a pure
tone at one or more one-third octave band levels.
7. In ARI's opinion, the air-conditioning and refrigera-
tion industry has an effective viable certification
program that could be readily approved by EPA.
8. Stated that, with additional public information by
EPA and the industry, the current certification
program voluntarily operated by the industry could
become a viable tool for use by the individual con-
sumer in comparative shopping and by noise enforce-
ment officers in states and other municipalities (as
has been done in Cerritos, California) that have noise
ordinances.
364
-------
Docket Number, Name,
Affiliation
Comments
77-8-707L (Continued)
9. Strongly suggested that the EPA give thorough
consideration to using a variety of noise descriptors
that may already be in effect for various products.
10. Expressed the opinion of ARI that a limited variety
of descriptors could be meaningful to the consumer
because the consumer is sufficiently educated in
his own area of concern to know the differences in
the various descriptors.
-708L
David Owens
1. Suggested checking the frequency as well as the
dB level on the Sunbeam Challenger vacuum cleaner.
-709L
Sears, Roebuck and Co.
1. Sears, Roebuck and Co. expressed the opinion that
the noise labeling program should be used to provide
the consumer with noise level data only on those
products which could be detrimental to his or her
health or welfare.
2, Felt that "labeling appliances which do not produce
noise levels which are detrimental would add undue
burden to the manufacturer, inevitably increase the
cost of the product to the consumer, create a negative
image of the product to the consumer and yet provide
no additional valuable information."
3. Stated its belief that the "intent of Section 8 of
the Noise Control Act of 1972 [should] be complied
with by objectively stating the product's noise level
or its effectiveness in reducing noise as its 'sound
rating' or 'sound reduction rating,'" because of the
negative bias in the term "noise."
4. Expressed concern over possible consumer confusion
about the logarithmic dBA scale.
5. Recommended that a method for comparative
acoustical data or information which is fair to all
manufacturers be established.
365
-------
Docket Number, Name,
Affiliation
77-8-709L (Continued)
8.
Comments
Suggested that EPA should use existing standards
for testing and rating appliances presently used by
the industry affected.
Believed that the overall effects of this program
will be to increase the cost of the product due to
the cost of the testing programs and the labeling
requirements. This does not even include addi-
i
tional cost resulting from governmental funds for
noise reduction programs.
Expressed the opinion that the label statement,
"Federal law prohibits removal of this label prior
to purchase," is unwarranted and may lead the
consumer into believing that other labels on the
product, such as the warning or warranty labels,
etc., may be removed at will since there is not a
prohibitionary statement on them.
-71OL
Robert A. Heath
Director of Government and Consumer
Affairs
Walker Manufacturing
The Walker Manufacturing Company expressed
agreement with the Agency's basic noise program.
Asserted that automotive parts are in a different
category than complete assemblies, such as
mixers or vacuum cleaners.
Encouraged a program that would operate under
statute limitations like the federal interstate truck
law.
For convenience and cost effectiveness to manu-
facturers and consumers, muffler designs on smaller
vehicles are consolidated which means that one
muffler can be used in many ways giving different
acoustical results.
Noted that consumers do not usually buy a brand
of an automotive part but rely on a repair shop to
select suitable products, making it more practical
to insist that these parts meet legal levels.
366
-------
Docket Number, Name,
Affiliation
77-8-710L (Continued)
Comments
6. The "running changes" made in parts during a
model year also present a problem in determining
which part, often with varying frequency ranges,
should be considered the best or standard.
7. To date, Walker has not seen nor do they
know of a practical bench test procedure.
8. Stated that: "In order to enact a practical con-
sumer product noise labeling regulation (1) an
informed population must exist which can make
practical decisions from either dB or relative
noise levels, (2) the public would have to be ad-
vised of a range and able to compare levels of all
competitive products, (3) for an auto parts manu-
facturer to know the noise level of his competition,
all manufacturers would have to test all products-on
all cars and installations-a formidable task, (4) com-
petition among manufacturers to reduce noise levels
must be allowed to develop."
9. Concluded that: "A regulation presenting a noise
level on the label of each automotive part for optional
consumer choice, purchase and installation will have
less effect in the automotive world than regulations
to a statute level."
-711L
Mrs. Brewster R. Heminway
1. Complained about "tree grinding equipment.'
•712L
Mrs. L. G. Glover, Jr.
1. Complained of noise caused by her vacuum,
washer, and old-time cutting saws.
-713L
Wayne Marcus
Technical Analyst
Motorcycle Industry Council, Inc.
1. Recommended that the provision requiring "the
range in noise ratings of other products of [the
same] type** be deleted, because such notice
exceeds authority in 1972 Act.
367
-------
Docket Number, Name,
Affiliation
77-8-713L (Continued)
Comments
2. Regarding Section 211.1.9 (a) (Inspection and
Monitoring) the word "properly" is undefined and
superfluous; therefore, MIC urged its deletion
from the provision.
3. Suggested that "oral" be deleted from Section
211.1.9 (b) in relation to notification, because it is
subject to misinterpretation.
4. A "Standards" requirement for the maintenance
of records, not in the Act's requirement, is beyond
the scope of the authority granted by the Act.
Therefore, the wording of this provision (211.1.9
(c)(l)) should be changed, substituting "and" for "or."
5. In Section 211.1.9(e) exception is again taken
to oral notification and it is recommended that
entry without 24-hour notice should be avoided
except in cases of blatant circumvention of the
regulation.
6. MIC felt that Section 211.1.10-1 (Testing Exemption)
lacked clarity and should be reworded or that
an explanation be developed.
714L
Harold W. Wolf
1. Complained of noise created by forced air circu-
lation systems.
-715L
Eliot Greb
1. Suggested that EPA stay out of the noise abatement
area completely, leaving it to the consumer to deter-
mine which products are not acceptable regarding
noise.
-716L
Mrs. Ed Reynolds, Sr.
1. Complained of noise made by her freezer and
refrigerator.
-717L
W. A. Hyland
1. Suggested that noise level be numbered so that the
higher the noise level, the noisier the product The
numbering system could have some direct correla-
tion to decibels.
368
-------
Docket Number, Name,
Affiliation
Comments
77-8-718L
Mrs. T. J. Brooks
1. Complained of noise made by her refrigerator.
-719L
Howard Schwartz
Complained of noise made by chain saws,
motorcycles, hairdryers, electric razors and
vacuum cleaners.
Expressed support for Agency action directed
at reducing product noise and labeling products
for noise emissions.
-720L
Rubin Helmin
1. In a personal visit requested information on chain
saw project.
•721L
Karla L. Yeager
1. Expressed support for the program, citing health
concerns and suggesting standards for high decibel
levels.
-722L
Lucille (Mrs. Herman) Haarer
1. Expressed concern over a noisy refrigerator and
noted the purported availability of a $50 kit to
abate the noise.
2. Expressed cautious support for the program.
-723L
Suzanne Badenhop
Department of Consumer Sciences
and Retailing
1. Reported findings of a survey of 150 women
regarding importance of consumer information on
labels for vacuum cleaners.
2. Noted that only 24 percent of the sample con-
sidered noise levels as important information for
a label, ranking it 10th of 11 factors, while 30.7
percent stated noise level information was not
important, ranking it second out of 11 in least
importance.
3. Expressed the opinion that consumers accept
noise as a "given" in vacuum cleaners, considering
cleaning performance of much greater importance.
369
-------
Docket Number, Name,
Affiliation
77-8-724L
Julia A. Morse
Comments
1. Requested any available information on noise labeling.
725L
Mrs. Charles W. Disbrow, Jr.
L Expressed opposition to the program as
"bureaucratic nonsense."
-726L
Janice F. Olson
1. Urged that the labels should be easily understood
and that an educational program on harmful noise
effects be adopted as well.
-727L
Delores Crozier
French Laboratory
1. Expressed concern that, if inadequately policed,
the program could lead to corruption to the
advantage of large over small businesses.
2. Noted that improper testing associated with the
"government seal of approval" could have damaging
effects on a small business.
-728L
Allen Nelson
1. Expressed interest in the issue of home appliance
noise.
2. Desired EPA response to the suggestion that
garbage disposals have motor casings more
resistant to noise.
-729L
John P. Reardon
Director of Governmental Affairs
Air-Conditioning and Refrigeration
Institute (ARI)
1. Noted that EPA need not identify unitary air
conditioners under either Section 5 or 8.
2. Referring to an article by Mr. Elkins in the
appliance manufacturer magazines, emphasized ARI's
voluntary certification program using the SRN
and a pure tone correction technique as a model
industry voluntary program.
3. Suggested that a number of descriptors might be
used in different product classes, such as the
SRN for unitary air conditioners, STC for construc-
tion materials, NRC for sound absorbing construe*
tion materials and dB(A) sound pressure at one
meter for home consumer products.
370
-------
Docket Number, Name,
Affiliation
Comments
77-8-729 (Continued)
4. Suggested that ARI's voluntary program could be
an effective consumer shopping and local noise
enforcement tool with public education by EPA.
5. Suggested that EPA work with industry to provide
guidance for voluntary noise programs, combined
with public education by EPA.
-730L
Caroline Pardoe
1. Expressed support for the program as providing
the opportunity to buy the least noisy appliance.
-731L
Daniel Queen
Daniel Queen Associates
1. Requested the opportunity to clarify his oral
testimony.
2. Restated earlier suggestion about maintaining
reliance on logarithmic designators (decibels and
bels), and reiterated his feeling that if given time,
consumers will become accustomed to relating the
designator to the stimulus.
3. Submitted a corrected version of his testimony
given before the noise labeling hearings,
September 16,1977.
-732L
Sherrie Sink
1. Complained of noise made by vacuum cleaner.
-733L
Mrs. Betty Westlund
-734L
Patricia Moran
1. Complained about noise made by her vacuum
cleaner.
2. Expressed support for noise labeling program.
1. Complained about excessive noise from stereos.
2. Expressed support for regulations which would
reduce the noise made by stereos.
371
-------
Docket Number, Name,
Affiliation
Comments
77-8-735L
Margaret Monji
1. Complained about noise made by a wall type
gas heater.
-736L
Elizabeth Bottomly
1. Complained about noise made by leaf blowers.
-737L
Gordon L. Cluff, Ph.D.
Director, Tri-Utility Hearing
Conservation Program
1. Submitted report to substantiate recommendation
that a single number rating system for personal
hearing protectors be adopted.
-738L
James W. Klimes
Product Safety Department
R. E. Anderson
Law Department
Deere and Company
1.
2.
3.
4.
Submitted responses to questions raised at the
noise labeling hearing, September 20, 1977, as
well as additions to testimony given at that time.
Expressed concern that the noise labeling
General Provisions Preamble may be written in
such a manner that it could later be used to direct
broader application of labeling requirements beyond
those cases where products are capable of adversely
affecting public health and welfare.
Expected that EPA would find it difficult to use
"public attitudes" as one of the "additional"
criteria listed on 42 FR 31723 (Column 1), since
public attitudes are constantly changing.
Expressed disbelief that public attitudes without
adequate factual support could act as the primary
stimulus for an EPA regulatory (labeling) action.
Expressed concern about the products listed as
"likely to be labeled" in the background document
for the General Provisions proposal. It reflects such
a broad interpretation of EPA's authority that the
scope of labeling requirements could be carried to
rather frivolous and costly ends.
37?
-------
Docket Number, Name,
Affiliation
Comments
77-8-738L (Continued)
6. Suggested that EPA redraft the General Provisions
preamble to more clearly indicate that the supplementary
or "additional" product selection criteria are intended
to narrow the range of products potentially subject
to labeling regulations.
7. EPA should develop well defined, objective product
selection criteria which can be stated quantitatively.
8. Commented on the inability to identify classes of
products for which noise labeling would be appropri-
ate due to the lack of a definition for "adverse affect
capability."
9. Expressed the feeling that it was the intent of the
language of Section 8 that notice be given to the
prospective user and thus the prospective user
would be the principle beneficiary of labeling.
10. The opinion was expressed that most products are
purchased by the ultimate user, thus even though
the intent of the statute is to give notice to pro-
spective users, EPA can proceed with a labeling pro-
gram which impacts more directly on the purchaser
without violation of Section 8.
11. Understood that if a product has been identified as
a major source of noise under Section 5, regulations
can be promulgated under Section 6 only if the
Administrator feels such regulations are feasible.
12. Expressed the feeling that determinations of feasibility
should be based on cost or marketing factors as well
as technology.
13. Felt that even if a noise emission standard was found
not to be feasible, EPA could require labeling under
Section 8.
373
-------
Docket Number, Name,
Affiliation
77-8-73 8L (Continued)
-739L
Richard Gimer
Comments
14. Stated: "Beginning in 1975, John Deere has
included as part of the Canadian Motor Vehicle
Safety Standards compliance for snowmobiles, a
statement as to a "not-to-exceed" noise level.
(Illustrations were attached.)
15. Pointed out that John Deere agricultural tractor
advertising brochures included data on operator
ear noise levels of Sound Card body equipped tractors.
16. Expressed the feeling that "brochure labeling" may
have more value for the potential customer because
the brochure information can be taken with the
customer allowing him to make meaningful, accurate
comparisons.
17. Unless required, Deere and Co. would likely not
modify its practice of labeling snowmobiles upper
dBA level rather than actual noise level for the
following reasons: (1) because of strict regulation
there is little difference in measured dBA levels of
snowmobiles and (2) because of the experience of
manufacturers who attempted to market "quiet
snowmobiles" and found that consumers appear
unwilling to accept the performance effects of
noise reduction.
1. Expressed a desire to testify at the Washington, D.C.
hearings on the general provisions of the labeling pro-
gram.
-740L
Arnold W. Rodin
Home Ventilating Institute
Commented that "Tlie HVI standards program for
rating and labeling its members' products' sound
emission has a well established standing among
consumers, the trade and building standards agencies."
Noted that, "HVI has required since 1971 that all
household range hoods and indoor exhaust fans in
its certification program be labeled with both air
delivery and sound ratings, as determined in inde-
pendent laboratory testing at Texas A&M University
under HVI test procedures."
374
-------
Docket Number, Name,
Affiliation
Comments
77-8-740L (Continued)
3. Pointed out that, "The U. S. Department of
Housing and Urban Development in its Minimum
Property Standards requires that all kitchen and
bathroom ventilators carry sound as well as air ratings
as tested under HVI procedures. The International
Conference of Building Officials recognizes HVI
as a Quality Control Agency for certified ratings
of home ventilators for sound and air."
4. HVI labels state sound ratings in sones, which
follow a linear scale rather than a logarithmic scale
as do decibels.
5. Stated that: "Consumers, builders, contractors,
dealers and salesmen have found HVI sones ratings
useful in the selection and installation of literally
millions of ventilators."
6. Expressed the opinion that the HVI standards meet
the essence of EPA's four objectives for the noise
labeling program in the Federal Register.
7. Pointed out "that the HVI sound testing procedure
simulates use-environment, which your notice says
will be considered where appropriate though not a
primary objective."
8. Expressed HVI's opposition to a dBA rating for
products because logarithms are difficult for con-
sumers, contractors, and sellers to handle in making
comparisons.
9. Urged EPA to adopt the sone as the-common sound
measurement for all labeling standards because of
these merits: "(1) Simplicity in understanding and
use (linear scale, low numbers, relevance to actual
experience). (2) Accuracy and appropriateness of
uniform laboratory testing. (3) Proven workability.
(4) Wide familiarity."
375
-------
Docket Number, Name,
Affiliation
Comments
77-8-740L (Continued)
10. Expressed the opinion that minimal Federal
involvement would be best for home ventilators
by letting the HVI program continue to operate
on its own.
11. Took issue with the assumption that home
ventilators pose any problems of health or welfare
to justify inclusion under EPA regulations.
12. Expressed the opinion "... that the consumer or
other purchaser needs no new information or new
protection than presently provided [since] the
sound of range hoods and exhaust fans is stated so
that the desired degree of quietness may be selected;
sound ratings come under specified limits set for HVI
certification and compliance to HUD standards; and
existing sound levels pose no health or welfare threat
to occupants or neighbors."
13. Offered its cooperation in developing the EPA
program, particularly in directions compatible with
the HVI program.
14. Suggested that "sound labeling" is a more accurate
and appropriate general term than "noise labeling"
since "noise" has subjective negative connotations,
whereas the word "sound" is objective.
-741L
Charles Wittyer
The Marley Organization, Inc.
1. Suggested that advance planning and involvement
prior to issuance of regulations was an advisable
approach for affected parties.
2. Requested noise labeling program information.
-742L
Douglas A. Frazer, President
International Union, UAW
1. Observed that UAW receives more complaints
about noise than any other single occupational
hazard. Therefore, UAW takes great interest in
EPA's intent to regulate noise at the time a product
is being manufactured.
376
-------
Docket Number, Name,
Affiliation
Comments
7 7-8-742L (Continued)
2. Expressed approval of a noise regulation program
and strong support for EPA's proposal to require
labeling of noisy products.
3. Expressed the hope that the program's major
focus would be on industrial noise sources, with
regulation at the point of manufacture a more
effective technique than workplace noise level
standards.
77-8-743L
Frank S. Fitzgerald
Executive Vice President
Noise Control Products
and Materials Association
1. Commended EPA "for its efforts to raise
public, awareness and understanding of
noise reducing properties of products and
materials at the marketplace."
2. Stated that, inadequate technical data will
however only confuse the purchaser and
frustrate the program's objectives.
3. Recommended that laboratories conduct-
ing tests pursuant to the regulations be ac-
credited by the American Association for
Laboratory Accreditation (AALA) and
commented on the Commerce Department's
national voluntary laboratory accreditation
program.
4. Stated that the establishment of public
testing facilities would be "a duplication
of that (above) effort and a needless ex-
penditure."
5. Believed the regulations for product selec-
tion should focus on the labeling of finished
systems and not parts of those systems.
6. Stated that "a single uniform rating system
for all products will not provide the consumer
with meaningful information."
377
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77-8-743L (Continued)
9.
10.
11.
Requested that in developing rating schemes
and test methodologies, EPA consult the
Noise Control Products and Materials Association,
American Association for Laboratory
Accreditation, American Society for Testing
and Materials, American National Standards
Institute, Society of Automotive Engineers,
American Acoustical Society, Institute of
Noise Control Engineers, and the National
Bureau of Standards.
Noted the need to consider sound reducing
parameters for the whole system rather than
individual parts and to present some parameters
as "a function of frequency, not by a
single number."
Stressed the problems in communicating
meaningful information to the consumer
through the use of a simple number or descriptor.
Asserted that EPA should consider a technique
of rating only for end use products and
systems.
Expressed hope that the Agency would consider
current trade practices emphasizing a systems
approach in marketing and the availability
of testing facilities in their formulation of a
Final Rule.
-744L
William V. Skidmore
Assistant General Counsel for
Legislation
Department of Commerce
1. Recommended changes in the proposed regulations.
2. Recommended that EPA discuss the Agency's
intention with respect to timing of the effective
dates of product-specific regulations in the
preamble of the Final Rule for the General
Provisions, so that manufacturers have some idea
of the minimum time allowed for compliance.
378
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77-8-744L (Continued) 3. Recommended that when EPA develops proposed
regulations for specifying rating procedures and
ranges pursuant to Section 211.1.4(b) and (c),
it considers the approach employed by the
Department of Commerce in implementing its
voluntary Energy Labeling Program.
4. The Commerce Department approach provided for
submission to the Department of measurement
data developed by manufacturers or generated by
independent test laboratories or national certification
programs. Then proposed ranges were published in
the Federal Register for comment; comments were
then considered and final ranges were established
and published in the Federal Register.
5. Submitted the following documents:
1. 15 CFR Part 9 (38 FR 29574, October 26,1973)
Procedures for a Voluntary Labeling Program for
Household Appliances and Equipment to Effect
Energy Conservation (Tab A);
2. 40 FR 32415 (August 1,1975) Voluntary
Energy Conservation: Testing and Labeling;
Specification No. 2075, for Refrigerators
(40 FR 32415 etseq.); Specification No. 3-75,
for Combination Refrigerator-Freezers
(40 FR 43427 et seq.); Specification Noi
4075, for Freezers (40 FR 32440 et seq.) (Tab B)
3. 40 FR 37063 Voluntary Labeling Program
(proposed ranges) (Tab C); and
4. 40 FR 58673 Voluntary Energy Conservation;
Testing and Labeling (final ranges) (Tab D).
6. Recommended "that EPA acknowledge its respon-
sibility in the general provisions for compiling rating
figures, establishing the limits of the range, and duly
specifying the range in published regulations pur-
suant to Section 211.1.4(c)."
7. Expressed the opinion that "This responsibility would
include periodic updating of the range as the extreme
high and low ratings change because of product modi-
fication, model additions and deletions and the like."
379
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-745
Frank E. Wilcher, Jr.
Executive Director
Industrial Safety Equipment Association
(From 77-5-038)
1. Maintained that the amount of information pro-
posed for the label is excessive and that EPA
should design a label that would not require re-
design and enlargement of the product package.
2. Gave examples of redundant label information,
such as company name, location, and product
model numbers.
3. Felt that contrast is unnecessary if the label is
legible.
4. Quoted Section 10 of the Administrative Procedures
Act, 5 U.S.C. S706(2)and suggested that the pro-
posed regulations were legally, as well as technically,
unsound.
5. Suggested that regulations concerning specification
of label content, EPA's inspection authority, and
recordkeeping requirements of manufacturers
exceed the authority conferred on EPA by Congress.
6. Pointed out that Section 8 of the Noise Control
Act of 1972, 42 U.S.C. Sec. 4907(b), requires
only a label giving notice of the hearing protector's
effectiveness in reducing noise and not items (d>
(h) of 211.1.4.
7. Stated that there is no statutory basis for the require-
ments that the label contain information beyond
the noise-reducing effectiveness notice such as
the EPA logo and especially the removal prohibition
statement noting that Congress usually expressly
specifies such requirements.
8. Suggested that the proposed enforcement provisions
magnify the manufacturers' requirements as stated
in Section 13 of the Noise Control Act.
380
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77-8-745 (Continued) 9. Cited specifics in the proposed rulemaking
which exceed the requirement of Section 13 by
requiring manufacturers to admit EPA inspection
officials to their private facilities for inspection
and monitoring activities.
10. Pointed out that the proposed regulations may
be unconstitutionally vague, noting that the
grounds for a cessation order are ill-defined,
particularly the term "substantial" [211.1.9(a)(2)],
381
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PUBLIC HEARING TESTIMONY
WASHINGTON HEARING
77-8-901-WH
Dr. Donna Dickman
Program Manager
Environmental Noise Program of
the Metropolitan Washington
Council of Governments; and
American Speech and Hearing
Association
Oral Statement
1. Dr. Dickman expressed concern over lack of
public awareness of noise problem and the
public's limited access to information which
might assist their decision-making. She urged
that the adopted labels be easily understandable
and highly visible. (14-15)
2. She expressed general support for the program as a means of providing information to the
public and for the inclusion of range data on the label. (15)
3. Dr. Dickman suggested an extensive public education effort be associated with the program,
including mass media exposure and pamphlets readily available in public places. (15-16)
4. Factors that should affect identification of products for labeling are number of persons
exposed, noise level, frequency of use, useful life and product cost. (16)
5. Dr. Dickman endorsed the selection of hearing protectors for labeling. (17)
Responses to Questions from EPA Panel: Mr. Thomas
6. Dr. Dickman suggested that a uniform descriptor be used for labeling all classes of noise-
emitting products to avoid public confusion and to promote learning, and expressed the
opinion that use of the range data is more vital than the choice of descriptor. (19-21)
Mr. Feith
7. When presented with possible alternative methods of providing comparative information, Dr.
Dickman opted for a label which allowed comparisons between products within the same class.
However, the educational program should address physiological and psychological annoyance
effects of differentiated noise levels. (23-24)
Mr. Elkins and Mr. Feith
8. Dr. Dickman cited the kitchen, repair, and lawn-care areas of her household as particularly
noisy. (23-24)
382
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Mr. Ricci
9. Dr. Dickman suggested clearly visible labels attached to the product so as to catch the
consumer's attention, and opposed presenting rating information via displays. (26-28)
Dr. Shutler
10. Dr. Dickman suggested that, in light of the fact that consumers do not test products
for sound levels, a procedure for confirming a purported noise level on a label must have
been employed before the consumer buys the product. Government oversight is the
procedure Dr. Dickman had in mind, although she mentioned industry self-policing as
well. (28-30)
Mr. Kozlowski
11. Dr. Dickman indicated that the public educational program must convey the fact that
the noisier product is not necessarily the more powerful or more effective product. (31-33)
12. Dr. Dickman noted that, from her observation and work with the Council of Governments,
consumer concern for quiet products is on the increase, generating the need for an educational
program directed not only at the consumer but also at the salesperson. (33-34)
Mr. Elkins
13. Dr. Dickman commented about inability to get noise information from salespersons. She
• felt that even if the salespersons were educated to noise levels, the consumer could still
face difficulties because realistic demonstrations of some products to check noise levels
(e.g., dishwashers) are impossible to perform at the point-of-sale, and noise level compari-
sons between stores are meaningless because of ambient variation and memory loss. (35-36)
14. She expressed support for warning the consumer of possible health hazards of noisy
products through the educational program and not on the label itself. (37-38)
15. Dr. Dickman suggested that education for the hearing protector labeling program must
reach both the ultimate user and the purchaser of the defice. (38-39)
Mr. Thomas
16. Dr. Dickman mentioned the practical cosmetic problem associated with permanent, visible
labels on household appliances. (40-42)
383
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77-8-902-WH Oral Statement
John Reardon
Director of Government Affairs 1. ARI believed the EPA Background Document
Air Conditioning and Refrigeration for Noise Labeling indicated EPA has deter-
Institute mined that it will not initiate a noise labeling
program for outdoor equipment even though
Table 4-3 mentions air conditioners. (45)
2. ARI questioned whether or not the above document includes central air conditioners or
room air conditioners or both in the category of outdoor equipment, especially since
page 4-24 states that "outdoor equipment of Category C... is not of interest for labeling
purposes; if it were very noisy, it would be regulated rather than labeled." (45-46)
3. Mr. Reardon discussed ARI's history of involvement with the issue of noise and ARFs
development of sound-rating technology and relevant testing for its member's products.
(46-50)
4. ARI indicated a preference for a voluntary program. (50-53)
5. ARI suggested that comparative acoustic data, or range, for a product not appear on the
label because of updating problems and because regionally exclusive products may not
be available. (53-55)
6. ARI considered the 24-hour notice for access to facilities as unreasonably disruptive and
harmful to proprietary interests (211.1.9(b)(2)). (55-56)
7. He believed noise enforcement officer should not be given the authority to photograph
a manufacturer's product, since the information could be given to a competitor under
the Freedom of Information Act. (56)
8. Mr. Reardon indicated that relatively long notice period should be required for EPA's informing
a manufacturer that a specific product is to be tested or that a specific test facility is to
be used for an EPA-monitored test, because many products may be "built to order."
(211.1.11(aXDand(2)). (57)
9. ARI objected to the exemption granted for prototype products because of the improper use
that could be made of them in a display or demonstration setting. (56-57)
10. Mr. Reardon also opposed tight scheduling of test facilities, preferring the alternate proposal
set forth in 2112.12( 1 )(d) of the hearing protector regulations. (58)
11. ARI suggested that labeling regulations permit advertising claims, beyond EPA's required
rating, to reflect differing actual use conditions, possibly supplementing the standardized
EPA rating point with different rating points. (58-59)
384
-------
12. ARI saw no reason for the retention of test records mandated by 211.2.9(a)(2).
Responses to Questions from EPA Panel: Mr. Cerar
13. Mr. Reardon indicated that noisy air conditioners do not cool better, but the units can be
altered by reducing their thermodynamic capabilities to be quieter. (68)
Mr. Feith
14. Mr. Reardon explained that an SRN number on a condenser unit would not provide a
comparative rating because of the variance in sound pressure level caused by installation
conditions and distance from the unit. (76-78)
15. Because of the possibility of rerating product noise level based on complaint testing, it
would be costly to include sound rating number on product label rather than in directory.
(78)
16. Mr. Reardon's response to questions indicatd the difficulty that an average consumer would
have in determining the level of noise emitted by an ah* conditioner, because of (1) lack
of knowledge about ARI coupled with lack of address on label; (2) price of directory
listing ratings; (3) salesperson's ignorance about ratings, etc. (80-82)
Dr. Shu tier
17. Mr. Reardon indicated that ARI's concern with entrance to test facilities by EPA rested
primarily with regard to tests on models not intended for commercial use. (93)
18. Mr. Reardon indicated that some small manufacturers do not enter the voluntary noise
certification program because of the prohibitive costs of in-house testing facilities, but
the manufacturers are allowed to use independent laboratories to conduct the tests. Mr.
Reardon could cite only two such laboratories capable of performing the indicated
testing. (94-95)
19. Mr. Reardon described the process by which ARI, through Electrical Testing Laboratories,
randomly selects the specific units of a manufacturer's model line for testing. He
noted that the unit is generally selected from a warehouse rather than the assembly
line, and the designated unit is sealed to prevent alteration prior to testing. (96-97)
385
-------
Mr. Kozlowski
20. Mr. Reardon was not able to provide precise information on the number of products
tested by the manufacturers, tested by ARI, or tested and failed. (97-100)
21. Mr. Reardon stated that a gradual drop in noise ratings had occurred since the beginning
of their voluntary certification program, although consumer interest in either energy
efficiency or sound ratings has not appeared high. (106-107)
22. Mr. Reardon suggested that periodic monitoring by EPA of a voluntary industry sound-
rating certification program would be a more effective use of EPA resources than would a
full EPA regulatory program. (108-109)
23. Mr. Reardon responded affirmatively when asked if a voluntary sound-rating certification
program would be feasible for window-unit air conditioners also. (109-110)
Mr.Elkins
24. Mr. Reardon expressed concern over the possibility of government paperwork and red
tape that could result from a full EPA labeling program, as well as the additional cost
of the labeling itself, which might run, he had heard, as high as $ 1.00 for each unit's
label. (110-113)
Donna Dickman (audience question)
25. Mr. Reardon responded affirmatively when asked if the idea of a noise range for a product class
might be "saved" by indicating at the point-of-sale that models of certain values were not avail-
able in a given area (see point No. 4 above), but "administratively" he still felt the range
information would have little practical shopping value for the consumers. (114-115).
386
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77-8-903-WH Oral Statement
Theodore Berland, President
Citizens Against Noise 1. Mr. Berland expressed support for the
program with criticism of some points and
catalogued environmental noise through a typical day's exposure. (117-119)
2. Mr. Berland suggested that EPA consider "products" for the program in the broadest
sense of the term, including not only household appliances and tools but also mercantile
office and factory equipment, and further suggested that the program be aimed at a
broad audience beyond the immediate consumer. (119A-l 19C)
3. Mr. Berland suggested that the label include a decibel rating and an indication of possible
harm such as "loud, 70-85 dB(A)" and "irritating, 60-70 dB(A)." This could possibly be
associated with an appropriate color coding and reflective surface such as a red label for
"dangerous" and yellow for "irritating." (119C-119D)
4. Mr. Berland urged a stronger, more articulated testing and enforcement plan for the
program. (119D)
Responses to Questions from EPA Panel: Mr. Thomas
5. Mr. Berland responded negatively when asked if could see any evidence of industry concern with
noise levels of their products or efforts to inform the public about noise (120-121)
Mr. Feith
6, Mr. Berland expressed the opinion that he would pay what it costs for a quiet environment
noting that $1.00 for a noise label on an air conditioner is "pretty cheap." (121-122)
Mr. Ricci
7. Mr. Berland suggested that louder products, such as airplanes, motorcycles and kitchen
appliances, be given priority in product selection for the labeling program. (122-123)
Dr. Shutler
8. Mr. Berland urged that penalties proportionate to the size of the audience affected be
imposed for violations of the labeling regulations. (123-124)
387
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Mr. Elk ins
9. Mr. Berland agreed that one objective of the program should be the establishment of
the noise ratings as an aid to enforcement of distinct local noise ordinances. However,
local use ordinances must address the problem of alteration of the sound qualities of a
product. (124-126)
Audience Question-Mr. Morris, American Rental Association
10. Mr. Berland contended that the costs of a quiet environment must be decided in the
courts, and the public must be educated to the harmful effects of noise. (126-127)
388
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77-8-904-WH. Also 77-5 Oral Statement
Mr. Stuart Low
President 1. Mr. Low objected to the handling of Subparts A
Flents Products Company and B by EPA with particular reference to the
lack of distinction given them by EPA and the
time obstacles for comments on Subpart B, directly affecting his firm as a manufacturer
of hearing protectors. (129-130)
2. Mr. Low indicated that labeling for retail hearing protectors would not be effective
because of the small size of the devices, the public's lack of awareness and the public
concern with comfort rather than a technical acoustic rating descriptor. (131-133)
3. Although Mr. Low had no objection to ASA 1-1975, per se, he did urge caution about the
use of such a relatively new procedure. (134-135)
4. With reference to 211.1. i and .y Mr. Low noted that the definition of 'manufacturer"
for the purposes of importation remains unclear; does "manufacturer," e.g., encompass
"assembler"? In addition, rules for importers have yet to be articulated. (135-137)
5. Mr. Low suggested allowances for sufficient lead time in the implementation of the
labeling program to account for importation and manufacturing difficulties. (137-138)
6. Referring to 211.1.4, Labeling Content, Mr. Low pointed to excessive information
requirements for earplugs, much of it duplicating contents on the product's packaging,
and also objected to the large size of the proposed labels, requiring larger and costlier
packaging for the earplugs. These requirements, Mr. Low concluded, are unduly
burdensome to the industry, given the low cost of making ear plugs.
7. Referring to 211.1 .S-.8, Mr. Low objected to the requirement to affix labels on each
individual product, since many of his firm's sales are in bulk lots in cost-saving packages.
Mr. Low also expressed confusion over what could be pasted as opposed to less costly
procedure of printing the label. (141-143)
8. Referring to 211.1.9, Inspection and Monitoring, Mr. Low objected, in light of unpleasant
experiences with New York State regulations, to the "extraordinary" inspection powers
afforded to EPA, and suggested two paragraphs (pp. 146-147) be appended to the regula-
tions circumscribing EPA's orders for cessation of production. (144-147)
9. Mr. Low objected to the lack of hearings on the hearing protector proposals, Subpart B,
and urged a dialogue with EPA and his industry leading to a more voluntary program.
(147-149)
389
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Responses to Questions from EPA Panel: Mr. Thomas
10. Mr. Low commented that he did not pppose the new ANSI standard test but rather was
concerned about its relative novelty for testing purposes. (150-156)
11. Mr. Low expressed concern over placing rating labels on both his product's packaging
insert and on the box itself, which he felt would be a costly procedure. (156-158)
12. Mr. Low suggested that EPA consider the differences for labeling purposes in hearing
protectors marketed for individuals versus those sold in bulk packages to industry.
(159-164)
Dr. Shutter
13. Mr. Low suggested more highly articulated enforcement language in the regulation, vesting
cessation-of-production authority clearly in the Administrator and informing enforcement
officers of the limits of their discretion. (16-5-168)
Mr. Kozlowski
H. Mr. Low pointed out differences in costs, marketing and packaging between ear muffs
and ear plugs but preferred to defer to Industrial Safety Equipment Association comments
on the ear muff matters. (168-170)
Mr. Cerar
15. Mr. Low expressed concern over possible delays hi implementing Import Section 9 through
Treasury Department regulations, which have yet to be issued. (171-173)
Mr. Feith
16. Mr. Low pointed out that a 12-422 attenuation test costs around $2,000, and labeling
might add 80 percent to the costs of some of his firm's containers. (175)
390
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77-8-905-WH Oral Statement
Roy W. Muth
Director of Technical Services 1. Mr. Muth noted that snowmobile noise
International Snowmobile emissions have been reduced from approximately
Industry Association 102 dB(A) in the late 1960's to 78 dB(A) currently
through industry efforts. (178-179)
2. ISIA endorsed the goals listed in "Toward a National Strategy for Noise Control" and the
NPAM's Supplementary Information and suggested voluntary industry labeling as the most
effective means for furthering these goals with a minimum of EPA involvement. (179-182)
3. ISIA suggested possible EPA inducements for industry to undertake effective voluntary
labeling programs: a) dropping such voluntarily-labeled products to the bottom of
the mandatory priority list; b) urging government agencies to favor such products;
c) offering EPA testing facilities to these manufacturers; d) agreeing to joint EPA-
industry financing of related sound control research; e) EPA applauding of such in-
dustry programs. (182-184)
4. Commenting on Part 211 of Title 40, ISIA suggested that EPA product selection criteria
be spelled out in the regulations, thus encouraging manufacturers of such products to
develop voluntary programs. He mentioned various criteria. (184-185)
5. Referring to Sections 211.1.2(0 and 211.1.4, ISIA called for clarification of the admini-
strator's statutory authority for required label information-such as the rating scale-and
for some inspection and monitoring activities, such as the 24-hour notice. (185-187)
6. ISIA, suggested generally that EPA enforcement focus on a manufacturer's capability to
perform the required tests, the results of the tests for noise emission, and auditing of
the tests. (187)
7. ISIA could not see the purpose in 211.1.10 and suggested that it grant an exemption from
labeling rather than from testing and further suggested that 211.1.11 be changed to con-
form to statutory authority with respect to requiring the manufacturer to ship products to
EPA and allowing EPA operation of private test facilities. (188)
Responses to Questions from EPA Panel: Mr. Thomas
8. Mr. Muth explained that industry labels on snowmobiles state that the product meets
the standards of the Snowmobile Safety and Certification committee on brakes, lighting
and noise, the last of which is 78 dB(A) at full throttle and 73 dB(A) at 15 miles per
hour, both "pass-by" tests. (192-193)
-------
Mr. Feith
9. Mr. Muth noted that the ISIA would support dissemination of information on operator
noise levels but had not yet approved a plan for doing so. (197-199)
Dr. Shutler
10. Mr. Muth pointed out that an independent laboratory verifies noise ratings using snowmobiles
taken from the production line or channel of distribution. (2031
11. Mr. Muth explained that, when a model fails to meet industry standards, the manufacturers
must remove the label from all its models until all are in compliance. Every model is tested
every year, but none have failed. (204-207)
Mr. Kozlowski
12. Mr. Muth preferred not to suggest what would be an acceptable level of Federal involvement
in the industry's voluntary program, and reiterated the advantages of a voluntary program.
