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Pesticide Product Dialogue Committee Consumer Labeling Workgroup - 2006 Consumer Labeling Recommendations to the Committee

Abstract

The Consumer Labeling Workgroup has been working for the past year identifying opportunities to improve consumer product labels with the goal of improving label comprehension, label compliance resulting in improved human health and environmental safety.  The Workgroup narrowed its list of identified opportunities and focused its efforts for 2006 on environmental protections.  The Workgroup recommends the PPDC consider its proposed revisions to the Environmental Hazards section of consumer use pesticide product labels (see table 1).  The proposed language is action oriented and is specific to the product form (liquid, granular, dust) and specific to the hazard potential associated with the product form and use pattern (broadcast application, spot treatment).  The Workgroup proposes voluntary implementation by registrants through existing label amendment processes to ensure that the registration transaction costs associated with label improvements is minimized.

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Background

It has long been recognized that consumer use of pesticide products, such as disinfectant cleaners, pet products and lawn and garden products, differs significantly from the use of pesticides in agricultural production.  Some labeling statements written for professional pest control applicators and others who use pesticides in the course of their occupations, may not be similarly understood by an ordinary consumer.  The need for reevaluating and making changes to consumer product labeling policies was recognized by EPA and industry and the Consumer Labeling Initiative (CLI) began in March 1996 with a Federal Register (FR) notice issued by the EPA Administrator, Carol Browner (61 FR 12011).  A voluntary initiative, the CLI was established with the goal “to foster pollution prevention, empower consumer choice, and improve consumer understanding of safe use, environmental, and health information on household consumer product labels.”  The CLI was a multi-phased pilot project focusing on indoor insecticides, outdoor pesticides, and household hard surface cleaners, some of which are registered antimicrobials/ disinfectants.

The CLI was undertaken in two parts. Phase I began in early 1996 and ended on September 30, 1996. The Phase I Report (EPA, September 1996) published the findings, recommendations, and action steps. Phase II, which began in October 1996, resulted from this first phase of research.

Phase II addressed issues that Phase I did not complete or include, and focused on the following objectives:

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As a result of both the qualitative and quantitative research conducted as part of the CLI, a number of conclusion regarding consumer understanding and use of label language were reached: 

  1. There was no strong motivator suggesting fundamental label changes, but that language and format could be improved. Consumers were generally able to find the information they want on the label. However, the data also indicated that improvements would encourage more reading and use of product labels.
  2. Labels for each of the product categories should not be treated in the same way since consumers perceive the products differently and have different label reading habits for each category, as follows —
    1. Household cleaner labels should be simpler, with exceptional information (i.e., very important or different than anticipated) highlighted. There is a lower motivation to carefully read these labels because of the perceived familiarity with cleaning products.
    1. Indoor insecticide labels are generally effective, but improvements can be made to simplify labels and make them easier to understand.
    1. Outdoor pesticide labels are confusing because they are more complex and less frequently used, and therefore less familiar to consumers. They should be simplified and arranged for easier reading.
  1. Consumers want clear, concise, easy-to-read information that connects consequences with actions. Instructions on labels should say ‘why’ and jargon should be avoided.
  1. Consumers look to all traditional media to gain information. Therefore, outreach to consumers should incorporate traditional media, and should also include education efforts directed toward store personnel and other “influencers.”
  1. Name, type or category of ingredient, and purpose of ingredient can communicate ingredient information, not just by a list of chemical names. Ingredients should be presented in tabular form, with flexibility as to where in the label they are located (e.g., front vs. back panel of the label).
  1. Additional information is needed to better understand how to answer the need some consumers expressed for useful ingredient information. A full disclosure list of names does not further consumer understanding.

