CLI Phase I Report: Introduction and Background
On this page:
- Introduction and Background
- CLI Overview
- CLI Participants and Their Roles
- CLI Research Process
- Summary of Findings
- Next Steps
This section of the report provides readers with a road map to
the CLI Phase I Report. The introduction presents CLI's goals and
research process, and describes the roles of various groups participating
in the CLI. The overview is followed by a summary of each major
section of the report which highlights:
- how and why the research presented in each section was undertaken,
- how each section fits into the overall design of the CLI,
- limitations of the current research, and
- how the findings of each section have been used to guide subsequent research.
The Agency expects that the issues raised and findings in each section of the report will, in conjunction with future CLI research, contribute to the Agency's future formation of labeling policy.
The goal of the Consumer Labeling Initiative (CLI) is to foster
pollution prevention, empower consumer choice, and improve consumer
understanding by presenting clear, consistent, and useful safe use,
environmental, and health information on household consumer product
labels. This goal can be achieved by providing consumers with clear
information on product labels so that 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. This report
summarizes the research and findings from Phase I of the CLI. Phase
II of the CLI will start October 1, 1996.
EPA is interested in improving the labeling of products used in
the home. Of particular concern are labels of pesticide products,
which are often difficult to understand and inconsistent with labels
on non-pesticide products of similar composition, such as hard surface
cleaners. CLI research will focus specifically on learning how to
better communicate the existing health, environmental, use, and
disposal information on pesticide products and similar non-pesticide
products. This report summarizes Phase I research, which has been
completed; outlines Phase II research which, is expected to begin
shortly; and provides recommendations for immediate interim label
and education improvements. Ultimately, research conducted under
the CLI should lead to learning how to make it possible for consumers
- quickly locate essential safe and appropriate use, environmental,
and health information on product labels;
- reasonably compare products intended for similar uses from information
on the label; and
- understand from the label how to use, store, and dispose of products safely and with minimal effect on the environment.
The three product categories selected for Phase I research are:
- Indoor Insecticides
- Outdoor Pesticides
- Household Hard Surface Cleaners (i.e. floor and basin, tub and tile), some of which are registered Antimicrobials/Disinfectants.
CLI stands out as a distinctly different and cooperative effort
between EPA and a wide range of the following Stakeholders interested
in labeling issues concerning consumer products: consumer product
manufacturers; marketers; trade associations; foreign governments;
local, state, and Federal agencies; public interest groups; health
and safety professionals; and individual citizens, who were involved
in CLI project planning, implementation, review, and comment.
EPA: Direct Project
The EPA staff initiated the pilot project, directed all CLI activities,
and was responsible for overseeing research and the preparation
of this report, which includes the opinions of all the various Stakeholders.
Decisions on individual questions or issues that arose in the project
were made by EPA staff, following opportunities for Task Force members
and EPA Partners to provide input. Dissenting opinions were always
invited and the diverse opinions are reflected in several parts
of this report, including the summary of Stakeholder comments. Two
contractors assisted EPA with the project: Abt Associates Inc.,
who performed the literature and Stakeholder comment reviews, and
Macro International, who conducted the qualitative research.
Task Force Members: Guide Project, Share Experience, Avoid Regulatory
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, coordinated with EPA to avoid
regulatory duplication or interference, and were invited to participate
in the design and execution of CLI research. The complete list of
Task Force members can be found in Appendix G.
EPA Partners: Help Guide Project, Provide Information/Data, Suggest
Options for Improving Labels, Possibly Pilot Label Solutions
Companies that manufacture or market products falling within the
selected three pilot product categories were recruited to serve
as EPA Partners through the Federal Register. They provided EPA
with input to guide the development of the qualitative research;
provided information and data for the literature review; assisted
in the design, testing, and execution of the qualitative research;
reviewed components of this report; and donated their considerable
experience and effort to the research process. The complete list
of EPA Partners can be found in Appendix H.
