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SUPPORTING STATEMENT FOR AN

INFORMATION COLLECTION REQUEST (ICR) 

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title

Use of Surveys in Developing Improved Labeling for Insect Repellent Products

EPA ICR No.: 2425.01 OMB Control No.: 2070-New

1(b) Short Characterization

The Environmental Protection Agency (EPA or the Agency) intends to initiate a new 

information collection, a voluntary one-time internet survey for consumer research. The goals of 

the internet survey are to (1) identify the types of information that users of insect repellents want 

on the label of an insect repellent product and (2) test four versions of an efficacy mark. This 

efficacy mark is a graphic that could be placed on the front label of an insect repellent to 

standardize the presentation of information on how long the insect repellent repels ticks or

mosquitoes. For the first efficacy mark viewed, participants would provide information on their 

understanding of the efficacy mark, just as if they came across the mark on a product label with 

no prior explanation of what the mark could mean. Participants would rate all of the efficacy 

marks for understandability and usefulness, and then indicate a preferred choice. EPA would use 

this information to formulate decisions and policies affecting future labeling of insect repellents. 

The ultimate goal of this activity is to help the consumer to effectively use information on the 

label to select the insect repellent product most likely to meet their needs and readily understand 

label instructions regarding safe product use. One survey would be conducted over the life of the 

ICR. 

The collected information could be used as part of a future analysis conducted as part of 

potentially revising insect repellent product labels and to create other user-friendly 

communication and educational materials. By enabling consumers to make better, more 

informed choices in regard to purchasing and using products intended to protect their health, 

EPA could more effectively carry out its mandate to protect the public from unreasonable risks 

to human health.

2. NEED FOR AND USE OF THE COLLECTION 

2(a) Need/Authority for the Collection 

With few exceptions, section 3 of the Federal Insecticide, Fungicide and Rodenticide Act 

(FIFRA), requires the EPA to register all pesticide products sold in the United States. (See 

attachment A). EPA uses this registration process to ensure that the products in question will not 

have unreasonable adverse effects on humans or the environment. As part of this process, EPA

examines the ingredients of a pesticide; the amount, frequency and timing of its use; and storage 

and disposal practices.
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EPA’s review of proposed labeling on an insect repellent package or container and the 

accompanying instructions is a key part of EPA’s pesticide registration process. Under FIFRA 

section 3(c)(1), a complete copy of the label, along with a statement of all claims made about the 

product, and any directions for use must be submitted with the registration application. The label 

of an insect repellent provides critical information about how to apply the repellent, how often to 

re-apply, and the pests that are repelled. 

Every pesticide product must bear a label containing the information specified by FIFRA 

as established in EPA’s labeling regulations at 40 CFR 156.10. (See attachment B). EPA’s 

pesticide product labeling requirements were developed in the 1970’s and primarily for 

agricultural products. However, since that time, the market for FIFRA-regulated consumer 

products has grown. FIFRA-regulated consumer products can include sanitizing and disinfecting 

products; lawn and garden products; and insect repellents. As a result, current label requirements 

may not adequately address the distinction between the needs of consumers and the needs of 

agricultural sector users. 

Without knowledge of consumers’ perceptions and understanding of pesticide label 

information, EPA cannot judge if the content and design of the label communicates the safety 

and performance information that consumers desire. More importantly, EPA cannot determine if 

consumers interpret labeling statements as EPA intended. It is the Agency’s goal that product 

labels help consumers to understand the products they use, and know how to use them safely. To 

further this goal, EPA recently conducted ten focus groups to better understand consumer needs 

and preferences regarding insect repellent product labeling and efficacy marks. The focus group 

format allowed for in-depth probing and discussion on consumers’ attitudes and perceptions and 

how consumers use information on an insect repellent label. Feedback from the focus groups 

allowed EPA to redesign the sample efficacy marks.

These focus groups were conducted in Bethesda, MD; Tampa, FL; Norwalk, CT; and 

Minneapolis, MN. Four consumer segments were included in the market research: 

light/infrequent product users, heavy users, parents of young children (less than 10 years old), 

and general users. A total of 92 participants participated in the focus groups.

Given the limited number of participants, it should be emphasized that the results of a 

focus group are considered to be qualitative research. A qualitative research methodology seeks 

to develop directions for future research rather than quantitatively precise or absolute measures. 

