0532 ss part B 12-7-06

Supporting Statement for

Experimental Study of Possible Footnotes and Cueing Schemes to Help Consumers Interpret Quantitative Trans Fat Disclosure on the Nutrition Facts Panel

OMB No. 0910-0532

Part B COLLECTION OF INFORMATION USING STATISTICAL METHODS

1. Universe and Sampling

The study uses an Internet panel methodology which has proved substantially equivalent to mall intercept methodologies in that it allows visual presentation of study materials, experimental manipulation of study materials, and the random assignment of subjects to condition. The study will be implemented using a convenience sample drawn from a large national consumer panel with nearly one million households. The consumer Internet panel includes consumers who span the full range of education, age, race and income characteristics in the population.

Participants will be adults, aged 18 and older, who agree to participate in a study about foods and food labels. Each participant will be randomly assigned to one of the 54 experimental conditions.

2. Procedures for Collecting Information

Participants will view two-dimensional mock-ups that show the back panels of food packages, with the major part of the display constituted by the NFP. For each product category, participants will see a side by side presentation of the back panels of two products and answer questions about their choice preference, the selected product’s perceived health benefits, how the selected product compares to the typical product in its category, and background questions regarding label use, dieting, and standard demographics (sex, age, education). (See Attachment F: Draft Questionnaire.)

The key measures for the study are expressed choices between two products described by their NFPs. The pair of panels presented to a participant embody one of the seven footnote/cueing schemes or NFP format options to be tested. Respondents are asked to pick the healthier product, report the reasons for their choice, and rate the selected product with respect to perceived nutrition characteristics and expected health effects.

Key Product Perception Questions

(1). Based on what you see on the labels, which product (A or B) would you choose as being healthier to eat yourself or to serve to your family?

(2). How would you rate this product compared to the typical product in the

[donut/margarine/frozen lasagna] category?

Will be asked with respect to amount of fat, sodium, cholesterol, saturated

fat and trans fat.

(3) How likely is it that eating this product as a regular part of your diet would raise your risk of [disease/health condition]? 7-point rating scale from 1 (“Very Likely” l) to 7 (“Very Unlikely”)

Will be asked for four health conditions (heart disease, high blood cholesterol, overweight and high blood pressure).

(4). Do you consider this product to be high, medium or low in… [list of

nutrients-calories, total fat, saturated fat, trans fat, cholesterol, sodium,

carbohydrates]?

Half the participants will be randomly assigned to the Full Information condition. In the Full Information condition, participants will read a one-page summary of the current state of scientific evidence for the health effects of trans fat in the diet. Nutrition scientists at FDA will review the summary for accuracy. The Full Information summary will be presented prior to viewing any labels.

3. Methods to Increase or Maximize Response Rates

Participants are sent multiple reminders asking them to complete the interview instrument. Because participants are practiced at accessing and completing such instruments, no additional measures are necessary.

4. Tests of Procedures or Methods

The contractor will conduct three waves of Internet pretests. The first wave will include up to 15 participants. Any procedural problems identified in the first wave will be addressed and the revised procedures tested on a second wave of up to 15 participants. If additional modifications are needed, the revised procedures will be tested on up to 10 participants. Prior experience shows that this number of pretests will be sufficient to identify and correct any procedural problems in the study.

5. Identification of Consultation

The contact individuals are Alan S. Levy, Ph.D., Consumer Studies Staff, Office of Regulations and Policy, HFS-727, telephone (301) 436-1762 (Project Officer), and Brenda M. Derby, Ph.D., Consumer Studies Staff, Office of Regulations and Policy, HFS-727, telephone (301) 436-1832 (Statistician), and W. Burleigh Seaver, Ph.D., Senior Vice President, Synovate/Market Facts, (703) 790-9099.

REFERENCES

Center for Science in the Public Interest (2002) Comment to Docket No. 94P-0036 (C2285). Received December 16, 2002.

ConAgra Food (2003). Comment to Docket No. 94P-0036 (C2297). Received January 16, 2003.

IOM/NAS, Dietary Reference Intakes for Energy, Carbohydrate, Fiber, Fat, Fatty Acids, Cholesterol, Protein and Amino Acids,' National Academy Press, Washington, DC, pp. S1-S17, 8-1 to 8-97, and 11-1 to 11-48, 2002 (Internet address: http://www.nap.edu/books/0309085373/html/

International Food Information Council (2003). Impact of Trans Fat Label

Information on Consumer Food Choices: Summary Findings. 6/10/2003. (www.ific.org/research/transres.cfm) (Also submitted as a comment to Docket No. 94P-0036).

Kozup, J., Burton, S., & Creyer, E.H. (2006). The Provision of Trans Fat Information and Its Interaction with Consumer Knowledge. Journal of Consumer Affairs, 40 (1), 163-176.

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