Supporting Statement A

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 which online safety warning
label is most effective.
CPSC is charged with protecting the public against hazards associated with consumer
products. To target specific threats, and advance programs that would mitigate the risk of
hazards related to products, CPSC conducts research to develop communication
recommendations to convey the hazard information. According to CPSC data, emergency
departments across the United States treated approximately 224,200 toy-related injuries in
2019, of which 35 percent were for cases involving children younger than 5 years of age
(Qin, 2020). Age-appropriate toy selection using safety-related information has the potential
to prevent some of these injuries (Argo & Main, 2004). Research suggests that caregivers
may not notice or seek out safety information, or rely on it when making purchasing
decisions when examining toy packages in person (Argo & Main, 2004). However, gaps in
the literature remain on how caregivers of young children interact with online safety-related
information when purchasing items via the Internet. As such, CPSC staff concludes that it is
critical that consumers understand the safety warning labels on children’s toys to reduce the
incidence of toy-related injuries among young children in the future.
CPSC staff seeks a better understanding about which warning labels are most effective.
Caregivers perceive warning labels as containing repetitive, non-specific information, and
often used as a tactic by manufacturing companies to protect themselves from liability.
Additionally, caregivers are inundated with safety messaging that changes constantly,
resulting in ambiguity about what messages are most relevant and current. Frequently,
caregivers listen to friends and family, or rely on past experience to decide what products are
safe for their child, rather than follow the guidelines recommended by experts. Additionally,
product marketing and new products pose a risk for consumers, as well. If caregivers are not
attuning to the safety messaging on new products, they are more likely to use the products
incorrectly.
Certain cautionary statements about choking hazards with small parts, balloons, small balls,
and marbles are required on product packaging. For websites that provide direct means for
purchasing shall also include the appropriate cautionary statement displayed on, or
immediately adjacent to that advertisement, in conspicuous and legible type, in contrast by
typography, layout, or color with other material printed or displayed in such advertisement.

CPSC staff seeks further understanding of the consumer response of online safety warning
labels. Ultimately, CPSC staff may use the findings to help refine and enhance online safety
warning labels to convey critical information effectively about product warnings in the
future. This work will serve to further 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 will not be tied directly to any policy decisions
regarding warning labels. Rather, information from this project will inform CPSC about
caregiver perceptions and comprehension of warning label language and placement. 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 online warning
labels in the future. Survey respondents will answer questions related to online toy
purchasing, and they will view safety warning labels which will inform CPSC staff about
consumer message comprehension, consumer motivation to follow instructions, and the
effectiveness of warning labels in conveying hazard information, and whether caregivers
notice these warning labels when purchasing toys for their child.
CPSC has contracted with FMG to develop and execute this project on behalf of CPSC. The
project will consist of an online survey with caregivers age 18 and above. Eligibility criteria
(which can be found in the screener attachment) specifies that: all individuals will be
caregivers (e.g., parent or guardian) of a 2-to-3-year-old child, because CPSC staff is
interested in assessing labels for products that are intended for this age range. CPSC is
interested in responses from primary caregivers only. To be an eligible caregiver, the
caregiver must be a parent or guardian of a 2-to-3-year-old child, and the child must reside in
the caregiver’s home at least 40 percent of the time.
Information obtained through this project is not intended to be nationally representative.
Survey
All respondents will be invited to join the study through a partnering panel provider,
Prodege. The panel provider will contact members from their panel who fit the eligibility
criteria for the survey through an invitation email that invites them to take part in the survey.
Invited individuals will be sent reminder emails to encourage them to take the survey. The
number and frequency of reminder emails is dependent upon survey fielding progress, but
typically, respondents will receive a reminder email about once a week. Potential respondents
invited to take the survey will first complete the online screening questionnaire, which will
take approximately 2-3 minutes to complete. After completing the screening questionnaire,

respondents who qualify for the study will be directed to an informed consent page. If they
choose to consent and participate, they will be directed to the main questionnaire.
A3. Use of Improved Information Technology and Burden Reduction
Prodege 1 will recruit for the survey and conduct the survey online.
Online consumer surveys are considered low-burden collections. Participation in the survey
is voluntary.
A4. Efforts to Identify Duplication and Use of Similar Information
To our knowledge, neither CPSC, nor any other agency or organization, has conducted a
comprehensive study to gather quantitative data on knowledge and awareness regarding the
specific hazards of interest (namely, understanding caregiver toy purchasing behavior and
determining whether caregivers notice and/or adhere to the safety warning label) in this data
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 product safety warnings to caregivers of 2-to-3-year-olds. Failure
to collect this information could prevent CPSC staff from making effective changes to online
warning labels in the future. CPSC staff has carefully considered the project design to
balance effectively the information collection objectives with participant burden.
A7. Special Circumstances Relating to the Guidelines of 5 CFR Section 1320.5
This request complies with Title 5 of the Code of Federal Regulations (5 CFR) section
1320.5.
1

https://www.prodege.com/.