EPA regards the focus groups as an important exploratory component of research on consumer 

understanding of labels, with findings that can be used to generate hypotheses for further study 

and decision-making. Though the non-statistical nature of qualitative research means the results 

cannot be generalized to the general U.S. population, EPA gathered from the focus groups 

valuable and useful information.
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Focus group participants want clearer, more concise statements on the labels of the insect 

repellents they buy. Currently, consumers seem to have a difficult time comparing products

when considering a purchase, largely because there are no standards for the type, placement, or 

format of information on the label. Consumers are looking for a consistent standard of 

measurement for evaluating the efficacy and safety of personal insect repellents. However, 

instead of standard information, claims on current insect repellent labels are widely variable, 

confusing, and not always easy to read or understand. Vague, general, or unsubstantiated claims 

such as “long-lasting protection” or “effective dependable protection” and wordy claims do not 

provide consumers with specific information, in a user-friendly format that could guide 

consumers to choose the best insect repellents for their needs. 

The results of the focus groups indicate that consumers primarily want insect repellent 

labels to communicate:

the specific number of hours of efficacy for the product, 

the specific insects or other pests the product repels, and 

the precise percentage of active ingredient in the product. 

These data must be presented in a sizeable, clear font and placed on the front of the 

package. They also would like manufacturers to use visuals that are eye appealing and relevant 

to the situations in which they use insect repellents. Therefore, it is critical for any revised 

labeling system to include these specific data points and criteria in an easy-to-read format on the 

front of the package. 

The exploratory research gained via the focus groups provided EPA with key information 

on consumer needs from insect repellent labels. To build on this information, a consumer survey 

is needed to fully understand and quantify consumers’ perceptions. The information collected 

will allow EPA to more completely understand consumers’ reasons for choosing personal insect 

repellents, their comprehension of label information, and their use of this information to make a 

purchasing decision and take safety precautions. The information collected will provide support 

for the Agency’s policy and regulatory activities in advising label language, designing label 

metrics, and revising labeling regulations and policies.

Today, there is an increasing trend of asking the public for their views and perceptions, in 

order to discover and understand the public’s needs and wants, and to access the public’s 

expertise and knowledge. This is evidenced by several recent surveys conducted by agencies of 

the Federal government, after approval by OMB, to understand consumer perceptions.

The Federal Trade Commission conducted an internet survey to examine consumer 

perception of environmental marketing claims (such as “eco-friendly” or “green”). The 

survey was part of the Commission’s regulatory review of the Guides for the Use of 

Environmental Marketing Claims (“Green Guides” or “Guides”). (OMB Control No. 

3084-0152)

EPA’s Office of Air and Radiation conducted internet survey research for developing the 

fuel economy labels that are posted on window stickers of all new light duty cars and 

trucks sold in the U.S. This survey was aimed at addressing the increasing market 
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penetration of advanced technology vehicles, in particular plug-in hybrid electric vehicles 

and electric vehicles, which will require new label metrics and presentation to effectively

convey information to consumers. (OMB Control No: 2060-0643)

The Food and Drug Administration's (FDA) Center for Tobacco Products conducted

internet research to evaluate the relative efficacy of various graphic images depicting the 

risks of cigarette smoking in influencing consumers' attitudes, beliefs, perceptions, and 

intended behaviors related to cigarette smoking. The information collected will inform 

FDA’s efforts to implement the mandatory graphic warnings required by the Tobacco 

Control Act. (OMB Control No: 0910-0668)

Similarly the information from EPA/Office of Pesticide Program’s one time survey on

labeling for insect repellent products could be used in the future to update the Agency’s pesticide 

labeling regulations and policies to more adequately address consumer needs. While both 

agricultural users and personal consumers need clear, understandable labeling instructions, 

consumers have different expectations about and less experience with the information on

pesticide labels. Just as they compare labels on grocery products, consumers expect to be able to 

compare pesticide products and select the one most appropriate to their needs. 

2(b) Practical Utility/Users of the Data

The Agency will use the information collected as part of an analysis to develop future

policy and/or regulatory efforts intended to clarify risk reduction and efficacy information to 

consumers via a label. Any new policy developed would improve consumer pesticide product 

labels and other supporting consumer materials. The Agency believes that any user of a

consumer-oriented pesticide product should be able to:

Locate on the label information such as:

o How much of the product to use

o Which pests the product effectively kills or repels

o How to apply the product

o How often to reapply the product

o Where to apply the product

o How to store and dispose of used products safely and with minimal effect on 

the environment

Compare products intended for similar uses. 

