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SUPPORTING STATEMENT FOR AN

INFORMATION COLLECTION REQUEST (ICR) 

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title: Consumer Research through Focus Groups to Develop Improved 

Labeling for Pesticide Products 

EPA ICR No.: 2367.02 OMB Control No.: 2070-0175

1(b) Short Characterization

The Environmental Protection Agency (EPA or the Agency) intends to renew a voluntary

information collection for consumer research involving the use of focus groups to test various 

versions of pesticide product labels and other informational materials intended for the general 

public. The purpose for this research is to identify the consumer’s understanding of the 

information on a pesticide product label. EPA will use this information to formulate decisions 

and policies affecting the labeling of pesticide products. The ultimate goal of this activity is to 

assure that the consumer can effectively use this information to select the pesticide product most 

likely to meet their needs, and to assure that the consumer can readily understand label 

instructions regarding the safe use, handling, storage, and disposal of the product. The collected 

information will be used to inform the Agency on the need for and nature of potential revisions 

to EPA guidance and regulations regarding pesticide product labels and to create other userfriendly consumer information materials. It is anticipated that multiple focus groups would be 

conducted over the life of the ICR.

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 all pesticides sold or distributed in the United States to be registered by EPA. 

(See attachment A). Pesticide registration is the process through which EPA evaluates the 

pesticide to ensure that it will not have unreasonable adverse effects on humans, the environment 

and non-target species. As part of the registration process, EPA examines the ingredients of a 

pesticide, the site or crop on which it is proposed to be used, the amount, frequency and timing 

of its use, and storage and disposal practices. Pesticides must be registered or exempted by

EPA's Office of Pesticide Programs (OPP) before they may be sold or distributed in the United 

States. Once registered, a pesticide may not legally be used unless the use is consistent with the 

approved directions for use on the pesticide's label or labeling.

Under FIFRA section 3(c)(1), a complete copy of the pesticide labeling, along with a 

statement of all claims made for the pesticide and any directions for pesticide use, must be 

submitted with the registration application. Therefore, a key part of EPA’s pesticide registration 

process is EPA’s review of the registration applicant’s proposed labeling on the pesticide 

package or container and any accompanying instructions. The label instructions provide critical 
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information about how to safely handle, use, store, and dispose of the pesticide product to avoid 

harm to human health and the environment. 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 primarily

for agricultural products. Since then, 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. Today, there is concern that the label 

requirements in 40 CFR §156.10 and other related guidance may not adequately address the 

distinction between the needs of consumers and the needs of the agricultural sector. 

The Agency believes that current labeling regulations, guidance, and policies need to be 

updated to more adequately address consumer needs, which are different from those of the 

agricultural sector. While all users need clear, understandable labeling instructions, consumers 

also have different expectations about the information that they will find on a label. Just as they

compare labels on grocery products, consumers expect to compare pesticide products in order to 

select the one most appropriate for their needs. 

As part of its Pesticide Program Dialogue Committee (PPDC), formed under the Federal 

Advisory Committee Act to provide a forum for a diverse group of stakeholders to provide 

feedback to EPA on various pesticide regulatory, policy, and program implementation issues, 

EPA recently established a workgroup on Comparative Safety Statements or Logos for Pesticide 

Product Labeling. Some producers of pesticide products want to use logos from organizations

that certify that the product meets certain criteria, such as EPA’s Design for the Environment, 

Green Seal, or EcoLogoCM, and use more “factual statements” on the label, essentially what is 

being termed as “green labeling.”

However, without knowledge concerning the consumer’s perspective and interpretation 

of the information on the label, EPA cannot judge if the proposed content and design of the label 

is effectively conveying useful safety and performance information to the consumer. It is the 

Agency’s goal that consumer labels enhance the consumer’s understanding of and ability to use 

products safely and effectively. For example, focus groups conducted during 2010 indicated that

in addition to wanting to avoid the pain and itching associated with insect bites, consumers of 

insect repellent products use repellents because they are aware that certain insects carry

potentially deadly diseases and want to reduce the risk of contracting these diseases. They want 

to know what insects are repelled, and they want to know how long those insects will be repelled

in hours so they will know how often to re-apply. Consumers want information on the label to be 

clear, concise, and in larger print, and they do not like vague statements such as “long-lasting.”