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Resulting from the conclusions reached, a number of label changes were recommended and many implemented, such as changing some terms, such as “Inert Ingredients” to “Other Ingredients” and “Statements of Practical Treatment” to “First Aid.”  Many registrants incorporated the recommended format changes, using bullet points, graphics, ordinal numbering of directions, etc.  In some areas simpler language was used, however, much of the mandatory language and headings remain unchanged and Agency policies in some cases blocks registrants from using positive statements of consequences related to consumer actions, instead maintaining an enforcement position of prohibited actions (Do Not’s) that may not indicate consequence.

As the Agency has continued to look at ways to promote the use of lower risk pesticides and encourage the proper use of pesticides, the area of “environmental marketing claims” was explored.  At the meeting of the PPDC in May, 2004 some ideas on “environmental marketing” were presented to the committee by two pesticide company representatives.  Two primary concepts were presented.  The first was that based on the success of other initiatives (recycling, pollution, forest fires) it was evident that consumers do change their behavior for the benefit of the environment when they understand the impact of their actions
.  The key was communicating those benefits with positive behavior statements – tell people what to do to have a positive influence on the environment being more effective than telling them what not to do to avoid a negative impact.  Secondly, based on consumer survey data, it was clear that consumers want to know how and where to use products safely, and it was proposed that the best way to provide that information is in direct language that speaks to safe use.
           
The recommendation was made at that meeting to form a workgroup to explore consumer labeling and come back to the full committee with recommendations for changes for consumer labels.  The stated mission of the group:

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Mission Statement

EPA is establishing the Consumer Pesticide Label Improvement Work Group, under the auspices of the Pesticide Program Dialogue Committee, to provide advice and commendations regarding improvement of label language on pesticide products intended for consumer use.  The goals of the Consumer Pesticide Label Improvement Program are two-fold.  First, we want to improve consumer understanding of safe use, storage, disposal and environmental and health information on household pesticide product labels.  Second, we want to design a Label Improvement Program that can be easily implemented by EPA and the registrant community to ensure that the registration transaction costs associated with label improvements is minimized.

This Labeling Improvement Program continues activities undertaken in the Consumer Labeling Initiative (CLI) which began in March 1996. Under the Consumer Labeling Initiative several recommendations were made.  Many of those recommendations including the “Read the Label FIRST” education program, presenting first aid information in simplified formats, including a toll-free number, and using new revised First Aid statements on consumer pesticide labels have been implemented.

However, there is still room for considerable improvement in label language for consumer products.  One of the CLI research conclusions was that improvements to the labels would encourage more reading and use of product labels.  The CLI recommended that “manufacturers and the EPA, where possible, use simple language, avoiding jargon; ..... and eliminate needless words.”  In the Pesticides Program, much of the boilerplate label language has been developed with the agricultural audience in mind.  The technical nature of that language may be essentially meaningless to consumers.  An example would be:  “Do not contaminate water when disposing of equipment wash waters.”  The technical aspect of such language may discourage consumers from reading the entire label.

The charge to the workgroup is:

  1. Working with EPA and other stakeholders, identify problematic language used on consumer pesticide product labels.  The identified language may be boilerplate language suggested in REDs for inclusion on labels or other standardized, frequently used phases.
  2. Prepare a menu of standardized alternative language and graphics, as appropriate, that registrants may use on consumer products as an alternative to current technical instructions.  The new language/graphics should be easy-to-read information that connects consequences with actions.  The objective is to develop label directions that consumers will read, understand, and follow, resulting in improved human and environmental safety.  The objective is not to make safety claims about any particular product.
  3. Recommend pesticide product criteria that can be used to limit use of proposed label language to products sold exclusively/principally to consumers.  Criteria could include package size or other appropriate “consumer distinguishing”factors.
  4. Consider whether further consumer education initiatives should be designed to increase the percentage of consumers who read pesticide product labels and follow the use directions.  Following the CLI recommendation, EPA has developed and  implemented the “Read the Label FIRST” campaign.  However, we are aware that most consumers do not read pesticide labels.  For example, the Green Gauge Report indicates that only 23% of Americans say they read pesticide product labels, down 4 points from the previous year.  The workgroup is encouraged to develop education materials, as appropriate.