Industry Trade Associations: Help Guide Project, Coordinate Input
Several industry trade associations participated on behalf of
their members, assisting in the design and review of the literature
review, qualitative research, and final report. In many respects
they functioned in the same capacity as EPA Partner representatives.
They helped to disseminate information on the CLI to their members,
and to assemble and organize comments and ideas from their membership
for presentation to EPA. The complete list of trade associations
can be found combined with the list of EPA Partners in Appendix
Other Stakeholders: Provide Input/Data, Raise Issues With Current
Labels, Suggest Options for Improving Labels, Assist in Project
Participating CLI Stakeholders included foreign governments; Federal, state, and local officials; EPA Partners; academics; individual citizens; consumer groups; environmental labeling program practioners; environmental groups; public interest groups; health and safety professionals; retailers; standard-setting organizations, media, and individual companies. They were invited to offer their ideas and comments at several points throughout the project, including written comments responding to a March 22, 1996 Federal Register Notice, a series of follow-up informational meetings with EPA management and staff, and written comments submitted throughout Phase I of the CLI. Their input was particularly valuable in identifying possible deficiencies in current labels and in suggesting options for changes to EPA programs not directly related to product labels. In addition, individual consumers were randomly recruited to participate in the qualitative research. The draft document was placed into the publicly accessible Administrative Record on the project, and was available for review and comment. For a list of participants, see Appendix J.
For practical purposes related to funding and the sequence of
primary consumer research, the CLI research was broken down into
two distinct phases. Phase I was undertaken during the 1996 Federal
fiscal year (ending September 30, 1996). During this period, various
investigations and research efforts focused on: 1) providing the
CLI Task Force with the full range of hypotheses related to consumers,
their information needs, and interactions with labels; and 2) summarizing
existing research and the experience of related programs concerning
the effectiveness and limitations of labeling as a policy tool to
protect public health. The second phase will focus on exploring
issues left unaddressed during the initial investigations, and validating
hypotheses related to consumer preferences and understanding of
specific labeling issues.
The research comprising Phase I of the CLI contains three components: qualitative consumer research, a literature review, and Stakeholder comments, all of which were submitted to EPA's peer review process (peer review comments are summarized in Appendix K). The literature review and Stakeholder comments were intended to assist in the development of a qualitative study to gather further information directly from consumers, but the consumer research was designed and conducted concurrently with review of the literature and gathering of Stakeholder comments because of the short time frame. As information became available from the literature review and Stakeholder comments, it was incorporated into the development of the qualitative research. The Stakeholder comments and literature review can provide background information, and the qualitative research provides deeper insight into many of the issues raised. Findings from the three parts were used together to develop the Findings and Next Step sections.
The qualitative research was designed to reveal information about respondents' use of labels and their understanding of the information on the labels for the three types of product categories studied. The Qualitative Research Development Committee (QRDC), composed of EPA staff and Task Force and EPA Partner experts in consumer research, was responsible for assisting EPA in developing a methodological approach and discussion guides for one-on-one interviews with consumers with recent product purchase/use experience. The QRDC also observed the 135 45-minute interviews that were held throughout the U.S. during May and June. Where there was remarkable consistency in consumer comments and when learnings corresponded to those found in the literature review, conclusions and recommendations can be drawn. Other findings will need further exploration, development, and/or testing of hypotheses or options for labeling improvements. The QRDC prepared findings related to each of 14 learning objectives that they identified prior to the interviews, as well as recommendations for subsequent quantitative research. The Key Learning Objectives can be found in Appendix C.
