1 SUPPORTING STATEMENT FOR AN INFORMATION COLLECTION REQUEST (ICR)

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title: Use of S urveys 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 voluntary information collection , a 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 i s 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 u se. This is a voluntary survey. One survey would b e conducted over the life of the ICR.

The collected information c ould 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 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 Collection2 With few exceptions, s ection 3 of t he Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), requires the EPA to register all pesticide products sold in the

United States

. (See a ttachment 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, fre quency and timing of its use ; and storage and disposal practices.

EPA’s review of proposed labeling on a n insect repellent package or container and the accompanying instructions is a key part of EPA’s pesticide reg istration process

. Under FIFRA section 3(c)(1), a complete copy of the label

, along with a statement of all

claims made about the p roduct , and any directions for use must be submitted with the registration application. The label of an insect repellent provide s critical info rmation

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. (Se e 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’ perception s an d understanding of pesticide label information, EPA cannot judge if the content and design o f the label communicat es 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 underst and 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 group s were conducted in Bethesda, MD; Tampa, FL; Norwalk, CT; and Minneapolis, MN. Four consumer segments were included in the market research: light/ in frequent 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 result s of a focus group are considered to be qualitative research. A qualitative research methodology seeks to deve lop 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 hypo theses for further study and decision

- making. Though the non

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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

.

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 b ecause there are no standard s for th e 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, i nstead of standard information

, claims on current inse ct 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 consumer s 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 situation s 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.

Th e 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 consumer s’ 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 Agen cy’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 u nderstand 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 Federa l Trade Commission conduct ed an internet survey to examine consumer perception of environmental marketing claims (such as “eco

- friendly”4 or “green”) . The s urvey was part of the Commission’s regulatory review of the

Guides for the Use of Environmental Marke ting 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 sol d in the U.S. . This survey was aimed at addressing

the increasing market 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

conduct ed 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 e fforts to implement the mandatory graphic warnings required by the Tobacco Control Act. (OMB Control

No: 0910

- 0668)

Similarly t he information from EPA/Office of Pesticide Program’s one time

survey on labeling for insect repellent products could be used i n 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 expec tations about and less experience with the information on pesticide label s . Just as they compare labels on grocery products, consumers expect to be able to compare pesticide products and sel e ct 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 develop ed 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 :

L ocate on the label information such as:

o How much of the product to us e

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 H ow to store and dispose of used products safely and with minimal

effect on the environment

C ompare products intended for similar uses.5 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 t hat 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 construct s
, or to make large

- scale assumptions about the population. Instead, r esponses from focus groups can be used to develop questions for a survey.

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 label s that are the clear est 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 a n internet survey involving a group of

3

, 000 respondents that

, statistically

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

. Thu s
, the informati on 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 collect ed through the survey is expected to assist EPA in designing insect repellent pesticide product labels that provide the consumer with clear

information . This will a id 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 b e 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 m andate 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 usefulnes s 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

-6

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

volu ntarily undertaken and funded by industry and trade association Partners of CLI. The

CLI partners c onducted 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 prod ucts 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

.

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. The Agency has established a public docket for this proposal, which can be

accessed at http://www.regulations.gov using the docket identifier EPA

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- 1085 . Any comments received will be given consideration when comple ting the supporting statement that is submitted to OMB.

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

, wi th the

assistance of a consultant with the expertise in consumer marketing and survey design

, will develop the instruments for the surveys and focus groups

. T he overall conclusions (descriptive and summary sta tistics) of the survey will be publicly

- availab le.

Additionally, EPA believes that there are two other opportunities for collecting information on the information that purchasers of insect repellents would like on the product label. During the 60

- day comment period for this ICR, EPA will specifically request that insect repellent registrants and any others who have conducted focus groups or surveys concerning insect repellent labels share that information with EPA. Also, if the regulations in 40 CFR 156.10 are proposed for revisions , then there would be a comment period of 90 days or longer associated with that proposed rul e

. 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 th ey prefer.

3(d) Consequences of Not Conducting the C ollection of Information7 Without the survey , it will be extremely difficult to det ermine how modifying

various presentations of efficacy information on insect repellent labels will impact consumers’ choices and use of these products

. T he 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

, stat istically

based information , the Agency will not be able to determine if an efficacy mark would improve the presentation of information on insect repellent label s
, and if the marks favored by focus group participants are understandable by a broader group o f people;

EPA therefore could not propose revisions to the labeling regulations in 40 CFR 156.10.