    5. Advice and recommendations from the Consumer Pesticide Label Improvement Work Group will be provided to the Pesticide Program Dialogue Committee for its review and deliberation prior to being given to the Agency.

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The group initially met in May 2005 and discussed many key points discussed, and it was agreed to develop a listing of alternative language statements, keeping in mind enforceability and literacy. A variety of label improvement concepts were explored including environmental stewardship, environmental hazards, promotion of safe use instructions and claims, and bilingual and multilingual labeling. The group also wanted to look at the impacts of label language on the effectiveness of translations for bilingual labeling, given the growing trend towards bilingual labeling. While bilingual labeling as an issue was discussed, the group determined that the issue of bilingual label policy was outside of the scope of this group, but that simpler, easy to understand language could facilitate bilingual labeling.

The issue of bilingual labeling was also discussed in the initial work of the Consumer Labeling Initiative.  Then, as with the current workgroup, the issue was seen as important, but not specific to consumer product labels.  This issue should be further studied at a separate venue to recommend possible courses of action to EPA on bilingual and multilingual labeling. 

The group subsequently explored some work made available from the Consumer Federation of America on general principles for effective warning labels.  A summary of this work and findings is attached as Appendix I.  The conclusions reached that could be applied to the work on consumer pesticide labeling are “warnings should be designed so that they are conspicuous, understandable and readily easy to comply with. Designing labels that comply with existing standards and which incorporates the elements discussed above can not assure compliance, but can, however, enhance the likelihood that the warning label will be noticed, read, understood, and effectively change behavior.”

In addition, the group determined that the conclusion from the CLI that different product categories, based on the objectives for consumer behavior, be looked at differently, be reemployed.  As a result the group would again look at the three categories investigated in the CLI (since there was already much data on these categories) and looking at the following objectives:

The workgroup focused its efforts on outdoor use pesticides and the communication of environmental impacts and encouraging appropriate consumer behaviors.  The group did therefore not address household cleaner and Indoor Insecticides as concerns since consumer behavior has less impact on the environment. The workgroup focused on identifying problematic language that does not effectively communicate to the target audience, and developing alternative language designed to impact consumer behaviors that have the greatest potential to impact the environment.  Outdoor use pesticides were subdivided into categories based on product form and use pattern.  This division permitted development of targeted label language specifically applicable to the subject product and directly addressing the actions and responsibilities associated with each product category.  Outdoor use pesticides were divided into 1) liquid concentrates, 2) broadcast granules 3) dilute ready-to use liquids, and 4) dusts.

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Outdoor Pesticides: Environmental Impacts and Best Practices

The Environmental Hazards section of pesticide product labels are managed in the same manner and bear the same language for a very wide range of products and an even wider range of end users.  The language is typically developed for the first end-use product registration for a particular active ingredient and is subsequently utilized for all follow-on use sites, use patterns, and product forms.  The same language is utilized for the agricultural use product (generally the first end-use registration), the professional nursery or horticulture product, the professional turf product, and the residential use product.  The language is often maintained for all product forms as well, ranging from manufacturing use products to wettable powders, emulsifiable concentrates, ready to use liquids, dusts, and granular products.  Theses statements often bear chemical specific language, include technical information that is not applicable to the residential setting, and do not provide instruction or warning information that the residential users can act upon. 

The Workgroup concluded that the current Environmental Hazards statements do not meet the needs of the residential users and present an opportunity for revision to increase consumer comprehension, label compliance and enhanced protection of human health and the environment.  The statements were not developed for the residential users but rather carried forward from other use patterns to the consumer label. 

The Agency, registrants, and end-users have benefited from recent label improvement programs addressing consumer use product labels.  The First Aid statements and Storage and Disposal instructions have been revised in recent years to provide more direct and actionable statements that encourage specific consumer behaviors.  The same improvements are warranted for the Environmental Hazard section of consumer use product labels.

