Supporting Statement part A

OMB Supporting Statement Part A and Part B
A. JUSTIFICATION
A.1. Circumstances Making the Collection of Information Necessary
This is a request for the implementation of a national in-home survey to estimate usage, user
hazard perception, and functionality of the smoke and carbon monoxide (CO) alarms in US
households. This would be accomplished through the administration of the Survey on Usage and
Functionality of Smoke Alarms and Carbon Monoxide Alarms in US Household, hereby referred
as the SCOA survey. This data collection effort will provide an updated national estimate of
operability of smoke alarms and carbon monoxide alarms based on direct observation. This data
will allow for better targeting of policy, messaging, and interventions to improve the operability
rate of smoke and CO alarms, as well as inform the Consumer Product Safety Commission
(CPSC) of recommendations to state/local jurisdictions related to codes, standards, and/or
regulations of smoke and CO alarms.
In 1992, the Consumer Product Safety Commission (CPSC) sponsored a national in-home survey
to collect information on the number of residential smoke alarms in actual use in homes and to
evaluate the operability of the sampled alarms. The results were published in the 1994 report,
Consumer Product Safety Commission Smoke Detector Operability Survey Report On
Findings 1, which turned 25 years old in 2017. Although the survey results were instrumental for
many years in developing codes and standards related to smoke alarms, subsequent changes in
technology, installation codes, and state/local ordinances have rendered the information outdated
and less effective, and therefore less applicable. Given the changes in technology and state/local
regulations, the increased use of CO alarms, and the value of the past study, CPSC seeks to
collect new data related to smoke and CO alarm use and operability.
Two organizations, National Fire Protection Association (NFPA) and Vision 20/20, have
expressed the need and benefits of repeating the CPSC 1992 survey. The NFPA publishes a
periodical report, Smoke Alarms in U.S. Homes Fires 2, which provides the latest information
about smoke alarms in home fires. The report recognizes the importance of the 1992 study. The
report states, “This study is the gold standard for smoke alarm research. The most complete
study of smoke alarm presence and operational status in the general population was done by the
U.S. Consumer Product Safety Commission's (CPSC’s) National Smoke Detector Project in
1992.” The report points out the key aspect between the CPSC study and other recent studies “This [CPSC] project surveyed the general population, not just high-risk groups or people who
had fires.” More recent studies by other groups have usually been combined with smoke alarm
installation programs and typically target high-risk groups, rather than the general population.
The NFPA still sees the importance of the survey even though the information may be outdated.
The Institution of Fire Engineers US Branch has established a steering committee, Vision 20/20,
comprised of noted fire service and related agency leaders to guide a national strategic planning
process for the fire loss prevention that results in a national plan that will coordinate activities
Charles L. Smith, Smoke Detector Operability Survey – Report on Findings, (Bethesda, MD: U.S. CPSC, November
1993).
2
Marty Ahrens, Smoke Alarms in U.S. Home Fires, Quincy, (MA: NFPA, September 2015).
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and fire prevention efforts. In March 2015, Vision 20/20 hosted a one-day Smoke Alarm Summit
at Johns Hopkins Bloomberg School of Public Health that included representatives from
different stakeholder groups such as the fire service, academia, government, non-profit, and
private sector organizations convened on the summit to develop consensus recommendations on:
1. Evidence-based and evidence-informed policy and practice interventions that will increase the
installation and maintenance of smoke alarms in all homes in the United States
2. High priority research gaps that need to be addressed
3. Next steps to ensure that the findings from this meeting inform policy and practice
The findings from the report, Evidence Informing Action: Consensus Priorities to Increase the
use of Smoke Alarms in U.S. Homes, 3 identified the next steps and priorities for a national effort
to increase the installation and maintenance of smoke alarms that were obtained from experts
who presented at the Summit and respondents who provided feedback during and after the
Summit. The number one priority was, “1. Conduct a national census (or representative sample
in-home survey) on the prevalence and characteristics of smoke alarms.” The experts at the
summit all agreed that an updated national survey needs to be conducted to develop a national
effort to increase the installation and maintenance of smoke alarms in the US.
A.2. Purpose and Use of the Information Collection
The purpose of the SCOA survey is to collect data that will assist CPSC with better estimation of
the number and types of smoke and CO alarms installed in US households, the proportion of
working smoke and CO alarms, the characteristics of residences and residents where the smoke
and CO alarms are not operational, perceptions of residents related to the cause of “false” alarms
or causes of faulty alarms, consumer hazard awareness, and consumer behavior related to alarm
use and smoke and CO hazards.
The information collected from this survey will allow CPSC to provide an updated national
estimate of operability of smoke alarms and CO alarms based on direct observation. It will also
allow us to create a demographic profile of groups that do not have operable smoke alarms
and/or CO alarms. This includes measures from the perspective of household members lacking
operable alarms as to why they lack functional alarms. This will allow for better targeting of
policy, messaging and interventions to improve the operability rate of these alarms. It will also
provide insights as to the kinds of alarms that are present to determine whether one variety or
another is more likely to be inoperable as well as provide some measure as to the age of alarms
in households. Results of the survey will inform CPSC of recommendations to state/local
jurisdictions related to codes, standards, and/or regulations of smoke and CO alarms. The
information can help improve the voluntary standard for carbon monoxide alarm, UL 2034 4, and
guide state and local jurisdictions for the use and installation of CO alarms. While the installation
Johns Hopkins Center for Injury Research and Policy, Evidence Informing Action: Consensus Priorities to Increase
the use of Smoke Alarms in U.S. Homes (Warrenton, VA: National Smoke Alarm Submit, 2015).
4
Underwriter Laboratories, “Standard for Single and Multiple Station Carbon Monoxide Alarms,” Standard 2034,
Edition 4, March 31, 2017. https://www.shopulstandards.com/ProductDetail.aspx?UniqueKey=32610
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codes for the two products, especially as required by states or local jurisdictions, are different, it
was determined that the information collection regarding these two products could be combined
in one survey as a means of optimizing resources and reducing burden.
A.2.1. Description of Survey
The SCOA survey seeks to collect information from 1,185 households ∗ within the United States.
The survey will be conducted only through face-to-face in-home interviews. Since previous
research showed that self-reporting surveys on use and functionality of smoke alarms provided
overestimated results of smoke alarms operability, CPSC identified the need to conduct in-home
direct testing and examination of smoke alarms, in addition to conducting data collection through
traditional survey questions.
Households will be recruited to participate at their front door. If the head-of-household is
interested in participating they will be immediately screened. In accordance with CDC
guidelines, the interviewer will ask a series of questions to ensure that no one in the household
has COVID-19, symptoms of COVID-19, or are currently quarantining because of COVID-19. If
respondents clear all questions, the rest of the screening questions would be asked. This ensures
a safe environment for the research team and the members of the household.
During the screening process, if the respondent indicates they have a smoke alarm that is not
connected to a central or security alarm, and thus allows a direct testing of the alarms, the
respondents will be eligible for the full-length in-home interview. However, if the smoke alarm
cannot be tested because the household does not have an alarm installed or if the alarms are
connected to a central alarm system that will notify the police or fire department, then the
respondent will only be eligible for a shortened version of the survey. This shortened version
consists of a subset of survey questions about safety attitudes and demographics. CPSC’s
Contractor—EurekaFacts, a market and social sciences research company—will conduct all the
tasks related to design, administration, fielding, analysis and reporting of the survey.
This survey will allow CPSC to better assess the next steps and priorities to increase installation
and maintenance of smoke and CO alarms for the general population by understanding their level
of awareness, perceptions, and demographics. The survey items will also help inform CPSC of
recommendations to provide state/local jurisdictions related to codes and standards.
The SCOA survey will provide the only source of data available to answer the following
research questions:
• What proportion and number of households have smoke and/or carbon monoxide (CO)
alarms installed in their home? Of these households with alarms, what proportion and
number have an operational alarm?
• What proportion and number of respondents perceive their home as safe? Does the
availability of smoke or CO alarms influence their sense of safety? For what reasons do
respondents not have alarms installed?