(208-210)
Mr. Elkins
13. Mr. Muth expressed the belief that noise level is not a major marketing factor for snow-
mobiles. (213)
392
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77-8-905-WH Addendum to Responses to Questioning from
Roy W. Muth EPA Panel
International Snowmobile
Industry Association 1. On the question of a volunteer noise labeling
program in the snowmobile industry, Mr. Muth
added that the Executive Committee of the ISIA had decided to adopt a voluntary program,
with details to be available the following morning.
393
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77-8-906-WH Oral Statement
Ernest Scott
Kirby Vacuum Cleaners 1. Mr. Scott stated that labeling of domestic
vacuum cleaners for noise is not needed
since they are not hearing hazards, but rather most complaints refer to them as only
annoyances. (190)
2. Mr. Scott suggested that a noise label might be incorporated into an overall performance
label on vacuum cleaners being voluntarily developed in cooperation with the FTC.
(190-191)
394
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77-8-907-WH Oral Statement
Wesley E. Schwieder
Executive Engineer 1. Ford did not wish Section 8 of the Noise
Environmental and Safety Control Act to be used to circumvent Sec-
Engineering Staff tion 6, avoiding noise impact studies. (217)
Ford Motor Company
2. Mr. Schwieder suggested that EPA spearhead
^ a movement to clarify and simplify burgeoning
Richard Genik labeling: requirements through a "Federal Inter-
Noise Control Planning Manager agency Product Labeling Review Committee." (218)
and 3. Ford noted that the public education effort needed
Herbert Epstein to convey tne labeling program will be "virtually
Senior Attorney impossible," suggesting an understandable 1-5
scale instead of decibel levels. (218-219)
4. Ford suggested that no automobile components already covered by noise emission regulations
be subject to Section 8, strongly opposing inclusion of vehicle exhaust systems in the plan
as undue interference with final design. Further, Mr. Schwieder stated that Ford felt that
labeling of replacement exhaust systems wouM not reach the consumer, would soon
become illegible and would have to be labeled for multiple applications. Rather, Ford
preferred a certification program as in Florida and California. (219-223)
5. Ford suggested use of the dB(A) rating as the most appropriate acoustic parameter. (223-224)
6. Ford expressed opposition to much of the enforcement scheme for the program as being
basically like that imposed for medium and heavy trucks. (224-225)
7. Mr. Schwieder stated that Ford could not find evidence that EPA had considered increased
costs to the consumer as a result of the program in the NPRM or Background Document.
(225-226)
8. Ford questioned the authority for comparative range information on the labels. (226-227)
Responses to Questioning from EPA Panel: Mr. Cerar
9. Mr. Schwieder explained that, in the event of a running change during the model year, a
labeled component part would have to be retested for assurance of its compliance with
the regulations. (228-229)
395
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10. Mr. Epstein pointed out that under the "economic impact" Executive Order 11821.
extended by 11949 and as construed by OMB Circular A-107, EPA is required to-perform
a cost-benefit analysis of the economic impact of the Section 8 labeling program, on
consumers as well as on manufacturers. (229-232)
Mr. Kozlowski
11. Mr. Schwieder stated that Ford's objections to labeling of mufflers center on analogies
to the "cumbersome" enforcement scheme for the heavy truck noise regulations.
Ford preferred the more flexible programs of Florida or California. (232-233)
12. Although Mr. Schwieder could not comment directly on the applicability for Ford of
voluntary noise programs such as those described by the air conditioning and snowmobile
industry representatives, he pointed to Ford's voluntary compliance with passenger car
dB(A) levels under the SAE 96A procedure and alluded to the saleability of quiet cars.
(233-236)
13. Mr. Schwieder contended that compliance for a muffler-noise-labeling program's
enforcement schemes similar to that for heavy truck noise would result in substantial
costs, while the more flexible examples of the California and Florida program would not
entail "painful costs." (237-238)
Mr. Thomas
14. Mr. Schwieder indicated that Ford's advertising for the quiet quality of its cars includes
comparisons with other makes but not noise levels themselves. (238-240)
IS. Mr. Schwieder commented that high performance, noisy automobiles do have an appeal
to certain segments of the market, but Ford has vacated that kind of market. (240-242)
Mr. Elkins
16. Mr. Schwieder offered the opinion that a noise-level label would not be the influencing
factor in consumer choice. He agreed the consumer might not perceive small dB(A)
differences through test driving. (242-246)
396
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Mr. Feith
17. Mr. Schwieder explained that Ford's concern over the comparative acoustic rating centered
on the difficulties of establishing the range, in light of the EPA fuel economy rating
problems. (248-250)
18. Mr. Schwieder reiterated Ford's opposition to labeling original component parts but
withheld assessment of labeling replacement parts until seeing a detailed proposal.
(250-251)
Mr. Thomas
19. Mr. Schwieder noted problems with noise labeling the original tires for a vehicle, such
as conflicts with braking regulations. However, Mr. Schwieder deemed replacement
tires worthy of consideration for labeling. (251-254)
Mr. Okins
20, Mr. Schwieder expressed Ford's concern that Section 8 could be used to impose regulatory
enforcement and to avoid the steps for identifying a product as a major noise source
under Section 6. He preferred the Section 6 step be undertaken first. (254-257,260)
21. Mr. Epstein speculated that Section 8, by its statutory language, might require a rule-
making decision to designate a product as falling within its purview, unlike Section 6.
(257-259)
(Also see Docket No. 77-8-643 for corrected hearing transcript and additional comments.)
397
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77-8-908-WH Oral Statement
Howard W. Burnett, Officer
Rent-It Center, Inc. 1. Mr. Burnett, speaking as a businessman, stated
Representing.the American Rental his opposition to product noise-labeling as it has
Association (ARA) been pressented, citing lack of consumer under-
standing and increased cost to the consumer.
with (263)
Roy Morris
Attorney, ARA 2. Mr. Burnett expressed concern over EPA noise
regulation of tools of production such as 250
horsepower crawler tractors, since the public does not come in contact with such items
and alterations could lower productivity. (264-265)
3. Mr. Burnett noted a problem with continued use, rehabilitation and resale of tools of
production leading to destruction of noise labels. (265-266)
4. Mr. Burnett pointed out an air compressor noise label developed by ARA at a cost of
$5.00 per label. He noted cities' general satisfaction with a sound level of 80 dB(A) at
50 feet, and felt that a worker can sustain 90 dB(A) for 8 hours. (266-267)
5. Mr. Burnett expressed the opinion that noise abatement of two cycle engines such as
those in chainsaws, could have adverse consequences for safety. (267-270)
Responses to Questions from EPA Panel: Mr. Cerar
6. Mr. Burnett emphasized his perspective as a safety expert by suggesting that products
lacking a potential for hearing loss (such as vacuum cleaners) or health damage need not
be noise-labeled (272-275).
Mr. Elkins
7. On the issue of the need to maintain the noise label after purchase of the product,
Mr. Burnett and Mr. Morris raised the problem of Section 8 notice being given to the
prospective user rather than the purchaser of the product. (276-279)
Mr. Kozlowski
8. Mr. Burnett accepted Mr. Kozlowski's criticism of the 90 dB(A) 8 hour tolerance level
for workers. (279-280)
398
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77-8-909-WH Oral Statement
Daniel Queen
Daniel Queen Associates 1. Mr. Queen suggested that the A-weighted sound
pressure level is the most useful descriptor,
but exposure varies in different settings necessitating the additional use of the noise power
emission to judge the noise in a given setting. (287-288)
2. Mr. Queen noted that noises occurring under relatively constant circumstances, such as
interior car noise, should be measured by A-weighting, but for sources varying in surroundings,
such as vacuum cleaners, the power emission measurement should be used as well. (288-289)
3. Mr. Queen expressed the opinion that the public could easily learn the meaning of power
emission levels, particularly if Bels are used for the power emission level to distinguish
its magnitude from SPL. (289-290)
4. Mr. Queen cited the examples of the mechanical versus electronic sirens and of the smoke
detector horns to illustrate his point that a sound pressure level measurement alone does
not adequately reflect the sound performance and effectiveness of the devices. He
pointed to the need for the power emission measure as a supplement. (290-293)
5. Mr. Queen suggested that the measurement problems of the sound power emission could
be overcome by use of noise classes. (293-295)
Responses to Questions from EPA Panel: Mr. Thomas
6. Mr. Queen indicated that the promulgation of noise-labeling regulations could be a factor
in itself in lowering costs of the required measurement methodologies, given rapid advances
in the state of the technology. (295-299)
Mr. Feith
7. Mr. Queen expressed the opinion that the public could learn to read and use a logarithmic
scale as well as a linear one. He urged that the common dB(A) scale should not be dis-
carded, and concluded that achieving a scale-type rating might not be possible given the
need for both pressure and power measures. (299-302)
399
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77-8-910-WH Oral Statement
Richard Gimer
Compressed Air and Gas 1. CAGI urged that clear criteria be set forth by
Institute (.CAGI) EPA for determining what products might be
subject to regulatory action. (306-307)
2. Mr. Gimer expressed CAGI's opinion that, once a product fell under Section 6 standards,
it would be inappropriate, with few exceptions for high dB(A) products, to proceed to
Section 8 mandatory labeling for that product. (307-308)
3. CAGI interpreted the intent of Congress in the Noise Control Act to focus on products
potentially damaging or injurious to health in the products' noise emissions. (309-310)
4. CAGI considered it inappropriate for EPA to propose noise regulations for those products
exclusively subject to existing OSHA noise regulations, preferring action under Section 4 (C)
(2) of the Noise Control Act. (310-312)
5. Mr. Gimer stated that CAGI could not determine if a single product with a value about its
established noise-rating scale would be considered a violative product, preferring the
approach in gas mileage in which every product need not attain its labeled value. (312-313)
6 CAGI objected to the comparative rating on the noise label, believing industry would
have to develop the scale and that such a requirement falls outside the statutory mandate
of the regulations. (314-316)
7 CAGI indicated that the requirement that the model number appear on the label
poses the problem of increasing label costs (316-317)
8. Mr. Gimer expressed CAGI's concern over the size of the label on a small product, suggesting
that some elements, such as the EPA logo, could be removed in such cases and wished
the choice of label type to be determined on a case-by-case format. (317-318)
9. CAGI objected to the inspection and monitoring provisions of the proposed regulations,
holding these unauthorized by the statute, unnecessary for the program and likely to lead
to litigation. (318-319)
10. CAGI expressed the opinion that the power to issue " cease to distribute" orders properly
rests with the Federal District Courts. (319)
11. CAGI felt that EPA should not require products to be submitted for testing at remote
sites, without full reimbursements and raised concerns over EPA supervised testing of
new products intended for commerce. (320-322)
400
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12. CAGI objected to the absence of economic analyses in the program, contending that
EPA has the burden of assessing the impact of the proposed regulations. (322-323)
Responses to Questions from EPA Panel: Mr. Cerar, Mr. Elkins, and Mr. Thomas
13. Mr. Gimer urged that competitive considerations be taken into account in Section 8,
economic analyses. (323-326)
14. Mr. Gimer expressed the view that finding an item in excess of its labeled noise rating
should not be cause for deeming the product violative of the regulation. (327)
15. On the issue of the intended audience for the regulations, Mr. Gimer saw some confusion
in addressing the regulation to either the purchaser or the user, referring particularly to
high noise, low sales product outside a broad public audience. (328-331)
Mr. Cerar and Mr. Kozlowski
16. Mr. Gimer saw no useful purpose in individually labeling products used in a work place
with an OSHA noise standard at the worker's ear, a standard that addresses the whole
work environment. (331-333)
Mr. Kozlowski
17. Mr. Gimer stated opposition to noise testing each product off the line and preferred an
"appropriate number" of the products be tested to establish the sound level, leaving
aside the mathematical questions involved. The number would remain with the product,
barring manufacturing changes. (333-337)
18. On the meaning of the manufacturer's obligation to supply products for testing under
Section 13(a)(3), Mr. Gimer expressed concern over a testing program similar to that
of the compressor regulations and expressed concern about requirements for shipping
products to a central testing facility. (338-341)
401
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19. Mr. Gimer suggested that the manufacturer identification should be required on the label
only if it does not appear elsewhere. (342-344)
Mr. Feith and Mr. Elkins
20. On the issue of protecting the health and welfare of the general public or of the product's
user, over cases involving a small number of products, Mr. Gimer indicated concern.
(346-348)
402
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CEDAR RAPIDS HEARING
77-8-911-CH Oral Statement
Bruce Anderson
representing 1. Mr. Anderson observed that noise is a serious
Senator Dick Clark problem that "deserves more attention" (9)
2. Mr. Anderson expressed support for the noise labeling program, and noted that the
success of the program is partially dependent on educating consumers about the seriousness
of the problem. (10)
3. Mr. Anderson urged EPA to utilize existing Federal, state, and local consumer protection
agencies and other consumer advocate groups to help educate consumers. (10)
Response to Questions from EPA Panel: Mr. Elkins
4. Mr. Anderson indicated that regulations, if sensible and to the point, would not be
burdensome. (11)
77-8-912-CH !• Ms. Boyse observed that noise is a serious
representing problem, though a subjective one. (13)
Congressman Michael Blouin
2. Ms. Boyse commented positively on the Agency's "good-faith effort" in developing
labeling standards. (14)
3. Ms. Boyse urged the use of common sense and sound judgment, as well as careful con-
sideration of economic costs, in the enforcement of noise regulations. (14)
Response to Questions from EPA Panel: Dr. Shutter
4. Ms. Boyse supported the use of a maximum noise rating on the label (16)
403
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77-8-913-CH
Dr. Charles Anderson
American Speech and Hearing
Association
Oral Statement
1. Dr. Anderson noted the increase in the level
of noise and its negative impact on communi-
cation and general health. (20-22)
2. Dr. Anderson stated that it has been the clinical impression of audiologists that the inci-
dence of high-frequency hearing loss is on the icnrease. Such hearing losses are subtle and
very difficult to detect. (23-24)
3. Dr. Anderson cited concern among consumers about the effects of noise. (24)
4. Dr. Anderson expressed support for noise labeling and regulation and suggested that
noise labels also include the frequencies involved in the noise level, since these frequencies
have a differential impact on hearing loss. (24-25)
5. He recommended a public information program which would serve to enlighten the consumer
about the value and usefulness of noise ratings. (25-26)
Responses to Questions from EPA Panel: Mr. Thomas
6.
7.
Dr. Anderson indicated that hearing loss is not the only health hazard that results
from noise exposure, but that studies have shown high correlations with peptic ulcers
and hypertension. (27)
He mentioned that it is not easy to establish a causal relationship between hearing loss and
noise and discurred the problems caused by the complexity of people's habits and their
tendency to change their behavior once they are aware they are being tested. (28)
Mr. Kozlowski
8. Dr. Anderson suggested certain criteria for choosing the products to be labeled: level of
noise, number of people affected and the frequency with which a product is replaced
(29-30)
Mr. Thomas
9. Dr. Anderson supported a uniform noise measure for all products to facilitate comparisons
(31-32)
404
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10. He felt that eventually a maximum rating was desirable in addition to the average
rating. (32)
Mr. Ricci
11. Dr. Anderson recommended use of the mass media to help educate the public, in addition
to utilizing the service organizations that exist to help spread materials. He indicated
that based on his experience, people will respond when provided with information. (33-34)
Mr. Elkins, Mr. Kozlowski, Mr. Thomas
12. Dr. Anderson mentioned a case in the University Hospitals' files where permanent hearing
loss followed the use of a chain saw. (34-35)
Mr. Feith
13. Dr. Anderson cited the high incidence of health problems among persons living near airports
as an example of a noise related health problem. (36)
Mr. Ropes
14. Dr. Anderson listed the SERTOMA Club and the Lions Club as service organizations
willing to help with the noise problem. (36)
77-8-914-CH Oral Statement
Representative Joan Lipsky
Iowa General Assembly 1- MS- Lipsky expressed her concern for noise
pollution and her belief that it should be sub-
ject to regulation. (38-39)
2. Ms. Lipsky expressed her opposition to the noise labeling program, because persons are
concerned only about the noise levels of machines operated by others. (39-40)
3. She felt that lowans do not want federal noise control, but appreciate EPA's assistance
in developing state and local programs. (40-41)
4. Ms. Lipsky maintained that labeling will increase costs to the consumer while confusing
him about their meaning and bringing no relief from the noise made by others. (41)
405
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5. Ms. Lipsky asked for the EPA's assistance in drafting noise legislation that is enforceable
and constitutional, in developing an enforcement mechanism, and in developing training
programs for enforcement personnel. (41-42)
Responses to Questions from EPA Panel: Dr. Shutler
6. Ms. Lipsky expressed her interest in the current EPA program to train police officers to
enforce noise regulations. (44)
Mr. Elkins
7. Ms. Lipsky disputed the utility of the labeling program, mentioning that it is difficult to
account for environmental noise. Enforcement of noise regulations, she argued, will
require technically trained persons. (46)
Mr. Feith
8. Ms. Lipsky responded affirmatively when asked if she advocated the establishment of
environmental noise levels rather than specific product regulations. (47-48)
9. She observed that consumers don't usually pay attention to the ingredients labels found
on food. (48)
Mr. Ropes
10. Ms. Lipsky expressed her appreciation for EPA's assistance with information in the past. (49)
77-8-915-CH Oral Statement
Larry Dupre
Illinois EPA 1. Mr. Dupre expressed his support for the proposed
Noise Technical Operations Center regulations because they would increase public
awareness and spur competition among manu-
facturers to decrease the noise level. (53)
2. Mr. Dupre suggested adding a footnote to the label to explain the scale being used. (53)
3. He recommended the use of consistent measurement techniques within each product
category. (53)
406
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4. Mr. Dupre expressed support for the regulation of mobile noise sources such as off-road
motorcycles, motorboats, snowmobiles, lawnmowers, chain saws and power model
vehicles as well as stationary products, such as resident air conditioners and ventilation
equipment, that affect third parties. (54)
5. Mr. Dupre suggested labeling consumer products such as hair dryers and vacuum cleaners,
in addition to labeling products such as mufflers which are sold on the basis of noise
reduction effectiveness. (54)
6. Mr. Dupre expressed his belief that the proposed EPA standards will assist the Illinois
noise control program by aiding enforcement and increasing public awareness. (55)
Responses to Questions from EPA Panel: Mr. Kozlowski
7. Mr. Dupre mentioned that noise level ratings on products being regulated would help
enforcement of the regulations. (55)
Mr. Feith
8. Mr. Dupre responded affirmatively when asked if the Illinois EPA receives requests from
consumers for information on the noise level of products. He indicated that the infor-
mation available is limited. (56)
Mr. Ricci
9. Mr. Dupre indicated that the most important time to have a label is at the time of purchase.
A permanent label would be beneficial in some cases, such as on a muffler, since it could
be incorporated into an auto inspection. (57)
Dr. Shutler
10. Mr. Dupre indicated that at the present time Illinois has no regulations regarding household
products and would be unable to enforce them. (59)
Mr. Elkins
11. Mr. Dupre suggested a rating scale for each category of products. (59)
407
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77-8-916-CH Oral Statement
Richard Worm
Environmental Coordinating 1. Mr. Worm spoke about products whose noise
Association levels have been a source of irritation for him:
his neighbor's air conditioner, lawnmowers,
motor vehicles, the ventilation system at the school where he works, office machines such as
typewriters, coffee machines and blowers. (66-71)
2. He discussed the notion that attitudes toward noise develop when one is quite young.
(71-72)
3. Mr. Worm expressed support for the product noise labeling program. (75-76)
Responses to Questions from EPA Panel: Mr. Ricci
4. Mr. Worm suggested that labeling would help to educate the public. The public is not
totally economy-mineded. (78-79)
5. Mr. Worm supported the idea of a label affixed directly on the product. Persons are not
inclined to put much work into purchasing a product so information must be easily
available to the public or it is not likely to be widely utilized. (79-80)
Mr. Ropes
6. Mr. Worm, as a 9th grade teacher of Earth Science, responded positively when asked what
he though of a module concerned with educating children about noise. (81)
77-8-917-CH 1. Mr. Kamps indicated that between 20 and 30
Vern Kamps percent of the persons over 55 for whom his
American Association of association attempts to find employment have
Retired Persons some degree of hearing loss. Most of these
persons were exposed to excessive noise levels
in factories in the past. (82)
2. Mr. Kamps spoke about the button factory in which he has been employed and the high
noise level in that factory. (82-83)
408
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Response to Questions from EPA Panel: Mr. Ropes
3. Mr. Kamps stated that he values quietness in a product, indicating a noise label would
affett his purchasing decision. (83)
4. In response to a question, Mr. Kamps indicated that persons exposed to factory noise
really never realized the danger. (84)
5. Mr. Kamps indicated that he was unaware of anyone from the federal government, such
as OSHA, enforcing any sort of noise regulation in his factory. (85)
Mr. Feith
6. Mr. Kamps stated that no one in his factory had worn hearing protectors. (85)
77-8-918-CH Oral Statement
Willis Lueders
Transparent Film Workers Union 1. Mr. Lueders spoke at length about the hearing
protection program in the Dupont factory where
he is employed. He mentioned the management's efforts to cut down on the noise level by
installation of carpeting and acoustical tiling, a yearly physical which includes an audiogram,
clear indication of the instances in which one must wear a haring protector, the methods for
monitoring exposure time and the use of mufflers on machines. (86-93)
Responses to Questions from EPA Panel: Mr. Kozlowski
2. Mr. Lueders thought that unions could and should "sell" the idea of the need for quieter
equipment to their members. (93-94)
Mr. Elkins
3. Mr. Lueders mentioned the importance of good communication between the employees
and the management. (95)
Mr. Ropes
4. Mr. Lueders mentioned a take-home safety program that also existed in their plant. (96)
409
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77-8-919-CH Oral Statement
Pat Dillan
United Auto Workers 1. Mr. Dillan seemed to feel that the law should
address itself to preventing noise in products
as they are manufactured rather than just mandating protection for employees. (100-104)
2. Mr. Dillan described the difficulties involved in getting compensation for a workman
who has suffered gradual but permanent hearing loss. (104)
3. From his experience, Mr. Dillan noted that excessive noise, even if one's ears are protected,
can lead to such health problems as indigestion, nervousness and migraine headaches. (105)
Responses to Questions from EPA Panel: Dr. Shutler
4. Speaking as a consumer, Mr. Dillan supported a public education program through the
media in addition to a labeling program. (108)
Mr. Kozlowski
5. Mr. Dillan indicated that increased costs should be passed on to the consumer and not the
worker, since quieter machinery is a cost of production. (108-109)
Mr. Feith
6. Mr. Dillan indicated that very little attention was paid by some plant workers to noise
warning signs placed in the working areas. (111-112)
Mr. Ropes
7. Mr. Dillan indicated that his union local would be delighted to assist in an educational
campaign. (112)
77-8-920-CH 1. Mr. Harwick discussed methods other than
Ed Harwick replacement of machines which could help
United Auto Workers to reduce noise in a factory. He suggested
mechanical changes as well as better maintenance. (114-115)
2. Employees in his factory complained about the uncomfortableness of all three hearing
protectors they were issued by the management. (116)
410
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7 7-8-921-CH Oral Statement
Ed Ryan
American Association of 1. Mr. Ryan argued that most of American
Retired Persons industry does not care about "people problems.'
(117-120)
2. He expressed support for a labeling program, particularly if there was an educational
program to back it up. (120)
77-8-922-CH 1- Mary Pickett stressed the fact that household
Mary Pickett appliances should be studied in the environ-
lowa State University Faculty ment in which they are used as well as in
isolation. (125-126)
2. She indicated that studies have shown that noise can be annoying and can produce stress,
but that no studies have demonstrated that physiological damage is related to interior
environmental noise. (126)
3. Related to this concern, Mrs. Pickett observed several'factors about the average American
consumer:
a. Middle and low income families are now being forced to buy cheaper dwellings
made from less expensive materials that vibrate more easily. (126-127)
b. Because of economic constraints, these families are more concerned about the
house than the appliances found in it. (127)
c. In addition, persons have different levels of sensitivity to noise. (127)
4. Mrs. Pickett stated her concerns about the cost of labeling, noting that the cost increase
will be passed on to the consumer who uses price as his parameter for purchase
decisionmaking. This has already been demonstrated with the energy-efficiency ratio
labeling which the consumer does not use because he does not understand it. Further-
more, the consumer still buys the cheaper product. (128-129)
5. Mrs. Pickett urged encouraging the building industry to consider house design in
terms of the appliances in the house. (130)
6. Mrs. Pickett felt that persons who service and install household appliances should be
educated to consider the surroundings of the appliance. (130-131)
411
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7. Mrs. Pickett observed that manufacturers are in the best position to do noise level
research, so that their support is needed. (131-132)
Responses to Questions from EPA Panel: Mr. Thomas
8. Mrs. Picket expressed her concern about the estimated one to two percent increase
in price that a labeling program would cause. (141)
Mr. Elkins
9. Mrs. Pickett's response to a question indicated that if she was given data to support the
fact that noise from household appliances causes physiological damage, she would not
question the \% increase in prices that could be caused by the program. (142)
10. Mrs. Pickett urged that attention be focused on the effective management of appliances.
77-8-923-CH Oral Statement
Tanya Wesley
Student 1. Ms. Wesley expressed her reluctance to pay
for the noise abatement program. (143)
2. Ms. Wesley argued that the quieter products are higher in price and are not being purchased
by the consumer. (144)
77-8-924-CH 1. Mr. Harris expressed the Case Company's
John Harris support for "reasonable labeling of products
J. I. Case Company as to noise levels." (152)
2. Mr. Harris suggested several factors he considered to be important for the success of the
program: the necessity for educated consumers who are aware of the noise program, a
uniform and repeatable product noise measurement procedure and a situation in which
manufacturers are allowed to develop quieter products competitively. (152)
3. The Case Company recommended that a reasonably permanent label be attached to the
product, the range of noise levels for a product class not be included on the label, the
test methodology be included on the label, and that the rating be expressed in dB(A)
and not an acoustic rating descriptor. (153-154)
412
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4. Mr. Harris cited the successful Nebraska program for testing noise emission levels of
agricultural tractors. As a result of the program, quieter products were produced through
competition. (155)
5. Mr. Harris felt that a uniform noise descriptor across product classes would be of
little comparative value, whereas a uniform descriptor within a product class is a
necessity. (157-158)
6. Mr. Harris indicated that EPA enforcement would not be necessary; industry can police
itself through competitive testing among manufacturers. (159)
7. Mr. Harris suggested that noise reducing products should not be labeled. (160)
Responses to Questions from EPA Panel: Mr. Elkins
8. Mr. Harris elaborated on the Nebraska program, emphasizing the positive impact of a
uniform standard. (161*162)
Mr. Thomas
9. Mr. Harris suggested that if a noise range must be included on the label, it should be
related to price range. (167-168)
10. Mr. Harris expressed opposition to providing a noise range on a product label. Such
information would be deceptive as far as the availability of all products. Comparative
shopping in an area would be more effective. (169-170)
Mr. Feith
11. Mr. Harris pointed to the market place as an effective mechanism for defining the
manufacturer's responsibility for the label. (171)
Mr.Ricci
12. Mr. Harris explained that consumer surveys used in the Nebraska program initially
indicated a preference for noisy tractors, but the availability of test results created a
demand for quieter tractors. (175-176)
413
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Dr. Shutter
13. Mr. Harris asserted that industry protocol and cross industrial testing provide a sufficient
incentive for compliance with EPA directives. (177)
14. Mr. Harris advocated the use of the mean value of the noise level and not the maximum
value. (183)
Mr. Kozlowski
IS. Mr. Harris favored voluntary action on the part of industry and utilization of the market
place to obtain compliance. (185-186)
77-8-925-CH. Oral Statement
Eldon Colton
Safety Commissioner 1. Mr. Colton elaborated on the experiences his
City of Cedar Rapids office has had with noise regulations. Cedar
Rapids had adopted and attempted to enforce
a noise regulation for motor vehicles that was subsequently struck down in court. This action
was taken because there was no legal authority for local regulation of noise. (192)
2. Mr. Colton stated that his office lacks effective means of enforcement under present
legislation. (192-193)
3. Mr. Colton thought there would be puclic support for a comprehensive noise ordinance
in Cedar Rapids. (195)
Response to Question from EPA Panel: Mr. Ricci
4. Mr. Colton stated that a labeling program would provide standards that their department
could use to enforce legislation. (196-197)
77-8-926-CH _ 1. Mr. Bach expressed support for noise abate-
lowa Department of ment programs, particularly the labeling
Environmental Quality program. (199)
2. He stated that a label should contain enough information to allow a consumer to decide
whether the noise level of a product should influence his purchase decision. (199)
414
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3. The noise level rating should also be somehow related to the consumer's health and
welfare. The inclusion of such information would enable the consumer to educate
himself over a period of time. (200-201)
Response to Questions from EPA Panel: Mr. Cerar
4. Mr. Bach mentioned a curricula on environmental education that is being developed for
statewide use, but stated there was no program to educate adults. (202-203)
77-8-927-CH Oral Statement
Dr. Claire Kos
Executive Director 1. Dr. Kos indicated that he was not speaking
American Academy of Ophthalmology officially for his organization.
and Otolaryngology
2. Dr. Kos noted that increased longevity means
that more persons have hearing impairments.
(210)
3. Hearing loss is gradual and incremental; once it becomes apparent it is too late to recover
what has been lost. (211)
4. Dr. Kos stated that excessively loud noises may compound physiological weaknesses, (211)
5. Dr. Kos noted that, according to scientists, the level of sound found damaging to the
ears varies due to differences found in human ears. (213)
6. Dr. Kos urged the adoption of warnings similar to those present on cigarette packages
since it is not possible at the present time to predict whose hearing will be impaired.
(215-216)
7. Dr. Kos felt that it is impossible to guarantee consumers' safety from products, and
that the public must be educated to understand the limitations in regulatory judgment.
(217)
Responses to Questions from EPA Panel: Mr. Elkins
8. Dr. Kos noted that the problem of noise in children may have a delayed effect. (219)
415
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Mr. Feith
9. Dr. Kos though that intermittent noise could cause fatigue in the ear muscles and
eventually, hearing loss. (221-222)
10. As a consumer, Dr. Kos felt that the amount of noise produced by a product is not as
important a consideration as the quality of the product. (223)
77-8-928-CH
Niel Van Hoef
Iowa Speech and Hearing Association
Oral Statement
1. Mr. Van Hoef expressed his support for the
proposed noise labeling standards. (226)
2. Mr. Van Hoef argued that the media, advertising, and other groups have confused the
public with respect to noise measurements. Efforts need to be made to standardize
noise measurements. (226-227)
3. Mr. Van Hoef suggested color-coding the acoustic desciptor on the label. (227-228)
Responses to Question from EPA Panel: Mr. Elkins
4. Mr. Van Hoef suggested the use of a sound-meter as a good means of educating the
public about noise and sound intensity. (232)
5. Mr. Van Hoef observed that it is impossible to know what other noise levels a person
has been exposed to during the day. Since it is possible that hearing damage is the result
of the cumulative impact of noise, it is important to let the consumer know what the
noise level of a particular product is. (234)
77-8-929-CH 1. Mrs. Sullivan commented on the level of
Judy Sullivan hearing impairment present today. An esti-
Consumer Education Coordinator mated 14 million Americans have suffered
Kirkwood Community College some type of hearing loss. The statistics
indicate a serious problem among young
people who have a high rate of high frequency hearing loss. (236-239)
2. Mrs. Sullivan expressed support for the labeling program, in addition to labeling regu-
lations in an attempt to control noise at the source. (239-240)
3. Mrs. Sullivan stressed the importance of consumer education. (240)
416
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Responses to Questions for EPA Panel: Mr. Thomas
4. Mrs. Sullivan emphasized the importance of the public right to be informed of the noise
level of a product so that a conscious choice is possible. (242)
5. Mrs. Sullivan compared the noise problem to other situations where warning labels are
required to indicate possible dangers to one's health. (243)
77-8-930-CH Oral Statement
James Klimes
Safety and Environmental Dept. 1. Mr. Klimes indicated the Deere Company
Deere and Company could support mandated noise labeling
programs "provided they are founded on
with need and administered in a reasonable and
meaningful manner." He urged the use of
Richardson Anderson existing voluntary labeling programs and
Attorney the encouragement of new voluntary programs.
(246)
2. Mr. Klimes stated that Deere and Company promote their products extensively on the
basis of the noise control measures incorporated into their designs. (248)
3. He expressed the Company's concern that EPA is expanding its legislative authority by
basing the decision of which products to label on individual perceptions and other
subjectively defined criteria. (289)
4. Mr. Klimes implied that labeling regulations can only be applied when there is factual
evidence that a capability for adverse effects exists. (249-250)
5. The purpose of labeling should be to inform product purchasers of potential adverse
effects. (250)
6. Given these constraints, he indicated that Deere and Company could foresee beneficial
uses of labeling, such as for identifying products capable of adverse effects, as comple-
mentary to reasonable noise level regulations or as an alternative to product noise level
regulations. (250)
Responses to Questions from EPA Panel: Mr. Elkins
7. Mr. Klimes implied that it is difficult to interpret the meaning of "health and welfare,
and criteria to determine this are not easily established. (254)
417
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8. Mr. Klimes indicated, based on the Congressional Record, that the primary concern of
Congress at the time of the passage of the Noise Control Act was with noise that could
produce hearing impairments. (254)
Mr. Thomas
9. Mr. Klimes said he would defer but would give some though to whether it should be the
purchaser or potential user who needed to be given noise information. (258)
Mr. Kozlowski
10. Rather than identify classes of products to be labeled, Mr. Klimes indicated that first
firm criteria for choosing products must be set and that each product must be weighed
against those criteria. (266)
Mr. Feith
11. Mr. Klimes responded affirmatively when asked if he would submit a list of the products
the Deere Company already labels for noise. (264)
(See Docket No. 77-8-738 for additional comments and responses to questions from
EPA panel.)