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The Workgroup Proposes Product Form and Use Pattern Specific Language

The environmental hazards are similar or identical for all forms of the end-use product whether it is a concentrate for broadcast application, a ready to use granule for broadcast application, a liquid trigger spray spot treatment product or a garden dust.  The product forms available to the consumer can vary considerably and the potential environmental risks associated with use of these products vary as well.  The Workgroup proposes statements that are specific to the product form and succinctly address the hazard potential associate with the product.  The distinction has effectively been made between indoor use and outdoor use products but a distinction must also be made among the various types of outdoor use products since each has specific attributes that must be addressed to minimize the potential for adverse effects.

Language should be use pattern and product form specific:  The environmental hazards language should be consistent among the product form (liquid, dust, granular) and the application method (broadcast spray, spot spray, granular spreader).  By providing consistent messaging for all “use-pattern specific” products, the consumer behavior and expectation can be replicated and reinforced.  The consumer will see the same information regardless of the brand or active ingredient.  Familiarity will breed consistent understanding and consistent action. 

Current Language is not actionable:  The environmental hazards statements simply state the potential hazard associated with the product (actually, the active ingredient) and do not provide constructive direction to encourage appropriate behavior or to discourage inappropriate behavior.  Revised language should promote best management practices, be consistent among like products, and be actionable.

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Workgroup Development Process 

Environmental stewardship label language will be most effective if it causes action and modifies behaviors.  Labeling should encourage beneficial behaviors and discourage negative behaviors.  The Workgroup moved forward with these goals in mind and began by identifying behaviors that should be reinforced and behaviors that should be avoided for each product category.  The resulting lists, as shown below, provided the foundation for the development of the Workgroups proposal for revised Environmental Hazard statements. 

Granular Products:  Ready to Use granular products, often is combination with fertilizers that are typically broadcast applied with a drop or rotary spreader.

Discourage Behaviors Encourage Behaviors
Outdoor Concentrates: Liquids mixed with water in tank sprayer or hose-end attachment.  Approximately half of concentrate use is applied via tank sprayer for spot treatment use.  The other half is broadcast applied via hose-end applicators.
Discourage Behaviors Encourage Behaviors

Aerosols:   Ready-to-Use Wasp and hornet products, spot weed products, foggers, aerosol fungicides, spot ornamental treatments. By nature not a broadcast treatment other than outdoor area-foggers.

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Discourage Behaviors Encourage Behaviors
Proper disposal

Liquid Trigger Sprayer: Spot weed product, insecticide used around perimeter of house–spot treatment products

Discourage Behaviors

Do not apply to any body of water

Encourage Behaviors

Proper disposal

Dust:  Garden or ornamental insect control or fungus control products.

Discourage Behaviors Encourage Behaviors
Proper disposal

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Recommended Revised label Language for Consumer Outdoor Use Pesticides

The PPDC Consumer Labeling Workgroup developed the following set of label statements and recommends the PPDC to encourage EPA adoption of these statements for all consumer outdoor use pesticide products.  The revised statements will provide the foundation for all environmental hazard label communications and can be supplemented with wildlife specific statement as acute toxicology data dictate (specific statements concerning fish, bee, aquatic organism precautions).

Table 1.  Revised Environmental Hazard baseline statements for consumer use products.

Liquid Concentrate Do not apply near water, storm drains or drainage ditches.  Do not apply when windy or when heavy rainfall is expected.  Rinse applicator over lawn or garden area away from storm drains.
Broadcast Granular Do not apply near water, storm drains or drainage ditches. Do not apply if heavy rainfall is expected.  Apply this product only to your lawn/garden, and sweep any product that lands on the driveway, sidewalk, or street, back onto your lawn/garden.
Dust Do not apply when windy when heavy rainfall is expected.  Do not apply near water or storm drains.
Liquid Ready-to-Use (RTU) Do not apply near water, storm drains or drainage ditches.  Do not apply when windy or when heavy rainfall is expected. 

