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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON D.C., 20460

OFFICE OF CHEMICAL SAFETY AND 

POLLUTION PREVENTION

December 15, 2015

MEMORANDUM 

SUBJECT: Science Review of Field Testing of S.C. Johnson Personal Mosquito Repellent 

Products to Support Their Use of the EPA Repellency Awareness Graphic.

FROM: Kevin J. Sweeney, Senior Entomologist

Invertebrate-Vertebrate Branch 1

Registration Division (7505P) 

Office of Pesticide Programs

Eric W. Bohnenblust, Ph.D., Entomologist

Invertebrate-Vertebrate Branch 2

Registration Division (7505P) 

Office of Pesticide Programs

TO: Marietta Echeverria, Chief,

Invertebrate-Vertebrate Branch 1

Registration Division (7505P)

Office of Pesticide Programs

REF: Palm, J. M. (2015) Field Testing of S.C. Johnson Personal Mosquito Repellent 

Products to Support Their Use of the EPA Repellency Awareness Graphic –

Project 864E1. Unpublished document prepared by S. C. Johnson & Son, Inc., 

1525 Howe Street Racine, WI 53403, September 24, 2015. 154 p. (MRID 

49750201) (D430001)

ACTION REQUESTED 

Conduct a science review of a completed field study testing the efficacy of an insect repellent 

formulated as a pressurized aerosol spray product containing diethyl toluamide (DEET) against 

mosquitoes. Determine the adequacy of the methods employed and the scientific validity of the 

reported data. These data are required to establish the median complete protection time (CPT) 

against mosquitoes for use in the EPA Repellency Awareness Graphic on the label of EPA Reg. 
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No. 4822-397, Mark-2 OFF! Deep Woods Sportsmen Insect Repellent II (Unscented Deep 

Woods Off! Insect Repellent) (30% DEET). The protocol used to conduct this study was 

previously reviewed and accepted by EPA and the HSRB on April 23, 2015. The protocol used 

in this study was amended to incorporate EPA and HSRB recommendations.

CONCLUSIONS

The EPA assessed the scientific aspects of the research in relation to the recommendations of the 

EPA §810.3700 product performance testing guideline and the EPA Human Studies Review 

Board. The study (MRID 49750201) was conducted in accordance with Good Laboratory 

Practices as described in 40 CFR §160 (with one minor GLP exception as described in Protocol 

Deviation #7), and provides scientific data that are acceptable. The Human Studies Review 

Board will be asked to comment on this study. 

SCIENCE REVIEW

Study objective: The objective of this study is to establish the complete protection time of 

MARK-2 in the field against populations of wild mosquitoes using human volunteer subjects. This 

is a guideline study designed to fulfill the requirements in OPPTS Series 810.3700 Product 

Performance Guideline, Insect Repellents to be applied to Human Skin. This study was conducted 

in accordance with EPA, FIFRA (Federal Insecticide, Fungicide and Rodenticide Act), Good 

Laboratory Practice Standards (GLP); 40 CFR, Part 160 (October 1989) (p. 3 of 154).

Identification of the test system: In this study, landings of wild mosquitoes on replicate human 

subjects were used to evaluate the repellency of a pressurized aerosol insect repellent product 

(30% DEET) applied to human skin. Mosquitoes were used because they are one of the insect 

pest groups targeted by the product and one of the insect groups represented on the EPA 

Repellency Awareness graphic. The registrant conducted tests in two field locations, one in 

Florida and one in Wisconsin. The following mosquito genera were collected and identified, 

Coquillettidia, Psorophora, Aedes, Culex, Mansonia, and Anopheles (Tables 3 and 4; p. 11 of 

154).