77-8-931 -CH Oral Statement
Marion Leese
American Association of 1. Mrs. Leese expressed support for noise abate-
Retired Persons ment. (270-271)
2. Mrs. Leese compared noisy products to products requiring danger warnings. (271)
Response to Question from EPA Panel: Mr. Elkins
3. Mrs. Leese stated that she would use quietness as one criterion for making a purchase
decision. She noted that her new vacuum cleaner is louder than her old one. (272)
418
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77-8-932-CH Oral Statement of Charles Edinger
Cleo and Charles Edinger
American Association of 1. Mr. Edinger Briefly elaborated on the noise
Retired Persons abatement program. (274-276)
2. Mr. Edinger expressed his support for the labeling program. (277)
Response to Question from EPA Panel: Mr. Elkins
3. Mrs. Edinger responded affirmatively when asked if she had noticed a distinct difference
between the amount of noise made by various brands of vacuum cleaners, and responded
negatively when asked if she would be able to determine the quieter product in the
store. (277)
Oral Statement of Geo Edinger:
4. Mrs. Edinger mentioned cars, trucks, trains and motorcycles as being major sources of
noise in her town. (278-281)
77-8-933-CH Oral Statement
Sheila Sidles
Executive Secretary 1. Mrs. Sidles stated that noise pollution has
Iowa Consumers League been a concern among many consumers she
has spoken with, though it has not been
one of the major concerns. (284)
2. Regarding noise-reducing products, Mrs. Sidles expressed strong support for labeling
which indicated the level of effectiveness of the product. She noted that certain products
are used to block out different noises in different instances. (285)
3. Mrs. Sidles stated that noise is sometimes necessary for safety, as it indicates that an
appliance is in operation. (285)
4. Mrs. Sidles indicated that cost and efficiency are the primary considerations for the
consumer. (286)
5. In cases where products can cause hearing damage, labeling is not sufficient. (286)
6. Mrs. Sidles mentioned the difference between products in duration of use and its
problems. (287)
419
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7. Mrs. Sidles stated that she was "not sure we are ready for mandatory noise labeling
and the enforcement that then would come with it." (287)
8. Mrs. Sidles suggested educating consumers concerning noise effects and methods for
handling noisy appliances. (288)
9. Mrs. Sidles expressed support for voluntary labeling by manufacturers rather than regula-
tion. (289)
Responses to Questions from EPA Panel: Mr. Kozlowski
10. Mrs. Sidles stated that one reason for her reluctance to see federal regulations imposed
is that such action makes an industry less competitive, since entry into the industry is
made more difficult for new firms because of increased costs. (292-293)
Mr. Cerar
11. Mrs. Sidles observed that there are many factors that concern a consumer. Noise may
not be a priority, but it is a very real concern, particularly with the increased incidence
of hearing loss. (294)
Mr. Thomas
12. Mrs. Sidles urged giving industries a chance to act voluntarily before making a program
mandatory. (296)
77-8-934 Remarks from the Floor
Pam Kidd
1. Ms. Kidd suggested'that as the public became
educated, industry would be forced to regulate itself because of demand. (297)
2. Ms. Kidd pointed out that independent testing companies are likely to develop as a
result of demand. (297)
420
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77-8-935-CH Oral Statement
Steve Keller
1. Mr. Keller observed that when industry makes
an addition to a label on its own impetus
(such as the Universal Product Code) there are few complaints about costs. (300-301)
2. Mr. Keller expressed his support for labeling products and regulating products which
affect a third party. (301)
3. Mr. Keller complained about the noise level of motor vehicles emphasizing the high
cost and short life expectancy of muffler systems. (303)
4. Mr. Keller expressed concern about the noise level he faces as an industrial worker. He
suggested that certain machines could be isolated and indicated that soundproofing
materials, such as those present in the office area of his factory, could be added to cut
down the noise level. (304-306)
Responses to Questions from EPA Panel: Mr. Thomas
5. Mr. Keller suggested that the label include an indication of how long the product will
maintain its noise rating. (309)
77-8-936-CH 1. Mr. Kammerer expressed Amana's support for
John Kammerer the noise labeling program because industry can
Product Manager operate better with uniform federal standards
White Goods of Amana Refrigeration than varying state standards. (313-314)
with 2. Mr. Kammerer pointed out that the goals of
Raymond Bowman the noise abatement program might conflict
Vice President of Engineering of with the energy efficiency goals of the FEA.
Central and Room Air Conditioning (314-315)
Products
3. Mr. Kammerer pointed out that Federal programs that were originally intended to be
voluntary, such as the FEA energy-efficiency program, have changed directions rather
suddenly. (316)
4. Mr. Kammerer mentioned two existing appliance industry noise labeling programs: The
Air Conditioning and Refrigeration Institute sound-rating program and the Association
of Home Appliance Manufacturers. Both of these programs could meet the four
criteria of the labeling program established by EPA with minimal effort. (316-317)
421
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Responses to Questions from EPA Panel: Mr. Kozlowski
5. Mr. Kammerer stated that the voluntary program for air conditioners, in its present form,
could not be applied to other products. Similar programs could be developed. (318)
6. Mr. Kammerer felt that industry is capable of policing itself. (319)
Mr. Elkins
7. Mr. Kammerer indicated that in those instances when Amana does have a sound rating
for a product, it is not listed on the product itself but on the specification sheets and
certification directory. (519)
8. Mr. Kammerer felt that listing the sound rating number on a specification sheet is
sufficient for central air conditioners. (319-320)
9. Mr. Kammerer expressed Amana's willingness to provide the noise rating on labels for
products, though he added that the testing facilities are largely occupied by energy
testing at the present time. (320)
10. Mr. Kammerer stated it was his experience that consumers are becoming increasingly
concerned about energy, particularly as energy costs increase. Consumers do utilize
energy labels. (320)
11. Mr. Kammerer indicated EPA's responsibility to educate the consumer to use the
label (322)
Mr. Feith
12. Mr. Bowman, a colleague of Mr. Kammerer, indicated that the noise rating number
provided on the specification sheet is not explained on that sheet, though such information
is available. The consumer is not furnished with information on room air conditioners.
(327)
13. Mr. Kammerer argued that if the public demands information on noise, the industry is
likely to provide it in a more accessible fashion. (328)
422
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77-8-937-CH Oral Statement
Kenneth Truce
1. Mr. Truce expressed concern with the level of
noise pollution found in all areas of the country. (332-333)
2. He observed that many Americans are seeking peace and quiet, though it is difficult to
find. (334-335)
3. Mr. Truce mentioned the situation where a person uses air conditioning as a means to
block out noise and filter the air. (336-337)
4. Mr. Truce expressed support for regulations but noted that industry tends to resent
regulations while consumers resent paying for them. (337-338)
5. Mr. Truce argued that consumers have a right to have noise information available, while
his experience with lawnmowers and refrigerators has indicated that it is not readily
available. (339-340)
6. Mr. Truce stated that noise increases stress on people. (341)
7. Mr. Truce argued that an educational program is needed. (341)
8. Mr. Truce suggested that noise demonstration in stores are unreliable, since a large
part of noise is contingent on the environment. (345)
77-8-938-CH 1. Mr. Dykstra submitted a report entitled
Dan Dykstra "Silencing the Roar-Should Iowa Enact
Student Noise Control Legislation?" which was
University of Iowa Law School written for the Iowa Senate Transportation
Committee. (353)
2. Mr. Dykstra stated that he had worked on the report as a member of the Senate Majority
Research Staff at the Iowa State Capitol. (353)
3. Mr. Dykstra stated that noise not only has physical effects, but emotional, social and
economic effects as well. (354)
4. Mr. Dykstra stressed the importance of considering household noise in addition to
environmental noise. Noise in the home adds stress to the lives of the family, who usually
return home to escape stress. (354-355)
423
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5. Mr. Dykstra mentioned that his recommendations lean toward "demanding industry to
quiet the goods." (355)
6. To effectively control noise, Mr. Dykstra suggested four steps:
a. Establishment of comprehensive national regulations for household products that
make noise. These regulations should be attainable by manufacturers. (355-356)
b. Adherence to the established regulations. (356)
c. Education of the American people about noise in general. (357)
d. Enforcement of all regulations, through a program which might include the
voluntary participation of households. (357)
Responses to Questions from EPA Panel: Mr. Thomas
7. Despite Mr. Dykstra's confidence in the American public, he did not believe that they
would utilize noise rating schemes because such schemes are difficult to understand.
(360-361)
77-8-939-CH Oral Statement
Lee Fisher
Grant Wood Area Education 1. Mr. Fisher indicated that his association has
Association hearing records for 5,100 school aged students,
7 percent of whom have experienced some
sort of hearing loss. Of those persons, 40 percent have high frequency hearing loss, with the
severity of loss varying widely. (365-366)
2. Mr. Fisher stated his belief that there is a direct relationship between noise exposure and
the hearing losses suffered by children. (367)
3. Mr. Fisher categorized noise sources: noise present in the household due to household
appliances, noise due to household tools, and noise to which exposure is voluntary,
such as recreational equipment or stereos. (367-368)
424
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4. Mr. Fisher indicated that high frequency hearing loss affects a person's ability to
discriminate between sounds and can be quite serious. (369)
5. Mr. Fisher indicated that the Grant Wood Area Education Association was finding
students whose ability to study was affected by this type of hearing loss. (369)
Responses to Questions from EPA Panel: Mr. Kozlowski
6. Mr. Fisher suggested that labeling would help increase public awareness, but it was
more important to establish maximum sound levels on products that are affecting
the hearing levels of children. (370)
Mr. Cerar
7. Mr. Fisher indicated that minor hearing loss in a child may become very serious as the
child reaches adulthood. (371-372)
Mr. Feith
8. Mr. Fisher stressed the importance of making the consumer aware of the frequency
range of a product, an element not included in the dB(A) measurement. (373-374)
425
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SAN FRANCISCO HEARING
77-8-940-SH Oral Statement
James Shone
Citizens Against Noise 1. Recommended that any labeling program be
Hawaii accompanied by an effort to inform the public
about the harmful effects of noise. (12)
2. Mr. Shone suggested some kind of rating for housing units themselves that would inform
purchasers about noise properties of design and construction. (13)
3. Effective noise labeling should include some indication "when a hazardous threshold is
crossed." (15)
4. Mr. Shone supported labeling of certain products (cars) both as a whole and also with
respect to their noise-producing components. (17)
5. Recommended color code for label with red being above 70 dB(A), yellow being between
50 and 70 dB(A), and green being under 50 dB(A). Mr. Shone also preferred, in addition
to the color, an appropriate description such as 'Very noisy." (18)
6. Mr. Shone suggested that labels be permanent, that warning lights be used on radio and
stereo equipment, that noise information be required on advertising, and that range
information be retained as in the sample label. (19-21, 58)
7. Mr. Shone opposed testing and export exemptions. (22)
8. Mr. Shone suggested products for labeling: typewriters and office equipment, high
frequency emitting equipment, toys, air conditioners, blenders, hair dryers, saws, power
tools, compost grinders, garbage disposals, dishwashers, refrigerators, etc. (23-26)
Responses to Questions from EPA Panel: Dr. Shutter
9. Mr. Shone believes strong federal enforcement is needed rather than relying on industry's
self-policing. (27)
10. Mr. Shone recommended that in labeling a product the maximum value of a series of tests
be used for the rating instead of the average value. (29)
Mr. Kozlowski
11. Mr. Shone recommended labeling in addition to emission standards for autos, garbage trucks,
buses, etc. (32)
426
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Mr. Elkins
12. According to Mr. Shone, one purpose of the product labels is to facilitate enforcement
by local officials, who can simply check a vehicle's noise label. (37)
Mr. Thomas
13. Mr. Shone encouraged the incorporation of some type of noise warranty, or acoustical
assurance period, into the label or other sales literature-suggesting the possibility of a
two-year warranty period. (45-46)
14 Mr. Shone saw no major problem in having labels permanently affixed to the product,
except for acoustic tile and esthetic considerations. (53-54)
15 Mr. Shone indicated that companies do not provide consumers with information on the
noise levels of their products. (60-62)
16. Mr. Shone noted there may be a serious problem caused by multiple labels. (61-63)
Mr. Feith
17. Mr. Shone noted that the quality of sound, affected by its periodicity or degree of
intrusion, is a factor to consider in a labeling program, and mentioned possibility of
incorporating sound quality into the rating scheme. (65-66)
18. Mr. Shone discussed the problem of using a color code when there may actually be two
noise measurements of importance-at the operator's ear and some distance away. (67-69)
Mr. Ricci
19. In response to a question concerning the noise rating on the label, Mr. Shone stated that
a 1 to 10 scale might be 'Very good," but also mentions the need for a word descriptor
such as "very noisy." (71-72)
427
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77-8-941-SH Oral Statement
Robert Friese
Chairman of Task Force on Noise Control 1. Mr. Friese expressed support for the labeling
San Francisco program and the idea of color coding. He noted
that duration of noise is an important factor to
with
consider in developing a noise rating, and
Cormac Brady mentioned Dr. Karl Kryter as a source of exper-
Senior Mechanical Engineer tise in this area. (80-82)
San Francisco Department of Public Works
2. Mr. Friese believed that the label should be per-
an(* manent, since this would assist enforcement
Officer Richard Podisco of locaj ordinances. In some cases, however, such
San Francisco Police Department ** household appliances, a permanent label may
not be practical. (83-84)
Responses to Comments from EPA Panel: Mr. Feith
3. To assist enforcement, a decibel rating is needed, according to Mr. Brady. He also mentioned
how the labeling program could benefit local enforcement efforts, particularly with
reference to construction equipment (e.g., on-site checks, evaluating degradation). (87-92)
Mr. Ricci
4. With respect to the issue of how to affix a permanent label to a muffer, Mr. Podisco indi-
cated that a stamping operation is required, with the number or lettering protruding
outward to prevent counterfeiting. Also, a heat-resistant paint could be used for the
muffler label's color code. (96)
Ms. Jordan
5. Mr. Friese discussed his group's public relations efforts, which included a noise annoyance
survey indicating that vehicular noise (buses, motorcycles, and trucks) elicited the greatest
number of complaints. (96-102)
Dr. Shutler
6. Mr. Friese preferred that the label's noise rating be derived from the maximum level a
product of a given type could emit rather than from an average number. (103-104)
7. Mr. Friese indicated that sirens should not be labeled; Mr. Brady noted that most complaints
were about the electronic siren, which was actually not the noisiest but had the most annoying
quality. Mr. Friese commented that it would be a mistake to limit the rating to dB(A)'s and
ignore the quality of the noise. (105-107)
428
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77-8-942-SH Oral Statement
Gerald E. Starkey
Santa Clara County 1. Mr. Starkey expressed support for the labeling
Environmental Management Agency program and nominated the air conditioner as
a primary candidate for noise abatement action.
He noted that, with many people keeping their windows open and with typical installation
conditions, the air conditioner poses a "formidable community problem." (110-113)
Responses to Questions from EPA Panel. Dr. Shutler
2. Mr. Starkey thought EPA labeling would provide incentive beyond the voluntary ARI
system in influencing ARI manufacturers'noise reduction efforts. (115)
Mr. Feith
3. Mr. Starkey, when asked to comment on label content, noted that a good approach was
to include a statement which notes the noise emitted by a quiet refrigerator or another
familiar product-a measurement that could be easily compared with the noise rating of the
product being purchased. (119)
4. Mr. Starkey listed common noise complaints: air conditioners, pool systems, and motor-
cycles. He will supply a more complete list at a later date. (119-121)
429
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77-8-943-SH Oral Statement
Judy Barnett
Concerned Citizen 1. Mrs. Barnett expressed support for labeling program
and commented on the results of her recent
research. (124-125)
Responses to Questions from EPA Panel: Mr. Elkins
2. She stated that homemakers would use the label information when purchasing certain
products. (127)
3. Mrs. Barnett suggested a public education program using magazines, newspapers, and
the local school system. (128)
4. Mrs. Barnett noted that she could not find information about the noise levels of
vacuum cleaners, refrigerators, blenders, and similar products. (129, 139-140)
Mr. Thomas
5. She listed products representing priority items for labeling: motorcycles, blenders,
garbage disposals, and vacuum cleaners. (130)
Mr. Ricci
6. Mrs. Barnett preferred using decibels on the label, didn't want a rating scheme which
makes comparisons between dissimilar products, and wanted a permanent label.
(133-135)
Ms. Jordan
7. Mrs. Barnett indicated that it would be useful if a brochure accompanied the product,
explaining how the noise measurement was taken, e.g., whether ice cubes or spinach
were being ground by a blender. (136)
430
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77-8-944-SH Oral Statement
Eric Mankuta
Director of Senior Citizens Community 1. Mr. Mankuta described the deleterious effects
Service Employment Program of noise pollution on the elderly. (140-143)
Response to Question from EPA Panel: Mr. Hkins
2. Mr. Mankuta believed from his own observations that the elderly have greater difficulty
sleeping than others and are easily disturbed by environmental noises. (143)
77-8-945-SH Remarks from the Floor
Marion Lockwood
Concerned Citizen !• Ms. Lockwood complained about the noise
from general aviation, military aircraft, and
leaf blowers. (143-149)
77-8-946-SH Remarks from the Floor
James Smith
Concerned Citizen 1 • Mr. Smith expressed support for the labeling
program. (151)
2. He felt the label should incorporate some type of comparative information to facilitate the
learning process about dBA's. (152)
3. Mr. Smith urged that the subjective quality of the sound be considered in the development
of a noise rating through the evaluation of a panel of noise experts. (153)
77-8-947-SH Remarks from the Floor
Robert Haehnel
Concerned Citizen !• Mr. Haehnel commented on the hazards of
stereo equipment (e.g., speakers and headsets),
suggested they be labeled, and recommended a warning statement similar to the one on cigarette
packages. (154-155)
2. Mr. Haehnel commented about the excessive noise at rock concerts and recommended
some kind of warning at the entrance or on the admission ticket (157)
431
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77-8-948-SH Oral Statement
Edward Lowe
California State Department of Health 1. The Office of Noise Control of the California
Department of Health supports the EPA in its
attempts to alert and inform consumers about the noise characteristics of products. The program
will also assist local noise enforcement by providing noise emission ratings on products, according
to Mr. Lowe. (164)
2. Mr. Low indicated that there was a conflict between the Background Document and NPRM
concerning label content and suggested that Area C contain two statements-one being
the ranee data, the other stating the noise level at which there is interference with speech.
He suggested that the "interference message" should use a single dBA value which is at the
safe (or lower) end of the range where such effects are experienced. Mr. Lowe also sug-
gested a similar interference message focusing on third-party effects, where the product
is likely to have an impact on neighbors, e.g., power lawnmowers and chain saws.
(165-166)
3. Mr. Lowe recommended that information be provided which describes the total noise
reduction effect when one product is used in combination with another product (e.g.,
mufflers and motorcycles). (16.7)
4. The noise rating label or brochure for air conditioners, filter systems for swimming pools,
and other products should indicate (1) noise ratings of similar products; (2) expected
ratings near the source; (3) ratings under installation conditions; (4) expected ratings
at a specified distance from noise source; and (5) noise levels in neighbor's yard. (167)
Responses to Questions from EPA Panel: Ms. Jordan
5. Mr. Lowe described his office's public education activities. (170-171)
432
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77-8-949-SH Oral Statement
Thomas Woods
President of Aural Technology 1. Mr. Woods, manufacturer of protective hearing
(Insert into Docket 77-5) devices, expressed support for the labeling pro-
gram and described a case where a person
exposed to noise at a recording company suffered extreme hearing loss. (178-179)
2. Mr. Woods expressed concern about the lack of interagency coordination and thus the
difficulty of satisfy ing different regulations. He also expressed concern about the
economic impact of the testing costs and objected to the authority of the Administrator
to order a compliance audit even when there was no evidence of non-compliance. (180-183)
3. Mr. Woods described the content of his company's proposed brochure. He stated that a
pressure-sensitive label which could be peeled off would cost about 3 cents per unit-a
reasonable price for a device costing S5.03/unit The cost of printing the sample brochure
he showed to the panel would be less than VA cents per unit, based on printing 100,000.
Costs for preparing camera-ready copy and graphics would be about $10,000, of which
$7,500 would be non-recurring expenses. The label could be done economicafly, he
asserted. His label also contained information on how to properly use the ear protectors.
(183-187)
Responses to Questions from EPA Panel: Mr. Thomas
4. Mr. Woods suggested that most companies in the hearing protective device industry would
not be reluctant to publish the noise attenuation properties of their products on a label,
though he admitted some would hesitate to do so. (190-192)
5. Mr. Woods suggested that the "label" information be required in advertisements directed
at industrial consumers of hearing protectors. (193)
6. Mr. Woods said the name of the company which introduces the product into commerce
should be on the label and not the original manufacturer. Annual reports represent a
means of tracking down the true manufacturer. Mr. Woods responded negatively when
asked if he saw any problem in repeating the company's name both on the packaging
and on the label. (196-200)
7. Mr. Woods felt the EPA logo should be on the label but noted that this carries with it
an explicit endorsement of the validity of the information by EPA. (201-202)
8. He suggested that it is important for EPA to require on the label information about the
likely degradation of the attenuation capabilities of hearing protective devices. (204-206)
433
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77-8-950-SH Oral Statement
Dr. Henry Schmitz
Audiologist, Hearing and Speech Center 1. Dr. Schmitz noted that the American Speech
of Orange County and Hearing Association supports the labeling
program. (208)
2. Dr. Schmitz recommended that the program focus initially on products used by children:
firecrackers, cap guns, minibikes, air horns, etc. He said high frequency hearing loss in
children is well documented and highly disturbing. In his opinion, an aggressive educa-
tional program directed at school-age children is a definite; "must." (209-210)
3. There are measurement problems with respect to air horns; the angle of incidence and
distance from the noise source are key factors. Any labeling requirements should con-
sider factors such as distance and duration in addition to dBA's. According to Dr.
Schmitz, accurate measurement of air horn noise requires a storage oscilloscope, probe
microphone, and a reflective and reverberant environment. (210-212)
Responses to Questions from EPA Panel: Mr. Kozlowski
4. Dr. Schmitz did not include stereos on his list of dangerous products, because the nature
of the hazard depends greatly on how the product is used—for example, distance from
loudspeakers and duration of listening are key. He claimed most children are not exposed
to rock music long enough to present a serious problem. In sum, the difficulty of taking
into account these variables argues against labeling stereos. (214-216)
Mr. Feith
5. Dr. Schmitz recommended that EPA concentrate on children's toys and adopt a hard-line
approach, because of the possibility that infants are "more sensitive to noise-induced
hearing loss and acoustic trauma than adults." For toys, he suggested the inclusion of
a general statement on the label such as: "Beware of the fact that the infant's hearing
is very sensitive and can be damaged by toys that make a lot of noise, such as this one."
Manufacturers should also indicate the amount of time the toy can be used safely.
According to Dr. Schmitz, the danger level for children should be much lower than for
adults, i.e., in the area of 65 dBA's. (217-222)
Mr. Thomas
6. Dr. Schmitz mentioned other products posing a serious health hazard for the operator
due to their noise emission levels: snowmobiles, tractors, saws, diesel trucks (for
mechanics), jack hammers, and shredders. (220-221)
434
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77-8-951-SH
James Adams
Environmental Protection Officer
City of Boulder, Colorado
Oral Statement
1.
Mr. Adams described noise ordinances and enforce-
ment procedures in Boulder, Colorado. The city
addresses two areas of noise control: vehicular and
non-vehicular. For vehicles under 10,000 Ibs., 80 dBA is the maximum permissible level, while
88 dBA is the limit for vehicles over 10,000 Ibs. (226-229)
2. Mr. Adams described "soft fuzz" enforcement approach, where the city recommends dismissal
of summons if the vehicle is brought into compliance. (229-230)
3. Of 3,882 summons issued, 2,950 (76 percent) were for automobiles; 815 (21 percent) for
motorcycles; and 116 (3 percent) for trucks. In 95 percent of the cases, the vehicle was
brought into compliance. The vast majority of auto complaints were due to non-stock
exhaust system components-glass packs (2,383) and side pipes (481). (230-231)
4. Mr. Adams outlined results of citizen noise surveys conducted in 1969 (221 responses),
1972 (841), and 1975 (1,221). Noise sources eliciting the greatest number of complaints
in 1969 were as follows (starting with the worst offender):
1. Motorcycles
2. Motorbikes
3. Barking dogs
4. Automobiles
5. Jet planes
1972 Survey Results:
1. Motorcycles
2. Trucks
3. Automobiles
4. Barking dogs
1975 Survey Results:
1. Motorcycles
2. Traffic
3. Barking dogs
4. Power mowers
(232-233)
6. Rock Bands
7. Large trucks
8. Lawnmowers
9. Chain saws
5. Buses
6. Sirens
7. Stereos
8. Aircraft (all categories)
5. Stereos
6. Dishwashers
7. Chain Saws
8. Vacuum cleaners
435
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5. Mr. Adams discussed the problem of motorcycle noise. He felt the components of motor-
cycle exhaust systems should be labeled—both stock and after-sale accessory items. As
far as stock equipment is concerned, the manufacturer's I.D. on the label can refer to the
company introducing the total product into commerce—for example, Harley Davidson.
However, for after-sale accessory items, the original manufacturer's name is definitely
needed on the label. (234-235)
6. Mr. Adams commented on the equipment responsible for excessive automobile noise—glass
packs and side pipes. (235-238)
7. Mr. Adams prioritized items requiring labeling or noise abatement action (worst is first):
1. Motorcycle exhaust system 4. Power equipment (chain saws, edgers, etc.)
a. Stock items 5. Home appliances (vacuum cleaners)
b. After-sale accessory items 6. Sound power amplifier
2. Automobiles 7. Aircraft
a. Glass packs a. Concorde
b. Side pipes b. FAR 36 jets
c. Extractors c. General Aviation
3. Barking dogs 8. Large trucks
(235-239)
8. Mr. Adams made a series of recommendations concerning labels for:
1. Exhaust system components (mufflers)
a. Type (glasspack, steel baffles, etc.)
b: Engine size (displacement, e.g., not to exceed 350 cu. in.)
c. Use (singly or in pairs)
d. dBA Reading ( @ feet)
e. Life expectancy (number of months)
f. Penalties for misapplication
2. Motorcycle exhaust systems
a. Type (stock systems, after-sale accessory systems, baffle sets)
b. Engine size and type (for use on: )
c. Life expectancy
3. Power equipment
a. Engine size
b. Engine stroke
c. Degradation
436
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4. Sound power amplifiers
a. Warning about hearing damage
b. Outdoor versus indoor use
5. Aircraft
a. In-cabin noise level
(241-247)
9. Mr. Adams urged the use of dBA for the descriptor in order to further consumer learning.
(242)
Responses to Questions from EPA Panel: Mr. Ken
10. Mr. Adams commented that the label on motorcycles would assist monitoring at the
annual state vehicle inspection. In relation to issuing citations, the label might
help identify violators but a measurement would still be taken by the officers. (249-50)
11. Mr. Adams agreed with Mr. Kerr that the label for motorcycle exhaust system components
should include the name of the manufacturer of the bike on which the muffler would apply.
(250)
Mr. Cerar
12. According to Mr. Adams, the majority of violators who have glass packs and side pipes
on their automobiles are actually trying to increase their vehicle's noise level. (251)
Mr. Feith
13. Mr. Adams noted that construction equipment noise labels would assist enforcement
efforts by telling the officer what level of noise the product should be emitting.fand
thereby making possible the determination of whether or not a new exhaust system would
be one way of reducing noise emissions. (256-257)
Mr. Ricci
14. Mr. Adams suggested a permanent label on mufflers, which should somehow be placed
in an area that is clearly visible to an enforcement officer. (258)
Ms. Jordan
15. Mr. Adams described Boulder's public education campaign. (258-260)
437
-------
77-8-952-SH Oral Statement
Dennis Paoletti
Paoletti/Lewitz/Associations 1. Mr. Paoletti expressed support for the labeling
program and the proposed label, but suggested
that a color code be used. (268-269)
2. He expressed support for a permanent label. (270)
3. Mr. Paoletti recommended that the labeling program include as one of its objectives the
elimination of false, unsubstantiated noise-related claims of manufacturers. (270)
4. Mr. Paoletti recommended labeling for the following products: typewriters, vending
machines, other office equipment, suspended ceilings, fixed wall systems, doors, and
windows. He commented that the testing procedures of ASTM suffer from the signifi-
cant acoustical difference between a laboratory setting and the real office environment
When a component is used in conjunction with other labeling products, Mr. Paoletti noted
the Sound Transmission Class value is useless. (217-273)
5. He suggested a phased program of labeling, beginning with the more easily-rated products
(e.g., household appliances) and moving later to large, complex pieces of equipment and
building materials used in combination with other materials. (274)
Responses to Questions from EPA Panel: Mr. Thomas
6. In relation to acoustic tile and building material, Mr. Paoletti suggested the need for a sim-
plified noise rating directed at consumers and the products they use rather than one for build-
ing engineers and designers if the consumer does not need a rating on such material. (278-280)
Mr. Feith
7. Mr. Paoletti commented on the limited utility of manufacturers' ratings of building
materials, due to the manipulation of measurement methodologies. He suggested EPA
develop a uniform rating method and monitor the testing of products. (284-285)
Mr. Kerr
8. Mr. Paoletti acknowledged the potential benefit of acoustic tile noise-reduction ratings to
the individual consumer. (288)
Mr. Kozlowski
9. Mr. Paoletti indicated that testing became "a numbers game," where competitors respond by
further manipulating testing conditions to attain a better rating. (289)
438
-------
77-8-953-SH Oral Statement
Al Perez
Minnesota Pollution Control Agency 1. Expressed support for the labeling program,
commenting that present market does not
allow the individual to make intelligent product choices. (290)
2. Mr. Perez noted there are extreme abuses associated with manufacturers' use of noise
measurement data. (291)
3. Mr. Perez stressed the importance of guarding against a misinterpretation of the label
which equates the EPA logo with certification or approval of the product's noise level.
(291)
4. Mr. Perez suggested using dBA's, which can be understood by the public, for the rating
on the label, but not "sound pressure level" which is "not contained in the weighting."
He indicated that sound power levels require extensive testing facilities and are therefore
meaningless to local enforcement officials. His preference is for "sticking to a simple
dBA versus distance scheme." (292-293)
5. Mr. Perez stated that air conditioners should be a first priority for labeling and expressed
support for permanent labels and a color code. (291-293)
6. Mr. Perez commented on the fraudulent activities of testing labs and the tendency for
manufacturers to choose ideal products for testing. (296-297)
7. Mr. Perez opposed (1) the provision for 24-hours prior notice before entering manufacturing
facilities for compliance testing and (2) the need for a "substantial" infraction before
remedial action is taken. He believed these provisions are too lenient. (297)
8. Mr. Perez suggested that to facilitate the selection of products for labeling action, a matrix
be developed which organizes products by the following categories:
1. Those affecting the user only, those affecting the receiver only, and
those affecting both.
2. Stationary versus non-stationary sources.
3. Constant operation versus intermittent operation.
(298)
9. He listed various products presenting noise problems: air conditioners, air-moving equipment,
outdoor power equipment, off-the-road vehicles, mufflers, snowmobiles, acoustical materials,
doors, windows, toys (e.g., "Raw Power"), sirens, etc. (299-303)
439
-------
10. He recommended that EPA postpone the difficult issue of product degradation until a
later date. (302)
Responses to Questions from EPA Panel: Mr. Kerr
11. Mr. Perez responded that the labels would greatly assist local enforcement efforts. He
also said the label should include a statement that reads: "for information purposes
only," so there is no implication of an EPA endorsement of the noise level. He empha-
sized that EPA should assure the label information is accurate, since its logo implies an
endorsement of the data's accuracy. (307-311)
12. Mr. Perez commented that if the testing methodology is simple, local officials can assist
in monitoring the label ratings for accuracy. (313)
13. He expressed opposition to the idea of a statement on the label in lieu of the EPA logo,
which says the rating was determined through a test required by EPA. Also, he felt that
a strictly-enforced program with few products was preferable to a weak program requiring
labels on numerous products. (313-315)
14. Mr. Perez recommended the labeling of non-powered equipment that serve essentially
the same function as powered equipment, when the latter is made subject to labeling.
(318)
77-8-954-SH Remarks from the Floor
Mr. and Mrs. Crazier
French Laboratory 1. Mr. Crozier, a manufacturer of custom-molded
hearing protectors, suggested that labeling take
into account factors like comfort, hygiene properties, and the appropriate fit. He noted that
an attentuation rating based on laboratory subjects is meaningless (and misleading to consumers),
since there are variations hi the structure of the human ear and protectors will not function
properly unless they are built to correspond to these variations. (325-326)
22. Mr. Crozier suggested a statement for the label (or brochure) which emphasizes that the
amount of attenuation an individual will derive from the product is based on a proper fit.
Factors-affecting the "fit" are ear canal configuration, haircut, eyeglasses, etc. (330-332)
3. Throughout Mr. Crozier's discussions with EPA panel members, questions were raised about
the validity and reliability of test procedures used by laboratories to rate hearing protectors
(e.g., ASA 1-1975). (326-334)
440
-------
4. Mr. Crozier explained that even if certain information cautions the user about the need
for a proper fit, there are serious problems because of the average person's ignorance
about what constitutes a "proper fit." (336)
5. Mrs. Crozier suggested there may be a serious problem raised by fraudulent activities of
test labs, working in collaboration with manufacturers. (341)
6. Mrs. Crozier cited the problem of an inaccurate label remaining on a product which has
undergone repairs affecting its noise properties. (343)
77-8-955-SH Oral Statement
Dr. Michael Kavanaugh
Public Interest Economics Center 1. Dr. Kavanaugh felt that because of the increasing
sales of noise-emitting products and the energy-
related movement of persons to densely populated areas, the costs of noise in terms of productivity
losses would increase in the future. Also, many on-the-job accidents and their costs can probably
be attributed in part to the disruptive, annoying impact of noise. (349-350)
2. Therefore, Dr. Kavanaugh felt that the provision of information about noise via a label,
though it may exact some costs, will help to make the market mechanism operate more
effectively. (351)
3. Because of the externalities associated with noise, Dr. Kavanaugh recommended a
system of taxes that will raise the prices of noisy goods and make the consumer pay the
full costs of the product. His position was that a tax system has many advantages over
a labeling program. (353-354)
441
-------
APPENDIX B
INDEX OF WRITTEN DOCKET SUBMISSION
AND PUBLIC HEARING TESTIMONY
-------
INDEX OF WRITTEN DOCKET SUBMISSIONS
Docket No. Person Organization
77-8-001 Larry Woods
002 Leona and Karl Wflhelmsen
003 Richard Grunow
004 Horace MacMahan
005 Mrs. Peter Hullin
006 Rhonda Beasley
007 Burt Fisher
008 John Statler
009 Vann Ellis
010 Jose Aspitarte
011 Jack Cirrencione
012 Archie Frank
013 Chester and Edna Darnell
014 Mrs. W. W. Lynch
015 Mrs. Arthur Klavans
016 Charles Wilson
017 Helen Williams
018 Phyllis Roberts
019 Charlotte Ackley
020 Glenn Kiringer
021 Parks Ladd
022 Daryl Schroder
023 John Cutshall
024 JonHelberg
025 Robert Northrop City of Trenton
026 Kenneth Piercy
027 Dennis Kortman
445
-------
DocketN°- Person Organization
7 7-8-028 Dodie Wheeler Haus
029 James Mogan, Ted Richardson
030 Mrs. E. G. Koch
031 Freda Bertagnoli
032 Dan Olsen
033 Ruth Jubach
034 Edward Golick
035 Joseph Shepherd
036 Thomas Evans
037 Thomas Erickson
038 Allan Callander Astrocom Electronics
039 E. R. Milholen
040 L. Risnain
041 Emmett Joseph
042 Disgusted Citizen
043 Concerned Citizen
044 Reba Roberts
045 C. Schuster
046 W.M.Wilson
047 Mary O'Neal Broida
048 Frank Ecklin
049 Joe McCartney
050 Larry Bernstein
051 Morris Tenenbaum
052 John Connolly
053 Patrick Holychuk
054 John Race
055 Robert Casper
056 Jack Ruefseaun
057 Leonard Hernog
058 James Bogar
446
-------
Docket No.
Person
Organization
77-8-059
060
061
062
063
064
065
066
067
068
069
070
071
072
073
074
075
076
077
078
079
080
081
082
083
084
085
086
087
088
Mrs. David Butler
France Ledford
Anna Moss
Mrs. R. A. McDonals
Daniel Shoemaker
Hunter Heath
Raymond Mahr
Earl Benham
E. A. Paklke
Shiryl Mastalesh
Mrs. Vemon Wall
J. E. Lilly
Marie Harrington
Lawrence Bates
Velma Bredberg
George Christensen
John Betzo
Dorothy Stewart
Dr. Audrey Oaks
Anita Rhein
James Dickey
Mrs. Alice Banner
Mary Zaehringer
Clifford Roth
Mrs. Douglas Nock
E. M. Dunbar
Illegible
Harley Reabe
B. M. Rathbun
James V. Neely
James Neely Nuclear Power Con-
sultants, Inc.
447
-------
Docket No.
Person
Organization
77-8-089
090
091
092
093
094
095
096
097
098
099
100
101
102
103
104
105
106
107
108
109
110
111
112
113
114
115
116
117
118
119
Mr. and Mrs. George L. Morgan
Esther Schneider
Marietta Smith
Paul Gitchel
Violet Taylor
John W. Griffiths
Syma Talvitic
Philip Ritter
Dr. Stephen Konz
Sam Earl Esco, Jr.
Lloyd Doyle
Sherwin Wood
Lester Moore
George Hinsdale
Mrs. Herbert Layman
L. C. Veterseher
Unsigned
Eilean Brain
Fernando Curth
Norman Quinn
Phil Brown
Leola Edgerton
Mildred Guinessy
Mrs. Clark
Joseph Anderson
Margarette Gallagher
A. Mauk
Morris Barnes
Albert Mastee
Paul Dici
Sally Ann Button
448
-------
Docket No.
77-8-120
121
122
123
124
125
126
127
128
129
130
131
132
133
134
135
136
137
138
139
140
141
142
143
144
145
146
147
148
149
Person
David Benforado
Mrs. and Mrs. F. Miller
C. B. Link
Kenneth Young
Susan Britt
William Bering
Mrs. Norman Solomon
John Critchley
Harry Freeman
Dorothy (Illegible)
Theresa Wright
Mary Neuman
M. L. Brubaker
Arthur Simpson
Harry Rocco
F. Schoelich
Mrs. J. O'Brien
Kathleen Canzaro
Marc Prass
John Gardner, M.D.
