Experience With 
 
 The Department of Commerce 
 
 Voluntary Consumer Product 
 
 Information Labeling Program 
 
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 US 
 
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Digitized by the Internet Archive 
 
 in 2012 with funding from 
 
 LYRASIS Members and Sloan Foundation 
 
 http://archive.org/details/experiencewithdeOOunit 
 
Foreword 
 
 This comprehensive report describes the origin of the 
 Voluntary Consumer Product Information Labeling Program 
 (CPILP) , the problems it encountered, and the reasons why 
 it was suspended before sufficient evidence had been gained 
 so as to adequately evaluate the program on its merits. 
 
 It is believed that future events, spearheaded by a 
 progressive resurgence of the American economy, will lead to 
 renewed interest in the program and a lifting of its suspension 
 When that occurs appropriate revisions to the program's 
 procedures should be made, together with a requisite commitment 
 of essential resources, in order to take advantage of the 
 lessons learned in the all-too-brief experimental phase of 
 the program as described in this report. Properly designed, 
 conducted and adequately supported, the program should 
 provide considerable return on the investments to consumers 
 and to manufacturers of quality products. 
 
 The overall administration of CPILP was provided by the Office 
 of Product Standards, a policy arm and constituent operating 
 unit of the Assistant Secretary of Commerce for Science and 
 Technology. Technical support for CPILP was furnished by 
 the National Bureau of Standards (particularly the Center 
 for Consumer Product Technology) , a primary operating unit 
 of the Office of the Assistant Secretary for Science and 
 Technology. 
 
 Howard I . Forman 
 Deputy Assistant Secretary 
 for Product Standards 
 
 August 1979 
 
 9 
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Table of Contents 
 
 Executive Summary 
 
 Page 
 
 1. Introduction 
 
 2. Background 
 
 3. The Development of CPILP 
 
 4. Selection and Labeling of Products 
 
 5. Labeling Efforts for Specific Products 
 
 5.1 Thermal Insulation for Homes 
 
 5.2 Smoke Detectors 
 
 5.3 Electric Irons 
 
 5.4 Luggage 
 
 5.5 Carpets 
 
 5.6 Vacuum Cleaners 
 
 5.7 Plumbing Fixtures and Fittings 
 
 5.8 Dry Cells and Batteries 
 
 5.9 Paint 
 
 6. Problems Encountered 
 
 7. Suspension of the Program 
 
 8. Summary and Recommendations 
 
 1 
 2 
 7 
 10 
 16 
 16 
 18 
 20 
 21 
 22 
 24 
 26 
 29 
 30 
 33 
 34 
 36 
 
 Appendix A 
 Appendix B 
 
 Appendix C 
 Appendix D 
 
 Appendix E 
 Appendix F 
 
 Appendix G 
 Appendix H 
 Appendix I 
 
 Appendix J 
 
 Proposed Operation and Procedures 
 Procedures for a Voluntary Consumer 
 
 Product Information Labeling Program 
 Abstract of Program Procedures 
 Consumer Product Information 
 
 Labeling Program Brochures 
 Summary Report of Letter Received 
 Finding of Need to Label 
 
 Thermal Insulation for Homes and 
 
 Determination of Need for 
 
 Inflationary Impact Statement 
 Meetings Related to CPILP 
 Study of Informative Labeling 
 Proposed Specification for Labeling 
 
 Thermal Insulation for Homes 
 Suspension of the Consumer 
 
 Product Information Labeling Program 
 
 A-l 
 
 B-l 
 C-l 
 D-l 
 
 E-l 
 F-l 
 
 G-l 
 H-l 
 
 1-1 
 J-l 
 
Executive Summary 
 
 In the consumer product marketplace there are complex 
 technical problems relating to the development of product 
 standards and test methods, the evaluation of product 
 performance, and the establishment of means by which consumers 
 may compare the attributes of the various products available 
 to them. The extent to which Federal Government programs 
 should address these technical problems has been and still 
 is the subject of controversy. Starting about fifteen 
 years ago, the consumer product marketplace experienced an 
 increase in the relative influence of consumers and consumer 
 organizations. This influence was expressed in part through 
 the passage of a series of Congressional bills addressing 
 consumer problems. 
 
 The Department of Commerce, and its National Bureau of 
 Standards (NBS) became involved in problems related to 
 consumer product technology, notable examples relating to 
 product safety and product energy usage. The first complete 
 outline for a DOC voluntary product performance labeling 
 program was completed in November 19 72. Due to the energy 
 crisis, this program was redirected towards energy efficiency 
 of appliances, and the broader program was not reinitiated 
 until the later part of 1975. 
 
 The proposed procedures for the Voluntary Consumer Product 
 Information Labeling Program (CPILP) were developed and 
 published for public comment in the Federal Register on 
 May 25, 1976. In response to the publication of the proposed 
 procedures, seventy-five letters of comment were submitted 
 by the public and twenty-two persons testified at hearings 
 on the proposed program. The public comments did not cause 
 any major revisions, therefore the final procedures, published 
 on May 25, 1977, were substantially the same as the proposed 
 procedures . 
 
 Since the comments and hearings had shown some concern about 
 the need for the program, the Department decided to initiate 
 the program on an experimental pilot basis. This would 
 provide an opportunity to learn how such a program could 
 be most useful and to evaluate its acceptance by manufacturers 
 and consumers for two products before a commitment to a continu- 
 ing program was made. CPILP was intended to be a self support- 
 ing program depending upon fees paid for the use of the labels. 
 Since the pilot program was designed to be a learning experi- 
 ence and an opportunity to evaluate the acceptance and use- 
 fulness of the program, the procedures were amended to 
 allow the Secretary of Commerce to suspend the fees, at 
 least during the pilot period. 
 
Requests for products to be included in the labeling 
 program were solicited from the general public (including 
 consumers, manufacturers, distributors and other government 
 agencies). Requests for a total of 145 different Droducts 
 or product categories were suggested for inclusion in the 
 program. Because of the time constraints of the pilot 
 program, the possible products were limited to those for 
 which test methods were thought to be available or for which 
 it seemed important that they be labeled, even if incompletely, 
 at an early date. Nine product classes were selected for 
 further examination. 
 
 These were: Carpeting 
 
 Dry cell batteries 
 
 Electric irons 
 
 Home insulation 
 
 Luggage 
 
 Paint 
 
 Plumbing fittings 
 
 Smoke detectors 
 
 Vacuum cleaners. 
 
 Preliminary investigations were conducted on the feasibility 
 of including the above product categories in the labeling 
 program. However, on only two of the above products, 
 thermal insulation and smoke detectors, was the decision 
 made to proceed further than the preliminary investigations. 
 The primary reason was the lack of sufficient or adequate test 
 methods to make the performance labeling of the product mean- 
 ingful . 
 
 The Finding of Need to Label Thermal Insulation for Homes, 
 was published in the Federal Register on December 14, 1977, 
 and a Proposed Specification for such labeling was published 
 on May 31, 1978. A Finding of Need to Label Residential 
 Smoke Detectors was also submitted to the Department of 
 Commerce. However, the decision to suspend CPILP was made 
 before the Smoke Detector Finding of Need was published, 
 and the Federal Register notice of the suspension of the 
 program also included a notice withdrawing the proposed 
 specification for thermal insulation. 
 
 The original concept of a product labeling program emphasized 
 the development and/or adaptation of test methods for rating 
 the performance of the consumer products. To insure that 
 these test methods would be acceptable to manufacturers and 
 consumers, the test methods generally would be developed in 
 a consensus mode. This consensus mode is a time consuming 
 process. Because of the one-year pilot program limitation, 
 
 ii 
 
test method development could not be permitted, and emphasis 
 was placed on finding oroducts that were important to 
 consumers and for which test methods were already available. 
 No products were found which fully met these conditions. 
 Also, for the program to be successful, a vigorous public 
 education program was needed to publicize its existance 
 and purpose, and methods would be required to evaluate the 
 usefulness of the performance labeling of products to 
 consumers. It was not possible to initiate these parts of 
 the program during the pilot period. 
 
 When it became apparent that it would be impossible to 
 successfully complete the labeling of two products within 
 the one-year pilot program, requests were made to extend 
 the program to the end of fiscal year 1979. Although the 
 request to extend the program was approved, funding was 
 reduced to less than 30% of the amount requested. This 
 amount would have marginally allowed for the completion of 
 the labeling of two products, but would have been insufficient: 
 to initiate any public education activity; to significantly 
 extend the contacts with manufacturers; or to properly evalu- 
 ate the progress, successes and failures of the program. 
 Under these circumstances, it was decided that: 
 
 1. Efforts to develop new labeling specifications 
 for specific products be discontinuted. 
 
 2. A summary and analysis of comments on the pro- 
 posed labeling specification for thermal 
 insulation for homes be completed. 
 
 3. An announcement suspending CPILP be published 
 in the Federal Register. This notice should 
 include a summary of accomplishments and problems 
 of the pilot program. 
 
 4. A report be prepared to document the efforts 
 of the program and to provide a useful basis 
 for making any decisions regarding future 
 Government efforts to provide performance 
 labeling programs for consumer products. 
 
 A notice formally suspending the program was published in 
 the Federal Register on April 2, 1979. 
 
 Based upon the limited experience with a few products, the 
 following recommendations for any future voluntary effort to 
 label performance characteristics of consumer products are 
 made: 
 
 iii 
 
1. A primary concern must be the locating or 
 developing of test methods for the various 
 performance characteristics of interest. 
 Both manufacturers and consumers should be 
 involved in any development effort. Whenever 
 practical, the needed test methods should be 
 developed in conjunction with a recognized 
 consensus standards developing organization 
 (e.g. ANSI, ASTM, etc.). 
 
 2. Provision should be made at an early date to 
 carry on a vigorous public education orogram. 
 
 3. Because of the relatively long period of time 
 required to develop labeling specifications, gain 
 manufacturer participation, and build up consumer 
 usage, a voluntary labeling program should be 
 allowed five years before being finally judged. 
 Funding of the program, by whatever sources are 
 deemed most appropriate, should be assured for 
 
 at least that amount of time before the program 
 
 is commenced. At the end of that period it is 
 
 expected that a fair and objective evaluation of 
 
 the merits of the program to both manufacturers 
 
 and consumers could be made. 
 
 4. Close contacts with manufacturers must be 
 encouraged, particularly with regard to test 
 methods, methods of ratings and establishment 
 of a schedule of fees. If the conduct of a 
 program such as CPILP is not to be dependent 
 upon public funding, reliance must be placed 
 upon an equitable scheduling of fees with proven 
 cost/benefit ratios acceptable to manufacturers. 
 
 5. Consumers and consumer advocate groups must be 
 fully involved in all phases of the program, 
 from product selection to program evaluation. 
 
 IV 
 
1. Introduction 
 
 On May 25, 1977 , the Department of Commerce published 
 Procedures for a Voluntary Consumer Product Information 
 Labeling Program (CPILP) to become effective on June 24 of 
 that year (42 FR 26647) . This program had the goal of 
 making available to consumers, at the point of sale, infor- 
 mation on consumer product performance in an understandable 
 and useful form. The program was also expected to help 
 educate consumers, distributors and retailers in the use of 
 product performance information, to provide manufacturers 
 with a means for conveying to the public the particular 
 advantages of their products in a manner that would gain 
 consumer acceptance and to help facilitate the making of 
 informed decisions by consumers. 
 
 The program was initiated due to the perceived difficulty 
 that consumers have in making rational and accurate market- 
 place decisions because of the lack of comparative, easily 
 comprehensive information on important product performance 
 characteristics at point of sale. Because about one- third 
 of the witnesses who testified at the hearings held to 
 determine whether to institute the program were opposed to 
 it, the Department of Commerce decided to initiate this 
 program on an experimental pilot basis. This approach was 
 used to provide an opportunity to learn how such a program 
 could be most useful and to evaluate its acceptance by 
 manufacturers and consumers for two products before a commit- 
 ment to a continuing program was made. It was intended to 
 evaluate the program at the end of one year before deciding 
 whether to continue it as a permanent program. Experience 
 showed that a year did not allow sufficient time to canvass 
 consumers, manufacturers and other interested parties: to 
 determine which products should be selected as candidates 
 for labeling under the program; to develop acceptable test 
 procedures; to have the labeled products enter the marketplace; 
 and then to evaluate the effectiveness of the program in 
 terms of product performance and sales acceptance as perceived 
 by manufacturers and consumers. 
 
 The all too brief, pilot program did not permit time to 
 develop test methods for objectively measuring product 
 performance characteristics. Recognizing this problem, it 
 became necessary to search for products that were of singu- 
 larly significant interest to consumers, products whose manu- 
 facturers could be expected to cooperate with the program 
 and for which acceptable test methods for rating the most 
 important performance characteristics already existed. 
 
This task proved to be formidable, and the above conditions 
 were not completely met by any of the nine products that were 
 examined in some depth. In particular, test methods that 
 could be used to measure adequately the characteristics 
 of interest and that were acceptable to most manufacturers and 
 consumers generally were not available. It became evident 
 that a more significant effort than had been expected would be 
 required to provide such test methods. By the time the vear 
 long pilot program was over it became clear that a minimum 
 of about 5 years would be required to test the effectiveness 
 and acceptance of the program. The economic pressures of the 
 day were causing the Administration to cut back programs of 
 long standing. It was not surprising, therefore, that the 
 decision was made to suspend CPILP indefinitely. 
 
 2. Background 
 
 Among the complexities of the consumer product marketplace 
 are certain technical problems relating to the development 
 of product standards and test methods, the evaluation of 
 product performance, and the establishment of means by which 
 both large-scale and individual consumers may knowledgeably 
 compare the attributes of the various products available to 
 them. The extent to which Government programs and activities 
 should address these technical problems has been the subject 
 of controversy for many years, and the debate still continues. 
 In particular, the National Bureau of Standards (NBS) frequently 
 has been criticized by members of the scientific community, 
 government, industry, business and consumer organizations 
 for being either too closely involved in, or too distantly 
 withdrawn from (or sometimes both simultaneously) the 
 technical problems of the marketplace. Some of the early 
 controversies, described in some detail in Measures for Progress , 
 A History of the National Bureau of Standards [1], were 
 sufficiently traumatic to cause NBS to adopt a very cautious 
 approach to consumer product related problems. 
 
 Starting about fifteen years ago, the consumer product 
 marketplace experienced an increase in the relative influence 
 of consumers and consumer organizations. This influence was 
 expressed in part through the passage of a series of bills 
 addressing consumer problems and in the insertion of consumer- 
 oriented provisions in bills addressing other national problems 
 such as the energy shortage. For example, a landmark of consumer 
 influence was the passage, after years of debate, of the Fair 
 Packaging and Labeling Act in 1966. Other recent legislation 
 that was influenced significantly by consumers includes the 
 Child Protection Act (1966), Highway Safety Act (1966), 
 National Commission on Product Safety (1967) , Fire Research 
 
and Safety Act (1968), Consumer Credit Protection Act (Truth 
 in Lending) (1968), Child Protection and Toy Safety Act (1969), 
 Public Health Cigarette Smoking Act (19 69), Poison Prevention 
 Packaging Act (1970), Lead-Based Paint Elimination Act (1970), 
 Environmental Protection Agency Act (19 70) , Motor Vehicle 
 Information and Cost Savings Act (1972), Consumer Product 
 Safety Act (1972), Noise Control Act (1972), Fire Prevention 
 and Control Act (1974), Magnuson-Moss Warranty Act (1975), 
 Energy Policy and Conservation Act (1975) , Energy Conservation 
 and Production ^ct (1976), Consumer Goods Pricing Act (1977), 
 and the National Energy Act (1978) . The defeat of the Agency 
 for Consumer Advocacy Bill in 19 78 was interpreted by some as 
 being a landmark of successful business-industry opposition 
 to some aspects of this stream of consumer-oriented legislation. 
 Although the defeat of the Consumer Advocacy Bill was a major 
 set-back for the consumer movement, it is anticipated that the 
 introduction of donsumer-oriented legislation in the Congress 
 will continue. 
 
 The flow of consumer-oriented legislation resulted in increased 
 interaction between Federal agencies and other participants in 
 marketplace activities. The Department of Commerce, through 
 NBS, became increasingly involved in problems related to consumer 
 product technology, particularly with regard to product safety 
 and product energy usage. This work included working closelv 
 with other agencies, particularly regulatorv agencies, in the 
 development of test methodologies. This involvement increased 
 to the point where it became practicable and desirable to 
 establish in 1974 a Center for Consumer Product Technology 
 within NBS. The function of the Center was to manage the 
 various consumer product related programs and to attempt to 
 anticipate future developments in that program area. It was 
 within this general framework of legislated responsibilities 
 in consumer product technology that the Department became 
 involved in consumer product performance labeling. 
 
 The Origin of CPILP . The first of the specific events that 
 led to the development of CPILP was President Nixon's consumer 
 message of October 30, 1969. That message, the content of 
 which had been coordinated with the Department of Commerce, 
 contained the following passage: 
 
 "No matter how alert and resourceful a purchaser 
 may be, he is relatively helpless unless he has 
 adequate, trustworthy information about the product 
 he is considering and knows what to make of that 
 information. The fullest product description is 
 useless if a consumer lacks the understanding or 
 the will to use it." 
 
In support of this passage, the Administration in 1969 
 introduced in the 91st Congress the first of a series of 
 consumer product test method bills. Similar bills were 
 introduced in each succeeding Congress. None of these 
 bills has passed. 
 
 The various consumer product test method bills introduced were 
 intended to require that consumer product performance test 
 methods be developed and that the product performance measure- 
 ments made through the use of these test methods be furnished 
 to consumers by various means -- chiefly by product labeling. 
 The bills usually prescribed a major role for NBS in the 
 development of the needed test methods. If passed, some 
 of the bills would have resulted in the establishment of 
 voluntary labeling programs, while others would have made 
 such labeling mandatory. Hearings were held in connection 
 with the consideration of some of the bills. Oficials of the 
 Department testified at these hearings, generally supporting 
 the idea of developing needed consumer product performance 
 test methods and providing consumers with objective product 
 performance information. The Department consistently favored 
 the concept of voluntary labeling programs as opposed to 
 mandatory programs. 
 
 The testimony of the Department with regard to product 
 performance labeling was based on studies of programs existing 
 at that time. In particular, several European voluntary 
 programs appeared to be oromising: these are described in 
 detail in European Informative Labeling [2] and Consumer 
 Information Handbook: Europe and North America [ 3] , books 
 which became available in 1973 and 1974. The Department, 
 particularly NBS, corresponded with the agencies responsible 
 for the major European programs, studied available literature 
 and discussed performance labeling problems with a number of 
 consultants. Existing Federal labeling programs, special- 
 purpose rather than general product performance labeling 
 programs, were also examined. Many of these were described 
 concisely in Background Document for Product Noise Labeling 
 [4] . These studies resulted in a concept for the type of 
 product performance labeling program suitable for use in the 
 United States, if any such program were to be adopted. 
 
 Even after the consumer product test method bills failed to 
 pass in the 91st and 92nd Congresses, interest in such 
 programs remained high at the Department of Commerce. In 
 June, 1972, the DoC General Counsel advised the Secretary 
 that, in his opinion, DoC had sufficient authority to carry 
 out a voluntary consumer product Labeling program without 
 
 4 
 
special legislation. He recommended that such a program be 
 undertaken, and the Assistant Secretary for Science and 
 Technology supported his recommendation. At NBS , the study 
 of performance labeling programs continued, with the first 
 outline for a DoC program being completed in November, 19 72. 
 
 Appliance Energy Labeling . As plans for a possible labeling 
 program were being developed, the energy crisis came into 
 being and caused a rethinking of program priorities. 
 President Nixon's Energy Message of April, 1973, which had 
 been coordinated with DoC, directed that DoC develop a 
 voluntary program for the labeling of household appliances 
 and equipment with respect to their energy efficiency. The 
 existing program plans were revised to meet this new objective. 
 
 The appliance industry cooperated fully in the development 
 and implementation of the appliance energy labeling program. 
 The program procedures were developed quickly and room air 
 conditioners, for which energy usage measurements were 
 already published by a trade association, were labeled 
 within about one year. The labeling of other products 
 progressed more slowly. The schedule of major documents 
 published was as follows: 
 
 Date Published in 
 Federal Register 
 
 DOCUMENT 
 
 PROPOSED 
 DOCUMENT 
 
 ^INAL 
 DOCUMENT 
 
 Program procedures 
 
 Room air conditioner labeling 
 
 Refrigerator labeling 
 
 Refrigerator-freezer labeling 
 
 Freezer labeling 
 
 Water heater labeling 
 
 Clothes dryer labeling 
 
 6-5-73 
 1-31-74 
 12-31-74 
 12-31-74 
 12-31-74 
 8-14-75 
 12-12-75 
 
 10-26-73 
 
 5-1-74 
 
 8-1-75 
 
 8-1-75 
 
 8-1-75 
 Not published 
 Not published 
 
 The final procedures for this program constitute 15 CFR Part 9. 
 Letters received in response to publication of the proposed 
 procedures, and an analysis of these letters, are available 
 for inspection or copying in the DoC Central Reference and 
 Records Inspection Facility, Room 5317, Main Commerce Building, 
 14th Street between E Street and Constitution Avenue NW, 
 Washington, D.C. 20230. 
 
Further detail on the initial operation of the program is 
 provided in Voluntary Labeling Program for Household Appliances 
 and Equipment to Effect Energy Conservation; Annual Report 
 for Calendar Year 19 74 [5] . 
 
 In March, 1975, a related voluntary appliance energy efficiency 
 program that did not involve labeling was also initiated by 
 the Department of Commerce. This program, which provided 
 efficiency targets for manufacturers, was largely based on 
 information developed during the course of the voluntary 
 labeling program. During 1975, proposed efficiency targets for 
 twelve major appliances were published in the Federal Register. 
 This program was superseded by a mandatory program, and 
 was therefore terminated on April 5, 19 76. A public docket 
 on this program is available for inspection or copying at 
 the DoC Central Reference and Records Inspection Facility at 
 the address previously provided. 
 
 The passage of the Energy Policy and Conservation Act (1975) 
 and the Energy Conservation and Production Act (1976) by the 
 94th Congress established requirements that mandatory appliance 
 labeling and appliance efficiency programs be developed and 
 administered by the Federal Trade Commission and the Federal 
 Energy Administration (now Department of Energy) respectively. 
 In April, 19 76, it was announced that the voluntary energy 
 efficiency program was rescinded and that the voluntary 
 energy labeling program would be maintained only until it 
 had been supplanted by the required mandatory program. 
 However, the mandatory programs, which are still under 
 development, are not patterned directly after the DoC/NBS 
 programs which were supported by the Appliance Industry. 
 Many aspects of the new programs have been and are being 
 criticized and, in fact, some of the program requirements 
 were revised with passage of the National Energy Act (1978) . 
 
 A Decision for CPILP. Though the voluntary appliance energy 
 programs had to be abandoned, the favorable industry response 
 to those programs increased the Department's interest in a more 
 general voluntary consumer product performance labeling program. 
 A new outline for a possible voluntary DoC/NBS program was 
 completed in September, 1975, and a draft initiative for the 
 program was submitted for aoproval in November, 19 75. In the 
 meantime, a new consumer product test method bill detailing 
 a mandatory labeling program was introduced in the 9 4th 
 Congress. DoC officials testified on that bill in November, 
 1975. However, this bill did not pass, and the decision was 
 made to initiate a voluntary DoC/NBS program, provided that 
 adequate public support could be demonstrated. 
 
3. The Development of CPILP 
 
 The Concept in 1975 . The consumer product performance 
 information labeling program envisioned by the Department of 
 Commerce in 19 75 was patterned largely after the European -- 
 particularly the Swedish and German — programs. Only those 
 performance characteristics measurable by objective means 
 would be shown on labels, existing standards and test methods 
 would be used wherever possible, manufacturers would be 
 responsible for measuring the performance of their own 
 products and for the accuracy of those measurements, and 
 there would be no minimum performance levels imposed by the 
 labeling program. Labeling specifications were to be developed 
 by the Department of Commerce with the assistance and coopera- 
 tion of all interested parties, including consumers. The DoC 
 program would not cover food and drugs, automobiles, or 
 other products already covered by comprehensive labeling 
 programs or regulations of other Government agencies. The 
 penalty for mislabeling under the program would be removal 
 of the guilty party from the program, after due consideration. 
 However, parties who mislabeled might also be susceptible to 
 legal action, e.g. by the Federal Trade Commission. 
 
 A number of questions about the program still existed. For 
 example, should the program be considered a general benefit for 
 all consumers, to be supported by general funds, or should it 
 be considered a particular benefit only for the manufacturers 
 and consumers of labeled products, and therefore be supported 
 by product labeling fees? z^nd who should select the products 
 to be labeled, (a) the program administrators, or (b) an 
 advisory committee of manufacturers, consumers, and other 
 interested parties? Also, it was realized that although the 
 benefits of the development and use of standardized per- 
 formance measurements were being demonstrated in the market- 
 place every day, the need for a Federal labeling program of 
 this type had not been proven conclusively. It was felt 
 that the public should have ample opportunity to comment on 
 such questions. 
 
 Development of the Procedures . Proposed procedures for the 
 Voluntary Consumer Product Information Labeling Program (CPILP) 
 were developed and published for public comment in the 
 Federal Register on May 25, 1976 (41 FR 21389, see Appendix A) . 
 The procedures provided for the establishment of fees for 
 labeling. The use of an advisory committee to select products 
 to be labeled was not planned. The proposed procedures were 
 accompanied by a notice listing several areas in which comments 
 would be particularly appreciated. In addition, public hearings 
 were held in Los Angeles, Chicago, and Washington, D.C. in 
 June, 1976, to provide further opportunity for public comment. 
 The hearings were chaired by the Assistant Secretary for 
 Science and Technology. 
 
In response to the publication of the proposed procedures, 
 seventy-five letters of comment were submitted bv the public 
 and twenty-two persons testified at the hearings. The 
 categories of respondents and the principal issues they 
 discussed are shown in Table 1. The comments are summarized 
 and analyzed in Summary and Analysis of Public Comments on 
 Proposed Procedures for a Voluntary Consumer Product Information 
 Labeling Program [6]. The letters and the analysis are avail- 
 able for inspection or copying in the DoC Central Reference 
 and Records Inspection Facility at the address previously 
 provided. 
 
 The most significant aspect of the public comment was the 
 divergence of opinion as to whether CPILP should be initiated. 
 In general, large corporations and trade associations opposed 
 initiation of the program. These organizations, sensitive to 
 the manner in which the voluntary appliance energy labeling 
 program had been replaced by a program mandated by legislation, 
 protested that initiation of a voluntary general labeling 
 program might pave the way for initiation of a mandatory 
 program. Consumers, consumer organizations, smaller manu- 
 facturers, and government agencies generally favored initia- 
 tion of the proposed voluntary program. With regard to the 
 actual provisions of the procedures, the Dublic comment did 
 not indicate that any major revisions were required. Therefore, 
 the final procedures were not substantially different from 
 the proposed procedures . 
 
 In 1976 and early 1977, organizational and personnel changes 
 were made at DoC and NBS that brought a number of new people 
 into active involvement with the program. These changes, 
 some of which were occasioned by the results of the 19 76 
 general election, necessarily delayed the progress of CPILP and 
 resulted in the reexamination of some of its structure. When the 
 final program procedures were approved in May, 19 77, urogram 
 operation was approved on a one-year pilot basis and only six 
 of the originally planned twenty-four personnel slots became 
 available. During the pilot program, two consumer products 
 were to be labeled. Since test methods and product labeling 
 specifications could not be developed within that time frame, 
 this meant that initiallv only products for which test methods 
 already existed could be labeled. The thrust of the program 
 was thus changed from one of developing needed test methods 
 to one of deploying labels as quickly as possible based on 
 existing test methods. The final procedures and the accompany- 
 ing notice were published in the Federal Register on May 25, 
 1977, (42 FR 26647) exactly one year after the proposed pro- 
 cedures had been published (See Appendix B) . 
 

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In an attempt to increase manufacturer support for the program, 
 the procedures were amended on November 4, 1977, (42 FR 57686) 
 to permit the Secretary to suspend the establishment of fees 
 and charges, at least for the duration of the nilot program, 
 (see Appendix B) . Although the program originally had been 
 designed to become self-sustaining in just a few years by 
 charging fees, because of the need to get some experience 
 with the program during the pilot year it was decided that 
 suspension of the fees was desirable as an added inducement 
 to manufacturers to participate in what amounted to an 
 experiment. 
 
 The procedures as first published stated that product 
 performance characteristics which are labeled under other 
 Federal programs would not be included on CPILP labels for 
 the specified product. However, it became evident during 
 the work on labeling of thermal insulation, discussed in a 
 subsequent section of this report, that CPILP could potentially 
 simplify Federal labeling requirements for manufacturers by 
 including on CPILP labels all or many of the characteristics 
 covered by other Federal urograms, providing CPILP require- 
 ments were compatible with the requirements of the other 
 Federal programs. The procedures were amended on 
 March 1, 1978, (43 FR 8254) to permit the inclusion 
 of characteristics covered by other Federal programs 
 on CPILP labels, providing the involved Federal agency 
 agreed to such inclusion (see Appendix B) . 
 
 The two amendments to the procedures did not attract much 
 
 public comment when proposed. The letters of comment 
 
 received and the analyses of the comments are available 
 
 for public inspection or copying in the DoC Central Reference 
 
 and Records Inspection Facility at the address previously 
 
 given. 
 
 The program procedures (Appendix B) constitute 15 CFR 
 Part 16. An abstract of the procedures as amended is 
 provided in Appendix C. 
 
 4. Selection and Labeling of Products 
 
 The labeling of a class of products under CPILP would require 
 a number of identifiable steps starting with the selection 
 of a product and continuing to the evaluation of the effective- 
 ness of the program. These steps are shown in Figure 1, 
 generally in chronological order. The following is a 
 description of these steps as imolemented during the pilot 
 period. 
 
 10 
 
11 
 
The product selection process began with the receiot of a 
 request that a product be labeled. Such requests were 
 solicited from the general public (including consumers, 
 manufacturers, distributors, and government agencies) 
 through general and trade news media publicity, through the 
 distribution of brochures to manufacturers and consumers, 
 and through personal contacts. Examples of the brochures 
 are provided in Appendix D. As a result of these efforts 
 a total of 145 different products or product categories 
 were suggested for inclusion in the program. A summary of 
 the letters received during the first year of the program 
 is given in Appendix E. 
 
 As the suggestions for products to be labeled were received, 
 they were acknowledged and reviewed to determine whether they 
 were products that might readily be labeled during the pilot 
 program. Some categories, such as food, prescription drugs 
 and plants, were excluded as being within the jurisdiction 
 of other government agencies. Because of the time constraints 
 of the pilot program, the possible products were further 
 limited to those for which test methods were thought to be 
 available or which it seemed important to label at an early 
 date. Nine product clases were selected for further 
 examination. These were: 
 
 Carpeting 
 
 Dry cell batteries 
 
 Electric irons 
 
 Home insulation 
 
 Luggage 
 
 Paint 
 
 Plumbing Fittings 
 
 Smoke detectors 
 
 Vacuum cleaners 
 
 In order to assist in the systematic review of products 
 being considered for labeling, criteria for determining 
 whether a product was appropriate for labeling under CPILP, 
 and a method for examining a product with respect to these 
 criteria, were developed and described in NBSIR 78-1450, 
 "Product Selection for the Voluntary Consumer Product 
 Information Labeling Program." [7] A useful feature of this 
 report is a decision tree chart that simplifies and systema- 
 tizes the selection of products that are likely candidates 
 for labeling. Examination of the products resulted in 
 Preliminary Product Reports which were reviewed by the pro- 
 gram management in deciding which products to include in 
 the program. Each of the nine products considered is 
 discussed later in this reoort. 
 
 12 
 
As products were chosen for inclusion in the program, work 
 was initiated on developing a Finding of Need, a determina- 
 tion of the need for an Inflationary Impact Statement, 
 and a Labeling Specification. 
 
 A Finding of Need to label a product that was developed 
 under CPILP addressed the eight points of Section 16.4 
 of the Procedures (Appendix B) . The finding was based upon 
 the preliminary product report and further information 
 gathered through literature search, contacts with consumers 
 and consumer groups, and contacts with manufacturers and 
 distributors. The need for an inflationary impact statement 
 was determined by estimating the effect of the costs to 
 manufacturers and consumers of adding the label to a product, 
 including additional testing required. These documents for 
 thermal insulation for homes are given in Appendix F. 
 
 The development of a Labeling Specification involved several 
 interrelated steps. These included: 
 
 (1) Selection of characteristics to be 
 shown on the label, 
 
 (2) Selection (and development, if necessary) 
 of test methods, 
 
 (3) Development of rating schemes for 
 presenting test results, and 
 
 (4) Design of the label. 
 
 The selection of characteristics and test methods required 
 significant input from consumers, potential participants 
 (primarily manufacturers) and testing laboratories to insure 
 that all included characteristics were important, that the 
 most important characteristics were included, that the 
 chosen characteristics could be measured and rated reliably, 
 and that the burden of rating and labeling would not exceed 
 the benefits derived from them. This was accomplised through 
 the use of interviews with focus groups (Sounding Boards, PTA. 
 groups, etc.), meetings with consumer organizations, meetings 
 with manufacturer and trade association representatives, and 
 extensive personal contacts. A total of 37 meetings were held 
 during the pilot program. A listing of these meetings is 
 provided in Appendix G. These meetings were useful for 
 establishing priorities for products and product characteristics, 
 for developing methods for rating and p? ^ntation that were 
 technically correct, and also meaningful t^ consumers for 
 identifying possible test methods and their weaknesses, and 
 for informing interested parties of the existence and purpose 
 of the program. 
 
 13 
 
The development of rating schemes and design of the label 
 took into consideration the need for the information nre- 
 sented to be easily understood and used to compare competing 
 products by unsophisticated consumers. At the same time, 
 the ratings and presentations must be technically correct 
 and acceptable to the expected program participants. In 
 addition, it was desirable that the labels for all products 
 have some common characteristics that would readily identify 
 them with the program. To achieve this, the input from 
 consumers, manufacturers, etc. was supplemented by a study 
 made by Marketing Science Institute (under contract to the 
 National Bureau of Standards) on the labeling of insulation, 
 smoke detectors and vacuum cleaners. (Appendix H) 
 
 Based upon all of the information available on thermal 
 insulation for homes, a proposed Labeling Specification was 
 prepared. The document included sections on purpose; scope; 
 definitions; how to initiate and terminate participation; 
 conditions for participation; identification, description 
 and use of methods for rating each characteristic; use 
 of the label on products and in advertising; and proposed 
 label design. The proposed specification was subjected 
 to comprehensive technical, policy and legal review prior to 
 publication in the Federal Register. The Proposed Specifica- 
 tion for Labeling of Thermal Insulation for Homes (43 FR 
 23488) is included as Appendix I. The Federal Register 
 notice accompanying the proposed specification invited 
 comments from all interested parties, including informal 
 hearings if requested. The comment period was 45 days. 
 
 The comments received were carefully reviewed and considered 
 in view of the purpose and operation of the program. This 
 review was documented in a Summary and Analysis, a working 
 document that is available in the Department of Commerce 
 Central Reference and Records Inspection Facility, at the 
 address previously provided. No hearings were requested. 
 
 Based upon the comments on the proposed labeling specifica- 
 tion and other information that became available, one of the 
 following actions could have been taken: 
 
 (1) A final specification, including minor modifications 
 if needed, could be published in the Federal Register. 
 
 (2) Major changes could be made and a new proposed 
 specification published in the Federal Register; or 
 
 (3) A Federal Register notice could be published 
 withdrawing the proposed specification. 
 
