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CLI Phase II Report: Executive Summary

The Consumer Labeling Initiative (CLI), a pilot program of the U.S. Environmental Protection Agency, began in March 1996 with a Federal Register (FR) notice (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 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.

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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The Phase II Process

The CLI is a voluntary initiative that depends upon extensive stakeholder participation. EPA staff have worked with stakeholders on all aspects on the CLI, and oversaw the research and preparation of the reports. EPA made certain decisions and recommendations about policy questions and issues that arose during the project, but only after requesting input from Task Force members, EPA Partners, and other stakeholder groups. Dissenting opinions have always been invited, and a wide diversity of opinions is reflected in the findings. All stakeholders with an interest in labeling issues concerning consumer products have been strongly encouraged to participate.

CLI Stakeholders were organized into several types of groups, including the CLI Task Force, Partners, and specific task subgroups. The CLI also invited the participation of other interested stakeholders throughout the Initiative. Notices in CLI "Updates" (brief documents published at several times during Phase II and distributed widely), website postings, and mailings invited individuals to contact key EPA staffers, join subgroups, attend meetings, and provide feedback.

The CLI Task Force was created by EPA to provide direction for the Initiative. The Task Force consists 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, coordinated with EPA to avoid regulatory duplication or interference, and participated in the design and execution of the CLI research.

After the Task Force was set in motion, 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, along with EPA and the Task Force, worked on the design, testing, and execution of the quantitative and qualitative research; provided information and data for the literature review; funded and directed quantitative research; reviewed components of this report; donated their considerable experience and effort to the research process; and provided input on specific policy-related issues being debated. The active CLI Partners included a number of businesses and trade associations related to manufacturing and distributing these products. 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.

Subgroups of CLI Partner and Task Force Members concentrated on each of the following areas during Phase II:

CLI Partner and Task Force members, as a whole, met in person several times during Phase II. During these meetings, subgroups presented their findings to the CLI Partner and Task Force members and other interested Stakeholders. Future direction of the CLI was also discussed and planned.

Throughout the CLI, the EPA actively encouraged the participation of all interested Stakeholders through outreach methods, including public announcements, publication of memos and other documents, posting of all relevant information about Phase II to the CLI website, and public meetings. The CLI offered Stakeholders a wide variety of opportunities for ongoing comments and feedback to EPA.

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Phase II Research

A crucial part of Phase II was the funding, development, and implementation of a detailed quantitative telephone and mail survey to assess consumers' comprehension, attitudes, behavior, and satisfaction with labeling, and to evaluate alternatives. CLI Partners funded and directed the quantitative research, with input from all CLI participants. An independent market research and polling firm conducted the survey. The study included consumers from many demographic segments of the U.S. population, including low-income, low-education, and minority representation. The survey included questions about locating 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 they wish to be able to find most quickly and easily.

The quantitative survey was designed to address six learning objectives that were identified as a result of the CLI Phase I research. The learning objectives aimed to determine the following:

These learning objectives were intended to focus the Phase II research on specific issues related to improving labels. Each objective was intended to generate research findings that would enable the EPA and CLI Stakeholders to take immediate and near-term steps to improve labels. Some changes, such as revised guidance and regulations, are almost entirely under the purview of EPA. Others, such as consumer education, involve many Stakeholders and require a longer time frame. Most important was the willingness of industry Partners owning significant market share of products in the three categories to make label changes based on this process.

These learning objectives and the results of the quantitative research were expected to lead to certain actionable steps that the EPA and its CLI Partners could implement, such as these:

In addition to the quantitative research, qualitative research in the form of small ("mini") focus groups was conducted with consumers in three U.S. cities during the Summer of 1998. These groups were intended to elicit in-depth, qualitative information on a number of topics related to the quantitative research surveys. The qualitative research was funded by EPA.

The key learning objectives for the qualitative research, were to determine the following:

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Conclusions of Quantitative and Qualitative Research

The CLI Partners and Task Force developed findings and implications from the quantitative and qualitative research. These findings and implications yielded a number of conclusions, which follow:

1. There is no strong motivator that suggests fundamental label changes, but language and format can be improved. Consumers are generally satisfied with current labels and are able to find the information they want on the label. However, the data indicate 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 --

3. Consumers want clear, concise, easy-to-read information that connects consequences with actions. Instructions on labels should say 'why' and jargon should be avoided.

4. 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."

5. Ingredient information can be communicated by name, type or category of ingredient, and purpose of ingredient, 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).

6. 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.

These conclusions are supported by detailed research findings.

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Phase II Recommendations

Out of the Conclusions of the research, the CLI developed suggested Recommendations. These Recommendations were developed by the CLI Partner and Task Force Members in September 1998, and subsequently were presented to the EPA. The complete list of suggested Recommendations stemming from the September 1998 Partners and Task Force meeting follows.

Signal Words and Hazard Hierarchy Recommendations

Product Label Changes

1. For products that fall into toxicity categories 1, 2, or 3, recommend that manufacturers be encouraged to voluntarily put one or more bullet points underneath the signal word on the front label, explaining the precautions associated with the product. The statement which currently refers people to turn to the back of the package for more explanation of the precautions should remain on the front of the label.