∗

1,185 in-home surveys include 1,055 in the main survey and 130 in the pilot survey

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•
•
•
•
•

Does the characteristics of a respondent’s residence affect the availability or operability
of smoke or CO alarms? Does the characteristics of residency characteristics affect fire
and CO risks?
What proportion and number of respondents are aware of how to maintain and test their
fire and/or CO alarms? Of these respondents, what methods, if any, do they use to
maintain and test their alarms?
Are there behaviors or activities, if any, that impact respondents either having alarms in
their home and/or having functioning alarms in their home?
What proportion of respondents seek out information about fire and CO safety? Of these
respondents, what resources do they use to seek out information about fire and CO
safety?
What, if any, demographics demonstrate a relationship between respondents’ possession
of fire or CO alarms and their risk of fire and/or CO incidents?

The table below shows how survey items will aid in answering the research questions and what
type of information it will provide. 5
Table 1. Question Mapping of Survey Instrument to Research Purpose

Research Question
What proportion and number of
respondents have smoke and/or
carbon monoxide (CO) alarms
installed in their home?

Corresponding Survey
Item(s)
4a-4c, 5a-5c, 11a-11d, 14a14d, 15a, 15b, 19a-19d, 20,
22a-22b, 25, 26-1a-26-1aa,
30, 32

Purpose of Collected
Information
The results will provide insight
into the prevalence of alarms in
respondents’ homes, identify
the types of alarms installed,
and determine how many, if
any, alarms are operational.
Conversely, these items will
also aid in revealing the
proportion of the residents who
do not have alarms in their
home and help uncover the
reasons why.

4d, 5d, 20, 29, 30, 31, 32

This information will help
understand how respondents
personally define “safety” and
how this perception influences

Of these respondents with
alarms, what proportion and
number have an operational
alarm?

What proportion and number of
respondents perceive their home
as safe? Does the availability of
smoke or CO alarms influence

The terminology “smoke alarms” and “CO alarms” is used in technical codes and standards to describe devices
that incorporate a sensing component (detector) and an audible component (alarm). It was determined through
cognitive testing that “smoke detector” and CO detector” has a higher consumer understandability for smoke
alarms and CO alarms. The instrument incorporates the terminology “smoke detector” and CO detector” but in this
document the terminology smoke alarm, CO alarm, or alarms (both units) will be used.

