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CLI Phase I Report: Next Steps and Recommendations
VI. Next Steps and Recommendations
The purpose of this section is to present EPA's recommendations for how to proceed with the next phase of the CLI based on the initial findings of the pilot project. In developing recommendations, EPA considered the secondary research and the primary research conducted to date, as well as input from its staff and management, CLI Task Force, EPA Partners, and interested Stakeholders.
At the outset of the CLI in March 1996, the Initiative was expected to take six months to complete. At the end of that period, it was expected that a report to the Administrator would include detailed recommendations for actions needed to improve labeling. However, in the course of designing consumer market research, EPA and others participating in the CLI determined that a phased approach to the primary consumer market research was more suitable and would provide EPA with a sound basis for label improvement and policy development at the Agency. Thus, the first phase of research activities, conducted in FY96 (ending on September 30th, 1996), was designed to probe a wide range of consumer needs and understanding of label information related to product selection, use, storage, and disposal of three product categories.
This investigation and scoping phase will assist those involved with the CLI to develop specific hypotheses and labeling alternatives to be evaluated as part of quantitative research planned for the near future (FY97). It also became clear that there were a number of label issues or problems that can be addressed now, without further research, based upon acceptable evidence presented in the first phase. In addition, EPA recognizes, as did many others involved in the CLI, that labels are just one of many tools with which to disseminate information and educate consumers. Therefore, the recommendations in this report will focus on the following areas:
- a subsequent phase of quantitative and secondary research
- interim label improvement measures
- label-related education, policy and procedural improvements
1. Recommendations for Quantitative Research and Supplementary Literature Review
Quantitative 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. The length of time and resources needed to conduct this research will depend on the research method selected and the complexity of the issue. EPA is currently working closely with the CLI participants to develop a quantitative research plan that will get the answers we need while using a reasonable amount of time and resources.
Focus of research
Research will focus on quantifying some of the following topics noted as needing further development for the product categories of indoor insecticides, outdoor pesticides, and hard surface cleaners (some of which are registered antimicrobials/disinfectants) following the first phase of research:
- frequency, context, and rationale for using various parts of
product labels;
- consumer satisfaction with scope of current label information
in various parts of labels;
- consumer attitude toward and satisfaction with format and location
of information within labels;
- comprehension and preference of specific label language; and
- hierarchy of the importance to consumers of various parts of
the label.
In addition, the Agency expects to test consumer preference and understanding of alternative labels and/or label components during quantitative research. Much of this work will focus on layout, readability, and comprehension alternatives, such as use of pictures and icons to convey or clarify key use or precautionary information.
How quantitative research will be utilized
Quantitative research will provide EPA with a statistically sound basis for policy formulation concerning labeling requirements falling within the Office of Pesticide Program's purview. Following completion of the second phase of research, EPA will combine the findings from the primary and secondary CLI research with input from CLI Task Force Members, Partners, and Stakeholders to develop recommendations for the Administrator. The findings of this research are expected to inform changes that EPA can make on pesticide labels including: some substantial improvements that EPA can make on pesticide labels within the context of existing regulations; and improvements that will require fundamental changes in the pesticide program, which may require legislative, regulatory or policy reform.
The findings of this research are also expected to identify changes that manufacturers and marketers can undertake voluntarily to improve non-pesticide labels, beginning with hard surface cleaners. The findings will also help EPA determine whether it is worthwhile to examine other non-pesticide product categories for inclusion in future CLI work. This research will help EPA determine if there is a need or benefit to standardize environmental information on product labels across product categories. It should be highlighted that further research in this area is still needed. Finally, it is expected that the results of this research will help EPA determine the utility of the approach used in the CLI and whether this should become part of the way EPA conducts its research and program evaluation where consumers are concerned.