 14 
 
In the first case, the final specification would contain 
 essentially the same information as the proposed document 
 plus a brief summary of the comments received and changes 
 made and an effective date for starting the program. If 
 major or controversial changes were made as a result of 
 comments, it would be appropriate to allow the people 
 concerned to comment on such changes . Another proposed 
 specification with an additional comment period would be a 
 proper way to do this. If it became evident that there were 
 major flaws in the proposed specification and these could 
 not be rectified without making the program for that product 
 unacceptable, it would be in order to withdraw the proposed 
 specification. It might also be appropriate to withdraw the 
 document if it were obviously oremature, e.g. new test 
 methods would soon be available, or if, as in the present 
 case, the whole program were to be suspended or terminated. 
 The appropriate document would be published in the Federal 
 Register after comprehensive technical, policy and legal 
 review. Such a notice withdrawing the proposed specification 
 for Labeling of Thermal Insulation for Homes with the sus- 
 pension of the Consumer Product Information Labeling Program 
 was published on April 2, 1979 (44 FR 19222) (See Aopendix J) . 
 
 As stated above CPILP was intended to be a self supporting 
 program depending upon fees paid for the use of the labels 
 to offset operating costs. Therefore, a schedule of fees 
 would usually be developed and published in conjunction with 
 the labeling specification. The fees would be based upon 
 projections of label usage and operating costs and could be 
 adjusted as necessary. However, since the pilot program was 
 intended to be a learning experience and to provide an 
 opportunity to evaluate the acceptance and usefulness of the 
 program, it was decided to drop the fees in the hope that 
 this would be an added inducement to manufacturers to partici- 
 pate in the program. Accordingly, the procedures were 
 amended to permit the Secretary of Commerce to suspend the 
 fees at her discretion. (See Appendix B) . The Secretary 
 was prevailed upon to exercise this option, at least during 
 the pilot program, and therefore no fees were proposed. 
 (Note: If the program should be resumed in the future, 
 serious consideration should be given to inclusion of a 
 schedule of fees in order to avoid the heavy economic 
 burden that forced the suspension of the fledgling program.) 
 
 It was generally accepted that during the early part of the 
 Program an extensive public education program would be needed 
 to make consumers aware of the labels and how they could be 
 used to make better purchase decisions and to generate 
 the interest of manufacturers and distributors in participating 
 in the program. Plans were being made for such a public 
 education program, including a full time public information 
 specialist, when the decision to suspend the program was made. 
 
 15 
 
5. Labeling Efforts for Specific Products 
 
 Nine products were examined to determine whether it was 
 feasible to develop labeling specifications and labels for 
 them during the pilot period. The results of the examination 
 of each of these products are summarized in the following. 
 
 5.1 Thermal Insulation for Homes 
 
 Early in the program, letters were received requesting that 
 thermal insulation for homes be labeled. During this time 
 homeowners were being encouraged to insulate their homes by- 
 Government actions and by the high cost of energy for heating 
 and cooling. ?Vt the same time questions were being raised 
 about the effectiveness and safety of various insulating 
 products. An informal survey of some local outlets for home 
 insulation showed considerable difference in the amount of 
 information given on the products and in the probable useful- 
 ness of this information to the average consumer. It was 
 also found that there were existing test methods that purported 
 to measure most of the characteristics of insulation that 
 were thought to be of principal concern to the consumers. 
 It was therefore decided to proceed with the development of 
 a Finding of Need to Label Thermal Insulation for Homes. 
 
 To develop the Finding of Need and gather information for 
 use in developing a labeling specification, meetings were 
 held with representatives of Government agencies, industry 
 and consumer advocates. A series of meetings were also held 
 with Consumer Sounding Boards and other consumer focus 
 groups. The results of these meetings confirmed the interest 
 of consumers in labeling of this product, identified the 
 characteristics that were of primary concern, and showed a 
 mixed reaction by manufacturers with respect to support for 
 the program but a general willingness to assist in the program 
 management's consideration of the feasibility of this effort. 
 Also, considerable interest was shown by other Government 
 agencies in various aspects of insulation use which could 
 influence a labeling effort. 
 
 The other agency interests that were particularly significant 
 were (1) revision of GSA Federal Specifications, (2) a 
 proposed FTC Trade Regulation Rule requiring disclosure of 
 R-Value and area coverage information, (3) pressure for a 
 CPSC mandated safety standard for cellulose insulation, (4) 
 a possible tax rebate for improving the energy efficiency of 
 homes, and (5) the Voluntary Laboratory Accreditation Program 
 for laboratories that test thermal insulation administered 
 by the Department of Commerce. It also seemed orobable that 
 the sale of insulation would peak in the near future, and 
 that a C p ILP label, to be most effective, should become 
 
 16 
 
available as soon as possible to assist consumers during 
 this time. A Finding of Need was therefore completed and 
 published in the Federal Register on December 14, 1977 
 (42 FR 62946) (see Appendix F) . Because of the interest of 
 other Government agencies in this product, as stated before 
 the CPILP Procedures were amended to permit CPILP labels 
 to include information about certain performance character- 
 istics when another Federal agency requires labeled informa- 
 tion about those characteristics if the other agency agrees. 
 (See Appendix B) . In this way CPILP was seen as a means of 
 consolidating labeling requirements and reducing the labeling 
 burden for participants. 
 
 Additional meetings were held with focus groups, manufacturer 
 representatives, Government agencies and consumer advocates 
 to discuss rating and labeling plans, suitability of test 
 methods, label design, etc. It became apparent that some of 
 the test methods, particularly those concerned with fire 
 properties and corrosiveness, were controversial. New test 
 methods for flame spread resistance were being proposed in 
 the revised Federal Specifications while congressional action 
 was directed towards mandating the use of the test method 
 generally used in building codes. Since no correlation had 
 been established between the two methods, the possibility of 
 using ratings based on both methods in the CPILP label was 
 suggested. 
 
 Considering the input received from consumers, manufacturers, 
 Government agencies and technical consultants at NBS, it was 
 decided to propose including the following factors on labels 
 for thermal insulation for homes: 
 
 1. Identification of material and its form 
 
 2. Place in home recommended for use 
 
 3. R-Value and area covered per package 
 
 4. Resistance to surface flame spread 
 
 5. Resistance to smoldering 
 
 6. Flame spread classification 
 
 7. Corrosiveness 
 
 8. A unit pricing factor based upon insulating 
 ability. 
 
 17 
 
Rating schemes for those factors were developed using existing 
 and proposed test methods, and a proposed label was designed to 
 show these ratings in a clear, easily understandable way. 
 This information was combined with program information 
 specifically related to thermal insulation for homes into a 
 Proposed Specification for Labeling of Thermal Insulation 
 for Homes. After thorough technical, policy and legal 
 review this document was published in the Federal Register 
 on May 30, 1978, (43 FR 23488) (See Appendix I) . 
 
 In response to the Proposed Specification, 45 letters were 
 received. Most of these letters contained constructive 
 comments relating to the testing, rating and labeling of 
 this product. Five manufacturers apparently thought that 
 the program had been initiated and applied to participate. 
 One letter was completely negative to the program. The 
 other letters contained comments and suggestions for changes 
 and expressed attitudes varying from positive to negative. 
 The comments were reviewed, analyzed and summarized. Some 
 changes to the proposed specification and label were found 
 to be in order. However, it was decided that the program 
 would be suspended and the proposed specification withdrawn 
 because funding for the program was to be drastically curtailed 
 due to efforts to reduce Federal expenditures. The Summary 
 and Analysis of the comments was prepared as a program 
 working document, and is available in the Department of 
 Commerce Central Reference and Records Inspection Facility, 
 at the address previously provided. 
 
 The Federal Register notice suspending the Consumer Product 
 Information Labeling Program and withdrawing the pronosed 
 Specification for Labeling of Thermal Insulatioa ."or Homes 
 was published on April 2, 1979 (44 FR 19222) (Appendix J) . 
 
 5.2 Smoke Detectors 
 
 Letters were received requesting that smoke detectors be 
 included in the labeling program early in the program. This 
 interest was prompted by the number of jurisdictions which 
 were contemplating or had adopted mandatory requirements for 
 the installation of residential smoke detectors. At that 
 time at least 3 3 states and about 25 percent of the cities in 
 the United States had some requirements for smoke detectors . 
 A report to the National Fire Prevention and Control Admin- 
 istration (NFPCA) stated that the information available to 
 consumers on smoke detectors was generally inadequate and in 
 specific instances misleading. 
 
 Meetings were held with other Government agencies, industry 
 representatives, consumers and consumer organizations to 
 determine the interest in including smoke detectors, and to 
 develop a list of performance attributes that were of 
 primary concern to these groups. 
 
 18 
 
There was strong support from the Government agencies, 
 consumers, and the consumer organizations for the labeling 
 of smoke detectors, and negative reaction from the industry 
 groups . 
 
 In developing the Finding of Need and in gathering informa- 
 tion for use in a labeling specification it was discovered 
 that a controversy existed between the manufacturers of the 
 two major types of smoke detectors, ionization and photo- 
 electric. The basis of this controversy was a possible 
 deficiency in Underwriters Laboratories Standard UL-217, the 
 primary standard used to test and evaluate smoke detectors, 
 with respect to a test method for response to "smoldering 
 fires". The proposed test method circulated by UL had been 
 withdrawn for further study and evaluation. Alternate test 
 methods for response to test fires proposed by several 
 European establishments had not been evaluated in the U.S. 
 Considerable discussions on the controversy between the 
 ionization and photoelectric types appeared in various 
 journals, such as the "World of Fire" and the "Appliance 
 Manufacturer." Since the controversy was not within the 
 scope of the CPILP it was decided to continue with the 
 development of a Finding of Need to Label Residential 
 Smoke Detectors. 
 
 In the discussions and meetings with industrv, Government 
 agencies and consumer organizations, a listing and ranking 
 of performance characteristics which could appear on the 
 product label were developed. The list of characteristics 
 were : 
 
 Sensitivity to various types of fires 
 
 Reliability 
 
 Sound level 
 
 Test feature 
 
 Power source 
 
 Sensing Mode - type of detector 
 
 Restrictions in use 
 
 Duration of trouble signal 
 
 Test frequency 
 
 Installation information 
 
 Battery availability 
 
 False alarm rate 
 
 Special features 
 
 Lamp replacement 
 
 Various agencies in both industry and Government are engaged 
 in improving existing test methods and developing alternative 
 test methods for determining the response of smoke detectors. 
 Attempts were made to obtain, for analysis, data from existing 
 test methods used to test and rate smoke detectors. These 
 attempts were unsuccessful. 
 
 19 
 
A Finding of Need to Label Residential Smoke Detectors was 
 developed. The Finding of Need stated that if suitable 
 tests were developed and verified for establishing response 
 ratings, they would be included in the Proposed Specification 
 for Residential Smoke Detectors. The Finding of Need to 
 Label Residential Smoke Detectors was submitted to the 
 Department of Commerce. However, the decision to suspend 
 CPILP was made before the document was reviewed and published 
 in the Federal Register. 
 
 5.3 Electric Irons 
 
 One of the first products considered as a possible candidate 
 for the development of a consumer product information label was 
 electric irons. This selection was made before the program 
 brochures were distributed to consumers or industry. 
 However, a letter had been received from a consumer requesting 
 that electric irons be included in the products to be labeled. 
 
 Some of the typical problems which might be encountered with 
 electric irons include: 
 
 1. Inaccurate temperature control could damage fabrics 
 
 2. Boil-over of excess steam or poor handle design 
 could cause burns to users 
 
 3. Uneven temperature distribution, poor spray or 
 steam pattern, or buildup of starch or other material 
 on soleplate could make ironing difficult 
 
 4. Breakage when dropped or buildup of deposits in 
 steam system could result in financial loss. 
 
 As a part of the decision process in the selection of a product 
 for labeling, a list of possible performance attributes to be 
 included on the label was developed. These attributes were: 
 
 Temperature "overshoot" on initial heatup 
 
 Soleplate temperature distribution 
 
 Heatup and cooldown time 
 
 Normal cyclic variation in soleplate temperature 
 
 Accuracy of temperature control 
 
 Steam rate and steam pattern 
 
 Tank capacity (or spray/steam duration) 
 
 Weight/balance 
 
 Stability at rest 
 
 Impact resistance 
 
 Electrical oower requirement 
 
 Electrical safety 
 
 Thermal safety 
 
 20 
 
A survey of standards and test methods indicated that test 
 methods already existed for some of these characteristics. 
 It was thought that the other test methods needed could be 
 developed quickly. 
 
 A total of 29 manufacturers and private brand labelers of 
 electric irons were listed in "Appliance Manufacturer" - 
 1977-78 Annual Directory of the Appliance Industry. On 
 September 7 , 1977 a meeting was held at the Department of 
 Commerce with the Association of Home Appliances Manufacturers 
 (AHAM) , several manufacturers of electric irons, and CPILP staff 
 personnel to discuss CPILP and to get the private sector's 
 reaction to the possible labeling of electric irons. The 
 trade association and the manufacturers objected to including 
 electric irons because the important test methods were not 
 developed and the test results of established methods were 
 difficult to define. The consensus of the association and 
 the manufacturers was that to develop and adopt needed test 
 methods and resolve the difficulties with present methods 
 would take several years. 
 
 As a result of this meeting, the decision was made not to 
 include electric irons as a possible candidate for product 
 information labeling during the pilot period. 
 
 5.4 Luggage 
 
 As a result of interest in CPILP by a leading luggage 
 manufacturer, it was decided to explore the possibility of 
 including luggage as a candidate for product labeling. 
 
 Following is a list of possible performance attributes 
 developed as a part of the process for selection. 
 
 Durability under rough handling 
 
 Handle strength 
 
 Capacity of clothing 
 
 Scuff resistance 
 
 Lock (fastener) strength or security 
 
 Puncture resistance 
 
 Crush resistance 
 
 Protection of fragile packed objects 
 
 Water resistance 
 
 Weight 
 
 Searches were conducted to determine the existence of accepted 
 standards or test methods to evaluate any or all of the 
 possible attributes proposed. It was found that there existed 
 voluntary, Federal and military standards to evaluate some 
 but not all of the attributes. 
 
 21 
 
On September 7 , 1971, two members of the NBS staff visited 
 the Luggage Division of a leading luggage manufacturer 
 to discuss CPILP and the possibility of including luggage in 
 the labeling program. They were given a tour of the manu- 
 facturing and testing facilities of the company. The company 
 also gave a presentation on the in-house standards and test 
 methods used to maintain quality control over the luggage. 
 Over 130 Standard Test Methods (STM's) for various product 
 and material characteristics were used by this company. 
 Many are similar to ASTM or other test methods. 
 
 On September 19, 19 77, a member of the NBS staff visited the 
 facilities of an independent testing laboratory to discuss 
 the testing of luggage. There was a tour of the testing 
 facilities and discussion of the test methods used. It was 
 noted that there were considerable differences between the 
 testing procedures of this testing laboratory and of 
 the luggage manufacturer. The conclusion was reached that 
 there was little or no standardization within the industry 
 in the testing of luggage. 
 
 As a result of these two visits, it was decided that the 
 time needed to develop standardized test methods would not 
 be available within the pilot orogram. Therefore, luggage 
 was not considered to be a possible candidate for inclusion 
 in the labeling program during the pilot period. 
 
 5.5 Carpets 
 
 In the continuing effort to identify a consumer product for 
 which a label and labeling specification could be quickly 
 developed within the one year pilot program limitation, it 
 was decided in the latter part of 1977 to investigate the 
 possibility of carpets as a candidate. There were several 
 factors which made carpets appear to be attractive as a 
 possible candidate. For example: 
 
 1. Carpets are important, high priced items in which 
 consumers have considerable interest. A great deal of test 
 information exists that is not readily available to consumers. 
 
 2. There are well-developed test methodologies, and 
 CPILP could advance the usage of the new methodologies in 
 specific performance areas. 
 
 3. Carpets are of direct interest to several Federal 
 agencies, and NBS was involved in some aspects of performance 
 measurements. CPILP could have possibly simplified Federal 
 labeling requirements by combining elements of the require- 
 ments of different agencies into one label. 
 
 22 
 
4. The Carpet and Rug Institute (CRI) represents 
 manufacturers who produce nearly 80% of the total U.S. 
 production of rugs and carpets. There are also other trade 
 associations which are directly related to the manufacture 
 of carpets, namely the Man-Made Fiber Producers Association, 
 the Jute Carpet Backing Council, the Carpet Cushion Council 
 and the National Congress of Floor Covering Associations. 
 
 As a result of the above, a preliminary product investigation 
 for carpets as a possible candidate was developed. 
 
 The carpet construction and performance characteristics that 
 are frequently measured and used include the following: 
 
 Average pile weight per unit area 
 
 Minimum pile weight of blend per unit area 
 
 Average percentage of fibers in blend 
 
 Average pile thickness 
 
 Average density 
 
 Weight density (the product of weight and density) 
 
 Pile coverage 
 
 Tuft bind 
 
 Secondary backing delamination strength 
 
 Dry breaking strength 
 
 Moth repellancy 
 
 Shrinkage 
 
 Colorf astness to light 
 
 Colorfastness to water 
 
 Colorf astness to ozone 
 
 Dry crocking (color rub-off) 
 
 Wet crocking 
 
 Flammability 
 
 Static control. 
 
 A survey of standards and test methods indicated that u est 
 methods already existed for all of these attributes. rhe test 
 methods were contained in either Federal, private or inter- 
 national test methods or specifications for rugs and carpets. 
 
 The above characteristics do not give consumers direct 
 indication of the ability of carpets to retain their appearance 
 in service. attempts to directly measure, or compute from 
 available data, the appearance retention of carpeting have 
 failed. The International Carpet Classification Organization 
 in Brussels has attempted to develop a categorization system 
 for carpets. The system requires a panel of experts, having 
 access to test data of the type discussed above, to place a 
 sample of carpet into one of five different recommended use 
 categories. This system has not been adopted in the United 
 States . 
 
 23 
 
Carpet cleanability is also important to consumers. However, 
 there appeared to be no test method suitable for determining 
 this attribute. The development of a carpet cleanability 
 rating system should proceed in parallel with the development 
 of a system of rating the cleaning ability of vacuum cleaners. 
 Test methods for evaluating the cleaning ability of vacuum 
 cleaners are in the process of being adopted by a committee 
 of the American Society for Testing and Materials (ASTM) . 
 
 There were 45 test methods, standards or purchase specifications 
 identified which are used to evaluate rugs and carpets. However, 
 there were no identified standardized or adopted methods to 
 evaluate two attributes considered to be of major importance 
 to consumers in selecting carpets, cleanability and appearance 
 retention. 
 
 The time necessary to develop the test methods for these 
 two attributes would have been longer than the time limitation 
 imposed by the pilot program. Therefore, carpets were not 
 considered as an initial candidate for CPILP. 
 
 5.6 Vacuum Cleaners 
 
 NBS interest in the performance labeling of vacuum cleaners 
 began in 1975 before the initiation of CPILP,. This was 
 the result of the Federal Trade Commission (FTC) contract 
 proposal from ASTM to develop or provide existing test 
 methods or standards to evaluate the ability of vacuum 
 cleaners to remove dirt from carpeting. NBS was requested 
 to submit a proposal to evaluate the output of the ASTM 
 contract. NBS staff attended meetings of the ASTM Committee 
 F-ll on Vacuum Cleaners. However, because of budget limita- 
 tions, FTC cancelled these contracts before work was started. 
 
 Because of these prior contacts, vacuum cleaners were con- 
 sidered as a possible candidate product to be included in 
 the pilot labeling program. CPILP personnel attended the 
 ASTM F-ll Committee meetings in March and October, 1977, to 
 explain CPILP and to determine the status of the work of the 
 F-ll sub-committee on Consumer Information. A member of the 
 CPILP staff was invited by the Chairman of F-ll to join the 
 committee and sub-committee on Consumer Information. 
 
 The sub-committee on Consumer Information (F-ll. 9 3) has an 
 active program to develop an information tag and brochures 
 for use by consumers. At the October, 19 77, meeting the 
 Consumer Information sub-committee presented for committee 
 consideration a list of attributes which it considered 
 necessary for listing on an information tag. These are 
 listed below. 
 
 24 
 
Definitely Required 
 
 Cleaning of embedded dirt in carpets 
 
 Surface litter pickup 
 
 Above the floor and bare floor cleaning 
 
 Weight of the cleaner 
 
 Ease of moving the cleaner back and forth 
 
 Capacity of the dirt container 
 
 May be Required 
 
 Noise (sound level) 
 
 Carpet wear 
 
 Durability 
 
 Cord length 
 
 Access depth under furniture 
 
 The F-ll Committee has developed and adopted test methods 
 for all of the above, except cleaning embedded dirt, surface 
 litter pickup, and sound level. The test method for cleaning 
 of embedded dirt was balloted in the main committee, and the 
 surface litter pickup test method in the sub-committee in 
 October, 19 78. 
 
 It is expected that these two methods will be adopted in the 
 near future. Tests for sound level determination will 
 probably use a method developed for the Environmental 
 Protection Agency (EPA) . 
 
 Subcommittee F11.9 3 on Consumer Information has also developed 
 several different methods for presentation of performance 
 attributes on the information tag. These methods are 
 presently being circulated to the members of the F-ll com- 
 mittee for comments. 
 
 It appears that the ASTM Committee F-ll on Vacuum Cleaners 
 will develop and adopt a consumer information tag for use by 
 the manufacturers of vacuum cleaners. Unless it were found 
 to be mutually beneficial to incorporate this information in 
 a CPILP label the ASTM effort could eliminate the need for a 
 CPILP label for vacuum cleaners. 
 
 Because of the decision to suspend CPILP, the staff member 
 was obliged to discontinue working with the sub-committee 
 on Consumer Information. 
 
 25 
 
5.7 Plumbing Fixtures and Fittings 
 
 A California Symposium on March 30, 1977, suggested that 
 plumbing fittings might be a suitable product category to be 
 included in the labeling program. The California Energy 
 Resources Conservation and Development Commission had issued 
 minimum efficiency standards for shower heads and some other 
 residential plumbing fittings for conserving energy and 
 water. On June 24, 1977, invitations were sent to 43 manu- 
 facturers of plumbing fixtures to attend a meeting at NBS on 
 July 7, 19 77. At this meeting the industry representatives 
 were not enthusiastic about the labeling of plumbing fixtures. 
 However, an August 9, 19 77, letter from one large manufacturer 
 indicated that the program had strong support from that 
 corporation. 
 
 A member of the CPILP staff attended a meeting of the 
 Plumbing Manufacturers Institute (PMI) on October 3, 1977, 
 to discuss CPILP with a large number of industry representa- 
 tives. Comments at that meeting indicated that the plumbing 
 fitting and fixture industry was being subjected to many new 
 Federal, state and local testing, performance, and labeling 
 requirements for improving effectiveness in conservation of 
 energy and water. The PMI members expressed new interest in 
 CPILP as a means of standardizing and unifying these 
 governmental requirements. 
 
 On March 10, 1978, PMI issued a press release indicating 
 that PMI would request the Secretary to label plumbing 
 fittings. PMI sent the request to the Secretary on April 4, 
 1978, requesting that shower heads, plumbing faucets, and 
 water closets be included in the labeling program. The 
 Secretary requested that CPILP staff conduct a preliminary 
 investigation of the feasibility of including the product 
 categories in the labeling program. PMI subsequently withdrew 
 the request for including water closets, as no water closet 
 manufacturer was a member of the organization. However, 
 CPILP continued to include water closets in the preliminary 
 investigation. There were no requests from consumers to 
 include plumbing fixtures and fittings in the labeling 
 program. 
 
 PMI ' s request that water closets, shower heads, and faucets 
 be labeled was based primarily on consideration of water 
 conservation. Consumers can adjust the maximum flow of 
 water through shower heads and faucets to achieve conserva- 
 tion and the water usage of water closets can be reduced by 
 dams or water-displacement objects in the closet tank. Most 
 manufacturers are producing low-flow devices. 
 
 26 
 
Therefore the primary reason for the PMI request for 
 labeling maximum flow rates was to help industry 
 standardize the various testing, performance and labeling 
 requirements of Government agencies . 
 
 In addition to the labeling of maximum water flow rates, a 
 study of each product category was made to determine whether 
 other attribtues could be included on the label. The results 
 of these studies are summarized. 
 
 Faucets - The State of California regulations include only 
 kitchen sink and lavatory faucets, and exclude utility 
 faucets, stops or valves used in supply lines to washing 
 machines, dishwashers, and other equioment. The American 
 National Standards Institute (ANSI) test method, ANSI 
 A112. 18. 1-1975, "Finished and Rough Brass Plumbing Fixture 
 Fittings," includes all types of sink, lavatory and utility 
 faucets, valves, and stops for use in residences and in 
 other buildings. The CPILP labeling was considered for only 
 those faucets, stops and valves used in residences. 
 
 Some of the major performance attributes for faucets include: 
 
 Bursting strength 
 
 Mechanical strength 
 
 Maximum recommended working pressure 
 
 Water flow rate 
 
 Operating force or torque 
 
 Durability 
 
 Ease of Repair 
 
 Toxicity of materials 
 
 Backflow prevention 
 
 ANSI A112 . 18 . 1-1975 contains test methods for evaluating 
 most of the above attributes. 
 
 Shower Heads - This category includes shower heads which are 
 mounted directly to rigid supply lines, those which include 
 a flexible hose attached to a rigid supplv line and shower 
 massagers. The category does not include the main fittings 
 or faucets/diverters that control the flow of water. 
 
 The major performance attributes for shower heads include: 
 
 Spray effectiveness 
 
 a. in wetting 
 
 b. in rinsing 
 
 27 
 
Water usage 
 
 Operating pressure range 
 
 Adjustability 
 
 Cleanability 
 
 Backflow prevention 
 
 The ANSI document would provide standard test methods to 
 evaluate the water usage and pressure requirements. A 
 standard test method for determining the effectiveness of a 
 shower spray had not been developed and would probably take 
 some time to develop. 
 
 Water Closets - This category includes residential water 
 closets only. It does not include chemical toilets or water 
 closets for use in boats or recreational vehicles. 
 
 The major performance attributes of water closets include: 
 
 Flushing effectiveness 
 
 a. heavy solids removal 
 
 b. floating solids removal 
 
 c. cleaning above water line 
 
 d. water change 
 
 Water usage 
 
 a. volume of water per cycle 
 
 b. multiple flush factor 
 
 c. afterflow factor 
 
 d. operating pressure range 
 
 e. average and peak supply rate 
 
 f. average and peak discharge rate 
 
 High pressure leakage 
 
 Backflow prevention 
 
 Noise level 
 
 Automatic water shut-off effectiveness 
 
 Seat and cover durability 
 
 a. static strength 
 
 b. impact resistance 
 
 c. dimensional stability 
 
 d. resistance to chemical attack 
 
 There were no suitable, generally accepted tests for flushing 
 effectiveness, and it would require considerable time and 
 effort to develop such a test method. Attempts were made to 
 determine manufacturers' interest in assisting in the develop- 
 ment of a suitable test method without positive results. 
 
 28 
 
PMI , which represents 44 manufacturers of plumbing fixtures 
 and fittings, has an active water conservation committee 
 working on problems associated with code and regulatory- 
 requirements. This committee had requested support in the 
 solution of these problems from the American Society of 
 Plumbing Engineers, the American Society of Sanitary 
 Engineering, the American Supply Association, the American 
 Water Works Association, the Mechanical Contractors Associa- 
 tion, and the National Association of Plumbing, Heating and 
 Cooling Contractors. The committee and supporting organiza- 
 tions planned to meet on June 22, 19 78, to discuss these 
 problems. Plans were formulated at the June 6-8, 1978, 
 meeting of PMI to establish a Committee on labeling. 
 
 NBS has been concerned with the technical problems of 
 plumbing systems design since 1924, and considerable 
 expertise has been developed in this area. 
 
 A preliminary draft of a Finding of Need to Label Residential 
 Plumbing Fittings, not including water closets, was completed 
 in August 1978. The decision to suspend the program was 
 made before the Finding of Need could be completed. 
 
 5.8 Dry Cells and Batteries 
 
 Interest in finding a widely used product that could be 
 labeled quickly led to the consideration of dry cells and 
 batteries. Requests had been received from four individual 
 consumers for such labeling and there was known technical 
 expertise at NBS. 
 
 The preliminary product report showed that available batteries 
 differ greatly in life and cost. Consumer Research Magazine 
 (August 1977) showed lifetimes of a popular size that varied by 
 a factor of more than 3, prices that varied by a factor of 
 about 3, but ratios of life to cost (minutes of life per 
 cent) that varied by a factor of 5. It was also found that 
 different systems used to designate battery size and voltage 
 could result in as many as seven designations for batteries 
 that could be interchangeable for some purposes. On the 
 other hand, it was recognized that such batteries are 
 generally low cost items, frequently less than one dollar, 
 and that physical limitations could make labeling difficult. 
 It appeared that test methods were quite well established by 
 ANSI Committee C 18 so that labeling would be possible if 
 the manufacturers were willing to cooperate and if there was 
 sufficient consumer interest. It was tentatively decided to 
 proceed to develop a Finding of Need to Label Batteries. 
 
 29 
 
As a first step in developing a Finding of Need, meetings 
 were held with two Consumer Sounding Boards and with 
 representatives of manufacturers. The meeting with manu- 
 facturers clearly showed a reluctance to cooperate with the 
 program. Factors that are outside the manufacturers' control, 
 particularly storage conditions; lack of agreement as to 
 test methods for leakage (indicated to be the most serious 
 battery problem) ; and space limitations for labeling were 
 cited as reasons for the reluctance. On the other hand, the 
 manufacturers did seem to be interested in providing informa- 
 tion in the form of a consumer brochure and would probably 
 cooperate with the Department of Commerce if this were 
 undertaken without an accompanying CPILP label. 
 
 The meetings with the Consumer Sounding Boards showed very 
 little interest in the labeling of drv cell batteries. 
 Because of the low unit cost of this product, these consumers 
 seemed to be willing to rely on brand names with which they 
 had satisfactory experience. 
 
 Because of the lack of consumer interest and manufacturers' 
 reluctance, it was decided not to pursue the labeling of dry 
 cells and batteries during the pilot program. 
 
 5.9 Paint 
 
 Letters requesting products which should be labeled included 
 two requests for paints and paint products. One of the 
 requests was from an individual consumer and one from a 
 national consumer organization. The consumer request to 
 label paints came as a result of the consumer's inability to 
 receive information from the paint retailer, manufacturer 
 and other experts on the removal of the product which had 
 spilled on the consumer's carpet. Because of the requests, 
 a preliminary product investigation was developed, in April, 
 1978, to determine if labels and labeling specifications 
 could be developed during the pilot program. 
 
 An article, "Voluntary Performance Rating of Consumer Paints", 
 which appeared in the April 19 78 issue of ASTM ' s "Standardi- 
 zation News", expressed concern over the lack of adequate 
 performance information for paints to allow the consumer to 
 select the paint or paint product to satisfy their particular 
 and specific needs. A.lso, an article by columnist Sylvia 
 Porter entitled, "Tips on Home Painting," resulted in over 
 6,000 requests to the National Paint and Coatings Association 
 (NPCA) for the oaint brochures referenced in the article. 
 
 30 
 
These articles were further evidence of the possible interest 
 of consumers and industry in the development of labels and 
 specifications for paints. 
 
 The preliminary investigation was concerned with paints, 
 interior and exterior, solvent or latex based. Some of the 
 attributes of interest to consumers are different for interior 
 and exterior paints, particularly in durability requirements. 
 Possible attributes for each type of paint are listed 
 below. 
 
 Interior-Solvent or Latex Based Paints 
 
 Type of paint 
 
 Surface characteristics 
 
 Drying time 
 
 Leveling 
 
 Hiding power 
 
 Application properties 
 
 Sag resistance 
 
 Durability 
 
 a. Resistance to household chemicals 
 
 b. Resistance to detergent 
 
 c. Washability 
 
 d. Scrub resistance 
 
 e. Moisture resistance 
 
 f. Flash point 
 
 Exterior-Solvent or Latex Based Paints 
 
 Type of Paint 
 
 Surface Characteristics 
 
 Hiding power 
 
 Leveling 
 
 Drying time 
 
 Durability 
 
 a. Blister resistance 
 
 b. Chalking resistance 
 
 c. Cracking resistance 
 
 d. Checking resistance 
 
 e. Flaking (scaling) resistance 
 
 f. Erosion resistance 
 
 g. Moisture resistance 
 h. Abrasion resistance 
 
 31 
 
A survey of standards and test methods indicated that test 
 methods existed for most of the above attributes in either 
 ASTM Test Methods or the U.S. Federal Test Method Standard 
 No. 141a. 
 
 The ASTM Committee D-l on Paint and Related Coatings and 
 Materials was founded in 1901. This Committee, with the 
 active participation of allied organizations such as the 
 NPCA and the Federation of Societies for Coatings Technology 
 (FSCT) ,. has drafted over 400 standards and test methods for 
 paint and related coatings. NBS is also an active partici- 
 pant in the activities of Committee D-l. Durability, one 
 of the important characteristics which might be shown on a 
 label, is generally determined by accelerated tests. There- 
 fore, such test methods must be carefully examined to assure 
 suitability. The test methods appeared, with the possible 
 exception of durability, to adequately cover the attributes 
 for these two types of paints . 
 
 Industry Contacts 
 
 On August 4, 1978, a meeting was held at NPCA in Washington, 
 D.C. The purpose was (1) to discuss CPILP and to explore the 
 feasibility of including household paints in the labeling 
 program, and (2) to learn of the extent of the consumer 
 education labeling programs of NPCA. 
 
 The NPCA has published many consumer information brochures, 
 some available at the point-of-sale. One, "The Household 
 Paint Selector," was published in 1975 as a reference to be 
 consulted when a consumer was planning a painting project. 
 The organization is developing a labeling guide for use by 
 paint manufacturers. The guide suggests to the manufacturer 
 the attributes, format and consumer language to be used on 
 the label. The description of the guide closely resembles 
 the CPILP labeling program. 
 
 The adoption by the paint industry of the labeling guide and 
 the many consumer information brochures already distributed 
 made it appear that the paint industry may, to a large 
 extent, accomplish aims similar to those of CPILP. 
 
 The decision to suspend CPILP occurred before additional 
 investigation on the feasibility of including paints in the 
 labeling program could be completed. 
 
 32 
 
6. Problems Encountered 
 
 When CPILP was initiated as a pilot program it was presumed 
 that labels could be developed for two products within one 
 year and some evidence could be collected for judging the 
 acceptance and usefulness of the program. These goals were 
 not attained, not because of a lack of effort and dedication, 
 but rather because the number and severity of the impediments 
 to developing a product label and introducing it into the 
 marketplace were unexpected. 
 
 The program, as initially conceived, would have devoted 
 considerable effort to the development and adaptation of 
 test methods for rating the performance of the selected 
 products. Test method development in a consensus mode is, 
 by nature, a time consuming process. On the other hand, 
 test methods and standards that are developed through a 
 consensus process are much more likely to gain wide accep- 
 tance more quickly than if they are imposed by the Government. 
 This is particularly important when the test methods are to 
 be used in a voluntary program such as CPILP where partici- 
 pation is voluntary and success would require confidence in 
 the labeled ratings by consumers. Since a one year pilot 
 program obviously would not permit development of test 
 methods, emphasis was placed on finding products for which 
 test methods were already available. At the same time, the 
 products selected should present significant purchase decision 
 problems to consumers, and a reasonable portion of the 
 manufacturers should be interested in participating in the 
 program. No products that fully met these conditions were 
 found. 
 
