This chapter describes the goals, structure, processes, and activities
of Phase II of the Consumer Labeling Initiative (CLI). Phase I of the
CLI included qualitative research to investigate consumer comprehension
and satisfaction with product labels for indoor insecticides, outdoor
pesticides, and household cleaners[1].
Phase II, begun in October 1996, involved a more in-depth investigation
of label information and consumer satisfaction, comprehension and preference
for these product labels.
During
Phase I, recommendations were made regarding the following topics:
-
label
changes that could be implemented immediately. Announced in September 1997, these included using the headings
First Aid and "other
ingredients";
-
further
improvement to labels that could be made, but that would require additional
quantitative research to investigate how to make these improvements;
-
gaining
an understanding of consumers' comprehension of and preference for current labels on household cleaning
products, indoor insecticides, and outdoor pesticides;
-
addressing
consumer needs for better information about specific issues, such
as ingredient and storage and disposal information; and
-
creating
a consumer education campaign to inform consumers about the importance
of reading product labels carefully.
The
Environmental Protection Agency's
(EPA) commitment to Phase II of the CLI was announced in a September 1997
press briefing by EPA Assistant Administrator, Lynn Goldman. Phase II focused on the following issues:
-
finding
simpler, clearer ways to word advice concerning an accident or emergency
involving household products;
-
initiating
a multi-faceted, broad-based education campaign to help consumers
understand and use labels effectively, and to disseminate information
about future labeling changes;
-
investigating
further issues regarding storage and disposal information, with the
goal of resolving conflicts among product labels and laws, ordinances,
and community practices for recycling and disposal of waste;
-
conducting
in-depth research to determine baseline consumer understanding, attitudes,
behavior, and satisfaction about these types of product labels; and
-
conducting
research to determine what ingredient information consumers want and
need on labels for pesticides and other household products.
The
CLI is a voluntary initiative that depends upon extensive Stakeholder
participation. The many Stakeholder groups involved in the CLI have included:
consumer product manufacturers; retailers; marketers; trade associations;
environmental labeling program practitioners; government (federal, state,
and local) agencies, including non-U.S. government agencies; EPA Partners;
academics; public interest groups; consumer groups; environmental groups;
health and safety professionals; standard-setting organizations; media
groups; interested companies; and individual citizens.
All
Stakeholders with an interest in labeling issues concerning consumer products
have been encouraged to participate. Stakeholders have been actively involved in project planning, implementation,
review, and comment. Stakeholders
have provided particularly valuable input in identifying possible deficiencies
in current labels and in suggesting options for changes to EPA programs
not directly related to product labels. Individual consumers also participated in qualitative and quantitative
aspects of the research.
Role
of the EPA
The
EPA staff directed the project and worked with Stakeholders on all aspects
of the CLI, oversaw the qualitative research, and prepared the Phase I
and Phase II reports. After
considering the input from Task Force members and CLI Partners, the EPA
made certain decisions and recommendations about some policy questions
and issues that arose during the project. Dissenting opinions were always invited, and a wide diversity of
viewpoints is reflected in the findings.
Role
of the CLI Task Force Members
The
CLI Task Force was created by the EPA to provide direction for the initiative. The Task Force consisted of federal, state, and other regulatory
entities that have expertise and/or interest in labeling issues. The Task Force helped to determine the overall direction of the
project, provided input on the development of the research plan, shared
labeling-related experience and knowledge, and participated in the
design and execution of the CLI research. Appendix 1-2 includes the complete list of Task Force members.
Role
of EPA Partners
After
the Task Force was set in motion, the EPA invited all interested entities
and individuals to become "CLI
Partners" and participate regularly and on a long-term basis in the CLI. In Phase II, the Partners worked on, and were crucial to, the design,
testing, and execution of qualitative and quantitative research; funded
quantitative research; provided information sources for the literature
review; reviewed sections of this report; and donated their considerable
experience and expertise to the research process. The active CLI Partners included a number of businesses holding
significant market shares of these product categories, and trade associations
related to manufacturing and distributing indoor insecticide, outdoor
pesticide, and household cleaner products. Partners also helped to disseminate information on the CLI to their
members and colleagues. They
also assembled and organized comments and ideas from their membership
for presentation to the EPA. Appendix
1-3 lists the CLI partners.