Table 3. Wisconsin Site Mosquito Species Collected - August 3,2015

Species Number 

Collected % of Total

Coquillettidia perturbans 17 17.2

Psorophora ferox 1 1.0

Aedes vexans 1 1.0

Aedes trivittatus 80 80.8

Total 99 100

Table 4. Florida Site Mosquito Species Collected - August 18-19, 2015
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Species

Number

Collected % of Total

Anopheles atropos 2 0.9

Anopheles crucians 1 0.4

Aedes atlanticus 76 32.6

Aedes infirmatus 116 49.8

Aedes taeniorhynchus 9 3.9

Culex erraticus 6 2.6

Mansonia dyari 3 1.3

Mansonia titillans 15 6.4

Psorophora ferox 5 2.1

Total 233 100.0

Experimental design: This field study was conducted with human subjects at two

geographically and ecologically distinct field sites, one in Kenosha County, Wisconsin on 

August 3, 2015, and one in Collier County, Florida on August 18-19, 2015. At each site, the 

experimental treatment groups consisted of 10 different treated subjects and the untreated control 

group consisted of two untreated subjects. Subjects at each site were selected from a pool of 

trained participants (Table 7). In Wisconsin, testing was conducted during the course of a single 

day while in Florida testing was conducted over the course of two consecutive days; each day 

with five treated subjects (§13.1, p. 20 of 154).

Table 7. Summary of Test Subject Participation in GLP864E1 – EPA Reg. No. 4822-397 (This 

is the revised version of Table 7 appearing on p. 13 of 154 sent to EPA by S. C. Johnson & Son, 

Inc.)

GLP 864E1 - 4822-397 Wisconsin Florida Total

Number of Subjects 

Enrolled 24 30

54

(Note: S.C. Johnson corrected 

the chart in the study which 

indicated a total of 53, which 

was a typographical error.)

Number of No-Shows to 

training and/or testing

No-shows for training: 3

No-shows for testing: 0

No-shows for training: 17

No-shows for testing: 0

20 (20 no-shows for training, 0 

no-shows for testing)

Number Assigned as Test 

Subjects 12 12 24

Number Assigned as 

Alternates or Extras

5 alternates

4 extras

0 alternates

0 extras 9

Number of Test Subjects 

Withdrawn Voluntarily 0

1 on training day

1 on test day (posttreatment)

2 (1 on training day, 1 on test 

day)

Number of Test Subjects 

Withdrawn Involuntarily 0 0 0

Number of Test Subjects 

Completed Research 12 11 23
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In Wisconsin: 12 test 

subjects (10 treated test 

subjects and 2 controls)

and 5 alternates were 

randomly selected as 

described in the report

out of the pool of 21

trained participants.

In Florida: Only 12 trained 

participants were 

available on this test day. 

10 treated test subjects 

and 2 controls were 

selected as described in 

the report out of the pool 

of 12 trained participants.

The experiment was partially randomized, the test subjects were randomly selected from a pool 

of potential subjects that met the inclusion criteria found in §12.3, pp. 14-15 of 154. Using an 

allocation table, treatments were assigned to the limbs of each subject. If the subject was 

assigned an odd number, the left limb was treated and if assigned an even number the right arm 

was treated. This was true for all treated test subjects except for one treated subject (Subject ID

#49) who drew an odd number but had her right arm treated. This was due to a prior injury to her 

left arm.

Treated subjects were blinded to the identity of the test substance (§13.3, p. 21). The two 

subjects most proficient at aspirating mosquitoes from the pool of subjects were used at each site 

as untreated controls to determine mosquito landing rate. The untreated control subjects chose 

which arm to expose to mosquitoes so the dominant hand could be used to aspirate mosquitoes.

Test preparation. At the testing sites, study staff prepared subjects for testing in a tent enclosure 

to protect them from mosquitoes during preparation. Subjects washed their limbs before 

dressing in bug suit pants and jackets, and gloves to protect untreated body parts from mosquito 

bites. To treat the forearm, the selected forearm of the bug suit was rolled up and the arm treated 

as discussed in the Test Substance Application Rate and Treatment section below (§13.4 -13.5, p. 

21 of 154). 

Measuring repellency. The unit of measure for assessing repellent effects in this experiment

was mosquito landings, similar to previous skin applied repellent evaluations where the 

“Landings” measure is used and repellency is measured as CPT. To determine CPT for each 

subject, subjects were grouped into pairs. Pairs were separated from each other by at least 

twenty feet. Starting two hours after application of the repellent product (Protocol Deviation #6, 

Appendix B, p. 118 of 154), subjects observed their limbs for five minutes for landing 

mosquitoes. Mosquitoes that landed were aspirated by each subject or their partner, and if 

necessary, headlamps were used at night so subjects could see to aspirate mosquitoes. For this 

study, headlamps were required on August 18, 2015 only. After the five-minute exposure 

period, subjects reported the number of mosquito landings on them to study staff who recorded

the number for each subject. Aspirated mosquitoes were labeled and kept to be identified. The 

five-minute exposures were conducted every thirty minutes until repellent failure occurred. 