5

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their sense of safety? For what
reasons do respondents not have
alarms installed?

whether or not they have alarms
installed within their homes.

Do the characteristics of a
respondent’s residence affect the
availability or operability of
smoke or CO alarms? Do the
characteristics of residency
characteristics affect fire and CO
risks?

1a, 4a – 4c, 5a – 5c, 6, 7, 8,
9a – 9c, 25, 27, 28

What proportion and number of
respondents are aware of how to
maintain and test their smoke
and/or CO alarms?
Of these respondents, what
methods, if any, do they use to
maintain and test their alarms?

10a – 10c, 11a – 11d, 12, 13, These questions help
18a – 18b, 19a – 19d, 21, 23 understand whether or not
people have the knowledge and
ability to test and maintain their
smoke and/or CO alarms and
the types of methods used.
This can inform CPSC of the
type of information that needs
to be dispersed.

Are there behaviors or activities,
if any, that impact respondents
either having alarms in their
home and/or having functioning
alarms in their home?

33a – 33d, 35

This information is important
as it will help understand the
relationship between how
respondents behave and what
activities they engage in that
may influence the likelihood of
having alarms in their home
such as their cooking behaviors
of using a stove or oven.

What proportion of respondents
seek out information about fire
and CO safety?
Of these respondents, what
resources do they use to seek out
information about fire and CO
safety?

34a – 34c

This information will assist
CPSC with addressing the best
types of resources to disperse
information about fire and CO
safety.

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The results will provide insight
into if the resident owns or
rents the home, duration of
residency, and the age of the
household. These items will
shed light on if there is a
relationship between the
characteristics of a respondent’s
home and their status of having
alarms such as having an
attached garage unit if they live
in a single family detached
house.

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What, if any, demographics
demonstrate a relationship
between respondents’ possession
of fire or CO alarms and their
risk of fire and/or CO incidents?

36 - 44

This will help provide insight
into the relationship between
respondent demographics and
their risk of fire or CO
incidents. This will also shed
light as to their status of
whether or not they have a
smoke or CO alarm(s).