 Of the products examined, thermal insulation for homes most 
 nearly met the conditions for early labeling. There were 
 test methods in existence, most of which had been published 
 by ASTM. However, some of these test methods were controversial, 
 and some new test methods were being advanced in revisions of 
 Federal Specifications. These new test methods had been 
 developed under the auspices of the General Services Admin- 
 istration, not through a consensus process, and considerable 
 resistance was encountered from some manufacturers. The 
 proposal to use both existing and new test methods to develop 
 ratings for the CPILP label, though probably beneficial for 
 consumers, would have increased the testing burden for 
 manufacturers considerably. The use of the two test methods 
 results for the label would probably have been an interim 
 procedure until either the existing or new test method 
 was clearly favored. A number of insulation manufacturers 
 had indicated, formally and informally, general support for 
 the program and that they intended to participate. However, 
 
 33 
 
manufacturers of the dominant type of insulation on the 
 market were publicly opposed to this program, which they 
 seemed to see as a possible prelude to more Government 
 regulation of their industry. Although it was expected that 
 some of these manufacturers would have participated, it is 
 likely that such participation would have come only after- 
 some time would elapse. 
 
 Home smoke detectors were another product in which there was 
 considerable consumer interest and pressure for installation 
 of these devices in homes. Current test methods provide for 
 a minimum performance rating of acceptability, but these tests 
 are not used to rank device response to various types of 
 fire situations. Attempts to obtain test data to determine 
 whether such ranking was feasible were unsuccessful. This 
 lack of cooperation by both manufacturers, a trade association 
 and a testing laboratory would have been difficult to overcome 
 during a pilot program. 
 
 Although existing test methods appeared to provide an adequate 
 basis for ranking and labeling non-rechargeable dry cells 
 and batteries, there was very little interest by consumers 
 and considerable resistance by manufacturers to including 
 this product in the program. Under such conditions, no 
 purpose was seen in developing a CPILP label for these items. 
 
 The above specific examples are indicative of the problems 
 encountered. The lack of test methods, resistance by manu- 
 facturers, and consumer indifference for some low cost products 
 were major obstacles to developing labels for products con- 
 sidered for the pilot period. Overcoming these would have 
 required significant support for test method development 
 and for a public education program. These must be strong 
 elements for such a program to succeed. 
 
 7. Suspension of the Program 
 
 As it became apparent that it would be impossible to complete 
 the development of labeling specifications and labels for 
 two products within the first year, discussions were carried 
 out within the Department of Commerce as to appropriate actions 
 to take. It was decided to request the Secretary to extend 
 the pilot period to September 30, 19 79, (the end of the fiscal 
 year 19 79) with the understanding that a recommendation as to 
 the future of the program would be provided at that time. 
 No further extensions were to be considered. This request 
 was coupled with a request for funding that would have permitted: 
 labeling of two or three products, depending upon the complex- 
 ities encountered; conducting preliminary studies of products 
 
 34 
 
so that the program could be continued without expensive 
 delays; initiating a vigorous public education program so 
 that the program could be properly judged; and starting 
 the development of methods for long term evaluation of the 
 program, including gathering of base line data. 
 
 The request to extend the pilot program was approved. 
 However, the funding for the additional time was reduced to 
 less than 30 percent of the requested amount. The program 
 management and staff considered that the approved funding 
 would be only marginally adequate to complete the labeling 
 of two products. It would not have been possible: to initiate 
 any public education activity; to signif icantlv extend 
 the contacts with manufacturers,; nor to properly evaluate 
 the progress, successes and failures of the program. Under 
 these circumstances, it was decided that: 
 
 1. Efforts to develop new labeling specifications 
 for specific products be discontinued. 
 
 2. A summary and analysis of comments on the proposed 
 labeling specification for thermal insulation for homes 
 be completed. 
 
 3. An announcement suspending CPILP be published in 
 the Federal Register. This notice should include a 
 summary of accomplishments and problems of the pilot 
 program. 
 
 4. A report be prepared to document the efforts of 
 the program and to provide a useful basis for making 
 any decisions regarding future Government efforts to 
 provide performance labeling programs for consumer 
 products . 
 
 A notice formally suspending the Program was published in 
 the Federal Register on April 2, 19 79, (44 FR* 19 2 22) 
 (see Appendix J) . 
 
 35 
 
8. Summary and Recommendations 
 
 The Voluntary Consumer Product Information Labeling Program 
 of the Department of Commerce was initiated because of the 
 conviction that consumers would make better purchase decisions 
 if product performance information were readily available at 
 the point of sale. This conviction was supported by recent 
 congressional proposals for mandatory and voluntary product 
 labeling and by the generally favorable reaction of consumers, 
 consumer advocate groups and some manufacturers to the 
 proposed program. The proposed program was not supported by 
 some manufacturers and trade associations. However, it was 
 considered that most manufacturers would benefit if perfor- 
 mance information for competing products were presented in a 
 uniform, easily understood format so that consumers could 
 readily consider the importance of various performance 
 characteristics in making a purchase decision. This would 
 encourage competition based upon performance and price, and 
 should significantly reduce consumer dissatisfaction, 
 complaints and return of purchased goods. 
 
 Providing uniform product ratings can only be accomplished 
 if standardized test methods are used to measure the character- 
 istics. Many such test methods exist for materials and 
 components. However, it was found that relatively few test 
 methods for consumer products exist that are known and 
 accepted by most manufacturers of a product. The need for 
 adequate test methods became very evident during the conduct 
 of the pilot program. 
 
 Since some manufacturers were reluctant to have their products 
 labeled in such a program, it seemed probable that a voluntary 
 program would only be successful if consumers were sufficiently 
 aware of and interested in such a program to make it readily 
 apparent that the labeled information was widely used and that 
 labeled products received purchase consideration preference. 
 Such consumer awareness could only be expected if a vigorous 
 public education program were pursued. It should be noted 
 that some manufacturers supported the program and could be 
 expected to assist in informing the public about it. 
 
 When the program was initiated, it was realized that the 
 experience with the first few products would provide the 
 learning experience that would be necessary for the long 
 term operation of a successful program. Although the 
 experience gained was contributing to the necessary 
 knowledge, not all phases of the program operation were 
 experienced even one time, and the experience with more than 
 one product was encountered only a few times. Additional 
 experience will be needed to optimize the operation of such 
 a program. 
 
 36 
 
Although the program was intended to be self supporting as 
 a result of fees for the use of the labels, this provision was 
 suspended, at least for the pilot program. The feasibility 
 of supporting the program in this way and the effect of such 
 a fee schedule on manufacturer participation was not tested. 
 If the conduct of a program such as CPILP is not to be 
 dependent upon public funding, reliance must be placed upon 
 an equitable scheduling of fees with proven cost/benefit 
 ratios acceptable to manufacturers . 
 
 Based upon the limited experience with a few products, the 
 following recommendations for any future voluntary effort to label 
 performance characteristics of consumer products are made: 
 
 (1) A primary concern must be the locating or development 
 of test methods for the various performance characteristics 
 of interest. Both manufacturers and consumers should be 
 involved in any development effort. Whenever practical, 
 the needed test methods should be developed in conjunction 
 with a recognized consensus standards developing organiza- 
 tion (e.g. ANSI, ASTM, etc.). 
 
 (2) Provision should be made at an early date to carry on a 
 vigorous public education program. 
 
 (3) Because of the relatively long period of time required 
 to develop labeling specifications, gain .manufacturer 
 participation, and build up consumer usage, a voluntary 
 labeling program should be allowed five years before being 
 finally judged. Funding of the program, by whatever 
 sources are deemed most appropriate, should be assured 
 
 for at least that amount of time before the program is 
 started. At the end of that period it is expected that a 
 fair and objective evaluation of the merits of the program 
 to both manufacturers and consumers could be made. 
 
 (4) Close contacts with manufacturers must be encouraged, 
 particularly with regard to test methods and methods of 
 ratings. 
 
 (5) Consumers and consumer advocate groups must be fully 
 involved in all phases of the program, from product selection 
 to program evaluation. 
 
 37 
 
REFERENCES 
 
 1 . Cochrane , Rexmond C . , Measures for Progress, A History 
 of the National Bureau of Standards , NBS MP27 5, 
 United States Department of Commerce, National Bureau 
 of Standards, 1966. 
 
 2. European Informative Labeling . Canadian Department 
 of Consumer and Corporate Affairs, Ontario, 1973. 
 
 3. Thorelli, Hans B., and Sarah V. Thorelli, Consumer 
 Information Handbook; Europe and North America , 
 New York: Praeger, 19 74. 
 
 4 . Background Document for Product Noise Labeling - 
 General Provisions , EPA 550/9-77-253, United States 
 Environmental Protection Agency, Office of Noise 
 Abatement and Control, April, 1977. 
 
 (129 pages plus appendices) 
 
 5. McGuire, B. J., and E. A. Vadelund, Voluntary Labeling 
 Program for Household Appliances and Equipment to 
 Effect Energy Conservation; Annual report for Calendar 
 Year 1974 , NBSIR 75-660, National Bureau of Standards, 
 Center for Consumer Product Technology, February, 19 75. 
 
 (10 pages plus appendices) Available from U.S. 
 Government Printing Office, Washington, D.C. 20402, 
 SD Cat. No. C13. 
 
 6 . Summary and Analysis of Public Comments on Proposes 
 Procedures for a Voluntary Consumer Product Information 
 Labeling Program , National Bureau of Standards, Center 
 for Consumer Product Technology, January 17, 19 77. 
 
 (86 pages plus appendices) 
 
 7. McDowell, E. C, E. N. Robertson, and S. M. Spivak, 
 Product Selection for the Voluntary Consumer Product 
 Information Labeling Program , NBSIR 78-1450, National 
 Bureau of Standards, Center for Consumer Product 
 Technology, March, 19 78. (39 pages plus appendices) 
 Available from U.S. Government Printing Office, 
 Washington, D. C. 20402, SD Cat. No. C13. 
 
 38 
 
Appendix A 
 
 U.S. DEPARTMENT OF COMMERCE 
 
 OFFICE OF THE SECRETARY 
 
 Reprinted from Federal Register, Volume 41, Number 102--Tuesday, May 25, 7976 
 
 (Pages 21389-21394) 
 
 Office of the Secretary 
 
 PROPOSED VOLUNTARY CONSUMER 
 PRODUCT INFORMATION LABELING 
 PROGRAM 
 
 Operation and Procedures 
 
 In his confirmation hearings. Secre- 
 tary of Commerce Richardson made the 
 following statements on the subject of 
 consumer information : 
 
 I strongly favor the provision of consumer 
 product testing information to consumers in 
 those product lines where Inadequate infor- 
 mation exists. I intend to pursue the devel- 
 opment of voluntary programs in which 
 industry works with Government to make 
 meaningful performance Information avail- 
 able to the marketplace. 
 
 This notice announces the intention of 
 the Department of Commerce to develop, 
 in cooperation with consumers, manu- 
 facturers, producers, distributors, retail- 
 ers, and other interested groups, a vol- 
 untary consumer product information 
 labeling program, provided that substan- 
 tial need and support for such a program 
 is demonstrated at the three scheduled 
 public hearings described later in this 
 notice. The purpose of the program 
 would be to facilitate consumer purchas- 
 ing decisions by making available at the 
 point of sale comparative information on 
 key product performance characteristics 
 and to provide manufacturers an oppor- 
 tunity to convey to the public the par- 
 ticular advantages of their products. To 
 operate and carry out this Program, 
 there are set out at the conclusion of this 
 notice proposed procedures. 
 
 Presidents Kennedy, Johnson, Nixon, 
 and Ford have affirmed that consumers 
 have a basic right to be kept informed. 
 In a Presidential Consumer Message In 
 1969, it was stated: 
 
 No matter how alert and resourceful a 
 purchaser may be, he is relatively helpless 
 unless he has adequate, trustworthy in- 
 formation about the product he is consider- 
 ing arid knows what to make of that infor- 
 mation. The fullest product description Is 
 useless if a consumer lacks the understand- 
 ing or the will to utilize it. 
 
 In the same vein, the National Business 
 Council for Consumer Affairs, in a 1973 
 report, made the following recommenda- 
 tion: 
 
 Wherever appropriate, manufacturers 
 should promote the development of mecha- 
 nisms for providing consumers with perform- 
 ance information on consumer durables. 
 
 The Council was also of the view that 
 government agencies could help in as- 
 suring that appropriate product charac- 
 teristics are chosen and measured in a 
 manner that would be fair and equitable 
 to manufacturers and consumers. 
 
 U.S. consumers today are unable in 
 many cases to make rational and accu- 
 rate marketplace decisions because of 
 lack of comparative, easily comprehen- 
 sible information at the point of sale 
 on important product performance char- 
 acteristics, including durability, capac- 
 ity, and efficiency. This lack of informa- 
 tion often results in consumer purchases 
 being made on a trial-and-error basis 
 or on the basis of unsubstantiated per- 
 formance claims, with consequent con- 
 sumer financial loss, dissatisfaction, and 
 inconvenience. 
 
 At least eight European countries — 
 Denmark, Finland, Norway, Sweden, 
 France, West Germany, Netherlands, 
 and Switzerland — are operating volun- 
 tary national information labeling pro- 
 grams that provide consumers with the 
 type of information discussed above. 
 These programs have four features in 
 common : 
 
 1. Manufacturer participation is on a vol- 
 untary basis; 
 
 2. The programs report levels of perform- 
 ance but do not set minimum levels; 
 
 3. The programs deal principally with 
 measurable performance characteristics; and 
 
 4. The programs utilize fixed labeling for- 
 mats that present information to consumers 
 in simplified form. 
 
 Three examples from these programs 
 are set out in Appendix A to this notice. 
 
 Public Comments Requested 
 
 Comments are requested on this pro- 
 posed Program, the proposed procedures 
 at the end of this notice, and on the 
 following areas of inquiry. 
 
 1. Beneficial or adverse impacts on 
 product cost, quality or availability. What 
 effects, either beneficial or adverse, 
 could the Program be expected to have 
 on the cost, quality or availability of con- 
 sumer products? What effect Is it likely 
 to have on consumers, retailers, manu- 
 facturers, producers or the economy in 
 general? What studies are now available 
 that Indicate the probable effects of such 
 programs? 
 
 2. Product selection iriteria and proc- 
 ess. How should products that will be 
 covered by the Program be selected? 
 What should be the selection criteria? 
 Would It be desirable to establish a prod- 
 uct selection committee(s) ? If so, what 
 criteria should be utilized to select the 
 membership? 
 
 3. Information label deisgns. How 
 should the effectiveness of label designs 
 pertaining to specific product categories 
 be evaluated? How much field te3ting 
 would be necessary to determine the na- 
 ture of public reaction to the labels? 
 Could proposed label designs be effective- 
 ly tested using Consumer Sounding 
 Boards or similar consumer groups in 
 lieu of field testing? 
 
 4. Consumer education approaches. 
 What is the best way to make the pub- 
 lic aware of this Program? Would it be 
 feasible for the Department to cooperate 
 in some way with the advertising depart- 
 ments or agencies of participating 
 manufacturers and producers to enhance 
 the total impact of the Program? 
 
 5. Benefits to manufacturers. What 
 would be the principal advantages of this 
 Program to manufacturers? Would a 
 better understanding by consumers of 
 the performance characteristics of 
 manufacturers' products result in a re- 
 duction in the return rate of such prod- 
 ucts and in a decrease in the number 
 of consumer complaints? Would the op- 
 eration of this Program improve the 
 ability of manufacturers to structure 
 their model mix to meet consumer needs 
 and desires? 
 
 A-l 
 
21390 
 
 NOTICES 
 
 6. Methods of establishing fees to help 
 defray program costs. On what basis 
 should equitable and reasonabe fees be 
 established? Would a fixed fee covering 
 one product category discriminate 
 against smaller manufacturers or pro- 
 ducers who might wish to participate in 
 the Program? Would a fee on a per unit 
 basis as provided in the proposed proce- 
 dures be administratively burdensome or 
 constitute an unwarranted invasion of 
 proprietary data? 
 
 7. Monitoring and certification pro- 
 cedures. How and to what extent should 
 the Department monitor the Program? 
 Would manufacturer and producer self- 
 certification, or industry certification, be 
 effective as an aid in the monitoring of 
 this Program? 
 
 The Department also encourages the 
 submission of any other proposals or sug- 
 gestions that might better carry out a 
 voluntary' program to assist consumers 
 in making accurate purchase decisions 
 by providing meaningful point-of-sale 
 information on key product perform- 
 ance characteristics. 
 
 Written comments should be submit- 
 ted in four copies to the Assistant Secre- 
 tary for Science and Technology, Room 
 3862, U.S. Department of Commerce, 
 Washington, D.C. 20230. on or before 
 July 9, 1976 Oral comments may be made 
 at informal hearings open to the public, in 
 
 accordance with the following schedule 
 
 and procedures. 
 
 Informal Hearings 
 
 The Department will hold three infor- 
 mal hearings on the proposed Program. 
 The first hearing will be held on Wednes- 
 day, June 23, 1976, at 10 a.m. Pacific 
 
 Daylight Saving Time in Los Angeles, 
 California. The second hearing will be 
 held on Tuesday, June 29, 1976, at 10 a.m. 
 Central Daylight Saving Time in Chi- 
 cago, Illinois. The third hearing will be 
 held on Wednesday, June 30, 1976. at 
 10 a.m. Eastern Daylight Saving Time in 
 the Auditorium of the Department of 
 Commerce, Main Commerce Building, 
 14th Street between E Street and Con- 
 stitution Avenue, N.W., Washington, 
 D.C. 
 
 Meeting places for the hearings in Los 
 Angeles and Chicago have not been 
 finalized. However, the precise meeting 
 place in those two cities will appear in 
 the Federal Register on Wednesday, 
 June 2, 1976, which will be three weeks 
 before the first of the scheduled hear- 
 ings is held. Anyone who misses the 
 June 2, 1976 notice and wishes informa- 
 tion on the precise meeting place for any 
 of the scheduled hearings may call or 
 write Dr. Melvin R. Meyerson, Chief, 
 Product Systems Analysis Division, Na- 
 tional Bureau of Standards, Washington, 
 D.C. 20234, telephone number (301) 921- 
 2907 on or after June 2, 1976. 
 
 Persons desiring to testny at tnese 
 hearings should notify the Assistant Sec- 
 retary for Science and Technology, Room 
 3862, U.S. Department of Commerce, 
 Washington, D.C. 20230, as promptly as 
 possible, and not later than 48 hours 
 prior to the date of the hearing at which 
 they will testify. Persons desiring to tes- 
 tify should also submit to the Assistant 
 Secretary for Science and Technology 
 four copies of their statement, not later 
 than 48 hours prior to the start of the 
 hearing at which they will testify. 
 
 The following procedures are estab- 
 lished for the informal hearings : 
 
 1. Purpose. The purpose of the in- 
 formal hearings is to provide all inter- 
 ested segments of the public with the op- 
 portunity to comment on whether the 
 Department should initiate a voluntary 
 consumer product information labeling 
 program. 
 
 2. Conduct of hearings, (a) These 
 hearings shall be informal, non-adver- 
 sary proceedings at which there will be 
 no formal pleadings or adverse parties. 
 Witnesses may submit written presenta- 
 tions for the record. 
 
 (b) The presiding officer shall have the 
 right to apportion in an equitable man- 
 ner the time available for making pres- 
 entations, and to terminate or shorten 
 the presentation of any witnesses when, 
 in his or her opinion, such presentation 
 is repetitive or not relevant to the pur- 
 pose of the hearings. 
 
 (c) The presiding officer and other 
 Department representatives shall have 
 the right to question witnesses on their 
 testimony and other matters relating to 
 the proposed Program. 
 
 (d) The presiding officer has the right 
 to exercise authority necessary for the 
 equitable and efficient conduct of the 
 hearings and to maintain order. 
 
 3. General provisions, (a) These in- 
 formal hearings shall be open to the 
 members of the public whether or not 
 such members wish to testify at the 
 hearings. 
 
 (b) A transcript will be made of the 
 informal hearings. ,_ 
 
 (c) Copies of the transcript and all 
 materials presented by the witnesses at 
 the hearings as well as all written com- 
 emnts received shall be available for 
 inspection and copying in the Central 
 Reference and Records Inspection Facil- 
 ity, Room 7068, Main Commerce Build- 
 ing, 14th Street between E Street and 
 Constitution Avenue, N.W., Washington, 
 D.C. 20230. 
 
 Issued: May 19, 1976. 
 
 Betsy Ancker-Johnson, 
 Assistant Secretary for 
 Science and Technology. 
 
 Pboposed Procedures 
 
 procedures for a voluntary consumes 
 product information labeling program 
 
 1. Purpose. The purpose of this part Is to 
 establish procedures under which a national 
 voluntary consumer Information labeling 
 program administered by the Department of 
 Commerce will function. 
 
 2. Description and Goal of Program, (a) 
 The Department's Voluntary Consumer Prod- 
 uct Information Labeling Program would 
 make available to consumers, at the point of 
 sale, Information on consumer product per- 
 formance In an understandable and useful 
 form. It would also educate consumers, dis- 
 tributors, and retailers In the use of the 
 product performance Information displayed 
 and would provide manufacturers with an 
 opportunity to convey to the public the 
 particular advantages of their products. 
 These objectives would be accomplished by: 
 
 (1) Selecting or developing standardized 
 test methods by which selected product per- 
 formance characteristics could be measured; 
 
 (ii) Developing labeling methods by which 
 information concerning product performance 
 could be transmitted in useful form to con- 
 sumers at the point of sale; 
 
 (ill) Encouraging manufacturers to volun- 
 tarily test and label their products according 
 to the selected or developed methods; and 
 
 (iv) Encouraging consumers through vari- 
 ous informational and educational programs 
 to utilize the product performance informa- 
 tion provided. 
 
 (b) The Program would involve voluntary 
 labeling by licensed participants of se- 
 lected categories of consumer products with 
 information concerning selected perform- 
 ance characteristics of those products. The 
 performance characteristics selected would be 
 only those that are of demonstrable impor- 
 tance to consumers, that consumers cannot 
 evaluate through mere inspection of the 
 product, and that can be measured objec- 
 tively and reported understandably to con- 
 sumers. The consumer products covered 
 would be those for which incorrect purchase 
 decisions can result In substantial financial 
 loss, dissatisfaction, or inconvenience. This 
 Program shall seek to avoid the duplication 
 of other Federal programs under which per- 
 formance characteristics are labeled by ex- 
 empting those performance characteristics 
 from this Program. 
 
 (c) For selected categories of consumer 
 products, the Program would Include ad- 
 vertising guidelines covering situations where 
 
 quantitative performance values are stated 
 la advertising or where qualitative compar- 
 isons are made of the performance of dif- 
 ferent products. 
 
 3. Definitions, (a) The term "Secretary" 
 means the Secretary of Commerce or his 
 designee. 
 
 (b) The term "consumer" means the first 
 person who purchases a consumer product 
 for purposes other than resale. 
 
 (c) The term "manufacturer" means any 
 person engaged in the manufacturing or as- 
 sembling of consumer products or In the 
 importing of such products for resale. The 
 term also Includes private brand labelers. 
 
 (d) The term "consumer product" means 
 any article produced or distributed for sale 
 to a consumer for the use. consumption, or 
 enjoyment of such consumer. 
 
 FEDERAL REGISTER, VOL. 41, NO. 102— TUESDAY, MAY 25, 1976 
 
 A-2 
 
NOTICES 
 
 21391 
 
 (e) The term "person" means an Indi- 
 vidual; a manufacturer; distributor; re- 
 taller; Importer; government agencies at 
 the Federal, State and local level; consumer 
 organizations; Industry and trade associa- 
 tions; standards writing bodies; professional 
 societies; or any other group or organiza- 
 tion of industries, companies, or individuals. 
 
 (f) The term "consumer product per- 
 formance" means those characteristics of a 
 consumer product such as durability, capac- 
 ity, composition, color-fastness, and strength 
 that are often difficult or impossible for con- 
 sumers to evaluate or ascertain without 
 actually buying and using the product under 
 consideration. 
 
 4. Finding of Need to Establish a Specifi- 
 cation for Labeling a Consumer Product, (a) 
 Any person may request the Secretary to 
 find that there is a need to label a par- 
 ticular consumer product with Information 
 concerning one or more specific performance 
 characteristics of that product. 
 
 (b) Such a request shall be in writing and 
 will, as a minimum, include the following 
 Information : 
 
 (1) Identification of the consumer prod- 
 uct; 
 
 (2) Extent that the product identified in 
 subparagraph (1) above is used by the pub- 
 lic and, if known, what the production or 
 sales volume Is of such product; 
 
 (3) Nature and extent of difficulty experi- 
 enced by consumers In making informed 
 purchase decisions because of a lack of 
 knowledge regarding the performance char- 
 acteristics of the identified consumer prod- 
 uct: 
 
 (4) Potential or actual loss to consumers 
 as a result of an Incorrect decision based 
 on an inadequate understanding of the per- 
 formance characteristics of the identified 
 consumer product; 
 
 (6) Extent of incidence of consumer com- 
 plaints arising from or reasonably traceable 
 to lack of knowledge regarding the perform- 
 ance characteristics of the identified con- 
 sumer product; 
 
 (6) If known, whether there currently ex- 
 ists test methods which could be used to test 
 the performance characteristics of the Iden- 
 tified consumer product and an identifica- 
 tion of those test methods; and 
 
 (7) Reasons why it is felt, in cases where 
 existing test methods are identified in re- 
 sponding to subparagraph (6) above, that 
 such test methods are suitable for making 
 objective measurements of the performance 
 characteristics of the identified consumer 
 product. 
 
 (c) The Secretary may ask for more in- 
 formation to support a request made under 
 paragraph (a) of this section if he feels it is 
 necessary to do so or. if he deems it to be In 
 the public interest, may develop such In- 
 formation himself. If the Secretary deter- 
 mines that there is no need to establish a 
 specification for labeling the requested con- 
 sumer product performance characteristics, 
 or because of a lack of resources, he will 
 decline to act further on the request. The 
 Secretary shall act expeditiously on all re- 
 quests and shall notify the requester of his 
 decision in writing. In those instances where 
 the Secretary declines a request, he shall 
 state the reasons for so declining. 
 
 (d) If the Secretary finds that a need 
 exists to establish a specification for label- 
 ing a consumer product that would identify 
 one or more performance characteristics of 
 the consumer product Identified in paragraph 
 (b) of this section, he shall publish a notice 
 in the Federal Register indicating that such 
 finding is a preliminary finding. The notice 
 shall Include a statement as to the basis for 
 the Secretary's finding and shall provide at 
 least a thirty (30) day period for the sub- 
 mission of written comments thereon by in- 
 terested persons. In the event that a public 
 hearing or hearings are held on this prelim- 
 inary finding as authorized under paragraph 
 (e) of this section, the period allowed for the 
 submission of written comments shall be ex- 
 tended to the date on which such hearing or 
 hearings are held. 
 
 (e) Interested persons wanting to express 
 their views regarding the Secretary's pre- 
 liminary finding of need in an informal hear- 
 ing shall notify the Secretary of that desire 
 within fifteen (15) days after the notice is 
 published In the Federal Register. Upon re- 
 ceipt by the Secretary of such request, in- 
 formal public hearings shall be held so as to 
 give all interested persons an opportunity 
 for the oral presentation of data, views, or 
 arguments, in addition to the opportunity 
 to make written submissions. If deemed ap- 
 propriate by the Secretary, such hearings 
 may be held at several locations within the 
 United States. Notice of such hearings shall 
 be published in the Federal Register at least 
 twenty (20) days In advance thereof. A trans- 
 cript shall be kept of any oral presentations. 
 
 (f) All written and oral comments will be 
 filed in the Central Reference and Records 
 Inspection Facility, Room 7068, Commerce 
 Building, 14th Street between E Street and 
 Constitution Avenue, N.W., Washington, D.C. 
 20230, and will be available for public inspec- 
 tion and copying at that location. 
 
 (g) After evaluating the comments re- 
 ceived, the Secretary shall publish a notice 
 in the Federal Register making a final find- 
 ing of need or withdrawing his preliminary 
 finding of need made under paragraph (d) 
 of this section. The notice shall state the 
 basis for the Secretary's final finding of need 
 or for the withdrawal of his preliminary 
 finding. 
 
 (h) The Secretary may make a preliminary 
 finding of need to establish a specification 
 for labeling a consumer product with infor- 
 mation concerning one or more performance 
 characteristics of that product when such 
 action is deemed by him to be in the public 
 interest, notwithstanding the absence of a 
 request from an outside source. The pro- 
 cedural requirements set out in paragraphs 
 (d), (e), (f) and (g) of this section are 
 applicable to the preliminary finding of need 
 made by the Secretary under this paragraph. 
 
 5. Development of Performance informa- 
 tion Labeling Specifications, (a) If the Sec- 
 retary makes a final finding of need pur- 
 suant to section 4 above, he will then pro- 
 ceed to develop a performance information 
 labeling Specification. Each Specification 
 shall as a minimum Include : 
 
 ( 1 ) A description of the performance char- 
 acteristics of the consumer product covered; 
 
 (2) The test methods to be used in meas- 
 uring the performance characteristics. The 
 test methods shall be methods described in 
 existing nationally-recognized voluntary 
 standards (preferably ANSI standards) where 
 such methods are appropriate. Where appro- 
 priate test methods do not exist, they will be 
 developed by the Department of Commerce 
 in cooperation with Interested parties; 
 
 (3) A prototype label and directions for 
 displaying the label on or with the consumer 
 product concerned; and 
 
 (4) Conditions of participation by manu- 
 facturers. 
 
 (b) The Secretary upon development of a 
 proposed Specification shall publish in the 
 Federal Register a notice giving the com- 
 plete text of the proposed Specification, and 
 any other pertinent information, and invit- 
 ing any interested person to submit written 
 comments on the proposed Specification 
 within 45 days after its publication In the 
 Federal Register, unless another time limit 
 is provided by the Secretary. Interested per- 
 sons wanting to express their views in an 
 informal hearing may do so if. ^rithin 15 days 
 
 after the proposed Speci fication is 
 published in the Federal Register". 
 
 they request the Secretary to 
 hold a hearing. Such informal hearings shall 
 be held so as to give all interested persons 
 an opportunity for the oral presentation of 
 data, views, or arguments in addition to the 
 opportunity to make written submissions. 
 Notice of such hearings shall be published 
 in the Federal Register. A transcript shall 
 be kept of any oral presentations. 
 
 (c) The Secretary, after consideration of 
 all written and oral comments and other 
 materials received in accordance with para- 
 graph (b) of this section, shall publish in 
 the Federal Register within 30 days after 
 the final date for receipt of comments, or as 
 soon as practicable thereafter, a notice 
 either: 
 
 (1) Giving the complete text of a final 
 Specification, including conditions of use, 
 and stating that any manufacturer of con- 
 sumer products desiring voluntarily to use 
 the Department of Commerce Mark devel- 
 oped under section 9 of these Procedures 
 must advise the Department of Commerce; 
 or 
 
 (2) Stating that the proposed Specifica- 
 tion will be further developed before final 
 publication; or 
 
 (3) Withdrawing the proposed Specifica- 
 tion from further consideration. 
 
 6. Establishment of Fees and Charges, (a) 
 The Secretary in conjunction with the use 
 of the Working Capital Fund of the National 
 Bureau of Standards, as authorized under 
 section 12 of the Act of March 3, 1901, as 
 amended (15 U.S.C. 278b), for this Program, 
 shall establish fees and charges for use of 
 the Department of Commerce Label and 
 Mark on each product. The fees and charges 
 established by the Secretary, which may be 
 revised by him when he deems it appropriate 
 
 FEDERAL REGISTER, VOL. 41, NO. 102— TUESDAY, MAY 25, 1976 
 
 A-3 
 
21392 
 
 NOTICES 
 
 to do so, shall be In amounts calculated to 
 maximize the self-sufficiency of the opera- 
 tion of this Program. A separate notice will 
 be published In the Federal Register simul- 
 taneously with the notice of each proposed 
 Specification referred to In section 6(b) 
 Such notice will set out a schedule of esti- 
 mated fees and charges the Secretary pro- 
 poses to establish. The notice would be fur- 
 nished for informational and guidance pur- 
 poses only in order that the public may 
 evaluate the proposed Specification in light 
 of the expected fees to be charged. 
 
 (b) At such time as the Secretary pub- 
 lishes the notice announcing the final 
 Specification referred to in section 6(c)(1), 
 he shall simultaneously publish a separate 
 notice in the Federal Register setting forth 
 the final schedule of fees that will be charged 
 participating manufacturers. The effective 
 date of such final schedule of fees shall be 
 the same as the date on which the final 
 Specification takes effect. 
 
 (c) Revisions, if any, to the fees and 
 charges established by the Secretary under 
 paragraph (b) of this section shall be pub- 
 lished in subsequent Federal Register no- 
 tices and shall take effect not Jess than 
 thirty (30) days after the date of 
 publication of such notice. 
 
 7. Participation of Manufacturers, (a) 
 Manufacturers desiring to participate in this 
 program will so notify the Secretary. The 
 notification will identify the particular Spec- 
 ification to be used and the manufacturer's 
 Identification and model numbers for the 
 products to be labeled. The notification will 
 also state that the manufacturer will abide 
 by all conditions contained in the Speci- 
 fication, agrees to pay the fees and charges 
 established by the Secretary, and will desist 
 from using the Department of Commerce 
 Label and Mark If requested by the Secretary 
 under the provisions of section 8. 
 
 (b) The conditions for participation will 
 be set out in the Specification and will in- 
 clude, but not be limited to, the following: 
 
 (1) Prior to the use of a Label the manu- 
 facturer will make or have made the meas- 
 urements to obtain the information required 
 for inclusion on the Label and, if re- 
 quested, will forward within 30 days such 
 measurement data to the Secretary. Such 
 measurement data will be kept on file by 
 the manufacturer or his agent for two years 
 after that product is no longer manufactured 
 unless otherwise provided in the Specifica- 
 tion. 
 
 (2) The manufacturer will describe the 
 test results on the Label as prescribed in 
 the Specification. 
 
 (3) The manufacturer will display or ar- 
 range to display, in accordance with the ap- 
 propriate Specification, the Label on or with 
 each individual product of the type covered 
 except for units exported from the U.S. 
 Manufacturers who utilize more than one 
 brand name may participate by labeling 
 some or all of the brand names.. All models 
 with the same brand name must be in- 
 cluded In the Program unless they are for 
 export only. 
 
 (4) The manufacturer agrees at his ex- 
 pense to comply with any reasonable re- 
 quest of the Secretary to have products 
 manufactured by him tested to determine 
 that testing has been done 'according to 
 the relevant Specification. 
 
 (6) Manufacturers may reproduce the De- 
 partment of Commerce Label and Mark In 
 advertising provided that the entire Label, 
 complete with all Information required to 
 be displayed at the point of retail sale, Is 
 shown legibly. 
 
 8. Termination of Participation, (a) The 
 Secretary upon finding that a manufacturer 
 is not complying with the conditions of 
 participation set out in these Procedures or 
 in a Specification may terminate upon 30 
 days notice the manufacturer's participa- 
 tion in the Program: Provided, that the 
 manufacturer shall first be given an op- 
 portunity to show cause why the participa- 
 tion should not be terminated. Upon receipt 
 of a notice of termination, a manufacturer 
 may request within 30 days a hearing un- 
 der the provisions of 5 U.S.C. 558. 
 
 (b) A manufacturer may at any time 
 terminate his participation and responsi- 
 bilities under this Program with regard to 
 a specific type of product by giving written 
 notice to the Secretary that he has discon- 
 tinued use of the Department of Commerce 
 Label and Mark for all consumer products of 
 the type involved. 
 
 9. The Department of Commerce Mark. 
 The Department of Commerce shall de- 
 velop a Mark which shall be registered in 
 the U.S. Patent and Trademark Office under 
 15 U.S.C. 1054 for use on each Label described 
 In a Specification. 
 