EPA evaluates and controls pesticide product risks through the registration process. The 

existing labels on consumer pesticide products adequately convey some information to the 

public. However, EPA believes that improvements are possible, and has identified areas where 

improvement is needed. The ten focus groups discussed earlier have provided qualitative data 

that provides a foundation for further research on proposed label improvements for insect 

repellents. Though this in-depth qualitative data is very important to the research process, it 

cannot be expanded to support statistical constructs, or to make large-scale assumptions about 

the population. Instead, responses from focus groups can be used to develop questions for a 

survey. 
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Quantitative data, which is provided by large surveys, is required to discover the 

statistical significance of any observations about consumers’ attitudes. It can also refine 

information gathered from the focus groups, and correct misperceptions resulting from the 

necessarily limited population comprising the focus groups. Therefore, to develop insect 

repellent labels that are the clearest and most effective for the largest number of people, a 

national survey should be carried out in addition to the focus groups already conducted. This ICR 

would be used to conduct an internet survey involving a group of 3,000 respondents that,

statistically, would more closely resemble the U.S. population. An internet survey was chosen 

over phone interview techniques, so that graphics can be included within the questions. The 

survey questions would be derived from the responses and discussions of the focus groups

concerning the efficacy marks reviewed by the focus group participants. Thus, the information 

collected through the survey will help the Agency to determine if an efficacy mark would be 

useful on an insect repellent product, and if there is a preference for one of the efficacy marks

offered in the survey. 

The information collected through the survey is expected to assist EPA in designing 

insect repellent pesticide product labels that provide the consumer with clear information. This 

will aid consumers in the safe and informed use of pesticides. EPA would use the data to 

determine what aspects of consumer pesticide product labels need to be improved and then 

establish the process for such improvements. Once the information from the survey has been 

translated into label revisions, consumers will be able to make better decisions about whether to 

purchase and use a given insect repellent. By enabling consumers to make better choices in 

regard to purchasing and using products intended to protect their health, EPA will more 

effectively carry out its mandate to protect the public from unreasonable risks to human health.

3. NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA 

3(a) Non-Duplication 

To date, the Agency is unaware of any survey that has been conducted concerning the 

usefulness and understandability of insect repellent labels, particularly with regards to efficacy.

However, in 1996, the Agency launched a voluntary project the Consumer Labeling Initiative 

(CLI) (Federal Register on March 22, 1996 (61 FR 12011)(FRL-4956-8). The purpose of the

project was to "...ensure that consumers have and understand the information they need in order 

to make responsible product choices based on their own needs and values, and to use chosen 

products safely as directed..” The CLI surveys were voluntarily undertaken and funded by 

industry and trade association Partners of CLI. The CLI partners conducted surveys concerning 

the labels of certain kinds of pesticide products used by consumers in and around their homes. 

However, none of the CLI surveys concerned insect repellent pesticide products, which are 

distinctly different than other pesticide products, since the insect repellent is deliberately applied 

to human skin. Additionally, the CLI did not address difficulties in comparing or selecting 

products based on label information. Instead, the CLI focused on improving ways to 

communicate information about a product’s hazards, first aid, storage, disposal, or providing 

manufacturer contact information. For additional information see

http://www.epa.gov/pesticides/regulating/labels/consumer-labeling.htm.
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3(b) Public Notice Required Prior to ICR Submission to OMB

Pursuant to 5 CFR 1320.8(d), EPA has published a Federal Register (FR) notice

announcing this proposed information collection activity and a 60-day public comment period

(February 18, 2011; 76 FR 9574). The Agency has established a public docket for this proposal, 

which can be accessed at http://www.regulations.gov using the docket identifier EPA-HQ-OPP2010-1085. EPA received one comment, which is addressed in Attachment G .

 

3(c) Consultations

Consultations with the general public have not been conducted since EPA was not able to 

readily identify potential respondents. Since these surveys would be conducted with a specific 

subset (those adults who purchase insect repellents) of the general public interested in 

participating in an online survey, there are no established, organized entities with whom EPA has 

a purposeful relationship. However, EPA personnel, with the assistance of a consultant with the 

expertise in consumer marketing and survey design, will develop the instruments for the surveys

and focus groups. The overall conclusions (descriptive and summary statistics) of the survey will

be publicly-available.