Further Research

1. Recommend that additional research be conducted on the effects of "highlighting" and graphical depictions of the signal words on the front of the label before any such changes are implemented. ("Highlighting" means things such as bolding the word, boxing the word, using colors to make the word stand out, making the word bigger, etc.; graphical depictions could include bar graphs, thermometers, "laugh meters," or similar designs incorporating all three words into a hierarchical visual format.) Also explore as a part of this research "information fragmentation" (i.e., placing precautionary-related information on both the front and back label panels) issues. Note on intent: the need for this research is not intended to preclude the change recommended pertaining to placing the precaution bullet on the front panel with the signal word.

Policy Choices

1. For toxicity category 4 products only, the EPA should consider not having a signal word. (Currently, both category 3 and category 4 products can have the signal word "Caution" associated with them.)

2. The EPA should determine what the consumer should understand about signal words and the hazard hierarchy. If the intent is for the signal words to flag for the consumer that care should be taken, then the recommendations here are enough along with appropriate educational efforts (see education recommendations). If the intent is for the hazard hierarchy to be understood, then additional research and education are necessary.

Consumer Education

1. Recommend that an effort be made to educate consumers about the meaning of the signal words, and how they are defined and used on labels. This should be done in a factual context, and without judgement calls which conclude the meaning for the consumer (i.e., the Agency should not recommend that consumers always buy products marked CAUTION in preference to products marked DANGER).

Ingredients Recommendations

Product Label Changes

1. Recommend that the EPA not make any across-the-board label changes for ingredients at the present time.

2. Recommend that the EPA allow manufacturers the flexibility to voluntarily provide "other ingredient" information on the label in a way that consumers in the study expressed they wanted (i.e., listed by category, perhaps with some explanation of purpose).

3. Recommend that the EPA allow manufacturers more flexibility in where they provide ingredient information (e.g., back panel versus front panel).

Further Research

1. Recommend that the EPA conduct further research to identify how to supply consumers' expressed need for medical information to people who want it. It was noted that information learned from the quantitative research of Phase II should be incorporated in any further research.

Policy Choices

1. Recommend that the EPA further examine how to provide ingredient information on the label in the way consumers expressed they want it, as indicated by the research (i.e., give them categories of ingredients along with the purpose.) Also, refer to research recommendations in the format section.

Consumer Education

1. Educate consumers about ingredient information on labels (i.e., why they appear on the label and the meaning of "active" and "other"), through the "Read the Label FIRST!" campaign. Additionally, it was suggested that the education campaign be utilized to inform the public about where to get health and safety information, e.g., for people prone to allergies, etc.

Label Format Recommendations

Product Label Changes

1. Recommend that statements that were clearly preferred by consumers in the quantitative research be used, as appropriate, and that the EPA make program changes to allow this to happen to the extent possible.

Directions for Use

2. Recommend that the EPA consider replacing the statement, "It is a violation of Federal law to use this product in a manner inconsistent with its labeling," with the simpler phrase tested on the quantitative survey -- "Use only as directed on this label."

3. Recommend that manufacturers voluntarily put direction for use in bulleted form with no wrapping text (i.e., making sure that each new direction for use is set off on a separate line, and does not continue on the same line), using ordinal numbers if sequence is important.

Precautionary Statements

4. Recommend that manufacturers voluntarily put the principal health hazard information from the precautionary statements in bulleted form underneath signal words.

5. Recommend that manufacturers and the EPA, where possible, use simple language, avoiding jargon; avoid wrapped text; keep sections together in same column; use more white space; and eliminate needless words. This recommendation was particularly expressed with regard to precautionary statements.

6. Recommend that the EPA remove language that is not appropriate to consumers from precautionary statements, e.g., language more appropriate for agricultural pesticides, etc.

Precautionary Statements -- First Aid Specific

7. Recommend that manufacturers voluntarily put First Aid information in a table format and within a box.

8. Recommend that manufacturers who provide a toll-free number for emergencies voluntarily include that number beneath or within any table/box that includes First Aid information.

Further Research

1. Recommend that further research be structured to investigate location and presentation of ingredient information (e.g., placing ingredient information on the front or back of the label, tabular formats, etc.), before any across-the-board changes are made to ingredients information. This recommendation addresses the variation in need which can arise between product categories, e.g., indoor and outdoor versus cleaner product labels.

2. Recommend that further research be conducted to investigate how the information hierarchy (i.e., information that consumers in the quantitative research said was most important to them) translates into the order in which information appears on labels.

Policy Choices

1. Given the efforts in other non-CLI forums to standardize the use of icons, further work on this topic should not be pursued as a part of the CLI.

Consumer Education

1. Recommend that the "Read the Label FIRST!" campaign educate consumers that it is acceptable for them to open and read label booklets (particularly for outdoor pesticide products) in the store.