Before initiating any formal policy or other regulatory decision-making activities to 

update label regulations or guidance, the Agency needs such information about consumer needs 

and an understanding of consumer perceptions of the information on a pesticide product label in 

a focus group setting. Testing of existing and/or proposed label statements in realistic situations 

with typical consumers is needed to determine the clarity and understandability of a pesticide 

product label, and to determine what these label statements are likely to communicate to 

consumers. This information collection will allow EPA to gather, via a focus group setting, the 
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necessary information about consumers’ comprehension of the information that is on a pesticide 

label, and how a consumer uses this information to make their decision to purchase and then 

safely handle the product. This information will also inform and provide support for revisions to 

the Agency’s policy, guidance, and regulatory activities related to pesticide label language and 

design label metrics.

2(b) Practical Utility/Users of the Data

The Agency will use this information collection to inform the development of future

pesticide labeling related policy, guidance, and/or regulatory efforts to provide consistent, 

meaningful, and transparent risk reduction and efficacy information to the public. The goal of 

any new or revised policy, guidance, or regulatory provision developed as a result of these 

efforts would be to 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 The pests that 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 Understand how to store and dispose of products safely and with minimal 

effect on the environment

 Compare products intended for similar uses. 

EPA evaluates and controls potential product risks through the registration process

described in 2(a) above, which includes the approval of the product’s label and accompanying 

information. Although the existing labels on consumer pesticide products may adequately

convey information to the public, EPA believes that improvements are possible. 

The first use of this ICR collected information in a focus group setting on the public’s 

understanding of insect repellent labels, and the potential use of an efficacy mark to identify the 

product’s repellency time. In the future, other focus groups may be used to gather information 

about the public’s understanding of labels used for other categories of consumer products, or on 

general proposals related to label design or other materials for consumers.

The focus groups will provide valuable qualitative information that can be used to gain 

insights into some consumer reactions, as well as ways to explore issues or structure future focus 

groups, or otherwise word the questions used in the focus groups. Focus group research consists 

of open-ended, yet structured discussions with small groups of individuals, and therefore can 

provide in-depth information about the topic discussed in that focus group. 

While EPA anticipates that focus group research would yield helpful information, the 

information obtained from small groups may not necessarily be extrapolated or generalized to 

the general public. In order to obtain a more robust understanding of consumers’ use of pesticide 

products and label comprehension, the Agency may also use the information obtained from the 

focus groups to develop more in-depth surveys to cover a larger population that can also produce 
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statistically significant quantitative data. Such in-depth surveys are not a part of the information 

collection activities covered by this supporting statement.

In addition to generally improving EPA’s understanding about the specific needs for 

consumer product labels and labeling in terms of design and content, EPA will use the data 

collected through the focus groups to determine what aspects of EPA’s policy, guidance, or 

regulations need to be improved, identify potential improvements, and then set about a process 

for implementing those improvements. 

Once the information from the focus groups has been translated into label revisions, 

consumers will be able to make better decisions about whether to purchase and use a given 

pesticide or insect repellent product. 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 

This information collection activity is specific to the needs of the federal pesticide law

that is administered by EPA, thereby negating the need for this or similar data by other federal 

agencies or any other office within EPA. 

3(b) Public Notice Required Prior to ICR Submission to OMB

Pursuant to 5 CFR 1320.8(d), EPA published a Federal Register (FR) Notice (76 FR 

76399, December 7, 2011) announcing this proposed information collection activity and 

provided a 60-day public comment period. The Agency established a public docket for this 

proposal, which can be accessed at http://www.regulations.gov using the docket identifier EPAHQ-OPP-2011-0902. The Agency did not receive any comments during the comment period. As 

a result, the Agency did not make any changes to the burden projections in this ICR, and has 

made only non-substantive changes to this ICR.

 

3(c) Consultations

The Agency’s efforts to improve consumer pesticide product labels is based on various 

discussions with different stakeholders and regulated entities that occurred as part of the 

programs ongoing consultations over the years. Examples of organizations for potential 

consultation could include:

 State agricultural agencies

 The PPDC workgroup on Comparative Safety Statements or Logos for Pesticide 

Product Labeling

 The State-FIFRA Issues Research and Evaluation Group (SFIREG). 
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The focus groups used to test various versions of pesticide product labels and other 

informational material would be conducted with members of the general public, so there are no 

established, organized entities with whom EPA has a purposeful relationship. Since EPA was 

not able to readily identify potential respondents, consultations with the general public have not 

been conducted. However, EPA personnel, with the assistance of a contractor from industries 

with the expertise in consumer marketing and design of focus group discussions about consumer 

products, will identify the materials and develop the design of the focus groups. The overall 

conclusions (descriptive and summary statistics) of the focus groups will be publicly-available. 