During the 60-day comment period for this ICR, EPA specifically requested that insect 

repellent registrants and any others who have conducted focus groups or surveys concerning 

insect repellent labels share that information with EPA. EPA received no data in response to that 

request.

Additionally, EPA believes that there could be, in the future, another opportunity for 

collecting information on the efficacy marker that purchasers of insect repellents would like on 

the product label. If the regulations in 40 CFR 156.10 are proposed for revisions to include the 

use of an efficacy marker, then there would be a comment period of 90 days or longer associated 

with that proposed rule. As part of the public comment period, EPA is considering to have a 

website available so members of the general public can “vote” on the efficacy marker that they 

prefer.

3(d) Consequences of Not Conducting the Collection of Information

Without the survey, it will be extremely difficult to determine how modifying various 

presentations of efficacy information on insect repellent labels will impact consumers’ choices 

and use of these products. The Agency will only be able to understand the consumer’s 

perspective on efficacy marks from a general qualitative perspective based on the remarks of 92 

consumers. Without the quantitative, statistically-based information, the Agency will not be able 

to determine if an efficacy mark would improve the presentation of information on insect 

repellent labels, and if the marks favored by focus group participants are understandable by a 

broader group of people; EPA therefore could not propose revisions to the labeling regulations in 

40 CFR 156.10.
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3(e) Compliance with General OMB Guidelines

This collection of information will be conducted in accordance with all OMB guidelines 

under 5 CFR 1320.6. The contractor will ensure a stratified sample of the population across 

consumer groups broadly representing the characteristics of U.S. noninstitutionalized 

respondents 18 years and older, relative to the most recent Census Bureau Current Population 

Survey. 

EPA acknowledges that survey participants would be limited to participants with access 

to a computer and that such participants tend to be persons who have self-selected by expressing 

an interest in consumer research. Having considered the costs and benefits of various data 

collection methods, EPA has concluded that the most efficient way to collect data to meet the 

research objectives within a feasible budget is to use an internet survey panel provider. One of 

the weaknesses of internet surveys is that such surveys cannot be considered representative of the 

US population as a whole. One of the sources of error for internet surveys is the lack of internet 

access: not everyone in the U.S. is online. According to the U.S. Census Bureau 2010 Statistical 

Abstract, 85 percent of U.S. adults, or 71 percent of U.S. households, have an internet connection

(2008 statistics (Table 1120 – Internet Access and Usage (2008)). 

[http://www.census.gov/compendia/statab/cats/information_communications/internet_publishing

_and_broadcasting_and_internet_usage.htm]

Though access to the internet through wired or wireless devices is increasing, 15 to 30 

percent of adults would not be able to self-select to participate in this survey. Additionally, 

“internet access tends to be positively associated with income and education and negatively 

associated with age (younger people are more likely to be online than older people). Some 

demographic groups are also less likely to be online (e.g., blacks, Hispanics, and undocumented 

immigrants)” (AAPOR, pages 9 and 52). Methods to address these issues are discussed in 

Section B. 

Because the primary focus of the study is to understand the perceptions of adults who 

purchase and use insect repellent products, using a broad sample of individuals at least 18 years 

of age will provide sufficient information to determine if the labeling regulations need to be 

changed, and information on the changes needed. Part B of this Supporting Statement has further 

detail about survey methodology.

3(f) Confidentiality 

Respondents to this information collection will be private citizens rather than regulated 

parties, so no proprietary trade secrets or other proprietary information will be collected. EPA 

will collect only the information necessary to evaluate the proposed efficacy marks. 

3(g) Sensitive Questions 

The information requested under this voluntary collection does not include questions of a 

sensitive nature. No personal or private questions will be asked. EPA will collect only the 

information necessary to evaluate the proposed labeling statements. All responses will remain 

strictly confidential, and EPA will guarantee to all survey participants that their responses will 
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remain private. However, the overall conclusions of the research will be publicly available. 

Consumer research conducted will fully conform to federal regulations – specifically the Privacy 

Act of 1974 (5 U.S.C. 552a), the Hawkins-Stafford Amendments of 1988 (P.L 100-297), and the 

Computer Security Act of 1987. 

3(h) Electronic Reporting. 

There will be no direct electronic submission scheme for this collection. The survey will 

be conducted via the internet.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED 

4(a) Respondents

Potential respondents affected by these voluntary collection activities will be adults

(those over 18) who purchase and use insect repellent products.