 10. Amendment or Revision of a Perform- 
 ance Information Labeling Specification. The 
 Secretary may by order amend or revise any 
 Specification published under section 5. The 
 Procedure applicable to the establishment of 
 a Specification under section 5 shall be fol- 
 lowed in amending or revising such Specifi- 
 cation. Such amendment or revision shall 
 not apply to consumer products manufac- 
 tured prior to the effective date of the 
 amendment or revision. 
 
 11. Consumer Education. The Secretary, In 
 close cooperation and coordination with in- 
 terested Government agencies, appropriate 
 industry trade associations and Industry 
 members, organizations, and other interested 
 persons shall carry out a program to educate 
 consumers relative to the significance of the 
 labeling program. Some elements of this 
 Program shall also be directed toward in- 
 forming retailers and other interested groups 
 about the Program. 
 
 12. Coort lation with State and Local 
 Programs. The Secretary will establish and 
 maintain an active program of communica- 
 tion with appropriate State and local gov- 
 ernment offices and agencies and will furnish 
 and make available Information and assist- 
 ance that will promote uniformity In State, 
 local and Federal programs for the labeling 
 of performance characteristics of consumer 
 products. 
 
 13. Annual Report. The Secretary will pre- 
 pare an annual report of activities under the 
 Program, including an evaluation of the 
 Program and a list of participating manufac- 
 turers and types of consumer products. 
 
 Authority: Sec. 2, 31 Stat. 1449, as 
 amended, sec. 1, 64 Stat. 371; (15 USC 272), 
 Reorganization Plan No. 3 of 1946. Part VI. 
 
 FEDERAL REGISTER, VOL 41., NO. 102— TUESDAY, MAY 25, 1976 
 
 A-4 
 
NOTICES 
 
 21393 
 
 APPENDIX A 
 Examples of European Labels 
 
 VDN SPECIFICATIONS 
 
 Capacity: 9-10 deciliter* — — — — 
 
 Temperature - retaining properties! If jug is kept closed 
 
 . after 6 hours after 17 hours 
 
 boiling liquid (100°C)- at least 80°C at least 70°C 
 
 cold liquid (6°C) /lot more than not more than 9°c 
 
 6°C 
 
 Figures assume that jug is full and is kept in ordinary room 
 temperature (20°C) . If the jug is only half full, the change in 
 temperature will take place more rapidly as it also will if there 
 is a still greater difference between the temperature of the content 
 and that of the surrounding air. 
 
 Durability of the glass container: Bating for resistance against 
 knocks against the casing: 3 (Scale is 1 to 5, where 5 represents 
 the greatest strength) . Will not crack if boiling hot liquid is 
 poured in without previous warming up. 
 
 Tightness: Joint between the glass container and the casing is 
 tight. Jug will not leak 
 
 Materials: Container: 
 Casing: SAN-plastic. 
 
 Glass 
 
 Withstands temperatures of 
 
 Stopper: Precious wood with expanding rubber seal. 
 Care: See attached folder 
 
 VARU 
 FAKTA 
 
 Rymd; J-10 dl. 
 ttoleringsfdrmJg; 
 
 Vid forvarlng 1 sluten kanna Sr 
 efter6tim efter 12 llm 
 kokhcl dryck (100'C) mlnst 80°C mlnst 70°C 
 
 kail dryck (6'C) hogst 6'C tidgst8°C 
 
 Detta galler om kartnan 3r helt fylld och forvaras 
 I vanhg rumslemperatur (20*C). For halvfylld kanna 
 Sndras dtyckens temperatur fortare. Ju slorre skill- 
 naden ar mellan dryckens och omglvningens tem- 
 peratur, desto fortare Sndras dryckens temperatur. 
 
 Glasels hallbarhet: Vid stbtar och slag mot ytter- 
 holjet: 3. 
 
 (Skala 1—5 dar 5 Innebar hogsta mekaniska hall- 
 barhet). 
 
 Kokhet dryck kan halla3 I det ej furuppvarmda 
 glaset utan att detta spricker. 
 
 Tathet: Skarven mellan glas och ytterholje ar tat. 
 Termosen lacker ej. 
 
 Material: Ytterholjet — plast (SAN) til +90° och 
 — W"C Innertlaska — glas. Handtag av Sdeltra. 
 Forslutnlng — expanderkork av adeltra med guru- 
 mipackning. 
 
 .Skdtsel: Se nedanstaendc anvisningar, 
 
 •AB Husqvarna Borstfabfik 5002.3 
 
 Skdtsel 
 
 r Kannan maste behandla3 varsarn!. Foremal av glas kan 
 xplodera. Man bar darfdr ej luta slg med ansiktet 
 ' over kannan. 
 Anvisningar I dvrigt: se bifogad Folder. 
 
 MANUFACTURER ■ 
 
 Care: Handle With Care. 
 
 Since glass may explode, keep face away from 
 opening. 
 
 Figure 1: Typical Label used in the Swedish Institute for Informative Labeling (VDN) Program. 
 
 RAL CERTIFICATION 
 from test of sample 
 Vacuum Cleaner 
 RAL-AGT 3S 
 
 Floor Vacuum Cleaner Make 
 
 with suction hose, 2 vacuum pipes, rotating junction/ 
 
 suction- nozzle, upholstery and groove nozzle and filter bag 
 
 Nominal voltage, type of current, 220V, Nominal load 450W 
 
 Electrical Safety. The equipment carries the test symbol 
 
 VDE (Society of German Electrical Engineers) 
 
 The following statements are based on DIN 44956: 
 
 & Dust and fiber suction (of wool and velours carpets) 
 Dust suction: 
 
 low high 
 
 Fiber suction: 
 
 Complete removal of test fibers in seconds 
 
 O Capacity for reception in the dust bag through suction 
 action: g test dust 
 
 O Limit of reach from electrical outlet to the nozzle: 
 
 O Operating noise 
 
 faint strong 
 
 (A number greater by 10 implies a doubled noise level) 
 O Suction distance under furniture (17 cm above floor) 
 
 RAL + Certificate and Control Number 
 
 Heed operating instructions — 
 
 RAL- TESTA? 
 
 nach MusterprOfung 
 
 Staubiougftr 
 
 RAL- AG t 3 S 
 
 Bodcnstaubiauger, Morke „ 
 
 mit Saugschlauch, 2 Saugrohren, Drehgelenl<a*YSe/5QUgdO'se, 
 
 Politer- und Fugenduse und Filrertute 
 
 Ncnnsponnung, Stromart: 220V-, Ntnnaufnahmer 450W 
 
 EleWrische Sicherheit; Das Gerat trogt das VDE-PrGfzeidien 
 
 Fofgende Angoben sind nach DIN 44956 ermirtelf: 
 
 • Staub- und Faden-Aufsaugen (von Woll-Velouri-Teppicfien) 
 
 hoch 
 
 Sfaubaufsauge 
 goring 
 
 30 .50 70 90 
 Fddertaufsaugent 
 Vollitondigej Aufsaugen von PrGHoden in .._ sek. 
 
 # Aufnobmevermogen des Staubbeutels 
 durch Savgen: g Prufstaub 
 
 • Reicnweite von der Sleckdose bis zur Diise: m 
 
 # Beffiebjgerauscht 
 
 T 
 
 tchwach 60 65 70 75 80 stark 
 
 (Eine urn 10 groflere Zahl bedeutet verdoppeltes Gerau&di) 
 
 • Saugreicriw«ite urtter Mobeln (bei 17cm BodenabitandJ; 
 
 RAL-TE'. AT Nr. 
 
 antral Hort 
 3 SB / *) 
 
 Gebrouchsonlcirung beochtenl 
 
 Pigure 2; Typical Label used in the German Committee for Delivery Conditions and Quality 
 Protection (RAL) Program 
 
 FEDERAL REGISTER, VOL. 41, NO. 102— TUESDAY, MAY 25, 1976 
 
 A-5 
 
21394 
 
 NOTICES 
 
 INFORMATIVE LABEL 
 
 NETHERLANDS INFORMATIVE LABELING 
 
 SLEEPING BAG • BLANKET MODEL 
 o 70 x 180 cm (finished size) 
 
 o filling 
 
 polyester fiber + synthetic foam 
 weight per square meter 
 
 o cover 
 
 outer: viscose rayon fiber 
 inner: viscose rayon fiber 
 
 o thickness (related to thermal insulation 
 not compressed (top) 
 
 (each square corresponds approximately 
 to a woolen blanket) 
 decrease on compression (bottom) 
 decrease on regular use and cleaning 
 
 O strength (5 is maximum) 
 
 o color fastness (5 is maximum) 
 on rubbing 
 on perspiring 
 on laundering 
 
 o shrinkage, maximum 
 
 o weight, excluding carrying bag 
 o HOW TO CLEAN: see label on bag 
 
 INFORMATION BASED ON STANDARD MEASUREMENT METHODS 
 
 BRAND NAME 
 MANUFACTURER 
 
 
 WPORiUTim KTIKSTTBIMMa N ■OSMUND 
 
 SLAAPZAK - DEKENMODEL 
 70x180 cm (afgewerkte maat) 
 
 • vulling 
 
 - polyester vezet + kunststof schuimlaag 
 
 - gewicht per m 3 
 
 • omhulsel 
 
 - buitenzijde: viscoserayonvezel 
 * binnenzijde: viscoserayonvezel 
 
 • dikte (i.v.m. warmtelsolatie) 
 
 - enbelast (bovenzijde) 
 
 550 g 
 
 I I \» I 
 
 12 24 36 
 
 (elk vak komt ongeveer overeen met een wollen deken) 
 - atname bij belasten (onderzijde) 52 
 
 8,5 % 
 12 3-4 5 
 1-2-34-5 
 
 !- afname na regelmatig gebruik en reinigen 
 ten hoogste 
 sterkte (5-hoogste waardering) 
 
 • kleurechtheid (5 hoogste waardering) 
 
 - bij wrijven 
 
 - bij zwelen 
 
 - bij wassen a 
 
 • krimp: ten hoogste A ?o 
 
 • gewicht (exci. loudraal): 2,1 kg 
 — • REINIGEN: zie etiket op slaapzak 
 
 INFORMATIE QEBASEERD OP 8TANOAAR0MEETMETH0DEN 
 
 SYNTON ALL SEASON 
 V. POLYDAUN, ZEVENAAR Jt.wi 
 
 Figure 3: Typical Label used in the Netherlands Informative Labeling (IE) Program 
 
 [FR Doc.76-15123 Filed 5-19-76; 4: 18 pm| 
 
 FEDERAL REGISTER, VOL. 41, NO. 102— TUESDAY, MAY 25, 1976 
 
 A-6 
 
Appendix B 
 
 U.S. DEPARTMENT OF COMMERCE 
 
 OFFICE OF THE SECRETARY 
 
 Reprinted from Federal Register, Volume 42, Number 101 --Wednesday, May 25, 1977 
 
 (Pages 26647-26651) 
 
 Title 15 — Commerce and Foreign Trade 
 
 SUBTITLE A — OFFICE OF THE SECRETARY 
 OF COMMERCE 
 
 PART 16 — PROCEDURES FOR A VOLUN- 
 TARY CONSUMER PRODUCT INFORMA- 
 TION LABELING PROGRAM 
 
 AGENCY: Assistant Secretary of Com- 
 merce for -Science and Technology, Com- 
 merce. 
 
 ACTION : Final rule. 
 
 SUMMARY: This new part to Title 15 
 CFR establishes procedures under which 
 a voluntary consumer product informa- 
 tion labeling program administered by 
 the Department of Commerce will func- 
 tion. Consumers today are unable in 
 many cases to make rational and accu- 
 rate marketplace decisions because of 
 lack of comparative, easily comprehen- 
 sible information at the point of sale on 
 important product performance charac- 
 teristics. Accordingly, the goal of this 
 program is to make available to consum- 
 ers, at the point of sale, information on 
 consumer product performance in an un- 
 derstandable and useful form. The pro- 
 gram is also intended to educate con- 
 sumers, distributors, and retailers in the 
 use of the product performance infor- 
 mation displayed and provide manu- 
 facturers and other participants in 
 the program with an opportunity to 
 convey to the public the particular ad- 
 vantages of their products. 
 
 EFFECTIVE DATE: June 24, 1977. 
 
 FOR FURTHER INFORMATION CON- 
 TACT: 
 
 Dr. Howard I. Forman, Deputy As- 
 sistant Secretary for Product Stand- 
 ards, Room 3876, U.S. Department of 
 Commerce, Washington, D.C. 20230, 
 202-37.7-3221. 
 
 SUPPLEMENTARY INFORMATION: 
 On May 25, 1976, the Department an- 
 nounced in the Federal Register (41 FR 
 21389) proposed procedures under which 
 a voluntary consumer product informa- 
 tion labeling program would be carried 
 out provided substantial need and sup- 
 port for such a program could be dem- 
 onstrated. The notice invited interested 
 persons to participate in the proposed 
 rulemaking by submitting written com- 
 ments or suggestions to the Department. 
 In addition, the notice advised that 
 three informal hearings would be held 
 on the proposed procedures. 
 
 Following the publication of the above 
 mentioned May 25 notice, written 
 statements and oral testimony were re- 
 ceived by the Department from 97 re- 
 spondents. The comments and testimony 
 represented input from private citizens, 
 consumer organizations, retailers, manu- 
 facturers, trade associations, testing 
 laboratories, consulting organizations, 
 educators, and government agencies. 
 The written comments and transcripts 
 of the hearings are part of the public 
 record which is available for inspection 
 and copying in the Department's Central 
 Reference and Records Inspection Facil- 
 ity, Room 5316, Main Commerce Build- 
 ing, 14th Street between E Street and 
 Constitution Avenue, NW., Washington, 
 D.C. 20230. 
 
 The comments and testimony on the 
 proposed procedures have been carefully 
 considered and evaluated. A summary 
 and analysis of the public's comrqents 
 and testimony has been prepared by the 
 Department. This document also is avail- 
 able for inspection and copying at the 
 Department's Central Reference and 
 Records Inspection Facility mentioned 
 above. 
 
 With regard to the question of whether 
 substantial need and support for the 
 program were demonstrated in the com- 
 ments received, sixty-four respondents 
 favored initiation of the program. Those 
 favoring the program included a ma- 
 jority of the private citizens, consumer 
 organizations, educators, government 
 agencies, and manufacturers of products 
 other than mechanical, electrical and 
 electronic products who commented. 
 Twenty-three respondents opposed initi- 
 ation of the program, and this group in- 
 cluded a majority of the trade associa- 
 tions and manufacturers of mechanical, 
 electrical and electronic products who 
 commented. Seven respondents from 
 various groups stated that they would 
 support initiation of a mandatory pro- 
 gram; however, such a course would be 
 beyond the scope of the Department's 
 proposal. 
 
 As noted, the comments received in- 
 dicated that a number of private citi- 
 zens, consumer organizations, educators, 
 government agencies and manufacturers 
 feel that there is a need for a consumer 
 product information labeling program. 
 Other comments indicated a lack of sup- 
 port by some manufacturers and trade 
 associations comprising a significant seg- 
 ment of the consumer product industry. 
 
 Upon balancing the respective views, the 
 Department has determined that the 
 public interest will be served best by in- 
 stituting the program on a limited pilot 
 project basis, and at the end of one 
 year of its operation, the Department will 
 evaluate its results to decide whether the 
 program merits continuance and, if so, 
 whether to enlarge or reduce the size and 
 scope of its operation. 
 
 A number of substantive changes in 
 the proposed procedures were made as a 
 result of the public's comments. The most 
 significant changes involve simplification 
 of the "finding of need" process and the 
 addition of provisions under which por- 
 tions of the program can be administered 
 by designated agents who would' make it 
 unnecessary for program participants to 
 report sensitive sales data directly to the 
 Department of Commerce. Other changes 
 in the procedures involve clarification of 
 the language used and the addition of 
 several terms to the section on defini- 
 tions. These various changes are dis- 
 cussed in greater detail below. 
 
 The proposed procedures called for the 
 use of a "finding of need" process that 
 would have required two separate publi- 
 cations of notices in the Federal Regis- 
 ter before work could be started on any 
 Performance Information Labeling Spec- 
 ification. Though this procedure was de- 
 signed to insure ample opportunity for 
 public input into the product selection 
 process, it also would have resulted in 
 what some respondents believed to be 
 unnecessary preliminary work and delay. 
 Two re lents suggested that the se- 
 lection process be simplified and short- 
 ened. Accordingly, upon further consid- 
 eration it was deemed appropriate to 
 eliminate the preliminary finding of 
 need. Under § 16.4(c) the Secretary, upon 
 receiving a request for a finding of need 
 to establish a specification for labeling 
 a consumer product may, if she deems 
 it to be in the public interest, develop 
 whatever additional information she feels 
 is necessary. This could include consulta- 
 tion on a one-time basis with consumers, 
 consumer organizations, and others. Ac- 
 cordingly, it is unnecessary to have a 
 preliminary finding of need. Rather, the 
 Secretary will make only one finding of 
 need which will be a final agency action. 
 The proposed procedures also called 
 for the establishment of fees and charges 
 for participation in the program. Accord- 
 ing to most respondents who commented 
 on this topic, the most equitable basis 
 
 B-l 
 
for establishing such fees would be to 
 relate the total fee paid by any one par- 
 ticipant to the number of units of the 
 product on which labels were placed. The 
 administration of such a fee schedule, 
 however, would require participants to 
 report to the Department the number of 
 units produced and labeled. Such infor- 
 mation is considered by many producers 
 to be confidential. Hence, in order to 
 avoid the necessity for the disclosure of 
 such confidential data or other valuable 
 proprietary trade information to the Sec- 
 retary and thus permit the association 
 of such data and information with a 
 particular participant, and in accordance 
 with other suggestions made that the 
 program be at least partly administered 
 by industry, provisions were added to the 
 final procedures under which individuals 
 or organizations such as trade associa- 
 tions could, when authorized by the Sec- 
 retary of Commerce, serve as designated 
 agents who would collect fees and statis- 
 tical information from consenting par- 
 ticipants, consolidate such fees and in- 
 formation from a number of partici- 
 pants, and transmit to the Secretary the 
 consolidated fees and information 
 '5 16.9). In addition, the proposed pro- 
 cedures were revised to recognize the va- 
 lidity of cost to participants as an item 
 to be considered in the program 
 '§ 16.4(b) '8)). 
 
 Finally, the proposed procedures were 
 revised to clarify and improve the lan- 
 guage in some areas. For example, the 
 term "participant" is now used to indi- 
 cate any manufacturer, assembler, pri- 
 vate brand labeler, or importer of con- 
 sumer products who participates in the 
 program, in place of the term "manufac- 
 turer" that was used previously. The defi- 
 nition of the term "consumer product" 
 was revised specifically to exclude prod- 
 ucts customarily intended primarily for 
 business, commercial, or industrial use. 
 Definitions for the terms "Specification" 
 and "designated agent" were added to the 
 final procedures, and several other minor 
 changes were made. 
 
 The procedures appended to this notice 
 have been carefully reviewed pursuant to 
 the provisions of Executive Order No. 
 11821 dated November 27, 1976 (39 FR 
 41501 dated November 29, 1974 >, Office 
 of Management and Budget Circular No. 
 A-107 dated January 28, 1975, and De- 
 partment of Commerce Administrative 
 Order 218-6 dated September 12, 1975. 
 and it has been determined that the pro- 
 mulgation of these procedures will have 
 no major inflationary impact. Each proj- 
 ect to develop a Performance Informa- 
 tion Labeling Specification initiated un- 
 der these procedures to effect the label- 
 ing of a specific class of consumer prod- 
 uct will be carefully examined and 
 evaluated to ascertain whether such 
 project would have a major inflationary 
 impact under the criteria described in 
 the above referenced Executive Order, 
 Office of Management and Budget Cir- 
 cular, and Department of Commerce Ad- 
 ministrative Order. 
 
 Issued: May 19, 1977. 
 
 Jordan J. Baruch, 
 Assistant Secretary for 
 Science and Technology. 
 
 16.6 
 
 16.7 
 
 16.8 
 
 16.9 
 
 16 10 
 
 16.11 
 
 16.12 
 
 16.13 
 
 Part 16 is added to Title 15 CFR to 
 read as follows: 
 
 Sec. 
 
 16.1 Purpose. 
 
 16.2 Description and goal of program. 
 
 16.3 Definitions. 
 
 16.4 Finding of need to establish a speci- 
 
 fication for labeling a consumer 
 product. 
 16 5 Development of performance informa- 
 tion labeling specifications. 
 
 Establishment of fees and charges. 
 
 Participation in program. 
 
 Termination of participation. 
 
 Rules governing designated agents. 
 
 The Department of Commerce mark. 
 
 Amendment or revision of a perform- 
 ance information labeling speci- 
 fication. 
 
 Consumer education. 
 
 Coordination with State and local 
 programs. 
 16.14. Annual report. 
 
 Authority: Sec. 2, 31 Stat. 1449. as amend- 
 ed: sec. 1, 64 Stat. 371; (15 U.S.C. 272); Re- 
 organization Plan No. 3 of 1946, Part VI. 
 
 § 16.1 Purpose. 
 
 The purpose of this part is to establish 
 procedures under which a voluntary con- 
 sumer product information labeling pro- 
 gram administered by the Department of 
 Commerce will function. 
 
 § 16.2 Description and goal of program. 
 
 (a) The Department's Voluntary Con- 
 sumer Product Information Labeling 
 Program makes available to consumers, 
 at the point of sale, information on con- 
 sumer product performance in an under- 
 standable and useful form so as to facil- 
 itate accurate consumer purchasing de- 
 cisions and enhance consumer satisfac- 
 tion. It also educates consumers, distrib- 
 utors and retailers in the use of the 
 product performance information dis- 
 played and provides manufacturers and 
 other persons who participate in the pro- 
 gram with an opportunity to convey to 
 the public the particular advantages of 
 their products. These objectives are ac- 
 complished by: 
 
 1. Selecting or developing standardized 
 test methods by which selected product 
 performance characteristics can be 
 measured; 
 
 2. Developing labeling methods by 
 which information concerning product 
 performance can be transmitted in use- 
 ful form to consumers at the point of 
 sale; 
 
 3. Encouraging manufacturers and 
 other participants in the program volun- 
 tarily to test and label their products ac- 
 cording to the selected or developed 
 methods; and 
 
 4. Encouraging consumers through 
 various informational and educational 
 programs to utilize the product perform- 
 ance information provided. 
 
 (b) The program involves voluntary 
 labeling by enrolled participants of 
 selected categories of consumer products 
 with information concerning selected 
 performance characteristics of those 
 products. The performance characteris- 
 tics selected are those that are of demon- 
 strable importance to consumers, that 
 consumers cannot evaluate through 
 mere inspection of the product, and that 
 can be measured objectively and re- 
 ported understandably to consumers. 
 The consumer products covered include 
 
 those for which Incorrect purchase de- 
 cision can result in financial loss, dis- 
 satisfaction, or inconvenience. The pro- 
 gram seeks to avoid the duplication of 
 other Federal programs under which 
 performance characteristics are labeled 
 by exempting those performance char- 
 acteristics from this program. 
 
 (c) For selected categories of con- 
 sumer products, the program includes 
 advertising guidelines covering situations 
 where quantitative performance values 
 are stated in advertising or where quali- 
 tative comparisions are made of the per- 
 formance of different products. 
 
 § 16.3 Definitions. 
 
 (a) The term "Secretary" means the 
 Secretary of Commerce or her designee. 
 
 (b) The term "consumer" means the 
 first person who purchases a consumer 
 product for purposes other than resale. 
 
 (c) The term "participant" means a 
 manufacturer, assembler or private 
 brand labeler of consumer products or 
 an importer of such products for resale 
 and who participates in the program. 
 
 <d> The term "consumer product" 
 means any article produced or distrib- 
 uted for sale to a consumer for the use, 
 consumption, or enjoyment of such con- 
 sumer. The term does not include prod- 
 ucts customarily intended primarily for 
 business, commercial, or industrial use. 
 
 (e» The term "person" means an in- 
 dividual; a manufacturer; distributor; 
 retailer; importer; private brand labeler; 
 government agency at the Federal (in- 
 cluding any agency of the Department 
 of Commerce), State and local level; 
 consumer organization; trade associa- 
 tion; standards writing body; profes- 
 sional society; testing laboratory; or ed- 
 ucational institution. 
 
 (f) The term "performance charac- 
 teristic" means a performance charac- 
 teristic of a consumer product that can 
 be measured in an objective manner with 
 respect to a given consumer product. 
 
 (g) The term "Specification" means 
 a Performance Information Labeling 
 Specification developed under § 16.5. 
 
 <h) The term "label" means printed 
 matter affixed to or otherwise provided 
 with a consumer product and contain- 
 ing all of the performance character- 
 istics as prescribed by the Specification 
 applicable to that product. 
 
 (i) The term "designated agent" 
 means a person as defined in paragraph 
 <e> of this section, who has been desig- 
 nated by the Secretary to carry out ap- 
 propriate operational procedures on be- 
 half of more than one participant in this 
 program in accordance with rules set out 
 under § 16.9. 
 
 § 16.4 Finding of need to establish a 
 specification for labeling a consumer 
 product. 
 
 (a) Any person may request the Sec- 
 retary to find that there is a need to 
 label a particular consumer product with 
 information concerning one or more spe- 
 cific performance characteristics of that 
 product. 
 
 (b) Such a request shall be in writing 
 and will, to the extent practicable, in- 
 clude the following information: 
 
 1. Identification of the consumer 
 product; 
 
 B-2 
 
2. Extent that the product identified 
 In subparagraph (1) of this paragraph 
 is used by the public and, if known, what 
 the production or sales volume is of such 
 product; 
 
 3. Nature and extent of difficulty ex- 
 perienced by consumers in making in- 
 formed purchase decisions because of a 
 lack of knowledge regarding the per- 
 formance characteristics of the identified 
 consumer product; 
 
 4. Potential or actual loss to consum- 
 ers as a result of an incorrect decision 
 based on an inadequate understanding 
 of the performance characteristics of 
 the identified consumer product; 
 
 5. Extent of incidence of consumer 
 complaints arising from or reasonably 
 traceable to lack of knowledge regarding 
 the performance characteristics of the 
 identified consumer product; 
 
 6. If known, whether there currently 
 exist test methods which could be used 
 to test the performance characteristics 
 of the identified consumer product and 
 an identification of those test methods; 
 
 (7) Reasons why it is felt, in cases 
 where existing test methods are identi- 
 fied in responding to subparagraph (6) 
 of this paragraph, that such test meth- 
 ods are suitable for making objective 
 measurements of the performance char- 
 acteristics of the identified consumer 
 product; and 
 
 (8) Estimated cost to participants to 
 test and label the product. 
 
 <c> The Secretary may ask for more 
 information to support a request made 
 under paragraph (a) of this section if 
 she feels it is necessary to do so, or, if 
 she deems it to be in the public interest, 
 may develop such information herself as 
 by consultation on a one-time basis with 
 consumers, consumer organizations, and 
 others. The Secretary shall act expedi- 
 tiously on all requests and shall notify 
 the requester of her decision in writing. 
 If the Secretary determines that there is 
 no need to establish a Specification for 
 labeling the requested consumer product 
 performance characteristics, or because 
 of a lack of resources, she will decline to 
 act further on the request. In those in- 
 stances where the Secretary declines a 
 request, she shall state the reasons for 
 so declining. 
 
 (d) If the Secretary finds that a need 
 exists to establish a Specification for 
 labeling a consumer product under this 
 program, she shall publish a notice in 
 the Federal Register setting out such 
 finding and its basis and stating that she 
 is developing a proposed Specification in 
 accordance with § 16.5. 
 
 § 16.5 Development of performance in- 
 formation labeling Specifications. 
 
 (a) If the Secretary makes a finding 
 of need pursuant to § 16.4, she will pub- 
 lish a proposed Performance Informa- 
 tion Labeling Specification in the Fed- 
 eral Register with a notice giving the 
 complete text of the proposed Specifica- 
 tion and any other pertinent informa- 
 tion. The notice will invite any interested 
 person to submit written comments on 
 the proposed Specification within 45 
 days after its publication in the Federal 
 Register, unless another time limit is 
 provided by the Secretary. Interested 
 persons wanting to express their views in 
 an informal hearing may do so, if within 
 
 15 days after the proposed Specification 
 is published in the Federal Register, 
 they request the Secretary to hold a 
 hearing. Such informal hearings shall 
 be held so as to give all interested per- 
 sons an opportunity for the oral pres- 
 entation of data, views, or arguments in 
 addition to the opportunity to make 
 written submissions. Notice of such hear- 
 ings shall be published in the Federal 
 Register. A transcript shall be kept of 
 any oral presentations. 
 
 (b) Each Specification shall as a mini- 
 mum include: 
 
 (1) A description of the performance 
 characteristics of the consumer product 
 covered ; 
 
 (2) An 'identification by reference of 
 the test methods to be used in measur- 
 ing the performance characteristics. The 
 test methods, where they exist and are 
 deemed appropriate for inclusion in the 
 particular Specification involved, shall be 
 those which are described in nationally- 
 recognized voluntary standards. Where 
 appropriate test methods do not exist, 
 they will be developed by the Department 
 of Commerce in cooperation with inter- 
 ested parties and set out in full in the 
 Specification; 
 
 (3) A prototype label and directions 
 for displaying the label on or with the 
 consumer product concerned. Such di- 
 rections will not prohibit the display of 
 additional information by the partici- 
 pant on space adjacent to the marked 
 boundaries of the label: and 
 
 (4) Conditions of participation. 
 
 (c) The Secretary, after consideration 
 of all written and oral comments and 
 other materials received in accordance 
 with paragraph (a) of this section, shall 
 publish in the Federal Register within 
 30 days after the final date for receipt 
 of comments, or as soon as practicable 
 thereafter, a notice either: 
 
 (1) Giving the complete text of a final 
 Specification, including conditions of use, 
 and stating that any prospective partici- 
 pant in the program desiring voluntarily 
 to use the Department of Commerce 
 Mark developed under § 16.10 must ad- 
 vise the Department of Commerce; or 
 
 (2) Stating that the proposed Specifi- 
 cation will be further developed before 
 final publication; or 
 
 (3) Withdrawing the proposed Specifi- 
 cation from further consideration. 
 
 § 16.6 Establishment of fees and 
 charges. 
 
 (a) The Secretary in conjunction with 
 the use of the Working Capital Fund of 
 the National Bureau of Standards, as 
 authorized under section 12 of the Act 
 of March 3, 1901, as amended (15 U.S.C. 
 278b), for this program, shall establish 
 fees and charges for use of the Depart- 
 ment of Commerce Label and Mark on 
 each product. Such fees and charges shall 
 be related to the number of units of 
 products labeled, where appropriate. The 
 fees and charges established by the Sec- 
 retary, which may be revised by her when 
 she deems it appropriate to do so, shall 
 be in amounts calculated to make the 
 operation of this program as self-suffi- 
 cient as reasonable. A separate notice 
 will be published in the Federal Reg- 
 ister simultaneously with the notice of 
 each proposed Specification referred to 
 
 in § 16.5(a). Such notice will set out a 
 schedule of estimated fees and charges 
 the Secretary proposes to establish. The 
 notice would be furnished for informa- 
 tional and guidance purposes only in or- 
 der that the public may evaluate the 
 proposed Specification in light of the 
 expected fees to be charged. 
 
 (b) At such time as the Secretary pub- 
 lishes the notice announcing the final 
 Specification referred to in § 16.5(c) d> , 
 she shall simultaneously publish a sep- 
 arate notice in the Federal Register set- 
 ting forth the final schedule of fees that 
 will be charged participants in the pro- 
 gram. The effective date of such final 
 schedule of fees shall be the same as the 
 date on which the final Specification 
 takes effect. 
 
 (c) Revisions, if any, to the fees and 
 charges established by the Secretary un- 
 der paragraph (b) of this section shall 
 be published in subsequent Federal Reg- 
 ister notices and shall take effect not less 
 than thirty (30) days after the date of 
 publication of such notice. 
 
 § 16.7 Participation in Program. 
 
 (a) Any manufacturer, assembler, or 
 private brand labeler of consumer prod- 
 ucts, or importer of such products for re- 
 sale, desiring to participate in this pro- 
 gram will so notify the Secretary. The 
 notification will identify the particular 
 Specification to be used and the prospec- 
 tive participant's identification and 
 model numbers for the products to be 
 labeled. The notification must include a 
 statement that if accepted as a partici- 
 pant in the program by the Secretary, 
 the prospective participant will: 
 
 (1) Abide by all conditions imposed by 
 these procedures: 
 
 (2) Abide by the conditions contained 
 in the Specification, as prescribed in 
 paragraph (d) of this section; 
 
 (3) Pay the fees and charges estar 
 lished by the Secretary; and 
 
 (4) Desist from using the Department 
 of Commerce Label and Mark if his par- 
 ticipation is terminated under § 16.8. 
 
 (b) The Secretary shall act expedi- 
 tiously on all requests to participate in 
 the program and shall notify each pros- 
 pective participant of her decision in 
 writing. In those Instances whfre the 
 Secretary declines a request, c>'ie shall 
 state the reasons for so declining. 
 
 (c) If a prospective participant seek- 
 ing to participate in the program is noti- 
 fied by the Secretary that she proposes 
 to deny that prospective participant the 
 right to participate, that prospective 
 participant shall have thirty (30) days 
 from the receipt of such notification to 
 request a hearing under the provisions of 
 5 U.S.C. 556. The Secretary's proposed 
 denial shall become final through the is- 
 suance of a written decision to such pro- 
 spective participant in the event that he 
 does not appeal such notification by the 
 end of the thirty (30) day period. If how- 
 ever, such prospective participant re- 
 quests a hearing within that thirty (30) 
 day period, the Secretary's proposed de- 
 nial shall be stayed pending the outcome 
 of the hearing held pursuant to 5 U.S.C. 
 556. 
 
 (d) The conditions set out in each 
 Specification will include, but not be lim- 
 ited to, the following : 
 
 B-3 
 
(1) Prior to the use of a Label, the 
 participant will make or have made the 
 measurements to obtain the information 
 required for inclusion on the Label and, 
 if requested, will forward within 30 days 
 such measurement data to the Secretary. 
 Such measurement data will be kept on 
 file by the participant or his agent for 
 two years after that product is no longer 
 manufactured unless otherwise provided 
 in the Specification. 
 
 (2) The participant will describe the 
 test results on the Label as prescribed in 
 the Specification. 
 
 (3) The participant will display or ar- 
 range to display, in accordance with the 
 appropriate Specification, the Label on 
 or with each individual product of the 
 type covered except for units exported 
 from the U.S. Participants who utilize 
 more than one brand name may par- 
 ticipate by labeling some or all of the 
 brand names. All models with the same 
 brand name must be included in the pro- 
 gram unless they are for export only. 
 
 (4) The participant agrees at his ex- 
 pense to comply with any reasonable re- 
 quest of the Secretary to have consumer 
 products manufactured, assembled, im- 
 ported, or privately brand labeled by him 
 tested to determine that testing has been 
 done according to the relevant Specifica- 
 tion. 
 
 (5) Participants may reproduce the 
 Department of Commerce Label and 
 Mark in advertising: Provided, That the 
 entire Label, complete with all informa- 
 t.ion required to be displayed at the point 
 of retail sale, is shown legibly and is not 
 combined or associated directly with any 
 other mark or logo. 
 
 § 16.8 Termination of participation. 
 
 (a» The Secretary upon finding that a 
 participant is not complying with the 
 conditions set out in these procedures or 
 in a Specification may terminate upon 30 
 days notice the participant's right to con- 
 tinue his participation in the program: 
 Provided, That the participant shall first 
 be given an opportunity to show cause 
 why the participation should not be 
 terminated. 
 