Mrs. George (Illegible)
Burt Collins
Ray Chapman
J. M. Breiburger
AnneBalas
Robert D. Barnes
R. L. Hastueau
Allen H. Shiner
Lee Nolfe
Rodger Ringham
Organization
3M Company
Shiner Associates
International Harvester
449
-------
Docket No.
Person
Organization
77-8-150
151
152
153
154
155
156
157
158
159
160
161
162
163
164
165
166
167
168
169
170
171
172
173
174
175
176
177
178
179
G. Bailie
Mrs. Hugh McKenna
H. W. Wehe
Unsigned
Hazel Spitze
Louise Green
Dorothy Brohe
Harry Harper
Mary Deysher
Thelma Smith
Joanne Gerety
Mrs. Albert Huber
Mrs. Anne Plucks
Mrs. D. Fisher
E. J. Kozminski
R. J. Roney
Mrs. W. Marshall
Mrs. Roger Balgard
Lucille Williams
Mrs. Herman LaDay
Michael Percy
Gina Powell
Phyllis Kozewski
Kathrine Rudolph
Wfflard Stigler
Ellen Taylor
June Lautt
J. A. Rombough
Overlay Manufacturing Company
Rapistan, Inc.
City of Mountain View, California
450
-------
Docket No.
77-8-180
181
182
183
184
185
186
187
188
189
190
191
192
193
194
195
196
197
198
199
200
201
202
203
204
205
206
207
208
209
Person
Warren Cast
Virginia Stilo
Mrs. M. B. Commons
Illegible
Mrs. J. Cripe
B. E. Patterson
Stella Olekra
Lawrence A. Slotkel
Jeanne Allen
Mildred Knobloch
Mrs. Frank Miltner
Draza Kline
Nel Jones
Edgar Lion
Mrs. Walter P. Krueger, Jr.
Evelyn Kaye
R. S. Morgan
A. Gerald Reiss
John D. Kramer
Virginia Smith
Sarah Leach
David Rankin
Unsigned
Margaret Lockler
Geroge Hunt
Richard Bolin
Harry Barter
Mr. and Mrs. Paul Rorda
Helen Pratt
Florence Kumicki
Organization
Cast Manufacturing Company
Fasco Industries
Illinois Department of Transportation
451
-------
Docket No. Person Organization
77-8-210 JohnBrubaker
211 Irving Frank, M.D. and Rosanne
Frank, R.N.
212 Phiffis H. Rosenthal
213 Glover Weiss
214 Robert Bogan
215 D. Me Andrews
216 Mrs. Eugene Emerson
217 Mrs. William Person
218 Mrs. Arthur Smith
219 Sylvia White
220 Michael Saija
221 S. Pelletier
222 Joanne Flock
223 R. Lansky
224 Dawn Weiss
225 Les Bradley
226 Rachel Riley
227 Harold Taylor
228 Bob Londergan
229 David Sullivan
230 W. Cox
231 John Moore
232 Mrs. D. E. Coward
233 Mr. and Mrs. Theodore Adams
234 Prof. Richard Morse
235 Wilhelmina Smith
236 E. Camen
237 Mrs. E. P. Geaque
238 Tom Meskan
452
-------
Docket No.
Person
Organization
77-8-239
240
241
242
243
244
245
246
247
248
249
250
251
252
253
254
255-
256
257
258
259
260
261
262
263
264
265
266
267
268
Kathleen Johnson
Thelma Coren
John D. Hopkins
Mrs. D. Klompus
Laurance Conti
Mr. and Mrs. Mike Main
Joseph Famulary
Lois Seegal
Michael Ramage
Mrs. G. Miller
H. Shilton
Edna Denton
Claire Pichette
Gabor Usbau
Helen Von Ehrenkrook
Ms. Kuniko Sato
Mrs. Paula Schreiner
niegible
Chuck Howell
Mr. and Mrs. Harry Oldinburg
Priscilla and Eugene Challed
Mrs. John Simoni
Zane Saunders, M.A.
Francois Louis
Dorothy Shannon, Ph.D.
F. W. Hetman
Jane A. Baran
Rev. Henry M. Biggin
Mrs. Lester Wiggins
RoyW. Muth
Environment Agency, Tokyo, Japan
Newington Children's Hospital
Renault, USA
Sinai Hospital of Baltimore
DeVac, Inc.
Indianapolis Speech and Hearing Center
International Snowmobile Industry
Association
453
-------
Docket No. Person Organization
77-8-269 Beth A. Brown
270 Mr. and Mrs. Larry Pinkston
271 Maria Henessh
272 Raymond F. Anderson
212 (Misnumbered) Michael E. Paul, Sr.
273 Ali Ragle
274 David and Eileen Garland
275 Claire Grossman
276 Judith Schlager
277 Mahlon E. Sipe
278 M.Grossman Peugeot
279 Mrs. Roy Higdon
280 Martha Mathews
281 Joe Swift Mercury Marine
282 Donna McCord Dickman, Ph.D. Metropolitan Washington COG
283 Lt. Jim Anderson Rapid City Police Department
284 Richard M. Snyder
285 George M. Gorman
286 EmmaNiemann
287 John P. Reardon Air Conditioning and Refrigeration
Institute
288 M. L. Downs
289 G. C. Simpson
290 Sue Vogelsanger
291 Jules A. Kaiser
292 F. K. Foster
293 Leila Aiken
294 Winston L. Mani
295 Esther Mary Lippard
296 Toshio Kitamura Japanese Government
454
-------
Docket No.
Person
Organization
77-8-297
298
299
300
301
302
303
304
305
306
307
308
309
310
311
312
313
314
315
316
317
318
319
320
321
322
323
324
325
326
T. J. McCann
Vincent Argondezzi
G. M. Hoch
Mrs. Arthur Klavans
James P. O'Donnell
Jerry Boyle
James E. Wingert
John R. Race
John T. Hughes
Gerald E. Starkey, P.E.
F. E. Powers, Jr.
Leona and Karl Wilhelmsen
Emmett Joseph
L. K. Lepley
Roland D. Junck
John G. New
Burt B. Fisher
L. F. Hendricks
Stuart M. Low
Larry D. Woods
Leo Payavis
A. C. Roller
Hope Nissenbaum
Mrs. Geraldine Graf
Irma M. Bennet
Marjorie Ackerman, RN
E. S. Mott
R. Lowens
Ruth Jabach
S. J. Alson
Honda of Piqua (Ohio)
County of Santa Clara
Prince Manufacturing Corporation
Flents Products Company
Mott Corporation
455
-------
Docket No.
Person
Organization
77-8-327
328
329
330
331
332
333
334
335
336
337
338
339
340
341
342
343
344
345
346
347
348
349
350
351
352
353
354
Gloria J. O'Reilly
Robert Z. Breakwell
George H. Hunt
Betty Jacques
Mrs. Mary E. Neumann
Norman O. White
Richard J. Peppin
Marcia MacDonald
Robert S. Jackson, M.D.
(Mrs.) Frances Oatley
William J. Stephens
Katherine M. Reilly, M.D.
Mrs. M. L. Branchaud
Anthony Kelly
Mr. and Mrs. William Woodhouse
A. H. Krieg
Mrs. E. K. Swartz
Mr. John G. Kovash
Mrs. Henry Kaye
Florence Shafter
Richard J. Peppin
Roy Ruuska
Mayda L. Lyons
David Fishken, Ph.D.
Joseph P. Fiori
Mary Davey Schambach
Marilyn B. Noyes
Virginia Regional Coordinator,
Acoustical Society of America
Commonwealth of Virginia
American Rental Association
Widder Corporation
Singapore Institute of Standards and
Industrial Research
John L. Price and Associates
456
-------
Docket No.
Person
Organization
77-8-355
356
357
358
359
360
361
362
363
364
365
366
367
368
369
370
371
372
373
374
375
376
377
378
379
380
381
382
383
384
LeRoy J. Pahmiyer
Leonard Feuerstein
Mrs. Sylvia L. White
Rudolf Donninger
Joseph P. Shepherd, Jr.
Kenneth Young
Mr. W. J. Perney
Dr. Bessie Chronaki
A. Stephen Boyan, Jr.
James M. Farrell
R. A. Mahr
David W. dark
Lany J. Hall, M.D.
Marvin Bing
W. E. Schwieder
MelvinD. Furman
Mrs. J. Lamb
Joi Anne Garrett
W. A. Hyland
Charles V. Anderson, Ph.D.
Kenneth Truse
Constance (Mrs. George) Bell
Patrick C. Welch
James W. Klimes
Dick Almy
Roland Westerdal
Chet Pitek
John E. Cutshall
Mrs. Josephine (Illegible)
Illegible
Ostereichisches Normungsinstitut
Ford Motor Company
Municipality of Anchorage, Alaska
Deere and Company
Bilsom International, Inc.
457
-------
Docket No.
Person
Organization
77-8-385
386
387
388
389
390
391
392
393
394
395
396
397
398
399
400
401
402
403
404
405
406
407
408
409
410
411
412
Jenny L. Armour
J. C. Cornelius
Lois (Mrs. Robert S.) Green
Clay Gerken
Elen L. (Mrs. John) McCamish
Theodore Borland
Illegible
Darrell E. Wolbers
High School Students
H. J. Wise
Dianne Spessard
Darlene Davis
Mrs. Lillian E. Burns
Cherie Larson
Charles E. Speiser
Richard O. Thomalla
David M. Anderson
Pearl Michaelson
Louis H. Bieler
Fred C. Worthington
Rhona Hellman
and
Bertram Scharf
Charles W. Hyer
Mrs. Gregory Brill
Lewis K. Hosfeld
Gaude Shirai
Frances J. Babon
Archie L. Spratt
K. F. Renneberg
Citizens Against Noise
MacMurray Pacific Wholesale
J. I. Case
W. H. Brady Company
International Acoustical Testing
Laboratories, Inc.
Bethlehem Steel Corporation
Boston University
Northeastern University
The Marley Corporation
Japan Machinery Federation
Instamatic Corporation
458
-------
Docket No.
Person
Organization
77-8-413
414
415
416
417
418
419
420
421
422
423
424
425
426
427
428
429
430
431
432
433
434
435
436
437
438
439
440
441
Melvin W. Talbott
Larry Potter
Mrs. F. J. Hammond
Stan Dudek
Thomas A. Dobbelane
Dr. and Mrs. Ronald L. Hall
Alberta J. McAlarney
Le Ann Price
Edward J. Reilly
William C. Legg
Frances Szablewski
Francois Louis
P. D. Southgate
L. Lamar Black
Rachel Corbin Riley
Mr. and Mrs. John R. Sheeley
Robert J. Entwisle
M. F. Crabtree
Mrs. Marie S. Griffin
Mrs. James H. Watson
Mrs. Dorothy Chapin
Warren E. Cast
Mrs. Buddy E. Arbuckle
Mrs. L. J. McNeill, Jr.
Andrew Aitken
Theonie Lilmore
S. Ditz
Helen M. Schmidt
Kentucky Department of Labor
Renault, USA
Automatic Switch Company
Cast Manufacturing Corporation
Family Finance Class, Fordland
High School, Missouri
459
-------
Docket No.
Person
Organization
77-8-442
443
444
445
446
447
448
449
450
451
452
453
454
455
456
457
458
459
460
461
462
463
464
465
466
467
468
469
470
471
Eunice B. Quids
Louise Wilson
K. O. looker
Carol Seamon
Unsigned
The Veresh's
Sam and Laura Robbins
Max O. Biltoft
J. C. and Dorothy Kenyon
Unsigned
Eleanor Culberson
Allison Titus
Unsigned
Mrs. A. William Butler
Mrs. Bill Joe Austin
Mrs. Ralph Moffet
Roger D. Smith
Yvonne Brunstad
Elizabeth McCutchen
Mrs. A. P. Lovato
John L. Warner
Mrs. R. J. Gelhar
Geraldine Greig
Shirley W. Valin
Muriel Cowing
Ann Smith
Unsigned
Frederick G. Crocker, Jr.
Mrs. Don E. Van Meter
Mrs. George W. Moore
Plasticast Laboratories, Inc.
Norton Company
460
-------
Docket No. Person Organization
77-8-472 Mrs. Carl Bostick
473 Shirley K. Jensen
474 Mrs. Bill MacLean
475 Mrs. David J. Lukens
476 Vera Korkus
477 R. J. Smith Pearl Harbor Survivors Association
478 Mrs. H. N. Kelly
479 Mrs. Gretchen Ogle
480 Kathryn Kennedy
481 Mr. and Mrs. Anthony P. Burasz
482 Roy C. Patrick
483 Mrs. Anthony B. Manera,
484 Illegible
485 Phyllis A. W. Jamison
486 Laurence B. Ritter
487 Paul t. Young
488 Ursula Stanton
489 Eliana Woodford
490 Illegible
491 W. L. Bolyard
492 Mrs. Albert E. Montague
493 M. M. Walker
494 Ms. Olive H. Kennedy
495 Mr. Allen D. Slater
496 Margaret Carrico
497 E. C. Blackburn
498 Mrs. Vernon Alvord
499 S. Smith
500 Unsigned
501 Mrs. R. LeRoy Rollins
461
-------
Docket No.
Person
Organization
77-8-502
503
504
505
506
507
508
509
510
511
512
513
514
515
516
517
518
519
520
521
522
523
524
525
526
527
528
529
530
531
E. Bailly
Mrs. Delbert Christiansen
Dr. Sharon L. Scholl
Pat Newport
H. Malcolm Lewis
D. Remain
Mrs. Herbert Bergam
W. A. Hyland
G. A. O'Brien
M. D. Furman
H. Hoffman
Mrs. J. V. Johnson
Mrs. Thomas Williams
Harry Hughes
William Andersen
A Concerned Citizen
Thomas R. Houck
Allen O. Kundtson
F. Macenko
Marilyn Wilkins Samuelson
Ruth Lynn
Edwin W. Abbott
Mrs. Grace Norris
Mrs. Richard Frank
Lawrence H. Hodges
Mrs. Charles Koofmans
Kelly Bright
Bruce Nordquist
Mrs. Elizabeth Adamson
Mrs. Patricia Cole Blake
Westside Building Materials Company
Representative, 17th District (Illinois)
Environmental Protection of Canada
Air Transport Association of America
J. I. Case Company
462
-------
Docket No.
Person
Organization
77-8-532
533
534
535
536
537
538
539
540
541
542
543
544
545
546
547
548
549
550
551
552
553
554
555
556
557
558
559
560
Nada Yanshak Brillante
Mr. and Mrs. R. Robert Wells
William Sorber, Sr.
Greg Serafina
Fred Koenig
Mrs. Ruth L. Levine
Mrs. J. W. Hunter
Charles S. Carlyle
Douglas A. Eraser
Aurella Worrell
Mrs. W. M. Bingham
Mary Wright
Ruth Kuper Levine
Tim Mueller
Thomas D. Rossing
Mrs. C. £. Lighter
M. B. Doyle
Elisabeth G. Garrison
Rhea A. Bahlion
Mrs. A. K. Bruhn
Roy R. Morris
Mrs. Hibbert L. Norton
Carl E. Curet
R. S. Gales
Ervin Poduska
Mary Hochman
Elinor M. Bowman
Douglas A. Fraser
Unsigned
International Union, UAW
International Snowmobile Industry
Association
American Rental Association
Acoustical Society of America
International Union, UAW
463
-------
Docket No.
77-8-561
562
563
564
565
566
567
568
569
570
571
572
573
574
575
576
577
578
579
580
581
582
583
584
585
586
587
588
589
Person
Earl Hardage, Mrs. Irene Hardage
Celia Turner, Fred Salter
Joan Stephens, M.A.
Gerald E. Starkey, P.E.
Unsigned
Webster and Chamberlain
John P. Reardon
Melvin F. Kuhn
Hon. Elford A. Cederberg
James M. Farrell
Mrs. D. D. Fisher
Mrs. H. Stovall
Larry F. Stikeleather, Ph.D.
James Egger
Jean C. Pressler
David P. Reed
Mrs. Evelyn Neeunas
John L. Bennett
Hay wood Clark Smith
Claude A. Frazier, M.D.
M. P. Nevotti
Nora Priest
Mrs. Helen M. Butter
Illegible
Enid M. Johnson
Edward I. Wolf
Unsigned
Don W. Robinson
Unsigned
Organization
County of Santa Clara
Power Tool Institute (PTI)
Air Conditioning and Refrigeration
Institute
Black and Decker Manufacturing Compan;
Whirlpool Corporation
464
-------
Docket No.
77-8-590
591
592
593
594
595
596
597
598
599
600
601
602
603
604
605
606
607
608
609
610
611
612
613
614
615
616
617
Person
Roderick T. Dwyer
C. F. Newburg
Sidney J. Flock
Mrs. Susan Alperin
Mrs. C. L. Mercer
Walter Brukwinski
Ruth Moses
Elbert O. Schlotzhauer
James W. Butler
Constance M. Gibson
Charles Painter
Mrs. Forrest M. Sullivan
Mr. Evan A. Johnson
H. Bruce Prillaman
Margaret House
Mars Gralia, D.Sc.
Miss S. Victoria Krusiewski
Martha Murdock
Kathleen C. Harrigan
Mrs. Charles Ladenberger
Larry J. Eriksson
Roy W. Muth
A. F. Barber, Jr.
Joyce Pacer
Pete Sirois
Patricia H. Robinson
Illegible
Peggy W. Norris
Organization
Outdoor Power Equipment Institute
(OPEI)
National Association of Truck Stop
Operators
Nelson Industries, Inc.
International Snowmobile Industry
Association
Town Office Supply
465
-------
Docket No.
Person
Organization
77-8-618
619
620
621
622
623
624
625
626
627
628
629
630
631
632
633
634
635
636
637
638
639
640
641
642
643
644
645
646
Ms. Areta Powell
Edith Mitchell
Mrs. J. C. Brown
E. Bruce Butler
E. G. Ratering
Frank E. Mclaughlin
Igor Kamlukin
A. K. Forbes
George Mosher
Gerald A. Stangl, Ph.D.
Miss B. L. Duncan
Guenther Baumgart
E.J. Halter
William L. Krentz
Mr. and Mis. D. W. Pfeifer
W. C. Painter
Carolina Jenclowski
Miss Marjorie L. Coates
E. Linn
Anthony 0. Cortese, Sc.D.
Mrs. Robert G. Rinehart
R. H. Alexander
Joan L. Mills
Michael G. Garland
Everett A. Plaster
W. G. Schwieder
John M. Cowart
Debro Saltzman
Peggy Jenkin
General Motors Corporation
Office of Consumer Affairs, DHEW
Briggs and Stratton Corporation
Terresearch Limited
National Business Furniture
The Charles Machine Works, Inc.
Association of Home Appliance
Manufacturers
Industrial Silencer Manufacturers
Association (ISMA)
Owens-Corning Fiberglass Corporation
Rockwell International
Commonwealth of Massachusetts
The Celotex Corporation
Ford Motor Company
466
-------
Docket No.
Person
Organization
77-8-647
648
649
650
651
652
653
654
655
656
657
658
659
660
661
662
663
664
665
666
667
668
669
670
671
672
673
Michael W. Blanck
Fred Tabacchi
John L. Phillips
Madeline Bolbol
George P. Lamb, Jr.
Ralph W. Van Demark
Ms. Patricia H. Robinson
Mrs. Earl B. Hampton
Theodore J. Fister
Lucy D. Strickland
Gene Boyce
Gordon Tapper
Mrs. Gerald N. Plotkin
Richard H. Lincoln
Steven K. Allsbruck
Vico E. Henriques
Donna McCord Dickman, Ph.D.
Mrs. R. H. Pfluger
Arthur L. Herold
Dr. G. L. Guff
Dale D. Nesbitt
Bernard Balmer
Mrs. E. Dale Petite
Eileene M. Young
David A. Kloepper
S. L. Terry
Marcus D. Maattala
Kodaras Acoustical Laboratories
The Hoover Company
Vacuum Cleaner Manufacturers
Association (VCMA)
Automotive Exhaust Systems
Manufacturers Committee
Outboard Marine Corporation
Computer and Business Equipment
Manufacturers Association
Metropolitan Washington Council of
Governments
Power Tool Institute
Tri-Utility,Hearing Conservation
Program
HILTI Fastening Systems, Inc.
Chrysler Corporation
467
-------
D°cketN°- Person Organization
77-8-674 Mrs. Pauline Wanker
675 Frank J. (Illegible)
676 Allan M. and Joyce S. Krell
677 William G. Haley
678 Alice T. Heinz
679 Illegible
680 C. Rodger Blyth The Maytag Company
681 Unsigned
682 Mrs. Joseph J. Doyle
683 Mrs. Joan Mundel
684 Mrs. Marlin Knight
685 Mr. and Mrs. Raymond Peeters,
Mr. Christopher Peeters, Miss
Pamela Peeters, and Mrs. Andrea
Peeters Hunt
6S6 Helen (Mrs. Thomas) Moon
687 MK. p. Q. Perrin
688 Mrs. Geovanna Gesatti
689 Charles M. Fisher
690 Mrs. James C. Warren
691 Eva Shun Kwiler
692 JohnS.Autry Johns-Manville Corporation
693 Robert Kauffman
694 William E. Leuchtenburg
695 Mrs. Edward L. Weimer
696 R. Wood
697 George M. Deranen
698 June Wooster
699 Robert C. Hume
700 Benedict G. Breitung
701 Ira M. Edwards
468
-------
Docket No.
Person
Organization
77-8-702
703
704
705
706
707
708
709
710
711
712
713
714
715
716
717
718
719
720
721
722
723
724
725
726
727
728
729
Phyllis J. Sundquist
Alinda Heath
Marcella J. Nickerson
Ross Buhrdorf
Robert Schneider
John P. Reardon
David Owens
Robert A. Heath
Elizabeth Heminway
Gladine Glover
Wayne Marcus
Harold W. Wolf
Eliot Greb
Mrs. Ed Reynolds, Sr.
W. A. Hyland
Mrs. T. J. Brooks
Howard Swartz
Rubin Helmin
(Record of Communication
with Don Silawsky)
Karla L. Yeager
Lucille (Mrs. Herman) Waarer
Suzanne Badenhop
Julia A. Morse
Mrs. Charles W. Disbrow, Jr.
Janice F. Olson
Delores Crozier
Allen Nelson
John P. Reardon
Air-Conditioning and Refrigeration
Institute
Sears, Roebuck and Company
Walker Manufacturing
Motorcycle Industry Council, Inc.
Husqvarna Company
French Laboratory
Air Conditioning and Refrigeration
Institute (ARI)
469
-------
Docket No.
Person
Organization
77-8-730
731
732
733
734
735
736
737
738
739
740
741
742
743
744
745
Caroline Pardoe
Daniel Queen
Sherrie Sink
Mrs. Betty Westlund
Patricia Moran
Margaret Monji
Elizabeth Bottomly
Gordon L. Cluff, Ph.D.
James W. Klimes and
R. E. Anderson
Richard Gimer
(Record of communication
with Henry E. Thomas)
Arnold W. Rodin
Charles W. Hyer
Douglas A. Fraser
Frank S. Fitzgerald
Assistant General Counsel
William V. Skidmore.
Assistant General Counsel
for Legislation
Frank E. Wilcher, Jr.
Daniel Queen Associates
Tri-Utility Hearing Conservation
Program
Deere and Company
Compressed Air and Gas Institute
Home Ventilating Institute
The Marley Organization, Inc.
International Union, UAW
Noise Control Products and
Materials Association
General Counsel of the Department
of Commerce
Industrial Safety Equipment
Association
470
-------
INDEX OF PUBLIC HEARING TESTIMONY
Washington, D. C. (September 16,1977)
Docket No. Person Organization
77-8-901 Dr. Donna Dickman Metropolitan Washington Council
of Governments
902 John Reardon Air Conditioning and Refrigeration
Institute
903 Theodore Berland Citizens Against Noise
904 Mr. Stuart Low Rents Products Company
90S Roy W. Muth International Snowmobile Industry
Association
906 Ernest Scott Kirby Vacuum Cleaners
907 Wesley E. Schwieder Ford Motor Company
Richard Genik
Herbert Epstein
908 Howard W. Burnett American Rental Association (ARA)
909 Daniel Queen Daniel Queen Associates
91 o Richard Gimer Compressed Air and Gas Institute
(CAGI)
Cedar Rapids, Iowa (September 20,1977)
911 Bruce Anderson Office of Senator Dick Clark
912 Dixie Boyse Office of Congressman Michael Blouin
913 Dr. Charles Anderson American Speech and Hearing
Association
914 Representative Joan Lipsky Iowa General Assembly
915 Larry Dupre Illinois EPA
91 g Richard Worm Environmental Coordinating
Association
471
-------
Docket No.
77-8-917
918
919
920
921
922
923
924
925
926
927
928
929
930
931
932
933
934
935
936
937
938
939
Person
Vern Kamps
Willis Lueders
Pat Dillan
Ed Harwick
Ed Ryan
Mary Pickett
Tanya Wesley
John Harris
Eldon Colton
Dave Bach
Dr. Claire Kos
Kiel Van Hoef
Judy Sullivan
James Klimes
Richardson Anderson
Marion Leese
Cleo and Charles Edinger
Sheila Sidles
Pam Kidd
Steve Keller
John Kammerer
Raymond Bowman
Kenneth Truce
Dan Dykstra
Lee Fisher
Organization
American Association of Retired
Persons
Transparent Film Workers Union
United Auto Workers
United Auto Workers
American Association of Retired
Persons
Iowa State University Faculty
J. I. Case Company
City of Cedar Rapids
Iowa Department of Environmental
Quality
Iowa Speech and Hearing Association
Deere and Company
American Association of Retired
Persons
American Association of Retired
Persons
Iowa Consumers League
Amana Refrigeration
Grant Wood Area Education
Association
472
-------
San Francisco, California (September 22,1977)
Docket No.
77-8-940
941
942
943
944
945
946
947
948
949
950
951
952
953
954
955
Person
James Shone
Robert Friese
Cormac Brady
Officer Richard Podisco
Gerald E. Starkey
Judy Bamett
Eric Mankuta
Marion Lockwood
James Smith
Robert Haehnel
Edward Lowe
Thomas Woods
Dr. Henry Schmitz
James Adams
Dennis Paoletti
Al Perez
Mr. and Mrs. Crozier
Dr. Michael Kavanaugh
Organization
Citizens Against Noise
San Francisco Task Force on Noise
Control
San Francisco Department of Public
Works
San Francisco Police Department
Santa Clara County
Senior Citizens Community Service
Employment Program
California State Department of Health
Aural Technology
Hearing and Speech Center of Orange
County
City of Boulder, Colorado
Paoletti/Lewitz/Associates
Minnesota Pollution Control Agency
French Laboratory
Public Interest Economics Center
473,
-------
PART III
PERSPECTIVES ON THE PROPOSED NOISE LABELING PROGRAM:
THE GENERAL PUBLIC AND INDUSTRY
-------
INTRODUCTION
In order to develop the final regulation and assess the pub-
lic response to the proposed EPA noise labeling program and the
elements of an effective noise label, the Agency undertook three
different actions to gauge public sentiment, one of which also
solicited the views of industry. The results are presented in
Part III. The first project involved the tabulation of public
docket comments reflecting either support or opposition for the
proposed noise labeling program. The second was a nationwide
telephone survey conducted by an independent private contractor.
The third consisted of two elements; a door-to-door public survey,
and the laboratory assessment of necessary label content through
the use of focus group discussions.
SECTION 1; ANALYSIS OF PUBLIC DOCKET COMMENTS
SUPPORT VS. OPPOSITION
In order to determine the level of support among commenters
for the noise-labeling program as proposed, each comment submitted
to the public docket - either written or oral - was evaluated in
terms of its position on the proposed product noise labeling pro-
gram. Of a total of 751 comments, which represented somewhat
fewer individuals due to multiple docket entries per person, there
were 652 cases where a pro or con position could be identified.*
For analytical purposes the comments were separated into two
groups: industry and non-industry. The results for non-industry
comments are presented in Table 3-1.
*Entries 687 through 720 and 731 through 744 were received too
late for inclusion in the analysis.
477
-------
Table 3-1
Percentage of Non-Industry Commenters with Different Positions
on EPA Noise Labeling and Abatement Activities^
1
34.0%
(205)
0.3%
(2)
10.3%
(62)
18.8%
(113)
2.7%
(16)
21.9%
(132)
9.3%
(56)
.2.7%
(16)
100.0%
(602)
With
Explicit Position
on Labeling
A
_B_
C
MMMMB
For Labeling
* 78.9%
(269)
E
G
Against
+. Labeling
21.1%
(72)
100.0%
(341)
With Explicit or
Implied Position
on Labeling
A
B
C
•••MM*
E
•~™ \
_L_
For
Labeling
"* 82.3%
(401)
\ **•/
^
G
H
Against
Labeling
* 17.7%
(86)
100.0%
(487)
With Explicit or
Implied Pro-Noise
Control Position2
A
B
C
MMMMB
D
E
F
88.0%
*(530)
A. Supported Labeling
B. Supported Labeling,
Not Abatement
C. Supported Labeling
and Abatement
D. Supported EPA Noise
Abatement
E. Supported Abatement,
Not Labeling
F. Complained about Noise
Emitted by a Product-
Implied Support for
Labeling and/or Abatement
G. Opposed to Labeling
H. Opposed to EPA Noise
Abatement
TOTAL
'Non-Industry * private citizens, public officials, academicians, small non-manufacturing businesses, etc.
-No percentage was calculated for anti-noise control position, because some labeling oponents may have favdred
emission regulations, though not stating this explicitly.
478
-------
The differences in scope of support were addressed by catego-
rizing the specific comments into the classes shown below, most of
which are self-explanatory. Clarification is necessary in certain
instances, however, individuals described as "supported EPA noise
abatement" for the most part either said specifically they sup-
ported direct abatement actions such as emission regulations, or
else expressed support in general terms such as "keep up the good
work" or "I support your Agency's efforts in abating noise." Many
individuals falling in this second group probably supported the
labeling program, but because they did not state so explicitly,
they were not classified as such.
A significant number of commenters simply complained about
the excessive noise emitted by a product. Because some of these
comments could have been mailed in response to news releases which
asked for suggested candidates for noise labeling, it is likely
that the overwhelming majority of these persons also supported
labeling, although they were not initially classified in this
manner. In relation to comments classified as "opposed to EPA
noise abatement," it could not be ascertained from the letters
themselves if the people were opposed to product noise labeling
specifically.
In the second column of the table, the data are collapsed
into a dichotomy, based on those persons who made it clear (or
explicit) that the labeling program was the target of their
evaluations. The strong public support for the program among
non-industry commenters is manifested by the 78.9 percent in favor
of labeling, as contrasted with 21.1 percent against labeling.
When product complaints (Category F) are added to pro-labeling
comments due to their implied support - and general opposition to
EPA noise abatement (Category H) is combined with specific opposi-
tion to labeling - there is a slight increase in the percentage
difference (i.e., 82.3 percent in favor of labeling versus 17.7
percent against). The final column gives the percentage of non-
industry respondents who implied or explicitly expressed support
for some kind of EPA noise control activity - 88.0 percent. While
479
-------
the docket does not provide a representative sample from which one
can deduce the actual level of support in the nation at-large,
these data do afford some evidence of public support for noise
labeling.
Persons opposed to labeling or noise abatement most often
cited increased costs as the main reason for their opposition
(Table 3-2). Other criticisms were that the regulations re-
stricted the individual's freedom to make his own decisions; that
labeling was not going to influence purchasing decisions; that the
free enterprise system will produce quieter products without
governmental intervention if the public wants them; and that
resources should not be spent on noise labeling when there are
more important national priorities.
Table 3-2
Percentage of Opponents (Items G and H from Table 1)
Citing Different Reasons1
Costs 52.8%(38)
To consumers (21)
To taxpayers (10)2
Infringement of Individual Freedom 20.8%(15)
Ineffective Means of Achieving End 19. 4% (14)
Free-market Solution is Preferable 16. 7% (12)
Other Problems Occupy a Higher Priority
than Noise Pollution 4.2%(3)
Miscellaneous 5. 6% (4)
No Reason 16. 7% (12)
1Sum of percentages is greater than 100 percent because many
respondents gave multiple reasons for opposition.
respondents just mentioned "costs," not specifying the
impacted party, while others based their opposition both on
"costs to consumers" and "costs to taxpayers." Therefore, the
N for these two latter response categories does not equal 38.
480
-------
Several persons who supported noise abatement but not label-
ing complained that EPA should focus on products such as cars,
trucks, and especially motorcycles and not worry about household
appliances, which they associated with the labeling program (42,
48, 72, 90, 102, 115, 194, 277, 483, 568). Two commenters (684,
723) that questioned the labeling program's effectiveness, re-
ported the results of surveys which demonstrated the low impor-
tance of a product's noise properties (as compared to other
factors) in the eyes of the consumer.
A representative of an industry (924), potentially affected
by the proposed product noise labeling program, provided a counter
argument to the latter point at the public hearing held in Cedar
Rapids, Iowa. His testimomy indicated that the noise factor may
only become important in the marketplace when there exists noise
level data that could be used to compare products, and when an
industry's marketing divisions begin to advertise products on this
basis.
Individuals favoring the labeling program often based their
support on its utility for making informed consumer decisions and
the belief it would force manufacturers to design quieter prod-
ucts. In addition, seven commenters endorsed the labeling program
for the assistance it would provide local noise control officials
in their enforcement efforts. Five of these comments came from
state and local officials themselves, representing the States of
California, Massachusetts and Minnesota and the cities of Boulder,
Colorado, and Cedar Rapids, Iowa (948, 637, 953, 951, and 925,
respectively), and two from representatives of Citizens Against
Noise (903, 940). These comments emphasized the utility of
accurate product noise ratings established under the EPA program
in comparing products against the noise standards of local ordin-
ances.
In contrast to the widespread support for the program among
the general public, the vast majority of industry spokesmen
expressed opposition to EPA-administered product noise labeling
(Table 3-3). Fifty percent of the industry respondents directly
481
-------
Table 3-3
Percentage of Industry Commenters with
Different Positions on EPA Noise Labeling*
A. Supported Labeling
B. Supported Labeling Regulation,
with Criticisms
C. Supported Voluntary Labeling
D. Offered Major Criticisms of Regu-
lations without Directly Stating
Opposition
E. Opposed to Labeling
F. Opposed to Labeling but Sup-
ported Emission Regulations
Total
With
Explicit or Implied
Position on
EPA Product Labeling
8.0% (4) _A
4.0% (2) B
^•••^
10.0% (5) _£.
26.0% (13) _D_
50.0% (25) J
2.0% (1) I
^•H
100.0% (50)
For Labeling
12.0% (6)
Against Labeling
88.0% (44)
Industry a manufacturers and trade associations.
482
-------
stated their opposition; another 26 percent implied opposition by
offering major criticisms of the proposed regulation; and 10 per-
cent indicated their opposition by expressing support for volun-
tary labeling. (Of course, Category C does not reflect the total
level of industry support for voluntary labeling, since comments
were first classified on the basis of direct support versus oppo-
sition. Of the many persons who expressed support for voluntary
labeling, Category C contains only those few individuals who, at
the same time, did not state, their opposition to EPA product
labeling.)
483
-------
SECTION 2: GENERAL AUDIENCE SURVEY
INTRODUCTION
In order for the Environmental Protection Agency to ade-
quately implement its Congressional mandate under Section 8 of the
Noise Control Act of 1972 (86 Stat 1234), it felt that a statisti-
cally correct study should be performed to know the public atti-
tude toward noise and the proposed product noise labeling. The
Agency conducted a nationwide telephone survey through an indepen-
dent contractor to obtain data from which the Agency could better
assess: the public perception of noise; the extent to which the
public is impacted by noise; which products are bothersome; to
what extent noise is a factor in purchase decisions; and the form
in which noise information should be available so that the public
can use it in the purchase decision.
The sample for the survey was drawn using carefully pre-
scribed procedures to minimize bias and insure that the results
obtained were representative of consumers, and 608 adults were
contacted.
This section will describe in detail the survey methodology,
the data collection procedures, the results of the survey and the
conclusions of the study.
SURVEY METHODOLOGY
A major advantage of telephone surveys is. that geographic
dispersion of respondents can be maximized. This makes it possi-
ble to include all geographic areas of the country as well as
urban and rural groups within each major area.
In conducting a telephone survey, it is important to select
the sample of telephone numbers in a way that will reduce the
possibility of bias. To select a sample of numbers from telephone
directories directly is not appropriate because many people have
unlisted numbers, which would introduce a potential source of
484
-------
bias. To counteract this problem, random digit dialing was used.
For this study, the most efficient method of random digit dialing
consisted of two steps:
o First, a random sample of telephone numbers was
drawn from a master data file maintained by Don-
nelley Marketing (a division of Reuben H. Donnelley
Corporation) of all residential telephone numbers
for the entire nation, including Alaska and Hawaii.