Two untreated control subjects were paired together and used to confirm that mosquito 

populations were adequate to test the repellency of the product. Untreated control subjects were 

exposed to mosquitoes for a five-minute period every thirty minutes as described above for 

treated subjects. However, to reduce the exposure of untreated control subjects to mosquitoes, 

untreated subjects covered their exposed limb after five landings in the five-minute exposure 

period. Five landings on each untreated subject during the five-minute exposure period were
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considered the minimum necessary to ensure the mosquito population was large enough to 

determine repellency of the tested product. The time to reach five landings on the untreated 

control subjects was recorded for each five-minute exposure period [§13.7, p. 23 of 154].

Subject specific Complete Protection Time (CPT) was calculated as time from application of the 

test substance to a subject and the First Confirmed Landing on that subject. A landing occurred 

when a mosquito alighted on the treated skin of a subject. A First Confirmed Landing is that 

which is followed by another landing within a 5 minute exposure period or, when one land 

occurs in such an exposure period and another landing occurs in the next exposure period (30 

minutes later) (§3.1, p. 8 of 154). Subjects with repellent failures were removed from the field 

test when a First Confirmed Landing occurred. The test was terminated as determined by the 

study director. 

The duration of repellency time to appear on the Repellency Awareness Graphic on the product 

label will be based on the EPA Repellency Awareness Guidance for Skin-Applied Insect 

Repellent Products, which states, “The mosquito claim should be calculated using the most 

conservative (i.e., lowest) CPT from all available studies (In this study - Florida compared to 

Wisconsin).” And “The number of hours of protection appearing on the repellency awareness 

graphic should be expressed as a whole number. If the most conservative calculated CPT is not a 

whole number, EPA recommends rounding down to the nearest whole number.” (§4.1, p. 8 of 

154).

Test substance application rate and treatment: The target application rate was 1.0 g per 600 

cm2 + 10%. Formula 1 (below) was used to calculate the amount of the test substance to apply to 

each subject. Prior to applying the test substance, each subject washed the limb to be treated 

with water and unscented soap, dried the limb, and then wiped the limb in a 70% solution of 

isopropanol and allowed the limb to dry. After drying, the area to be treated was marked with a 

felt-tipped pen. Adhesive surgical tape and adhesive bandage were wrapped around the area to 

be treated so the area to be treated was the only exposed skin. The test substance was placed on 

the balance and the balance tared. The test substance was applied directly from the aerosol can 

onto the skin. After spraying, the sample was returned to the balance and the amount sprayed 

onto the skin was determined. If the amount sprayed was below the target weight, more was 

sprayed onto the forearm and the can weighed again (§14.6, p.24 of 154). The target amount and 

the amount applied to each subject is found in Table 8 (p. 25 of 154). The mean amount applied 

was the target amount (100% of target) with a range of 94-111% of the target amount. Subject 

ID #51 had 11% more than the target amount applied but a protocol deviation was not 

reported.

Formula 1. Weight of test substance to apply (g) = [Area of limb cm2/600 cm2] * 1.0 g

Table 8. Amount of Test Substance Applied.
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Site

Test 

Subject

No. Date

Limb 

Treated

Target

Amount 1

(g)

Actual

Amount

(g)

