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CLI Phase I Report: Executive Summary
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Background and Goals
The Environmental Protection Agency undertook the Consumer Labeling Initiative (CLI), published in the Federal Register (61 FR 12011, March 22, 1996), with the goal to foster pollution prevention, empower consumer choice, and improve consumer understanding of safe use, environmental, and health information on household consumer product labels. The CLI is a multi-phased pilot project focusing on indoor insecticides, outdoor pesticides, and household hard surface cleaners (i.e. floor and basin, tub and tile), some of which are registered antimicrobials/disinfectants. CLI efforts are aimed at achieving the goal by conducting research and gathering information so that EPA and our project Partners may learn how to provide consumers with clear information on product labels so they will be better able to make informed choices among products based on their own needs and values, and to use chosen products safely as directed.
The CLI project is noteworthy as a model for cooperative effort between EPA and a wide range of Stakeholders, including a number of local, state, and Federal agencies, consumer product manufacturers, trade associations, public interest groups, health and safety professionals, market research experts, and individual citizens. This report is the product of the collective efforts and expertise of the Stakeholders, volunteer Partners, and the Agency. Initially, it was expected that after six months of work, final recommendations would be forwarded to the EPA Administrator. However, in the process of developing the research plan, it became clear that a phased approach to the research, proceeding from qualitative to quantitative consumer market research, would be needed to provide a sound base for policy making, including more comprehensive labeling improvement recommendations to the Administrator.
Research Process
The first phase of CLI research, ending September 30, 1996, is comprised of three components: qualitative consumer research, a literature review of relevant publications and reports of studies available in the public domain or provided by various Stakeholders, and a review of extensive Stakeholder comments solicited through the FR notice. The qualitative component of the research plan was specifically designed for the CLI project by the CLI Qualitative Research Development Committee, which was comprised of experts in consumer research. The qualitative research was executed by Macro International and included 135 in-depth one-on-one interviews with users of products in each of the focus categories in five major cities across the U.S. Because of the short time frame, the consumer research was designed and conducted concurrently with review of the literature and gathering of Stakeholder comments. However, as information became available from the literature review and Stakeholder comments, it was incorporated into the iterative development of the qualitative research (Phase I) and will be considered in subsequent phases of consumer research.
CLI Report Overview
This Phase I report of the CLI is comprised of an Introduction and Background, a Summary of Stakeholder Comments, a Summary of the Literature Review, a Summary of Qualitative Consumer Research, a Summary of Findings, a section with proposed Next Steps and Recommendations, and a number of appendices referenced in the report, which provide more detail and background on the research.
Research Findings
there was disparity regarding specific points of view, there was also consistency in many of the Stakeholder comments, literature review findings, and learnings from the consumer research. The comments, literature review, and consumer research addressed primarily label readability, the comprehension of product ingredient information, statements mandated by the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), hazard identification, and precautionary labeling information. The research also assessed, to the extent possible, consumer reliance upon labels in purchase decisions before use of the product, for precautionary/first aid information, and at the time of container and/or product disposal. The research addressed these questions in general, and where possible, for each of the focus product categories, i.e., indoor insecticides, outdoor pesticides, and household hard surface cleaners.Key general findings in each of these areas are summarized below. Please note that the qualitative research was used as a means for identifying and probing issues concerning messages on the selected product category labels, and do not reflect statistically representative responses. Most of these general findings and other more specific ones not highlighted here warrant further exploration or validation in the next phase of the CLI, which will include quantitative consumer research. Other findings may be more appropriately addressed through channels of communication other than labeling.
Use of Product Labels by Consumers
The available research suggested that whether a consumer read a label depended on the type of product and their familiarity with the product. Most consumers read the label if the product was new to them and if there was concern or an expectation of potential hazard if it was used incorrectly. The literature and consumer research findings indicated that most consumers felt that household chemical products were safe if used according to directions. In general, the research indicated that First Aid information was read only when there was an accidental exposure. Purchasers of insecticides and outdoor pesticides read the label primarily to understand product efficacy and directions for use. Consumers with children or pets were more likely to read precautionary labeling for pesticide products before purchase, but this largely applied to the indoor insecticide and outdoor pesticide product categories. In general, consumers did not read disposal directions, but did report that they stored pesticides in the house or garage out of the reach of children. Stakeholders commented that FIFRA-mandated disposal directions often conflicted with local government household hazardous waste program requirements. Stakeholders suggested, since many people were not reading the label, that efforts should be undertaken to educate consumers about the importance of reading the label.