 (b) Upon receipt of a notice from the 
 Secretary of the proposed termination, 
 which notice shall set forth the reasons 
 for such proposed termination, the par- 
 ticipant shall have thirty (30) days from 
 the date of receipt of such notification to 
 request a hearing under the provisions of 
 5 U.S.C. 556. The Secretary's proposed 
 termination shall become final through 
 the issuance of a written decision to the 
 participant in the event such participant 
 does not appeal the proposed termination 
 within the thirty (30) day period. If, 
 however, the participant requests a hear- 
 ing within the thirty (30) day period, 
 the Secretary's proposed termination 
 shall be stayed pending the outcome of 
 the hearing held pursuant to 5 U.S.C. 
 556. 
 
 (c) A participant may at any time 
 terminate his participation and respon- 
 sibilities under this program with regard 
 to a specific type of product by giving 
 written notice to the Secretary that he 
 has discontinued use of the Department 
 of Commerce Label and Mark for all con- 
 sumer products of the type Involved. 
 
 § 16.9 Rules Governing Designated 
 Agents. 
 
 (a) The following rules, requirements 
 and tasks shall be applicable with respect 
 to the seeking of designated agent status 
 and the performance of that role after 
 such status has been obtained. Each per- 
 son desiring to be designated as a des- 
 ignated agent under this program shall: 
 
 (1) Make written application to the 
 Secretary; 
 
 (2) Provide appropriate information 
 showing his qualifications to represent 
 members within a given product area 
 and that more than one prospective par- 
 ticipant in that product area is agreeable 
 to such representation; and 
 
 (3) Agree to service any participant in 
 this program in the agent's cognizant 
 product area whether or not such par- 
 ticipant is a member of the organization 
 or body which that agent represents. 
 
 (b) The Secretary may require a per- 
 son seeking designated agent status to 
 supply further information before grant- 
 ing such status to that person. The Sec- 
 retary will notify each person seeking 
 designated agent status, in writing, as 
 expeditiously as possible after evaluat- 
 ing such person's application. 
 
 (c) Each person granted designated 
 agent status shall : 
 
 (1) Provide the Secretary with a list 
 of the participants that the designated 
 agent services under the program. The 
 Secretary shall also be provided an up- 
 dated list as soon thereafter as may be 
 practicable whenever there are any 
 changes in the list ; 
 
 (2) Collect fees and charges from the 
 participants serviced under this program, 
 consolidate such sums, and transmit 
 those fees and charges required under 
 § 16.6 to the Secretary; 
 
 (3) Distribute Department of Com- 
 merce Marks developed under § 16.10 or 
 Instructions for the printing of such 
 Marks to the participants that the desig- 
 nated agent services under this program; 
 
 (4) Gather and consolidate such sta- 
 tistical information as may be required 
 by the Secretary from individual partici- 
 pants serviced; 
 
 (5) Provide the Secretary with reports, 
 including the consolidated statistical in- 
 formation referred to in subparagraph 
 (4) of this paragraph, as may be called 
 for by her, relative to the activities of the 
 participants the designated agent is 
 servicing; and 
 
 (6) Perform any additional tasks 
 mutually agreed upon by the designated 
 agent and the Secretary. 
 
 (d) If a person seeking designated 
 agent status is notified by the Secretary 
 that she proposes to deny that person 
 such status, that person shall have thirty 
 (30) days from the date of receipt of 
 such notification to request a hearing 
 under the provisions of 5 U.S.C. 556. The 
 Secretary's proposed denial shall become 
 final through the issuance of a written 
 decision to such person in the event that 
 he does not appeal such notification by 
 the end of that thirty (30) day period. 
 If, however, such person requests a hear- 
 ing within that thirty (30) day period, 
 the Secretary proposed denial shall be 
 stayed pending the-outcome of the hear- 
 ing held pursuant to 5 U.S.C. 556. 
 
 (e) If the Secretary finds that a desig- 
 
 nated agent has violated the terms of 
 paragraph (c) of this section, she may, 
 after consultation with such designated 
 agent, notify such person that she pro- 
 poses to revoke his status as a designated 
 agent. 
 
 (f ) Upon receipt of a notice from the 
 Secretary of the proposed revocation, 
 which notice shall set forth the reasons 
 for such proposed revocation, the desig- 
 nated agent shall have thirty (30) days 
 from the date of receipt of such notifica- 
 tion to request a hearing under the pro- 
 visions of U.S.C. 556. The Secretary's 
 proposed revocation shall become final 
 through the issuance of a written decision 
 to the designated agent in the event such 
 designated agent does not appeal the pro- 
 posed revocation within that thirty (30) 
 day period. If, however, the designated 
 agent requests a hearing within that 
 thirty (30) day period, the Secretary's 
 proposed revocation shall be stayed 
 pending the outcome of the hearing held 
 pursuant to 5 U.S.C. 556. 
 
 § 16.10 The Department of Commerce 
 Mark. 
 
 The Department of Commerce shall 
 develop a Mark which shall be registered 
 in the U.S. Patent and Trademark Of- 
 fice under 15 U.S.C. 1054 for use on each 
 Label described in a Specification. 
 
 § 16.11 Amendment or Revision of a 
 Performance Information Labeling 
 Specification. 
 
 The Secretary may by order amend or 
 revise any Specification published under 
 § 16.5. The procedure applicable to the 
 establishment of a Specification under 
 § 16.5 shall be followed in amending or 
 revising such Specification. Such amend- 
 ment or revision shall not apply to con- 
 sumer products manufactured prior to 
 the effective date of the amendment or 
 revision. 
 §16.12 Consumer Education. 
 
 The Secretary, in close cooperation 
 and coordination with interested Govern- 
 ment agencies, appropriate trade associ- 
 ations and industry members, consumer 
 organizations, an other interested per- 
 sons shall carry out a program to edu- 
 cate consumers relative to the signifi- 
 cance of the labeling program. Some ele- 
 ments oi Li'.is prog im shall also be 
 directed toward informing retailers and 
 other interested groups about the 
 program. 
 
 § 16.13 Coordination with State and 
 Local Programs. 
 
 The Secretary will establish and main- 
 tain an active program of communica- 
 tion with appropriate State and local 
 government offices and agencies and will 
 furnish and make available information 
 and assistance that will promote uni- 
 formity in State and local programs for 
 the labeling of performance characteris- 
 tics of consumer products. 
 
 §16.14 Annual Report. 
 
 The Secretary will prepare an annual 
 report of activities under the program, 
 including an evaluation of the program 
 and a list of participants, designated 
 agents, and types of consumer products 
 covered. 
 
 (FR Doc. 77-14851 Piled 5-20-77:3:00 pm] 
 
 B-4 
 
57686 
 
 RULES AND REGULATIONS 
 
 [3510-18] 
 
 Title 15— Commerce and Foreign Trade 
 SUBTITLE A— OFFICE OF THE SECRETARY 
 
 OF COMMERCE 
 PART 16— PROCEDURES FOR A VOLUN- 
 TARY CONSUMER PRODUCT INFORMA- 
 TION LABELING PROGRAM 
 Amendment to Authorize the Secretary to 
 Suspend Fees and Charges 
 
 AGENCY: Assistant Secretary of Com- 
 merce for Science and Technology, Com- 
 merce. 
 
 ACTION: Rule. 
 
 SUMMARY : This document amends the 
 procedures for the Voluntary Consumer 
 Product Information Labeling Program 
 to authorize the Secretary at any time 
 to suspend for any length of time the 
 requirement for her to establish fees and 
 charges for participation in the program. 
 This amendment will provide the Secre- 
 tary with greater flexibility to encourage 
 participation by manufacturers and 
 others in this program. 
 
 EFFECTIVE DATE: December 5, 1977. 
 
 FOR FURTHER INFORMATION CON- 
 TACT: 
 
 Dr. Howard I. Forman, Deputy Assist- 
 ant Secretary for Product Standards, 
 Room 3876, U.S. Department of Com- 
 merce, Washington, D.C. 20230, 202- 
 377-3221. 
 
 SUPPLEMENTARY INFORMATION: 
 On May 25, 1977, the Department of 
 Commerce announced in the Federal 
 Register (42 FR 26647) procedures un- 
 der which a Voluntary Consumer Prod- 
 uct Information Labeling Program ad- 
 ministered by the Department will func- 
 tion. The Department determined that 
 the program would be instituted on a 
 limited pilot project basis. Section 16.6 
 (a) of the procedures provides that the 
 Secretary shall establish fees and 
 oharges for use of the Department of 
 Commerce Label and Mark on each 
 product. 
 
 On August 30, 1977, the Department 
 announced in the Federal Register (42 
 FR 43641) that, upon further study of 
 the need to establish such fees and 
 charges, it had been determined that it 
 would be in the public interest to dis- 
 pense with all fees and charges at least 
 for the duration of the limited pilot proj- 
 ect in order to encourage participation 
 by manufacturers in the program. In 
 order to provide the Secretary with au- 
 thority to suspend the fees and charges 
 required by I 16.6(a) of the procedures, 
 a proposed amendment was published in 
 the Federal Register (42 FR 43641, Au- 
 gust 30, 1977). Interested persons were 
 invited to submit written comments on 
 the proposed amendment on or before 
 September 29, 1977. 
 
 Comments concerning the proposed 
 amendment were received from two 
 sources. The first of these was submitted 
 by the Office of Consumer Affairs, De- 
 partment of Health, Education, and 
 
 Welfare, which stated support for the 
 proposed amendment and offered certain 
 suggestions for the Department's con- 
 sideration that might additionally in- 
 crease industry acceptance of the pro- 
 gram. These suggestions were not di- 
 rected toward the proposed amendment : 
 however, the Department may consider 
 them in its continuing review of the pro- 
 gram. 
 
 The second comment was provided b.v 
 Electrical Testing Laboratories, Inc 
 (ETL), New York, N.Y. ETL »tated op- 
 position to the proposed amendment be- 
 cause it would increase the amount of 
 taxpayer's money used to support a pro- 
 gram that ETL considers competitive 
 with available existing programs. ETL 
 stated that the proposed amendment 
 represents the utilization of taxpayer's 
 money to subsidize programs that are 
 competitive with existing, available pro- 
 grams. After careful consideration, the 
 Department has determined that if the 
 Procedures for the Voluntary Consumer 
 Product Information Labeling Program 
 (CPILP) provide the Secretary with au- 
 thority to suspend fees and charges, the 
 public interest will be served in appro- 
 priate cases by encouraging companies 
 to participate in the program who would 
 not do so if they had to pay such fees 
 and charges. The Department does not 
 believe that this program will compete 
 with existing programs, but that it will 
 operate in conjunction with such pro- 
 grams. Therefore, the comment by ETL 
 is not considered persuasive. 
 
 Copies of the two letters of comment 
 received and a summary and analysis of 
 these letters are available for public in- 
 spection and copying in the Depart- 
 ment's Central Reference and Records 
 Inspection Facility, Room 5317, Main 
 Commerce Building, 14th Street between 
 E Street and Constitution Avenue NW.. 
 Washington, D.C. 20230. 
 
 Accordingly, in order to provide the 
 Secretary with authority to suspend the 
 fees and charges required by § 16.6(a) of 
 the procedures, these procedures are 
 hereby amended by adding a new para- 
 graph <d) to § 16.6 as set forth below 
 
 Note. — The Department of Commerce has 
 determined that adoption of this amendment 
 does not constitute a major proposal requir- 
 ing preparation of an Economic Impact 
 Statement under Executive Order 11821. as 
 amended by Executive Order 11949, and Of- 
 fice of Management and Budget Circular No 
 A-107. 
 
 Issued: October 31, 1977. 
 
 Jordan J. Baruch, 
 Assistant Secretary for 
 Science and Technology. 
 
 15 CFR 16.6 is amended by adding a 
 new paragraph (d) to read as follows: 
 
 § 16.6 Establishment of fees and charged. 
 
 ***** 
 (d) The establishment of fees and 
 charges under this section may, at any 
 time, be suspended by the Secretary for 
 any length of time. 
 
 [FRDoc.77-32082 Filed 11-1-77:5:07 pm] 
 
 FEDERAL REGISTER, VOL. 42, NO. 213 — FRIDAY, NOVEMBER 4, 1977 
 
 B-5 
 
[3510-13] 
 
 »i.-,. IS C ■.. t :,Jf...w'j/(.-i. 
 
 SUBTntJ A— OFFKI OF THS SS€tf?AaV Of> 
 COMMERC1 
 
 ?AIT 16—*SOCEEA)*IS FOB A VOLUHTA&tf- 
 CONSUMER PXOOUCT INFORMATION LA- 
 SUING FtOSftAM 
 
 AoMndaMOt T» P***H Cf!SJ> UUb Ta tedw4e 
 
 Uik Whmt AaoHmt F*S«f<at Ag en c y B«q w lf » 
 Ub*t«d iNfwsMrtim Abu rt Ttset CharacfeKta- 
 tic 
 
 AGENCY: Assistant Secretary for Sci- 
 ence and Technology. UJ3. Depart- 
 ment of Commerce. 
 
 ACTION: Rule. 
 
 SUMMARY: This document amends 
 the procedures for the Voluntary Con- 
 sumer Product Information Labeling 
 Program (CPILP) to authorize the De- 
 partment of Commerce to Include on 
 CPILP label* for selected consumer 
 products Information about perfor- 
 mance characteristics which are in- 
 cluded in the labeling program of an* 
 other Federal agency, provided the 
 other agency agrees. The object of the 
 amendment is to decrease the com- 
 plexity of labeling for manufacturers 
 by enabling them to comply with the 
 labeling requirements of other Gov- 
 ernment programs through participa- 
 tion in CPILP. and to simplify product 
 comparison by consumers at the point 
 of sale. 
 
 EFFECTIVE DATE: March 31. 1978. 
 
 FOR FURTHER INFORMATION 
 CONTACT. 
 
 Dr. Howard I. Forman, Deputy As- 
 sistant Secretary for Product Stan- 
 dards. Room 3876, U.S. Department 
 of Commerce. Washington, D.C 
 20230. 202-377-3221. 
 
 SUPPLEMENTARY INFORMATION: 
 On May 25. 1977. the Department of 
 Commerce announced in the Frontal. 
 Register (42 FR 26647) procedures 
 under which a Voluntary Consumer 
 Product Information Labeling Pro- 
 gram administered by the Department 
 will function. The Department deter- 
 mined that the program would be in- 
 stituted on a limited pilot project 
 basis. The goal of this program is to 
 make available to consumers, at the 
 point of sale, information on consumer 
 product performance in an understan- 
 dable and useful form. 
 
 Other Government agencies— such 
 as the Federal Trade Commission, the 
 Consumer Product Safety Commis- 
 sion, and the Environmental Protec- 
 tion Agency— also are proposing or 
 considering various information disclo- 
 sure requirements for consumer prod- 
 ucts. In many cases, however, it would 
 be desirable to provide on a single 
 label Information of interest to con- 
 sumers r.bout a wider ran^e of attri- 
 bute; than is being considered for la- 
 beling requirements by any one 
 
 agency. For selected consumer prod- 
 ucts, the Department of Commerce de- 
 sires to make CPILP labels compatible 
 with the corresponding labeling re- 
 quirements or recommendations pro- 
 mulgated by other agencies, so that 
 the information disclosure require- 
 ments of those agencies can be satis- 
 fied by participation In CPILP. In 
 such cases, product labeling would be 
 simplified for manufacturers partici- 
 pating in CPILP since compliance with 
 those other agency requirements 
 would be assured. Product comparison 
 by consumers at the point of sale also 
 would be simplified since all of the In- 
 formation would be on a single label 
 having a uniform, consumer-oriented 
 format. 
 
 The final sentence in § 16.2(b) of the 
 CPILP procedures states that: "The 
 program seeks to avoid the duplication 
 of other Federal programs under 
 which performance characteristics are 
 labeled by exempting those perfor- 
 mance characteristics from this pro- 
 gram." In view of the above stated 
 desire of the Department of Com- 
 merce to include on CPILP labels per- 
 formance characteristics which are In- 
 cluded in other Federal labeling pro- 
 grams, a proposed amendment was 
 published in the Federal Register (42 
 FR 64909. December 29. 1977) to 
 amend the final sentence of § 16.2(b) 
 of the CPILP procedures. It was em- 
 phasized In the preamble to the pro- 
 posed amendment that CPILP is a vol- 
 untary program, and that manufactur- 
 ers can comply with the labeling re- 
 quirements of other Federal agencies 
 without participating in CPILP. Inter- 
 ested persons were invited to submit 
 written comments on the proposed 
 amendment on or before January 30, 
 1978. 
 
 Comments concerning the proposed 
 amendment were received from two 
 sources. .A card dated January 3. 19'C, 
 from Amy Beckett. 1310 East Meadow- 
 mere, Springfield, Mo. 656CW, endorsed 
 "the Commerce Department proposal 
 to coordinate Federal product labeling 
 requirements." The second letter 
 dated January 16, 1978, was received 
 from Lawrence H. Hodges, Vice Presi- 
 dent, Technical Affairs. J I Case Co,, 
 700 State Street. Racine. Wis. 53404. 
 This letter states, "J 1 Case Co. sup- 
 ports the Department's proposal that 
 certain mandated labeling required by 
 the regulations of other regulatory 
 agencies and the labeling required by 
 voluntary participants in the DoCs 
 "Voluntary Consumer Product Infor- 
 mation Labeling Program <CPILP) be, 
 in some instances, incorporated into 
 one label.' " 
 
 Copies of the two letters of comment 
 received, and a summary and analysis 
 of these letters are available for pubhc 
 Inspection and copying in the Depart- 
 ment's Central Reference and Records 
 Inspection Facility. Room 5317, Main 
 Commerce Building, 14th Street be- 
 tween E Street and Constitution 
 Avenue NW„ Washington. D.C. 20230. 
 
 For purposes of clarity, the amend- 
 ment language was changed slightly so 
 that the amendment consists of 
 adding a new sentence at the end of 
 8 16.2(b). Accordingly, the CPILP pro- 
 cedures are hereby amended as set 
 forth below. 
 
 Nora.— The Department of Commerce has 
 determined that adoption of this amend- 
 ment does not constitute a major proposal 
 requiring preparation of an Economic 
 Impact Statement under Executive Order 
 11821. as amended by Executive Order 
 11949, and Office of Management and 
 Budget Circular No. A-107. 
 
 Issued: February 24. 1978. 
 
 Jordan J. Baruch. 
 
 Assistant Secretary for 
 Science and Technology. 
 
 §16.S [Amended) 
 
 15 CFR Part 16 is amended by 
 adding the following sentence at the 
 end of § 16.2(b): 
 
 However, where the Federal agency con- 
 cerned agrees, the Department of Com- 
 merce may include Information about those 
 performance characteristics In CI'ILI* labels 
 If. by doing so, product comparison at the 
 point of sale is simplified for consumers, 
 and the complexity of product labeling Is re- 
 duced for the manufacturers by enn.bllr.ft 
 them to comply with the labeling require- 
 ment* of other Federal agencies through 
 participation Ln CPILP. 
 
 Section 18.2(b), as amended, will 
 read In its entirety as follows: 
 
 § 16.2 Description and goal of program. 
 
 (b) The program involves voluntary 
 labeling by enrolled participants of se- 
 lected categories of consumer products 
 with Info mation concerning selected 
 perform nee C-i.uacterlstics of those 
 products. Tl* performance character- 
 istics selected are those that are of de- 
 monstrable importance to consumers, 
 that consumers cannot evaluate 
 through mere Inspection of the prod- 
 uct, and that can be measured objec- 
 tively and reported understandably to 
 consumers. The consumer products 
 covered Include those for which Incor- 
 rect purchase decision can. result in fi- 
 nancial loss, dissatisfaction, or Incon- 
 venience. The program seeks to avoid 
 the duplication of other Federal pro- 
 grams under which performance char- 
 acteristics are labeled by exempting 
 those performance characteristics 
 from this program. However, where 
 the Federal agency concerned agrees, 
 the Department of Commerce may In- 
 clude Information about those perfor- 
 mance characteristics in CPILP labels 
 If, by doing so, product comparison at 
 the point of sale is simplified for con- 
 sumers, and the complexity of product 
 labeling is reduced for the manufac- 
 turers by enabling them to comply 
 with the labeling requirements of 
 other Federal agencies through par- 
 ticipation in CPILP. 
 IFR Doe 78-5398 Filed 2-28-78; 8:45 ami 
 
 FEDSRAl *JS!ST«, VOL 43, NO. 41_WEDN£SDAr. MA8CH 1, 1978 
 
 B-6 
 
Appendix C 
 
 Department of Commerce 
 
 Voluntary Consumer Product Information Labeling Program 
 
 Abstract of Program Procedures 
 
 NOTE: Program procedures were published in the Federal 
 Register on May 25, 1977 (42FR26647), and were amended on 
 November 4, 1977 (42FR57686) and March 1, 1978 (43FR8254). 
 This abstract covers much of the content of the procedures, 
 but is not intended as a substitute for the official document 
 or for any of the terms, conditions, or requirements which 
 are set out in that document. 
 
 1^.1 Purpose. The purpose of this part (Part 16, Title 15) 
 of the Code of Federal Regulations is to establish operating 
 procedures for the Department of Commerce Voluntary Consumer 
 Product Information Labeling Program. 
 
 16.2 Program Goal. The goal of the program is to make 
 product performance information available to consumers at 
 the point of sale. A further goal is to educate consumers 
 in the use of product performance information. The program 
 will also help participants more accurately describe to 
 consumers the performance of their products . 
 
 Program participants such as manufacturers and retailers 
 will test their products using standardized test methods and 
 will label their products with the results of the tests. 
 Prpducts covered will be those that consumers have difficulty 
 evaluating and comparing. Performance characteristics covered 
 will be chiefly those that are important to consumers and 
 can be measured objectively, but that consumers cannot 
 determine through mere inspection of the product. Performance 
 characteristics covered by programs of other Federal agencies 
 will be covered only when the other, agency agrees. 
 
 The program will also cover some advertising requirements 
 for labeled products. 
 
 16.3 Definit ions . The terms used have the following 
 meanings : 
 
 "Secretary" means the Secretary of Commerce. 
 
 "Consumer" means the person who purchases a consumer product 
 for his or her own use. 
 
 C-l 
 
"Participant" means a manufacturer, assembler, importer, or 
 private brand labeler of consumer products who is in the 
 program. 
 
 "Consumer product" means a product sold to a consumer for 
 his or her own use, except for products that are intended 
 primarily for business or industrial use. 
 
 "Person" means an individual or any of several types of 
 business, industrial, educational, or government 
 organizations . 
 
 "Performance characteristic" means an aspect of a product's 
 performance that can be measured objectively. 
 
 "Specification" means a Performance Information Labeling 
 Specification as discussed in section 16.5. 
 
 "Label" means printed matter accompanying a consumer product 
 and describing that product's performance. 
 
 "Designated agent" means an individual or organization 
 representing participants in the program. 
 
 16.4 Products to be Covered . Any person may ask the 
 Secretary to label a particular consumer product with 
 performance information. The request should include all 
 information that person has available on the problems 
 associated with the suggested product, including knowledge 
 of any current test methods which could be used to measure 
 the performance of suggested product. The Secretary may 
 obtain additional information from the requester or from 
 other sources. 
 
 The Secretary will notify the person who requested the 
 labeling of her decision. If the Secretary determines that 
 the product should be labeled, she will also publish a 
 "finding of need" in the Federal Register. 
 
 16.5 Labeling Specifications . A Performance Information 
 Labeling Specification will be developed for each type of 
 consumer product to be labeled. Each Specification will 
 describe the test methods to be used, the label design, and 
 all program rules relating to the particular product. 
 
 Each new proposed Specification will be published in the 
 Federal Register for public comment. Anyone may send their 
 comments to the Secretary, or request a public hearing. 
 
 C-2 
 
When all the comments are in, the Specification will be 
 either revised and published in final form or withdrawn, 
 depending on the nature of the comments. 
 
 16.6 Fees . The Secretary will set fees to be paid by 
 participants in the program. The fee schedule for a 
 particular consumer product will be published in the Federal 
 Register at the same time as the Specification. Fees will 
 be related to the number of products labeled, where 
 appropriate. The Secretary may suspend the fee requirement 
 at any time for any length of time. 
 
 16.7 Participants . Any manufacturer, assembler, importer, 
 or private brand labeler of a covered consumer product may 
 ask to be in the program. The Secretary will notify the 
 applicant whether he or she has been admitted. Any 
 applicant who is not admitted may request a hearing. 
 
 Participants must agree to follow the rules of the program. 
 
 16.8 Termination of Participation . Participants who do not 
 follow the rules of the program may be removed from the 
 program. Participants who are notified of impending removal 
 may request a hearing. 
 
 Participants may drop out of the program whenever they wish. 
 
 16.9 Designated Agents . Individuals and some types of 
 business, industrial, or educational organizations may ask 
 to'be designated agents in the program. The Secretary will 
 notify each applicant whether he or she has been accepted. 
 Any applicant who is not accepted may request a hearing. 
 
 Designated agents collect information and fees from 
 participants who want to use their services. The agents 
 consolidate the fees and information collected and send them 
 to the Department of Commerce. This permits participants to 
 be in the program without revealing their exact sales 
 figures. 
 
 Designated agents who do not follow the rules of the program 
 may be removed from the program. Designated agents who are 
 notified of impending removal may request a hearing. 
 
 16.10 DoC Mark . The Department of Commerce will develop and 
 register a distinctive mark to be used on each label 
 described in a specification. 
 
 C-3 
 
16.11 Revision of Specifications . Performance Information 
 Labeling Specifications may be revised using the same 
 procedures that were used to develop them, but the revision 
 will not apply to consumer products manufactured before the 
 revision. 
 
 16.12 Consumer Education . A consumer education program will 
 be carried out as part of the labeling program. 
 
 16.13 Coordination . The program will be coordinated with 
 State and local programs. 
 
 16.14 Annual Report . Program activities will be described 
 in annual reports. 
 
 6/17/77 
 revised 11/8/77 
 3/10/78 
 
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 « 
 
 PLEASE RETURN THIS CARD 
 
 VOLUNTARY CONSUMER PRODUCT INFORMATION LABELING PROGRAM 
 
 check appropriate boxes 
 
 □ We support the program in concept. 
 
 □ We may be interested in participating in the program. 
 
 □ Please send us more information. 
 
 Name 
 
 Position 
 
 Affiliation 
 Address _ 
 
 Telephone 
 
 D.4 
 
Appendix E 
 
 Summary Report 
 
 of Letters Received by the 
 
 Voluntary Consumer Product Information 
 
 Labeling Program 
 
 Report Period: June 24, 1977 - June 30, 1978 
 
 Date Prepared: July 1978 
 Prepared by: J. J. Persensky 
 
 J. L. Gagnon 
 
 E-l 
 
On June 24, 1977, the Voluntary Consumer Product Information 
 Labeling Program was formally initiated by announcement 
 in the Federal Register . The procedures stated that: 
 
 "1116.4(a) Any person may request the Secretary 
 to find that there is a need to label a particular 
 product with information concerning one or more 
 specific performance characteristics of that product. 
 
 (b) Such request shall be in writing and will, 
 to the extent practicable, include the following 
 information ..." 
 
 In addition to the announcement in the Federal Register 
 other means of informing "persons" of their right to 
 request the labeling procedures existed. These were: 
 
 1. News Releases 
 
 2. Direct distribution of program brochures 
 
 3. Personal contacts 
 
 4. Distribution of program brochures through 
 
 consumer groups . 
 
 E-2 
 
A file of the letters received by the program has been 
 established. Responses to all letters have been processed 
 by either the Office of Product Standards or the Center 
 for Consumer Product Technology. 
 
 Reports detailing the requests received during the periods 
 June - December 1977 and June 1977 - March 1978 were submitted 
 in January and April 19 78 respectively. The present report 
 details requests received during the period June 24, 1977 
 through June 30 , 19 78. 
 
 Data Summarv 
 
 During the period June 24, 1977 through June 30, 1978, a 
 total of 1375 letters were received. A total of 145 different 
 products or product categories (e.g. automotive accessories, 
 food, appliances, etc.) were suggested for inclusion in the 
 program. There were 496 requests for products or product 
 categories to be labeled. Fifty-five of the letters included 
 requests for more than one product. Of the total letters, ' 
 1071 were requests for information only. The other letters 
 were requests to include products in the program or product 
 and information requests. 
 
 E-3 
 
The product request letters were tabulated in categories by 
 author. Fifteen author categories were established. These 
 categories and the respective number of requests to include 
 products are presented in Table 1. 
 
 Table 1. Product Requests by Author 
 
 Consumer 394 
 
 Consumer group 47 
 
 Industry general 3 
 
 Manufacturers 5 
 
 Retailers 
 
 Suppliers 
 
 Financial Servi ces 
 
 Consultants 1 
 
 Educators 20 
 
 Local Government 7 
 
 State Government 6 
 
 Federal Government 5 
 
 Foreign 1 
 
 Consumer Reporter 6 
 
 Other 1 
 
 Total 496 
 
 The categories, by author, include letters from organizations 
 
 as listed below. 
 
 Consumers - Individuals with no apparent affiliation. 
 
 Consumer Groups - Recognized consumer affiliations 
 such as the National Consumer League 
 
 General Industry - No specified relation to manufacturer, 
 retailer or supplier, etc. 
 
 Manufacturers - Those who can be identified as the 
 
 producers of products and have submitted letters on 
 company stationary. 
 
 Retailers - Those who can be identified as being involved 
 in direct sales to consumers. 
 
 Suppliers - Businesses which are identified to supply 
 products to industry or retailers 
 
 Note: The data described do not resolve to the total number of letters 
 because the letters may have included more than one product request. The 
 data were tabulated only in terms of product or product and information 
 requests. 
 
 E-4 
 
Financial Services - Banks, credit unions, insurance 
 
 Consultants - As identified by letterhead 
 
 Educators - Those requesting information for use in 
 formal class work 
 
 Local Goverment - City or county offices of consumer 
 affairs 
 
 State Government - State consumer offices, States 
 Attorney General, state uniyersities , and 
 extension services 
 
 Federal Government - Main or local offices of the Federal 
 Government 
 
 Foreign - Requests from other countries 
 
 Consumer Reporter - Individuals who identify themselves 
 with the print or electronic media 
 
 Other - Individuals or groups with no specified 
 affiliation but should not be identified as 
 individual consumers 
 
 Two additional categories of letters were established. These 
 were Positive Reaction (no product or information requested) 
 4 letters received, and Negative Reaction (no product or 
 information requested) 17 letters received. 
 
 All data are tabulated by product and category of author 
 in Appendix I. 
 
 E-5 
 
The 26 products for which the greatest number of requests were 
 received during the data collection period and the associated 
 number of requests are liseted in Table 2. 
 
 In addition to the tabulations described above the letters 
 were reviewed to determine if the particular respondent 
 indicated support for the program in concept, interest in 
 participating in the program, or information only. The 
 distribution of requests, by author category, is presented 
 in Table 3. 
 
 Note: The numbers expressed in this report may not 
 agree or resolve to data presented in the two earlier reports. 
 However, the, reporting system and categories have been 
 modified for more detailed tabulation and easier access. All 
 letters have been reviewed and validated. The values expressed 
 herein supercedes all earlier data. 
 
 E-6 
 
Table 2. 26 Products Receiving the Greatest Number of Requests 
 
 Food 49 
 
 Electric Appliances (Unspecified) 23 
 
 Clothes 21 
 
 Vacuum Cleaners 18 
 
 Refrigerators/Freezers 14 
 
 Automobiles and Accessories 13 
 
 Home Insulation 13 
 
 Carpet 11 
 Cosmetics 9 
 
 Furniture 9 
 
 Lawn Mowers 9 
 
 Stero Equipment 9 
 
 Televisions 9 
 
 Washing Machines 9 
 
 Air Conditioners 8 
 
 Hair Dryers 8 
 
 Shoes 8 
 
 Radios 7 
 
 Bed Liners and Blankets 6 
 
 Fans 6 
 
 Ranges (Gas and Electric) 6 
 
 Solar Equipment 6 
 
 Batteries 5 
 
 Lamps 5 
 
 Mattresses 5 
 
 Smoke Detectors 5 
 
 E-7 
 
Table 3. Total Requests by Author Category 
 
 
 
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 Consumer 438 
 
 Consumer Group 30 1 
 
 Industry General 
 
 Manufacturers 
 
 Retailer 
 
 Suppliers 
 
 Financial Services 
 
 Consultants 
 
 Educators 
 
 Local Government 
 
 State Government 
 
 Federal Government 
 
 Foreign 
 
 Consumer Reporters 
 
 Other 10 
 
 TOTAL 1,071 123 154 
 
 245 
 
 89 
 
 114 
 
 105 
 
 20 
 
 31 
 
 26 
 
 4 
 
 2 
 
 3 
 
 1 
 
 1 
 
 8 
 
 
 
 2 
 
 12 
 
 
 
 1 
 
 63 
 
 2 
 
 1 
 
 70 
 
 2 
 
 1 
 
 36 
 
 2 
 
 1 
 
 5 
 
 
 
 
 
 8 
 
 
 
 
 
 12 
 
 2 
 
 
 
 E-8 
 
APPENDIX I 
 Tabulation of Products and 
 Product Categories by Author Category 
 
 E-9 
 
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 Local 
 
 
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 Product 
 
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 !-• 
 
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 Local 
 Government 
 
 I-* 
 
 State 
 Government 
 
 Federal 
 Government 
 
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 Reporters 
 
 Other 
 
 Total by 
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U.S. DEPARTMENT OF COMMERCE 
 
 OFFICE OF THE SECRETARY 
 
 Reprinted from Federal Register, Volume 42, Number 240--Wednesday, December 14, 1977 
 
 (Pages 62946-62949) 
 
 Office of the Secretary 
 
 VOLUNTARY CONSUMER PRODUCT 
 INFORMATION LABELING PROGRAM 
 
 Finding of Need To tabs! Thermo) Insulation 
 for Homes 
 
 AGENCY. Assistant Secretary of Com- 
 merce for Science and Technology, 
 Commerce. 
 
 ACTION: Notice of Finding of Need. 
 
 SUMMARY: Pursuant to the Proce- 
 dures for a Voluntary Consumer Prod- 
 uct Information Labeling Program ( 15 
 CPR Part 16), this notice announces a 
 finding of need to label thermal insu- 
 lation for homes and sets out the 
 bases for such finding. This notice also 
 announces that the Department of 
 Commerce is developing a proposed 
 Performance Information Labeling 
 Specification (Specification) for ther- 
 mal insulation for homes which will be 
 published in the Federal Register for 
 public comment. These actions are 
 being taken in response to requests 
 that such insulation be labeled. 
 
 EFFECTIVE DATE: December 14, 
 1977. 
 
 FOR FURTHER INFORMATION 
 CONTACT: 
 
 Dr. Howard I. Forman, Deputy As- 
 sistant Secretary for Product Stan- 
 dards, room 3876. U.S. Department 
 of Commerce, Washington, D.C. 
 20230, 202-377-3221. 
 
 SUPPLEMENTARY INFORMATION: 
 On May 25, 1977, the Department of 
 Commerce announced in the Federal 
 Register (42 FR 26647-26651) proce- 
 dures under which a Voluntary Con- 
 sumer Product Information Labeling 
 Program (CPILP) administered by the 
 Department would function. The goals 
 of the program are to make available 
 to consumers, at the point-of-sale, in- 
 formation on consumer product per- 
 formance and to educate consumers in 
 the use of such information. The pro- 
 gram also provides manufacturers and 
 other participants in the program with 
 an opportunity to convey to the public 
 the particular advantages of their 
 products. The program was initiated 
 on a limited pilot project basis, with 
 results to be evaluated at the end of 1 
 year and a determination made wheth- 
 er to continue CPILP and whether to 
 increase or reduce its scope. 
 