% of

Target

Wisconsin 49 8/3/15 Right Arm 0.85 0.85 100

Wisconsin 50 8/3/15 Right Arm 0.79 0.85 108

Wisconsin 51 8/3/15 Left Arm 0.94 1.04 111

Wisconsin 52 8/3/15 Right Arm 0.92 0.91 99

Wisconsin 53 8/3/15 Left Arm 0.79 0.78 99

Wisconsin 62 8/3/15 Right Arm 0.92 0.89 97

Wisconsin 63 8/3/15 Left Arm 0.96 0.93 97

Wisconsin 66 8/3/15 Right Arm 1.00 0.98 98

Wisconsin 68 8/3/15 Right Arm 0.97 0.96 99

Wisconsin 69 8/3/15 Left Arm 0.96 1.03 107

Florida 149 8/18/15 Left Arm 0.65 0.67 103

Florida 151 8/18/15 Left Arm 0.76 0.76 100

Florida 152 8/18/15 Right Arm 0.77 0.79 103

Florida 156 8/18/15 Right Arm 0.72 0.68 94

Florida 158 8/18/15 Right Arm 0.97 0.99 102

Florida 162 8/18/15 Right Arm 1.10 1.06 96

Florida 172 8/19/15 Right Arm 0.60 0.58 97

Florida 174 8/19/15 Right Arm 0.75 0.78 104

Florida 179 8/19/15 Left Arm 0.68 0.64 94

Florida 182 8/19/15 Right Arm 0.99 0.94 95

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Target amount was based upon forearm surface area calculation (Formula 1).

 

Protocol amendments and deviations: The approved protocol was dated June 26, 2015. There 

were no amendments to the protocol (Appendix A, pp. 32-33 and 100-101 of 154) but seven

protocol deviations occurred during the study (Appendix B, p. 112 -119 of 154). The deviations 

did not have a negative impact on the study.

Results and analyses:

Test systems: Test subjects collected mosquitoes representing six genera (Aedes, Anopheles, 

Coquillettidia, Culex, Mansonia, and Psorophora) in this study across both field sites. Three 

genera including four species were present on the day of testing in Wisconsin while five genera 

including nine species were collected in Florida for a total of six genera and 12 species across the 

two sites. Aedes spp. mosquitoes, a mosquito genus containing numerous important vectors of 

human diseases, represented 81% of the mosquitoes collected in Wisconsin with Coquillettidia 

peturbans, a vector of Eastern Equine Encephalomyelitis, accounting for almost the entire 

remainder of the collection. Aedes spp. disease vectors were collected in Florida (Tables 3 and 4; 

§10.1, p. 11 of 154). 
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Landing frequency and duration of repellency: At both the Florida and Wisconsin sites at 

least 5 mosquitoes landed on the untreated control in all of the five-minute exposure periods. At 

the Wisconsin site, the time to count five mosquito landings on control subjects ranged from 12 

to 146 seconds with only 6 of 17 exposure periods having untreated controls exceeding 60 

seconds. At the Florida site, the time to count five mosquito landings on control subjects ranged 

from 7- 215 seconds on August 18 with untreated control subjects in 6 of 17 exposure periods 

exceeding 60 seconds (Table 11, p. 28 of 154). A rain event occurred at the Florida site causing 

exposure period 4 to be skipped (Protocol Deviation #5, p. 117 of 154) on August 18, 2015. The 

protocol did not address how to determine repellent failure in the event of a rain delay but no 

subject received a landing in exposure period 4 or 6. On August 19, 2015 at the Florida site 14 of 

the 15 untreated control exposure periods reached 5 landings in less than one minute. 

The repellent failed on all subjects except: Subject ID #66 at the Wisconsin site due to the study 

director’s decision to stop testing at 9.5 hours post-treatment; Subject ID #162 at the Florida site 

on August 18 because the study director stopped testing at 10 hours post-treatment; and Subject 

ID #158, who withdrew from the study on August 19, 2015 in Florida after the end of exposure 

period 14 (8.5 hours after treatment without any landings) [§13.6.4, pp. 22 of 154; Tables 12 and 

13, pp. 29-30 of 154].

Median Complete Protection Times. Median complete protection times with 95% confidence 

limits [Lower Confidence Limit (LCL) and Upper Confidence Limit (UCL)] were calculated by 

Kaplan Meier analysis using PROC LIFETEST in SAS, which employs a generalization of the 

Brookmeyer and Crowley (1982) method under a log-log transformation. The median duration of 

repellency (CPT) for the test substance (Mark-2) was 7.5 hours in Wisconsin and 8.5 hours in 

Florida (Tables 1 and 2, pp. 8-9 of 154). However, the Florida site study was conducted over 

two days with 5 subjects each plus one untreated control. There was no discussion in the study 

on whether or not this affected the study outcome and data analysis. 