3(d) Effects of Less Frequent Collection

Each focus group will be a one-time collection exercise for the enrolled participants, so 

the effect of conducting the information collection activity less frequently would be to not 

conduct it at all. 

3(e) Compliance with General OMB Guidelines

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

under 5 CFR 1320.6. Respondents will be asked to participate in the consumer research 

activities only once and their participation will be voluntary. There will be no need for 

participants to maintain records or submit proprietary trade secrets or other information. 

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.

3(g) Sensitive Questions 

Focus group participants voluntarily agree to participate in this research by specifically 

opting-in. Participants must actively seek such opportunities by signing-up and placing their 

information in the focus group facility database. A minimal amount of information is collected 

for that database, such as name, address (contact information), age, highest level of education 

completed, employment status, household income, ethnicity, and gender. Such information 

would be collected by the research company as part of their standard business practice,

regardless of whether EPA conducted a survey or not. The research company uses this 

information to search within their database to locate appropriate participants, and then balance 

the focus groups. Significantly, EPA does not collect or retain this information. EPA retains 

only the opinions of the participants. EPA will guarantee all participants that their responses will 

not be attributed to any individual. 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. 
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4. THE RESPONDENTS AND THE INFORMATION REQUESTED 

4(a) Respondents

Potential respondents to this information collection will include members of the general 

public that volunteer (opt-in) to participate in a focus group.

4(b) Respondent Activities

Focus Groups may involve the following activities:

 Listen to instructions.

 Review handouts (labels and/or other information) being discussed.

 Participate in discussions

 Complete forms, if applicable

5. AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND 

INFORMATION MANAGEMENT

5(a) Agency Activities

EPA or its contractor will perform the following activities:

 Identify the topic for the focus group.

 Design the approach for conducting the focus group (agenda, discussion points, 

presentation materials).

 Internal EPA review and approval of discussion topics and the design of the 

approach.

 Identify and then screen focus group participants (recruited from the focus group 

facility database).

 Conduct focus group.

 Review and analyze the information obtained.

 Provide an aggregated report of the information obtained and the overall conclusions 

and results.

 File and store data (information from focus group and analysis), as appropriate.

 Use the data to inform the design of label statements for consumer pesticide products

and/or prepare questions for a national survey.

5(b) Collection Procedures

EPA’s contractor will implement the approach prepared for the focus group, including 

making the necessary logistical arrangements for the focus group and contacting the participants. 

Both video and tape recordings will be used to document the discussions. Given the fixed 

position of the camera and recording equipment, identification of specific individuals would be 

challenging. The contractor will also prepare written transcripts. Video or tape recording “clips” 

may be used in briefing materials, but the “clips” will be maintained under Agency control and 

would not be distributed or used for publication purposes. 
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5(c) Small Entity Flexibility

The focus groups will be designed for participation by individuals, not businesses. 

5(d) Collection Schedule

EPA anticipates conducting up to 10 focus groups each year, over the next three years. 

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION 

6(a) Estimating Respondent Burden and Cost

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

respondents, EPA used the information obtained during the focus groups conducted during 2010. 

The per respondent burden to participate in a single focus group is estimated to be 

approximately 2 hours. Each focus group would have 8 to 12 participants, or an average of 10 

participants for each focus group. This is an estimated respondent burden of 20 hours for each 

focus group. The industry standard is to use the same or similar materials to conduct a series of 

focus groups. Therefore, for a series of 10 focus groups, conducted using the same materials, the 

estimated annual respondent burden is 200 hours.

Serving on a focus group means the respondent merely answers the questions and 

participates in the discussions. There are no capital expenditures, or operation and maintenance 

costs associated with this information collection activity. To value the respondents’ time, 

information from the Bureau of Labor Statistics (BLS) released on June 8, 2011, was used 

(http://www.bls.gov/news.release/archives/ecec_06082011.pdf). Wages averaged $20.91 per 

hour. Benefits averaged $9.15. Thus, the total potential cost for the participants’ time is 

estimated to be $30.07 per hour. The cost of 10 focus group participants, two hours each, is

$601.40 per focus group (20 hours x $30.07 per hour). The annual cost for a series of 10 focus 

groups is $6,014.00. 