Stakeholder
Outreach
Success
of the CLI required the involvement of many project Stakeholders. Over the course of both phases of the CLI, hundreds of individuals
and organizations expressed interest in the initiative. These Stakeholders included consumer advocacy groups, environmental
groups, consumers, health and safety professionals and organizations,
international groups, government agencies, manufacturers of consumer household
products, and retailers (for a listing of CLI Stakeholders, please refer
to Appendix 1-4). The CLI
Partners attempted to identify the particular interests of individual
Stakeholders and the most effective ways to communicate with and learn
from them. Communication
methods that were utilized to identify and communicate with Stakeholders
included the following:
-
press
conferences and public announcements for all important milestones
in the CLI, such as the Phase I and Phase II recommendations;
-
public
meetings, announced and publicized several months in advance, at which
Stakeholder feedback was actively sought;
-
news
releases;
-
publication
and dissemination of CLI informational memos to EPA staff, Partners,
Task Force Members, subgroup members, and other participants;
-
publication
and dissemination of consumer-oriented CLI "Updates"
to all parties that had expressed interest;
-
posting
of all published materials on the CLI website, in a form that could
be downloaded or printed online;
-
publication
of the names, telephone numbers, and e-mail addresses of CLI project
leaders at the EPA;
-
active
encouragement of participation by new Stakeholders;
-
identification
of important points for feedback on the CLI process and content;
-
solicitation
of written comments on public notices printed in the Federal Register;
and
-
informational
meetings of Stakeholders with the EPA management and staff.
Other Participants in the CLI
Other businesses
that participated in the CLI included:
-
Abt
Associates Inc., which, under contract to EPA, in Phase I reviewed
the literature and Stakeholder comments and wrote the Phase I report;
and in Phase II coordinated work of many participants, as well as
performed research, helped to develop questions for the quantitative
research, and wrote the Phase II report;
-
Macro
International, which, under contract to EPA, conducted the qualitative
research in Phase I, and the First Aid one-on-one interviews in Phase
II;
-
The Newman
Group, Ltd., which, under contract to EPA, performed the qualitative
survey research in Phase II; and
-
National
Family Opinion Research (NFO), which, under contract to one or more
CLI Partners, performed the quantitative survey research in Phase
II.
At
the close of Phase I, it was decided that in-depth quantitative research
was needed to further investigate consumer understanding, preference,
and satisfaction with current product labels. Additional information was needed on specific topics such as First
Aid, ingredient information, precautionary statements, direction for use,
storage and disposal instructions, consumer education, and standardized
environmental information on product labels. Smaller subgroups of Partner and Task Force members were established
to develop the quantitative research and to address these specific topics.
Throughout
the course of Phase II, subgroups worked both separately and together. Information from quantitative and qualitative research was incorporated
into decisions made by different subgroups. Similarly, knowledge provided by various subgroup members was taken
into consideration when developing the quantitative and qualitative research;
although, in one case, an omission led to inconclusive data. For example, the Storage and Disposal Subgroup shared information
with the Consumer Education Subgroup in preparation for the Consumer Education
Campaign. Another example
of this interaction is that the quantitative mail survey questionnaire
included questions about consumers' storage and disposal practices.
The
History of Phase II
Phase
II of the CLI began in October 1996. Between then and February 1997, Stakeholders involved in CLI engaged
in planning and preparation activities. The group formally adopted and initiated a joint strategy for Phase
II during the March 1997 CLI "kick-off" Partner and Task Force meeting. At this meeting the proposal for the Phase II quantitative research
was presented and Partner and Task Force members gave their support for
the research plan and development. It was announced at this meeting that EPA would be unable to fund
any quantitative research, given the magnitude of the project. Company and trade association partners felt very strongly that
such research would be vital for producing sound recommendations for label
improvement, and they voluntarily undertook to jointly fund and direct
a quantitative research program that would involve all of the CLI project
participants. Interim label
improvements arising from the Phase I research were also announced at
this meeting, as were policy initiatives such as standardizing label information. Finally, preliminary ideas for a consumer education campaign
were discussed at this meeting.
In
April 1997, the EPA met with environmental and public interest
groups, and other interested parties, to bring them up to date on the
CLI project and to introduce to them the quantitative research plan, interim
label changes, policy initiatives, and consumer education project. Environmental and public interest groups were invited to actively
participate in all aspects of the development of Phase II.