Table 1. MARK-2 (30% DEET aerosol) Repellency Duration Results Summary, Hours, Sample 

size = 10 per site (p. 8 of 154).

Measure Wisconsin

Site

Florida

Site

Median 7.5 8.5

95% LCL 4.0 4.5

95% UCL 8.0 10

Range 4.0 to 9.5 4.5 - 10

Table 2. MARK-2 (30% DEET aerosol) Repellency Duration Results, Hours (p. 9 of 154)

Wisconsin

Site

Florida

Site

Subject

No.

Repellency

Duration

Subject

No.

Repellency

Duration

49 4.0 149 6.5
8

50 7.0 151 8.5

51 7.5 152 10.0

52 6.0 156 8.5

53 8.0 158 8.51

62 7.5 162 10.0

63 7.5 172 5.5

66 9.5 174 8.5

68 7.5 179 4.5

69 8.0 182 9.0

 1 Subject withdrew from study at 8.5 hrs. post-treatment.

Conclusions:

The methods used in this study were adequate to produce scientifically reliable results. The 

methods were based on the protocol reviewed and accepted by the EPA and HSRB on April 23, 

2015 as amended to address EPA and HSRB recommendations before testing began. The data 

in the study are acceptable to support a median CPT of 7.0 hours against mosquitoes for the 

EPA Repellency Awareness Graphic on the label of EPA Reg. No. 4822-397, Mark-2 OFF! 

Deep Woods Sportsmen Insect Repellent II (Unscented Deep Woods Off! Insect Repellent) 

(30% DEET). 

Note: One subject (Subject ID # 51) received 11% of the target dose but no protocol deviation 

was reported.

HSRB Comments and Science Recommendations from the April 2015 Meeting Report 

Dated June 23, 2015:

Product application rate:

The Board understands that the data from this protocol will be used to calculate median CPT 

values across all subjects from each of two sites rounded down to the nearest integer and the 

lowest value will be used for the product graphic. (p. 11 of 39, Sweeney and Sherman). Given

the stated use of the data, the Board agrees with the use of a standardized dose of 1 gram product 

per 600 cm2 treated skin. However, we strongly suggest changing the language from 

standardized dose to standardized application rate and reserve “dose” to describe how much 

active ingredient is applied. 

The protocol specifies that the actual amount of product applied will be recorded. The percent 

active ingredient in each product is also available so the Agency can in fact assess the 

relationship between dose (active ingredient) and efficacy (or CPT) as a quality assurance check 

of the data. An assessment of the relationship between CPT and dose (mass active ingredient per 

treated area) can provide an indication of the quality of the data or point out data that might be 

suspect because it does not fall along the expected dose-response trend. The Board recommends 

that the data analysis include a dose-response comparison for all products where multiple 

concentrations are available (e.g., DEET content in the different products ranges from 5% to 

98.25%) to help assess data quality. In addition, the Agency might consider normalizing the CPT 

results to better represent the expected application rates derived from earlier dosimetry studies 

when calculating the final graphic number.
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S.C. Johnson Response: The word “dose” was changed to “application rate” throughout. A 

dose-response comparison was not included in the data analysis because each study only tested a 

single product. 

Product application method: 

The protocol proposes to use a variety of application methods including using pipettes for 

transferring liquid contents from pump sprays and spatulas for lotions, while aerosol sprays are 

applied directly. In each case, the product is applied and spread on the subject’s skin by a staff 

member. The Board was concerned that these application methods were not representative of 

actual application methods but ultimately concluded that the need for consistency outweighs the 

need for the protocol to be representative of consumer behavior. However, the Board stresses the 

importance of accurately reporting the application rate (mass of product per area of skin) for 

each subject. 

A particular concern with the aerosol application method was that the iterative procedure leaves 

open the possibility to repeatedly apply more than the target 1 gram. Some means should be 

integrated within the protocol to limit or preclude the potential to bias the average dose upward. 

One (and perhaps not the best) way to preclude such a bias would be to place some upper bound 

on the highest level above 1 gram that would be allowed to proceed to the field testing phase. 