Design and implementation of quantitative research
Future planning forums and other opportunities for input from the CLI Task Force, Partners, and Stakeholders will be used to assist EPA in developing more detailed and comprehensive research studies, protocols, and instruments. As with the first phase, EPA anticipates preparing a detailed quantitative research plan including a limited set of learning objectives designed to help EPA meet CLI's project goals. The overall research plan will be circulated to all interested CLI Stakeholders. Specific components of the plan, such as research instruments and sampling design, will be circulated to interested individuals and organizations as they are prepared. Later in the project, the statistical weighting and analysis of results will be circulated widely for review, comment, and interpretation. EPA will seek input from all Stakeholders as Agency staff drafts a Phase II report summarizing quantitative research findings.
Supplementary Literature Reviews
Additional literature reviews are proposed for two reasons. They will provide those involved in the CLI with background information, which will help to inform the design of quantitative research and will provide EPA with a synopsis of existing research in specific topic areas. Possible topics include but are not limited to:
- published studies and other available research on consumer reactions
to and interactions with other aspects of labeling, such as directions
for use;
- published studies and other available research on surveys and
study design;
- published studies of segmentation of potential consumers and
profiles of various subpopulations of potential consumers (who
may interact with product labels); and
- published studies on how labeling challenges have been addressed to meet the multiple regulations of various agencies, including multilingual labeling requirements, packaging constraints, label design considerations, the use of icons, etc.
2. Recommendations for Interim Label Improvement Measures
EPA recommends that the Pesticide Program institute several interim labeling improvements based on acceptable evidence supporting certain findings presented in this report. These recommendations are supported or allowed under current regulations. As interim measures, they can be evaluated for their effectiveness within a certain period of time and/or could be replaced with more permanent measures that may be recommended following the next phase. The following are proposed changes to be implemented.
Use of Common Names for Active Ingredients
CLI finding: Consumers indicated that the common name for a chemical should be used on the label in addition to or instead of the scientific name. Many products do not yet have a common name for the active ingredient.
Recommendation: The Pesticide Program should work with product registrants, the American National Standards Institute (ANSI, the organization that approves common names) and others to identify the barriers to approving common names, make recommendations for increasing the number of chemicals having common names, and ultimately get these common names listed on the label.
Use of the Term "First Aid" instead of "Statement of Practical Treatment"
CLI finding: Consumers indicated that the phrase "first aid" was more simple and straightforward than "statement of practical treatment."
Recommendation: The Pesticide Program should issue an EPA Label Policy Alert that encourages registrants to voluntarily use the term "First Aid" in place of the term "Statement of Practical Treatment."
Phone Numbers for General or Emergency Information
CLI finding: Consumers indicated a desire for phone numbers on labels that they can use to get general or emergency information regarding a product.
Recommendation: The Pesticide Program should encourage registrants of pesticide products to place phone numbers on labels where consumers can call to get general or emergency information. EPA should also explore other options for making this type of information available to consumers.
3. Recommendations for Agency Education and Planning Activities
Education Activities
There was general agreement among CLI Stakeholders regarding the need for educational programs that stress the importance of reading product label thoroughly. The need to improve consumers' use of labeling information was highlighted by several of the Phase I research findings. Research found that consumers were less likely to read all parts of the label if they were already familiar with a product or if they perceived that a product poses very low risks. Specifically, Storage and Disposal information is often disregarded completely, and Health and Safety information is often disregarded unless an accidental exposure to the product has occurred. The terms and wording used on the labels also appear to cause confusion and may be misunderstood. Furthermore, many consumers may not be able to read labels because of physical (related to sight), literacy, or language barriers. Therefore, educational efforts may be warranted to help consumers distinguish differences in label information, such as safety or ingredient information, for products within the same product category.
Form a Product Label Consumer Education Task Force: The Consumer Education Task Force would gather information regarding both current and completed education activities geared toward getting consumers to read product labels. The Task Force would then develop recommendations for improving the effectiveness of those activities. The Task Force should be made up of representatives of Federal, state, and local agencies and interested CLI Stakeholders, and should be mandated to recommend and implement effective consumer education activities that emphasize the importance of reading the label. The purview of the Task Force would include all products and be well-coordinated with the appropriate Federal, state, and local governments, and other organizations. EPA must provide adequate funding for both the formation of the task force and for carrying out its recommendations.