After
initiation of Phase II, a media event was held in September 1997. The Assistant Administrator of EPA's Office of Prevention, Pesticides and Toxic Substances (OPPTS), Lynn
Goldman, announced the immediate label changes that resulted from Phase
I of CLI. These included:
inclusion of a toll-free number on labels so that consumers could call
someone in case of emergencies, use of common names for ingredients instead
of chemical names, encouraging companies to use "other
ingredients" instead
of "inert
ingredients," simple first aid instructions, and changing the heading for these to read
"First Aid." It was also announced that in Phase II a fuller investigation of
the ingredients issues (i.e., right-to-know issues), and storage and disposal
issues would take place. Finally, the initiation of the quantitative research and the
development of the consumer education efforts were announced at this media
event.
In
February 1998, the entire CLI Partner and Task Force met in Alexandria,
VA. At that meeting, the
various subgroups gave status updates of the work they had done up to
that point. Development of
the quantitative consumer research was well under way and the research
Core Group updated the rest of the Partner and Task Force members on the
research methodology, questionnaire development, and research implementation. The EPA's
Deputy Assistant Administrator for the Office of Prevention, Pesticides
and Toxic Substances, Susan Wayland, asked Partner and Task Force members
to begin investigating the feasibility of including standardized environmental
information on product labels of household cleaners, indoor insecticides,
and outdoor pesticides.
Implementation
of the (national) quantitative survey began in April 1998 with
screening for participants and ended in June 1998. Results from the quantitative research were tabulated in several
volumes of raw data. Relevant
data were shared with the various subgroups (e.g., information about consumers'sources of information was shared with the Consumer Education Subgroup),
to gain feedback and interpretation of the data from the subgroup. The data were analyzed by the research Core Group. This group met several times via conference calls and face-to-face meetings throughout the months of July and August to interpret and analyze the data in order to develop findings and implications.
During
June 1998, while the quantitative research was coming to a close,
a small subset of the Research Core Group was formed to address the Phase
I charge of investigating standardized environmental information on product
labels. It was decided that
qualitative consumer research would be the best way to find out what types
of environmental information consumers want to see on labels. At this point, results from the quantitative research were beginning
to materialize, and they showed that, by and large, consumers did not
consider environmental information to be one of the more important parts
of product labels. Instead,
they indicated that standardized label formats would be useful for increasing
consumer comprehension of label information. The Core Group's
focus, therefore, shifted: the qualitative research, used to enhance the
findings from the quantitative research, would also be used to investigate
consumer preference for standardized label formats.
Qualitative
research took place during July and August 1998. Results from the research were incorporated into the overall conclusions
from Phase II. The findings,
implications, and conclusions of both the quantitative and qualitative
research were presented to the entire CLI Partner and Task Force on the
first day of the Partner and Task Force meeting in Washington, DC, in
September 1998. Subgroups also presented the work they had done since the February
meeting. During the second
day of the meeting, CLI Partner and Task Force members made recommendations
to the EPA for potential next steps (beyond Phase II) for CLI.
In
April 1999, the EPA held another Partner and Task Force meeting
in Alexandria, VA, to update CLI participants on steps that had been taken
since, and in response to, the recommendations made at the September meeting. The CLI recommendations were considered by the EPA. The EPA's
Office of Pesticide Programs (OPP) announced how it intended to address
the recommendations for label changes. Planning for a media event in Spring 2000 was announced. In addition, an update for the completion of the Phase II Report
was given, as well as an update on the activities for the Consumer Education
Campaign.
First
Aid Qualitative Research
Phase
II began by addressing the issues relating to First Aid information on
product labels. The qualitative research in Phase I found that the consumers
tested often referred to the First Aid section on labels only in the event
of an emergency or accident. When
prompted to read the text during the qualitative survey, however, many
of these consumers reported that the phrases on labels that tell them
what to do in these types of situations were confusing.
During
Phase I, CLI Stakeholders had recommended that one of the goals for Phase
II of CLI be to find simpler, clearer ways to provide instructions to
consumers about what to do in case of an emergency or accident. In accordance with this goal, the phrase "Statement
of Practical Treatment"
was replaced by "First
Aid." Furthermore, CLI Stakeholders worked with the EPA's
OPP to update and improve First Aid statements. The CLI team made a decision, based on previous research, to replace
the word "physician" with"doctor" and "area
of contact" with "skin."