A.2.2. Survey Administration Procedures
Originally, randomly selected households within the randomly selected tracts were contacted in
advance via a mailed pre-notification letter. Households were then called to be screened to
determine their eligibility for either an in-home or telephone interview and scheduled for a
relevant type of administration mode. The initially approved OMB methodology yielded a
response rate of less than one quarter of 1% (only 0.23%) during recruitment efforts in two
metropolitan areas. OMB approved revisions were made to the screening instrument to raise the
appeal, urgency and information on the public benefit of the study, along with streamlining of
language for greater efficiency in screening potential participants. Following these revisions to
the recruitment efforts and their implementation, the response rate results were unchanged and
remained inadequate in meeting the schedule and the current contract with CPSC.
In the fall of 2019, EurekaFacts submitted and was approved by OMB to redesign the
recruitment effort as a random walk door-to-door knocking sample methodology. To maintain
the structure of the original recruitment procedure, field teams will first distribute door hangers
as a pre-notification that researchers will be knocking on doors asking for participation in a
survey. This provides households a distinctive piece of literature with vital information about the
study and sources to seek out more information. A map of the tract will be marked where the
door hangers were left, so field interviewers can follow the same path to recruit from those
households a few days later.
The recruitment, screening, and in-home survey will be conducted by a qualified two-member
team (this may consist of fire inspectors, fire educators, firefighter from a local fire department,
survey research professionals, or other qualified individuals with either fire safety or research
experience from the local area). The field teams will be made up of local partners who
understand and can gain the trust of the local community. Both members will present their
government-issued IDs and their official badges (either representing the company they work for
or badges designed by EurekaFacts for the purpose of the study) to confirm their identity and
legitimacy. The team will carry with them a letter printed on official letterhead with
endorsements from the local fire department and CPSC, should they be needed. If the home is in
an apartment building or condominium, prior permission will be obtained from the property
manager to proceed with the in-home survey administration. A consent form will be provided to
the participant to explain the purpose, the statement of confidentiality, and the benefits and
potential risks of the study.
Following the entrance, the survey professional will begin to administer the questions based on
the respondent’s residence type, and smoke and CO alarms availability and functionality. Once
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the survey professional finishes asking questions about the smoke and CO alarms, the survey
team will move on to examine the smoke and CO alarms in the residence. The fire alarm
inspector will then identify, test, and examine the alarms to determine different variables such as
their operability, energy source, their type, and age. After examining each alarm, the survey
team, and resident, will repeat the testing procedure on another alarm (if applicable). Due to the
time constraint of the survey, not all alarms in a home can usually be inspected. The survey team
will coordinate with the participant to test a reasonable number of alarms in as varied of
locations as possible within the time constraint of the survey.
If the alarm or alarms are found to be faulty, the resident will have the option of either receiving
a new alarm, receiving new batteries, or having no action taken at all if the respondent chooses
not to have the alarm fixed or replaced. In all cases, respondents will sign a waiver indicating
whether they refuse, or any other course of action taken during the in-home administration.
Once the administration is complete and the final set of demographic questions is administered,
the survey professional will offer the participant the monetary incentive for their completion of
the survey.
EurekaFacts will work with on-the-ground partners to take all necessary COVID-19 precautions
and procedures in accordance with local and federal guidelines throughout the duration of the
survey. This includes working with partners to be sure all guidelines are being implemented,
including wearing masks, using hand sanitizer, maintaining social distancing and regularly
checking the health and wellness of all those involved in the study. EurekaFacts will coordinate
training of field workers to apply these principles in the field and provide the needed personal
protective equipment (PPE).
EurekaFacts will provide masks for all field workers and extra masks to give to participants that
do not have one on hand. Field teams will be instructed to maintain a 6-foot distance when
screening heads of households at the door and when interviewing them in their house. Field
teams will each be given hand sanitizer to use periodically throughout the day as well as
disinfecting wipes for tablet surfaces.
A.2.3 Audiences of Data and Results
The designated CPSC Contracting Officer’s Representative (COR) and assigned CPSC staff will
be the primary audience of the data and results. A summary report of aggregated results will be
presented that encompasses all phases and methods employed in the study and will present a
comprehensive description to help inform the agency of the number and types of smoke alarms
and CO alarms installed in households, the characteristics of residences and residents where the
smoke and CO alarms are not working, perceptions related to the cause of “false” alarms or
causes of faulty alarms, and resident alarm maintenance habits. In addition to the summary
report, a PowerPoint presentation, raw data, a table of univariate results, and various data
analysis documentation will also be delivered electronically to the primary audience identified
above.
A.2.4 Methods of Dissemination
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The contractor’s final report will be made available to the public after the draft report has been
reviewed and approved by the CPSC’s COR and assigned CPSC staff.
The final report will be released by the Commission by disseminating the report on the agency’s
website and presentations at meetings and conferences related to the subject matter. The
procedures to disseminate the information by the Commission, its staff, agents and
representatives will be accordance with the law and Commission policy to ensure the
information is accurate and not misleading.
In order to encourage dissemination of the findings, the report will be freely accessible on
cpsc.gov. The work was prepared in the course of the author's official contracting duties with
CPSC, thus Title 17 U.S.C. Section 105 provides that there can be no copyright in a United
States government publication.
A.3. Use of Improved Information Technology (IT) and Burden Reduction
In order to minimize respondent burden, the respondents that do not have smoke alarms installed
or have a central alarm system, and thus are not eligible for the full-length interview which
includes alarm inspection and testing, will participate in the shorter version of the survey and
answer only a portion of questions. All data from the in-home interviews, both full-length and
short, will be collected using a tablet computer. Both versions of the survey instrument will be
programmed into a singular programmed survey using Qualtrics software and will be
administered via tablet, with the interviewer reading the questions to the participant. Qualtrics is
programmed with the appropriate question skipping patterns to ensure that interviewers only ask
each respondent survey items appropriate for the respondent’s residence type, and smoke and CO
alarms availability and functionality.
The instrument was first pre-tested through in-depth cognitive interviews with a sample of 18
respondents (OMB Control Number 3041-0136) to certify that the survey items are clear and
easy to understand when the survey is administered on a wider scale, reducing any potential
burden for respondents.
Aligned with the original approach, EurekaFacts sought to identify and adjust any recruitment or
data collection procedures or aspects to the instruments during the initial launch of the study. In
the original methodology, EurekaFacts found that the mailing and multiple attempts of calling
participants yielded a very low response rate (less than one-quarter of 1%). EurekaFacts initially
sought to correct this issue by purchasing more sample and focusing on calling households first,
then mailing interested residents. When this did not change response rate, EurekaFacts changed
methodology entirely to a door-to-door random walk recruitment. After the first round of
recruitment and data collection, EurekaFacts found no major issues and continued with the data
collection effort. After the first 50 completes were collected, a brief analysis of selected
questions was conducted to ensure data quality and instrument functionality; no changes were
needed. Additionally, an internal debrief was conducted and lessons learned from those initial
interviews were incorporated into the rest of the data collection effort and highlighted in the pilot
report.
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EurekaFacts plans to continue fielding the study to collect 1,055 total completes. The
information will be summarized into a final report, which will be electronically submitted to the
CPSC Contracting Officer’s Representative (COR).
A.4. Efforts to Identify Duplication and Use of Similar Information
The intent of this data collection is to obtain information that is not readily available elsewhere.
The last time this type of data was collected occurred 25 years ago by CPSC. Other recent
studies were focused on targeting high-risk groups or people who had fires; however, the
estimates for a general population are not available, thus, CPSC specifically selected to focus this
survey on the general population. This data collection will help CPSC develop a national effort
to increase installation and maintenance of smoke alarms in the U.S.
The need for the proposed data collection and the design of this national survey was based on
several consultative efforts with and feedback from experts, stakeholder groups such as the fire
service agencies, academia, government, non-profit and private sector organizations 6 7. The
collected input from experts and stakeholders ensured that the present survey does not duplicate
the information available elsewhere.
A.5. Impact on Small Businesses or Other Small Entities
The information will not be collected from small businesses or other small entities.
A.6. Consequences to Federal program or policy activities if collection is not conducted or is
conducted less frequently
The 1992 national in-home survey, sponsored by CPSC, helped collect information on the
number of residential smoke alarms in actual use in homes and evaluated the operability of the
sampled alarms. The 1992 CPSC survey had the most impact to the installation code, NFPA 72 8,
for smoke alarms. The 1992 CPSC survey set the foundation for many installation and give-away
programs to target specific groups that do not have smoke alarms, thus increasing the presences
of smoke alarms in US households. The presence of smoke alarm in the household considerably
increases the chances of the occupants escaping a home fire.
However, this survey will be 25 years old as of 2017. In order to ensure that the collected
information being referenced remains current and that changes in technology and installation
codes are upheld, the collection of information must be conducted again. By implementing the
new nation-wide SCOA survey, the codes and standards will be current so that fire prevention
organizations and agencies will have all the up-to-date information needed to efficiently and
effectively target the areas for improving life safety and saving lives.
A.7. Special Circumstances Relating to the Guidelines of 5 CFR 1320.5
6. Johns Hopkins Center for Injury Research and Policy, Evidence Informing Action: Consensus Priorities to Increase
the use of Smoke Alarms in U.S. Homes.
7. Amanda Kimball, P.E., Workshop for Survey on Usage and Functionality of Smoke Alarms and CO Alarms in
Households, (Quincy, MA: NFPA, 2017).
8. NFPA 72 – National Fire Alarm and Signaling Code, (Quincy, MA: NFPA, 2016).