3(e) Compliance with General OMB Guidelines

This collection of information will be co nducted 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, relati ve 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 inte rest 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

pane l provider. One of the weaknesses of i nternet 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 on line. 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/compend ia/statab/cats/information_communications/internet_pu blishing_and_broadcasting_and_internet_usage.html]

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 participa te 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 an d 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.8 3(f) Confidentiality

Respondents to this information collection will be private citizens rather than regulated parties, so n o 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 i nformation requested under this voluntary collecti on 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 w ill guarantee to all survey participants that their responses will remain private. However, the overall conclusions of the research will be publicly available. Consumer research conducted will fully conform to federal regulations

– specifically the Priva cy 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. T he survey will be co nducted via the internet.

4

. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents

Poten tial respondents affected by these voluntary collection activiti es will be

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

4(b) Respondent Activities

S urveys 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:9 Develop survey design; Refine survey questions based on the questions derived from the focus groups

A ss emble 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 fro m 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

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 a n internet survey is the flexibility that such a collection offers the respondent . For example,

such s urveys 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 indi viduals 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.10

T ABLE 1

. Total Respondent Burden and Cost Estimates for One

- Time Survey

Testing

In struments Estimated

Number of Respondents Estimated

Response Time (min) per Respondent Estimated

Respondent Time (hours) Estimated

Respondent

Costs ( $2 0.90 /hr )

Totals for One

Time Survey 3 000 15 7 50 $ 15675

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

answer s 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 responde nts is their time. However, to value the respondents’ time, information from the Bureau of Labor Statistics

was used. This information indicated t hat for June 2010 wages averaged $20.90 per hour. Thus, the estimated value of the respondents’ response tim e of 15 minutes is $ 5.23.

6(b) Estimating Agency Burden

Total costs will depend on the costs necessary to develop, pre

- test, conduct, and

follow

- up the survey. EPA will incur costs such as hiring contractors to de velop and conduct the survey

. Agency p ersonnel would evaluate and then determine how to use the information collected to revise insect repellent labels. C osts for agency managerial and

agency technical staff were determined using the methodology below. Attachment B contains a worksheet provi ding the breakout of these costs. Costs are index ed 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 l abor types ( management, technical, and

clerical ) within applicable sectors. T he Agency uses a verage 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://ww w.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 (see Attachment F). Within each sector, the wage data are provi ded by Standard Occupational Classification (SOC). The SOC system is used by Federal statistical agencies to classify workers into11

occupational categories for the purpose of collecting, calcu lating, 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.

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 $ 2,4 80

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 $ 24 6

Prepare findings 0.7 10 10.7 $ 823

TOTAL 1.7 89.8 91.6 $6,878

Contractor Costs: approximately $55,000.0012

TABLE 4

. Estimated Annual Respondent and Agency Burd en Hours and Cost

Hours Cost
Respondents

Respondent Total for

One

- Time Survey 7 50 $ 15

, 675

Agency

Agency T otal for One

Time Survey 91.6 $6,187

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 be 250 to 3 75 hours. This is a program

ch ange.

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 in formation collection instrument as applicable, i.e., form or instructions.

The Agency has established a public docket for this ICR under Docket ID No.

EPA

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- 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 o f 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 Strategie s13

Division, U.S. Environmental Protection Agency (2822 T ), 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

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- 1085 an d OMB control number 2 070

- new in any correspondence but do

not submit information under this collection to these addresses.14

ATTACHMENTS TO THE SUPPORTING STATEMENT

At tachments to the supporting statement are available in the public docket established for

this I nformation C ollection R equest (ICR) under the docket identification number EPA

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- 1085 . These attachments are available for online viewing at www.regulations.gov or otherwise accessed as described in the section s below.

Attachment A : 7 U.S.C. 136a

- FIFRA Section 3 :

- This attachment can be accesse d via

the internet at : http://www4.law.cornell.edu/uscode/7/usc_sec_07_00000136

--- a000

- .html

Attachment B : 40CFR 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

HQ

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- 1085 at regulations.gov.

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

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- 2010)

Attachment E: Focus Group Report . Prepare d by Shugoll Research (09

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- 2010): This attachment is part of the docket EPA

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

Resear ch: This attachment is part of the docket EPA

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- 1085 at regulations.gov.