During
Phase II, qualitative consumer research was conducted on a series of proposed
First Aid statements, to assess the potential for changing, simplifying,
and clarifying these statements. In July of 1997, the CLI conducted 23 follow-up interviews with
consumers to test several proposed wordings of First Aid statements. (See Chapter 5 for a full description of the Qualitative First
Aid research.) First Aid
instructions for all combinations of the Federal Insecticide, Fungicide,
and Rodenticide Act's
(FIFRA's) toxicity categories and hazard indicators were tested. The Office of Pesticide Programs (OPP) proposed an initial set
of First Aid statements, with input from industry, the American Poison
Control Center, and other CLI Partners and Stakeholders.
Based
on the results of these consumer interviews, the EPA revised the First
Aid statements. CLI Partners, Task Force members, and Stakeholders, such as
the American Red Cross, PPDC, and academia, commented and gave their feedback
on these revisions. The statements
were subsequently revised one final time, taking all of the feedback into
account. The final revisions
to the First Aid statements are expected to be released in an OPP Pesticide
Registration (PR) notice in Fall/Winter 1999. See Chapter 5 for a detailed discussion of the First Aid qualitative
research.
Quantitative
Consumer Research
Phase
I research yielded qualitative results about the circumstances under which
consumers read product labels, which parts of labels they pay the most
attention to, and satisfaction about current label information and format. Since the qualitative research could not provide quantifiable results,
the CLI used quantitative research in Phase II for this purpose.
The
quantitative research was a major component of Phase II of the CLI. The research was funded by several CLI industry Partners. The development of the quantitative research, including questionnaire
development, was a collaborative group effort involving industry Partners,
EPA personnel, Task Force members from the EPA and other federal agencies,
(e.g., the (Consumer Product Safety Commission (CPSC), and the Food and
Drug Administration (FDA)), as well as other interested CLI Stakeholders. The industry Partners hired an independent market research and
polling firm, National Family Opinion (NFO), to conduct the survey. The study design team took direction from the results of the CLI
Phase I research, including the many public comments received, as well
as input from the various CLI Subgroups (see discussion below) that were
meeting at the same time as the survey was being developed and implemented.
The
quantitative research consisted of a national survey of consumers. The survey aimed to:
-
collect
more data from consumers about potential new label formats and wording
changes;
-
benchmark
and study current consumer practices and preferences with regard to
product labels, to help the CLI determine what other label changes
are appropriate and how best to make them;
-
provide
information to help the EPA and CLI Project partners consider policy
implications and take some immediate actions;
-
assess
consumer ability to locate label information;
-
measure
consumer comprehension of labels; and
-
provide
demographic analysis capability.
The
survey was conducted during May and early June 1998. Survey results were analyzed during the Summer of 1998. The survey included questions about how consumers locate label
information, how well consumers understand the information, when and where
they consult the labels, the relative importance of different kinds of
label information, and which information consumers wish to find most quickly. The quantitative portion of the study included both a mailed,
written survey instrument and a telephone interview. The study was designed to include a fair representation of
low-income, low-education, and ethnic minorities in the U.S. See Chapter 2 for a detailed discussion of the survey research
design, implementation, and results.
Qualitative
Consumer Mini Focus Groups
The
qualitative research performed in Phase I, backed by Stakeholder comments
and the literature review, found that while generally satisfied with the
labels, many consumers do not consistently read or understand product
labels for household pesticides, insecticides, and hard surface cleaners. This finding was also supported by Phase I Stakeholder comments
and the Phase I literature review. Possible reasons that were proposed for this finding included:
-
excessively
technical and sometimes obscure wording of information on labels;
-
poor
layout and design of information, with inadequate contrast and difficult-to-read
type;
-
information
that does not address consumers' needs;
-
consumers'
lack of understanding of the potential benefits of reading the label
information;
-
consumers'
lack of motivation to read labels; and
-
general
consumer satisfaction with the existing level of information on labels.
Quantitative
survey techniques, including those used in Phase II quantitative research,
do not lend themselves well to detailed probing of interviewees to uncover
why and how they react to a variety of different text phrasings and formats. The CLI felt that a more subjective approach would enlighten certain
areas of inquiry. The CLI,
therefore, pursued further qualitative research in Phase II to investigate:
-
consumer
understanding of where to locate information on product labels;
-
consumer
understanding of the meaning of specific phrases;
-
possible
alternatives to the way certain label information is stated;
-
how labels
can be more clearly designed;
-
consumer
interpretation of certain "signal"
words, such as DANGER;
-
consumer
reactions to the possibility of standardizing label information;
-
consumer
reactions to possible logo designs for the Consumer Education Campaign;
and
-
compelling
motivators for reading and understanding labels.