4(b) Respondent Activities

Surveys may involve the following activities:

Read instructions

Complete questionnaire

Return/submit questionnaire

5. AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND 

INFORMATION MANAGEMENT

5(a) Agency Activities

EPA or its contractor will perform the following activities:

Develop survey design; 

Refine survey questions based on the questions derived from the focus groups

Assemble data sources (internet address lists, etc.)

Pretest the survey

Internal EPA review and approval of survey

Submit specific survey design, including collection methodology, sample size, 

incentive plans, and summary of focus group results, to OMB for clearance under the 

PRA

Disseminate survey to respondents

Gather information from respondents

Review and analyze the information obtained

Prepare findings of the overall conclusions and results

Use the data to inform the design of label statements for pesticide products
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5(b) Collection Procedures

The survey is voluntary and will be designed to be completed by individuals and/or 

households, not small businesses. An advantage of collecting information via an internet survey

is the flexibility that such a collection offers the respondent. For example, such surveys can be 

completed at the convenience of the respondent, in privacy. There is no need to arrange times 

for interviews, disclose information to an interviewer, or return a paper form by mail.

5(c) Small Entity Flexibility

The surveys will be designed to be completed by individuals and/or households, not small 

businesses. 

5(d) Collection Schedule

One survey will be conducted.

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION 

6(a) Estimating Respondent Burden

To estimate the paperwork burden hours and costs, and the potential number of 

respondents, EPA used historical respondent information from other surveys. Table 1 below 

describes the respondent burden hours and costs.

TABLE 1. Total Respondent Burden and Cost Estimates for One-Time Survey

Testing 

Instruments

Estimated 

Number of 

Respondents

Estimated 

Response Time 

(min) per 

Respondent

Estimated 

Respondent Time 

(hours)

Estimated 

Respondent 

Costs

($20.90/hr)

Totals for OneTime Survey3000 15 750 $15675

Little is required of a survey respondent. The respondent reads the instructions, answers

the questions, and then submits the survey. 

There are no capital expenditures, or operation and maintenance costs associated with 

this information collection activity. The only cost to respondents is their time. However, to value 

the respondents’ time, information from the Bureau of Labor Statistics was used. This 

information indicated that for June 2010 wages averaged $20.90 per hour. Thus, the 

approximate value of the respondents’ response time of 15 minutes is $5.23. 
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6(b) Estimating Agency Burden

Total costs will depend on the costs necessary to develop, pre-test, conduct, and followup the survey. EPA will incur costs such as hiring contractors to develop and conduct the 

survey. Agency personnel would evaluate and then determine how to use the information 

collected to revise insect repellent labels. Costs for agency managerial and agency technical 

staff were determined using the methodology below. Costs are indexed to 2006 data. 

Methodology: The methodology uses data on each sector and labor type for an Unloaded wage 

rate (hourly wage rate), and calculates the Loaded wage rate (unloaded wage rate + benefits), 

and the Fully loaded wage rate (loaded wage rate + overhead). Fully loaded wage rates are used 

to calculate respondent costs. 

Unloaded Wage Rate: Wages are estimated for labor types (management, technical, and clerical) 

within applicable sectors. The Agency uses average wage data for the relevant sectors available 

in the National Industry-Specific Occupational Employment and Wage Estimates from the 

Bureau of Labor Statistics (BLS) at http://www.bls.gov/oes/current/oes_nat.htm. 

Sectors: The specific North American Industry Classification System (NAICS) code and website 

for each sector is included in that sector’s wage rate table Within each sector, the wage data are 

provided by Standard Occupational Classification (SOC). The SOC system is used by Federal 

statistical agencies to classify workers into occupational categories for the purpose of collecting, 

calculating, or disseminating data (see http://www.bls.gov/oes/current/oes_stru.htm ). 

Loaded Wage Rate: Unless stated otherwise, all benefits represent 43% of unloaded wage rates, 

based on benefits for all civilian non-farm workers, from 

http://www.bls.gov/news.release/ecec.t01.htm. However, if other sectors are listed for which 

43% is not applicable; the applicable percentage will be stated.

Fully Loaded Wage Rate: We multiply the loaded wage rate by 50% (EPA guidelines 20-70%) 

to get overhead costs.
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TABLE 2. Estimated Annual Agency Burden Costs Estimates for a Survey

Collection Activities

Totals

Mgmt.