 Under § 16.4(a) of the procedures, 
 any person may request the Secretary 
 
 of Commerce to find that there is a 
 need to label a particular consumer 
 
 product with information concerning 
 performance characteristics of that 
 product. By letter dated June 16, 1977, 
 the Federal Energy Administration, 
 Region I, requested that home insula- 
 tion materials, along with certain 
 other energy conservation related 
 products, be labeled. In a letter dated 
 July 18, 1977, National Consumers 
 League requested that home insula- 
 tion, among other products, be la- 
 beled. Subsequent letters asking that 
 home insulation be labeled were re- 
 ceived from Mr. E. MacDonald, Mr. W. 
 F. Robinson, and Mrs. L. J. Gray. 
 Copies of these requests are available 
 for public inspection and copying in 
 the Department's Central Reference 
 and Records Inspection Facility, room 
 5317, Main Commerce Building, 14th 
 Street between E Street and Constitu- 
 tion Avenue NW., Washington, D.C. 
 20230. 
 
 In evaluating the mentioned re- 
 quests, it was felt necessary to obtain 
 supplementary information concern- 
 ing the nature of the consumer infor- 
 mation problems relating to thermal 
 insulation for homes, the suitability of 
 this product for labeling under CPILP, 
 the appropriateness of developing a 
 Performance Information Labeling 
 Specification for this product. Accord- 
 ingly, pursuant to section 16.4(c) of 
 the procedures, such supplementary 
 information has been obtained and 
 evaluated and has, together with the 
 mentioned requests, resulted in the 
 finding of need to label thermal insu- 
 lation for homes as shown below. 
 
 Finding of Need 
 
 The requests of Federal Energy Ad- 
 ministration, Region I; the National 
 Consumers League; Mr. E. MacDonald; 
 Mr. W. F. Robinson; and Mrs. L. J. 
 Gray that thermal insulation for 
 homes be labeled under the Voluntary 
 Consumer Product Information Label- 
 ing Program (CPILP) have been exam- 
 ined and the probable usefulness to 
 the public of such action has been 
 carefully considered. Based on the re- 
 sults of that examination and on the 
 supplementary information obtained, 
 it is hereby found that a need exists to 
 label thermal insulation for homes 
 under CPILP. The basis for this find- 
 ing, which are keyed to the informa- 
 
 tion items listed in section 16.4(b) of 
 the procedures, are as follows: 
 
 1. Identification of the Product to be 
 Labeled. Thermal insulation for use in 
 the walls, ceilings, and floors of pri- 
 vate dwellings is available to consum- 
 ers in the form of loose-fill, flexible 
 batts and blankets, and boards. The 
 materials available include mineral 
 and organic materials in cellular and 
 in fiber form. To the extent practica- 
 ble, the Specification will cover all of 
 those forms of thermal insulation 
 which are normally purchased by con- 
 sumers for their own use in retrofit- 
 ting existing housing or in insulating 
 housing under construction. 
 
 For the types of thermal insulation 
 under consideration, the performance 
 characteristics of primary interest to 
 consumers include the thermal insu- 
 lating properties of the material, the 
 amount or quantity of material in a 
 package, the area that can be insulat- 
 ed with the material in a package, and 
 the fire properties of the material. 
 The Specification will cover these per- 
 formance characteristics and may 
 cover other characteristics which, 
 upon further investigation, prove to be 
 of value to consumers and amenable to 
 listing on labels. 
 
 2. Extent of Product Use. During the 
 years 1974-76, an estimated 8 million 
 homes were retrofitted with thermal 
 insulation. About 70 percent of this 
 work was done by homeowners. In the 
 first half of 1977, an estimated 2.8 mil- 
 lion homes were retrofitted, with 
 about 60 percent of the work being 
 done by homeowners. On the average 
 each retrofit requires about 170 
 pounds of thermal insulating material. 
 It is possible that more than 500 mil- 
 lion pounds of insulation will be pur- 
 chased by consumers for their own use 
 in 1977. 
 
 Residential use of thermal insula- 
 tion is expected to increase significant- 
 ly in the future due to increasing fuel 
 costs and interest in energy conserva- 
 tion. Federal and State governments 
 are promoting increased use of ther- 
 mal insulation through proposals such 
 as aid to low-income families, tax 
 rebate plans, building code require- 
 ments, loan guarantee programs, and 
 other energy conservation legislation. 
 It can reasonably be expected that a 
 significant portion of the resulting 
 
 F-l 
 
work will be performed by home- 
 owners. 
 
 3. Difficulties Experienced by Con- 
 sumers. Consumers purchasing ther- 
 mal insulation for installation in their 
 homes are faced with the problem of 
 obtaining some desired amount of 
 thermal resistance, or insulating abili- 
 ty, over some given area of floor, wall, 
 or ceiling. The method of stating ther- 
 mal resistance in terms of an "R 
 value" is fairly well standardized in 
 the insulation industry, though many 
 consumers are not yet familiar with 
 the significance of the term "R value." 
 However, there are at present many 
 ways of stating the effective coverage 
 that can be obtained from a given 
 package of insulation. This is particu- 
 larly true of loose-fill insulation, 
 where the coverage or quantity state- 
 ments on packages may be in terms of 
 volume as packed, volume when in- 
 stalled, area covered when installed 
 with a given thickness of insulating 
 material, area covered at a given "R 
 value", or weight. With so many vari- 
 ations to consider, it is difficult for 
 consumers to compare the cost and 
 the insulating ability of various types 
 of insulation. A standard, easy-to-un- 
 derstand method of presenting infor- 
 mation on insulating ability and cover- 
 age information to consumers is 
 needed so that they may make cost ef- 
 fective comparisons of the various in- 
 sulating materials available for pur- 
 chase in the open market. 
 
 Consumers also experience difficulty 
 In obtaining comparable and realistic 
 information on the fire properties of 
 various thermal insulation materials. 
 The fire test method widely in use at 
 this time provides fire hazard ratings 
 in terms of flame spread classification 
 (FSC) numbers. Such ratings are 
 sometimes used in building codes and 
 purchase specifications, but it has 
 been determined that the ratings do 
 not accurately indicate the relative 
 fire hazard potential of all currently 
 available thermal insulation materials 
 as they are used in actual construc- 
 tion. Therefore, consumers cannot be 
 certain that they are getting insulat- 
 ing materials which have acceptable 
 fire hazard limitations even if the ma- 
 terials comply with local building 
 codes. The development of new and 
 more realistic test methods for the fire 
 properties of thermal insulation is 
 nearing completion. When available, 
 these new test methods will be utilized 
 in this program. FSC numbers may 
 also be used to assist consumers to 
 comply with building codes and speci- 
 fications. The results of both the old 
 and the new tests can be of maximum 
 value to consumers only if they are 
 presented in a standardized and easily 
 understandable form. 
 
 4. Potential for Consumer Loss. It is 
 important for consumers tp know how 
 much insulation coverage can be ob- 
 tained from the various packages of 
 insulating material available to them. 
 When too much insulation is installed, 
 initial costs will be higher than neces- 
 sary and available supplies, which are 
 
 in an increasing level of demand due 
 to energy shortages, will be depleted 
 unnecessarily. When too little is in- 
 stalled, energy losses and heating and 
 air-conditioning costs will be higher 
 than necessary and will continue in- 
 definitely at the higher level. In either 
 case, there is no practicable way for 
 consumers to estimate the true extent 
 of their financial burden. 
 
 Similarly, consumers might install 
 thermal insulation which could in- 
 crease the potential fire risk, particu- 
 larly if installed incorrectly. Without 
 proper education and information as 
 to such matters, it would be difficult 
 for many consumers to understand 
 how fires may occur due to the addi- 
 tion of Insulation, to recognize the in- 
 teraction between the thermal insula- 
 tion and some other component of the 
 house, or to realize that major damage 
 to a home and possible injury or loss 
 of life could result from such a fire. 
 
 5. Extent of Consumer Complaints. 
 Though the proper selection of ther- 
 mal insulation for homes presents sig- 
 nificant problems to consumers, there 
 is at present no one channel for con- 
 sumer complaints in this area. There- 
 fore, the full extent of the volume and 
 nature of complaints is not known. 
 However, consumer complaints have 
 triggered responses in several Govern- 
 ment and private sector organizations, 
 and these responses provide an indica- 
 tion of the magnitude of the problems 
 being encountered. Some of the re- 
 sponses are: 
 
 (a) The Consumer Subcommittee of the 
 Senate Committee on Commerce, Science 
 and Transportation held hearings on energy 
 conservation on September 16 and 17, 1977, 
 at which 6 of the 11 witnesses stated that 
 consumers need more complete information 
 on home insulation. At this hearing, the in- 
 adequacy of some present insulation label- 
 ing was demonstrated. 
 
 (b) At the 62d National Conference on 
 Weights and Measures, in July 1977, dele- 
 gates adopted as a guideline a proposal con- 
 cerning the labeling of thermal insulation. 
 This guideline, which is available to State 
 and local governments desiring to add re- 
 quirements concerning insulation to their 
 regulations or codes, was developed in re- 
 sponse to a consumer complaint originally 
 registered with the Bureau of Consumer 
 Protection and Environmental Health of 
 the State of Wisconsin. 
 
 (c) The Consumer Product Safety Com- 
 mission neld a public hearing on August 22, 
 1977, on the safety of thermal insulation 
 materials. This hearing was held in response 
 to a petition from the Metropolitan Denver 
 District Attorney's Consumer Office. 
 
 (d) The Federal Trade Commission has 
 published in the November 18, 1977 Federal 
 Register (42 FR 59678) a proposed Trade 
 Regulation Rule for thermal insulation ma- 
 terials that would require disclosure— on a 
 label or in advertising— of the R value, the 
 area that packaged insulation will cover to 
 attain the stated R value, and the thickness 
 to which the R value and area correspond 
 for loose-fill insulation. 
 
 (e) The National Association of Home 
 Builders has recently initiated, and the Na- 
 tional Cellulose Insulation Manufacturers 
 Association is planning to initiate, product 
 certification programs for specific forms of 
 thermal insulation. 
 
 (f) The Council of Better Business Bu- 
 reaus, after a comprehensive study, issued 
 "Standards for Home Insulation Materials- 
 advertising and selling," dated August 1977. 
 
 The magnitude and variety of the 
 above efforts point to the need for 
 more information on the properties of 
 thermal insulation for homes present- 
 ed in a uniform, consumer-oriented 
 way. 
 
 6. Current Test Methods. Existing 
 test methods and recommended prac- 
 tices for measuring thermal insulation 
 characteristics relevant to the labeling 
 program include: 
 
 ASTM C 177— Test for Thermal Conductiv- 
 ity of Materials by Means of the Guarded 
 Hot Plate. 
 
 ASTM C 518— Test for Thermal Conductiv- 
 ity of Materials by Means of the Hot Flow 
 Meter. 
 
 ASTM C 236— Test for Thermal Conduc- 
 tance and Transmittance of Bullt-Up Sec- 
 tions by Means of the Guarded Hot Box. 
 
 ASTM C 653— Recommended Practice for 
 Determination of Thermal Resistance of 
 Low-Density Mineral-Fiber Blanket-Type 
 Building Insulation. 
 
 ASTM C 687— Recommended Practice for 
 Determination of Thermal Resistance of 
 Low-Density Fibrous Loose Fill-Type 
 Building Insulation. 
 
 ASTM C 167— Tests for Thickness and Den- 
 sity of Blanket- or Batt-Type Thermal In- 
 sulating Materials. 
 
 ASTM C 272— Test for Water Absorption of 
 Care Materials for Structural Sandwich 
 Constructions. 
 
 ASTM C 519— Test for Density of Fibrous 
 Loose Fill Building Insulations. 
 
 ASTM C 520— Test for Density of Granular 
 Loose-Fill Insulations. 
 
 ASTM D 1622— Test for Apparent Density 
 of Rigid Cellular Plastics. 
 
 ASTM E 84— Test for Surface Burning 
 Characteristics of Building Materials. 
 
 ASTM E 136— Tests for Noncombustibility 
 of Elementary Materials. 
 Some product specifications may in- 
 clude additional test methods that 
 
 may be used in this program. These in- 
 clude the following: 
 
 ASTM C 516— Specification for Vermiculite 
 Loose Fill Insulation. 
 
 ASTM C 549— Specification for Perlite 
 Loose Fill Insulation. 
 
 ASTM C 553— Specification for Mineral 
 Fiber Blanket and Felt Insulation (Indus- 
 trial Type). 
 
 ASTM C 591— Specification for Rigid Pre- 
 formed Cellular Urethane Thermal Insu- 
 lation. 
 
 ASTM C 665— Specification for Mineral 
 Fiber Blanket Thermal Insulation for 
 Wood Frame and Light Construction 
 Buildings. 
 
 ASTM C 728— Specification for Perlite 
 Thermal Insulation Board. 
 
 ASTM C 739— Specification for Cellulosic 
 Fiber (Wood-Base) Loose-Fill Thermal In- 
 sulation. 
 
 ASTM C 764— Specification for Mineral 
 Fiber Loose Fill Insulation. 
 Other documents pertinent to the 
 
 program include: 
 
 ASTM C 168— Definitions of Terms Relat- 
 ing to Thermal Insulating Materials. 
 
 ASTM C 390— Sampling Preformed Ther- 
 mal Insulation. 
 
 ASTM E 122— Recommended Practice for 
 Choice of Sample Size to Estimate the 
 Average Quality of a Lot or Process. 
 
 7. Suitability of Current Test Meth- 
 ods. The test methods and recom- 
 mended practices listed above are in 
 
 F-2 
 
general use in measuring those phys- 
 ical properties of thermal insulation 
 materials necessary for the determina- 
 tion of insulation effectiveness or com- 
 pliance with various specifications and 
 building code requirements. To the 
 extent that the listed test methods 
 and recommended practices serve such 
 purpose, they are considered valid. 
 Furthermore, the product specifica- 
 tions, test methods, and recommended 
 practices listed above are among those 
 cited in the Department of Commerce 
 notice of final finding of need to ac- 
 credit testing laboratories that test 
 thermal insulation materials. That 
 notice was published in the Federal 
 Register on October 12, 1977, under 
 the Department's National Voluntary 
 Laboratory Accreditation Program 
 (see 42 FR 55020). 
 
 The FSC numbers provided by 
 ASTM E-84 are used in some purchase 
 specifications, and -in some building 
 codes for certain types of buildings, as 
 a comparative measure of the fire per- 
 formance of various thermal insula- 
 tion materials. However, it has been 
 determined that the FSC numbers do 
 not accurately indicate the relative 
 fire hazard potential of all currently 
 available thermal insulation materials 
 as they are used in actual construc- 
 tion. New and more realistic test meth- 
 ods are being developed, and will prob- 
 ably be used for developing fire safety 
 evaluation ratings on the proposed 
 CPILP labels. However, the FSC num- 
 bers may also be included on the 
 CPILP labels in order to assist con- 
 sumers in complying with any applica- 
 ble requirements in local building 
 codes. 
 
 . 8. Estimated Cost of Labeling. The 
 cost to manufacturers, private brand 
 labelers, or importers of participation 
 in the program will consist primarily 
 of the costs of testing and of printing 
 and affixing labels. 
 
 With regard to test costs, it is ex- 
 pected that, because of the require- 
 ments of various building codes, regu- 
 lations, specifications, and industry 
 programs, most thermal insulation for 
 homes in the near future will have to 
 be tested for determination of thermal 
 insulating properties, fire properties, 
 and perhaps other characteristics. It is 
 
 anticipated that the test methods 
 which will be used to meet these var- 
 ious requirements will also be used in 
 CPILP. 
 
 Therefore, the testing will probably 
 be done regardless of whether such in- 
 sulation is labeled under CPILP. Thus, 
 it is expected that manufacturers in 
 most cases will not have to test specifi- 
 cally for CPILP, and the result of the 
 program under these circumstances 
 will be to put the test information al- 
 ready available to manufacturers (or 
 which they may be required to obtain 
 for other reasons) into a uniform 
 format usable by consumers. 
 
 With regard to labeling costs of 
 thermal insulation for homes, it is ex- 
 pected that the label developed under 
 CPILP would merely be printed on the 
 package along with or in place of 
 other printed information. A separate 
 printing operation and the affixing of 
 a separate label to the package nor- 
 mally would not be necessary, so label- 
 ing co,sts are expected to be relatively 
 insignificant. 
 
 Other Government agencies, such as 
 the Federal Trade Commission, have 
 proposed or are considering various in- 
 formation disclosure requirements for 
 insulation. CPILP labels will provide 
 information— in a uniform, consumer- 
 oriented format— about a wider range 
 of attributes than is being considered 
 by any one agency. The Department 
 of Commerce intends to make CPILP 
 labels compatible with any such re- 
 quirements promulgated by regulatory 
 agencies so that their disclosure re- 
 quirments can be satisfied by partici- 
 pation in CPILP. Therefore, CPILP 
 labels could actually decrease the com- 
 plexity of the labeling job for insula- 
 tion manufacturers, and also simplify 
 product comparison by consumers at 
 the point of sale. 
 
 Section 16.6 of the procedures, 
 which originally called for the setting 
 of fees and charges for participation in 
 the program, was amended by notice 
 in the Federal Register on November 
 4, 1977 (42 FR 57686), effective De- 
 cember 5, 1977, to permit the Secre- 
 tary to suspend, at any time and for 
 any length of time, the setting of fees 
 and charges for participation. It is ex- 
 pected that the Secretary will make a 
 
 determination that no fees or charges 
 will be established for participation in 
 the program with respect to thermal 
 insulation for homes during the pilot 
 phase of this project, in order to en- 
 courage manufacturers to participate 
 in the program. Accordingly, manufac- 
 turers will not have to bear that ex- 
 pense. 
 
 In connection with the above finding 
 of need, notice is also hereby given 
 that a Performance Information La- 
 beling Specification (Specifications) 
 for thermal insulation for homes is 
 being developed. When the proposed 
 specification has been developed, its 
 complete text will be published in the 
 Federal Register for public comment 
 pursuant to section 16.5(a) of the pro- 
 cedures. 
 
 Section 16.2(d) of the CPILP proce- 
 dures contains the statement that 
 "The program seeks to avoid the du- 
 plication of other Federal programs 
 under which performance characteris- 
 tics are labeled by exempting those 
 performance characteristics from this 
 program." The procedures are being 
 amended to permit CPILP labels to in- 
 clude information about performance 
 characteristics for which another Fed- 
 eral agency may require labeled infor- 
 mation (such as in the Federal Trade 
 Commission's proposed trade regula- 
 tion rule mentioned in section 5.d 
 above for disclosure of "R values" and 
 coverage of thermal insulation) pro- 
 vided the other Federal agency agrees 
 that the inclusion of such information 
 in CPILP labels will be acceptable to 
 that agency. 
 
 Note.— The Department of Commerce has 
 determined that this document does not 
 contain a major proposal requiring prepara- 
 tion of an Economic Impact Statement 
 under Executive Order 11821, as amended 
 by Executive Order 11949, and Office of 
 Management and Budget Circular No. A- 
 107. 
 
 Issued: December 9, 1977. 
 
 Jordan J. Baruch, 
 Assistant Secretary for, 
 Science and Technology. 
 [FR Doc. 77-35614 Filed 12-9-77; 11:35 am] 
 
 
 F-3 
 
VOLUNTARY CONSUMER PRODUCT INFORMATION LABELING PROGRAM 
 PROPOSED LABELING OF THERMAL INSULATION FOR HOMES 
 
 Determination of Need for Inflationary Impact Statement 
 
 Following is an examination of whether a project to 
 label thermal insulation for homes under the Department's 
 Voluntary Consumer Product Information Labeling Program 
 (CPILP) constitutes a major proposal requiring preparation 
 of an Economic Impact Statement under Executive Order 11821 , 
 as amended by Executive Order 11949/ and Office of 
 Management and Budget Circular No. A-107. The criteria 
 examined are as listed in Department of Commerce 
 Administrative Order 218-6 dated September 12, 1975. 
 
 1. Will the proposal be expected, during any one-year 
 period of its implementation, to result in a price change of 
 one percent or more for the- most specific affected item or 
 category for which data are regularly published in 
 connection with the V?holesale Price Index, the Consumer 
 Price Index, or the GNP Implicit Price Deflator, or a 1/10 
 of one percent change in either index or the deflator? 
 
 F-4 
 
Comment: Although the residential insulation materials 
 industry is relatively small with less than $1 
 billion in gross output, it is also one of the 
 fastest growing industries at this time. The 
 impetus for growth stems from the rapidly 
 increasing demand influenced by rising energy cost 
 in general and the experience of the severe winter 
 of 1976-77 in particular. When existing production 
 capacity cannot meet demand, a strong upward 
 pressure on price ensues. The pressure on prices 
 and supply is creating a rapid expansion of 
 capacities. According to an August 1977 industry 
 survey prepared by the Office of Business Research 
 and Analysis (DoC) , the expected capacity 
 expansions from 1977 to 198 are 27% for 
 fiberglass insulation, 31% for rock wool 
 insulation, 192% for cellulose insulation, and 
 88 0% for plastic foam insulation. The inflationary 
 pressure on prices therefore may ease considerably 
 after three to four years; however, such pressure 
 would remain quite strong for the next year or 
 two. Any short-term price increase for this 
 industry would be accounted for mostly by this 
 supply-demand imbalance which would far outweigh 
 
 F-5 
 
any small price change that may result from the 
 initiation of CPILP. 
 
 Specifically, it is expected that we will 
 observe neither a 1% increase in the price of 
 residential insulation materials nor a 0.1% 
 increase in the Wholesale Price Index, Consumer 
 Price Index, or the GNP Implicit Deflator as a 
 direct result of initiating the program to label 
 thermal insulation for homes under CPILP. The 
 shipment values for the three biggest insulation 
 products for 1977 are estimated as follows.* 
 
 Fiberglass $449,920,000 
 
 Rock Wool 137,198,000 
 
 Cell ulo s e 192, 930,00 
 
 Total $78 0,04 8,00 
 
 If a constant volume is assumed, a 1% rise in 
 the insulation materials component of the 
 Wholesale Price Index would bo equivalent to a 
 $7,800,480 increase in shipment value. The total 
 expenditure for CPILP borne by the Federal 
 Government for FY 1978 is $0.5 million, and the 
 
 *The production data were derived from the Surve y Report: U.S. 
 Residentia l In sulat ion Industry, Office of Business Research and 
 Analysis, Department of Commerce, August 19 77. Average price 
 data were supplied by industry sources. 
 
 F-6 
 
expenditures by industry for testing and labeling 
 associated with CPILP are not expected to be as 
 high as $7.8 million. The relatively minor costs 
 expected to be incurred by industry under this 
 program reflects the fact that the industry is 
 already conducting a considerable amount of 
 testing either by themselves or indirectly through 
 independent testing laboratories. Among the 
 reasons for performing these tests* are: 
 compliance with the thermal resistance 
 certification of the National Association of Home 
 Builders; compliance with the flammability and 
 toxicity requirements of Underwriters 
 Laboratories; compliance with Federal Government 
 procurement specifications; and consumer demand 
 for thermal resistance information (the R values) , 
 fire ratings, and other information. 
 
 An additional consideration is that this 
 industry accounts for only 0.103% of the Wholesale 
 Price Index (WPI) . In order to affect WPI by 0.1% 
 or more, the prices of residential insulation 
 materials would have to double in a year. 
 
 F-7 
 
It may be concluded, therefore, that changes 
 in the price of . residential insulation materials 
 will not satisfy the Commerce Department criterion 
 stated above. 
 
 2. Will the proposal be expected to: 
 
 a. result in increased combined budget outlays by 
 consumers, businesses, and Federal, state, and local 
 governments exceeding $100 million in any one-year 
 period, or $150 million in any two-year period as a 
 consequence of compliance costs associated with the 
 program, or 
 
 b. result in increased budget outlays by either 
 consumer, businesses, Or Federal, state, and local 
 governments exceeding $50 million in any one-year 
 period, or $75 million in any two-year period as a 
 consequence of compliance costs associated with the 
 program? 
 
 Comment: a. It was shown in the comment for criteria 1 
 
 that the Federal Government's outlay will be $0.5 
 million for fiscal year 1978. Even if wc were to 
 
 F-8 
 
assume a 1% increase in product price due to CPILP 
 which reflected increased cost to producers, this 
 amount would be only $7.8 million. Assuming that 
 this increase will ultimately be borne by the 
 consumers, the combined outlay of $8.3 million by 
 the Federal Government and consumers falls far 
 short of $100 million stipulated in the Department 
 of Commerce criterion. 
 
 Since it is reasonable to assume that the 1% 
 increase in product price due to CPILP is a one- 
 shot event, the combined outlay by the Federal 
 Government and consumers for the second year falls 
 to $0.5 million. The overall expenditure for the 
 first two-year period will be $8.8 million, $8.3 
 million for the first year and $0.5 million for 
 the second. 
 
 b. The administration of CPILP does not involve 
 State and local governments directly. Also, we 
 can assume that the industry can successfully pass 
 on any added cost to consumers because of the 
 demand outpacing supply for the present and the 
 near future. Hence, the biggest increase in 
 
 F-9 
 
budget outlay would be $7.8 million borne by the 
 consumers in any one-year period. The same amount 
 would hold for any two-year period since the CPILP 
 induced price increase can be assumed to be a one- 
 shot event. The amount of $7.8 million falls far 
 short of $50 million for any one-year or $75 
 million for two-year periods. 
 
 3. Will the proposal be expected to reduce labor 
 productivity by one percent or more in the item which is the 
 unit of focus in the proposal (i.e., workers per ship , 
 safety per constructio n site , etc.)? If the proposed 
 action, due to such factors as constraints on output or 
 investment, barriers to substitution of materials supplies, 
 or limitation on use of technologies or skills, would 
 restrict increases in labor productivity which otherwise 
 would have occurred, such restriction shall be considered as 
 a reduction. 
 
 Comment: It is expected that labor productivity for the 
 
 residential insulation materials industry will be 
 affected only marginally because of CPILP and 
 certainly by less than one percent. As stated 
 above, many firms are already testing their 
 
 F-10 
 
products by themselves or indirectly through 
 independent laboratories, so that the additional 
 testing stipulations would affect the existing 
 production process but little. The cost of 
 preparing and printing CPILP labels would also be 
 marginal. 
 
 4. V7ill the proposal be expected to change employment by 
 one percent or more in the activity which is the unit of 
 focus in the proposal? 
 
 Comment: The comment for criterion 3 applies equally well 
 here. Employment will not be affected by as much 
 as J_ 'o . 
 
 5. For the explicitly defined relevant market affected, 
 will the proposal be expected to result in a one percent or 
 more decline in supply of mater ^ils, products, or services, 
 or a one percent or more increase in consumption of these 
 materials, products, or services after all incipient 
 compliance adjustments have occurred? These materials, 
 products, or services include, but are not limited to, 
 energy and energy products, components of the National 
 Stockpile, materials or services identified as critical by 
 
 F-ll 
 
either the National Security Council, Economic Policy Board, 
 or Council on International Economic Policy, and other 
 materials, services, or products as the Secretary may 
 designate. In the case of energy, if the impact on supply 
 or consumption exceeds 1/100 of one percent of total U.S. 
 consumption, an impact analysis v/ill be required. 
 
 Comment: The proposed product labeling program by itself is 
 not expected to affect, the aggregate supply or 
 demand appreciably to result in a 1% change. As 
 stated in the comment under criterion 1 above, the 
 factors that are now affecting the supply and 
 demand of this industry are quite strong. Besides 
 the strong desire and perhaps the necessity of 
 reducing expenditure for energy by homeowners, the 
 thermal resistance value of "R" as well as other 
 performance information is already being provided 
 voluntarily by many manufacturers. Also, the 
 voluntary nature of CPILP would mean that 
 producers who may feel they could be affected 
 adversely by CPILP would not join the program. 
 The more likely effect of CPILP is a shift in 
 demand among the existing products. Consumers may 
 prefer the standardized and more informative 
 
 F-12 
 
format of DoC labels to hitherto heterogeneous 
 formats for providing performance information. 
 
 6. For the same explicitly defined relevant market, will 
 the proposal be expected to result in a clearly identifiable 
 decline in competition, including such factors as limitation 
 of market entry, restraint of market information, or other 
 impediments to the functioning of the market system, after 
 all incipient compliance adjustments have occurred? 
 
 Comment: The effect of initiating the program should be to 
 increase competition among the sellers of 
 residential insulation materials. This will 
 result from the increase. in consumer awareness as 
 the important characteristics of such materials 
 are presented in a uniform format at the point of 
 sale. Product comparison for consumers should be 
 easier and more meaningful among different types 
 of insulating materials, such as between 
 fiberglass and cellulose or between rock wool and 
 plastic forms. In effect, the program will help 
 to transform technological substitutability among 
 different types of insulating materials to 
 economic substitutability in the market. 
 
 F-13 
 
Increased competition through the provision of 
 more uniform, clear means of providing product 
 information should also help to dampen any price 
 increase that might otherv/ise occur. 
 
 Conclusion and Recommendation 
 
 It is concluded that the project to label thermal 
 insulation for homes under CTILP does not constitute a major 
 proposal requiring preparation of an Economic Impact 
 Statement. 
 
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Appendix H 
 
 STUDY OF INFORMATIVE LABELING POR TTIE VOLUNTARY 
 CONSUMER PRODUCT INFORMATION LABELING PROGRAM: 
 
 Insulation, Smoke Detectors, Vacuum Cleaners 
 
 National Bureau of Standards 
 Contract No. 7-35832 
 
 Report prepared by 
 
 H. Keith Hunt, Brigham Young University 
 
 John Miller, University of Colorado 
 
 Jerry C. Olson, Pennsylvania State University 
 
 MARKETING SCIENCE INSTITUTE 
 
 14 Story Street 
 Cambridge, Massachusetts 0213S 
 
 January 20, 1978 
 H-l 
 
TABL12 OF CONTENTS 
 
 I. Introduction 1 
 
 II. General Procedure 6 
 
 III. Thermal Insulation Label 14 
 
 IV. Smoke Detector Label 17 
 
 V. Vacuum Cleaner Label 19 
 
 VI. Concluding Comments ..22 
 
 Appendix: Labels Developed by NBS 27 
 
 H-2 
 
I . INTRODUCTION 
 On Juno 24, 1977, the Voluntary Consumer Product Information Labeling 
 Program (CPILP) became effective as a one-year pilot program (Federal 
 Register, 42,101, May 25, 1977, pp. 26647-26651). Section 16.5, Development 
 of performance information labeling specifications, paragraph b(3), states 
 that a prototype label and directions for displaying the label will be developed 
 for inclusion in the Specifications. The milestones for this program in- 
 dicated that a completed label design would be submitted in no more than 
 ten (10) weeks after a product was selected. It was determined that in 
 order to meet these severe time constraints a jury of labeling experts might 
 be a viable tool in the label design process. This report describes the 
 procedures used by and the work product of the jury of experts. 
 
 The objective of the jury of experts was to develop prototype labels and 
 directions for displaying label information for three product categories: 
 insulation, smoke detectors, and vacuum cleaners. 
 
 In the following paragraphs, the qualifications of the selected jurors are 
 discussed and the method of gathering the jury comments and the schedule which 
 was followed arc described. 
 
 The Jury 
 
 A jury of experts was selected. Each possesses nationally and internationally 
 recognized expertise and experience in at least one and usually in several of the 
 following specified areas of importance to information provision: consumer in- 
 
 H-3 
 
formation processing, label design research, consumer satisfaction, informative 
 labeling, advertising or marketing. Jury members were selected to represent 
 areas of knowledge most likely to produce immediately usable information on 
 how to develop effective infonnative labels for consumer products. The 
 members of the expert jury were: 
 
 - Alden Clayton, Managing Director, Marketing Science Institute 
 
 - H. Keith Hunt, Principal Investigator, Associate Professor, Brigham 
 
 Young University 
 
 - John Miller, Associate Investigator, Associate Professor, University 
 
 of Colorado, Colorado Springs 
 
 - James Bcttman, Associate Professor, University of California, 
 
 Los Angeles 
 
 - James Casey, Marketing Research, Sears, Roebuck, and Company 
 
 - Jerry Olson, Associate Professor, Pennsylvania State University 
 
 - Michael Ray, Professor, Stanford University 
 
 - Jay Russo, Associate Professor, University of Chicago 
 
 - Hans Thorelli, Professor, Indiana University 
 
 - Scott Ward, Associate Professor, Harvard University 
 
 - William Wilkic, Professor, University of Florida 
 
 Professor Hunt is an acknowledged leader in the area of consumer satis- 
 faction. He lias published widely in the area and has produced a workshop 
 and proceedings on consumer satisfaction which is the standard work in the 
 field. He has also published extensively in informative labeling, especially 
 in the area of corrective advertising, where he is an acknowledged expert. 
 
 Professor Miller has done extensive research in grade labeling and 
 consumer information. He has also written about the problems with current 
 
 H-4 
 
labeling and consumer information, especially those instances of government- 
 required disclosures which may mislead consumers, frustrating their ability 
 to make reasoned purchasing decisions. 
 
 Professor Bettman is a leading researcher in the areas of consumer 
 information processing, choice decision making, and cognitive processes. His 
 recent work lias, focused on consumers' conceptions and use of product information. 
 His many publications have given direction to the development of the field of 
 consumer information processing. 
 
 Mr. Casey is a senior research executive with the marketing research 
 group of Sears, Roebuck and Company and has extensive experience in consumer 
 research on consumer perception of product information and on salience of 
 product attributes in consumer decision making. Sears has direct research 
 experience with each of the three product categories of importance to this 
 study . 
 
 Jerry Olson is widely known as a consumer psychologist and has pub- 
 lished broadly in the areas of how consumers acquire and use product information. 
 His recent work focuses on consumers' cognitive processes including how con- 
 sumers encode, store, and retrieve product information. 
 
 Michael Ray is a nationally recognized social psychologist. His research 
 interests focus on consumer information processing and advertising effectiveness 
 and consumer information systems. lie has published widely and has frequently been 
 an expert witness on consumer behavior matters. 
 
 Jay Russo is an experimental psychologist with particular expertise in 
 human information processing issues. His research work has been concerned with 
 such information processing topics as memo 17 storing, retrieval processes and 
 eye movement. 
 
 H-5 
 
Hans Thorclli is internationally known for his work in consumer in- 
 formation and labeling and is the leading expert on labeling research outside 
 the United States, especially in England and the Scandinavian and European 
 countries which arc the acknowledged leaders in consumer product labeling. 
 His book, CONSUMER INFORMATION HANDBOOK: EUROPE AND NORHI AMERICA, is the major 
 international source on consumer product labeling. 
 
 Scott Ward is an acknowledged expert in consumer communication, especially 
 that directed toward children, and on developmental aspects of consumer informa- 
 tion processing. He has published widely and is in frequent demand as an 
 expert witness. 
 
 William Wilkic was a major contributor to the questionnaire phase of 
 the project but became ill and was unable to participate in the jury meeting. 
 He is a leading expert in consumer information processing and has completed 
 a special study and monograph for National Science Foundation on that topic. 
 
 Alden Clayton, managing director of Marketing Science Institute, was an 
 active participant in the jury meeting and made substantial contributions based 
 on his wide experience in consumer goods marketing and marketing research. 
 
 Jury members were selected primarily for their professional expertise in 
 consumer information processing, labeling research, and marketing. In 
 addition various members of the group had substantial personal experience 
 with the three product categories. 
 
 The Three Product Categories 
 
 On November 8th, 1977, Marketing Science Institute (MSI) was informed 
 by the National Bureau of Standards (NBS) that the three product categories for 
 which prototype labels would be developed were insulation, smoke detectors, and 
 vacuum cleaners, though wo final decision has been made to actually label any of 
 these products as part of the Labelling Program. NBS provided material from its 
 files regarding these products. 
 
