SupportingStatement_A_WarningLabelSurvey

Consumer Product Safety Commission: Warning Label Comprehension and Interpretation
by Consumers for Children’s Sleep Environments
November 17, 2020

Supporting Statement Part A

Program Official/Project Officer
Celestine T. Kish, M.A.,
Sr. Engineering Psychologist
Division of Human Factors
U.S. Consumer Product Safety Commission
Phone: 301-987-2547
Email: [email protected]

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Information Collection for Copy Testing Survey

Supporting Statement A .................................................................................................................. 5
A1. Circumstances Making the Collection of Information Necessary ........................................... 5
A2. Purpose and Use of Information Collections ........................................................................... 6
A3. Use of Improved Information Technology and Burden Reduction ......................................... 7
A4. Efforts to Identify Duplication and Use of Similar Information.............................................. 7
A5. Impact on Small Businesses or Other Small Entities............................................................... 7
A6. Consequences of Collecting the Information Less Frequently ................................................ 7
A7. Special Circumstances Relating to the Guidelines of 5 CFR § 1320.5.................................... 7
A8. Comments in Response to the Federal Register Notice and Efforts to Consult Outside the
Agency ............................................................................................................................................ 7
A9. Explanation of Any Payment or Gift to Respondents .............................................................. 8
A10. Protection of the Privacy and Confidentiality of Information Provided by Respondents ..... 9
A11. Institutional Review Board (IRB) and Justification for Sensitive Questions ........................ 9
A12. Estimates of Annualized Burden Hours and Costs ................................................................ 9
A13. Estimates of Other Total Annual Cost Burden to Respondents or Record Keepers ............ 10
A14. Annualized Cost to the Government .................................................................................... 10
A15. Explanation for Program Changes or Adjustments.............................................................. 10
A16. Plans for Tabulation and Publication and Project Time Schedule ....................................... 10
A17. Reason(s) Display of OMB Expiration Date Is Inappropriate ............................................. 11
A18. Exceptions to Certification for Paperwork Reduction Act Submissions ............................. 11

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LIST OF ATTACHMENTS
Attachment 1: Survey Screener
Attachment 2: Informed Consent Form
Attachment 3: Survey Questionnaire
Attachment 4: Survey Stimuli

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Information Collection for Copy Testing Survey

Goal of the study: This study is aimed at helping CPSC staff to provide evidence-based and
audience-centered warning label recommendations to increase overall caregiver adherence to infant
product warning labels.
Intended use: Findings from this information collection will provide CPSC strategies and best
practice approaches for delivering warnings to infant caregivers. Ultimately, CPSC staff will use the
findings to help refine and enhance warning label recommendations to effectively convey critical
information about product warnings in the future. The ultimate goal of this research is to identify
ways to increase caregiver understanding and adherence to infant product warning labels, which, in
turn will potentially reduce the incidence of infant sleep-related deaths in the future.
Methods to be used: We plan to conduct a copy test survey to test and assess infant product warning
label language across parents and grandparents of children ages 2 months–11 months. A total of 650
participants will take the survey.
The subpopulation to be studied: The study population for this effort will be made up of individuals
ages 18 and over. Eligibility criteria (which can be found in the screener in Attachment 1) is as
follows: all individuals will be a parent or grandparent with a child/grandchild between 2 months-11
months old. To be an eligible grandparent, the grandchild must visit the grandparent at least once a
week and be under the grandparent’s supervision. Lastly, the individuals must not have worked for or
in childcare (e.g., daycare employee, nanny), children’s product manufacturing, market research,
marketing, or health care company as a medical professional at any organization in the past 5 years.
How the data will be analyzed: Survey data will be used to conduct A/B comparisons of warning
label copy, meaning two variations of the same product will be tested. Quantitative analyses will
include t-tests between each label to assess the results of the A/B comparisons to eventually provide
strategies and best practice approaches for delivering warnings.

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Supporting Statement A
A1. Circumstances Making the Collection of Information Necessary
The Consumer Product Safety Commission (CPSC) requests Office of Management and
Budget (OMB) approval of a quantitative survey project to test and assess warning label
language.
The CPSC is charged with protecting the public against dangers associated with consumer
products. To target specific threats and put forth programs that would mitigate the risk of
dangers related to products, CPSC conducts research to develop communication
recommendations to influence positive behavior change. The 2019 Nursery Product Annual
Report reported 320 deaths related to nursery products from 2014-2016. Infant sleep products
were associated with the most deaths: cribs/mattresses (33%), cradles/bassinets (18%), and
playpens/play yards (20%). As such, CPSC staff concludes that it is critical that consumers
understand the warning labels on infant sleep products, as well as hazards associated with
infant sleeping environments, to reduce the incidence of infant sleep-related deaths in the
future.
CPSC staff seeks a better understanding of consumers’ comprehension of specific warning
labels for products that may be used as a sleeping environment for infants and how those
labels influence caregivers’ behavior. Past research conducted by Fors Marsh Group, LLC
(FMG), for CPSC highlights caregivers’ lack of adherence to infant sleep safety messaging. 1
Caregivers perceive warning labels as containing repetitive, non-specific information that is
often used by manufacturing companies as a tactic to protect themselves from liability.
Additionally, caregivers are inundated with constantly changing safety messaging, resulting
in ambiguity about what messages are most relevant and current. Caregivers often end up
listening to friends and family, or relying on past experience, to decide what behaviors are
safe for their child, rather than following the current guidelines recommended by experts.
Product marketing and new products pose a risk for consumers as well. If caregivers are not
attuned to the safety messaging on new products, they are more likely to use the products
incorrectly. CPSC staff is aware that the purpose of safety warning labels and safety
messaging is not clear to the target audience and is becoming a barrier to safe sleep for
infants.
As such, CPSC staff seeks further research to understand the gap in consumer knowledge
about product warning labels and consumer adherence to, and behaviors associated with,
Caregiver Perceptions and Reactions to Safety Messaging Focus Groups.”
Uploaded to ROCIS on: 3/20/2019.
CR Reference #: 201707-3041-003.
1