Such an upper bound (or similar restriction) could be applied to all application methods, but 

over-exposures seem most likely to occur with the aerosol application method.

S.C. Johnson Response: The test substance (aerosol formulation) was applied as directed by the 

revised protocol (study Section 14.6, p. 24 of 154) and results reported in Table 8 (p. 25 of 154). 

The mean amount applied was equal to the target amount with a range of 94-111% of the target 

amount applied. 

Use of sites outside the U.S.:

The protocol specifies the use of two established and ecologically distinct field sites in the 

United States for testing, and the Board agrees that this will provide sufficient representation for 

determining CPT, but the Board shares the concerns expressed by the Agency about using sites 

located outside of the U.S. The study sponsor has described that in addition to the two 

established sites in the U.S., there is at least one established site in Australia that could be used. 

The protocol needs to provide more information on what constitutes an “established site” either 

in the U.S. or another country (i.e., climate, mosquito species present, other hazards such as other 

mosquito borne diseases, presence of cell phone service, representativeness of local 

demographics) and more importantly should describe how the data collected at the alternate sites 

outside the U.S. will be related to the U.S. consumer demographics and the expected mosquito 

populations in the U.S.

S.C. Johnson Response: The protocol only states that sites will be qualified by confirming 

mosquito populations are adequate to achieve the minimum landing pressure (5 mosquitoes on 

an untreated control in five minutes) required to evaluate efficacy. In addition, the protocol was 
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revised to include the requested information (e.g., mosquito species present, climate, etc.) for the 

proposed site in Australia. However, testing was not conducted outside of the U.S., so this 

information is not relevant to the submitted study. 

Potential for cross contamination:

There are a number of places in the protocol that provide opportunities for insecticide to be 

inadvertently either lost or gained from/to the treated area on subjects. Simple precautions can be 

taken to alleviate this issue, but the protocol should specify steps that will be taken to insure that 

the treated area on subjects is not impacted by activities that take place before or during the 

experiment (i.e., rubbing sleeve or pant leg across the treated area).

S.C. Johnson Response: Subjects were not transported using a vehicle after the test substance 

was applied, and subjects were reminded not to touch or contact the treated skin in any manner. 

Any inadvertent contact with the treated area was reported to the study staff and documented in 

the raw data.

Potential for “carryover”:

No justification was provided for the adequacy of separating multiple participations by any test 

subject by a minimum of one day (Science Response #6 in S.C. Johnson letter of 17 April 2015). 

It is important to verify that no carryover effect is present on subjects used on multiple days. The 

protocol suggests that a day between treatments will be sufficient when the same subject is used 

a second time, but justification or references are needed to support this. If a subject is treated 

with 98.25% DEET, is there any residual effect after 24 hours that might affect a low dose 

treatment (application of 5.6% DEET wipe)?

S. C. Johnson Response: Subjects washed before and after each test, and a minimum of two 

days was required to pass before subjects could participate in another test. There is no indication 

that test subjects participated in multiple tests except as described in Protocol Deviation #3 

where an untreated control subject on August 18, 2015 was asked to participate as an alternate on 

August 19, 2015. Since the subject had been an untreated control, the deviation was justified 

because an alternate was needed on August 19, 2015 and participation of an untreated control 

subject from the previous day eliminated any possibility of a carry-over effect. 

Landing pressure:

The protocol includes untreated control subjects with each test to insure that there is sufficient 

landing pressure to provide valid results. However, the landing pressure is not measured in 

quantitative terms, only whether it is sufficient or not (five landings in five minutes). Discussions 

during the meeting seemed to imply that landing pressure will influence the measured CPT. If in 

fact the landing pressure can influence the resulting median CPT and products tested on different 

days are subjected to different landing pressures, then it would be important to collect 

quantitative information on landing pressure that could be used to correct, normalize, or at least 

interpret the resulting CPT values. The Board recommends that the Agency and S.C. Johnson 

consider how a quantitative estimate of landing pressure can be determined without increasing 
11

the likelihood of bites if landing pressure is excessive (e.g., recording the time of each landing, 

the time to reach 5 landings, or the total landings in 5 minutes) and how that information can be 

used to normalize or interpret CPTs measured under different landing pressure conditions.