Procedure 
 
 The jury met in Cambridge , Massachusetts, January 5th through 7th. The 
 jury meeting was scheduled for early January in order to avoid academic con- 
 flicts. Prior to that meeting, each of the jury members was contacted by 
 telephone for their comments regarding relevant issues for discussion. Their 
 individual comments were summarized and distributed prior to the Cambridge meeting. 
 Therefore jury members arrived at the meeting having given prior thought to the 
 major issues involved in developing prototype labels. At Cambridge those general 
 issues were discussed prior to moving into the discussion of the three proto- 
 type labels. 
 
 Organization of the Report 
 
 The second section of this report explains the general procedures used at 
 the jury meeting. The next three sections present and discuss the labels for 
 the three products. The final section presents summary comments and recommendations. 
 
 
 
 
 H-7 
 
II. GENERAL PROCEDURE 
 
 To perforin the specified tasks within the limitations of the timetable, 
 the expert jury decided on using a two-step procedure. First, the jury identi- 
 fied a number of major issues relating to consumer information processing as 
 specifically related to informative labeling. Second, the group proceeded with 
 the label development process. 
 
 Major Issues Related to Label Design 
 
 Before designing the specific labels, members of the expert jury identified 
 several major issues related to the design of effective informative labels for 
 consumer products. These broad issues were grouped into five categories: 
 (1) identification of relevant or essential product attributes, (2) label format 
 or mode of information presentation, (3) the typical decision context, (4) label 
 adaptability in response to changing circumstances, and (5) consumer segment issues. 
 1. Issues Related to Identification of Product Attributes or Characteristics , 
 a. Attribute List Generation -- Aggregation vs. Disaggregation? A list 
 of product attributes or characteristics could be developed or generated 
 in at least two ways. One method would begin by identifying major di- 
 mensions or categories of concern to the consumer and proceed to disaggregate 
 to successively more detailed subclcments or characteristics. The other 
 method would simply list the detailed attributes or characteristics and 
 eventually aggregate that list into appropriate broad categories, developing 
 as many levels as necessary to meaningfully organize the information listed. 
 In fact, it may be necessary to use both methods -- or a hybrid of the two -- 
 such as when a product characteristic or attribute which was originally listed 
 as a single-dimensioned attribute turns out upon inspection to be comprised 
 of more than one dimension. 
 
 H-8 
 
b. Minimum Thresholds for Characteristics. Are there certain character- 
 istics where a minimum level must or ought to be specified before that 
 characteristic would be listed or that term or specification used? For 
 example, should there be some determination that a cleaning apparatus 
 must be capable of generating a certain degree of suction before it could 
 be classified or labeled as a vacuum cleaner? Mist or ought a sensing 
 device be capable of detecting a certain concentration of combustion 
 particles within a certain amount of time before it can be labeled a 
 smoke detector? Even in a program of voluntary labeling such decision 
 rules may be necessary to preclude the transmission of misinformation 
 
 or the encouragement of false or incorrect inferences by consumers. 
 
 c. Attribute Importance or Salience. The jury agreed that an informative 
 label should include only attributes important or salient to consumers. 
 
 It is unresolved whether informative labels should reflect the relative 
 importance of attributes. While.it may not be necessary to explicitly 
 weight the various characteristics for importance,. such importance might 
 be reflected in the ordering of label elements as well as through the 
 graphics, type size, and format of the label. 
 
 d. Tradeoff Between Simplicity and Completeness. It is clear that con- 
 sumers have varying needs or preferences for different amounts and types 
 of information about products. Beyond that, however, as one attempts to 
 provide more complete (and therefore more detailed) information on an 
 informative label, the useability and readability of the label begins to 
 decrease. These two objectives, completeness and simplicity, are opposed 
 to each other and label designers must make tradeoffs between the two. 
 
 Hr9 
 
e. Buying Guides. Since more informative labels have space constraints, 
 some information useful to some consumers must be omitted. Also, some 
 information can be shown in simple summary form on the label but re- 
 quires explanation for consumers having special concerns. And some 
 warnings and hazards occur only for a few models and under limited 
 circumstances which need to be explained but not on the general label 
 used for all models. For some products it is highly desireable that a 
 Buying Guide booklet be available at the point of sale which provides 
 detailed information on the general product category and specific informa- 
 tion on sucli hazards and warnings. 
 
 f. Families of Characteristics. The developer of the label must con- 
 sider which characteristics or variables should be included on the label 
 and how these characteristics should be grouped to reflect consumer 
 expectations and to facilitate information processing. The issue is 
 analogous to a mental "factor analysis" procedure, determining the basic 
 underlying dimensions which are important and meaningful to the consumer 
 in making choice decisions. 
 
 2 . I ssues Relate d to the labe l Format and Modes of Information Presentation , 
 Once the attributes are selected the format of information presentation 
 must be decided. 
 
 a. Attribute Information and Explanatory Material. When a characteristic 
 or performance measure" is presented on an informative label it may be 
 necessary or desirable to explain that measure so it is meaningful to the 
 consumer. For example, is it meaningful to express a vacuum cleaner's 
 carpet wear performance on a scale from zero to ten (from worst to best 
 possible) or should the label include the parenthetical explanation "Carpet 
 Wear (grams of carpet removed)"? Or is "grams of carpet removed" meaningful 
 
 to the consumer? 
 
 H-10 
 
b. Meaning fulness of Terms and Measures. When an attribute is listed 
 
 or a measurement given on an informative label, the term, scale, or index 
 format used should be expressed in a form meaningful to consumers. 
 
 c. Facilitating Comparisons Between Purchase Alternatives. Performance 
 measures, characteristics, scales, and indices should be designed to 
 facilitate comparisons with other purchase alternatives. The scales 
 should be formatted so the consumer can compare this product with others 
 available merely by looking at one label without having to search out 
 all relevant labels. Thus, a single informative label can provide the 
 consumer with important and essential information prior to the purchase 
 decision. 
 
 d. Interproduct Standardization of Label Format. The overall design and 
 format of the labels used in the voluntary labeling program should be 
 sufficiently standardized so consumers can transfer label use experience 
 across product categories. The education and expectation thus generated 
 should help consumers use and interpret product information more effectively. 
 
 e. Hierarchical Formatting and Summary Indices. In order to facilitate 
 "chunking" or grouping information into broader indices and also to provide 
 summary measures for those who desire less detailed information, it may be 
 dcsireablc to use a hierarchical format to present information. In 
 
 such a mode of presentation, performance ratings of subelements that 
 comprise a broader attribute may be presented along with the broader 
 index. If Buying Guides are also developed, more detailed information 
 about measurement procedures may be described where such detailed informa- 
 tion could not possibly be included on the label itself. 
 3 . Issues Related to the Consumer Dec i sion Contex t . 
 a. Comparability. Again it should be noted that format, measures, terms, 
 
 H-ll 
 
scales, and symbols used on informative labels should be designed to facilitate 
 
 comparisons between brands and products. 
 
 b. Reliability and Validity of Test' Procedures. Although it may not 
 
 be feasible to describe the reliability or validity of given test procedures 
 
 on an informative label, it may be desirable to include such information 
 
 in the accompanying Buying Guide. The intent of such information 'would 
 
 be to show that the label information is accurate. 
 
 4 . Issues Related to the Dynamic Label Use Situation -- The Living Label . 
 Provision should be made for making adjustments to the informative label as 
 changes occur in test procedures or in the marketplace. In this sense, the label 
 itself should be a dynamic information source. Where possible, attributes should 
 be measured or scaled on ceilingless scales to allow for competitive develop- 
 ments and improvements in products. As technology and competition interact, 
 differentiating dimensions of product performance or characteristics will evolve. 
 The labeling system should provide for addition of these new attributes to the 
 label. 
 
 5. Issues Relating to Consumer Segment Differences . There is ample 
 empirical evidence that consumers differ in their preference for and use of 
 types and amounts of information. A voluntary labeling scheme should recognize 
 that there exists in the marketplace information avoiders as well as non-users 
 of information, in addition to the information seekers. 
 
 These arc the major issues involved in designing informative labels. 
 
 Description of Procedure Followed by lixpert Jury in Develop ing the Labels 
 
 Having denoted the major issues surrounding the development of informative 
 product labels, the expert jury began the process of label development. This 
 
 H-12 
 
process involved several successive' phases. First, potential attributes and 
 characteristics to be included on the label were "brainstonncd." Next, 
 the attribute list was categorized and collapsed into several major groupings 
 and specific elements were added or removed. The third phase involved the 
 development of the form and content of the prototype label. Finally, the 
 "draft" label was revised into a "final" form. In the case of the home insula- 
 tion and the smoke detector labels (not with vacuum cleaners) there were two 
 additional phases. After the "final" label draft was completed by the jury, the 
 COTR distributed copies of a prototype label designed by NBS. Following 
 evaluative and comparative discussions by the jury and the COTR a "final revision" 
 was made of the jury's proposed label. 
 
 Developing the Attribute List . For each of the three products the first 
 stage in label development- was a "brainstorming" type of listing of product 
 characteristics and product performance descriptors. Although consumer data 
 from focused group or survey research was not available, the jury reflected a 
 concern for characteristics which were important or essential for consumer 
 choice, which differed among alternatives, and/or which would have health or 
 safety impact. When information about actual consumer preferences or desires 
 was available, the jury was guided by that data. In general, attributes which 
 did not differ significantly among alternatives were not included. If attributes 
 were obvious to the consumer upon product inspection and if it were likely that 
 the consumer would have the opportunity to inspect the product befor e purchase, the 
 jury was less likely to keep the attribute item on the label. It was possible 
 to add to or subtract from the list at any time during the label development process. 
 
 H-13 
 
Categorizing Attributes and Col l a psing the Lis t. Once a relatively 
 complete list of important attributes had been developed, the jury identified 
 several major categories or groupings of those attributes. The groupings 
 reflected important concerns of consumers such as: (a) What is the product 
 or what kind is it? (b) Where or how can it be properly used? (c) How well 
 does it perform compared with other alternatives on major performance characteristics? 
 (d) Are there any other important things I should know before I make my purchase 
 decision? 
 
 Developing Label Format . Once general agreement had been reached that 
 categorization and "list editing" was completed, the jury began to develop 
 the prototype label format. In developing all three labels the jury attempted 
 to use essentially a standardized order of information, terminology, scale 
 format, etc. Basically the labels present general descriptive product information 
 first. Wherever it was desirable to inform consumers of alternatives of which 
 they might otherwise not be aware, the alternatives were presented. After 
 descriptive information, the label typically noted information regarding 
 appropriate applications or uses of the product. Performance information followed. 
 Wording and format were chosen to reflect performance dimensions in terms meaning- 
 ful to consumers. Wherever possible, scales (such as those used by the VDN labeling 
 program in Sweden) involving numeric, pictorial, or verbal cues were used rather 
 than a simple number or word. This format was intended to facilitate comparisons 
 of purchase alternatives by consumers. The final section of the label usually 
 included warnings about health or safety of product use. When appropriate, a 
 reference directed the consumer to the "Buying Guide" for more detailed information. 
 
 Revision of the Dra ft Label . After completing the first draft, the jury 
 considered the total label and made revisions. 
 
 H-JL4 
 
NBS Uibcl Evaluation and Comparison . When the jury had completed its 
 "final draft" of its prototype label for both home insulation and smoke detectors, 
 the COTR distributed copies of the prototype labels developed by NBS for its 
 products (sec Appendix AJ . Jurors noted similarities. in the content and format 
 of the labels in both cases and basic differences between the NBS and jury 
 labels. At times the COTR requested jury comment on specific aspects, elements, 
 or formats of the NBS prototypes. 
 
 Final Revision . As a result of the discussion and evaluation of the 
 NBS and jury labels and in view of other specific guidelines or constraints 
 expressed by the COTR, the jury made a final revision of their label, incor- 
 porating elements from the NBS label where appropriate. In the following section 
 of this report the final revised versions of the jury's labels for the three 
 products -- home insulation, smoke detectors, and vacuum cleaners -- are presented, 
 along with specific discussion about label elements that warrant comment or emphasis, 
 
 H-15 
 
III. THERMAL INSULATION 
 The jury prototype label for residential thermal insulation is presented 
 on the next page. 'Jhe following discussion of the label focuses only on 
 those features whose presence requires justifications or whose format needs 
 explanation. 
 
 Buying Guide 
 
 Insulation is a complex product available in multiple forms, each with 
 particular uses and requiring proper installation to achieve satisfactory 
 performance. Therefore, the label contains a direct statement urging consumers 
 to acquire more information about the product from the Buying Guide which 
 should be available at the poLnt of purchase. The jury felt that the label 
 alone could not present all the information necessary for consumers to make an 
 informed choice of insulation type and brand. 
 
 Type 
 
 The jury felt that it was important not only to indicate which type of 
 insulation a given package contained but also to show explicitly what other 
 types of insulation are available. The purpose of the "box-check" format was 
 to show the variety of alternative types clearly and simply. 
 
 Dimensions 
 
 The physical dimensions of the insulation product contained in the package 
 arc only meaningful for blanket insulation and rigid board. Thus, this informa- 
 tion will be omitted from labels for loose fill and foam insulation. 
 
 Table Content 
 
 The specific content of the "thermal insulating ability" table will differ 
 by type of insulation. The major organizing basis of the table is the thick- 
 
 I?-16. 
 
/^CONSUMER PRODUCT INFORMATION 
 
 THERMAL INSULATION FOR HOMES 
 
 Befote buuiVo my)la!t«^ see "Buuiki Guide fcf ouJd ificmal irtwma.'noVi 
 
 TYPE: B / Bla.^kcf,- ( cll Q Blanket ,batf Q Uosefcll for pootir^ 
 □ UuA\\\-ix blew mo CI Ri^'d board D Foam 
 
 WERiAL: RWc^ $v* DIMENSIONS: 3"/*"x 15'// x32' 
 
 INTENDED FOR USE IN: O'AHit floor a Hollow waU E^Ope* wall 
 
 0t)pm ce't W or ra5 teff QHiase™er(t ce i I mo or 
 
 crawl space. 
 
 THERIAAL INSULATING ABILITY: 
 
 This 
 
 ■xM»«rt 
 
 R value 
 
 3.B 
 
 * 
 
 IS 
 
 M> 
 
 TKi'ckriess 
 Ouches') 
 
 1.0 
 
 3.5 
 
 6.0 
 
 q.o 
 
 Co verrtjy. in toxb 
 
 pox.Ko.c\e 
 te^uMe -feet.) 
 
 E^!wit=d Fuel Savins as % of fuel ^ 
 g ets -for a home wilh vo insu la-hbvi 
 
 Coldest Wintw Hwpe."<itw6 
 
 -3o° -lo" o° zo° -qo° 
 
 * The Rvalue per irch -for cfiffewnt brawl's of fibrous Alass mso ahwr> ra^aes from 
 £.fc -Jo ^U.. ° 
 
 ** See. tiu-uiro Guile -for explanation . 
 
 PRICE COMPARISON NUMBER FOR THIS PACKAGE = ^'^ °^ | ^' S P * 1 ^ 
 (liO«= Rvalue K Scuuxre feet of coven-age in -iKi's pac.Kac|e) 
 
 The lauer -|ta. Price CowpMvsaft kiiwvbefj -rhe lower ibe cost of msalatOna a, awen 
 avea. •}© a debited level of insulation ptolcctior. (Rvalue"). Yoa can use Price 
 Comparison Numbers ■(© lonNpare ihe costs df a. ce/rlam level of fnsularUM pnrfec- 
 •hon ft>r different bra-rds or W different -kjpas of msuda.'Kon . 
 
 FIRE SAFETY RATINGS*. 
 
 " Resistance to -f Iotinc spread 
 
 iiA^i 
 
 10 mnl. . 
 _j rcslttum. 
 
 Resistance to two Wcrri 
 
 ?3 
 
 fcast j_ 
 
 © 
 
 10 meat 
 — | usisfarit 
 
 kwj-. TKtTftkvi^ (ex H(\!s predict m tyvtn bij ifit cmoio. Ik; ™>\ae <k 
 SiAwp obkwd far o!W bitvnds rf fibrous qla.*S insulalcaii 
 is ftivw bu -<f\CL d<vtK ootid bar ufoAtt eachsc/vle. Ihe to^oio 
 of iiv4ivft*. ffw all. 4<^p« cif ivvjulaUow is givov\ bo Idt 
 clc'lkd bevr ondti ccvtU scale . 
 
 CAUTIONS AND WARNINGS (s« Buyirtj Guide &r additional \nfcrrwaticm) 
 
 A. Seme ^fv^> of msulabon hawe a. -1',/ndencij -|o corrode iome -mcFals , attract 
 venwftj or pcn-vrjjt -funrws axo\olb. 
 
 B. BokcU"yc clollwro f ccowv\ondet) for iYvstalla.Wv. ThtaknA >rv\asl< and piopor clolniiY) 
 
 C. Keep ncuwwvndcd. srnte fcxWcen iTtwlaltovi aird object* ^Kat ntui oxd- hot. 
 
 D. Ptopfttr iT>*ilallaltfs\ is vie.tttJicVtvi fen sxflai a-rvd eHcd wemess. 
 
 H-17 
 
ness of the insulation. For blanket and rigid board types, the table must 
 reflect the basic thicknesses in which that form of insulation is manufac- 
 tured. For loose fill and foam, the table might be organized in terms of 
 connnon lumber dimensions (e.g., 3 1/4", 6", 8", 10", 12"). 
 
 One Inch Standard 
 
 The first line of every "thermal insulating ability" table will present 
 the R-valuc and its related data for one inch of that type and brand of insula- 
 tion. By presenting the R- value for a standard of one inch, insulation brands 
 and types can be compared in terms 6f absolute thermal insulating power or 
 protection. To facilitate such comparisons the footnote for the one -inch 
 R- value presents the range of variation in R- value for insulation of that type. 
 
 Fuel Savings . The jury was concerned that certain technical ratings of 
 insulation properties (such as R- value) may have little or no direct meaning 
 to the consumer. In the absence of Other information, an R-value of "12" 
 has no meaning to the consumer. Such a raw index by itself connotes little 
 or nothing about the thermal resistance properties of the product. One cri- 
 terion critical to many consumers' decisions to purchase insulation is the 
 fuel cost likely to be saved by insulating their homes, Therefore, we suggest 
 that NBS develop an estimate of the approximate savings in fuel cost that 
 would be realized by insulating one's house. A standard might be developed 
 mathematically using a typical house, fuel costs and predicted fuel consumption, 
 and different levels of thermal insulation. The jury feels that a percentage 
 index of the savings realized at a given R-value compared to no insulation 
 would be more understandable to the consumer than the R-valuc would be by 
 itself. However, we would urge that indices of wide applicability be developed. 
 Because the procedure to develop the expected fuel cost savings is likely to 
 
 H-rl8 
 
be complex, the jury feels it cannot be explained on the label but the 
 explanation should be included in the Buying Guide. 
 
 Price Comparison Number . The jury members feel strongly that the 
 label should provide consumer information to facilitate comparisons between 
 brands and between product types. The Price Comparison Number is intended 
 to do just that by providing consumers with an index that reflects the price 
 of a given level of thermal protection provided by one package of insulation. 
 When the index is computed for alternative brands the consumer can identify 
 the most cost-effective alternative. 
 
 Fire Safety Ratings . The same objective of simplifying comparisons 
 influenced the jury's decisions regarding the format of the scales describing 
 fire resistance properties. The proposed scale not only shows a given brand's 
 performance level but also shows the range of performance (a) for other brands 
 of the same insulation type and (b) for all other types of insulation. Thus, 
 the product rating is put into a meaningful context and can be directly inter- 
 preted by a consumer. 
 
 Caution "A" . The jury feels that corrosion, vermin, and fungus factors 
 are fairly complex and are relevant only to limited segments of the insulation 
 market. Therefore, the details regarding this information should be presented 
 in the Buying Guide. Consumers witli these special problems could consult the 
 Buying Guide for further infromation. 
 
 Cautions "B" and "C" . Because these factors are major health and/or 
 safety hazards, a clear warning statement is deemed necessary. 
 
 H-19 
 
IV. SMOKE DETECTORS 
 
 The smoke detector label continues using the labeling principles 
 explained in the previous section. The label is shown on the following page. 
 Both the ionization type and the photoelectric type are listed, indicating 
 to the consumer that there are two alternatives. Members of the expert jury- 
 were informed that both heat and gas detectors arc available but are not 
 considered as "smoke detectors." Other types of detectors are under develop ? 
 ment and when available, additional categories may need to be added. 
 
 The same comparison scale explained in the previous section is used for 
 this label. It is believed to be the best form for conveying the complex information of 
 specific rating, comparison to other brands of the same type, and comparison 
 for all types of the product. 
 
 Type of Fire and Smoke 
 
 Sensitivity in terms of response time is expected to vary by type of 
 fire. The six types of fire are intended to represent the proposed International 
 Standards Organization (ISO) types of fires, described in meaningful terms to 
 the consumer would have a correct perception of the type of fire and type of 
 smoke involved. This alerts consumers that there are different types of fires 
 and allows consumers to evaluate differences in response time in relation to 
 their own needs. 
 
 Time for Mann to Sound 
 
 The end point (30 minutes) on the "time to respond" scale may be tech- 
 nically incorrect. The jurors did not know the actual response times, and 
 this end point might appropriately be shortened or lengthened, depending on the 
 range of actual response time encountered. 
 
 H-20 
 
The jury agreed that sensitivity would be the most important item of 
 information to consumers. They emphasized, therefore, the need to include 
 information about sensitivity and expressed the belief that NKS could select 
 or develop an adequate testing method. Thus, the alternative of a label 
 without a basis for comparing smoke detector sensitivity was considered by 
 the jury to be unacceptable. Finally, the jury believed that technical 
 standards should be based on actual response time rather than a surrogate 
 standard such as optical density. 
 
 Summary 
 
 Complex issues regarding the use of measures, simplicity vs. complete- 
 ness, and differing product information needs come together here. Where 
 information on brand or product performance for varying applications or uses 
 is provided and where several scales or measures are used, it is possible that 
 consumer information processing will be made more difficult. The jury was 
 unable to resolve this issue to its satisfaction because of time constraints. 
 How a summary measure or statement set is determined, whether on balance it 
 is more or less useful, etc, are questions to be addressed in future research. 
 
 Battery 
 
 The "Battery" information entry is omitted for AC- only models. 
 
 
 H-21 
 
CONSUMER PRODUCT INFORMATION 
 
 0j5j3 
 
 
 SMOKE DETECTOR 
 
 TYPE: 
 
 D PKoVoelec+YiC 
 
 lcmiza.-HoT» 
 FWJER SOURCE: Bfb^Wu Q M-dneefc Q AC-pluj-w (-Priwj bwjjgv 
 
 REO)MlErtDED PLACEMENT: DM s'Ccilim D EMcy 
 
 SENS IT 1 V1TT: 
 
 1 TXPE OF FlKfc AND SfOOKE 
 
 ] 
 
 A. St-wr^ flcxvne., liWeswolte (uxxd) 
 
 "B. O^eak ■fWie.j nvxh swoke (weed) 
 
 C. SwokWvvru wuck smoke (Jowa) , n. 
 
 E H^W&. Icouvd , swoku (o\i) 
 
 F; FlocfftwaUz, Iiou'd, heat (alcohol) 
 
 TttAE FOR AU\t>N\ ID SOUND 
 
 30 witwks 
 
 —i 
 
 —I 
 
 50i<ttMuU4 
 
 ■30 Yuwukft 
 
 30 Yftiwjko 
 
 Htiv 1h& yOlHmo ^rr -Hu« pxtdudc u> ANCm bu -ItaciNYbtd. "Tt\e. Ycwvatof- 
 •jolUwk &< oUdlv bxaMds of ioru-i cvk/v deJldcn 5> u> qivtA\ b^ iht oa^k 
 SedA loiv uwcjc* each scale. Tim tOlmoc c4 rtvliwjs &*- brtuxds o c 
 pMoeUtVot dekt-Ws w QiwAA bu <K\c cJo+kd liwe ov\dev efljoh savte. 
 
 SUMWY: 
 
 ALARfA IXXJIDNESS; 87 decibels (ftxale^ l^W wwbw »<vluuk ^ttaJcv loudvKH 
 
 TEOOBIE SIGNAL EURATW: 7 cWs 
 
 TESTING PROCEDURE: OnhodotiMfl 6W0 ^ irrfo uri& uo't-tl aluxiuS 4tM ewW UVU.t) 
 B^ Hols k& botioY\ whutV\ Hats e-oiuewit^ Ji^l -kjoto pewxw am! horn cr\lu 
 
 BmTERX (if oppUttab^e^): ExpeektMife: IZwaw^s AvoiloJbilc^; Oroide QliWW 
 
 CAUTIOMS: 
 
 Rt&hichoA5 on locator* ; This wit staold not be usedl iv> kvJchews^ aa/raaes^ 
 
 a,Vk<w, or w cold spacer. 
 
 The efktkwftess e>{ -Hog imit -rernures txopyr lYvslallalion . £ee Stone* s fAoMuaJ 
 ■for msKUakcw uwshvcHWL 
 
 — " " H-22 
 
V. VACUUM CLUANIiKS 
 
 The label for vacuum cleaners also continues using the labeling principles 
 discussed in the previous sections on thermal insulation and smoke detectors. 
 The label is shown on the following page. In the "Type" section the format 
 listing all alternatives is used again to call attention to the fact that there 
 are product type alternatives which should possibly be considered before a 
 purchase decision is made. Ihe comparison scales used in the previous sections 
 are also used on this label as the best form for conveying the complex informa- 
 tion of specific ratings and comparisons among brands and across product 
 types . 
 
 Types 
 
 Although type or model alternative lists usually include upright, 
 cannister, and cannister with power nozzle models, our listing also includes 
 both the electric broom and the hand-held models. For example, the hand-held 
 model may offer an alternative to the cannister for consumers seeking a 
 vacuum cleaner model to satisfy cleaning needs such as a small apartment, little 
 carpeting, stairs, or drapes. 
 
 Accessories 
 
 Because it is not obvious to the consumer which accessories are included 
 in the priced package, it is important to list the accessories included. A 
 standardized nomenclature and order of listing should be developed to facili- 
 tate interpretation (e.g., "crevice tool l/2"xl l/4"xl0") and to make possible 
 comparisons between brands and/or products. 
 
 H-23 
 
CONSUMER PRODUCT INFORMATION) 
 
 J 
 
 VACUUfn CLEAMER5 
 
 TYPE.J O Up*iaV*t EfCawvskf Q ConmsIw wii{\ pou>w t£>tt\a 
 D Hnd-KtU 
 
 ACCESSORIES; (liskd in &Jtw\±i/«l v*twntlaluTe) 
 
 VJEICHT: CodD LEKSTB: Hc6E LENGTH: 
 
 EFFECTIVE BAG CAPACITY: B'T-ull Bag Indit^W □ Reusable U3 
 
 PUMCTION: Q Suction cjf.1 
 
 3 
 
 ^ 
 
 Sucker^ o.yA bloiou\( 
 
 Q^i^po^blc bao 
 
 CLEANING. AtMUTY: 
 
 Canpu.'t Tupe 
 
 Embedded Tnrt Swrfcte U+k>r 
 
 Plush jiuuuuuiuuj 
 
 Oi- 
 
 _,«> 
 
 Shan 
 Level loop 
 
 ii±m± 
 
 crrfT r ' rr ^\ 
 
 »t- 
 
 4 too 
 
 -iito 
 
 o*_ 
 
 JM 
 
 -,!» 
 
 _,«* 0^ 
 
 ^KO 
 
 Boj«efloovs olAuI Kivrd 
 
 ,165 
 
 Drapes , upok-k/ru 1 dt. L » 
 
 KtY: lit. yolW) ft* -Wuo j»odud W quwrt bu -frtia. O^nxOi . All -OikicaJ 4*t 
 vm ^twa of tta j>c«UMiai>t £.% ) oV dirt re«woved. TAt sotid 
 dOjffel. b»* owdyr coo.lv scale im<1uC(S.>C& "Ita. -«»«(t, ef pOl"f*r-mA/vvtl, 
 t\Wm fVr cfffW uxt»Lo)u ™odjla. 7l\t clcntd ttW. wlui&iy 
 
 CARPET 10EAE m»o Ease CP NMfcWENr fcCG.035 CARPET 
 
 Plu&h 
 
 ftlol{i.le\*& ttWUUUU 
 
 \ 6Uear C^t>^- imia) J / E<ua- of fAwgAnt*J [ 
 
 _L 
 
 Lewei Ibop 
 
 <ancyy>-iy^ 
 
 KEY: TKc vakA'<} (« "flui ptxWt ii qwew bti fte. (ynftu). iVtfejddOwt lme 
 u/vu^ eo.ck saita- ouki lux. vaavil ^ pevfo-rvwaw^i -foy of/uw 
 
 NOISE LEVEL: II decibel* (ft-sad*) 
 
 i6 >- 
 
 -e»o 
 
 EXPECTED SERVICE- FRE£* LIFE: fclfe 'utoj© 
 
 * EskwiO.'kd 4<avwl of wftrvvxali. 
 l>sc wrfWjd- truiierr vt/wui/rs. . 
 No(- ft-UMjcfftMiluMw quafltxvvfcae. 
 
 H-24 
 
Effective Bag Capacity 
 
 Units with smaller bag capacities obviously require the inconvenience 
 of emptying and/or the costs of bag replacement more often than do units with 
 a larger capacity. In addition, for most units the empty capacity of the bag 
 (its maximum capacity of dust or lint) is not the significant measure of 
 performance. Because of design differences, cleaning efficiency varies among 
 units as the bags fill. The jury suggests that a standardized measurement 
 procedure be developed to test for effective bag capacity (e.g., the amount 
 in liters of standardized dirt accumulated by the machine in the bag up to 
 the point where the machine will perform at 801; of its empty cleaning ability). 
 
 Carpet Types and Cleaning Surfaces 
 
 Because consumers have different cleaning requirements and because 
 vacuum cleaners differ in their abilities to clean different surfaces, standard 
 measurement procedures should be developed for testing cleaning ability on 
 several representative carpet surfaces as well as on hard surfaces (bare 
 floors) and fabric surfaces (drapes and upolstery). A variety of alternatives 
 are reflected in the labels of European countries with labeling programs. The 
 terms and surface types should, of course, be readily interpretable by 
 consumers . 
 
 Embedded Dirt and Surface Litter . Because performance differences 
 between models as well as brands exist for different types of dirt and 
 because these differences arc important to consumers, the performance scales 
 are separated for these two representat Lvc types of dirt for carpeting 
 materials. Standardized dirt and litter composition should be determined 
 and a standardized measurement procedure should be developed for measuring 
 performance on these attributes. 
 
 H-25 
 
Wcajr. Carpet wear is also a significant concern of consumers. Models 
 as well as brands show noticeable variation in performance here. A standard- 
 ized measurement should be developed to reflect performance of the machine 
 (or nozzle) on this characteristic and the test should be performed on differ- 
 ent types of carpet surfaces if variation is significant. 
 
 Ease of Movement 
 
 Some standardized measure of ease of movement of the cleaning nozzle 
 (or machine) over various types of carpet surfaces should be developed. 
 
 Expected Service -Free Life 
 
 Models and brands differ in length of trouble-free life. The basic 
 repair- free expected life of the brand or model gives the consumer a summary 
 measure for comparing the reliability and durability of the product. A 
 standardized measurement procedure -- perhaps like the methods used by MIT's 
 Center for Policy Alternatives in its total product life cost studies -- 
 should be developed for reporting expected longevity of the product. The ex- 
 planatory note or disclaimer is intended to prevent misinterpretation of "free 
 service" by consumers and to interpret the concept of "service- free" life. 
 
 H- 26 
 
VI. CONCLUDING COMMENTS 
 
 Jury members individually and collectively insisted on making some 
 concluding comments about the label development process in which they 
 participated, expressing some important reservations, offering several recom- 
 mendations for label development procedures, and identifying some unresolved 
 issues inherent in this activity. 
 
 • Evaluation of This Process 
 
 The "expert jury" process used to develop these three labels is 
 "workable". However, while there is similarity between two of the jury's 
 labels (insulation and smoke detectors) and the NBS counterparts, it is 
 important to note the differences and to consider several suggestions regarding 
 this process. 
 
 A "Workable" Process 
 
 The process in which the jury participated did result in achievement of 
 the task objective. Three prototype labels were developed for the products 
 assigned within the time frame specified. In that sense, the process "worked." 
 
 Similarity Between NBS and Jury Labels 
 
 A first glance at both the NBS and the jury labels for insulation or 
 for smoke detectors shows some strong similarity between the labels produced 
 by each group. The elements included and their order on the label are 
 reasonably close. Perhaps that is not surprising. The NBS label is the result 
 of secondary data gathering coupled with primary comment and work by engineers 
 and "consumer sounding boards." 'Hie jury's work was completed in a span of 
 
 H-27 
 
two days. It reflects their use of secondary data, their knowledge of consumer 
 concerns, and their experience with the products, and discussion with technical 
 experts. 
 
 Differences Between NBS and Jury Labels 
 
 A careful comparison of the NBS and jury labels exposes some rather 
 important differences between the output of the two label development processes. 
 The differences include jury emphasis on meaningfulness of terms and measures, 
 on facilitating comparisons, and on identification of choice alternatives -- 
 in general, an orientation toward a consumer use criterion rather than one of 
 technical correctness. 
 
 A meaningfulness to the consumer is critical. The basic criterion of 
 whether one label is superior to another is whether or not the consumer is able 
 to interpret and use one label better than the other; it is not whether one 
 label uses terms or symbols technically more correct than the other. 
 
 The jury labels consistently attempt to aid consumers in comparing 
 product as well as brand alternatives. The use of the comparison -type scale 
 offers the opportunity to see at a glance where a brand performed not merely 
 in some absolute sense, but, more importantly, to see that performance level 
 in relation to the range of performance for other brands and alternative 
 product types. 
 
 Not only docs the jury label emphasize comparison facilitation, but 
 it also makes consumers aware of important choice alternatives . Alternative 
 product types or characteristics are explicitly listed with boxes to be 
 checked to identify the presence of a given attribute. Thus, the label itself 
 makes consumers aware of alternatives which previously may not have been known. 
 
 H-28 
 
In summary, the basic cliff crehces between the NBS and jury labels reflect 
 the jury's strong concern that the label be meaningful and useful to consumers. 
 The bottom- line question is, "Is important information presented in such a 
 manner that the consumer can readily apprehend, process, and correctly use it 
 in a way that relates to the consumer's experience?" 
 
 Recommendations Regarding This Procedure 
 
 As a result of their participation in this label development procedure 
 and in view of their desire for a more efficient process if this procedure is 
 used again, jury members suggest that (a) more information should be provided 
 before the jury is assembled and (b) jury membership could be broadened to 
 include one or. two technical experts familiar with the product and its 
 distribution. It is recognized that the jury must be held to a manageable 
 size in order to make feasible the interactions and the quick consensus 
 necessary for creation of a draft label within the time constraint. 
 
 Reservations About the Procedure 
 
 Jury members repeatedly voiced strong concerns that this procedure 
 should not be considered a substitute for a consumer-validated label development 
 process. Validation of informative labeling can be achieved only by empirical 
 consumer research. 
 
 Member participation in the development of these draft prototype labels 
 should not be viewed as an endorsement of the voluntary labeling program, the 
 label development process, or the draft labels thems elves . 
 
 Recommendations 
 
 The label development process should include provisions for implementing 
 evaluation research, for consumer label testing research, for product specific 
 research, and for basic consumer information processing research. 
 
 H- 29 
 
1. Evaluation Research . Informative labeling programs should state 
 specific objectives or goals to be achieved by informative labels and should 
 specify measurements to determine if those goals have been achieved. Impact 
 research should be planned as an integral part of informative labeling 
 programs . 
 