Product Label Readability
During the qualitative research, consumers mentioned that they wanted less technical words on product labels, and some Stakeholders suggested that labels be at a fourth or fifth grade reading level. Two major problems identified were too-small type size and inadequate color contrast. There was also consensus that when there is a significant potential hazard, the label should prominently instruct consumers to read the label. When they were read, consumers judged labels on household cleaning products not regulated by FIFRA to be easier to read and understand than those on FIFRA-regulated products. Some Stakeholders suggested that a standard format for key information would improve readability. A few Stakeholders recommended fold-out labels, but consumers interviewed in the qualitative research expressed concern that opening a fold-out label before purchase would obligate them to buy the product. Moreover, when they opened the booklet, many consumers expressed a sense of information overload that discouraged them from reading the information. Another area of investigation was the location of label information. One finding was that consumers look at the back panel for ingredient labeling, but FIFRA requires labeling to be on the front panel. While consumers thought labels could be easier to read, they did not suggest information that could be deleted.
Comprehension of Ingredient and Mandated Label Statements
Public interest groups recommended that comprehensive ingredient information, including full chemical names and even Chemical Abstracting Service (CAS) numbers, must be required for all ingredients. Some Stakeholders provided evidence that consumers did not read or comprehend chemical names, and it was heard repeatedly from consumers in the qualitative research that they did not understand chemical names. For indoor insecticides and outdoor pesticides, qualitative research revealed that some consumers look for specific ingredients in comparison shopping, but they generally recognize only the active ingredient common name. There was also consistency in comments, the literature review, and the consumer research in finding that consumers did not understand the term "inert ingredients."
Mandated statements that consumers did not read and did not understand included the statement, "It is a violation of Federal law to use this product in a manner inconsistent with its labeling."
Hazard Identification and Precautionary Labeling
Consumers also consistently misinterpreted the EPA mandated labeling, "Hazards to humans and animals" to mean "hazardous to humans and animals." It was also interpreted as a stand-alone statement and not as a heading. Stakeholder comments and the CLI consumer research also showed that consumers prefer the term "first aid information" over "statement of practical treatment." The literature review (with support from the information learned from the qualitative consumer interviews) led to the conclusion that consumers understand that the term Danger is more serious than Caution or Warning, but there was not a clear distinction between the latter terms. Some consumers perceived outdoor pesticides and indoor insecticides to be very hazardous (as opposed to cleaners and disinfectants). The implications of consumer reception to new or additional labeling information merits further investigation. Public interest group Stakeholders urged the Agency to provide extensive and explicit hazard information on the label for all ingredients, including acute, chronic, and reproductive health hazards, noting particularly risks to children and pregnant women.
Next Steps and Recommendations
EPA worked with the Stakeholders, through meetings with our Partners and open discussion forums with others wishing to participate, to categorize all the findings into one of the following three categories: 1) labeling issues requiring further development or statistical validation through quantitative research, for example, the need to establish the hierarchy of importance of label content to consumers, and how satisfied consumers are with each specific label section (e.g., ingredients); 2) labeling issues not requiring further validation, for example, consumers prefer the term "first aid" over "statement of practical treatment;" and 3) education, policy planning, and coordination issues.
Based on the above categories, the recommendations in the report focus on the following areas: 1) a subsequent phase of quantitative and secondary research review; 2) interim label improvement measures; and 3) label-related education, policy, and procedural improvements.