A literature review was undertaken to synthesize existing research in three areas: consumer understanding of environmental, health and safety issues; consumer perception of product attributes; and consumer reaction to precautionary labels. The review was intended to provide the CLI with a synopsis of the wide range of labeling research that the Agency could use in designing the primary research and in interpreting results. It built upon environmental labeling research undertaken previously for EPA and upon precautionary labeling research performed by the Consumer Product Safety Commission. The literature review was not fully completed by the time the qualitative research was designed and conducted, but relevant information from the literature was incorporated as it became available. While the goal of the CLI project was defined around the improvement of environmental, health, and safe use information, and the primary research focused on all parts of the label to assist in reaching this goal, the majority of the literature identified focused on the precautionary part of labels. A future literature review is recommended to address issues related to other parts of the label, such as directions for use, product storage and disposal, environmental information, and education of consumers regarding labeling issues.
EPA announced the start of the CLI in a March 22, 1996 Federal Register Notice. The Notice described the goals and proposed a general plan of research, at the same time soliciting comments and information. Forty-one substantive comments were received from: foreign governments; Federal, state and local officials; EPA Partners; academics; individual citizens; consumer groups; environmental labeling program practioners; environmental groups; public interest groups; health and safety professionals; retailers; standard-setting organizations; media; and individual companies. In addition, EPA staff and management met with small groups of Stakeholders in April and May and again in August to present the CLI and interim findings and to solicit input. Finally, EPA received approximately 3,000 postcards written by private individuals, and other comments over the course of Phase I. The Stakeholder comments are valuable in defining policy issues, such as consumer education, which may not be addressed directly by CLI's focus on product labels. The summary also captures a wide range of opinions and perspectives concerning the content, format, and role of product labels, allowing EPA to take these into consideration in the future development of policy and guidance.
Findings based on the qualitative research, literature review, and Stakeholder comments are summarized in Section V. Each of these three sources was incorporated into the CLI to provide EPA with very different types of information as described above. These findings, in addition to a set of overview findings (categorized into three groups: issues requiring additional validation, issues not requiring further validation and education, and policy planning and coordination issues), are an integral part of a comprehensive background document which 1) identifies the full range of issues related to the CLI, and 2) provides a thorough examination of the core issues related to labeling. This investigation and scoping phase will assist those involved with the CLI to develop specific hypotheses and labeling alternatives (e.g., language, format, and/or content), which will be evaluated as part of the Phase II quantitative research planned for the near future (FY97). The findings are also useful to EPA in framing the important policy considerations being addressed by the CLI.
At the outset of the CLI in March 1996, the Initiative was expected
to take six months to complete and would contain comprehensive recommendations
for label improvements. In the course of designing primary research,
EPA and others participating in the CLI determined that a phased
approach to the primary research was more suitable and would provide
EPA with a sound basis for policy making concerning labeling activities
at the Agency. However, EPA staff did identify some interim steps
that the Agency can take right now to improve labels and label-related
policies. The purpose of Section VI is to articulate as clearly
and in as much detail as possible next steps for the Consumer Labeling
Initiative. Phase I of research activities, conducted in FY96, probed
a wide range of consumer issues related to product selection, use,
storage, and disposal in three product categories. Two major tasks
are proposed for the second phase: primary quantitative research
and additional literature reviews. Also in this section, EPA makes
several recommendations based on the summary findings from Phase
I. The quantitative research, i.e., a survey of a large number of
consumers nationwide, will be used to derive statistically significant
conclusions regarding the consumer comprehension of (FIFRA and non-FIFRA)
labeling and an evaluation of labeling alternatives that may improve
any or all of the following: consumer interaction with various parts
and component of labels, consumer understanding of label content,
wording, retention of labeling information, and recognition of the
label as a resource for future needs (e.g., first aid instructions).
The literature review would likely address consumer reaction to
and interactions with other parts of the label beyond precautionary
and environmental information, such as directions for use; research
on comparable survey/study design; and segmentation and profile
of potential and current subpopulations of consumers.
EPA makes three main recommendations for interim pesticide label improvement measures: increase the use of common names for active ingredients, use the term "first aid" instead of "statement of practical treatment," and include on product labels phone numbers for general emergency information. For education activities directed at all EPA labeling programs, EPA recommends forming a product label consumer education task force. Finally, EPA makes several recommendations regarding policy planning and coordination activities.