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There are no special circumstances. This information collection is consistent with the guidelines
prescribed in 5 CFR 1320.5.
A.8. Consultation and Public Comments
Part A. PUBLIC NOTICE
A 60-Day Federal Register Notice for the collection published on July 23, 2021. The 60-Day FR
citation is 86 FR 39006. The CPSC received one comment during the 60-Day Comment Period.
The commenter stated that although survey email may produce some results, door-to-door
solicitation should not be conducted because people do not want strangers coming to their front
door.
Staff agrees that current public perceptions regarding an in-person survey are significantly
different than when the smoke alarm survey was last conducted in 1992. However, the initial
rollout of the survey in 2019, soliciting randomly selected households via a mailed prenotification letter, which were subsequently screened for an in-home or telephone interview,
resulted in an extremely low response rate. To increase the response rate, the SCOA survey
recruitment effort was redesigned as a door-to-door walk-recruitment methodology. Field teams
distribute door hangers on randomly selected households to provide prenotification that
researchers will be knocking on doors asking for participation in a survey. A pilot survey
conducted in the Washington metro area showed significant improvement in the response rate.
Accordingly, to obtain the best information available, the SCOA survey data collection will
continue to use this door-to-door recruitment methodology, recognizing that home visits by
trained data collectors with inspection and testing provide much better-quality data compared to
telephone or Internet surveys.
A 30-Day Federal Register Notice for the collection published on October 26, 2021. The 30-Day
FR citation is 86 FR 59152.
Part B. CONSULTATION
CPSC consulted with various stakeholder groups in planning the survey. Stakeholders that
participated included representatives from the fire service, enforcers/authority having
jurisdictions (AHJs), public educators, researchers, equipment manufacturers, standards
developers, and others.
To gauge interest in the need for this data, CPSC hosted or participated in the following industry
events:
•
•
•

SCOA survey planning workshop, hosted by CPSC on February 16, 2017.
Vision 20/20 workshop on smoke alarms in March 2015. CPSC received input on a
representative, in-home survey on the prevalence and characteristics of smoke alarms.
International Conference & Workshop Current Practices in Emergency Response: Carbon
Monoxide Poisoning on September 26, 2018. CPSC received input from representatives
from the fire service, enforces/AHJs, public educators, researchers, equipment
manufacturers, standards developers, and others on CO poisoning and CO alarms.

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EurekaFacts, National Fire Protection Association (NFPA), Vision 20/20, and United States Fire
Administration (USFA) were consulted in the availability of accurate smoke and CO alarm
operability data for consumer homes. All four confirmed that information for in-home
operability of smoke and CO alarms have not been available since the last time the survey was
conducted by CPSC in 1992, and that current phone surveys of inoperable smoke alarms in the
US are less reliable.
CPSC staff consulted with EurekaFacts in developing and executing the survey. EurekaFacts is
compliant with the standards in quality for a research organization. 9 EurekaFacts was consulted
on the frequency of collection and the total number of responses required to provide estimates on
the operability of smoke and CO alarms in the US.
CPSC staff consulted with EurekaFacts in developing the survey questioner and to ensure the
understandability and clarity of the question being asked.
A.9. Explanation of any Payment or Gift
Contractor will provide a monetary incentive to respondents through the form of a gift card from
a major credit card company. Based on their eligibility, as determined through the screening
process, respondents will receive one of two incentive amounts at the completion of the survey.
If respondents qualify for the in-home survey administration, respondents will receive a $50 gift
card from a major credit card company in appreciation for their completion of the survey.
However, if respondents qualify for the shorter survey administration, at the completion of the
survey, respondents will receive a $25 gift card from a major credit card company. The variation
of monetary value is due to the amount of time and effort involved in the in-home full survey and
alarm testing administration compared to the shorter survey administration.
A.10. Assurance of Confidentiality Provided to Respondents
Participation in the survey is voluntary and respondents will be so informed before the screening
and at the beginning the survey. Subjects are informed of the measures taken to protect their
confidentiality in the introductory language read to sampled persons. Information collected from
respondents will be kept confidential and only used for research purposes.
Survey respondents will have assigned a Random ID number not linked to any personal
identifying information. Respondents’ contact information (name, address, phone number, e-mail
address) along with the Random ID number will be maintained in one secure database
(“Database 1”). The survey responses and respondents/household demographic information will
be maintained in a second secure database (“Database 2”) where potential survey participants are
identified by Random ID Number only. Database 2 will not contain participants’ names,
addresses, phone numbers, e-mail addresses, or other personally identifying information (PII).