Every nth number was taken off this file.
o Second, because this data file does not include
unlisted numbers, the last two digits of the
sampled numbers were randomized. This was done by
retaining the first eight digits of each number
(e.g., 703-893-52XX) and selecting from a table of
random numbers two-digit suffixes to complete the
number.
Since the last two digits of each were generated at random, a
variety of outcomes was possible. The more frequently occurring
were:
o Non-working numbers
o Business
o Busy/no answer
o Household
o Coin telephone booth
o Institutional number (hospital, dormitory, etc.)
It is apparent from this list that in order to complete a speci-
fied number of interviews, more numbers must be dialed than inter-
views needed. The number of completed interviews is determined by
the error one is willing to tolerate in the results. As Table 3-4
shows [1], a sample size of 600 would provide results with a 4
percent tolerated error at the 95 percent confidence level. This
485
-------
Table 3-4
Simple Random Sample Size for Several
Degrees of Precision [1]
Tolerated
Error
(percent)
1
2
3
4
5
6
7
Confidence Limits
95 Samples
in 100
9,604
2,401
1,067
600
384
267
196
99 Samples
in 100
16,587
4,147
1,843
1,037
663
461
339
was assumed to be satisfactory for this study. In order to ob-
tain 600 households, approximately 2-1/2 times that number were
selected for calling. Thus, approximately 1,500 numbers were
sampled with the last two digits randomized.
Once a household was dialed, there had to be a method of
determining who in the household was to be interviewed. This had
to be done in advance to insure that there was no bias in favor of
people who are home more often or are more willing to be inter-
viewed. Several criteria were set. First, it was decided that
only one adult (age 18 and over) would be interviewed in each
household. This was done to avoid possible bias due to cluster-
ing. Second, a procedure for selecting the one person to be
interviewed was developed. This included asking (1) how many
adults were in the household and (2) how many men were in the
household. By using a set of four tables, it was possible for the
interviewer to select the specific person to be interviewed. A
486
-------
modification of this technique was applied as described by Bryant
[2] in order to correct for a tendency for males to be harder to
contact than females. This modification involved repetition of
the first three tables so that males were slightly over-sampled.
Thus, once a household was reached, the interviewer selected
the appropriate table, asked the number of adults and males, and
determined from the table who should be interviewed. No substitu-
tions were allowed.
DATA COLLECTION
The interviews were conducted by staff selected and trained
specifically for the noise labeling survey. A total of 21 inter-
viewers were used. Each was required to attend a four-hour train-
ing session which covered such things as the purposes and back-
ground of the project, general interviewing techniques, the data
collection instrument and other elements specific to the project.
Each was required to conduct practice interviews and was critiqued.
There were three shifts of interviewing per day, with calling
from 8:30 a.m. until 9 p.m. at night (local time for the number
called).
Three attempts were made to reach a number. If after three
tries no answer was obtained, the number was dropped and no
further attempts made. In order to maximize the probability of
reaching someone, one of the three calls was made during the day
(before 6 p.m. local time Monday through Friday) and two at night
(after 6 p.m., or Saturday and Sunday).
If a household was reached, but the person to be interviewed
was not there, an attempt was made to determine the best time to
call back in order to obtain an interview. Once a household was
identified, three additional calls were made in order to reach the
respondent.
4R7
-------
Each shift consisted of a maximum of eight interviewers and
at least one supervisor. The supervisor checked every form upon
completion of an interview to insure that there were no missing
data. Introduction and interview procedures were closely moni-
tored to insure that interviewer bias was minimized. The results
of the dialing are shown in Table 3-5. Of the 1,580 numbers
dialed, a total of 987 were to a residence of some type (62.5
percent). From these households reached, 608 completed interviews
were obtained (38.5 percent). The actual data collection occurred
between December 21 and 29, 1977. No calls, however, were made on
December 24, 25, or 26.
Table 3-5
Result of Dialings
Busy /No answer after three calls
Dead line
Non-working numbers
Business
Language barrier
Other communication problem (bad lines, etc.)
Refusals
Respondent not available
Other (no adults, not a private residence)
Completed Interviews
N
188
26
264
101
14
19
282
64
14
608
1,580
%
12.0
1.6
16.7
6.4
0.9
1.2
17.8
4.1
0.9
38.5
100.1
488
-------
Once the appropriate respondent was contacted, the interview-
ers asked a series of questions using a questionnaire designed
specifically for this study, based on the information needed by
EPA. A copy of the questionnaire is shown in Appendix A of this
Part.
Major areas covered by the questionnaire included information
about:
o The public's perception of noise as an irritant.
o Products commonly considered to be bothersome because of
noise.
o Major criteria in the selection of products for purchase,
including noise,
o Willingness to pay for quieter products.
o The public's desire' for information about the noise levels
of products.
p The public's attitude toward noise labeling.
o Knowledge levels regarding noise related terms.
The results of this survey are presented in the following section.
RESULTS OF THE INTERVIEWS
A total of 608 completed interviews were obtained. These
included both males and females from all regions of the United
States. The responses indicate some awareness of noise problems
and general approval of government efforts to label noise produc-
ing products. The data obtained in these interviews are described
below. The questionnaire used to collect these data is included
in Appendix A to this Part.
The Sample
The respondent sample was almost equally divided between
males and females. Table 3-6 shows the breakdown by sex. This is
quite close to the 1970 census findings of approximately 49 per-
cent males and 51 percent females in the general population.[3]
489
-------
Table 3-6
Respondent Sex
Male
Female
Number
300
308
608
%
49.3
50.7
100.0
For the purposes of analysis the sample was also divided into
regions with approximately equal numbers of respondents in each.
The regions were defined as follows:
East Maine, Vermont, New Hampshire, Massachusetts,
Rhode Island, Connecticut, New York, New Jersey,
Pennsylvania, Delaware, Maryland, Virginia, West
Virginia, and the District of Columbia.
South
Midwest
West
North Carolina, South Carolina, Georgia, Florida,
Tennessee, Alabama, Mississippi, Arkansas, Loui-
siana, Oklahoma, and Texas.
Ohio, Indiana, Kentucky, Illinois, Michigan, Wis-
consin, Iowa, and Missouri.
Minnesota, North Dakota, South Dakota, Nebraska,
Kansas, Colorado, New Mexico, Arizona, Utah,
Wyoming, Montana, Idaho, Nevada, Washington,
Oregon, California, Alaska, and Hawaii.
These designations were meant to produce a reasonably equal
distribution of respondents across regions. Table 3-7 shows the
distribution of respondents obtained using these categories.
Households were contacted for interviews in all 50 states,
and the 608 interviews include, respondents from 48 states. No
interviews were obtained in Nevada or Alaska where only a very few
telephone numbers were called.
The sample thus can be considered to be a good nationwide
distribution, fairly closely matching certain general population
characteristics.
490
-------
Table 3-7
Distribution of Respondents by Region
East
South
Midwest
West
Number
163
143
159
143
608
%
26.8
23.5
26.2
23.5
100.0
Questionnaire Responses
As stated above, the questionnaire attempted to obtain infor-
mation in a number of areas related to the noise labeling program.
The results are presented below, by topic, and differences in
responses by sex or by region of the country are indicated when-
ever they occur.
o General Irritation Due to Noise.
The first question asked of respondents was whether or not
they were irritated by noisy products or appliances. About forty
percent of the respondents replied affirmatively to this question,
as shown in Tables 3-8a and b. Females were slightly more likely
to respond affirmatively than males. There were no significant
differences by region of the country. These responses seem to
indicate that noise is a major concern for a substantial propor-
tion of the population.
491
-------
Table 3-8
Perception of Noise as an Irritant
Question;
Do you ever feel uncomfortable or irritated by noisy
products or appliances in your home, your neighborhood,
or your place of work?
(a)
Yes
No
Number
Male
116
184
300
Female
144
164
308
Total
260
348
608
Total%
42.8
57.2
100.0
(b)
Yes
No
Number
East
68
95
163
South
56
87
143
Midwest
68
91
159
West
68
75
143
Total
260
348
608
Total %
42.8%
57.2%
100.0%
For respondents who replied that they were irritated by
noise, additional questions were asked about the types of products
that bothered them.* As Table 3-9 shows, a majority of the 260
respondents who were asked felt that the most bothersome noisy
products were those used by someone else.
*See the questionnaire in the Appendix for the skipping patterns
called for by specific item responses.
492
-------
Table 3-9
Source of Irritating Noise
Question; Are the most bothersome noisy products those that you
own and use, or those used by someone else?
Byrne
By someone else
Both
Number
76
146
38
260
%
29.2
56.2
14.6
100.0
o Factors in Purchase Decision.
Several questions were asked to try to assess the importance
of noise as a criterion in purchase decisions. One question which
relates to this is whether or not consumers believe that different
brands of a given product create different amounts of noise. As
Table 3-10 shows, a large proportion of respondents believed that
there are differences between brands, but many others did not
believe this to be true or were not sure.
Table 3-10
Perceived Brand Differences in Noise Levels
Question; Do you think that there is much difference in the
amount of noise that different brands of products such
as vacuum cleaners or chain saws create?
Yes
No
Don't Know
Depends on
Product
Number
Male
151
103
41
5
300
Female
130
108
67
3
308
Total
281
211
108
8
608
Total %
46.2
34.7
17.8
1.3
100.0
493
-------
There were significant differences between males and females
on this question, with males being more likely than females to
believe that there are differences between brands.
In a series of questions aimed at determining the relative
importance of various criteria in consumer purchase decisions, the
quietness of the operation of a product or appliance was rated as
very important by over 40 percent of the respondents (Table 3-11).
Of the criteria asked about, the most important to consumers ap-
pears to be the cost of operation. A majority of the respondents
considered this to be "very important."
Table 3-11
Importance of Different Criteria in Purchase Decision
Question; Usually, in buying an appliance or product do you con-
sider (price)(brand name)(cost of operation)(quietness
of the operation) to be very important, somewhat
important, or not very important?
Very important
Somewhat important
Not very important
Depends on product
Price
Number
281
206
79
42
608
%
46.2
33.9
13.0
6.9
100.0
Brand Name
Number
255
216
95
42
608
%
41.9
35.5
15.6
6.9
99.9
Cost of
Operation
Number
357
129
102
20
608
%
58.7
21.2
16.8
3.3
100.0
Quietness of
Operation
Number
259
164
125
60
608
%
42.6
27.0
20.6
9.9
100.1
In another attempt to determine whether or not the quietness
of products is important to consumers, a question was asked about
how much extra they would be willing to pay for a quieter vacuum
cleaner. Table 3-12 shows that the respondents indicated a gen-
eral willingness to pay a higher price for a substantially quieter
vacuum cleaner. However, there were 38 percent (214 of 558) of
the respondents to this item who stated they would pay nothing
extra for a vacuum cleaner that was three-fourths as loud.
494
-------
Table 3-12
Willingness to Pay for Quieter Products
Question; If you were planning to buy a vacuum cleaner and the
average cleaner cost about $70, how much extra would
you be willing to pay, in dollars, for a vacuum cleaner
that was only
Three-fourths as loud (N a 558)
Half as loud (N* 552)
Mean
$13.39
15.36
Refusals to respond equal 50 and 56, respectively.
The actual dollar amount that respondents stated were willing
to pay is very much tied to the base price of $70. The mean
dollar amounts, however, work out to approximately 19 percent and
23 percent of the base purchase price, showing definite flexi-
bility on the part of consumers to pay extra for features they
deem desirable.
o Desire for Noise Control and Noise Labels.
Two different factors which the Agency must take into account
when considering a product for regulation are whether to set
levels on the maximum amount of noise the product may emit and/or
whether to label the product as to the amount of noise it does
produce.
The responses to a question on government noise control are
shown in Table 3-13a, b. A large majority of respondents felt
that the government should set noise levels for some products.
There were significant differences between males and females on
this question. Although equal numbers of males and females were
in favor of government standards, among those not in favor, males
were more likely to report disapproval and females to respond that
they didn't know if the government should set such standards.
Respondents from the West showed the smallest percentage in favor
of government standards, both in objecting to the standards and in
being the most definite about their answers (i.e., very few "don't
knows").
495
-------
Table 3-13
Desire for Government Noise Control
Question;
Do you think the government should set noise levels for
some products?
(a)
Yes
No
Don ' t Know
Number
Male
199
80
20
299
Female
199
61
48
308
Total
398
141
69
607
Total %
65.6
23.2
11.3
100.0
(b)
Yes
No
Don1 t Know
Number
East
128
21
13
162
South
89
34
20
143
Midwest
93
37
29
159
West
88
49
6
143
Total
398
141
68
607
Total %
65.6
23.2
11.2
100.0
The reasons given by those people not in favor of the govern-
ment setting noise levels (as obtained through the previous ques-
tion) are shown in Table 3-14. The replies are grouped according
to a few major classifications. The most frequent response was
that the government already has too much control. Other fre-
quently mentioned reasons were that such controls are not needed
and that the consumer should regulate noise levels through pur-
chases, and allow the effects of the free market to encourage
manufacturers to reduce noise.
496
-------
Table 3-14
Reasons for Government Not to Set Noise Levels
Question; Why should the government not set noise levels?
Too much government control
Noise controls not needed
Consumers should regulate
Not feasible
Would increase prices
Could give no reason
Number
58
34
33
7
3
,6
141
%
41.1
24.1
23.4
5.0
2.1
4.3
100.0
The respondents to the survey were very strongly in favor of
information on the amount of noise a product makes being made
available to consumers before purchasing (Table 3-15).
Table 3-15
Desire for Noise Information
Question; Do you think consumers should be given information
about the amount of noise a product makes before they
buy it?
Yes
No
Don't know
Number
528
57
23
608
, %
86.8
9.4
. .. , 3.8
100.0
497
-------
The 528 respondents who indicated that they would want such
information were asked two further questions about the source of
this information. Table 3-16 shows that the majority of replies
were in favor of the manufacturer supplying the information, which
in essence is what the EPA program proposed. The most frequently
mentioned other sources for the information were independent
testing laboratories and publications such as Consumer's Report.
Male respondents were more likely than females to cite some other
source, while females primarily felt the manufacturer should
supply the data.
Table 3-16 also shows that the majority of respondents felt
the EPA would provide more accurate information than the manufac-
turer. This could imply support for the EPA program as proposed,
since it would require the manufacturer to supply accurate and
verifiable noise information, and EPA's enforcement procedures
would assure that manufacturers comply with the requirements.
Three other questions which exhibit general audience support
for noise labeling are shown in Tables 3-17, 3-18 and 3-19. A
large majority of respondents report that they would like to see
a noise label placed on products and that they would use such a
label in their purchase decision; and a majority state that they
would want the label even if it increased the price.
While a majority of all respondents reported that they would
still want a noise label even if it increased the price of a
product, there were differences between males and females in their
responses to this question. Among the respondents who did not
reply affirmatively to the question, males were more likely to
state that they definitely would not want the label if it caused a
price increase, while females were more likely to reply that it
would depend upon the amount of the price increase. Substantial
proportions of both groups are obviously concerned about the
economic impact of the labels on purchase prices.
498
-------
Table 3-16
Sources of Noise Information
Question; Do you think this information should come from the
government, from the manufacturer, or from some other
source?
The government
The manufacturer
Other
Don ' t know
Number
Male
35
157
59
6
257
Female
42
190
31
10
273
Total
77
347
90
16
530
Total %
14.5
65.5
17.0
3.0
100.0
Question;
Question; Which source do you think would provide more accurate
information about the noise level of a product; the
manufacturer or the Environmental Protection Agency?
The manufacturer
The EPA
Neither
Both
Number
165
317
17
29
528
%
31.3
60.0
3.2
5.5
100.0
Table 3-17
Desire to Have Label Placed on Products
Would you like to see a label placed on products to
show how much noise they make?
Yes
No
Number
471
137
608
%
77.5
22.5
100.0
499
-------
Table 3-18
Potential Use of Noise Labels
Question;
If a noise label were provided, would you be likely to
use the information in your purchase decision?
Yes
No
Depends on product
Number
464
92
52
608
%
76.3
15.1
8.6
100.0
Table 3-19
Willingness to Pay for the Label
Question;
If putting a label on products to show how much noise
they make would increase the price, would you want the
information?
Yes
No ;
Depends on Price
Increase
Other
Number
Male
155
83
46
16
300
Female
171
61
69
7
308
Total
326
144
115
23
608
Total %
53.6
23.7
18.9
3.8
100.0
500
-------
o Label Characteristics.
Two questions were asked to assess consumer preferences about
particular characteristics of the noise label. Only those 516
respondents who had indicated a possible willingness to use the
labels were asked these questions (see Table 3-18, those respond-
ing "Yes" or "Depends on Product"). As can be seen in Table 3-20,
the majority of replies were in favor of some type of permanently
affixed label on the product. A hang tag was seen as somewhat
acceptable, but very few respondents favored a single product
display sign. Several respondents remarked that an acceptable
form of a permanent label would be one which was pasted onto the
product but which could be removed by the consumer after purchase.
There was less agreement among respondents when asked about
the type of rating scale they would prefer on the label (Table
3-21). The most acceptable alternatives were a number scale
(26.9%) or a word description (40.3%). The preference for a
word description may indicate that some word explanation would be
desirable if a number scale is used.
Table 3-20
Preferences for Type of Label
Question; If products were labeled to show how much noise they
make, would you prefer the label to be;
A hang tag attached to each product
A permanently affixed label on the product
A single sign as part of the product display,
but not attached to each item
Depends on the product
Number
131
308
41
36
516
%
25 .4
59.7
7.9
7,0
100.0
501
-------
Table 3-21
Preferences for Rating Schemes
Question;
I'd like to read to you four different ways of indicat-
ing on a label amounts of noise. After I have read all
four, please indicate which approach you would prefer.
A star scale where four stars meant a very
quiet product
A number scale where a low number meant
a very quiet product
A color-coded label where a green symbol
meant a very quiet product
A word description which said "quiet" or
"noisy"
No preference
Number
74
139
60
208
35
516
%
14.3
26.9
11.6
40.3
6.8
99.9
o Knowledge of Noise Terminology.
The choice of a rating scheme may be based on a variety of
scientific criteria, but even if acoustical engineers can deter-
mine the appropriate noise measure to be used in rating each prod-
uct, the noise labeling program cannot be successful unless the
consumer can understand the rating. In order to estimate the
scientific sophistication of consumers in the area of noise, a
question was asked to determine the familiarity of respondents
with the term "decibel.11 The same question was asked about the
terms "therm" and "watt" in order to provide some comparative
data.
502
-------
Table 3-22 shows that a majority of respondents were able
to correctly identify "decibel" as a measure of noise level, a
slightly higher percentage than knew the term "therm," but far
below the familiarity level of the term "watt." The percent cor-
rectly identifying "decibel" may be a somewhat biased estimate
upward because of the fact that this question was asked last and
respondents could have eliminated alternatives in their mind based
on their previous answers. Also, the respondents knew the survey
was about noise and so this could have served as a prompter in
guessing.
Table 3-22
Knowledge of Rating Terms
Question; Can you tell me if a (therm) (watt) (decibel) is a
scientific measure of electricity, heat, noise, or
gas?
Correct response
Incorrect response
Don't know
Therm
Number
289
48
271
608
Total %
47.5
7.9
44.6
100.0
Watt
Number
545
14
49
608
Total %
89.6
23.0
8.1
100.0
Decibel
Number
317
35
256
608
Total %
52.1
5.8
42.1
100.0
Number
Male
189
11
100
300
Number
Female
128
24
156
308
There were differences between males and females with sig-
nificantly more males (189 of 300 = 63%) knowing the term "deci-
bel" than females (128 of 308 - 41.6%), this may indicate a need
for particular consumer education to be aimed at females to
heighten their familiarity with noise terminology.
503
-------
After the above questions on terminology were asked, respon-
dents were told that a decibel is a measure of noise level and
then asked to guess how loud a vacuum cleaner and a lawnmower are,
given that city traffic is about 75 decibels and a quiet whisper
is about 20 decibels. Table 3-23 shows the results of this
question. The mean values are fairly close to the actual values
of approximately 75 decibels for vacuum cleaners and 90 decibels
for lawnmowers. The range of values was quite large, however; for
vacuum clearners the guesses ranged from one decibel to 400
decibels, with only 139 cases (26.5 percent) in the range 65 to
85; for lawnmowers the guess ranged from two decibels to 600
decibels, with only 140 cases (26.6 percent) in the range 80 to
100.
Table 3-23
Estimates of Decibel Levels
Question;
A decibel is a measure of noise level. City traffic is
usually about 75 decibels, while a quiet whisper is
about 20 decibels. Can you guess how loud
a vacuum cleaner migfrt be? (N - 524)
a lawnmower might be? (N = 527)
Mean
77.98 decibels
87.97 decibels
Refusals to guess 84 and 81, respectively.
o Products.
Another goal of this survey was to determine which products
consumers felt were irritants and which products they felt should
be labeled. The respondents were specifically asked about vacuum
cleaners, chain saws, and air conditioners. Table 3-24 shows the
504
-------
Replies from those respondents who had indicated that they were
bothered by noise, but who had not already mentioned that they
were bothered by these particular products. For this reason the
number of respondents varies, and the number of persons who ac-
tually indicated displeasure with these products is higher.
There were significant differences in the responses of males and
females for vacuum cleaners with 30.7% (32 of 104) of the males
bothered by noise from vacuum cleaners, while 18% (24 of 133) of
the females responded that they were bothered. Likewise, 28% (32
of 114) of the males were bothered by noise from air conditioners,
while 15.8% (22 of 139) of the females were similarly bothered.
Table 3-24
Particular Products as Irritants
Question: Are you ever bothered by noise from (vacuum cleaners)
(chain saws) (air conditioners)?
Yes
No
Vacuum Cleaners
Number
Male
32
72
104
Female
24
109
133
Total
56
181
237
Total
%
23.6
76.4
100.0
Chain Saws
Number
Male
33
78
111
Female
42
97
139
Total
75
175
250
Total
%
30.0
70.0
100.0
Air Conditioners
Number
Male
32
82
114
Female
22
117
139
Total
54
199
253
Total
%
21.3
78.7
100.0
Respondents who had indicated in the first question asked of
them that they were bothered by noisy products or appliances were
asked to name the products that bothered them the most. These 260
respondents named an average of 2.01 sources of noise each, encom-
passing some 80 different categories. Table 3-25 shows the number
of times each category was mentioned.
505
-------
Table 3-25
Products Whose Noise is Irritating
Question; What are some of the products whose noise bothers you
the most?
(N = 260)
Major Household Appliances
Washing machine
Dryer
Dishwasher
Refrigerator
Freezer
Self-cleaning oven
Humidifier
Air conditioner
Furnace
Space heater
Small Household Appliances
Appliances
Vacuum cleaner
Hairdryer
Blender
Mixer
Food processor
Ice crusher
Pressure cooker
Coffee pot
Can opener
Garbage disposal
Clock
Window fan
Exhaust fan
No. of Times
Mentioned
131
31
12
41
23
2
1
2
10
7
2
88
11
27
7
14
1
1
2
1
3
6
5
2
4
4
% of Total
Number
25.0
5.9
2.3
7.8
4.4
0.4
0.2
0.4
1.9
1.3
0.4
16.8
2.1
5.2
1.3
2.7
0.2
0.2
0.4
0.2
0.6
1.1
1.0
0.4
0.8
0.8
% of Respondents
Mentioning
50.4
11.9
4.6
15.8
8.8
0.8
0.4
0.8
3.8
2.7
0.8
33.8
4.2
10.4
2.7
5.4
0.4
0.4
0.8
0.4
1.2
2.3
1.9
0.8
1.5
1.5
506
-------
Table 3-25 (Continued)
Products Whose Noise is Irritating
Power Tools
Power tools
Drills
Lawnmowers
Chain saws
Leaf machine
Air compressor
Machinery
Machines
Vibrating machinery
Industrial machinery
Factory noise
Auto shop noise
Conveyor belt
Farm machinery
Tractor equipment
Vehicle Noise
Traffic
Cars
Trucks
Motorcycles
Buses
Trains
Subways
Airplanes
Motorboats
Snowmobiles
Garbage trucks
Office Equipment
Typewriters
Adding machines
Computers
Teletype machine
No. of Times
Mentioned
38
9
3
19
5
1
1
35
15
2
11
3
1
1
1
1
134
5
34
16
27
7
5
2
25
1
5
7
7
3
1
2
1
% of Total
Number
7.3
1.7
0.6
3.6
1.0
0.2
0.2
6.7
2.9
0.4
2.1
0.6
0.2
0.2
0.2
0.2
25.6
1.0
6.5
3.1
5.2
1.3
1.0
0.4
4.8
0.2
1,0
1.3
1.3
0.6
0.2
0.4
0.2
% of Respondents
Mentioning
14.6
3.5
1.2
7.3
1.9
0.4
0.4
13.5
5.8
0.8
4.2
1.2
0.4
0.4
0.4
0.4
51.5
1.9
13.1
6.2
10.4
2.7
1.9
0.8
9.6
0.4
1.9
2.7
2.7
1.2
0.4
0.8
0.4
507
-------
Table 3-25 (Continued)
Products Whose Noise is Irritating
Products Whose Purpose is Noise
Television
Stereo
•Radio equipment
CB radio
Radio & TV ads .
Juke box
Music in stores
Telephones
Intercom system
Horns
Buzzers
Factory whistle
Police and fire sirens
Smoke detectors
Fire alarms
Burglar alarms
Firecrackers
Miscellaneous
Noise in general
People/talking
Toys
Barking dogs
Dishes in restaurants
Toilet
Fish tank pump
Reservoir
Transformer
Fluorescent lights
No. of Times
Mentioned
66
17
15
6
4
2
1
1
3
2
3
3
1
4
1
1
1
1
24
3
5
2
4
1
3
2
1
1
2
% of Total
Number
12.6
3.3
2.9
1.1
0.8
0.4
0.2
0.2
0.6
0.4
0.6
0.6
0.2
0.8
0.2
0.2
0.2
0.2
4.6
0.6
1.0
0.4
0.8
0.2
0.6
0.4
0.2
0.2
0.4
% of Respondents
Mentioning
25.4
6.5
5.8
2.3
1.5
0.8
0.4
0.4
1.2
0.8
1.2
1.2
0.4
1.5
0.4
0.4
0.4
0,4
9.2
1.2
1.9
0.8
1.5
0.4
1.2
0.8
0.4
0.4
0.8
508
-------
The major types of products whose noise is most irritating
to the respondents are household appliances and vehicle noise.
Particular products frequently mentioned include dishwashers,
washing machines, vacuum cleaners, automobiles, and motorcycles.
When asked specifically about products which they felt should
be labeled, those 516 respondents, who had indicated that they
would use a label if it were available, named an average of 1.73
products each as needing labels. As Table 3-26 shows, over 60
categories of products were mentioned, and again household appli-
ances were the most frequently named type of products. Over 25
percent of the respondents also mentioned different kinds of power
tools.
The very high proportions of respondents mentioning vacuum
cleaners, air conditioners, and chain saws may have been affected
by the questionnaire, since previous questions had mentioned these
products.
509
-------
Table 3-26
Products Which Need to be Labeled
Question; Are there any products you think it would be particu-
larly important to label?
(N-516)
Major Household Appliances
Washing machine
Dryer
Dishwasher
Refrigerator
Freezer
Humidifier
Air conditioner
Furnace
Space heater
Trash compactor
Small Household Appliances
Appliances
Vacuum cleaner
• Hairdryer
Blender
Mixer
Food processor
Ice crusher
Can opener
Garbage disposal
Clock
Window fan
Exhaust fan
Electric broom/sweeper,
Floor polisher
Sewing machine
Electric razor
Electric knives
No. of Times
Mentioned
261
57
28
46
52
7
1
55
6
8
1
350
41
172
11
39
20
4
3
9
9
5
4
9
10
1
10
2
1
% of Total
Number
29.3
6.4
3.1
5.2
5.8
0.8
0.1
6.2
0.7
0.9
0.1
39.2
4.6
19.3
1.2
4.4
2.2
0.4
0.3
1.0
1.0
0.6
0.4
1.0
1.1
0.1
1.1
0.2
0.1
% of Respondents
Mentioning
50.6
11.0
5.4
8.9
10.1
1.4
0.2
10.7
1.2
1.6
0.2
67.8
7.9
33.3
2.1
7.6
3.9
0.8
0.6
1.7
1.7
1.0
0.8
' 1.7
1.9
0.2
1.9
0.4
0.2
510
-------
Table 3-26 (Continued)
Products Which Need to be Labeled
Power Tools
Power tools
Lawnmowers
Chain saws
Air compressor
Snowblower
Lawn trimmer ;
Well pump
Air hammer
Machinery
Industrial machinery
Anything with a motor
Vehicle Noise
Cars
Trucks
Motorcyles
Trains
Airplanes
Motorboats
Snowmobiles
Outdoor vehicles
Mufflers
Helicopters
Office Equipment
Typewriters
Copier
No. of Times
Mentioned
143
15
45
69
4
4
1
2
3
9
5
4
62
21
10
20
1
2
1
2
1
3
1
2
1
1
% of Total
Number
16.0
1.7
5.0
7.7
0.4
0.4
0.1
0.2
0.3
1.0
0.6
0.4
7.0
2.4
1.1
2.2
0.1
0.2
0.1
0.2
- 0.1
0.3
0.1
0.2
0.1
0.1
% of Respondents
Mentioning
27.7
2.9
8.7
13.4
0.8
0.8
0.2
0.4
0.6
1.7
1.0
0.8
12.0
4.1
1.9
3.9
0.2
0.4
0.2
0.4
0.2
0.6
0.2
0.4
0.2
0.2
511
-------
Table 3-26 (Continued)
Products Which Need to be Labeled
Products Whose Purpose is Noise
Television
Stereo
Radio
Receivers
Headphones
Telephones
Smoke detectors
Miscellaneous
Everything
Anything over 90 decibels
Any noise damaging to health
Anything that interferes with sleep
Beauty shop noise
Toys
Fluorescent lights
Guns
No. of Times
Mentioned
20
5
8
3
I
I
I
1
45
23
5
2
2
3
8
1
1
% of Total
Number
2.2
0.6
0.9
0.3
0.1
0.1
0.1
0.1
5,0
2.6
0.6
0.2
0.2
0.3
0.9
0.1
0.1
% of Respondents
Mentioning
3.9
1.0
1.6
0.6
0.2
0.2
0.2
0.2
8.7
4.5
1.0
0.4
0.4
0.6
1.6
0.2
0.2
512
-------
Conclusions
The results of this nationwide survey show that the general
public has some awareness of noise, and is a concern to a signifi-
cant number of people. When they are asked specifically, most
people are able to identify products that bother them. Most re-
spondents state that the products that bother them the most are
those used by someone else, rather than those they use themselves.
Household appliances, vehicles, and power tools are the most
frequently named sources of irritating noise. Since many of these
products are purchased by consumers for their own use, the prod-
ucts would appear to be likely candidates for noise labeling.
A majority of the public is in favor of the government's set-
ting noise levels for certain products. The public also shows
general support for a labeling program, stating that they would
like to have such labels, that they would use such labels, and
that they would still want the labels even if this increased the
price of the products. Consumers want the manufacturer to supply
the noise information but feel that the EPA would provide more
accurate information. This supports the proposed product noise
labeling program, which would require manufacturers to supply
accurate and verifiable noise data on a label, with EPA's enforce-
ment procedures to assure that manufacturers comply with the
requirements.
The label must be made intelligible to the consumers to make
use of the limited understanding of the terminology and relative
levels of acoustic rating scales. Consumers are interested in
noise as a factor in their purchase decisions, and there is reason
to believe that, provided with a clear label, they will use it to
purchase quieter products. The respondents stated a general will-
ingness to pay more in order to get a quieter product.
There were almost no differences between respondents from
different regions of the country and few differences by sex. This
implies that a general consumer education program can be developed
513
-------
for the entire country. The most important point is that such
a program is needed if consumers are to better understand and most
effectively use noise information on labels when purchasing a
product.
514
-------
SECTION 3: TEST OF NOISE LABEL ELEMENTS
INTRODUCTION
In order to provide noise information to the public, as re-
quired by Section 8 of the Noise Control Act, that would, in ef-
fect, be usable, the Agency proposed the general provisions for
protect noise labeling on June 22, 1977, in the Federal Register
[4].
This proposed regulation included provisions on the content
and format of the noise labels and solicited comment from the
public. The following information and data were proposed as the
content of the labels [5] :
(A) The term "Noise Rating" if the product is noise produc-
ing, or the term "Noise Reduction Rating" if the prod-
uct is noise reducing;
(B) An acoustic descriptor rating;
(C) Comparative acoustic information;
(D) Product manufacturer identification;
(E) Product model number or type identification;
(F) The phrase "Federal law prohibits removal of this label
prior to purchase";
(G) The U.S. Environmental Protection Agency logo;
(H) The term "Environmental Protection Agency"; and the for-
mat proposed for the label is shown in Figure 3-1.
The appropriate acoustic descriptor (A), the acoustic de-
scriptor (B) rating and the comparative information (C) would be
provided in a regulation specific to a certain product. A sample
noise label, less descriptor rating and comparative information,
is shown in Figure 3-2.
To further evaluate the proposed and alternative means of
communicating noise information on product noise labels, the
Agency felt that additional public response and perceptions were
necessary.
515
-------
Figure 3-1
A
2
_
.1
j<
Y
5Y
: —
3Y
IY
\
•t I
-{ ' J
r ^]
(AJ (B}
tc)
ID) IE)
(F) IG) (H)
v J
/
<>
-'-.1Y
•M
'(.75X)
Figure 3-2
Noise
Rating
(B)
(C)
Manufactured
Camoridge Corporation,
Boston, Mass.
Federal law prohibits
removal ofthis label.
7% •, Environmental Protection
Agency.
516
-------
Therefore, the Agency conducted an in-depth study of the
public's perception of the proposed noise labels, and others
suggested as alternatives/ by means of a door-to-door public
survey. In addition, based on the direction the results of the
door-to-door survey led us, the Agency conducted a series of focus
group discussions on the labels to further define the most effec-
tive, most informative label content and format for the Product
Noise Labeling program.
The objectives, procedures, results, and conclusions of the
door-to-door survey and the focus group discussions are described
in the first and second parts of this section, respectively.
The interview protocols used in the door-to-door survey and
focus group interviews are provided in Appendix B and C. Appendix
D contains a summary of consumer comments obtained in the focus
group sessions.
DOQR-TO-DOOR SURVEY TO EVALUATE ALTERNATIVE MEANS OF
COMMUNICATING NOISE INFORMATION ON PRODUCT LABELS
The proposed general provisions of the noise labeling program
provided that the acoustic descriptor rating and the comparative
acoustic information would be specified as part of a regulation
on a specific product. An independent contractor conducted the
personal interview door-to-door survey for the Agency to gather
the information the Agency needs to properly evaluate a number of
methods for communicating descriptor and comparative acoustic
information to the public.
Objectives
An ideal noise descriptor rating should be precise enough
to allow consumers to distinguish between products having dif-
ferent noise levels. It should be based upon a system or scale
so that each value represents only one meaning or noise level.
It should be easily measurable and accurate; and it should be
administratively and technically feasible to use in a noise
labeling program.
517
-------
The decibel, which is a measure of the magnitude of a parti-
cular quantity of sound (such as sound power or sound pressure)
with respect to a standard reference value (20 micronewtons per
meter squared (20/nN/m2) for sound pressure, and 10 pico-watts
(lOp-watts) (10~12 watts) for sound power), possesses all of the
above characteristics.
For this reason noise labels incorporating decibels as the
descriptor were used in the door-to-door survey. Since the deci-
bel scale is logarithmic, and potentially difficult to understand,
a label with a "number only" and a label with an explanation of
the decibel scale ware also used in the survey. The explanation
of the decibel scale read as follows: "A 10 decibel increase will
roughly double the amount of noise a product makes."*
The comparative acoustic information on the noise label
should provide additional assistance to consumers who wish to
purchase quieter products by using noise labels. Three methods of
providing comparative information were tested in the door-to-door
survey. A simple statement urging consumers to "Compare Noise
Ratings" was tested. A statement attempting to inform consumers
about the general noise level of the labeled product was tested.
This second statement, referred to as the barometer statement,
read as follows: "60-75 decibels may interfere with TV listening
in a roort adjacent to the device." Finally, a statement providing
information about the specific noise level of the product being
labeled relative to the noise levels of other products of the same
type was tested. This statement, referred to as the range infor-
mation, read as follows: "The range in noise ratings for products
of this type is approximately 60 to 80 decibels."
A total of nine different labels were developed to test the
various methods of presenting the descriptor and comparative
information. Five labels stating "decibels" were tested - four
*Actually, to be completely accurate in the technical sense this
statement should read "A 10-decibel increase will result in noise
which is 10 times the amplitude, but only perceivable to people
as twice as loud."
518
-------
with comparative information only, and one with both comparative
information and a short explanation of the nature of the decibel
scale. Four different "number only" labels were tested, each
corresponding to one of the four decibel labels. The descriptor
and comparative information variations tested in the door-to-door
survey are shown in Figure 3-3. The "A" labels correspond to the
labels stating "decibels". The "B" labels correspond to the
"number only" labels. The objective of the door-to-door survey
was to obtain information necessary to evaluate the methods
of providing descriptor and comparative acoustic information on
product noise labels described above and shown in Figure 3-3.