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Implementation

The Workgroup’s mission statement and charter include the goal to “design a Label Improvement Program that can be easily implemented by EPA and the registrant community to ensure that the registration transaction costs associated with label improvements is minimized”.  The Workgroup suggests the PPDC and the Agency propose adoption of the revised statements by registrants on a voluntary basis.  The Workgroup also suggest the issuance of a PR Notices to provide guidance to registrants of the availability of these voluntary  label revisions. The Workgroup suggests that existing label amendment review process be employed for the revised statements as a means of ensuring ease of implementation and reducing costs associated with the proposed label improvement program. 

APPENDIX I

Summary of Warning Label White Paper

Introduction

The PPDC working group sought to draft more effective warning labels for pesticide products.  To achieve our goal, the working group sought guidance about how to draft and implement a user-friendlier warning label that better communicates to the consumer the inherent hazards of the products as well as the best safe practices for use and disposal.  To assist us in our efforts, the working group relied upon a white paper by Carol Pollack-Nelson, Ph.D. of Independent Safety Consulting written for Consumer Federation of America, entitled, “Warning Label Effectiveness: Overview of Current Research,” (September 18, 2003).  A summary of the paper is provided to illustrate the main elements, which were relied upon by the PPDC working group as we sought to draft warning labels for pesticide products.

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Summary of White Paper

The purpose of warnings labels is usually two-fold. First, it fulfills some statutory or legal obligation requiring manufacturers to notify consumers of potential hazards and second, it provides the consumer with information about how to safely use the product in order to avoid harmful consequences.  In the case of pesticides, both of these purposes are applicable: the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) sets out EPA’s regulatory authority over pesticides including warning label requirements and EPA has undertaken a Consumer Labeling Initiative (CLI) to better indicate what warning labels on pesticides should include.  In addition, the warning labels on pesticides seek to inform consumers about the safe use and disposal of pesticides.

While compliance with FIFRA and EPA’s CLI is mandatory, it is not sufficient.  Current guidance on warning label design and effectiveness is provided by voluntary standards.  The American National Standards Institute (ANSI), published ANSI Z535.4, which is a general standard for warning label design that can be applied to a wide range of consumer products.  This standard, used as a guide, by the PPDC Working group, identifies acceptable formats and key features for warnings and suggests a uniform and consistent visual layout.

ANSI Standard Sets out Guidelines for Effective Warning Labels

ANSI Z535.4 was first published in 1991 and revised in 2002.  This standard is most relevant to consumer product warnings and sets out the three distinct types of information panels that compose product warning labels.  These three parts are the signal word panel, the message panel and the safety symbol panel.

The signal word panel serves as a header for the label. A signal word such as DANGER, WARNING, or CAUTION calls attention to the safety sign and identifies the degree of hazard seriousness.  The signal word should be printed in bold upper-case lettering that is 50% larger than the other print on the warning sign.  A safety alert symbol, an exclamation mark inside an equilateral triangle should precede the signal word.  The color of the signal word and its background are critical components of the signal panel as well. For example, the word “DANGER” is used for imminently hazardous situations that if not avoided will result in death or serious injury.  ANSI Z3535.4 instructs that DANGER should be printed in white lettering on a red background.

The second panel of a warning label is the message panel.  The message panel usually consists of an identification of the hazard, the consequences of not avoiding the hazard, and how to avoid the hazard.  The message panel should be written and formatted so that it is concise and easily understood. ANSI Z3535.4 includes suggestions for drafting the text of the message.  These include: using language that can be understood by the target audience, writing using a headline style- eliminating non-essential words, using active voice and separating out the message content by using an outline format or bullets.

The third panel of the warning label, the safety symbol panel, is optional.  Safety symbols are graphic representations that convey specific hazard information.  The ANSI standard instructs that this panel should have a black symbol on a white background, though other colors may be used for safety emphasis.  Symbols should be pre-tested for comprehension to ensure that the public correctly interprets the intended meaning of the symbol.