EurekaFacts holds a certification for the ISO 20252: Market, Opinion, and Social Research International Quality
Standard.

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Analysis will be conducted on data sets that include only respondent ID numbers; they will not
contain any identifying data. The software that EurekaFacts will use to collect survey data,
Qualtrics, is a secure platform endorsed by the federal government. Qualtrics has FedRAMP
authorization, ISO 27001 certification, and FISMA compliance, ensuring data security. All
collected data will be secured by EurekaFacts and will be kept on the password protected
computers and secure server and locked file cabinets (as applicable), accessible only to project
staff.
Access to the facilities and server where data will be stored is restricted only to authorized
individuals. Access restrictions are defined for each individual based on his/her role. Access to
data requires the entry of a valid account username and password. Project staff receive data
security training and sign an assurance of confidentiality of survey data. All project staff
complete required annual privacy and security training and sign a document pledging
confidentially and maintaining privacy according to Health Insurance Portability and
Accountability Act (HIPAA). The training includes information and data security factors, using
information sources responsibly, employee responsibilities, and how to report instances where
violation of data security is suspected.
Any administrative and PII collected from respondents may be destroyed within 365 days after
of the end of the study. However, to ensure the possibility for potential replication of the study in
the future, any non-administrative data may be kept by CPSC indefinitely.
A.11. Justification for Sensitive Questions
A majority of questions asked in the survey are not typically considered sensitive in nature.
Potentially sensitive questions include the demographic questions that ask about the respondent’s
ethnicity/race, ages of those living in the household, disabilities, and combined annual household
income. Both the trained interviewer and the communication materials will reassure that
participation is voluntary, that they may choose not to answer some questions, and that responses
are confidential. The instructions presented in the survey is designed to make respondents feel as
comfortable as possible in answering these questions.
In addition, each respondent will be informed that a unique ID will be assigned to them that does
not link to any personal identifying information. Data analysis will be conducted on data sets that
include only respondent ID numbers; they will not contain any identifying data.
A.12. Estimate of hour burden to respondents
Upon launch of the survey phase in 2019 fielding in two metro areas, response rate and
cooperation were very low as outline above, impeding the success of the study within contract
timeline, budget and respondent burden level. Revised sampling methods and corresponding
response rates were submitted and approved by OMB in the interim from the initial approval and
the renewal of the project. To complete 1185 interviews (the total burden for the study including
the Washington Metro Area pilot and 24 metro areas that constitute the random sample of
primary sampling units), will require 1,552 burden hours on the public. Several factors may lead
to lower respondent burden. The revised methodology requires a fewer number of interactions
per household which may ultimately reduce the total respondent burden when compared against
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the original address-based sampling (mail to phone to household) methodology. (Please see
section A.15, for further explanation of methodology and response rate change).
The time for screening an individual and starting the interview is also reduced. Multiple phone
calls for screening, scheduling, and confirmation are replaced with interviewers at the door
immediately ready to do screen and conduct interviews upon contact with potential participants.
The original methodology experienced high attrition between scheduling a session and
interviewers arriving at the door, but the revised methodology is expected to receive hardly any
barriers to completing a confirmed interview (baring some extreme circumstance) since the
interview immediately proceeds after screening.

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Below is a discussion of the burden hours.
Table 2. Total Burden Hours by Recruitment and Data Collection Task
Recruitment
activity/ Survey
instrument
Invitation
Recruitment appeal
at door
Screener
Agree to screening
and are screened and
found eligible to
participate
Survey
Full-length survey
(one hour)
Shortened survey for
no-alarm and
security alarm
households (20minutes)

Hours per
respondent

Total number
of contacted
participants

Response
rate

Number of
respondents

Total hours

0.05
(3 minutes)

22,931

30%

6,879

344

0.075
(4.5 minutes)