$112.36/hr

Tech.

$74.47/hr

EPA

Hours

EPA

Cost

Develop survey questions 0 33.3 33.3 $2,480

Obtain approval 0.7 3.3 4 $324

Conduct survey 0 13.3 13.3 $990

Review data 0 13.3 13.3 $990

Analyze results 0.3 13.3 13.7 $1,024

Store and maintain results 0 3.3 3.3 $246

Prepare findings 0.7 10 10.7 $823

TOTAL 1.7 89.8 91.6 $6,878

Contractor Costs: approximately $55,000.00

TABLE 4. Estimated Annual Respondent and Agency Burden Hours and Cost

Hours Cost 

Respondents 

Respondent Total for OneTime Survey 750 $15,675

Agency 

Agency Total for One-Time 

Survey

91.6 $6,878

Agency Contractor Costs --- $55,000

6(e) Reason for Change in Burden

This is a new information collection activity, and therefore there are no changes in 

burden other than the beyond the new estimates provided herein. The total annual respondent 

burden for this ICR is estimated to be750 hours. This is a program change.
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6(f) Burden Statement

According to the PRA, “burden” means the total time, effort, or financial resources 

expended by persons to generate, maintain, retain, or disclose or provide information to or for a 

Federal agency. For this collection, it is the time responding to survey questions. The Agency 

may not conduct or sponsor, and a person is not required to respond to, a collection of 

information unless it displays a currently valid OMB control number. The OMB control number

will appear on the information collection instrument as applicable, i.e., form or instructions. 

The Agency has established a public docket for this ICR under Docket ID No. EPA-HQOPP-2010-1085, which is available for online viewing at www.regulations.gov, or in person 

viewing at the OPP Regulatory Public Docket in Rm. S-4400, One Potomac Yard (South 

Building), 2777 S. Crystal Drive, Arlington, VA. This docket facility is open from 8:30 a.m. to 4 

p.m., Monday through Friday, excluding legal holidays. The docket telephone number is (703) 

305-5805. You may submit comments regarding the Agency's need for this information, the 

accuracy of the provided burden estimates and any suggested methods for minimizing 

respondent burden, including the use of automated collection techniques. 

Comments may be submitted to EPA electronically through http://www.regulations.gov

or by mail addressed to Director, Collection Strategies Division, U.S. Environmental Protection 

Agency (2822T), 1200 Pennsylvania Ave., NW, Washington, D.C. 20460. You can also send 

comments to the Office of Information and Regulatory Affairs, Office of Management and 

Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Office for EPA. Include

docket ID No. EPA-HQ-OPP-2010-1085 and OMB control number 2070-new in any 

correspondence but do not submit information under this collection to these addresses.
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ATTACHMENTS TO THE SUPPORTING STATEMENT

Attachments to the supporting statement are available in the public docket established for this 

Information Collection Request (ICR) under the docket identification number EPA-HQ-OPP2010-1085. These attachments are available for online viewing at www.regulations.gov or 

otherwise accessed as described in the sections below. 

Attachment A: 7 U.S.C. 136a - FIFRA Section 3 - This attachment can be accessed via the 

internet at: http://www4.law.cornell.edu/uscode/7/usc_sec_07_00000136---a000-.html

Attachment B: 40 CFR 156.10: This attachment can be accessed via the internet at:

http://www.access.gpo.gov/nara/cfr/waisidx_07/40cfrv23_07.html

Attachment C: Part B - Survey Methodology - This attachment is part of the docket EPA-HQOPP-2010-1085 at regulations.gov.

Attachment D: Consumer Efficacy Mark Questionnaire. Prepared by Shugoll Research 

(draft – 05-23-2011). This attachment is part of the docket EPA-HQ-OPP-2010-1085 at 

regulations.gov.

Attachment E: Focus Group Report. Prepared by Shugoll Research (09-21-2010). This 

attachment is part of the docket EPA-HQ-OPP-2010-1085 at regulations.gov.

Attachment F: Short Presentation of Focus Group Report. Prepared by Shugoll Research. 

This attachment is part of the docket EPA-HQ-OPP-2010-1085 at regulations.gov.

Attachment G: EPA’s Response to Comments Document. This attachment is part of the 

docket EPA-HQ-OPP-2010-1085 at regulations.gov.