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warning labels. Ultimately, CPSC staff may use the study findings to refine and enhance
warning labels to help effectively convey critical information about product warnings in the
future. Additionally, this work will serve to advance CPSC’s overall mission of protecting
the public against dangers associated with consumer products.
A2. Purpose and Use of Information Collections
Information obtained through this project is not intended to be nationally representative and
will not be directly tied to any policy decisions regarding warning labels. Rather, information
from this project will inform CPSC about caregiver perceptions and comprehension of
warning label language. CPSC staff may use findings from this effort in conjunction with
findings from other phases of this research to assist with providing recommendations for
refining and enhancing warning labels in the future. Specifically, survey respondents will
answer questions related to various types of warning labels to assist CPSC staff to better
understand message comprehension, consumers’ motivation to follow instructions, and
overall effectiveness of the warning label in conveying hazard information.
CPSC contracted with FMG to develop and execute this project. The project will consist of
an online survey with caregivers age 18 and above. Eligibility criteria (which can be found in
the screener attachment as well) are as follows: all individuals will be a parent or grandparent
with a child/grandchild between 2-11 months old, because CPSC staff is interested in
assessing labels on products that are intended for this age range. To be an eligible
grandparent, the grandchild must visit the grandparent at least once a week and be under the
grandparent’s supervision. Lastly, the individuals must not have worked for or in childcare
(e.g., daycare employee, nanny), children’s product manufacturing, market research,
marketing, or health care company as a medical professional at any organization in the past 5
years.
Survey
All respondents will be invited to join the study through a partnering panel provider,
Prodege. Prodege will contact members from their panel who fit the eligibility criteria for the
survey through an email inviting them to take part in the survey. Invitees will receive
reminder emails encouraging them to take the survey. The number and frequency of reminder
emails depends on survey fielding progress; but typically, respondents will receive a
reminder email about once a week. Potential respondents invited to take the survey will
complete the online screening questionnaire first, which will take approximately 2 minutes to
complete. After completing the screening questionnaire, respondents who qualify for the
study will be directed to an informed consent page, and then to the main questionnaire.

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A3. Use of Improved Information Technology and Burden Reduction
Prodege will recruit for the survey and conduct the survey online.
A4. Efforts to Identify Duplication and Use of Similar Information
To our knowledge, CPSC has never conducted a comprehensive study to gather data on
knowledge and awareness regarding the specific hazards of interest (i.e., not adhering to
infant sleep product warning labels and testing warning label language) in this collection.
A5. Impact on Small Businesses or Other Small Entities
Respondents in this project will be members of the general public and not business entities.
CPSC staff does not anticipate any impact on small businesses or other small entities.
A6. Consequences of Collecting the Information Less Frequently
This effort is a one-time data collection. Without the information collection requested for this
project, CPSC staff could face difficulties in developing effective strategies and best practice
approaches for delivering warnings to caregivers of infants. Failure to collect this
information could prevent CPSC staff from making effective changes to warning labels in the
future, which in turn could decrease adherence to warnings. CPSC staff has given careful
consideration to the project design to effectively balance the information collection
objectives with participant burden.
A7. Special Circumstances Relating to the Guidelines of 5 CFR § 1320.5
This request fully complies with Title 5 of the Code of Federal Regulations (5 CFR) section
1320.5.
A8. Comments in Response to the Federal Register Notice and Efforts to Consult Outside
the Agency
A. CPSC staff consulted the following individuals outside of the agency on project design
and material development:
Any public comments received will be addressed prior to final OMB submission.
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•

Panne Burke, Senior Researcher, Fors Marsh Group
901 N Glebe Rd Ste 1010
Arlington, VA 22203
571-303-2898
[email protected]

•

Lauren Angel, Researcher, Fors Marsh Group
901 N Glebe Rd Ste 1010
Arlington, VA 22203
571-444-1140
[email protected]

•

Elizabeth Simoneau, Researcher, Fors Marsh Group
901 N Glebe Rd Ste 1010
Arlington, VA 22203
571-444-1130
[email protected]

