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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 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 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. This is a voluntary survey. 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 

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 
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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.

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 FIFRAregulated 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-
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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 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” 
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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 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. 
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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. 

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-
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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.

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-HQ-OPP-2010-

1085. Any comments received will be given consideration when completing 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, 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.

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 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
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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, statisticallybased 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.

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_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 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.
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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 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:
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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

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.
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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 estimated value of the respondents’ response time 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 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. Attachment B

contains a worksheet providing the breakout of these costs. 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 (see Attachment F). 

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 
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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.

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

Hours Cost 

Respondents 

Respondent Total for 

One-Time Survey 750 $15,675

Agency 

Agency Total for OneTime 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 375 hours. This is a program 

change.

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-HQ-OPP-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 
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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. EPAHQ-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 EPAHQ-OPP-2010-1085. 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: 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 EPAHQ-OPP-2010-1085 at regulations.gov.

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

(draft – 11-22-2010)

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.