Procedures
The door-to-door survey was conducted in the Washington,
D.C. metropolitan area. Blocks were randomly selected using the
Block Statistics of the U.S. Census Bureau covering the District
of Columbia, the City of Alexandria, Virginia and Arlington
County, Virginia. Five sequential households were surveyed from a
random starting point on each block. The survey took place April
10th through April 26th, 1978, from 3:30 p.m. to 7:30 p.m. each
day. The only requirement for the selection of a respondent
within a household was that the person be actually involved in
the purchase of appliances for that household, i.e., someone who
would potentially use noise labels. Once the appropriate person
was available, an interview was conducted.
Initial questions related to noise as a potential irritant.
Respondents were then asked to rate a label for its ability to
communicate information, once after seeing the label for only
10 seconds, and then again after having read the label for as
long as he or she wished. A second label, presenting the same
descriptor and method of providing comparative information, but
having a different numerical value, was then shown and the per-
son's understanding of the labels was tested. Respondents were
asked which of the two products would make more noise, whether
either of the two products would be good to purchase if they were
519
-------
Figure 3-3
Descriptor and Comparative Information Variations for Labels
Al
A. (decibel)
/-
Noise
Rating
60 decibels
\
Compare Noise Ratings
A2 (Range)
r
Noise
Rating
The range in noise rating
is approximately:
60 decibels
for products of this type
60 to 80 decibels
\
A3 (Barometer)
Noise
Rating
60 decibels
60*75 decibels may interfere with TV listening in a
room adjacent to the device
A4 (Range and Barometer)
Noise
Rating
60 decibels
The range in noise ratings
for products of this type is
approximately: 60 to 80
decibels
60 to 75 decibels may
interfere with TV
listening in a room
adjacent to the device
AS (Range and Explanation)
f~ Noise
Rating
The range in noise ratings
for products of this type is
approximately: 60 to 80
decibels
A
60 decibels
A 10 decibel increase
wfll roughly double
the amount of noise
a product makes
Bl
B. (number only)
Noise
Rating
60
Compare Noise Ratings
B2 (Range)
Noise
Rating
60
The range in noise ratings for products of this type
is approximately: 60 to 80
B3 (Barometer)
Noise
Rating
60
60-75 may interfere with TV listening in a
room adjacent to the device
B4 (Range and Barometer)
Noise
Rating
60
The range in noise ratings 60-75 may interfere with
for products of this type is TV listening in a room
approximately: 60 to 80 adjacent to the device
520
-------
interested in buying a quiet product, and so on. To develop
information concerning the background of the person answering the
questions, questions were asked about age, occupation, education,
attitudes toward noise, and attitudes toward the labeling of prod-
ucts to show their noise characteristics.
A copy of the interview procedures is included in Appendix B
to this Part.
Results
A total of 144 persons were interviewed: 49 from the Dis-
trict of Columbia, 60 from Alexandria, and 35 from Arlington.
Their demographic profile is shown in Tables 3-27 through 3-30.
Females and non-whites were overrepresented in the sample. The
overrepresentation of females reflects their availability during
the survey hours and the numbers of females actually involved in
product purchasing. The overrepresentation of non-whites in
the survey was intentional, considering the population composition
of the Washington, D.C. metropolitan area, so that a more reliable
estimate of the usefulness of the information on noise labels to,
and the perceptions of the noise labeling program by non-white
groups might be obtained.
The results of the door-to-door survey in this metropolitan
area indicate, as did the nationwide telephone survey previously
conducted,* that there is strong consumer support for noise label-
ing, as shown in Tables 3-31 and 3-32. When asked, "Would you
like to see a label placed on products to show how much noise
they make?", approximately 85 percent of the people questioned in
the survey indicated support. About 67 percent of the respondents
reported that they would want noise label information even if an
increase in the price of the products resulted. These results are
similar to those obtained in the nationwide telephone survey.
*Part III - Section 2.
521
-------
Table 3-27
Sex of Those Respondents Answering This Question
Male
Female
Total
Number
55
82
137
Percent
40.0
60.0
100.0
Table 3-28
Race of Those Respondents Answering This Question
White
Non-White
Total
Number
74
64
138
Percent
53.6
46.4
100.0
522
-------
Table 3-29
Education of Those Respondents Answering This Question
Less than high school
graduate
High school graduate
Some college
College graduate
Graduate work
Total
Number
24
34
25
34
25
142
Percent
16.9
23.9
17.6
23.9
17.6
99.9
Table 3-30
Income of Those Respondents Answering This Question
Under $5,000
$5,00049,999
$10,000-$ 14,999
$15,000-$ 19,999
$20,000-$24,999
$25,000 or more
Total
Number
9
13
30
20
23
33
128
Percent
7.0
10.2
23.4
15.6
18.0
25.8
100.0
523
-------
Table 3-31
Desire to Have Label Placed on Products
Question: Would you like to see a label placed on products to
show how much noise they make?
Yes
No
Don't know
Total
Number
121
15
7
143
Percent
84.6
10.5
4.9
100.0
Table 3-32
Willingness to Pay for the Label
Question; If putting a label on products to show how much noise
they make would increase the price of the products,
would you still want the information?
Yes
No
Don't know
Total
Number
87
39
4
130
Percent
66.9
30.0
3.1
100.0
524
-------
Respondents also reported that they would read the labels,
that the labels contained believable information, that the labels
contained easily understandable words, and that the labels would
encourage them to buy quiet products.
Many of those questioned, however, expressed concern that
there was too little information on the labels.
Some very interesting response patterns were identified when
the respondents were asked to rate the various labels on their
ability to communicate information. For one, the ratings on the
labels stating "decibels" went down from label to label as more
information was provided on the label, while the ratings on the
"number only" labels went up from label to label as more informa-
tion was provided on the label - suggesting that additional deci-
bel information was confusing people. Also, the ratings on the
decibel labels were low when rated after viewing them for 10
seconds, but went uip_ after respondents read the labels for as long
as they wished. The "number only" labels were rated high after
being viewed for 10 seconds, but went down after respondents read
the labels for as long as they wished. At first glance, the
respondents apparently believed that the labels stating "decibels"
were too difficult to understand. After reading those labels
thoroughly, however, they were not as hard to understand as
respondents originally thought. Whereas, the respondents believed
"number only" labels to be easy to understand at first glance,
but as they read these labels more carefully, they began to
believe they did not understand them as well as they originally
thought.
To determine whether people understood the direction of the
noise rating scale, each respondent was shown two labels and was
told the labels would be found on two different types of products.
The first label had a 60 decibel rating; the second label had a 50
decibel rating. The respondent was then asked which of the two
labeled products would make more noise. The. correct answer was
the 60 decibel product.
525
-------
There was essentially no difference on this question between
responses to labels stating "decibel" or "number only". About
80 percent of the consumers who were shown decibel labels and 80
percent of the consumers who were shown "number only" labels
responded by saying that higher numbers would represent a noisier
product. Twenty percent responded that the lower number would
represent a noisier product.
An indirect reference to the direction of the decibel scale
was included on Label A5 which said, "a 10 decibel increase will
roughly double the amount of noise a product makes." About 90
percent of the people shown Label A5 responded that higher was
noisier. Although this represents somewhat of an improvement, it
suggests that a direct reference to the direction of the decibel
scale, such as "lower noise ratings mean quieter products" is
required. Table 3-33 presents the results of the questions, by
the three types of labels tested, concerning the direction of the
scale.
The labels containing barometer statements were misinter-
preted by the majority of those questioned. The barometer infor-
mation on the 60 decibel label read as follows: "60 to 75 deci-
bels may interfere with TV listening in a room adjacent to the
device." The barometer information on the 50 decibel label read
as follows: "45 to 60 decibels may interfere with TV listening in
the same room as the device." The concept of TV interference and
the concept of distance used in these statements were misinter-
preted. Many people regarded TV interference in the "viewing"
sense, not in the "hearing" sense, and many believed a product
which would interfere with TV listening in the same room as the
device would be louder than a product which would interfere with
TV listening in a room adjacent to the device. These results
suggest that the specific barometer statements used in the survey
were inadequate. They do not necessarily suggest, however, that
the barometer approach is inadequate.
526
-------
Table 3-33
Direction of Scale
Question; Can you tell me which of the two products would make
more noise?
Decibel Labels (A1-A4)
Correct (higher number)
Incorrect (lower number)
'Total
Number
49
13
62
Percent
79.0
21.0
100.0
"Number Only" Labels (B1-B4)
„
Correct (higher)
Incorrect (lower)
Total
Number
51
13
64
Percent
79.7
20.3
100.0
Decibel/"10 Decibel Increase" (AS)
,
Correct (higher)
Incorrect (lower)
Total
Number
16
2
18
Percent
88.9
11.1
100.0
527
-------
To determine the effectiveness of providing a range of
"ratings" as the comparative acoustic information, respondents
were shown two different labels having different noise ratings and
different ranges of ratings. The first label had a noise rating
of 60 decibels and a range of 60 to 80 decibels. The second label
had a noise rating of 50 decibels and a range of 30 to 50 deci-
bels. Respondents were told the labels would be found on two
different types of products and were then asked, "If you were
interested in buying a quiet product do you think the product with
the first label on it would be a good product to buy? And why?"
The correct response would be "yes" since the product was at the
lower end of the range. Consumers were then asked, "If you were
interested in buying a quiet product do you think the product
with the second label on it would be a good buy? And why? The
correct response would be "no" since the product was at the very
top of the range.
Very few people (about 10 percent) were able to answer the
range question correctly. Since they were also asked why they
responded as they did, it was possible to identify the reasons for
the incorrect responses. Three basic reasons were identified.
First, one group of respondents believed that the higher number
was the quieter product and therefore their responses to this
question were reversed. Second, another group of respondents
misunderstood the range statement. This group thought the range
information referred to the particular product being labeled and
not to other products of its type. They believed that the 60
decibel product - "under different conditions," "at different
speeds," "at different times" - could be as loud as 80 decibels
and therefore would not be a good product to buy, whereas the 50
decibel product "could only be quieter" or "could make as little
as 30 decibel noise" once you bought it, and therefore would be a
good buy. Finally, a very large group of respondents compared the
noise ratings only and disregarded the range information. The
number of people in this group increased dramatically as the
528
-------
amount and complexity of the information on the test labels in-
creased. This finding is not inconsistent with several well-known
"information overload" theories.
To determine if consumers presently understand the mathema-
tical or logarithmic nature of the decibel scale and whether a
simple label statement explaining the nature of the decibel scale
would suffice, respondents to this survey were shown labels
and asked, "What would the noise rating be for a product which
is twice as loud as a 60 decibel product?," and "What would the
noise rating be for a product which is half as loud as a 50
decibel product?" The results are shown in Tables 3-34 and 3-35.
Clearly, the respondents did not understand the mathematical
nature of the decibel scale. Only 5 percent correctly answered
that 70 decibels would be approximately twice as loud as 60
decibels, and not one person responded correctly that 40 decibels
would be half as loud as 50 decibels. What is more problematic,
however, is that the following explanation of the decibel scale -
"a 10 decibel increase will roughly double the amount of noise a
product makes" - provided little improvement. Only about 17
percent of the consumers shown this information provided the
correct response.
When asked if they believed they could use the kinds of
labels shown to them to purchase quieter products, and why or why
not, the answers were favorable, but respondents expressed the
desire to learn more about decibels. Table 3-36 shows the per-
centage, by type of label, of those answering the question that
believe they could use the labels.
Conclusions
While the people questioned in this survey responded very
favorably to a noise labeling program - stating that they would
like to have noise labels on products and that they could and
would use the noise labels - many of the responses to the ques-
tions requiring some understanding of "decibels" and the intended
use of the information on the label were unfavorable. Very few
respondents were able to correctly use the range information
529
-------
Table 3-34
Question on Nature of Decibel Scale
Question;
What would the noise rating be for a product which is
twice as loud as a 60 decibel product?
Decibel Labels (A1-A4)
Correct (70 decibels)
Incorrect (120 decibels)
Incorrect (other numbers)
Don't know
Total
Number
3
28
16
16
63
Percent
4.8
43.6
25.8
25.8
100.0
Decibel/" 10 Decibel Increase" (A5)
Correct (70 decibels)
Incorrect ( 1 20 decibels)
Incorrect (other numbers)
Don't know
Total
Number
3
5
6
4
18
Percent
16.7
27.8
33.3
22.2
100.0
530
-------
Table 3-35
Another Question on Nature of Decibel Scale
Question; What would the rating be for a product which is half as
loud as a 50 decibel product?
Decibel Labels (A1-A4)
1
Correct (40 decibels)
Incorrect (25 decibels)
Incorrect (other numbers)
Don't know
Total
Number
0
30
20
14
64
Percent
0.0
47.5
31.2
21.3
100.0
Decibel/" 10 Decibel Increase" (AS)
Correct (40 decibels)
Incorrect (25 decibels)
Incorrect (other numbers)
Don't know
Total
Number
3
7
5
3
18
Percent
16.7
38.9
27.7
16.7
100.0
531
-------
Table 3-36
Ability to Use Labels
Question; Do you think that you could use these kinds of labels
to purchase quieter products?
Decibel Labels (A1-A4)
Yes
No
Don't know
Total
Number
44
14
6
64
Percent
68.8
21.9
9.4
100.1
"Number Only" Labels (B1-B4)
Yes
No
Don't know
Total
Number
47
11
4
62
Percent
75.8
17.7
6.5
100.0
Decibel/"10 Decibel Increase" (A5)
Yes
No
Don't know
Total
Number
14
2
2
*8
Percent
77.8
11.1
11.1
100.0
532
-------
provided on the labels, many misinterpreted the barometer informa-
tion, and only a very small percentage of those answering ques-
tions on the "decibel" understood its mathematical nature, even
when "a 10 decibel increase will roughly double the amount of
noise a product makes" was included on the label. However, the
answers that were given to the question "why" they answered the
choice-of-product questions suggested: that a minor modification
to the range statement might increase consumer understanding a
great deal; that alternative barometer statements might be more
successful than the one used during the survey; and that addi-
tional explanatory decibel information might be an acceptable
substitute for a complete understanding of the mathematical nature
of the decibel scale.
FOCUS GROUP DISCUSSIONS
Objectives
The objectives of the focus group discussions were closely
tied to the conclusions of the door-to-door survey. They were to:
(1) determine if consumers needed to understand the mathematical
nature of decibels to be able to use decibel noise labels; (2) de-
termine if negative responses to the range and barometer informa-
tion obtained in the door-to-door survey were related to the
specific statements used to communicate this information, or to
the informational approach in general; and (3) determine what
information consumers would like to have placed on labels, and how
they would like it to be communicated.
Procedures
Five focus group session's were conducted with people selected
through a quota sampling system.
The quota sampling was intended to .develop a group of par-
ticipants that would be approximately 50% male and 50% female with
a total composition of approximately 15% non-white. The group was
533
-------
intended to be based on a broad range of demographic features
primary of which were age, education, sex, race and family income,
but not in that order.
A total of 62 people attended the five focus group sessions.
Their demographic characteristics are presented in Tables 3-37
through 3-41. As can be seen from these tables a wide representa-
tion of consumers was obtained. A summary of the participants1
reactions to each of the labels tested is provided in the follow-
ing section. Appendix D contains a more detailed summary of focus
group comments.
Table 3-37
Age of Participants
20 and younger
21-25
26-30
31-35
36-40
41-45
46-50
51-55
56-60
61 and older
Total
Number
2
10
21
17
5
1
0
3
2
0
61
Percent
3.3
16.4
34.4
27.9
8.2
1.6
0
4.9
3.3
0
100.0
534
-------
Table 3-38
Sex of Participants
Male
Female
Total
Number
30
32
62
Percent
48.0
52.0
100.0
j
Table 3-39
Education of Participants
High school grad or GED
Some college
College degree
Some graduate work
Advanced degree
Total
Number
11
27
13
2
9
62
Percent
] 62.0
| 38.0
100.0
Table 3-40
Race of Participants
White
Non-white
Total
Number
55
7
62
Percent
89.0
11.0
100.0
535
-------
Table 3-41
Annual Household Income of Participants
$5,001-$ 10,000
$10,001 -$15, 000
$15,001 -$20,000
$20,001-$25,000
S25,001-$30,000
$30,001-$35,000
S35,001-$40,000
$40,001 and over
Total
Number
5
19
4
14
10
13
5
2
62
Percent
} 39.0
) 45.0
) 16.0
100.0
The procedures in the focus groups included a series of prod-
uct and label displays, followed by self-administered question-
naires and in-depth exploratory interviewing. Four different
types of products were labeled and displayed in the first four
focus groups - three food blenders were labeled with "Compare
Noise Rating" labels which stated "decibels" next to the number
value Of the rating; three food mixers were labeled with labels
showing a range of "ratings"; three hair dryers (blow dryers) were
labeled with "decibel guide" labels, i.e., a barometer by which it
was possible to gauge the effect of certain levels of noise; and
three power drills were labeled with "as loud as" labels, i.e.,
the decibel levels associated with certain products or actions.
Power drills were also labeled in the fifth focus group session
with labels developed from recommendations obtained during
the first four sessions. Samples of each of the above types of
labels and alternative labels which were shown to participants of
the focus group discussions are provided in the Results section
which follows.
536
-------
Results
o General Reactions to Labels Stating Decibels
(Label A: Figure 3-4)
The EPA seal and name on the label served to legitimize the
label information. It was likened by many to the EPA automobile
MPG labeling program -
-"If someone saw EPA they'd think of automobile regulation.
They'd relate it to the way the government is trying to
regulate gas mileage."
-"We always hear about the EPA ratings on gas mileage and all
it means to me is 'measurement.' It doesn't mean approval
or disapproval."
All of the participants understood that the general purpose
of the noise labels was to communicate information on a product in
the form of a noise rating, but some of the consumers did not
understand the direction of the decibel scale, and many expressed
a desire or stated a need to learn more about decibels. No one
expressed a desire to have dB, dB(A) (abbreviations for decibel
and an "A"-weighted decibel), or an explanation of the unit of
measurement on the labels, but several consumers suggested that
the words NOISE RATING be changed to OPERATING NOISE LEVEL.
o Range Labels (Label B: Figure 3-5)
General reactions were very positive to labels stating a
range of ratings: "a product range is important"; "it gives you
something to go by - to use as a guide." Very few individuals
misinterpreted the range information as was the case in the door-
to-door survey. Tying the range down to the particular type of
product - in this case, food mixers - helped to eliminate much
of the confusion encountered during the door-to-door survey. The
participants in the discussions also understood the range was an
approximate range:
-"These end points are not necessarily fixed."
-"Right, it says approximately."
-"I'll also say that I believe there is a drill that is less
than 70 and possibly more than 92."
-"I'll agree with that."
-"The 'approximate' range . . . that kind of spells it out."
537
-------
Figure 3-4
Label A: Example of a Decibel Label
Noise
Rating
Compare noise ratings.
Manufactured by: Cambridge Corporation.
Boston. Mass.
Federal law prohibits /'7C*S Environmental Protection
removal of this label. (.SBE,1 Agency.
Figure 3-5
Label B: Example of a Range Label
Noise
Rating 77***
The approximate range in noise ratings for
food mixers u from: 45 to 80 decibels.
Manufactured by: Cambridge Corporation.
Boston, Mass.
Federal law prohibits »'fC\ Environmental Piotection
removal of this label. (XK/ -Agency.
538
-------
o Range Label Alternatives (Label C: Figure 3-6)
General reactions to both of the range alternatives were
negative. The first one was said to be redundant and the second
was said to be merely a longer way of saying the same thing.
Furthermore, the second alternative was incorrectly assumed to
represent the exact end points of the range by some and should
be avoided since, in fact, the end points are approximate. A
consensus was reached in all groups that the range alternatives
were not as good as the original range label shown to them.
o Decibel Guide Label (Label D: Figure 3-7)
The general reaction to the decibel guide information was
positive, although many participants expressed the desire to have
the range information on the label and the decibel guide in sup-
plementary or educational materials. Many of the group members
stated that the decibel guide contained too much information, but
that the information was necessary:
-"I think it is too much, but on the other hand, maybe they
could make a law to have it for about a year. It would
educate the person ..."
-"I agree with you [on that] as far as education is concerned.
This gives you something to go by, but it shouldn't be on
the label all of the time."
o Decibel Guide Alternatives (Label E: Figure 3-8)
Two alternative decibel guides were shown to the focus
groups. The first alternative incorporated only the specific
decibel guide statement which pertained to the particular value
of the descriptor. That is, those sample labels which had 84
decibels as the value of the descriptor, had only the statement
"75 and above. Must shout to be understood" on them. This pre-
sented a method of providing decibel guide information without
providing the entire decibel guide and therefore without providing
"too much information." The second alternative incorporated four
different decibel guide statements for each of the four decibel
levels. Two of these statements related to TV interference and
had been used in the door-to-door survey.
539
-------
Figure 3-6
Label C: Examples of Range Label Alternatives
Noise
Rating
//
The noise rating for this food mixer is 77 decibels.
The approximate range in noise ratings for
food mixers is from: 45 to 80 decibels.
Manufactured by:
Cambridge Corporation,
Boston. Mass.
Fedtral law prohibits /
removal of ihis label.
Env»onrnental Protection
Agency.
Noise
Rating
77
//
***
The lowest noise rating for a food mixer is approximately 45 decibels.
The highest noise rating for a food mixer is approximately 80 decibels.
Manufactured by:
Cambridge Corporation.
Boston. Mass.
Federal law prohibits
removal of this label.
'~r?
Environmental Protection
Agency.
540
-------
Figure 3-7
Label D: Example of a Decibel Guide Label
Noise Q A
Rating a4 decibds
Decibel Guide
75 and above. Must shout to be understood.
60-75. .May interfere with normal conversation.
45-60. May interfere with relaxed activities.
45 and below. May interfere withjieea.
Manufactured by: Cambridge Corporation.
Boston, Mass.
Federal law prohibits ,'e\\ Enviionmental Piotection
removal of this label. UHX,' Agency.
541
-------
Figure 3-8
Label E: Example of a Decibel Guide Alternative
Noise
Rating
84
decibels
Decibel Guide
75 and above. Must shout to be understood.
Manufactured by:
Corporation,
Boston. Mass.
Federal law prohibits /'7C**-, Environmental Protection
removal o/this label. (.SBC,1 Agency.
^ X-* ^/
Noise
Rating
84
decibels
75 and above. Potentially damaging to hearing.
60-75. May interfere with TV listening in a room adjacent to the device.
45-60. May interfere with TV listening in the same room as the device.
45 and below. May interfere with quiet activities.
Manufactured by:
Cambridge Corpe/ation.
Boston. Mass.
Federal law prohibits //%"'-, Environmental Prelection
removal of this label. vJttt/ Agency.
542
-------
The general reactions to both of the decibel guide alterna-
tives were negative. Many of the participants reported, however,
that they would like to see a statement on the label to inform
them of potentially damaging decibel levels, such as "75 and
above. May be potentially damaging to hearing." The TV inter-
ference statements were criticized by all groups - "that last one
is bad ... really bad . . . when you have to compare it to TV .
..." General agreement was reached in all of the groups that the
original decibel guide was better than the alternatives, under the
assumption that the original could be modified to include state-
ments on potentially damaging decibel levels.
o Test of Barometer Statements
After having seen the different decibel guides, the focus
groups were asked to use the guides to estimate the decibel levels
of a number of different sounds such as that produced by thunder,
a dishwasher, a typical business office, etc. They were then
questioned to determine if any of the decibel guide statements
were useful in estimating decibel levels.
The results of this test are provided in Table 3-42. The
shaded boxes represent the approximate level of noise produced
by the examples given. With the exception of the noise level
produced by a typewriter, the group members were relatively
accurate in their estimates. The two decibel statements - "75 and
above. Must shout to be understood" and "60-75 may interfere with
normal conversation" - were said to be the most useful in estimat-
ing decibel levels.
These results have several major implications. First, the
responses were obtained from people who did not possess an under-
standing of the mathematical nature of decibels; therefore, the
decibel guide statements can be an adequate substitute for an
understanding of logarithms. Second, use of barometer statements
which best aid a consumer in decibel level estimation should be
considered for inclusion in the labeling program. Third, examples
543
-------
Table 3-42
Results of Decibel Level Estimation
(Shaded areas represent decibel levels identified in published acoustical reports)
EXAMPLE:
Breathing
1 . Garbage disposal (67-93)
2. Soft whisper (30)
3. Vacuum cleaner (62-85)
4. Thunder (110)
5. Air-raid siren (130)
6. Dishwasher (54-85)
7, Typewriter (80)
8. Rustling leaves (20)
9. Typical business office (50)
Decibel Levels
45 and below
(X)
1
;^>W
i
i
5
&&%$
3
45-60
1
1
3
5
2
' *'
/u
36
18
V;;;,34'; <*
60-75
f \. f * -
/19
'*&\:. *'
20
4
y s «v
-\32
21
1
24
75 and above
. 31;:,
- 38. >/
,34 J,
56 ^
'"14 " /
f ',,f
'"
\
Percent
Estimating
Corrccilv
96.8
98.4
93.7
56.7
90.3
77.4
:
69.3
54.8
-------
of sounds used to represent various decibel levels in the baro-
meter statements should be picked carefully. For example, a soft
whisper, measured at approximately 30 decibels, was perceived by
all but one of the respondents to be in the 45 and below category,
while rustling leaves, which were measured at 20 decibels (10
decibels lower than a soft whisper) , were perceived to be 45 or
higher by over 30 percent of the focus group members. Therefore,
a soft whisper would be a much better example for very low decibel
levels than would rustling leaves. Along the same line, an air-
raid siren would appear to be a more appropriate example for very
high decibel levels than would thunder. Finally, misleading ex-
amples, such as a typewriter, should not be used as examples of
noise since not one of the 62 participants perceived the sound of
a typewriter to be as loud as it actually is.
o "As Loud As" Labels (Label F: Figure 3-9)
Consumer reaction to the "as loud as" labels was very nega-
tive.
-"It bordered on ridiculous."
-"I think it is dumb."
-"I don't care for this at all."
Many of the group members reported that they could not judge
distance very well, that they could not determine how loud a
motorcycle, or truck, or car actually sounded, and that there was
too much variability in the loudness of cars, trucks, and motor-
cycles to make the comparisons meaningful: "Is it a new Honda or
a Harley Davidson with straight pipes?"- "Is that a Pinto or a
Corvette?" "Is it going 5 miles per hour or 70 miles per hour?"
o "As Loud As" Alternatives (Label G: Figure 3-10)
Two alternative "as loud as" labels were shown to the group
members. The first alternative incorporated all three of the "as
loud as" statements used separately on the original labels. The
second alternative incorporated different "as loud as" examples
for the three decibel levels.
545
-------
Figure 3-9
Label F: Example of an "As Loud As" Label
Noise
Rating
Decibel Guide
90 decibels is approximately as loud as a
moving motorcycle which is 25 feet away.
Manufactured by:
Cambridge Corporation,
Boston, Mass.
Federal law prohibits
removal of this label.
Environmental Protection
Agency.
546
-------
Figure 3-10
Label G: Examples of "As Loud As" Alternatives
Noise
Rating 92
Decibel Guide
70 decibels-Loud radio.
80 decibels-Garbage disposal.
90 decibels-Gas lawnmower.
Manufactured by: Cambridge Corporation.
Boston, Mass.
Federal low prohibits //%*'•, Environmental Prelection
removal olthis label. (SMC,1 Agency.
Noise
Rating ***
Decibel Guide
70 decibels-a moving car at 25 feet.
80 decibels-a moving truck at 25,feet.
90 decibels-a moving motorcycle at 25 feet.
Manulaclured by: Cambridge Cerporaiion,
Boston. Mass.
Federal law prohibits t'"f\\ Environmental Protection
removal of this label. (jfiKy' Agency.
^«
J
547
-------
Consumer reaction to the "as loud as" alternatives was very
negative - "I might not have a garbage disposal . . . What do you
call a loud radio? ... My idea of a loud radio might not be your
idea of a loud radio;" "there's too much variability in what they
are comparing . . . the reference is too variable." The second
alternative was reported to be somewhat better than the original
label and first alternative, although most consumers reported that
they did not like any of the "as loud as" labels - "I don't like
any of them/ but the bottom one is a lot easier to relate to."
o Test of "As Loud As" Examples
To help determine the usefulness of the "as loud as" ex-
amples, consumers were given two examples at the 70, 80, and 90
decibel levels and were then asked to provide three examples of
their own. The results of this test indicate that consumers are
remarkably accurate in their estimation of decibel levels. The
most frequently cited examples for each of the three decibel
levels are provided in Table 3-43. The general categories of
examples and the frequencies with which they were provided are
presented in Table 3-44. Many of these examples compare favorably
with decibel measurements found in published acoustical reports.
Kitchen and other home appliances were the most frequently cited
examples at the 70 and 80 decibel levels, while tools and vehicles
(trucks and airplanes) were cited most frequently at the 90
decibel level. The general categories also compare favorably with
published acoustical reports. These results indicate (as did the
earlier test) that, when consumers are provided with the proper
supporting materials, they may 'be able to effectively use noise
labels which are expressed in decibels.
Table 3-43
Most Frequently Cited Decibel Level Examples
70 decibels
Example
Typewriter
Dishwasher
Mixer
Hairdryer
TV
n
9
7
6
6
5
80 decibels
Example
Vacuum cleaner
Dishwasher
Hairdryer
Blender
n
14
13
10
8
90 decibels
Example
Power saw
Power (hand) drill
Pneumatic drill
n
10
9
8
548
-------
Table 3-44
General Categories of Examples Provided by
Consumers at the 70, 80, and 90 Decibel Levels
Kitchen Appliances
(Other) Home Appliances
Tools
Vehicles
Warnings
Voice-related 'Sounds
Activity-related Sounds
Animal-related Sounds
Place-related Sounds
People-related Sounds
Other
(Total Number of respondents)
Total number of responses
70 decibels
26
31
2
4
1
5
5
2
6
0
14
(46)
96
80 decibels
27
33
4
12
3
2
5
0
0
2
5
(46)
93
90 decibels
1
8
33
21
10
2
0
0
0
1
5
(46)
81
o Label Preferences (Figure 3-11)
Each focus group member was asked which of the label types -
range, decibel guide, "as loud as" labels - he or she liked the
best and the least. The majority reported that they liked the
range information the best and the "as loud as" information the
least. A number of participants reported, however, that the
decibel guide information was essential and should be available
in some form.
549
-------
Figure 3-11
Consumer Preferences of Label Types
(in order of preference)
Noise
Rating
77
decibels
The approximate range in noise ratings for
food mixers is from: 45 to 80'detibels.
Manufactured by:
Cambridge Corporation,
Boston, Mass.
Federal law prohibits
removal of this label.
., .Environmental Protection
,' Agency.
Noise
Rating
84
decibels
Decibel Guide
75 and above. Must shout to be understood.
60-75.,May interfere with normal conversation.
45-60. May interfere with relaxed activities.
*5 end below. May interfere with deep.
Manufactured by;
Cambrid9e Corporation.
Boston, Mass.
Federal law prohibits
removal of this label.
Environmental Protection
Agency.
550
-------
Figure 3-11 (Continued)
Consumer Preferences of Label Types
(in order of preference)
Noise
Rating
Decibel Guide
90 decibels is approximately as loud as a
moving motorcycle which is 25 feet away.
Manufactured by: Cambridge Corporallon,
Boston, Mais.
Federal law prohibit! S'f\t\' Environmental Protection
renovafef this label. ISK,1 Agency.
551
-------
Conclusions
The results of the focus group discussions indicate consumers
strongly agree that the range in noise ratings for products of a
given type should be placed on the label, while barometer or deci-
bel guide information should accompany the label. The negative
reactions to the range and barometer during the door-to-door
survey reflected difficulties that those being interviewed had
with the specific statements used to communicate the information,
and not to the approaches in general. Also, since these difficul-
ties did not show up during the focus group discussions, they
might have been a consequence of there being no example products
with which to associate the noise labels and information state-
ments.
The focus group sessions indicated that an appropriate
decibel guide or barometer may be an able substitute for consumer
understanding of the mathematical nature of decibels. These dis-
cussions indicated that consumers can, indeed, think in terms of
decibel levels when they have little or no understanding of the
logarithmic nature of the scale, as shown by the group members'
rather accurate matching of products with appropriate decibel
levels, and rather accurately supplied examples of sources which
would produce sounds of 70, 80, and 90 decibels.
A sample noise label recommended by the contractor is shown
in Figure 3-12 based on the results of the focus group discus-
sions. A sample noise chart or barometer which might accompany
the label, based on information from the focus group discussions,
is shown in Figure 3-13.
552
-------
Figure 3-12
Sample of Recommended Noise Label
Noise
Rating 77
Lower noise ratings mtan quieter products
Die approximate ran£e in See the EPA Noise Rating
noise ratings for food mixers Chart for further information.-
is from: 45 to SO decibels. about decibel ratings.
Manufactured bf. Cambridge Corporation.
Boston, Mass.
Fttferal law prohibits, /X"'-, Environmental Protection
removal of Ihis label. vBE,1 Agency.
Figure 3-13
Sample Noise Chart or Barometer
Noise Rating Chart
75 decibels and above. Must shout to be understood.
60 Id 75 decibels. May interfere with normal conversation.
45 to 60 decibels. May interfere with relaxed activities.
45 decibels and below. May interfere with sleep.
553
-------
REFERENCES FOR PART III
[1] Backstrom, Charles H. and General D. Hursh, Survey Research.
(Evanston, 111.: Northwestern University Press, 1963), p. 3.
[2] Bryant, Barbara E. "Respondent Selection in a Time of Changing
Household Composition," Journal of Marketing Research, XII,
(May, 1975), pp. 129-135.
[3] U.S. Bureau of the Census, 1970 Census of Population, General
Population Characteristics (Washington, D.C.: U.S. Govern-
ment Printing Office, 1971).
[4] Notice of Proposed Rulemaking. Noise Labeling Standards:
General Provisions. Federal Register, Vol. 42, No. 120,
Wednesday, June 22, 1977. p. 31722.
[5] Ibid, p. 31725.
554
-------
CONSULTANT'S GUIDE FOR PART III
Human Sciences Resources/ Inc. Westgate Research Park, McLean,
Virginia. Report #HSR-RR-78/10-Dl, 30 June, 1978.
555
-------
APPENDIX A
QUESTIONNAIRE USED
IN TELEPHONE SURVEY
-------
Wing:
(2*23)
24-25)
(26-27)
28-29)
Interviewer:
m
Date: f3*>
Shift: «D Morning
cfternoon
Evening
NOISE LABELING TELEPHONE SURVEY
Area Code
Telephone Number: I I I I [
nxn
Number of Adults in Household:
Selected Respondent: f/;D Male
"" «D
(20)
Oldcst
Youn
Only
Repeat as much of Introduction as necessary.
Now I'd like to ask you a few questions.
1. Do you ever feel uncomfortable or irritated by noisy products or appliances in your
home, your neighborhood, or your place of work?
,-., «d Yes
(21) «, n jjo
If no, skip to Question 5.
2. What are some of the products whose noise bothers you the most?
m
m
,32.33) rT~] Are there any others?
For products below not mentioned above:
3. Are you ever bothered by noise from:
vacuum cleaners?
chain saws?
»ir conditioners?
(34)
(35)
(36)
Yes
No
Not asked
Yes
No
Not asked
Yes
No
Not asked
559
-------
4. Are the most bothersome noisy products those that you own and use, or those used
by someone else?
by me
by someone else
both
WD not asked
5. Do you think that there is much difference in the amount of noise that different brands
of products such as vacuum cleaners or chain saws create?
Yes
(38) MD No
Don't know
Depends on the product
Now I'd like to know something about the things you think about when you buy certain
products.
6. Usually, in buying an appliance or a product do you consider price to be very important,
somewhat important, or not very important?
Very important
Somewhat important
(39) WD Not very important
WQ Depends on the product
7. Do you consider the brand name to be very important, somewhat important, or not
very important?
Very important
Somewhat important
WQ Not very important
WED Depends on the product
8. Usually, do you consider cost of operation to be very important, somewhat important,
or not very important?
Very important
Somewhat important
WD Not very important
Depends on the product
560
-------
Coding:
9. How about the quietness of the operation of a product or appliance?
WD Very important
(42) Wd Somewhat important
WED Not very important
WD Depends on the product
10. If you were planning to buy a vacuum cleaner and the average vacuum cleaner cost about
$70, how much extra would you be willing to pay, in dollars, for a vacuum cleaner that was
only
(41441
three-fourths as loud?
half as loud?
11. Do you think the government should set noise levels for some products?
Yes
(47) p57D ,No
I W D Don't know
Why not? _
If no:
12. Do you think consumers should be given information about the amount of noise a
product makes before they buy it?