Policy Planning and Coordination Activities
The CLI has begun a research process to better understand consumers' comprehension and use of label information. Ultimately, this will help the Agency to better present information on product labels. However, EPA needs to also begin a formal process of 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 other relevant factors as well. These other factors include the scientific, legal, regulatory, business, and right-to-know issues that may affect whether and how information should be presented on labels. It may be that the label is not the most suitable means of transmitting all types of information to all consumers. Following are some specific planning and coordination activities that EPA can undertake now so that EPA is in position to take advantage of the information likely to come out of the upcoming CLI quantitative market research.
Distribute Phase I findings to enhance labeling policy coordination and development: Within EPA, the Office of Pollution Prevention and Toxics (OPPT) has the responsibility for general coordination of environmental marketing and labeling issues and policy development. Recommendation: Many of the general learnings from the qualitative research, Stakeholder comments, and literature review will be furnished to those who manage labeling programs and to those dealing with related policy issues throughout EPA, in other Federal Agencies, and at the state government level. In addition, these learnings will be considered in the development of EPA comments on developing international industry standards (e.g., International Standards Organization, or ISO) work on environmental labeling, to the Organization for Economic Cooperation and Development (OECD), and to environmental labeling programs in the U.S. and abroad.
Examine the CLI research process as a prototype: The process used for this pilot was well received by the EPA, Partners, and Task Force Members. Recommendation: A work group of CLI Stakeholders and others should be formed to develop recommendations for EPA use of the CLI process for other Agency policy work.
Recognize that 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). It is expected that the quantitative research will identify ways in which EPA can present information on labels that are easier for consumers to understand. However, current regulations make no distinction between consumer and agricultural/professional products. Recommendation: The Program should take steps now to explore how to eliminate policy or regulatory barriers to address these differences.
Continue 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.). Recommendation: The Office of Pesticide Programs Labeling Unit should continue attempting to better coordinate claims approved for pesticide labels with the FTC Guidelines for Environmental Marketing Claims.
Investigate issues related to inert terminology, ingredients listing, and health and safety information: The issue of the availability and presentation of ingredient and health and safety information, and the use of the word "inert" on product labels, is complicated and controversial. The qualitative research examined these issues in the context of labels (for the three product categories studied) on products that are registered pesticides, and those that are not registered but serve the same function (e.g., hard surface cleaners). Through the quantitative research proposed in this report, the EPA expects to learn a great deal about consumers' understanding and demand for this type of information. However, EPA also needs to identify all of the scientific, legal, regulatory, business, and right-to-know points of view that also must be considered. Recommendation: Form a small work group made up of representatives of all interested Stakeholders to work with the Pesticide Program and charge them with the development of a white paper that identifies and discusses the above points of view as they relate to the use of the word inert, policy options concerning the listing of ingredients, and health and safety information. This paper can then be considered along with the results of the quantitative research when EPA determines possible recommendations regarding this information on registered pesticide labels.
Investigate storage and disposal labeling issues: Phase I CLI findings indicate a need for EPA to better understand consumer perceptions and needs for disposal information on pesticide labels. This need can be met by the quantitative research proposed in this report. However, CLI findings also indicate that EPA-required storage, and disposal label information may contradict local regulations on household hazardous waste. Recommendation: Form a work group made up of representatives of CLI Stakeholders to identify all current applicable storage and disposal regulations and issues affecting storage and disposal and to articulate the relevant issues within a white paper on storage and disposal labeling. The white paper can then be considered by the pesticide program along with the results of the quantitative research when EPA considers how to improve the availability of this information.
Determine if CLI pilot should be expanded: The CLI was designed as a pilot project. Recommendation: EPA should determine whether to further examine additional product categories.
Determine effects of standardizing environmental messages on product labels: EPA could consider if it is possible to standardize messages on product labels (e.g., format, elements of the message).