Recommendations for Quantitative and Secondary Research
EPA recommends that the next phase of the CLI include a quantitative assessment of consumer comprehension, attitude, behavior, and satisfaction of (FIFRA and non-FIFRA) labeling and an evaluation of labeling alternatives. In addition, undertaking a subsequent literature review is recommended to explore more detailed existing information in the specific topic areas to be examined during the quantitative phase of research. This research will result in comprehensive and specific recommendations for: 1) label design and content improvements, 2) regulatory or policy changes needed to allow improvements, and 3) additional research to further clarify issues or to test alternative labeling.
Following completion of the second phase of research, EPA will combine the findings from the primary and secondary CLI research phases over two years with input from CLI Stakeholders to develop recommendations for the Administrator.
Recommendations for Interim Label Improvement Measures
Based directly on the findings and information presented in Phase I of the CLI, the Office of Pesticide Programs should consider three areas as an immediate starting point for label improvement: 1) broader use of common names for active ingredients in addition to chemical names approved by International Union of Pure and Applied Chemistry (IUPAC), 2) use of the heading "first aid" instead of "statements of practical treatment," and 3) inclusion on labels of phone numbers for general or emergency information. The pesticide program can take steps right now to improve information on labels in these three areas.
Recommendations for Education Activities
Recommendations call for the formation of a Product Label Consumer Education Task Force. The task force would be comprised of staff from Federal, state, and local government agencies and interested CLI Stakeholders, and would be mandated to recommend and implement consumer education activities throughout EPA that emphasize the importance of reading the label.
Policy Planning and Coordination Activities
Recommendations in these areas will focus on establishing processes for identifying and presenting the other important factors or considerations that go into the development of labels, so that once it has the consumer perspective in hand, EPA can make sound policy decisions based on all relevant factors. These other factors include the scientific, legal, regulatory, business, and right-to-know issues that may affect how information should be presented on labels or through some other mechanism. Some specific recommendations are as follows:
- Labeling Policy Coordination and Development: The Office of
Pollution Prevention and Toxics (OPPT) houses responsibility for
general coordination of environmental marketing and labeling issues
and policy development. Many of the general learnings from the
qualitative research, Stakeholder comments, and literature review
will be furnished to those who manage labeling programs and related
policy issues throughout EPA, in other Federal Agencies, and at
the state government level. In addition, these learnings will
be considered appropriate in the development of EPA comments on
developing international industry standards (e.g., International
Organization for Standardization or ISO work on environmental
labeling) for the Organization for Economic Cooperation and Development,
and in the development of environmental labeling programs.
- CLI Research Process: The process used for this pilot was well
received by the EPA Partners and Task Force Members. A work group
of CLI Stakeholders and others should be formed to develop recommendations
for EPA use of the CLI process to inform other Agency policy work.
- Pesticide Labeling Needs Vary: The Office of Pesticide Programs
should recognize the difference between consumers' label needs
and the label needs of agricultural sector users (for whom FIFRA
labels were first developed). The Program should take steps now
to explore how to eliminate policy or regulatory barriers to address
this difference.
- Continued Coordination Between EPA and FTC: The EPA and FTC
continue to coordinate on environmental marketing and labeling
issues across all environmental media programs (e.g., pesticide
programs, trade and environmental activities, environmentally
preferable products guidance, Energy Star, etc.). Specifically,
the Office of Pesticide Programs Labeling Unit is attempting to
better coordinate claims approved for pesticide labels with the
FTC Guidelines for Environmental Marketing Claims.
- Form Inert Ingredients and Health and Safety Information Work
Groups: Form one or two small work groups made up of representatives
of all interested Stakeholders to work with the Office of Pesticide
Programs, and charge them with the development of a white paper
that identifies and discusses the scientific, legal, regulatory,
business, and right-to-know points of view as they relate to the
presentation of ingredient and health and safety information on
registered pesticide labels.
- Storage and Disposal Labeling: Form a work group made up of
representatives of CLI Stakeholders to work with the Office of
Pesticide Programs to identify all current applicable storage
and disposal regulations and issues affecting storage and disposal
for development of a white paper.
- CLI Pilot: the CLI was designed as a pilot project. EPA should
determine whether to further examine additional product categories.
- Standardization of Environmental Messages on Product Labels: EPA should consider if it is possible to somehow standardize messages on product labels beyond pesticides (e.g., format, elements of the message).