A8. Consultation and Public Comments
Part A. Public Notice
A 60-Day Federal Register Notice (FRN) for the collection published on June 24, 2021. The 60Day FRN citation is 86 FR 33239.
CPSC received one comment in response to the June 24, 2021 notice. The commenter stated
support for the research; however, raised concern that the small sample size of 250 will not
provide enough information and stated that an increased sample size such as 500 would provide
more insights.
Commenter also suggested that efforts be made to get a diverse range of shoppers in the sample,
both in terms of income, race, and other demographic information, but also in terms of
familiarity with shopping and purchasing online. The commenter believes that first-time
shoppers for an online children’s product will have different responses from regular online
shoppers. Furthermore, the commenter recommends that CPSC look to garner information on
different types of products parents shop for online, while conducting the survey.
CPSC considered the comment and made modifications to increase the sample size of the survey
to 750. Staff also reiterates that the participants will be screened to ensure the selection of a
sample that varies on income, education, age, age of their child(ren), and other parameters. The
panel provider will also monitor respondents to ensure that underserved populations are
represented in the sample and that insights are collected from a diverse population.
CPSC will differentiate results between first-time and regular online shoppers. At this time,
CPSC will be unable to garner information on the different types of products parents shop for
online, but may consider additional research to collect this information in the future.

Part B. Consultation
CPSC has consulted with FMG. Specifically, FMG has helped inform CPSC’s decisions
regarding the availability of the requested information, data collection techniques, and the clarity
of information and instructions provided to participants.

A9. Explanation of Any Payment or Gift to Respondents
For taking 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 this study, participants will earn Swagbucks equivalent to about $1 for completing
the survey.
Because 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 but an acknowledgement of
respondents’ participation (Halpern, et al., 2004).
Incentives must be high enough to equalize the burden placed on respondents for 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 drop out early.
Additionally, inadequate incentives can cause a difficult and lengthy recruitment process
that, in turn, can cause delays in launching the information collection, which can lead to
increased costs. Incentives are also necessary to ensure adequate representation among
harder-to-recruit 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. FMG is using a panel
for this data collection and will collect the respondents’ self-reported state. Contact
information, such as names, addresses, email addresses, or telephone numbers will not be
collected. The consent form contains a statement emphasizing that no one can link a
participant’s identity to their 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, ages of their children, 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 consist of
750 respondents.

Table A12.1. Estimated Annualized Burden Hours: Survey

Project Activity

Copy Testing Survey

Number of
Respondents

Frequency
of Response

(A)
750

(B)
1

Time
Burden of
Response
(hours)
(C)
0.25

Total
Hours

Respondent
Cost

(D=AxC)
187.50

(Dx$38.60)
$7,237.50

The U.S. Bureau of Labor Statistics estimates the cost of employee compensation for civilian
workers averaged $38.60 per hour worked in December 2020 (Table 2. Employer Cost for
Employee Compensation for civilian workers by occupational and industry group,
https://www.bls.gov/ect). Therefore, the respondent burden for the collection is estimated to
cost $7,237.50 ($38.60 per hour × 187.5 hours).

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 $152,712. 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 $138,866 (the equivalent of a GS-14, Step 5 employee, in the Washington
D.C. area, in 2021), which represents 68.2 percent of the employer costs for employee
compensation, with the remaining 31.8 percent added for benefits (U.S. Bureau of Labor
Statistics, “Employer Costs for Employee Compensation,” December 2020, Table 2,

percentage of wages and salaries for all civilian management, professional, and related
employees), for total annual compensation per FTE of $203,616.
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 from 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 providing recommendations for refining and enhancing
warning labels in the future.
Table A16.1 outlines the project timeline.
Table A16.1. Project Timeline
Item

Timeline

Survey Fielding

Within 1 month of OMB approval

Conduct Data Analysis and Submit Draft Report

7 weeks after survey completion

Final Summary Report

10 weeks after survey completion

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.

REFERENCES
Argo, J. J., & Main, K. J. (2004). Meta-Analyses of the Effectiveness of Warning Labels.
Journal of Public Policy & Marketing,23(2), 193-208. doi:10.1509/jppm.23.2.193.51400.

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.
Qin, Angie. (2020). Toy-Related Deaths and Injuries Calendar Year 2019.
Retrieved from: https://www.cpsc.gov/s3fs-public/Toy-Related-Deaths-and-Injuries2019.pdf?v6yNSJjbr4hygVOEEUztk3cSm9pc8et0.