Qualitative
research was funded by the EPA, which hired The Newman Group, Ltd. to
conduct the research. The
qualitative research took the format of 27 "mini" focus groups, each consisting of 3 to 5 participants, who were purchasers
and users of the products under consideration. Nine focus groups were held in each of three cities, Chicago, IL;
Ft. Lauderdale, FL; and Dallas, TX, during July and August of 1998. In each city, hard surface cleaners, indoor insecticides, and outdoor
pesticides were each covered by three separate focus group discussions. A strong effort was made to represent low-income, less-educated,
and minority-group segments of the populations of each city.
See
Chapter 3 for a detailed discussion of the Phase II qualitative research
design, implementation, and results.
The
CLI was envisioned from the beginning as a partnership and a process involving
teamwork among many Stakeholders. Phase II of the CLI had several different focuses, each of which
required the expertise of different EPA management and Stakeholders. Subgroups concentrated on each of the following areas:
-
research
on consumer knowledge, attitudes, and behaviors related to labeling
information;
-
standardized
environmental information;
-
storage
and disposal information on products; and
-
consumer
education related to label awareness and use.
Members
of each subgroup consisted of CLI Partners, Task Force members, EPA, other
federal agency personnel, and other interested CLI Stakeholders. Each subgroup made efforts to keep other CLI groups informed of
all significant activities and findings. Subgroup members were responsible for collaborating with others
in their subgroup and conveying information from the subgroup meetings
to people in their own organizations. Subgroups provided information to the group developing and implementing
the quantitative and qualitative research. Input from subgroups was instrumental in survey development, analysis
of the survey results, and formulation of the Phase II recommendations. In many ways, the work of each subgroup affected that of the others,
and the CLI has been a dynamic process of teamwork among the many Stakeholders.
Quantitative
and Qualitative Research Core Group
A
group of 22 CLI Stakeholders volunteered their time and expertise to coordinate
the quantitative and qualitative research of Phase II. Members included key people from the EPA, market researchers from
Amway Corporation, Bayer Corporation, the Chemical Specialties Manufacturers
Association (CSMA), Procter and Gamble, Reckitt and Colman, The Clorox
Company, Monsanto Lawn and Garden, S.C. Johnson and Son, Inc., RISE (Responsible
Industries for a Sound Environment), the Consumer Product Safety Commission
(CPSC), and the Food and Drug Administration (FDA). Appendix 1-5 lists all the Core Group members who were involved
primarily with the quantitative research.
The
group met on a weekly basis via conference calls to develop and refine
questions for the quantitative survey instruments (telephone and mail
survey). The market researchers
from the companies were experts in their field and were able to provide
input on the types of questions and question formats that would be appropriate
for each product category. The group worked together to formulate questions addressing
consumer understanding, preference, and satisfaction with current labels. Additional questions were asked regarding specific topic areas,
such as ingredient information. (See Chapter 2 for a full description of the quantitative research.)
The
Core Group also developed the focus and questions for the qualitative
research and helped familiarize The Newman Group, Inc. with the CLI and
its goals and objectives. Members of the Core Group observed several of the qualitative
focus groups and provided feedback after each group on ways in which the
moderator might be better able to convey the ideas being tested in subsequent
focus groups. Appendix 1-6
lists all the members of the Qualitative Subgroup.
Finally,
after the quantitative and qualitative research was completed, a small
subset of the Core Group (consisting of market researchers [one each from
Amway Corporation, Bayer Corporation, The Clorox Company, Procter and
Gamble, and S.C. Johnson and Son, Inc.] and three EPA Task Force members),
continued to meet on a weekly basis to interpret and analyze the survey
results. This group studied
the data thoroughly, and formulated findings, implications, and conclusions. (See Chapters 2, 3 and 4 for a complete discussion of the findings,
implications, and conclusions from the quantitative and qualitative research.)