No major unresolved problems stem from this consultation.
A9. Explanation of Any Payment or Gift to Respondents
For the survey, respondents will receive proprietary internal currency through the panel
provider. Swagbucks are virtual currency that can be redeemed to purchase gift cards.
Swagbucks have a 100 to 1 redemption value. For example, 50 Swagbucks are equivalent to
$0.50. For the purposes of this study, participants will earn Swagbucks equivalent to about
$1 for completing the survey.
As participants often have competing demands for their time, incentives are used to
encourage participation. The use of incentives treats participants justly and respectfully by
recognizing and acknowledging the effort they expend to participate. When applied in a
reasonable manner, incentives are not an unjust inducement and are an approach that
acknowledges respondents for their participation (Halpern, et al., 2004).
Incentives must be high enough to equalize the burden placed on respondents with respect to
their time and cost of participation (Russell et al., 2000), as well as provide enough
motivation for them to participate in the project. If the incentive is not adequate, participants
might agree to participate, and then not show up, or drop out early.

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Additionally, inadequate incentives can cause a difficult and lengthy recruitment process,
which, in turn, can delay launching the information collection. This can lead to increased
costs. Incentives are also necessary to ensure adequate representation among harder-torecruit populations, such as low socio-economic groups and high-risk populations (Groth,
2010).
A10. Protection of the Privacy and Confidentiality of Information Provided by
Respondents
FMG will collect all information for this project with an assurance that the respondents’
responses and data will remain private to the extent allowable by law. The consent form
contains a statement emphasizing that no one can link a participant’s identity to his/her
responses and that each participant can only be identified by a unique ID. FMG will encrypt
all data in transit. Finally, FMG will operate and maintain all equipment according to
industry standard practices, and validate all software using industry standard quality
assurance practices.
Independent contractors will not share personal information regarding participants with any
third party without the participant’s permission, unless it is required by law to protect their
rights, or to comply with judicial proceedings, a court order, or other legal process. All
project information received by the CPSC will remain in a secured area. No project
information will contain identifying information.
A11. Institutional Review Board (IRB) and Justification for Sensitive Questions
The survey does not include any questions considered especially sensitive in nature;
although, we will collect respondent's ethnicity, children’s ages, and annual household
income, to determine the potential for non-response bias.
A12. Estimates of Annualized Burden Hours and Costs
Table A12.1 estimates the time burden and costs to respondents. The online survey for the
proposed study will take approximately 15 minutes (0.25 hours) to complete, and it will
consist of 650 respondents.

Table A12.1. Estimated Annualized Burden Hours: Survey
Project Activity

Number of
Respondents

Frequency
of Response

Time
Burden of

Total
Hours

Respondent
Cost

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Copy Testing Survey

(A)
650

(B)
1

Response
(hours)
(C)
0.25

(D=AxC)
162.50

(Dx$36.22)
$5,885.75

A13. Estimates of Other Total Annual Cost Burden to Respondents or Record Keepers
Respondents bear no costs to participate, other than their time.
A14. Annualized Cost to the Government
The total cost of this collection to the federal government is $150,978. This represents 9
months of staff time annually. This amount includes federal employee salaries and benefits.
No travel costs are associated with the collection. This estimate uses an annual total
compensation of $137,491 (the equivalent of a GS-14 Step 5 employee, in the Washington
D.C. area), which represents 68.3 percent of the employer costs for employee compensation,
with the remaining 31.7 percent added for benefits (U.S. Bureau of Labor Statistics,
“Employer Costs for Employee Compensation,” March 2020, Table 2, percentage of wages
and salaries for all civilian management, professional, and related employees), for total
annual compensation per FTE of $201,305.
A15. Explanation for Program Changes or Adjustments
This is a new information collection.
A16. Plans for Tabulation and Publication and Project Time Schedule
FMG will develop a technical report summarizing the findings of the project after the survey
has fielded. CPSC staff will use the findings with findings from other phases of this research,
to assist CPSC staff with making recommendations on how to refine and enhance warning
labels.
CPSC requested OMB approval for 1 year. Table A16.1 outlines the project timeline.

Table A16.1. Project Timeline
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Item

Timeline

Survey Fielding

Within 1 month of OMB approval

Survey Analysis
Research Report

Within 2 months of completion of
survey fielding
Within 2 months of completion of
survey fielding

A17. Reason(s) Display of OMB Expiration Date is Inappropriate
The display of the OMB expiration date is not inappropriate.

A18. Exceptions to Certification for Paperwork Reduction Act Submissions
There are no exceptions to the certification.

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REFERENCES
Groth, SW. (2010). Honorarium or coercion: use of incentives for participants in clinical
research. Journal of the New York State Nurses Association.
Halpern, SD., Karlawish, JH., Casarett, D., Berlin, JA., Asch, DA. (2004). Empirical assessment
of whether moderate payments are undue or unjust inducements for participation in clinical
trials. Archives of Internal Medicine, 164(7), 80l–803.
Russell, ML., Moralejo, DG., Burgess, ED. (2000). Paying research subjects: Participants’
perspectives. Journal of Medical Ethics, 26(2), 126–130.

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