S. C. Johnson Response: Study staff recorded the time to reach five landings if they occurred in 

less than five minutes and these results were reported in the study (Table 11, p. 28 of 154). 

Because all studies were performed at the same two sites, landing pressure appeared to be fairly 

consistent across sites, therefore normalization was not required.

Delayed start:

The Board recognizes the advantages of delaying the exposure to mosquitoes for subjects treated 

with products that are known from previous experience to last for a long time. However, the 

protocol needs to provide more information about the criteria used to determine how long to wait 

before starting the test cycles (5 minute exposure at 30 minute intervals). Regardless of how long 

the subject’s exposure is delayed, the protocol should require a minimum number of completed 

cycles to insure valid results. For example, following a delayed exposure, the subject should 

complete at least three exposure cycles before getting a confirmed landing.

S. C. Johnson Response: Exposures were delayed until two hours after application (Protocol 

Deviation #6). The test substance contained 30% DEET as the active ingredient, and according 

to the protocol, exposures were to be delayed by three hours for products containing more than 

16% DEET. There was no negative impact on the study by having two additional exposure 

periods to the beginning of the study. Subjects completed at least three exposure cycles before 

getting a confirmed landing.

Experimental design:

The design as presented tests all ten subjects assigned to a product on a single day. The downside 

of this design is that it does not allow results to be easily generalized to a range of environmental 

conditions that may affect the attractiveness of a subject (e.g., sweating due to temperature and 

humidity levels). An alternative would be to test each product on several days; e.g., five subjects 

on each of two days or three subjects on each of two days and the remaining four subjects on a 

third day. Each day would form a block for the analysis of that product’s data. Such a design 

would allow testing of multiple products on a given day. If it were of interest to compare product 

formulations and/or application methods, the combined data could be analyzed as a block design 

with multiple replications of each product within each block (day). 

These alternative designs that utilize blocking (e.g., by individual test subject) could be 

considered to account for known sources of variation (e.g., individual effects).

S. C. Johnson Response: The two different sites in different areas of the country should allow 

for greater generalization of results to a range of environmental conditions than a single site. 

Also, the main goal of the study is to determine the CPT for an individual product, not to 

compare multiple products. That being stated, this study was conducted in one day with 10 

subjects at the Wisconsin site and on two consecutive days with 5 subjects each at the Florida 
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site. However, this approach was not planned Protocol Deviations #2, #3 and #4 report why this 

took place and corrective actions taken (pp. 115-116 of 154). The data were not analyzed 

differently. 

Randomization:

The randomization mechanism should be described in more detail and rationale should be given 

for any given choice of randomization within the protocol. For example, it is not clear 

whether/how cross-substance relations are to be evaluated in the data analysis and why 

randomization among test substances is needed. An explanation of this would be helpful. In 

addition, when the conditions support use of arm rather than leg for exposure, then it may be 

more important to consider handedness when selecting what arm to treat, rather than randomly 

assigning to left or right hand, so the subject can have their dominant hand to remove landing 

mosquitoes before they bite. 

S.C. Johnson Response: One test substance was tested on each day, therefore randomizing the 

treatment was not necessary. The mechanism for randomizing the arm was not provided in the 

study; however, after discussions with S.C. Johnson, they indicated that the mechanism for 

randomizing the arm to be treated was based on the random selection of test ID numbers. 

Subjects assigned odd numbers had their left arm treated, and subjects with even numbers had 

their right arms treated. This was true for all treated test subjects except for one treated subject 

(Subject ID #49) who drew an odd number but had her right arm treated. This was due to a prior 

injury to her left arm. In addition, the protocol notes that aspirating mosquitoes is not difficult 

even with a non-dominant hand. The untreated control subjects were allowed to choose which 

arm to expose.

Sample size determination:

A sample size calculation would be useful here to inform the power of testing and the width of 

confidence intervals. Power and sample size calculation can be implemented using existing SAS 

procedures. Information about appropriate sample size calculations is included in the EPA 

document “Product Performance Test Guidelines OPPTS810.3700: Insect Repellents to be 

Applied to Human Skin.” 