Consumer Education and "Read the Label FIRST!" Recommendations

It was noted that the Consumer Education Subgroup will address any recommendations from other topic areas related to Consumer Education.

1. Educate consumers on what specific parts of the label mean or are intended to communicate; specifically, signal words, active and other ingredients, storage and disposal, and precautionary statements including First Aid.

2. As the CLI project continues, expand membership of the Consumer Education Subgroup to include brand managers, marketing staff, and label designers from within the Partner companies, particularly with respect to designing and assessing the impact of the logo for the "Read the Label FIRST!" campaign.

3. Recommend that messages conveyed through the consumer education campaign be market-tested in appropriate ways before they are launched.

4. Recommend that retailers be brought into the Consumer Education Subgroup, as they will be important for distributing the messages developed by the group.

Storage and Disposal Recommendations

Phase II Follow Up

1. Recommend that the EPA send information from the quantitative study about recycling symbols (those with chasing arrows) to relevant organizations.

2. Recommend the EPA gather any available information on risk assessments regarding product disposal from states, manufacturers, and other appropriate organizations and share this information with all applicable parties, in an effort to coordinate these types of studies.

3. Recommend that the quantitative data on disposal practices be sent to the North American Hazardous Materials Management Association (NAHMMA) and that NAHMMA be encouraged to share this information with its members.

Product Label Changes

1. Recommend that for empty containers, the statement on product labels read, "Place in trash. Recycle where available." The recycling statement would be optional for manufacturers. Also optional, manufacturers may use the statement that reads: "Do not re-use container."

2. Recommend that, given that there was no agreement on label statements for partially filled containers, there be a delay in any Pesticide Registration (PR) notice regarding the disposal statement on empty containers until the EPA makes a policy decision about how to handle partially filled containers.

3. Recommend to keep the status quo for storage statements on product labels.

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EPA Actions on CLI Recommendations

During the April 7-8, 1999, Partner and Task Force meeting, the EPA discussed how it intended to address the recommendations made during the September 1998 Partner and Task Force meeting. The EPA's Office of Pesticide Programs (OPP) is handling the recommendations for label changes, and it presented a draft strategy for dealing with those recommendations at the April 1999 meeting. Also at the meeting, planning was initiated for a CLI media event in Spring 2000, to announce the CLI recommendations; and updates on both the completion of the Phase II Report and the Consumer Education Campaign activities were presented.

Draft OPP Strategy for Implementation of the Phase II Label Changes

OPP's draft strategy for implementing some of the CLI recommendations, presented in the April 1999 Partner and Task Force meeting, includes the following:

Label Changes That Can be Submitted Now

While manufacturers must abide by current regulations, they can submit the following label changes to the OPP (see Appendices 3-3 to 3-6 for examples of some of these label changes):

Changes to the overall label format and presentation that can currently be made include:

Label Changes That Need to be Discussed with EPA Product Managers Before Submitting

Label Changes That Cannot be Submitted at Present Time

CLI Media Event

During the April 1999 Partner and Task Force meeting, the EPA informed CLI Stakeholders about plans for an upcoming media event, to announce some of the labeling recommendations that EPA will be making as a result of the CLI. Plans for the media event were postponed until Spring 2000, however, to coincide with the 'kick-off' of the CLI Consumer Education Campaign; the media event will serve as the 'kick-off' event for the "Read the label FIRST!" Campaign. This launch is timed to coincide the appearance of newly redesigned labels on store shelves with consumers' general interest in seasonal gardening and cleaning activities. Eventually, the Consumer Education Subgroup intends to finalize and make available to the public a variety of educational materials (e.g., brochures, pamphlets, etc.).

Completion of the Phase II Report

An update on the Phase II Report and details for its completion were presented to CLI Partner and Task Force members during the April 1999 meeting. Partners and Task Force members were informed that all of EPA's recommendations on label changes, as a result of CLI, will be included in the Report. Partner and Task Force members agreed that displaying the Phase II findings on the Internet before the completion of the Report would be counterproductive and, therefore, resources should be spent on completion of the Report.

Consumer Education Campaign

An update of the activities since the September 1998 Partner and Task Force meeting regarding the Consumer Education Campaign was presented during the April 1999 meeting.

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Next Steps for the CLI

The launch of the "Read the Label FIRST!" consumer education campaign by EPA and the CLI Partner and Task Force members is targeted for Spring 2000. The campaign will include media messages about the entire CLI project. EPA's Office of Pesticide Programs will be implementing its strategy for adopting and announcing label changes beginning in the Summer of 1999 and continuing through 2000. Policy issues that were identified by the CLI and that remain to be resolved -- for example, the appropriate disposal language to be used on partially filled containers -- will be addressed separately by the Office of Pesticide Programs. Final changes to First Aid statements are expected to be announced in a Pesticide Registration (PR) notice in Fall/Winter 1999. The CLI will continue to accept public comment on the project and its effects, and the Agency will consider implementing future research to assess the effectiveness of both the recommended changes in labels and the "Read the Label FIRST!" campaign.

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