6,879

17.4%

1,197

90

1

1,096

99%

1085

1085

0.33

101

99%

100

33

1185

1,552

Total Burden Hours: 1552 hours
According to the U.S. Bureau of Labor Statistics, the total compensation for civilian workers in
March 2021 was $39.01 per hour (Employer Cost for Employee Compensation, Table 2,
https://www.bls.gov/news.release/ecec.t02.htm). Therefore, CPSC estimates the cost burden for
respondents to be $60,544 ($39.01 per hour × 1,552 hours = $60,543.52).
A.13. Estimate of total annual cost burden to respondents
There are no costs to respondents to complete this collection other than the labor burden costs
addressed in Section 12 of this document, and there are no respondent recordkeeping
requirements associated with the SCOA survey. There are no operating, maintenance, or capital
costs for respondents associated with the collection.
A.14. Estimate of annualized costs to the Federal government
The contracts to design and conduct the Survey on Usage and Functionality of Smoke Alarms
and Carbon Monoxide Alarms in Households were issued to Eureka Facts LLC under contract
numbers F-16-0091 and F-17-0088 for $562,725 (this figure does not include the cognitive
testing phase that was approved through OMB Control Number 3041-0136).
Salary and benefits costs for government personnel assigned to this study are estimated using the
January 2021 pay scale for a GS-13, Step 5 employee in the Washington, D.C. area, of $117,516,
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and the March 2021 Employer Costs for Employee Compensation (ECEC), published by the
U.S. Bureau of Labor Statistics (https://www.bls.gov/news.release/ecec.t02.htm). According to
table 2 of the ECEC, 68.8 percent of total compensation is paid in wages and the remaining 31.2
percent is benefits. Therefore, in 2021 the staff cost is $142,340, based on 10 staff months
(($117,516/.688) × 10 staff months). In 2022, the staff cost is $106,755, based on 7.5 staff
months (($117,516/.688) × 7.5 staff months). And, the total estimated cost to the federal
government is $249,095 ($142,340 + $106,755), in government labor.
A.15. Program changes or adjustments
Since the initial OMB application and approval in October 2018, EurekaFacts has submitted and
been approved to make several changes to the sampling and data collection process.
Changes that have been incorporated into the current process (from most to least significant)
include:
1. Modifying the third stage of the sampling approach (selection of occupied housing units
in tracts). Originally, houses were randomly selected through ABS (address-based
sampling) with follow-up phone call appointments to conduct the interviews, but the
extremely low response rate and logistical challenges on part of both participants and
field teams results in only a few completed in-home interviews. To streamline the
process, the recruitment method was changed to a random walk door-to-door knocking
methodology. This allowed for direct recruitment and completion of the in-home
interview at one time.
2. Altering the pre-notification document from a mailed letter to a streamlined and eyecatching door hanger to compliment the modified sampling approach. This maintains the
process of pre-notifying residents about the study with a cost-efficient alternative that
raises both individual and community awareness. Distributing the door hangers provides
the field teams flexibility to pre-notify residents of a tract a few days before the intended
recruitment effort, thus maximizing the impact of the literature.
3. Increasing the incentive amount from $25 to $50 for completion of the full-length (60
minute) survey interview. This is an important recruitment tool to increase the
cooperation rate of contacted households and more closely parallels the monetary
incentive offered in 1992, once adjusted for inflation.
4. Implementation of COVID-19 screening questions and protocols. Because of the
coronavirus (COVID-19) pandemic, the project was paused in March 2020, pending
evaluation of the public health environment to determine when best to relaunch the study
in each chosen metro area. EurekaFacts is following the CDC recommendations to ensure
both interviewer and participant safety, including masking and social distancing. If heads
of households are interested in participating after hearing the introduction and purpose of
the study, the interviewer will ask a series of questions to ensure that no one in the
household has COVID-19, symptoms of COVID-19, or are currently quarantining
because of COVID-19. If respondents clear all questions, the rest of the screening
questions would be asked.
5. Inclusion of refusal aversion language to persuade residents to participate. This additional
approved language provides field teams with additional information to recruit
participants.
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6. Revising the expected response rate of the study. The original sampling design resulted in
a response rate of 0.23% (or less than one-quarter of 1%). Upon revision to the door-todoor methodology, EurekaFacts garnered a response rate of 3.5% in the Washington D.C.
metro area during the pilot of the methodology (15x that of the original response rate).
Additionally, field teams during the pilot had face-to-face interaction with 20% of
households contacted. Once an interviewer initiated the recruitment process, there was a
17% chance of participant cooperation that resulted in a completed interview.
EurekaFacts is factoring in the recorded response rate and cooperation data of the pilot
location into calculating the efforts for other metro areas and the study overall. Because
of the overall lower response rate, more households need to be contacted for the initial
pitch of the study; however, the revised methodology reduces the number of contacts
made per residence, which reduces the overall burden per respondent.
7. The original sample selection of metro areas (AKA, primary sampling units) included
each of the following 24 metro locations proportionally drawn (based on concentration of
occupied households) from each of four U.S. Census regions. The Washington DC Metro
area was not randomly selected for this effort but was instead a purposively selected
metro area to test revisions to the sampling method mid-field for proof of concept. As
others may remember, following great challenges experienced with the original 2018
sampling design using an address-based sampling approach, a new door-to-door (D2D)
sampling method was proposed and approved by CPSC and OMB. To test feasibility of
D2D methods for the SCOA survey, the Washington DC Metro was proposed and
endorsed. The advantages of the Washington area included close and convenient data
collection for successful monitoring, the ability to judge and react quickly to challenges,
and cost containment measures, among other benefits.
The research design and budget contracts for this survey effort did not include a pilot
location for the testing of methods. A redesign was not anticipated. Only the 24 metro
locations identified above were selected for sampling to constitute the N=1,185
nationwide proportionally representative interviews as approved under the study design
and budget.
Ultimately, the decision was made by CPSC and EurekaFacts to not consider the
Washington metro as eligible for the SCOA survey (within the N=1,185 total completes)
and instead treat this location as a pilot study only. 10 In turn, the survey is being
completed in each of the originally selected 24 metro locations, while reducing the total
nationwide sample size to N=1,055 (i.e., N=1,185 completes minus the N=130 interviews
completed in the Washington Metro area). The number of expected completes has been
redistributed in proportion to occupied housing unit counts for each of the 24 metro
locations. These changes were made, in part, to complete the study in full within the
contracted periods established by CPSC and National Fire Protection Association
(NFPA), no later than fall 2022 and accounting for time lost for data collection