(SO)
If yes:
Yes
No
Don't know
Do you think this information should come from the government, from the
manufacturer, or from some other source?
the government
(3i D the manufacturer
(51) W D other (specify:
don't know
not asked
Which source do you think would provide more accurate information about
the noise level of a product: the manufacturer or the Environmental Protec-
tion Agency?
Ia/
the manufacturer
the EPA
wD neither
not asked
both
561
-------
Coding:
56-V)
58-59)
60-61)
13. Would you like to see a label placed on products to show how much noise they make?
fs3f WD Yes
a D No
14. If a noise label were provided, would you be likely to use the information in your
purchase decision?
Yes
If no, skip to Question 18
Depends on the product
IS. If products were labeled to show how much noise they make, would you prefer the
label to be:
(*l D A hang tag attached to each product,
(55) m ^ ^ permanently affixed label on the product, or
W D A single sign as part of the product display, but not attached to each item.
Depends on the product.
Not asked.
16. Are there any products you think it would be particularly important to label?
17, I'd like to read to you four different ways of indicating on a label amounts of noise.
After I have read all four, please indicate which approach you would prefer.
W D A star scale where four stars meant a very quiet product.
A number scale where a low number meant a very quiet product.
^ color-coded label where a green symbol meant a very quiet product.
A word description which said "quiet" or "noisy."
(Si n No pre ference
WD Not asked
18. If putting a label on products to show how much noise they make would increase the
price, would you still want the information?
Yes
No
Depends on the price increase
WD Other
562
-------
19. I'd like to know if you can define certain terms for me now. If you don't know an answer
just say so rather than guess.
Can you tell me if a "therm" is a scientific measure of
electricity,
heat,
<64) WD noise, or
WO gas.
don't know
Can you tell me if a watt is a scientific measure of
electricity,
(65) heat'
WCH noise, or
WD gas.
don't know
Can you tell me if a decibel is a scientific measure of
WO electricity,
(66) WD heat'
noise, or
gas.
don't know
20. A decibel is a measure of noise level. City traffic is usually about 75 decibels, while a
quiet whisper is about 20 decibels. Can you guess how loud
(67-69) a vacuum cleaner might be?
(70-72) how about a lawnmower?
That's all of the questions I need to ask you. The information you've provided will go into
the decisions being made on labeling. We appreciate your taking the time to respond. Goodbye.
563
-------
APPENDIX B
DOOR-TO-DOOR SURVEY: INTERVIEW
PROTOCOL
-------
EPA APPLIANCE SURVEY
Code No.
Tract
Block
Date (11-1
Interviewer
INTRODUCTION
(1-3)
(4-7)
)
(8-10)
Hi, we're conducting a survey for the United States Environmental Protection Agency
which deals with people's attitudes toward noise. Would you mind if I asked you a few questions?
You don't have to answer any question you don't want to answer.
1. Do you ever feel uncomfortable or irritated by noisy products or appliances:
(IS) in your home? w° Yes «O No wn Don.tknow
(16) How about in your neighborhood? fl>E3 Yes WD No WD Don't know
(17) How about in your place of work? wd Yes ^D No WD Don't know
2. What are some of the products whose noise bothers you the most?
t'18-19) _..
; f20-2/;
'• (22-23)
(24-25)_
3. Are you ever bothered by noise from:
(26) vacuum cleaners?
(27) chain saws?
(28) air conditioners?
purchase of appliances for this household?
Yes
Yes
Yes
WD No
«O No
WD No
4. Are you ever involved in the
(29) WD Yes WP No
T
IF NO, ask to interview a person involved
in purchase of appliances.
Don't know
Don't know
Don't know
567
-------
Now I would like to show you a label for a few seconds which may be placed on appliances
in the near future. We are testing the ability of this label to communicate to you and would
like to ask you a few questions about it. We are not testing you, we are testing the label.
SHOW RESPONDENT LABEL NUMBER__FOR EXACTLY 10 SECONDS
Now I would like you to rate this label in several ways. Here is a group of cards which have words
and phrases on them and a seven-point scale.
HAND RESPONDENT GREEN CARD GROUP-Hard to Understand, etc.
Please look at each card, read me the letter on the card, and give me the number on the card
which corresponds to how you feel about the label.
Record Answers Below
QUESTIONS: (Green Card Group)
Letter on Card Number Comments
a. Understanding. (30),
b. Attractiveness (31),
c. Complexity (32),
d. Importance (33),
e. Label Reading (34).
Now I would like to show you the label again. Please read the label for as long as you think
you would if you were in a store and saw the label on a product which you were considering
buying.
SHOW RESPONDENT LABEL NUMBER __AGAIN
Now I would like you to rate the label again using these cards. Once again please read me
the letter on the card and the number which corresponds to how you feel about the label.
568
-------
HAND RESPONDENT WHITE CARD GROUP-Too little information, etc.
Record Answers Below
QUESTION 6: (White Card Group)
Letter on Card Number Comments
a. Information (35)
b. Interest (36)
c. Understanding (37)
d. Utility (38)
e. Label (good or bad) (39)
f. Believable Information (40)
g. Encourages procurement
of quiet products
Now I would like to give you a piece of paper which has two labels on it. The first label is
the same as the one you have just been looking at. The second label is very similar to the
first but would be found on a product of a different type. Please look at these labels for as
long as you like and then I will ask you a few questions about them. Remember we are test-
ing the ability of the label to communicate with you, we are not testing you.
HAND RESPONDENT SHEET
QUESTION 7: Can you tell me which of the two products would make more noise,
would it be the product with the first label on it or the product with
the second label on it?
(42) D fU First label. Why?
D (V Second label. Why?.
(3) D Don't know
569
-------
QUESTION 8: If you were interested in buying a quiet product do you think a product
with the first label on it would be a good buy?
(43) wD yes rod No
Why?
Don't know
QUESTION 9: If you were interested in buying a quiet product do you think a product with
the second label on it would be a good buy?
(44) WED Yes
Why?
No
Don't know
QUESTION 10: What do you think the rating would be for a product which was twice as loud
as the product with Label 1 on it? n Don't know
J3;
Why?
QUESTION 1 1: What do you think the rating would be for a product which was half as loud
as the product with Label 2 on it?
Why?
D
Don't know
QUESTION 12: Do you think that you could use these kinds of labels to purchase quieter
products?
(47) (Dd Yes wn No ^D Don't know
If yes, how would you do so?
If no, why couldn't you use the label?
If don't know, why aren't you sure?
570
-------
QUESTION 13: Do you think there is much difference in the amount of noise that different
brands of products make such as vacuum cleaners or chain saws?
Yes
(48) mC\ No
WD Don't know
QUESTION 14: Would you like to see a label placed on products to show how much noise
they make?
Yes
(49) ra/D No
If NO, skip past Question 15
Don't know
QUESTION 15: If putting a label on products to show how much noise they make would
increase the price of the products, would you still want the information?
Yes
(50) WD No
WD Don't know
WD Should not label
Now I would like to ask you a few questions about yourself for background purposes. Remember,
this information is being used for statistical purposes only.
QUESTION 16: Would you please tell me your age on your last birthday?
(51-52)
QUESTION IT.. What is your occupation?
(53-54)
QUESTION 18: What is the highest grade you completed in school?
For Coding
Purposes Only
grade school
junior high school
some high school
(55) wD high school graduate
some college
college graduate
some graduate work
graduate degree
refusal
571
-------
QUESTION 19:
Could you tell me approximately what your annual family income is?
Just give me the number from the list.
Under $5,000
$5,000-$"9,999
$10,000-$ 14,999
$15,000-$ 19,999
$20,000-$24,999
$25,000 or more
Don't know
Refusal
(56) WD
Comments:
LABEL NO.
572
-------
APPENDIX C
FOCUS GROUP: INTERVIEW GUIDE
AND QUESTIONNAIRES
-------
INTRODUCTION
Welcome to HSR.
We are conducting a study for the Environmental Protection Agency which deals with
noise. More specifically, the study deals with labels which may be placed on products in the
near future to tell consumers how much noise different products make. We have several different
types of labels we would like to show you and get your comments on ... whether you think
they are good or bad, easy or hard to understand, and so forth. Please don't be afraid to tell
us what you think... it's just as helpful for us to know that you don't like something as it is
to know that you do like something. Before we begin, I'd like to go around the room and have
each of you give your first name and tell us if any kinds of noise(s) bother you.
575
-------
Descriptor
Okay, does anybody have any questions?
Fine, In a minute, I would like all of you to go over and look at the labels on the
three blenders. I have a couple of questions I'd like you to answer on these forms when you
look at the labels. Please don't discuss the labels or the questions with each other. After
you have finished reading the labels please come back and have a seat.
Okay, has everybody gotten a chance to look at the labels?
Fine. Now I would like to ask you a few questions and I want to be sure everybody
answers each question in one way or another. We need a response from everybody but it's
okay for you to just say "I agree with him or I agree with her."
1. When you looked at the labels, what did the words "Noise Rating" mean to you?
2. What did the EPA seal and name mean to you?
3. What did the word "decibels" mean to you?
4. What did the number in front of the word decibels mean to you?
5. Do you think quiet products would have high noise ratings or low noise ratings?
6. How many of you knew that decibels referred to noise?
576
-------
7. How many of you have heard of dB's?
8. How about dBA's?
9. How many of you think you could use these labels to select a quieter product?
How would you do so? Why couldn't you do so?
There are several different ways to present the noise ratings. Please take a look at these labels
and tell me which type you like the best.
How about the least?
Can you think of any better ways to present the Noise Rating information?
577
-------
Range
Okay, in a minute I'd like you to go over and take a look at the labels on the mixers.
Again I would like you to take a little questionnaire with you to fill out when you are looking
at the labels. Once again, please don't discuss the labels with each other and when you are
finished please come back and have a seat.
Okay, has everybody gotten a chance to look at the labels?
Okay, now I'd like to ask each of you a few questions again like we did before. The
information in the second part of the label is what we're interested in now. We call this the
"range" information.
What did the range information mean to you?
Do you think the range information is important?
Do you think you need this information on the label to be able to use the label?
There are different ways of providing the range information. Please take a look at these labels
and tell me which type you like the best.
How about the least?
Can you think of any better ways to present the range information?
578
-------
Decibel Guide
Okay, now I would like you to go over and look at the labels on the blow dryers. Once
again, please don't discuss the labels with each other.
Okay, has everybody gotten a chance to look at the labels?
Okay, now I'd like to ask you a few-questions again. The information in the second
part of the label is what we're interested in now; we call this the "Decibel Guide" information.
Do you think the Decibel Guide information is important?
Do you think you need this information on the label to be able to use the label?
There are several different ways of providing the Decibel Guide information. Please look at
tnese alternative labels and tell me whether they are better, about the same, or worse than the
first one you saw.
Now I'd like you to answer a few questions for me about decibel levels. Here is a short ques-
tionnaire which has a number of different types of noise on it. I'd like you to place a check
in the column which you think is appropriate for the noise level of each type of noise.
Can you think of any better way to present the Decibel Guide information?
579
-------
'As Loud As*
Now I would like you to go over and look at the labels on the drills. Once again,
please don't discuss the labels with each other.
Okay, has everybody gotten a chance to look at the labels?
Fine. Now I'd like to ask you a few questions again. The information in the second
part of the label is what we're interested in; we call this information "As Loud As" information.
What did the "As Loud As" information mean to you?
Do you think the "As Loud As" information is important?
Do you think you need this information on the labels to be able to use the labels?
There are several different ways of providing "As Loud As" information. Please look at these
labels and tell me which one you like the best.
How about the least?
Can you think of any better way to provide this information?
580
-------
Label Preferences
Now that you have seen several different types of information on the labels, I'd
like you to tell me which type of information you like the best.
You have seen the "Range Information," the "Noise Guide Information," and the
"As Loud As Information."
How many of you like the range information the best?
How many of you like the noise guide information the best?
How many of you like the "as loud as" information the best?
581
-------
EPA NOISE LABELING
FOCUS GROUP INTERVIEW
To help us know who is attending these focus group interviews, please tell us the
following things about yourself. The information you provide will be confidential. DO NOT
put your name on this sheet.
Age:
Sex:
Education:
Race:
Annual Household
Income:
D 20 and younger
D 21-25
D 26-30
G 31-35
D 36-40
G 41-45
D 46-50
ill 51-55
G 56-60
O 61 and older
D Male
D Female
D Some high school
G High school graduate or GED
O Some college
G College degree
G Some graduate work
G Advanced degree
G Black
G White
G Neither black nor white (please specify
G $5,000 and under
G $5,001-510,000
G $10,001-$15,000
G $15,001-520,000
G $20,001-525,000
G $25,001-$30,000
G $30,001-535,000
G $35,001-$40,000
G $40,001 and over
582
-------
1. If you were interested dn buying a very quiet mixer, do you think that mixer A would
be a good mixer to buy?
D Yes
D No
d Don't know
2. If you were interested in buying a very quiet mixer, do you think that mixer B would
be a good mixer to buy?
D Yes
D No
D Don't know
3. If you were interested in buying a very quiet mixer, do you think that mixer C would
be a good mixer to buy?
D Yes
D No
D Don't know
583
-------
Please fill in blanks (c, d, and e) with more examples of what you believe would be
approximately as loud as the number of decibels given. If you cannot think of examples, please
write "don't know" in the blank or blanks.
'70 decibels" is approximately as loud as:
a. a moving car at 25 ft. 1
b. a loud radio / examples
c.
e.
'80 decibels" is approximately as loud as:
a. a moving truck at 25 ft. \
b. a garbage disposal j examples
c.
d.
e.
"90 decibels" is approximately as loud as:
a. a moving motorcycle at 25 ft. \ examples
b. a gas lawnmower j
c.
d.
e.
584
-------
Place an X in the column that you think describes the noise range for each of the
following items:
EXAMPLE:
Breathing
1. Garbage disposal
2. Soft whisper
3. Vacuum cleaner
4. Thunder
5. Air-raid siren
6. Dishwasher
7. Typewriter
8. Rustling leaves
9. Typical business office
10. Conversational speech
Decibel Levels
45 and below
(X)
45-60
60-75
75 and above
585
-------
APPENDIX D
EXCERPTED FOCUS GROUP COMMENTS
-------
APPENDIX D: EXCERPTED FOCUS GROUP COMMENTS
Reactions to Decibel Labels
Interviewer: What are your general reactions to the noise labels?
Group 1 -1 assume that it is a rating.
• If I would see one label I would go to look for another.
-1 would look at the labels and assume a better model wouldn't make
as much noise.
Group 2 -1 first noticed NOISE RATING, then looked at the figure and noticed
a differentiation by "decibels."
- (What did Noise Rating mean to you?) A connotation of loudness.
- (Did Noise Rating mean anything else to anyone else?)-I felt the higher
rating must be louder and wondered if pitch was differentiated.
Group 3 - It would have to tell you what decibels mean as far as sound goes. A lot
of people might really not know what they're talking about and just
automatically take the low rating.
- When I see that-I don't know how to read it right now-but once I know
exactly how the decibels go I think it is going to say how loud a product is,
but if I don't right now know I can't compare it to anything-what is 87
decibels?
- If it were a scaled system, or a scaled number of decibels per appliance
and consumer understood this rating, I think it would be a lot easier to
shop.
Group 4 - - Some scale by which you could measure noise.
- General problem until I saw all three labels is what did the noise rating mean-
you couldn't tell whether it was high or low. You need a basic education-
consumer education-for a person to evaluate.
589
-------
Reactions to EPA Name and Seal
Interviewer: What does the EPA name and seal signify to you?
Group 1 - It authenticates it.
- Nothing except the government is getting their thumbs on something else.
-1 didn't look at it.
- If someone saw EPA they'd think of automobile regulation. They'd relate
it to the way the government is trying to regulate gas mileage.
- If you see EPA as opposed to Joe Smith's Noise Rating-it's a lot more
impressive.
- A lot more impressive.
- It's an agency for standardization. They (labels) all go back to one point-
rather than what each manufacturer is saying.
- (Interviewer: Did anyone think that it meant this was a good product because
it had been tested?)-No.
Group 2 • Federal government—government regulation.
-1 didn't even notice it-I just saw numbers and "decibels."
Group 4 - It means some sort of government regulation.
• I would think with the seal that it had been inspected by some government
agency.
• It almost signifies legitimacy.
• I disagree with that. We always hear about the EPA ratings on gas mileage
and all it means to me is "measurement." It doesn't mean approval or
disapproval.
• Well, at least these products had been measured. I don't know whether all
products will have to be measured, but if it didn't have to be across the board,
the ones with the stamp would to me carry a little more legitimacy.
Group 5 -1 didn't even look at it. I think it's an excellent label though-very easy to
understand.
590
-------
Reactions to Decibel Alternatives
Interviewer: Does anyone like any of these three alternatives better than the decibel labels?
(The three alternatives are provided in the Figure on the following page.)
Group 1' - The first one (* and explanation), in my opinion, tells you more for the
average person. It has a rating... but explains it down here. It gives you more
information-it still doesn't tell most people though ...
- It catches your eye, but it doesn't say anything once you read it, to me.
• As far as the decibel rating... I think it's better to have decibel spelled
out. I probably could figure out dBA's in a very short time, but decibels are
associated with noise-87 decibels is very straightforward.
[General agreement that "decibels" is the best alternative.]
Group 2 -1 thought the first one was the best (decibels)-abbreviations and formulas
and asterisks connote being over-scientific-they look too hard-seems like a
consumer fraud.
-1 thought it was over-clarification which meant confusing the consumer issue-
the definition doesn't say anything.
• I agree.
-1 agree.
- The asterisk alternative is the most confusing.
• I agree.
-1 had no idea what dB or dBA's meant.
[General agreement that "decibels" is the best alternative.]
Group 3 • I prefer the first one (decibels) because I don't know what the others mean,
it might mean the same thing but I wouldn't know that.
- It seems like they're just adding more confusion, the simpler it is, the better
it's going to be.
[General agreement that "decibels" is the best alternative.]
Group 4 • I don't think anyone would understand what they meant (alternatives).
-1 was getting ready to say the same thing.
• If I saw that on a product I wouldn't know what it meant.
-1 would have no idea, except for "noise rating."
• The top one-I wouldn't know what they meant by A-weighted decibels-I'm
not familiar with any of it.
[General agreement that "decibels" is the best alternative.]
591
-------
Noise
Rating
87
Compare noise ratings.
Manufactured by:
Cambridge Corporation.
Boston, Mass.
Noise ratings are measured /<*
in A-weighted decibels at
\gne meter.
Environmental Protection
Agency.
Noise
Rating
O/
iBA's
Compare noise ratings.
Manufactured by:
Cambridge Corporation.
Boston. Mass.
Federal law prohibits
removal of this label.
Environmental Protection
Agency.
Noise
Rating
O /
dB's
Compare noise ratings.
Manufactured by:
Cambridge Corporation,
Boston, Mass.
Federal law prohibits /'s*\ Envirom
removal of this label. (+Z2J Agency.
Environmental Piotection
-------
Reactions to Range Labels
Interviewer: What are your general reactions to these kinds of labels, we call these labels
the range labels?
Group 1 - A product range is important. It helps you decide on that particular one.
It's a good guide. It helps you to measure.... it gives you the norm.
-1 think if you're going to buy a mixer, you know it is noisy, and the guide
shows you that if it's close to 80 it's going to be more noisy than a normal
mixer.
I Interviewer: How are you interpreting it?]
- These end points are not necessarily fixed.
- Right, "approximately."
- With same range on every label (for a particular type of product), I don't
think there will be any misunderstanding.
Group 2 - It gives you something to go by-to use as a guide. I had felt the need for a
reference guide to tell me what the numbers meant.
- It referred to mixers presently on the market.
-1 thought EPA determined that products could be no higher than the highest
number and the range indicated that the product in this range was "safe" or
not too noisy for consumers, i.e. food mixers should not go over 80 dB's.
-1 felt this particular product,could be as high as 80, or as low as 45, since it's
variable speed, it might.
- Felt that EPA hadn't recommended that range, it doesn't suggest a qualitative
connotation-just that on the market there exists mixers whose decibels range
from 45 to 80.
[Interviewer: How many people felt the range indicated an EPA standard?-!]
[Interviewer: How many people felt that any one food mixer could encompass
the entire range, depending on number of speeds?-1 ]
[Interviewer: How many people felt the range indicated approximately the
highest and lowest rated food mixer on the market?-14)
Group 3 -1 think it's very good. At least it gives people an idea of what type of noise
to expect from the appliance itself.
[Interviewer: What does that statement mean to you?]
- It's telling me that a food mixer at 45 decibels is going to be an extremely
quiet appliance versus Brand X at 80 decibels which will be extremely noisy.
593
-------
[Interviewer: Did it mean to anybody that that particular blender being labeled
could range anywhere from 45 to 80 decibels?-NO!]
- The only thing is I can't differentiate in my mind what 45 decibels sounds like and
an 80-1 don't know where 45 starts, I don't know how loud that is to begin with.
[Interviewer: Do you think that you could use this kind of information without
knowing that?]
- Yes, if noise bothers you, you definitely would go for the lowest one.
- The thing is you don't really know how many mixers are going to be in the
lower part of the range, like these three here, I get the impression that most
mixers are very noisy, cause they're all in the high 60's and 70's.
[Interviewer: How would this affect you as a consumer?]
• I would probably have to shop around more to see if there are any lower than
that. I would try to find one that's down in the forties.
Group 4 - That's better than the first one, but still you're not learning anything about
what a decibel is. I know about mixers now, but I don't know whether this
is harmfully loud or not... I still don't know anything about it.
- It appears to me that it's very loud.
-1 don't think people are educated yet to know what these all mean. Considering
all levels of intelligence-the majority wouldn't.
[Interviewer: Were any of those mixers a good buy?-NO!]
[Interviewer: Why was that?]
- All were high in comparison to 45.
[Interviewer: The range meant...?]
- You could find one for 45 or one for 80.
[Interviewer: Did it mean to anyone that the approximate range for that particular
food mixer could be anywhere from 45 to 80?—No.]
- It meant to me that all food mixers fall in that category and that these mixers
(the display models) were in the upper limits of the category of mixers.
Group 5 - It says here that the approximate range for power drills is from 70 to 92 ...
[Interviewer: What do you take that to mean?]
- It means that they have manufactured drills that hit 70 and also hit 92.
- Ill also say that I believe there is a drill that is less than 70 and possibly more
than 92.
- Ill agree with that.
• The "approximate" range-that kind of spells it out.
594
-------
Reactions to Range Label Alternatives
Interviewer: Does anyone like any of these alternatives (range) better than the one you've
just seen?
Group 1 - It doesn't tell me anything more.
- The first one is redundant. The second one seems like an elongated way
of doing it.
- The second one-I would get insulted-what am I a jerk or something?
• This one (the second)-for the less intelligent people, that is, the less informed
people ... they could use this a little better than the first one.
-1 think the approximate range may be confusing for some people. That
phraseology may be confusing, but as far as... the very first one (original range
label) is the most straightforward and I think it would be more easily interpreted
because the wording doesn't change.
[Interviewer: Does anyone like either of the alternatives better?-No.]
Group 2 [General Reaction: No.]
Group 3 • The bottom one on the second sheet is better. It gives you the lowest noise
rating, where the first gives you the approximate. It's more to the point, it
looks exact, "the lowest noise rating for a mixer is..." oh, wait a minute,
it does say approximate—scratch that comment
- It's basically saying the same thing.
- The top one is repetitious.
[Interviewer: Does anyone like the top alternative better?-No.]
[Interviewer: Does anyone like the bottom alternative better?-! ]
- Yes, because it tells you exactly what the noise rating is.
- No it doesn't.
- It still says approximately, it says the same thing. .
- The first one is better then.
[Interviewer: How many people like the first one better?-All]
Group 4 -1 like the second one. It lets you know exactly what lowest and highest are.
- The other one says "the approximate range."
- It's saying the same thing "is approximately."
-1 find the third one verbose.
[10 out of 11 like the original range label better.]
595
-------
Reactions to Decibel Guide Labels
Interviewer: What are your general reactions to these labels?
Group 1 - Like I was saying earlier, you had a rating but you didn't know exactly what
that meant-this is good because it tells you where you stand-what that
noise is going to do.
- It would give just about anybody a real good understanding about what a
decibel is. They would know how loud—they would have to shout to somebody-
they could compare that to another sound.
• I would be very interested in this type of label. I work as a hairstylist and
the part that I'd be interested in is "normal conversation" because I want to
talk while I'm drying hair.
Group 2 - Very, very informative.
-1 don't like it because it makes you think that there are products in the lower
decibel levels—you could spend a lot of time looking for the "non-existent" blender
in the lower range. I like the idea of having the range for the product. If
you want a product, you have to deal with what is on the market. From this
label assumes a 45 dB hairdryer is available.
- You can interpret this label in many ways.
• It borders on laughable—I really hope EPA is not spending too many tax dollars
coming up with labels like this. I think some amount of regulation is being
called for, but this srems to go over the edge, it's more than the consumer
needs. Why not have an index. This is going too far.
- But the label is meant to be informative, not for regulation. I think the infor-
mation is good.
• Yes, consumers cover a really wide range, it has to be easily understood.
- Isn't it too informative?
• I think it is too simple-but it still has to be understood.
-1 like the guide but perhaps it's too detailed. •
!
Group 3 • I think this is too much, but on the other hand, maybe they could make a law
to have it for about a year, it would educate the person and then go back to
the first one (the range).
• I look at it-if someone is going to buy a hair dryer, in my opinion, they're
not going to worry about whether they could be understood or whether your
children could hear you. You buy it because you need it, and this is just...
596
-------
[Interviewer: But if they could manufacture a hair dryer that would only
interfere with conversation and you wouldn't need to shout, would you buy it?]
-No.
- Yes you would, because I'm the one who has to listen to it! (spouse)
-1 think the guide should be reversed and have 45 and below at the top and
work your way down ...
- Yeah, because that's what you're looking for, you have to read so much before
you get there.
[Interviewer: How many of you like the idea of reversing the scale? 5 of 11.)
-1 like the idea of the scale to tell you the different ranges, and what they are.
I think it is much more accurate than the one you had before (range). It
gives you something to gauge it from.
-1 agree with you on that as far as education is concerned, this gives you something
to go by, but it shouldn't be on the label all the time.
- Yeah, people are lazy, they just won't read it.
- Once you know that... you look at something that's 50... you would and I
would automatically pick the 50 over the 65.
-1 think a lot of it-"must shout to be understood," "may interfere with normal
conversation"-these things are so personal, I can't sleep when there's a TV
going, but Sam, it doesn't bother him one bit cause hell sleep no matter what.
Group 4 -1 have a problem with this one. It tells you what the things mean, but it still
doesn't tell you how the product compares with the different brands.
- If I were to purchase one, I would look for one with 45.
[Interviewer: Do you think you could use this information to purchase quieter
products?]
- Not necessarily, because you may be forever looking for that 45 when the lowest
is 60 for that product
-1 think there is too much to read there. I don't think a person is going to spend
that much time reading.
- The worst one on there, the one that gives you the least information is "may
interfere with relaxed activities." I don't know what that means. The others
give you a pretty good idea about the sound associated with the decibel rating.
- It doesn't tell you how low they go. You may be looking for one at 45
when they don't even manufacture that in any brand. I don't understand "may
interfere with sleep."
- It doesn't tell me if it's going to bother me.
- When you asked if this had too much information-it doesn't, for what you're
trying to say, but I still like the last label which gave the range instead. Given
this kind of product-you can find them in a given range.
- This information should be like TV education. In school... advertisements...
where it's learned by everybody so it's common knowledge and doesn't have to
be written 5 million times.
- It's better to have the range for the kind of product you're buying.
597
-------
Reactions to Decibel Guide Alternatives
Interviewer: Does anyone like either of these two alternatives better than the one you have
just seen?
Group 1 - That last one (second alternative) is bad ... really bad ... when you have to
compare it to TV ...
• The only thing that last one (second alternative) does do is that "over 75 decibels
is hazardous."
• It gives additional information. In addition to being noisy it can be damaging.
-1 would be scared away by it... A hairdryer? Potentially damaging?... it would
scare you. I think the first one (original label) is the less dramatic of the three
and does get the point across.
-1 think the first one down here (second alternative)... "75 and above" and
"45 and below" are much more descriptive than anything. But the two in the middle,
when they compare it to TV are kind of... If they could take the two out
of the first one ... "may interfere with conversation" and "may interfere with
relaxed activities" and plug them into this one (second alternative)... you'd have
a dynamite rating system.
-1 think in the ratings you've got to tell them what it does... So it interferes
with normal conversation... Where you do have what's potentially damaging...
If this is to protect the consumer... I think you do need to show them what
damage can be incurred.
-What's «!relaxed" activities?
Groups 2, 3 [Tape recording errors were encountered. However, general agreement was
reached in both groups that neither of the two decibel guide alternatives were
better than the first one shown and the "TV interference" statements were
criticized by both groups.]
Group 4 - The bottom one would discourage me from buying any kind of blow dryer...
Because it's "potentially damaging to hearing" or "may interfere with TV in
an adjacent room" etc. The buyer would be discouraged before he got started.
[General agreement that neither alternative was better.]
598
-------
Reactions to "As Loud As" Labels
Interviewer: What-aie your general reactions to these labels?
Group 1 -I don't like any of that stuff.
• It's ridiculous.
- It's about as good as a duck on a pond, when it's raining in China
during a total eclipse.
- It's as good as one hand clapping.
-1 thought it was informative. It gave you something you could
relate to.
- But didn't it make you feel like an idiot?
- It put it in relationship to something you know.
• I don't know how far 25 feet is.
[Interviewer: Perhaps the idea is good, but the statements are bad?]
- You are qualifying "it. Some people like motorcycles... others don't. This
will color their opinions about how loud the product is.
• Your mood at the time you last heard the noise will also affect how loud
you think it is. How do you relate to a motorcycle?
- Going back to this one (decibel guide)... I think this is much more informative.
- a new Honda versus a Harley Davidson with straight pipes?-they're different.
• I think it is a good idea if you can find a common point, e.g. motorcycles versus
dirt bikes. The idea is good-the point of reference is confused.
- I've never paid attention to the noise of a motorcycle.
- But are there any sounds that you can relate to?
- A universal sound is the problem.
-1 like the statements about interference-whether it interferes with what you
are doing is most important.
• The concept is simplistic.
Group 2 - Bordered on ridiculous... Should you borrow a motorcycle to see what it
sounds like 25 feet away.
-1 didn't like it because it's using a reference that also varies. Compared with
a car—is that a Pinto or a Corvette?
• Yeah, at 5 miles per hour or 70 miles per hour?
- Yeah, I don't know how far 25 feet is.
[Interviewer: Does anybody like the distance idea?-NO!)
599
-------
Group 3 - It doesn't really tell you much. You have to flag down a car and tell it to get
25 feet away.
- Yeah, some cars are louder than others.
- Yeah.
- What size car? What size truck? What size engine?-or whatever.
- Yeah, what's it doing, what are the weather conditions?
- Or is it even sitting still?
- Also, I found as I went around (the table) that I didn't really notice until
I got to C (display Appliance C) that one (label) said a car, one Gabel) said
a truck, and one (label) said a motorcycle.
-Right.
[Interviewer: Does anybody like the idea of distance?-No!)
- It's too hard to reference.
- A lot of people don't know how far 25 feet is.
- If I were trying to figure this out (the label) from trying to read that
and trying to ascertain what type of sound it was, I'd say the hell with it
It wouldn't be worth the hassle.
Group 4 - It's dumb.
- Yeah, dumb.
[Interviewer: How many people think this label is dumb?—Everyone.]
[Interviewer: Why is it that you don't like this one?]
- You have to run out and find out what a moving motorcycle at 25 feet
sounds like.
* It's hard to relate to since I've known cars louder than motorcycles-it depends
on the car, the truck, and the motorcycle.
- It's very imprecise... I don't know what that means. The variation in motor-
cycles, trucks, and cars doesn't mean anything to me.
- If I were looking for a rating system I would be looking for something standard
that could be used across the board—not going from trucks to motorcycles.
I preferred the range where you could be your own judge about where you
wanted to go on the scale.
[Interviewer: How about the distance aspect?]
-1 don't care for that at all.
- I'm a terrible judge of distance.
- The main thing about this label... I keep thinking back to this being a label
from the Environmental Protection Agency and I'm not being told whether
I'm being protected or not. Again, I'd have to go back to the range.
600
-------
Reactions to "As Loud As" Alternatives
Interviewer: Does any one like any of these alternatives better than the original label?
Group 1 -1 might not have a garbage disposal. What do you call a loud radio? My idea
of a loud radio might not be your idea of a loud radio.
- I've never heard a gas lawnmower.
- You can't relate a gas lawnmower to a loud radio.
- How many feet is 25 feet? ... You don't pay attention to it.
-1 think you should relate it to interference.
Group 2 -1 wouldn't buy anything that sounds like a motorcycle or a truck because
of a bad experience with them.
- There's too much variability in what they are comparing. The reference is
too variable.
Group 3 -1 don't like any of them ("approximately as loud as" labels) but the bottom
one (second alternative) is a lot easier to relate to.
-Yeah.
-Yeah.
- Yeah, but how many people have never heard a garbage disposal.
-True.
-That's true
- Yeah, it's (garbage disposals) really only in the more modern or luxurious
homes, the cities.
- Or a gas lawnmower (for that matter).
-Yeah.
-Right.
- Yeah, a loud radio is very personal too.
- But, if they say 90 decibels sounds like a gas lawnmower, nobody will ever
buy a garbage disposal!
-1 think something like this 60 decibels is the conversation level or something
to that effect would be more effective ... something that is common to the
entire human race in other words-such as conversation-sleeping-shouting.
- It varies though.
- Yes, but compared to this ("approximately as loud as" labels).
• Normal... what is your definition of normal?
601
-------
Group 4 -1 don't like either of the alternatives ... nor any of this group ("approximately
as loud as"). The others were much better. I felt much more comfortable with
the information I got from some of the others than I do with this.
-1 don't think some people would know how loud a garbage disposal or a gas
lawnmower was.
- You can talk about a loud radio with a three-inch speaker or a loud radio with
a 20-inch woofer.
• Again ... there is no range for the drills.
- Go back to the first label (range label).
602
-------
Noise Labeling Preferences
Interviewer: You have now seen three types of labels... what we have called the "range*
labels, the "decibel guide" labels, and the "as loud as" labels. I would like
each of you to tell me which of the three types you like the best and why.
Group 1 - Guide-the first one gave you the range, but that didn't help you much.
- The guide helps you to relate to it.
- Range-from the consumer standpoint... it tells me I should shop around
... there are others lower.
- Range-helps you shop around.
- Guide-the reference you can apply across products.
- Guide—because I can relate to it.
- Range-same reasons as others.
- Guide-I can relate to it.
• Guide-same reasons.
- Guide-same reasons.
• Range-same reasons.
• Guide-same reasons.
Group 2 - Range-most people know generally how loud something will be and this
gives a guide.
-1 don't like any. Of these three, though, I like the range.
• All are bad. Need to clarify the range, e.g., "the range of those on the
market now is from..."
- Range
-1 feel all are unnecessary, but if I had to take one, I'd take the first one-
give the consumer the figures, better yet, let the consumer plug it into
the wall.
- Range-it's easier to understand, the decibel guide has too complicated
comparisons, the third one ("as loud as") won't work.
- Guide-if "relaxed activities" and "normal conversation" were clarified.
It gives more information if I wanted to purchase on the basis of quietness.
- Range-I wouldn't read the guide.
- Range
- Range-assuming 80 decibels is not going to damage ears or hearing.
- Range-but would want guide in stores, in public view.
• Guide-it clearly states how noise interferes with daily living, if this is
the purpose of the labeling program ... would like 75 level as "must shout
to be understood/can be dangerous."
603
-------
• Range—as long as some statement is included about the level which
is potentially damaging.
- Range—since I'd want to know about a given product.
- Range—but would like reference to which is potentially dangerous.
- Range-if safety factor were included, since no safety factor is included,
will recommend guide since it lets the consumer know which level is
potentially harmful.
Group 3 - Range—it's giving you a range in numbers, but I kind of like the one that
goes into more detail (decibel guide). I want to know that information,
but I don't want it to be on every label—the one I like the least is the
92 decibels ("as loud as") ... a motorcycle 25 feet away, even though
I don't like motorcycles... I still can't decide what that sounds like.
• Range-that seems to be the most direct message, you know that 77 is
fairly high-I like 84 (decibel guide) the least, nobody is going to read
all of that.
- Range-92 ("as loud as") I like the least, the other one (decibel guide) is
good initially but after that... it gives you a little information ... but
I wouldn't want it on the package all of the time.
- Range—this is the best as far as I'm concerned, once you get educated to the
point when you get this information (decibel guide information )... which
you can get in other ways too .... they can put it on television, minifUms, etc.
- Range-too much on 84 (decibel guide) and 92 ("as loud as") I don't like at
all.... but it is better than nothing.