EPA notes that focus group participants are paid. This is an industry standard to 

acknowledge the use of the participant’s time, as well as driving and parking expenses. A 

customary payment is $75 per participant for 2 hours. This is part of the contractor costs.

6(b) Estimating Agency Burden and Costs

Total Agency burden and costs will depend on the costs necessary to develop and

conduct the focus groups, and then to analyze the data gathered and prepare the report that will 

be made publicly available for that focus group. This also includes costs such as hiring 

contractors to develop materials and conduct the focus groups, travel to focus group cities for 

both agency and contractor personnel, and renting meeting space. Agency personnel would

determine how to use the information collected to improve consumer pesticide product labels, as 

well as related policies, guidance, or regulations. The same or similar materials and approaches 

are used for a series of 10 focus groups. 
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Costs for agency managerial and agency technical staff were determined using the 

following methodology: 

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 the Agency’s staffing 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 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 43.6% 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 

43.6% 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. Costs are indexed to 2009 data (See Attachment C). 

The industry standard is to use the same or similar materials to conduct a series of focus 

groups. Therefore, the estimated annual Agency burden is for a series of 10 focus groups, 

conducted using the same materials. 

The estimated Agency burden for one focus group is 36 hours and the estimated cost for 

one focus group of $11,266, which includes an estimated $8,500 for contractor costs and $2,766 

for EPA administrative costs (See Table 1). 

The total annual Agency burden for conducting a series of 10 focus groups is estimated to 

be 360 hours (36 hours for one focus group x 10 focus groups) and cost $112,657.60 ($2,765.76

plus $8,500 for one focus group x 10 focus groups).
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TABLE 1: Estimated Annual Agency Burden Costs Estimates for One Focus Group

Collection

Activities

Burden Hours Total

Mgmt.

$112.42/hr

Tech.

$74.51/hr

Contractor EPA

Hours

EPA

Cost

Develop focus groups 

materials 0.6 12

$8,500.00

per focus group

(includes 

payments

to participants)

12.6 $961.57

Conduct focus groups 0.4 0.8 1.2 $104.58

Review data 0 6 6 $447.06

Analyze results 0 7 7 $521.57

Store and maintain results 0 0.5 0.5 $37.26

Prepare findings 1.2 7.5 8.7 $693.73

TOTAL 2.2 33.8 $8,500.00 36 $2,765.76

6(c) Bottom Line Burden Hours and Cost 

The total annual burden hours and costs for this ICR are presented in Table 2.

TABLE 2. Estimated Annual Respondent and Agency Burden Hours and Cost

Per Event (Focus Group) 10 Focus 

Groups 

per Year

Total Annual

Burden Hrs. Costs Burden Hrs. Costs

Respondent 20 $601.40 10 200 $6,014.00

EPA 36 $11,265.76 360 $112,657.60

6(d) Reason for Change in Burden

The total annual respondent burden from the previously approved ICR was 80 hours at a 

cost of $2,012.80. The burden in the previously approved ICR is based on the Agency’s use of 

estimates that were based on a similar ICR. This ICR renewal is based on the actual costs of 

conducting a series of 10 focus groups in 2010. This ICR will increase the burden hours to 200 

hours at a cost of $6,014.00. This change is an adjustment. 

6(e) Burden Statement

The total annual respondent burden is estimated to be 200 hours at a cost of $6,014.00, 

for a series of 10 focus groups. The per respondent burden is 2 hours. 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 participating in a focus group. The Agency may not conduct or sponsor, 

and a person is not required to respond to, a collection of information unless it displays a 
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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-2011-0902, which is available for online viewing at www.regulations.gov, or in person 

viewing at the OPP Docket in the EPA Docket Center, EPA West, Rm. 3334, 1200 Pennsylvania 

Ave, NW, Washington DC. This docket facility is open from 8:30 a.m. to 4:30 p.m., Monday

through Friday, excluding legal holidays. The OPP 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-OPP2011-0902 and OMB Control No. 2070-0175 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-OPP2011-0902. These attachments are available for online viewing at http://www.regulations.gov

unless 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://www.law.cornell.edu/uscode/7/136a.html

Attachment B: 40 CFR 156.10: Labeling Requirements: This attachment can be accessed via 

the internet at: http://edocket.access.gpo.gov/cfr_2007/julqtr/pdf/40cfr156.10.pdf

Attachment C: Work Sheet used to Calculate EPA and Federal Government Labor Costs