CPSC SCOA Survey – Washington, DC Door-to-Door Pilot (April 3, 2020), EurekaFacts, Rockville, MD CPSC-SurveyRevised-DiagnosticReport_11_18_20206b6.pdf
10

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attributable to a work stoppage for face-to-face interviewing during the COVID-19
pandemic.
To adjust the total sample selection nationwide, among the 24 metros, each metro area’s
expected sample size was reduced in proportion to its share of occupied housing units in
the overall sample frame. For example, Los Angeles, CA (the largest metro area in the
sample) had an original sample size expectation of N=205 based on 1,185 interviews.
After recalibration, using a total nationwide sample size equal to 1,055 the new sample
size expectation for Los Angeles, CA metro area equals N=183 completes. Providence,
RI (one of the smallest metro areas) had an original sample size expectation of N=34
completes based on 1,185 total interviews. After recalibration, the new sample size
expectation for the Providence, RI metro area equals N=30 completes.

Table 3. Calculation for adjustment in metro area sample sizes.
Formula for metro area sample sizes:
(Solve for SampleN)

OHUs^ for each metro

=

Total OHUs all metros
Los Angeles, CA Metro Area

62,942

Total sample (N=1,055)
=

363,111
Providence, RI Metro Area

10,350
363,111

^

SampleN

183
1,055

=

30
1,055

Occupied housing units (OHU).

Note that the changes listed here, and the details of the resulting administrative, technological,
and sampling revisions, are incorporated throughout the text of the revised supporting statements
A and B.
A.16. Plans for tabulation and publication
A.16.1 Analysis Plan
Prior to data analysis, EurekaFacts will complete data cleaning and a non-response analysis. The
data cleaning process will include: identification and removal or re-coding of inconsistent
responses and subsequent inclusion in the final data file and elimination of or recoding of
respondents’ choices when outside the ranges specified in the response categories. A nonresponse analysis will follow the data cleaning. The objective is to identify differences between
respondents and non-respondents based on their demographics and other measurable
characteristics to assess the representativeness of our sample necessary to allow statistical
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inferences of the survey results. Weights will be applied to correct an over or underrepresentativeness of categories of the target audience in the final survey data.
The analysis will provide estimates of operability of smoke alarms and CO alarms, estimates of
percentages of households as well as subgroups with installed of smoke alarms and CO alarms,
estimates of the proportions of respondents demonstrating hazard awareness, and relevant
behavior related to alarm use and smoke and CO hazards. Analysis will include evaluation of
factors leading to inoperable alarms, types of housing relative to alarm operability conditions.
Analysis will identify demographic groups that do not have operable smoke alarms and/or CO
alarms, as well as demographic characteristics affecting alarms operability conditions.
The data analysis will include a tabulation of all survey questions, graphs, frequency
distributions, and two-or-three way cross-tabulations of meaningful parameters to show
similarities or differences among respondents. Analysis will be conducted using case-appropriate
statistical, data-mining, and database modeling procedures. Analysis deliverables will include a
final technical report describing the SCOA methodology and summarizing the results, findings,
and conclusions. The report will include American Association for Public Opinion Research
(AAPOR) indices for survey response rates, descriptive statistics on the demographic data,
summary lists of open responses, and frequency distributions. A table of survey interviews and
non-responses, in accordance with nationally recognized guidelines from AAPOR, will also be
delivered.
A.16.2 Publication Plan
The Contractor will develop a technical report that will present a description of study design,
research methods, summary of results, finding and conclusions.
The final technical report will be released by the Commission by disseminating the report on the
agency’s website and presentations at meetings and conferences related to the subject matter.
The procedures to disseminate the information by the Commission, its staff, agents and
representatives will be accordance with the law and Commission policy to ensure the
information is accurate and not misleading. The agency will disseminate the findings when
appropriate, strictly following the agency’s “Guidelines for Ensuring the Quality of Information
Disseminated to the Public”.
In order to encourage dissemination of the findings, the report will be freely accessible on
cpsc.gov. The work was prepared in the course of the author's official contracting duties with
CPSC, thus Title 17 U.S.C. Section 105 provides that there can be no copyright in a United
States government publication.
A.17. Rationale for not displaying the expiration date for OMB approval
No such exception is sought. The OMB survey number and expiration date will be displayed on
the initial screener and informed consent forms to be used as a reference if needed.
A.18. Exception to the certification statement
No such exception is sought. These activities comply with the requirements in 5 CFR 1320.9.
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