• Range-the only thing is... I'd still like to see something on there that
tells people the higher number is louder/the lower number is quieter... I
still think people are going tc get mixed up, some people may think that
the 77 would be good, because it's close to 80 ... the 84 (decibel guide)
has too much and the 92 ("as loud as") I don't think people know anything
about distance.
- Range-I don't care for the 92 decibel ("as loud as") I can't relate to it...
initially I would like 84 (decibel guide) but I wouldn't want to read it all
of the time on every product.
• Range-92 ("as loud as") you just can't tag to anything ... what kind of
motorcycle? 77 (range) is the best, but it does make the assumption that
you know that 45 is very soft, but also the difference between 45 and 80 ...
is that a big range or small? ... the difference between 45 and 80 if the
loudest thing you can imagine is 200... we don't really have a way of
telling exactly ... it assumes that you know about how loud a food mixer is.
- Guide-like the 84 (decibel guide) because it gives you a good range and
tells you where things are, 77 (range) I think that gives you no basics,
or what to start with, and 92 ("as loud as") I don't like at all.
604
-------
- Range-but should be an asterisk after decibel and down at the bottom
say "a decibel is a unit of noise measurement on a scale of 0 to 130,
where 130 is the pain threshold," so that you know that higher isn't
better, and that the scale doesn't stop at 100 ... 84 is too busy ... and
92 is rather ambiguous even though it sounds precise.
- Range-I think this is going to be rather redundant all the way around the
room, but 92 basically cannot be related to; 84 ... is too busy; 77 (range)
is the best... I would look at the approximate range as "this is the quietest
it's going to be at the one end and the other is the loudest it's going to be
at the other end" but we still won't be able to reference... is 80 at the
painful level? is it still going to be what I can stand?
• Range-it tells you the rating for that particular appliance, for example,.
for drills this one will be high ... it kind of breaks it down a little bit
for you; (84) the information is good for educational purposes, but I
don't think it needs to be on the label, and 92 doesn't tell me anything.
• Range-but it should be supplemented with some sort of graphic repre-
sentation, such as a green to red type of thing like a stop light, everybody
understands red and green, give the decibel ranges in a color code; 84 would
be very difficult to read; 92 can't be related to.
• Range-because I could comparative shop and see which is about the quietest
and these others don't say anything about the specific appliance, but I do
think you also need some kind of gauge to tell you how it relates to the
threshold of pain.
• Range-92 is worthless; 77 is the best but I would definitely want to see it
combined with some type of a graphic or picture form using the information
on 84, maybe not that detailed, but something comparing it to the normal
conversation level.
- Range-92 is totally useless; 77 is the best but have something about a 0 to
130 scale; 84 is useless provided the consumer would be advised of this
in advance anyway.
Group 4 - Range—it (range) gives comparative information.
• Range-"as loud as" doesn't make much sense; "decibel guide" has too
much information and I probably wouldn't bother with it at all; the
first one (range) is more precise.
• Range-It (range) tells me something about the product in relation to
other brands of the same kind of product, so I liked that the best, the
92 ("as loud as") is the least satisfactory.
- Range—the first one (range) gives you a better idea of what you're looking
for in the particular product you're after so you can do comparison shopping.
I liked the last one the least ("as loud as")-it leaves a lot to your imagination-
I have nothing to relate it to.
605
-------
Range—First is the best (range). You still have the problem of whether 45
is high or low, but it's still a lot better-as opposed to having to sift through
a lot of information-Hiked the last one ("as loud as") the least.
Range-First is best (range) as long as the person is educated as to what
high is and low is—Least is the last one ("as loud as"), how many people
know what a moving motorcycle sounds like 25 feet away. It leaves you
wondering what they're talking about.
Range-First is preferable (range). It gives a clear scale. When you purchase
something there are many reasons for purchasing it. I think this would give
you a dear quick scale for determining the noise component.
Range-First (range) is best for the reasons we've stated and the last ("as loud
as") has no redeeming value whatsoever-social or otherwise.
Range-First one (range) because it gives you a scale to go by. The last
one the least ("as loud as") because it doesn't tell you anything.
Range-I agree with everybody else.
606
-------
APPENDIX E
PUBLIC PARTICIPATION
-------
This appendix contains a listing of contacts with the public,
the communications media and members of Congress during the develop-
ment of the regulation, and an abbreviated list of all the organiza-
tions, associations and individuals, both domestic and international,
that the Agency was able to identify as potentially affected by,
proponents of, users of or in any way interested in, the General
Provisions for Product Noise Labeling.
The Agency has actively contacted the parties on this list
by direct mailing of information to them about the General Pro-
visions.
609
-------
NOISE INFORMATION SYSTEM
ACQUISITION NUMBER
3324200X
3324190X
3324180X
319317AX
319316AX
331394AX
326213EX
32 6212 CX
33012 OAX
330119AX
330118AX
330117AX
330116AX
330115AX
330114AX
330113AX
330111AX
MEMBERS OF CONGRESS WITH WHOM THERE
WAS CONTACT DURING REGUIATORY DEVELOPMENT
Teague, 0.
Congress House of Representatives
Stokes, L.
Congress House of Representatives
Weicker, Jr., L. P.
Congress Senate
Esch, M. L.
Congress House of Representatives
Kennedy, E. M.
Congress Senate
Huges, W. J.
Congress House of Representatives
Bayh, B.
Congress Senate
Thurmond, S.
Congress Senate
Eagleton, T. P.
Congress Senate
Dodd C. J.
Congress House of Representatives
Glenn, J. H.
Congress Senate
Kenp, J. F.
Congress House Representatives
Talmadge, H. E.
Congress Senate
Schweiker, R. S.
Congress Senate
Hayakawa, S. I.
Congress Senate
Heinz, H. J.
Congress Senate
Stone, R.
Congress Senate
610
-------
NOISE INFOFMATICN SYSTEM
ACQUISITION NUMBER
MEMBERS OF CONGRESS WITH WHOM THERE
WAS CONTACT DURING REGULATORY DEVELOPMENT
3283840X
3275480X
3269760X
326462OX
324098AX
319367AX
305066DX
318576CX
318576AX
318553EX
316186AX
313730CX
312367BX
309516CX
310158CX
Hughes, W. J.
Congress House Representatives
Dodd, C. J.
Congress House of Representatives
Stokes, L.
Congress House of Representatives
Rousselot, J. H.
Congress House of Representatives
Griffin, R. P.
Congress Senate
Sawyer, H. S.
Congress House of Representatives
Griffin, R. P.
Congress Senate
Flock, S. T.
5611 St. Roch. Ave.,
New Orleans, La.
c/o Boggs, L.
Congress House of Representatives
Boggs, L.
Congress House of Representatives
Johnston, J. B.
Congress Senate
Rooney, F. B.
Congress House of Representatives
Hayakawa, S. I.
Congress Senate
Cederberg, E. A.
Congress House of Representatives
G, B.
Congress House of Representatives
Nunn, S.
Congress Senate
611
-------
NOISE INFORMATION SYSTEM
ACQUISITION NUMBER
31013CDX
31013QAX
310128CX
31012 6BX
31012 5DX
307443FX
305122CX
305121CX
302610CX
303770BX
3036373X
303449BX
MEMBERS OF CONGRESS WITH WHOM THERE
WAS CONTACT DURING REGULATORY DEVELOPMENT
Percy, C. H.
Congress Senate
Percy C. H.
Congress Senate
Hayakawa, S. I.
Congress Senate
Cederberg, E. A.
Congress House of Representatives
Thone, C.
Congress House of Representatives
Griffin/ R. P.
Congress Senate
Stevenson, A. E.
Congress Senate
Proxmire, W.
Congress Senate
Armstrong, W. L.
Congress House of Representatives
Armstrong, W. L.
Congress House of Representatives
Anderson, J. B.
Congress House of Representatives
Rooney, F. B.
Congress House of Representatives
612
-------
NOISE INFORMATION 'SYSTEM
ACQUISITION NUMBER
•
3329310X
332161CX
3316600X
3305110X
331497BX
330260ZX
3296870X
3309050X
3273000X
3272990X
3256990X
3237240X
314503AX
312626AX
312624MX
312622QX
312607EX
3227380X
320888AX
3207590X
3194620X
3194570X
305066CX
MEDIA CONTACT DURING REGULATORY DEVELOPMENT
Farm and Home News
Milwaukee Wisconsin Journal
Air Conditioning Heating and Refrigeration News
Appliance Manufacturing
New York Times
Noise Regulation Reporter
Parkersburg W Sentinel
Worcester MA Gazette
Lexington KY. Hearld Leader
Alameda CA. Times Star
Rental Equipment Register
Air Conditioning Heating and Refrig. News
Noise Regulation Reporter
Bureau of National Affairs
Noise Regulation Reporter
Bureau of National Affairs
Noise Regulation Reporter
Bureau of National Affairs
Noise Regulation Reporter
Noise Regulation Reporter
Passaic NJ Herald News
Noise Regulation Reporter
Occupational Hazards
Commerce Business Daily
Muffler Digest
Appliance Manufacturer
613
-------
NOISE INFORMATION SYSTEM
ACQUISITION NUMBER
3190830X
318576DX
3176870X
3176330X
3175860X
317278BX
3161530X
316152OX
3161500X
3156040X
3151060X
311855SR
314602 OX
314555GR
314554ER
314646WR
314646MR
314074PR
313641PR
313641HR
MEDIA CONTACT DURING REGUIATORY DEVELOPMENT
Product Safety and Liability Reporter
New Orleans IA Times Picayune
Kleiman, R. L.
lantana PL. National Enquirer
Changing Times
Sacramento CA. Bee
Sound and Vibration
Washington Post
Hall Street Journal
St. Louis Mo. Post Dispatch
Construction Equipment
Montgomery, G. F.
Scientific American
Bureau of National Affairs
Noise Regulation Reporter
Changing Times
Bureau of National Affairs
Noise Regulation Reporter
Bureau of National Affairs
Noise Regulation Reporter
Bureau of National Affairs
Noise Regulation Reporter
Bureau of National Affairs
Noise Regulation Reporter
Bureau of National Affairs
Noise Regulation Reporter
Bureau of National Affairs
Noise Regulation Reporter
Bureau of National Affairs
Noise Regulation Reporter
614
-------
NOISE INFORMATION SYSTEM
ACQUISITION NUMBER
312989CX
3126690X
312 02 6 OX
3116530X
31182SOX
3118230X
309517BX
310159BX
3081810X
308042OX
307832 OX
3081240X
30812OOX
3078190X
3078180X
3077830X
3077580X
3077350X
3077130X
3075580X
3075530X
3072680X
3075810X
3071890X
MEDIA CONTACT DURING REGULATORY DEVELOPMENT
Sound and Vibration
Dunkirk, N.Y. Observer
Los Angeles CA. Herald Examiner
Occupational Safety and Health Reporter
Lynn MA. Evening Item
Longview WA News
Business Week
Environment
Tacoma WA. News Tribune; Washington
Transport Topics
Cwensboro KY. Messenger and Inquirer
Kbldfax Oct. 1977, IP.
Air Conditioning Heating and Refrig. News
Portland ME. Press Hearld
Tulsa OK. World
Boston MA. Hearld American
Berland, T.
Pittsburgh PA. Post Gazette
Quincy MA. Patriot Ledger
Dallas TX. Morning News
New York Daily News
Washington Post
Damascus MD. County Courier
Yonkers NY. Herald Statesman
White Plains NY. Reporter Dispatch
615
-------
NOISE INFORMATION SYSTEM
ACQUISITION NUMBER
3073470X
306693DX
306382CX
3060730X
3061760X
3061710X
3061600X
305066BX
305025WR
3048950X
304861AX
3054410X
3054260X
3054110X
3053820X
3053520X
3052880X
304854CX
304703FR
304653MR
MEDIA CONTACT DURING REGULATORY DEVELOPMENT
Baltimore MD. Sun
Reprinted from New Civil Engineer,
29th August 1974
"Appliance Manufacturer"
Farrell, J. M.
Newark NJ. Star Ledger
Business Week Magazine
Eastern Sea Magazine
Air Conditioning Heating and Refrig. News
Appliance Manufacturer Magazine
Bureau of National Affairs
Noise Regulation Reporter
Collier, T.
Cedar Rapids Television Station
San Francisco CA. Chronicle
Berland, T.
San Francisco CA. Examiner Chronicle
Payton, B.
San Francisco CA. Examiner
Alameda CA. Times Star
Champion, D.
San Francisco CA. Chronicle
Anderson,C.
Cedar Rapids IA. Gazette
New York Times
Environmental News
Bureau of National Affairs
Noise Regulation Reporter
Bureau of National Affairs
Noise Regulation Reporter
616
-------
NOISE INFORMATION SYSTEM
ACQUISITION NUMBER
304653CR
30462SOX
3044900X
304575LR
304574YR
300273EX
302337BX
3038950X
3038450X
3037100X
302006CR
303705VX
3036890X
30362OOX
3036160X
3036060X
3035930X
301746DR
3015260X
3 01521 OX
MEDIA CONTACT DURING REGULATORY DEVELOPMENT
Bureau of National Affairs
Noise Regulation Reporter
Appliance Manufacturer Magazine
Philadephia PA. Inquirer
Bureau of National Affairs
Noise Regulation Reporter
Bureau of National Affairs
Noise Regulation Reporter
Sound and Vibration
Detroit MI. Free Press
Denver Co. Post
Environmental News
Birmingham AL. News
Bureau of National Affairs
Noise Regulation Reporter
Shaffer, T.
Denver CO. Post.
Lane, E.
long Island NY. Newsday
Cook, L.
Tulsa OK. Tribune
Murray KY. Ledger and Times
Nashville TN. Tennessean
Worcester MA. Gazette
Bureau of National Affairs
Noise Regulation Reporter
Nail Street Journal
Cummings, J.
Corvallis OR. Gazette Times
617
-------
NOISE INFORMATION SYSTERM
ACQUISITION NUMBER
3015180X
301714BX
3017160B
3013260X
3016700X
3015490X
3014050X
3013850X
3013770X
1128370X
1126430X
111147HX
1109490X
1105320X
16573
15061
14509
04860
72N00504
MEDIA CONTACT DURING REGULATORY DEVELOPMENT
Payette, V.
New York NY News World Daily
Cummings, J.
New York Tiroes
Bureau of National Affairs
Noise Regulation Reporter
OMAHA NB Evening World Herald
Chicago IL Daily News
Flattau, E.
Rockford IL Register Republic
Washington Star
Tucson AR Daily Star
Ann Arbor Minews
Commerce America
Outdoor Power Equipment Inst
OPEI Newsletter
Bureau of National Affairs
Noise Regulation Reporter
Erwin, D.
Dallas TX Morning News
Mr Conditioning Heating and Pefrig News
Modern Materials Handling
Noise Pollution Aatement Market
Jacobson, R. A.
Machine Design
Business Week
House Beautiful
618
-------
NOISE INFORMATION SYSTEM
ACQUISITION NUMBER
PUBLIC CONTACT DURING REGULATORY DEVELOPMENT
332161DX
3321220X
318752BX
3324240X
3324120X
3323150X
3323140X
3317370X
331731BX
3317290X
3317060X
331431AX
331621BX
3316140X
3316010X
3316340X
3318110X
3317930X
3317920X
3317910X
331465AX
3304870X
331560AX
American Society For Testing and Materials
Department of Conmerce/Occupational
Safety and Health Admin.
Union Carbide Corp.
Case J. I. Co.
Minnesota Mining and Manufacturing Co.
Smith Corona Labs.
Chain Saw Manufacturing Assoc.
Federal Trade Commission
Norton Co.
Farm and Industrial Equipment Inst.
Chain Saw Manufacturing Assoc.
Major Appliance Consumer Action Panel
Ceilings Interior Systems Contractor Assoc.
Vacuum Cleaner Manufacturing Assoc.
Underwriters Labs., Inc.
Construction Industry Manufacturing Assoc.
Perkins Diesel Corp.
American Society for Testing and Materials
Louis C. Kramp Assoc.
Association of Home Appliance MFRS.
Trane Co.
Federal Trade Commission
619
-------
NOISE INFORMATION SYSTEM
ACQUISITION NUMBER
3315940X
3298970X
3298930X
3302570X
3302370X
3302290X
3293340X: 3293350X
329327BX
329060BX
3150850X
329075BX
329075AX
3290630X
3289340X
3299290X
3299280X
3292730X
329269BX
3289630X
3289569X
3289530X
3289520X
329259BX
3290360X
PUBLIC CONTACT DURING REGUIATORY DEVELOPMENT
Federal Register
Verband Deutscher Elektrotechniker
Federal Trade Commission; Squire Sanders
and Dempsey
Union Carbide Corp.
Air Conditioning and Refrigeration Inst.
Sears Roebuck and Co.
Farm and Industrial Equipment Inst.
MPI Marketing Research, Inc.
Dekker and Nordemann BV
American Society For Testing and Materials
Baumgart, G.
Association of Home Appliance Manufacturers
American Society For Testing and Materials
Vacuum Cleaner Manufacturers Assoc.
Coast Guard
Federal Trade Commission
Air Conditioning and Refrigeration Inst.
American Speech and Hearing Assoc.
Federal Trade Commission
Conwed Corp.
Sears Roebuck and Co.
Singer Co.
Air Conditioning and Refrigeration Inst.
Noise Control Engineering
Texas A and M Univ.
620
-------
NOISE INFORMATION SYSTEM
ACQUISITION NUMBER
3283720X
3283710X
3274870X
3280080X
3277170X
327715AX
329044DX
3112830X
3142610X
3269840X
3269700X
3269620X
3269510X
326213CX
326212BX
3269390X
3269380X
3269370X
3265720X
3265280X
3261620X
3266170X
3265970X
3265800X
PUBLIC CONTACT DURING REGULATORY DEVELOPMENT
United Kingdom Embassy
Outdoor Power Equipment Inst.
Technology Consulting Group, Inc.
Association of Home Appliance Mfrs.
Stanford Research Inst.
Sylvester, Jr., J.
American Speech and Hearing Assoc..
Occupational Safety and Health Admin.
EPA Region III Philadelphia
Gonwed Inc.
Department of the Air Force
National Bureau of Standards
American Rental Assoc.
Vacuum Cleaners Manufacturing Assoc.
Electrolux
Audiology Inc.
Salem Label Co. Inc.
Southern California Uhiv. of
Toro Co.
National Bureau of Standards
Federal Trade Commission
Office of Management and Budget
Power Tool Inst.
Massey, W.
Department of the Army
621
-------
NOISE ACQUISITION SYSTEM
ACQUISITION NUMBER
3265790X
3265780X
3265730X
3256950X
3256930X
3256590X
3256230X
3266890X
3099290X
313236AX
3264630X
3260460X
3259530X
3135900X
0135870X
3257990X
3255350X
3254950X
3254820X
3254430X
3252280X
PUBLIC COMPACT DURING REGULATORY DEVELOPMENT
Washburn
Department of the Army
Marin, J.
Department of the Army
Outdoor Power Equipment Inst.
Hoover Co.
Bissell Inc.
Regina Co.
Interagency Regulatory Liaison Group Status
Citizens Against Noise
Consumer Product Safety Commission
Pennsylvania State University
Armstrong Cork Co.
Commerce Business Daily
Vacuum Cleaner Manufacturers Assoc.
Leach, A. F.c.
P.O. Box 10510
Portland OR 97210.
Bernstein, D.
Hoover Worldwide Corp.
Harnik, P.
2200 19th Street, N.W.
Washington, D.C.
Schwarz, W.
1215 First Avenue, 4A
New York, N.Y. 10021
Rosco Bloss of NBS
Consolidated Foods Co.
Aerospace Medical Research Lab.
Department of Air Force
622
-------
NOISE INFORMATION SYSTEM
ACQUISITION NUMBER
PUBLIC CONTACT DURING REGULATORY DEVELOPMENT
3252260X
325225BX
325225AX
3252130X
3247950X
3247830X
324760AX
323927BX
323927AX
3239110X
323910BX
323910AX
323909BX
323909AX
322631UX
3226220X
322578QX
3225750X
3225640X
3226080X
3226070X
Douglas Products
Bank of America Nat'l. Trust Savings Assoc.
Bank of America Nat'l. Trust Savings Assoc.
Air Conditioning and Refrigeration Inst.
Sears, E. L.
64 East Acocia Boulevard
Battle Creek, Mi. 49015
Kirby Co.
Bosch Siemens Hauseraete GMBH
Altuner, H. J.
219 B. Jackson Circle
Chapel Hill, N.C. 27514
Altuner, H. J.
National Bureau of Standards
Uncon Ltd.
Danzey, B. J.
Uncon Ltd.
New Zealand Department of Health
New Zealand Department of Health
Shop Vac Corp.
Contact with Mobile Source Labeling People
Smith, F.
Southwest Manufacturers Distributors, Inc.
Dowell and Dowell
Patchogue N.Y. Department of Environmental
Protection
French Government's Domestic Product Labeling
Program
Consoli, M. A.
Director Prevention Pollution Nuisances
623
-------
NOISE ACQUISITION SYSTEM
ACQUISITION NUMBER
3221560X
3213600X
3211850X
3211840X
3211830X
3211250X
3211210X
3209990X
3209920X
320682BX
3206580X
320365AX
3186250X
319141JX
318S82BX
318545AX
3184270X
3184180X
3179370X
PUBLIC CONTACT DURING REGULATORY DEVELOPMENT
Bautz, W.
ABT ZE-TV, Postfach 12 20,
7928 Giengen/Brenz, West Germany
Bosch Siemens Hausgeraete GMBH
Natter Manufacturing Co.
Northeastern Univ.
Jet Line Products, Inc.
Eureka Co.
Nixon, C.
Department of the Air Force
Limacher, R.
Petrosewicz, T.
Platts, J. H.
Robin, S.
Interstate Engineering
Association of Home Appliance Mfrs.
J. C. Penney Co., Inc.
Sound and Vibration
Interstate Engineering
Gypsum Assoc.
Trane Co.
International Organization for Standardization
Eureka Co.
Parrell, J. M.
819 Maconber St.
Greenville, MI 48838
Blaskovich, N.
Johnson, D.
Nixon, C.
Tobias, G.
Meyeroord Co.
Leboeuf Lamb Leihy and Macrae
624
-------
NOISE ACQUISITION SYSTEM
ACQUISITION NUMBER
3176420X
317557AX
3175510X
3172620X
317260BX
3170370X
3168590X
3165980X
3165970X
3161760X
3160920X
3155870X
3155480X
3154310X
3156120X
3153040X
3150670X
311418IX
311418HX
PUBLIC CONTACT DURING REGULATORY DEVELOPMENT
General Accounting Office
San Francisco CA. Police Department
National Inst. Occupational Safety & Health
AO Safety Products
Talty, J. T.
Robert A. Taft Laboraties
4676 Columbia Parkway
Cinncinnati, OH. 45226
Outdoor Power Equipment Inst.
Baake, P. K.
Carrier Parkway
Syracuse, NY. 13221
Leboeuf Lamb Leihy and Macrae
Technomic Consultants
Aerospace Medical Research Lab.
Fleming, R. M.
National Inst. Occupational Safety Health
Dieffenbach, A.
National Inst. Occupational Safety Health
Danzey, B. J.
Uncon Ltd.
Munger, G. R.
Air Conditioning and Refrigeration Inst.
Doyle, M. B.
International Snowmobile Industry Assoc.
Martens, T.
Walnut Creek CA. Contra Costa Times
Herold, W.
Yankee Clipper Trading Co. Ltd.
Pankiewicz, D. V.
New Jersey Department of Transportation
Ford Motor Co.
625
-------
NOISE INFORMATION SYSTEM
ACQUISITION NUMBER
311418EX
310934BX
310921AX
3082530X
3081B80X
3139140X
3132810X
309051AX
3083600X
3132570X
3132550X
313249BX
3128710X
3117290X
3120560X
3116140X
PUBLIC CONTACT DURING REGUIATORY DEVELOPMENT
North Dakota State Univ.
Krish, E.
30301 Forest Grove
Willowick, or 44094
Mentz, E. J.
Outdoor Power Equipment Institute Inc.,
New, J. T.
Hughes Tool Co.
Bilsom International Inc.
Brigham, R. N.
Electrolux
Hoover, J. S.
Hoover Co.
Campanella, A. J.
Acculab
Large, J. B.
Southampton Univ.
Doyle, M. B.
International Snowmobile Indus. Assoc.
Neroda, T.
968 Bradley Street
Watertown, N.Y. 13601
Northland Division
Taylor, H. E.
2000 Ocean Drive
Ft. Lauderdale PL. 33316
Citizens Against Noise
Doyle, P.
Outboard Marine Corp.
Denting, R. H.
McGraw Edison Co.
General Motors Technical Center
626
-------
NOISE INFORMATION SYSTEM
ACQUISITION NUMBER
3110200X
3098100X
3098090X
3095120X
3094650X
3094640X
3094620X
310158AX
3101360X
3101710X
3093870X
3074070X
3097970X
307647CX
3073770X
3091950X
PUBLIC CONTACT DURING REGULATORY DEVELOPMENT
Schmitz, H. D.
18081 Beach Boulevard
Suite A, Huntington Beach, CA. 92648
Audiology Inc.
Merfeld, M. J.
Century Engineering Corp.
Bobrowski, H.
Embassy of Federal Republic of Germany
Jensen, D. A.
Ford Motor Co.
Woods, T. J.
Aural Technology Inc.
Blaskovich, N.
National Inst. Occupational Safety Health
Broker, E.
Norton Co.
Black, L. L.
Route 2, Box 144-A
Millen, Ga. 30442
Tobias, G. B.
Civil Aeromedical Inst. P.A.A.
Rusch, F. S.
Stihl Inc.
Reynolds, Sr., E.
40165 Upper Calopooia Drive
Sweet Home, OR. 97386
Franz, R. N.
Chrysler Corp.
Form Letter to Radio Stations Asking for
Advance Coverage on Labeling Public Hearing
Engine Manufactures Assoc.
Forman, H. I.
Department of Commerce
Nolte, V. A.
Fairmont Railway Motors, Inc.
627
-------
NOISE INFORMATION SYSTEM
ACQUISITION NUMBER
3089500X
3089490X
3088760X
3080150X
3080120X
307645AX
307634AX
306973AX
3068130X
306372AX
306461AX
3063540X
3063140X
3063030X
PUBLIC CONTACT DURING REGULATORY DEVELOPMENT
Spiller, W.
Clipper Vacuum Systems, Inc.
Blyth, C. R.
Maytag Co.
Buyers Guide
Hoover Co.
Mohler, P. H.
Hoover Co.
Osterreichisches Normungsinstitut
Dwyer, R. T.
Outdoor Power Equipment Inst.
Cole Blaha, P.
135A East Colonial Court
Indian Harbour Beach, PL. 32927
Mott, E. S.
Mott Corp.
Adams, J. V.
Boulder Co. Office of Environmental
Protection
Milliken, W. 6.
Michigan Office of the Governor
Tobias, J. V.
Aeronautical Center, P.O. Box 25082
Oklahoma City, OK. 73125
Sobesky, J. V.
Harness Dickey and Pierce
Benwell, D. A.
Radiation Protection Bureau, Rm. 237
Tunney's Pasture
Ottawa, Ontario, CN.
Rodman, C. W.
1916 Race St.
Philadelphia, Pa. 19103
American Society for Testing and Materials
628
-------
NOISE INFORMATION SYSTEM
ACQUISITION NUMBER
3062870X
3062400X
3051640X
3051590X
3051430X
305121AX
3050940X
304876AX
304759BX
3031380X
3028730X
3029960X
302813AX
PUBLIC CONTACT DURING REGUIATORY DEVELOPMENT
Phillips, H.
20 North Wacker Drive
Chicago, IL. 60606
Association Home Appliance Manufacturers
Food and Drug Admin.
Wtight, J. H.
645 locust Street, P. 0. Box 476
Waukee, IA 50263
Faber, K. H.
Mercedes Benz of North America Inc.,
Flynn, R. P.
Safety Products, Southbridge, MA. 01550
Hyland, W. A.
708 Karen Lane
Horicon, WI. 53032
Environmental Protection Office Equipment
Noise Test Data
Boulder CD. Office of Environmental Protection
Boulder, CO.
Mohler, P. I.
General Offices and Main Factory,
North Canton, OKI 44720
Hoover Co.
Barnes, B.
Chrysler Indianapolis Foundry
Lund, A. L.
Spray Tech. Corp.
4307 Quebec Avenue North
Minneapolis, MN. 55428
Sornson, R. 0.
Chrysler Corp.
Food and Drug Administration
Louis, F.
Regie Nationale Des Usines Renault
100 Sylvan Avenue
Englewood Cliffs, N.J. 07632
629
-------
NOISE INFORMATION SYSTEM
ACQUISITION NUMBER
3027820X
3028020X
302653CX
302651DX
3026370X
3008160X
3040940X
304051BX
303735AX
303783DX
300606DX
300262AX
PUBLIC CONTACT DURING REGULATORY DEVELOPMENT
Kawano, J.
Toyota Motor Co. Ltd.
Lyndhurst Office Park, 1099
Wall Street, West, Lyndhurst, N.J. 07071
Shirai, C.
Japan Machinery Federation
Jackson, A. J.
Div. of Professional Services
Cincinnati OH.
Blumenthal, W. M.
Department of the Treasury
Perm, J. C.
Artie Enterprises, Inc.
Thief River Falls, MN. 56701
Michael, P.L.
Environmental Acoustics Lab.
110 Moore Building, University Park, PA. 16802
Pennsylvania State University
Federal Register
Thompson, J. N.
Room 481, Queen Anne's Chambers
28 Broadway, London, UK.
London Department of the Environment
Wasko, R. J.
Motor Vehicle Manufacturers Assoc.
Address: 300 New Center Building
Detroit, MI. 48202
Motor Vehicle Manufacturers Assoc.
Jones, D. K.
Large, J. B.
Organization for Economic Coop, and Devel.
Bruel and Kjaer Precision Instruments,
5111 West 164th Street,
Cleveland, OH. 44142
Leach, A. F.
Hearings Evaluation and Acoustic Res., Inc.
732 Northwest 19 Street
Portland, OR. 97209
630
-------
NOISE INFORMATION SYSTEM
ACQUISITION NUMBER
3001270X
3033300X
303440AX
3021230X
3021220X
3020730X
301699BX
300694AX
111351AX
1110670X
20206001
18210
PUBLIC CONTACT DURING REGUIATORY DEVELOPMENT
Johnson, D. L.
Biological Acoustics Branch
Biodynamics and Bionics
6570 TH .Aerospace Medical Division
Research Lab. (AFSC)
Weight-Patterson AFB, OH 45433
Peppin,R. J.
1711 Westwind Way McLean, Va. 22101
American Society of Mechanical Engineers
Maling, G. C.
Institute of Noise Control Engineering
P.O. Box 3206, Arlington Branch
Poughkeepsie, NY. 12603
Mellard, B.
Stihl Inc.
5701 Thurston Avenue, Box 5514
Virginia Beach, Va. 23455
McKenzie, M.
Southern First Aid Supply Co. Inc.
1120 Piedmont Drive, P. 0. Box 669
Lexington, N.C.
Macenko, F.
Environment Canada
Ottawa, Ontario, CN. KIA IC8
NBS Label Program
Reardon, J. P.
Mr Conditioning and Refrigeration Inst.
1815 North Fort Myer Drive
Arlington, VA 22209
Purdue Univ.
Jacklin, A. W.
Jacklin Seed Co.
Alexandre, A.
Environmental Directorate
Organization for Economic Coop and Devel
Miller, P. C.
5821 Harper Road, Zip 44139
Tooling and Production
631
-------
NOISE INFORMATION SYSTEM
ACQUISITION NUMBER PUBLIC CONTACT DURING REGUIATORY DEVELOPMENT
72N00485 Martin, W. 6.
Thompson,E. B.
Home Metal Production Co.,
Piano, TX
72N00484 Dorn, J. E.
Frigidaire Division
632
-------
PUBLIC PARTICIPATION THROUGH DIRECT MAILING
GENERAL PROVISIONS
CATEGORY
Acoustical Associations
NUMBER
OF ENTRIES
Business Associations
Citizens Associations
Community Groups/
Associations
Construction Industry
Associations
Consumer Associations
Environmental Associations
Associations of Importers/
Exporters
Insurance Associations
Legal Associations
122
7
13
17
19
126
19
11
EXAMPLES
Acoustical Society of
America
National Council of
Acoustical Consultants
American Chamber of Commerce
Jaycees International
Citizen Action Group
Call for Action
Rotary International
Lions International
American Building Contractors
Association
Associated General Con-
tractors of America, Inc.
Center for Consumer Affairs
Consumers' Union of United
States
John Muir Institute for
Environmental Studies
National Environmental
Development Association
World Trade Centers
Association
National Federation of
Export Management
Companies
Health Insurance Associa-
tion of America
International Claim
Association
American Bar Association
Special Committee on
Environmental Law
Student Legal Action Action
Organization
633
-------
CATEGORY
Manufacturers' Association
Professional Associations
Retailers' Associations
State & Local Associations:
Mayors & Governors
Teachers' Associations
NUMBER
OF ENTRIES
63
15
Trade Association
Congress
Congressional Committees
Docket Entries-
General Provisions
8
5
32
535
11
777
Environmental Research Centers 48
Federal Agencies
Foreign Embassies
International Organiza-
tions
42
102
2
EXAMPLES
National Association of
Manufacturers
National Canners Association
Home Economists in Business
American Society of Mechani-
cal Engineers, Inc.
National Retail Merchants
Association
U.S. Conference of Mayors
National Congress of Parents
& Teachers
National Education Asso-
ciation
National Beauty & Barber
Manufacturers Association
Northwestern Lumber, Inc.
Senate and House of
Representatives
Senate Committee on Energy
and Natural Resources
Environmental Sciences
Institute
Office of Management &
Budget
National Mediation Board
Department of Commerce
Embassy of Brasil
Organization for Economic
Cooperation and Develop-
ment
634
-------
Law firms with Environ-
mental Interest
Mail Order Houses
Major Manufacturers &
Distributors
Major Retailers
Media: Environmental
Publications
Media: General
Media: Industry Specific
Public Interest Groups
Sports Stores
State and Local:
Attorneys General
State and Local:
Governors
Universities
State and Local Law
Enforcement
State and Local:
Mayors, Local Noise
Officials and Health
Departments
State and Local
Procurement Offices
332
23
554
100
92
70
14
133
41
50
50
515
893
Abatuno and Chisholm
Walter Drake and Son, Inc,
Sears, Roebuck and Co.
National Gypsum Corp,
Eastman Kodak Co.
General Electric Co.
Top 100 Retailers
Journal of the Acoustical
Society of America
Archives of Environmental
Health
Cry Californian
U.S. News and World Report
Better Homes & Gardens
Heavy Duty Trucking
National Council of
Senior Citizens
American Association of
Retired Persons
Abercrombie and Fitch
50
Texas A & M
National Sheriffs
Association
L.A. Banda, City of
Fremont CA., Planning
Dept..
Zoning Administrator,
Tucson, AZ.
Mrs. Jane Byrne, Chicago
Purchasing Bureau, State
of Maryland
Material Management Bureau
District of Columbia
635
-------
Army/Navy Exchanges 2 Army/Air Force Exchange
System
Foundations 5 Carnegie Foundation
636
-------
TECHNICAL REPORT DATA
ff lease read Instructions on the reverse before completing)
I. REPORT NO.
EPA 550/9-79-255
2.
3. RECIPIENT'S ACCESSIO(*NO.
4. TITLE AND SUBTITLE
REGULATORY ANALYSIS SUPPORTING THE GENERAL
PROVISIONS FOR PRODUCT NOISE LABELING
5. REPORT DATE
August 1979
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO,
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Environmental Protection Agency
Office of Noise Abatement and Control
401 "M" Street, S.W.
Washington, D.C. 20460
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
Environmental Protection Agency
Office of Noise Abatement and Control
Washington, D.C. 20460
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
200-2
IS. SUPPLEMENTARY NOTES
16. ABSTRACT
This document presents information used by EPA in developing the
General Provisions for Product Noise Labeling including: a review of
other Federal labeling programs; the major issues involved in formu-
lating a general approach to product noise labeling; the approach to
the design graphics; potential technical problems associated with the
development of specific noise rating schemes; the Agency's response
to comments, and resolution of issues raised during the public comment
period; an analysis of the public comment to understand the public
perception of product noise labeling; and the participation of the
public throughout the development of the regulation.
7.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lOENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
Docket analysis, economics, enforc
ment, label graphics, Noise Rating
Noise Reduction Rating, sound
power, sound pressure, voluntary
labeling
i- Acoustic descrip-
tors, consumer
issues, labeling,
population surveys,
public participatior
rating schemes
8. DISTRIBUTION STATEMENT
RELEASE UNLIMITED
IB. SECURITY CLASS (This Report)
TTnnl aae-i -F-i oH
21. NO. OF PAGES
639
20. SECURITY CLASS (This page)
Unclassified
22. PRICE
IFA Form 2220-1 (t-73)
*UJ, GOVERNMENT PRINTING OFFICE: 1979 298-518/6395 1-3
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