S. C. Johnson Response: After discussions with S.C. Johnson, they indicated that they did not 

conduct a sample size calculation or power analysis but the table regarding sample size presented 

in the protocol for testing repellents against ticks to the Human Studies Review Board at the 

October meeting would apply to these studies.

Sources of variation:

Multiple sources of variation including, for example, site selection, treatment dosage, application 

rate, mosquito type/age/condition, and landing pressure can impact the results. For the most part, 

however, they are not accounted for explicitly within the study, and when the source of variation 

is not controlled (e.g. as it is using a standard application rate) then the contribution to variance 

should be acknowledged or discussed. The protocol does not currently specify the conditions that 

might cause the CPT data from the two sites to differ; however, the researchers should consider 

collecting information to explain any large and potentially significant differences in the CPT 

values between otherwise matched studies conducted at two different sites.
13

S. C. Johnson Response: The researchers identified mosquitoes to species, recorded habitat 

characteristics, climatic conditions, and the time to five landings on the untreated control

subjects, information which could explain large and significant differences in CPT. Note the 

CPTs at both sites were similar.

EPA Comments and Science Recommendations from the April 2015 Meeting Review 

Dated March 31, 2015:

EPA Comment: Change “mosquito biting pressure” to “mosquito landing rate” as subject bites are 

not counted or recorded in this study. 

S. C. Johnson Response: The term “mosquito biting pressure” was changed to “mosquito landing 

rate” throughout the protocol.

EPA Comment: Describe how the data will be analyzed if the number of test subjects at the end of 

the test is less than ten. In other words, what if subjects withdraw? If alternates replace them, how 

will Johnson account for this change of subjects in the data analysis? 

S. C. Johnson Response: One of the treated subjects (Subject ID # 158) withdrew from the study at 

the Florida site on August 19, 2015 after completing 14 exposure periods (8.5 hours) without a 

landing. There was one subject left after this exposure period that had a FCL at 9.0 hrs. The data 

from Subject ID #158 was included the analysis with a reported CPT of 8.5 hrs. (Table 2, p. 9 of 

154). 

EPA Comment: The protocol states that up to 10% of the exposure periods in a test may have less 

than the minimum landing (biting in the protocol) pressure of five mosquitoes landing in five minutes 

or less. Will treatment exposures occur during periods of insufficient landing pressure? If treatment 

data are collected during these periods, how will they be used in CPT calculation? If they are not 

used, how will the lack of data points be considered in the K-M analysis and calculation of Median 

CPT? 

S.C. Johnson Response: Landing pressure at both locations reached the minimum biting 

pressure for all exposure periods therefore this comment does not apply to this study. 

EPA Comment: State/justify why no positive control substance is to be used. 

S. C. Johnson Response: A positive control was not used because the Agency did not provide 

information on how positive control data would be used to normalize the data across sites. 

Therefore exposing additional subjects to repellent products and mosquitoes was not justified.

EPA Comment: Product application is not fully described. After weighing the set dose, how is 

the product applied to the limb for pump sprays and lotions? For instance, is the required amount 

left in the container and the pump used to spray it on the limb? For lotions, the amount to be 
14

applied is removed with a spatula instead of a larger syringe so transfer to the subject might be 

easier? For aerosols, Johnson could estimate the delivery of the prescribed amount of product by 

counting the number seconds needed to deliver the dose to the limb and determine the amount 

applied per second of spraying to more closely estimate the application amount? How does this 

compare to the product’s label directions? Will study staff be spreading the lotion with a gloved 

hand? 

S. C. Johnson Response: The exact method of determining the amount applied to each subject 

in this study is described in §14.6 (p. 24 of 154).

EPA Comment: Appendix III – Land Data Form. Identification of which limb was treated needs 

to be added to this data sheet. 

S. C. Johnson Response: A line was added to the data form to identify the treated limb.

EPA Comment: Data compilation and processing. Little detail is provided in the protocol on 

how the data from these sheets will be compiled and processed before entry into Excel, JMP, or 

SAS, etc. 

S.C. Johnson Response: Median complete protection time and 95% confidence limits were 

calculated by Kaplan Meier analysis using PROC LIFETEST in SAS, which employs a 

generalization of the Brookmeyer and Crowley (1982) method under a log-log transformation.