Standardized
Environmental Information on Product Labels Subgroup
A
small working group consisting of EPA personnel and industry Partners
was formed to address the issue of standardized environmental information
on product labels. The group
initially met regularly; as the scope of this issue changed, the group
also met with the research Core Group. Appendix 1-7 lists all the members of the Standardized Environmental
Information Subgroup.
Initially,
the group set out to investigate the possibility of developing standardized
information on product labels in the form of a facts box of environmental
information (analogous to the food nutrition label). Based on input from this working group and the desire of the Agency
to advance the development of this concept and frame the debate, consumer
research on standardizing environmental information was performed as part
of the quantitative research. Part
of the quantitative research asked consumers what they felt was the most
important information on a label and to identify which types of information
they looked for in different situations. The quantitative research found that consumers interviewed did
not generally consider environmental information to be one of the more
important sections of the product labels. Consumers also said that a standardized format for labels would
help them to more easily locate the information that they consider to
be important.
The
group's focus regarding standardization of information on product labels then
shifted. Given what consumers
were saying, the group decided that it was most important to test variations
of standardized formats on product labels to see whether any of the formats
improved consumers'
understanding of label information. It was decided that various box and standardized label formats
would be tested via the qualitative research. Consumers in the focus groups were asked questions about their
preference for specific formats, whether the formats made a difference
in their understanding of the information presented, and whether they
had a preference for which information should be presented in standardized
or box formats.
See
Chapter 6, section 1 for a more details regarding the standardized format
research.
Storage and Disposal Subgroup
The Storage and
Disposal Subgroup was formed at the end of Phase I to address some of
the key findings from Phase I research on storage and disposal issues. (The complete Storage and Disposal Subgroup is listed in Appendix
1-8.) These Phase I findings
included the following:
- consumers
often do not read storage and disposal instructions;
-
consumers
frequently attempt to recycle the empty plastic containers that hazardous
household products come in, which often violates regulations relating
to public health and safety; and
-
EPA standard
disposal instructions on labels may conflict with some state or local
laws or practices.
In
Phase II, the CLI Storage and Disposal Subgroup directed research to obtain
a better overview and understanding of current state and local regulations
and practices regarding storage and disposal of household hazardous products. The Subgroup also identified problems related to modifying storage
and disposal language on labels. An informal survey was made of members of the North American Hazardous
Materials Management Association (NAHMMA). Telephone interviews, a literature review, and discussions with
and presentations of data by a variety of Stakeholders supplemented the
survey results. Input from
the storage and disposal groups was also taken into consideration when
formulating questions for the qualitative and quantitative research, and
in the analysis of the research data.
See
Chapter 6, section 2 for a detailed discussion of the Storage and Disposal
Subgroup activities.
Consumer
Education Subgroup
The
ultimate goal of the CLI is to change the behavior of consumers regarding
pesticides and household cleaning products, especially to:
-
increase
reading and use of labels;
-
decrease
the misuse of products;
-
decrease
the incidence of accidents involving products; and
-
decrease
environmental impacts caused by improper use, storage, and disposal
of these products.
Phase
I research and the extensive literature search, supported by many Stakeholder
comments, found that many consumers do not consistently or thoroughly
read labels for these types of products. Changes of label information or design will not be beneficial to
consumers unless they read the labels. As part of Phase II, the CLI therefore established a Consumer Education
Subgroup, to concentrate on ways to 1) increase consumer awareness of
labels; 2) encourage consumers to read labels and use their information
thoughtfully, for both their personal safety and as part of their environmental
responsibility; and 3) to help people understand the information presented
on labels. Appendix 1-9 lists
all the members of the Consumer Education Subgroup.
The
Consumer Education Subgroup conceptualized, developed, and began implementing
a broad-based, long-range consumer education plan intended to help people
to read, understand, interpret, and use label information. The Subgroup developed an easily understood message - "Read the Label FIRST!" - and began developing a unique, memorable, consumer-friendly logo of the message. The various components of the campaign were designed to work with and reinforce each other. The Subgroup also strategized the goals of the education campaign and support materials, and suggested ways in which to use the materials. The subgroup prepared brochures targeting different audience groups, and designed succinct messages that can be adapted to a variety of educational approaches and materials.
See
Chapter 6, section 3 for a detailed discussion of the Consumer Education
Campaign.
For a complete list of all the product types that are covered under
the CLI, please refer to Appendix 1-1. |
![[logo] US EPA](../gif/logo_epaseal.gif){kind=logo}