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Warning Label Effectiveness

Since the goal of warning labels is to promote safe use of a product, assessing the effectiveness of how a label was able to garner compliance with the warning’s instructions is critical.  Effectiveness can be measured by the percentage of people who change their behavior as recommended by the warning label or by comparing pre- and post warning label injury and/or fatality data.  For a warning label to actually change consumer behavior, a number of hurdles must be overcome, including: the consumer must notice the label, the consumer must read and understand the message, the warning message must be encoded in the user’s memory, the user must remember the critical information at the time it is needed, and a decision is made as to whether or not to comply.

Research Findings Related to Warning Label Design

Salience

For the past several decades, researchers have studied different components of warning labels to identify the most important elements that facilitate comprehension and compliance.  The following factors have been analyzed: color (colored warnings are perceived as more hazardous than back and white and contrast between the lettering and background is important), warning size (larger the better), surround shape of the warning (surround the warning in a distinctive shape), off-setting the warning from other printed material (separating information with the use of white space or a border), symbols (pictorial depictions of the hazard or how to avoid it), signal word (use of a signal word attracts attention) and placement (placement where the warning is readily visible and alerts the viewer to the potential hazard in time to take appropriate action). A combination of some of these features has been found to best attract attention than the use of one element alone.  The inherent nature of pesticide containers, specifically the crowded packaging makes a combination of these elements difficult but not impossible to achieve.

Readability and Understandability

Research recommends the following characteristics to assist the reader in comprehending the warning: font and lettering style (sans serif typestyles and a width-to-height ratio ranging from 1:6 to 1:8, the use of upper and lower case lettering), letter size and spacing (formula for favorable reading conditions: when reading a warning at a distance of 2 feet or less, the recommended letter height is found by dividing: viewing distance in inches by 150, largest size of font is most preferred, spacing between lines improves readability), and outline format (writing text in headline style without non-essential pronouns or propositions, using bullets, and presenting text in a horizontal layout).

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Interpretation of the Message

Researches have identified the following features as assisting the viewer in interpreting the message on the warning label: signal word (used to draw attention and also to convey the degree of hazard posed, DEADLY is perceived as greatest degree of hazard followed by DANGER, WARNING, and CAUTION), explicit statements of the hazard and how to avoid it (this is influenced by the way the hazard is described and depicted), symbols (can convey a message without words, research found that consumers prefer warnings with pictures over text alone), and use of words familiar to the target audience (pretest the message to  ensure that the intended audience comprehends the message).

Obstacles to Warning Label Effectiveness

Consumers may overlook even a well-drafted warning label due to factors that are separate from the warning label itself.  Research has identified individual and situational factors that have been found to influence warning label effectiveness.

Individual Factors

The following individual factors have been found to influence warning label effectiveness: perceived product hazardousness, familiarity with the product, benign experiences using the product, perceived control over the product and potential hazards, and demographic variables such as age and gender.

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Situational and Product- Related Factors

The following situational and product-related factors have been found to influence warning label effectiveness: cost of compliance, task overload and stress, overuse of warnings and habituation, consumer interaction with the product, and the behavior of others regarding use of the product.

Conclusion

While the hierarchy of safety prescribes the following sequence for addressing potential hazards: 1) design the hazard out of the product, 2) guard or shield to protect against the hazard, and 3) warn users of the hazard, for pesticides, for which the hazardous component is essential to the utility of the product, the focus of the PPDC working group has been to improve the warning labels on the products.

Warning labels are inherently limited but much can be done to optimize their effectiveness.  Initially, warning label drafters should be familiar with ANSI Z535.4. In particular, warnings should be designed so that they are conspicuous, understandable and readily easy to comply with. Designing labels that comply with existing standards and which incorporates the elements discussed above can not assure compliance, but can, however, enhance the likelihood that the warning label will be noticed, read, understood, and effectively change behavior.

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