 2. Label /Element Testing Research . It is imperative that drafted 
 labels as well as specific copy or working alternatives, format alternatives, 
 scale alternatives, symbol alternatives, etc., all be tested using represen- 
 tative consumer samples using proper field and laboratory research procedures. 
 
 3. Product Specific Research . Before labels are developed for a product 
 category it is necessary to have consumer data relevant to product preferences, 
 concerns, and uses. Secondary information should be collected and, where 
 necessary, primary data should be gathered on attribute salience and importance, 
 how consumers chunk or group atomistic attributes into molar chunks for making 
 decisions or storing in memory, and about what products are considered 
 substitutes for this product. 
 
 4. " Basic" Research . Finally, an on- going labeling program should 
 support the basic research into consumer information processing of product 
 information. Such research should investigate how consumers use labels as one 
 form of product information. 
 
 Unresolved Issues 
 
 There arc some issues which are left unresolved by the jury. It became 
 clear that manufacturers of smoke detectors were not satisfied that there is 
 currently an acceptable- SMMP (Standard Methods of Measuring Performance) for 
 measuring "sensitivity". The jury also is aware that vacuum cleaner manufac- 
 turers continue to debate techniques and procedures for measuring "cleaning 
 
 H-30 
 
ability." At issue then is the question: "Is it better to develop and 
 promulgate an ' informative' label which omits a significant dimension of 
 performance evaluation for the consumer, or is it better to not promulgate 
 an incomplete lal>cl at nil?" "Is a partial label better than none at all?" 
 
 The jury is also concerned about including certain terms without 
 explanatory detail on the label. Without adequate explanation the terms 
 could be misleading and deceptive. While Buying Guides may relieve some 
 concerns about such incompleteness, it is not likely that all consumers 
 would seek out information in the Buying Guides if available. 
 
 The first and final question to be asked by the informative labeler 
 is, "Can the label be used by tlit consumer in a meaningful way to facilitate 
 or simplify an educated ciwict bttween brands and/or products?" 
 
 H-31 
 
I" 
 
 ■<T.Pa» 
 
 U.S. Department ol Commerce 
 
 CONSUMER PRODUCT INFORMATION PROGRAM 
 
 DMFOTAE3 
 
 WARNING: Follow Instructions. Proper installation is necessary for safely and effectiveness 
 
 Thermal Insulation (or Homes 
 Cellulose (Wood Fiber) 
 Loose Fill for Blowing 
 
 For use in: S Artie floor □ Basement ceiling 
 
 B Exterior Wall D Crawl space 
 
 Interior Wall 
 The contents of this package will provide: 
 
 An R vaUpt' of 
 
 At, J UiiCi<."feSS of 
 
 Whrfcifi \w«tl Cover 
 
 
 rriKChesi 
 
 (square; feet) 
 
 38 
 
 1 
 
 18G 
 
 13 
 
 35 
 
 53' 
 
 21 
 
 5 5 
 
 33 8 
 
 40 
 
 105" 
 
 177 
 
 Price comparison number for this package 
 
 NOTE: The higher the R value for a given 
 area, the more you save on fuel. 
 
 Price of package 
 
 710 
 
 The lower this number, the less it will cost to insulate a given area, 
 
 43 
 
 Surface flame spread rating 
 
 The higher this number, the more resistant the insulation is to surface flame spread. 
 
 Ratings range liom 1 to. 10. 
 
 Smoldering rating 
 
 The higher this number, the more resistant the insulating is to smoldering. Ratings 
 ranoe from to 10. 
 
 FSC number: 
 
 Some building codes and oilier regulations require that this number not exceed a certain value 
 Check with your local authorities 
 
 Corrosion: This material may corrode the following metals. Steel 
 
 Chemical additives: Bone Acid 
 
 Data on this label lor this unit 
 
 III'. ('It IlitlllP IK ll>(|ll III 
 
 certified by 
 
 m.iuul.ii dure or older 
 
 
 ()'(|.'ini/,ituni 
 
 JKL, Inc. 
 
 TT 11 
 
U.S. DEPARTMENT OF COMMERCE 
 OFFICE OF THE SECRETARY 
 
 Reprinted from Federal Register, Volume 43, Number 104 — Tuesday, May 30, 1978 
 
 (Pages 23488-23495) 
 
 DEPARTMENT OF COMMERCE 
 
 Office of the Secretary 
 
 VOLUNTARY CONSUMER PRODUCT 
 INFORMATION LABELING PROGRAM 
 
 Proposed Specification for Labeling of Thermal 
 Insulation for Homes 
 
 AGENCY: Assistant Secretary of Com- 
 merce for Science and Technology, 
 Commerce. 
 
 ACTION: Proposed performance infor- 
 mation labeling specification. 
 
 SUMMARY: Pursuant to the proce- 
 dures for a voluntary consumer prod- 
 uct information labeling program, as 
 'amended (15 CPR Part 16; 42 FR 
 26647, dated May 25, 1977; 42 PR 
 57686, dated November 4, 1977; and 43 
 FR 8254, dated March 1, 1978), this 
 notice announces the Department's 
 proposed performance information la- 
 beling specification for the labeling of 
 thermal insulation for homes under 
 the program and invites interested 
 persons to comment thereon. The pro- 
 posed specification includes a descrip- 
 tion of the product and the perform- 
 ance characteristics covered, identifi- 
 cation of product test methods to be 
 used, label designs and label display 
 requirements, and requirements for 
 participation in the program with re- 
 spect to thermal insulation for homes. 
 A separate notice is also being pub- 
 lished in this issue of the Federal Reg- 
 ister announcing the Secretary's in- 
 tention to suspend fees for participa- 
 tion in this program with respect to 
 thermal insulation for homes. 
 
 DATE: Comments must be received on 
 or before July 14, 1978. 
 
 FOR FURTHER INFORMATION 
 CONTACT: 
 
 Dr. Howard I. Forman, Deputy As- 
 sistant Secretary for Product Stand- 
 ards, Room 3876, U.S. Department 
 of Commerce, Washington, D.C. 
 20230, 202-377-3221. 
 
 SUPPLEMENTARY INFORMATION: 
 On December 14, 1977, the Depart- 
 ment announced in the Federal Regis- 
 ter (42 FR 62946-62949) a finding of 
 need to label thermal insulation for 
 homes under the voluntary consumer 
 product information labeling program 
 and further announced that a per- 
 formance information labeling specifi- 
 cation (specification) was being devel- 
 
 oped for such insulation. These ac- 
 tions were taken in response to re- 
 quests that thermal insulation for 
 homes be labeled and were in accord- 
 ance with § 16.4(d) of the Depart- 
 ment's published Procedures for a vol- 
 untary consumer product information 
 labeling program as amended (15 CFR 
 Part 3 6; 42 FR 26647 at 26649, dated 
 May 25, 1977; 42 FR 57686, dated No- 
 vember 4, 1977; and 43 FR 8254, dated 
 March 1, 1978) (procedures). The 
 effort to develop the specification has 
 resulted in the proposed specification 
 included in this notice, which is 
 hereby presented for public comment 
 in accordance with § 16.5(a) of the pro- 
 cedures. 
 
 Under § 16.2(b) of the procedures, 
 the Department of Commerce may in- 
 clude on product performance labels 
 information on product performance 
 characteristics also covered by labeling 
 programs of other Federal agencies, 
 provided the other Federal agencies 
 agree to such inclusion. The Depart- 
 ment is cognizant of other Federal 
 agency requirements and proposed re- 
 quirements for labeling of thermal in- 
 sulation for homes. Efforts have been 
 made to coordinate the proposed spec- 
 ification with those requirements of 
 other agencies so as to avoid the need 
 for separate labels to meet differing 
 agency requirements. These coordina- 
 tion efforts will continue as the final 
 specification is written. 
 
 Interested persons desiring to com- 
 ment on the proposed specification set 
 out below are invited to submit such 
 comments on or before July 14, 1978, 
 to the Assistant Secretary for Science 
 and Technology, Room 3862, U.S. De- 
 partment of Commerce, Washington, 
 D.C. 20230. 
 
 Any person desiring to express his or 
 her views relative to the proposed 
 specification m an informal hearing 
 may do so by communicating that 
 desire in writing, on or before June 14, 
 1978, to the Assistant Secretary for 
 Science and Techonolgy at the address 
 shown in the preceding paragraph. 
 Upon receipt of such request informal 
 hearings will be held so as to give all 
 interested persons an opportunity for 
 the oral presentation of data, views, or 
 arguments in addition to the opportu- 
 nity to make written submissions. 
 Notice of such hearings will be pub- 
 lished in the Federal Register. 
 
 Upon receipt of the comments sub- 
 mitted in response to this notice, in- 
 cluding the testimony of individuals at 
 any hearings that may be held in con- 
 junction therewith, a complete evalua- 
 tion of such comments and testimony 
 will be made. Upon completion of that 
 evaluation a notice will be published 
 in the Federal Register either (1) 
 giving the complete text of a final 
 specification, (2) stating that the pro- 
 posed specification will undergo fur- 
 ther development before final publica- 
 tion, or (3) withdrawing the proposed 
 specification from further considera- 
 tion. 
 
 Being published simultaneously in 
 this issue of the Federal Register 
 with this notice is a separate notice 
 announcing that pursuant to §§16.6 
 (a) and (d) of the procedures the Sec- 
 retary intends, at such time as a final 
 specification for the labeling of ther- 
 mal insulation for homes is issued, to 
 suspend all fees and charges for par- 
 ticipation in the program with respect 
 to thermal insulation for homes. 
 
 Issued: May 23, 1978. 
 
 Jordan J. Baruch, 
 Assistant Secretary for 
 Science and Technology. 
 
 The following is the proposed speci- 
 fication under consideration for the la- 
 beling of thermal insulation for 
 homes: 
 
 Proposed Performance Information Label- 
 ing Specification for Thermal Insula- 
 tion for Homes 
 
 1.0 Purpose. 
 
 2.0 Scope. 
 
 3.0 Definitions. 
 
 4.0 Initiation and termination of participa- 
 tion in program. 
 
 5.0 General conditions for participation. 
 
 6.0 Identification of material, form, and 
 recommended application. 
 
 7.0 Testing and rating for area covered. 
 
 8.0 Testing and rating for R value. 
 
 9.0 Rating for thermal coverage and pric- 
 ing factor. 
 
 10.0 Testing and rating for resistance to 
 surface flame spread. 
 
 11.0 Testing and rating for resistance to 
 smoldering. 
 
 12.0 Testing and rating for PSC number. 
 
 13.0 Testing and rating for corrosiveness. 
 
 14.0 Product labeling. 
 
 15.0 Use of program information in adver- 
 tising. 
 
 16.0 Amendment. 
 
 Figure 1. Label for Loose Fill Type Insula- 
 tion. 
 
 1-1 
 
Figure 2. Label for Blanket, Batt, or 
 Board Type Insulation. 
 
 Appendix A, Form for Notification of 
 Desire To Participate in Program. 
 
 1.0 Purpose 
 
 The purpose of this Performance Infor- 
 mation Labeling Specification is to establish 
 procedures for the testing and labeling of 
 thermal insulation for homes in accordance 
 with the Procedures for a Voluntary Con- 
 sumer Product Information Labeling Pro- 
 gram, as amended (15 CFR Part 16; 42 FR 
 26647, dated May 25, 1971; 42 FR 57686, 
 dated Nov. 4, 1977; and 43 FR 8254, dated 
 Mar. 1, 1978) and to define requirements for 
 participation in that program with respect 
 to such insulation. 
 
 2.0 Scope 
 
 2.1 This Specification shall apply to the 
 product class consisting of all insulation as 
 defined in § 3.9 of this Specification. 
 
 2.2 Insulation covered by this Specifica- 
 tion shall be labeled with respect to its ma- 
 terial, form, recommended application, R 
 value, area covered, pricing factor, resis- 
 tance to surface flame spread, resistance to 
 smoldering, FSC number, and corrosiveness. 
 
 3.0 Definitions 
 
 3.1 The term "Secretary" means the Sec- 
 retary of Commerce or her designee. 
 
 3.2 The term "participant" means a man- 
 ufacturer, assembler or private brand label- 
 er of insulation, or an importer of insulation 
 for resale, who participates in the Program 
 with respect to insulation. 
 
 3.3 The term "designated agent" means a 
 person, as defined in § 16.3(e) of the Proce- 
 dures, who has been designated by the Sec- 
 retary to carry out appropriate operational 
 procedures on behalf of more than one par- 
 ticipant in accordance with § 16.9 of the Pro- 
 cedures. 
 
 3.4 The term "Program" means the Vol- 
 untary Consumer Product Information La- 
 beling Program. 
 
 3.5 The term "Procedures" means the 
 Procedures for a Voluntary Consumer Prod- 
 uct Information Labeling Program, as 
 amended <15 CFR Part 16; 42 FR 26647, 
 dated May 25, 1977; 42 FR 57686, dated Nov. 
 4, 1977; and 43 FR 8254, dated Mar. 1, 1978). 
 
 3.6 The term "Specification" means the 
 Performance Information Labeling Specifi- 
 cation for Thermal Insulation for Homes. 
 
 3.7 The term "Label" means printed 
 matter affixed to or otherwise provided 
 with insulation and meeting the require- 
 ments of § 14.0 of this Specification. 
 
 3.8 The term "Department of Commerce 
 Mark" means the mark indicated in Figures 
 1 and 2, which is registerable in the U.S. 
 Patent and Trademark Office under 15 
 U.S.C. 1054. 
 
 3.9 The term "insulation" means thermal 
 insulation intended for use in the ceiling, 
 walls, floors, or other structural elements of 
 private dwellings and customarily available 
 to consumers for their use in the retrofit- 
 ting of existing buildings or in the Initial fit- 
 ting of new buildings. The term includes 
 loose-fill, batt, blanket, and board type insu- 
 lation consisting of either organic or miner- 
 al materials in either cellular or fiber form. 
 
 3.10 The terms "ASTM Standard Test 
 Method" and "ASTM Standard Recom- 
 mended Practice," when used as references 
 to specific documents and when used with- 
 out Identifying dates, means the current 
 version of the specific American Society for 
 Testing and Materials standard test method 
 or standard recommended practice refer- 
 enced. Copies of these documents may be 
 obtamed from the American Society for 
 
 Testing and Materials, 1916 Race Street, 
 Philadelphia, Pa. 19103. 
 
 3.11 The term "Proposed Federal Specifi- 
 cation" means the proposed version of the 
 designated Federal purchase specification 
 published by the Federal Supply Service. 
 General Services Administration, for the 
 use of all Federal agencies. The referenced 
 portions of Proposed Federal Specifications 
 may be obtained from the National Bureau 
 of Standards, Division 761, Washington, 
 D.C. 20234. 
 
 4.0 Initiation and Termination of Partici- 
 pation in Program 
 
 4.1 Any manufacturer, assembler, or pri- 
 vate brand labeler of insulation, or importer 
 of insulation for resale, desiring to partici- 
 pate in the Program with respect to insula- 
 tion will nofity the Secretary. The notifica- 
 tion shall list the brand name(s) for which 
 the prospective participant proposes to use 
 Labels and the proposed date of entry into 
 the Program for each brand name. The no- 
 tification shall also include a statement that 
 if accepted as a participant in the Program 
 the prospective participant will (1) abide by 
 all conditions imposed by the Procedures, 
 (2) abide by all conditions imposed by this 
 Specification, and (3) desist from using the 
 Department of Commerce Label and Mark 
 if its participation in the Program is termi- 
 nated. The notification shall be addressed 
 to the Assist Secretary for Science and 
 Technology, Room 3862, U.S. Department 
 of Commerce, Washington, D.C. 20230. The 
 notification may be in the form shown in 
 Appendix A. 
 
 4.2 The Secretary shall act expeditiously 
 on all requests to participate in the Pro- 
 grams and shall notify each prospective par- 
 ticipant of her decision in writing. In those 
 instances where the Secretary declines a re- 
 quest, she shall state the reasons for so de- 
 clining. 
 
 4.3 If a prospective participant seeking to 
 participate in the Program is notified by the 
 Secretary that she proposes to deny that 
 prospective participant the right to partici- 
 pate, that prospective participant shall have 
 30 days from the receipt of such notification 
 to request a hearing under the provisions of 
 5 U.S.C. 556. The Secretary's proposed 
 denial shall become final through the issu- 
 ance of a written decision to such prospec- 
 tive participant in the event that he does 
 not appeal such notification by the end of 
 the 30-day period. If, however, such pro- 
 spective participant requests a hearing 
 within that 30-day period, the Secretary's 
 proposed denial shall be stayed pending the 
 outcome of the hearing held pursuant to 5 
 U.S.C. 556. 
 
 4.4 A participant may at any time termi- 
 nate his participation and responsibilities 
 under this Program with respect to a given 
 brand of insulation by giving written notice 
 to the Secretary that he has discontinued 
 use of the Department of Commerce Label 
 and Mark for all insulation of that brand. 
 
 4.5 The Secretary, upon finding that a 
 participant is not complying with the condi- 
 tions set out in the Procedures or In this 
 Specification, may terminate upon 30 days' 
 notice the participant's right to continue his 
 participation in the Program with respect to 
 insulation: Provided, That the participant 
 shall first be given an opportunity to show 
 cause why the participation should not be 
 terminated. 
 
 4.6 Upon receipt from the Secretary of a 
 notice of proposed termination of participa- 
 tion, which notice shall set forth the rea- 
 sons for such proposed termination, the par- 
 ticipant shall have 30 days from the date of 
 receipt of such notification to request a 
 
 hearing under the provisions of 5 U.S.C. 
 556. The Secretary's proposed termination 
 shall become final through the issuance of a 
 written decision to the participant in the 
 event such participant does not appeal the 
 proposed termination within the 30-day 
 period. If, however, the participant requests 
 a hearing within the 30-day period, the Sec- 
 retary's proposed termination shall be 
 stayed pending the outcome of the hearing 
 held pursuant to 5 U.S.C. 556. 
 
 5.0 General Conditions for Participation 
 
 5.1 Prior to the use of a Label partici- 
 pants shall make or have made the tests and 
 ratings and the identifications required 
 under §§6,0 through 13.0 of this Specifica- 
 tion and shall retain adequate records of 
 the tests and computations involved. Such 
 records shall be kept on file by the partici- 
 pant or his agent for three years and shall. 
 If requested by the Secretary within that 
 three-year period, be forwarded to the Sec- 
 retary within 30 days of such request. 
 
 5.2 Participants should make or have 
 made tests on sufficient samples of insula- 
 tion to provide a valid basis for determining 
 ratings and should maintain such quality 
 control programs, to include testing, as are 
 necessary to insure that no insulation 
 having a Label is mislabeled. 
 
 5.3 Participants shall enter product rat- 
 ings and other Information on their Labels, 
 and shall display their Labels in accordance 
 with the requirements of § 14.0 of this Spec- 
 ification. 
 
 5.4 Each participant shall be identified 
 on Labels used by that participant as the or- 
 ganization certifying the accuracy of ratings 
 on the Labels. 
 
 5.5 In addition to the testing referred to 
 in §§ 5.1 and 5.2 of this Specification, partici- 
 pants shall, if requested by the Secretary in 
 accordance with § 16.7(d)4 of the Proce- 
 dures, make or have made at their expense 
 further tests or provide samples of insula- 
 tion for further testing to determine wheth- 
 er testing has been done according to this 
 Specification. The results of the requested 
 tests, or the requested samples, shall be pro- 
 vided to the Secretary as soon as practica- 
 ble, preferably within 30 days of receipt of 
 such requests. This requirement does not 
 preclude the Department of Commerce 
 from testing or having tested any insulation 
 at its own expense. 
 
 5.6 The requirement in §§5.1 and 5.5 of 
 this Specification and the recommendation 
 in § 5.2 of this Specification that partici- 
 pants "make or have made" tests of insula- 
 tion may be fulfilled through the use of in- 
 house testir. - testing by Hher laboratories, 
 testing associated with certification pro- 
 grams, or a combination of these three 
 types of testing. However, for the purposes 
 of this Program, accountability shall remain 
 with the participant for information en- 
 tered on Labels by that participant. 
 
 5.7 Participants may reproduce or may 
 authorize non-participants such as retail 
 sales organizations to reproduce Labels, in- 
 cluding the Department of Commerce Mark, 
 in the advertising of insulation labeled 
 under the Program: Provided, That the re- 
 quirements in § 15.0 of this Specification are 
 satisfied. 
 
 5.8 Participants may utilize the services 
 of designated agents who have been desig- 
 nated by the Secretary under § 16.9 of the 
 Procedures to carry out specified operation- 
 al procedures on behalf of participants in 
 the Program with respect to insulation. 
 
 6.0 Identification of Material, Form, and 
 Recommended Application 
 6.1 Insulation shall be identified with re- 
 spect to its basic material through the use 
 
 1-2 
 
of the most appropriate of the following de- 
 scriptive terms on Labels: mineral wool, cel- 
 lular glass, perlite, vermicullte, cellulose, 
 polystyrene, polyurethane, polyisocynurate. 
 If none of the above terms is appropriate, a 
 descriptive term provided and published by 
 the Secretary under §6.4 of this Specifica- 
 tion shall be used. 
 
 6.2 Insulation shall be identified with re- 
 spect to its basic form through the use of 
 the most appropriate of the following terms 
 on Labels: board type, board type with 
 vapor varrier, blanket type, blanket type 
 with vapor barrier, batt-type, batt type with 
 vapor barrier, loose fill type for pouring, 
 loose fill type for blowing, loose fill type for 
 pouring or blowing. If none of the above 
 terms is appropriate, a descriptive term pro- 
 vided and published by the Secretary under 
 § 6.4 of this Specification shall be used. 
 
 6.3 Insulation shall be identified with re- 
 spect to its recommended application by 
 checking one or more of the following de- 
 scriptive terms on Labels: attic floors, base- 
 ment ceilings, floors over crawl spaces, en- 
 closed walls, open walls. If none of the 
 above terms is appropriate, one or more de- 
 scriptive terms provided and published by 
 the Secretary under § 6.4 of this Specif ica- • 
 tion shall be used. 
 
 6.4 Participants or potential participants 
 desiring to describe on Labels an insulation 
 with respect to its material, form, or recom- 
 mended application, for which insulation 
 the descriptive terms listed in §6.1, 6.2, or 
 6.3 of this Specification are not appropriate, 
 should notify the Secretary of the need for 
 additional descriptive terms. Any such noti- 
 fication shall describe the material, form, 
 and recommended application of the subject 
 insulation and shall include proposed addi- 
 tional descriptive terms. Such notifications 
 shall be addressed to the Assistant Secre- 
 tary for Science and Technology, Room 
 3862, U.S. Department of Commerce, Wash- 
 ington, D.C. 20230. The Secretary shall pro- 
 vide additional descriptive terms if needed, 
 or shall inform the submittor of the notifi- 
 cation as to which of the previously listed 
 descriptive terms should be used for the 
 subject insulation, within 30 days of receipt 
 of the notice. When additional descriptive 
 terms are provided to the submitter, the 
 Secretary shall also, as soon as practicable, 
 publish in the Federal Register a notice of 
 such provision. 
 
 6.5 Insulation shall be considered misla- 
 beled if the material or form of the insula- 
 tion is different from the approved descrip- 
 tive terms for material and form listed on 
 the Label, or if the insulation is deemed by 
 the Secretary to be inappropriate for one or 
 more of the approved recommended applica- 
 tions checked on the Label. 
 
 7.0 Testing and Rating for Area Covered 
 
 7.1 For loose fill type insulation, area 
 covered shall be computed using the rela- 
 tionship A = M/(D • t/12), where A is the 
 area covered, in square feet; M is the weight 
 of insulation in a package, in pounds; D is 
 the settled density in pounds per cubic foot 
 determined in accordance with section 4.5.1 
 of Proposed Federal Specification HH-I- 
 515D, Insulation, Thermal (Loose Fill for 
 Pneumatic or Poured Applications): Cellulo- 
 sic or Wood Fiber, as proposed November 4, 
 1977, or section 4.5.1 of Proposed Federal 
 Sepcification HH-I-1030B, Insulation, Ther- 
 mal (Mineral Fiber, for Pneumatic or 
 Poured Application), as proposed November 
 4, 1977, as appropriate; and t is the settled 
 thickness of the installed insulation, in 
 inches. (See section 3.11 of this Specifica- 
 tion.) Area covered shall be computed for 
 settled thicknesses of 1.0, 3.5, and 5.5 inches, 
 and for the settled thicknesses in inches cor- 
 
 responding to R values of R = 30 and R = 
 40 as determined under section 8.1 of this 
 Specification. Area covered values of less 
 than 50-square feet shall be expressed in 
 tenths of a unit and area covered values of 
 50-square feet or more shall be expressed in 
 whole numbers on Labels. 
 
 7.2 For blanket and batt type insulation, 
 area covered shall be computed using the re- 
 lationship A = W • L, where A is the area 
 covered jn square feet and W and L are the 
 width and total length in feet of the pack- 
 age piece or pieces, measured on a flat hori- 
 zontal surface in as-installed condition. 
 Measurements of W and L may be made 
 with any measuring device of suitable accu- 
 racy but care must be taken not to distort 
 the insulation in the measurement process. 
 During the measurement process, normal 
 installed thickness in inches shall also be 
 determined in accordance with section 4.1.1 
 of ASTM C 167, Standard Test Methods for 
 Thickness and Density of Blanket or Batt 
 Type Thermal Insulating Materials. Area 
 covered values of less than 50-square feet 
 shall be expressed in tenths of a unit and 
 area covered values of 50-square feet or 
 more shall be expressed in whole numbers 
 on Labels. 
 
 7.3 For board type insulation, the area 
 covered shall be computed using the rela- 
 tionship A = W • L, where A is the area cov- 
 ered in square feet and W and L are the 
 width and total length of the packaged 
 piece or pieces, in feet. Measurements may 
 be made with any measuring device of suit- 
 able accuracy. During the measurement 
 process, normal installed thickness in inches 
 shall also be determined. Area covered 
 values of less than 50-square feet shall be 
 expressed in tenths of a unit and area cov- 
 ered values of 50-square feet or more shall 
 be expressed in whole numbers on Labels. 
 
 7.4 When tests to determine if insulation 
 is mislabeled are conducted in accordance 
 with section 7.1, 7.2, or 7.3 of this Specifica- 
 tion and any value for area covered so deter- 
 mined is found to be less than the value 
 shown on the Label for the same thickness 
 of insulation by 0.2-square foot or 3 percent 
 of the labeled value, whichever is greater, 
 the insulation shall be considered misla- 
 beled. 
 
 8.0 Testing and Rating for R Value 
 
 8.1 For loose fill type insulation, R value 
 (thermal resistance) shall be determined in 
 accordance with ASTM C 687, Standard 
 Recommended Practice for Determination 
 of the Thermal Resistance of Low-Density 
 Fibrous Loose Fill Type Bulding Insulation. 
 R values shall be determined at a mean tem- 
 perature of 75°F for the settled density as 
 determined under section 7.1 of this Specifi- 
 cation. R values shall be computed for set- 
 tled thicknesses of 1.0, 3.5, and 5.5 inches, 
 and the settled thicknesses in inches corre- 
 sponding to R values of R= 30 and R= 40 
 shall also be computed. R values shall be 
 given in °F • h • ftVBtu where "F means tem- 
 perature difference in degrees Fahrenheit, 
 h means hours, ft 2 means square feet, and 
 Btu means British thermal units. R values 
 of less than 10 shall be expressed in tenths 
 of a unit and R values of 10 or more shall be 
 expressed in whole numbers on Labels. 
 
 8.2 For blanket and batt type insulation. 
 R value shall be determined in accordance 
 with ASTM C 653, Standard Recommended 
 Practice for Determination of the Thermal 
 Resistance of Low-Density Mineral-Fiber 
 Blanket-Type Building Insulation. R value 
 shall be determined at a mean temperature 
 of 75°F for the normal installed thickness as 
 determined under section 7.2 of this Specifi- 
 cation. R value shall be given in "F-h-fty 
 
 But, where °F means temperature differ- 
 ence in degrees Fahrenheit, h means hours, 
 ft 2 means square feet, and Btu means Brit- 
 ish thermal units. R values of less than 10 
 shall be expressed in tenths of a unit, and R 
 values of 10 or more shall be expressed in 
 whole numbers on Labels. 
 
 8.3 For board type insulation, R value 
 shall be determined in accordance with 
 either ASTM C 177, Standard Test Method 
 for Thermal Conductivity of Materials by 
 Means of the Guarded Hot Plate; ASTM C 
 236, Standard Test Method for Thermal 
 Conductance and Transmittance of Built- 
 Up Sections by Means of the Guarded Hot 
 Box; or ASTM C 518, Standard Test Method 
 for Steady State Thermal Transmission 
 Properties by Means of the Heat Flow 
 Meter. Measurements shall be made at a 
 mean temperature of 75°F on aged test 
 specimens representative of the density and 
 thickness of the labeled insulation. R value 
 shall be computed for the installed thick- 
 ness as determined under section 7.3 of this 
 Specification and shall be given in "F-h-fty 
 But, where °F means temperature differ- 
 ence in degrees Fahrenheit, h means hours, 
 ft 2 means square feet, and Btu means Brit- 
 ish thermal units. R values of less than 10 
 shall be expressed in tenths of a unit and R 
 values of 10 or more shall be expressed in 
 whole numbers on Labels. 
 
 8.4 Since in sections 8.1 and 8.2 of this 
 Specification the referenced recommended 
 practices provide alternative test methods 
 for determining R value, and since in sec- 
 tion 8.3 of this Specification alternative test 
 methods are also provided, then in all cases 
 where an R value rating comes into dispute 
 the following order of precedence shall be 
 held to prevail: R values determined in ac- 
 cordance with ASTM C 177, Standard Test 
 Method for Thermal Conductivity of Mate- 
 rials by Means of the Guarded Hot Plate, 
 shall prevail over R values determined in ac- 
 cordance with other methods, and R values 
 determined in accordance with ASTM C 
 236, Standard Test Method for Thermal 
 Conductance and Transmittance of Built- 
 Up Sections by Means of the Guarded Hot 
 Box, shall prevail over R values determined 
 in accordance with ASTM C 518, Standard 
 Test Method for Steady State Thermal 
 Transmission Properties by Means of the 
 Heat Flow Meter. 
 
 8.5 When tests to determine if insulation 
 is mislabeled are conducted in accordance 
 with section 8.1, 8.2, or 8.3 of this Specifica- 
 tion and any R value so determined is found 
 to be less than 95 percent of the R value 
 shown on the Label for the same thickness 
 of insulation, the insulation shall be consid- 
 ered mislabeled. 
 
 9.0 Rating for Thermal Coverage and Pric- 
 ing Factor 
 
 9.1 For loose fill, blanket, batt and board 
 type insulation, a thermal coverage rating 
 shall be computed using the relationship 
 TCR=RA where TCR is the thermal cover- 
 age rating, R is the R value determined 
 under §8.1, 8.2, or 8.3 of this Specification 
 and A is the area covered value, correspond- 
 ing to this R value, determined under §7.1, 
 7.2, or 7.3 of this Specification. For loose fill 
 type insulation TCR shall be computed 
 using the R value and area covered value 
 corresponding to a settled thickness of one 
 inch. For batt, blanket and board type insu- 
 lation, TCR shall be computed for the R 
 value and area covered corresponding to the 
 installed thickness. 
 
 9.2 For display on the Label, a pricing 
 factor shall be calculated using the relation- 
 ship PF=1000/TCR, where PF is the pric- 
 
 1-3 
 
ing factor and TCR is the thermal coverage 
 rating determined in accordance with §9.1 
 of this Specification. Pricing factor shall be 
 expressed in hundredths of a unit on Labels. 
 9.3 When ratings to determine if insula- 
 tion is mislabeled are made in accordance 
 with §§9.1 and 9.2 of this Specification and 
 the pricing factor so determined is found to 
 be not in agreement with the pricing factor 
 shown on the Label, the insulation shall be 
 considered mislabeled. 
 
 10.0 Testing and Rating for Resistance to 
 Surface Flame Spread 
 
 10.1 For loose fill, blanket, batt, and 
 board type insulation, resistance to surface 
 flame spread shall be determined in accord- 
 ance with the surface flame spread test re- 
 ferenced in the following three specifica- 
 tions: 11 4.5.7 of Proposed Federal Specifica- 
 tion HH-I-515D, Insulation, Thermal (Loose 
 Fill for Pneumatic or Poured Applications): 
 Cellulosic or Wood Fiber, as proposed No- 
 vember 4, 1977; §4.5.8 of Proposed Federal 
 Specification HH-I-1030B, Insulation, Ther- 
 mal (Mineral Fiber, for Pneumatic or 
 Poured Applications), as proposed Novem- 
 ber 4, 1977; and § 4.7.6 of Proposed Federal 
 Specification HH-I-521F, Insulation Blan- 
 kets, Thermal (Mineral Fiber, for Ambient 
 Temperatures), as proposed November 9, 
 1977. (See §3.11 of this Specification.) How- 
 ever, the following requirements shall apply 
 to the testing of insulation having a vapor 
 barrier or other membrane: Insulation 
 having a vapor barrier or other membrane 
 shall be tested both with the membrane ex- 
 posed to the radiant panel and with the 
 membrane either removed from the insula- 
 tion or intact but not exposed, and the 
 lower of the resulting values of resistance to 
 surface flame spread shall be shown on 
 Labels: Except That insulation which is 
 clearly and conspicuously marked on the 
 membrane that an exposed membrane may 
 present a fire hazard and should not be in- 
 stalled so as to expose said membrane may 
 be tested only with the membrane intact 
 but not exposed to the radiant panel and 
 the resulting value of resistance to surface 
 flame spread shown on Labels. Resistance to 
 surface flame spread shall be determined at 
 the density used in the determination of R 
 value under §8.1, 8.2, or 8.3 of this Specifi- 
 cation. Resistance to surface flame spread 
 shall be given as the critical radiant flux in 
 watts per square centimeter, shall be ex- 
 pressed in hundredths of a unit, and indicat- 
 ed at the appropriate position on the resis- 
 tance to surface flame spread scale on 
 Labels. 
 
 10.2 When tests to determine if insula- 
 tion is mislabeled are conducted in accord- 
 ance with §10.1 of this Specification and 
 the resistance to surface flame spread so de- 
 termined is found to be less than 95 percent 
 of the resistance to surface flame spread 
 shown on the Label, the insulation shall be 
 considered mislabeled. 
 
 11.0 Testing and Rating for Resistance to 
 Smoldering 
 
 11.1 For loose fill, blanket, batt, and 
 board type insulation, resistance to smolder- 
 ing shall be determined in accordance with 
 the smoldering test referenced in the follow- 
 ing three specifications: § 4.5.8 of Proposed 
 Federal Specification HH-I-515D, Insula- 
 tion, Thermal (Loose Fill for Pneumatic or 
 Poured Application): Cellulosic or Wood 
 Fiber, as proposed November 4, 1977; § 4.5.9 
 of Proposed Federal Specification HH-I- 
 1030B, Insulation, Thermal (Mineral Fiber, 
 for Pneumatic or Poured Applications), as 
 proposed November 4, 1977; and §4.7.7 of 
 Proposed Federal Specification HH-I-521F. 
 
 Insulation Blankets, Thermal (Mineral 
 Fiber, for Ambient Temperatures) as pro- 
 posed November 9, 1977. (See §3.11 of this 
 Specification.) For boa.rd type insulation, 
 the hole for insertion of the ignition source 
 may be formed by drilling with an 8-mm 
 drill. Resistance to smoldering shall be de- 
 termined at the density used in the determi- 
 nation of R value under §8.1, 8.2, or 8.3 of 
 this Specification. Resistance to smoldering 
 shall be computed as (100 -weight loss in 
 percent)/10 and shall be expressed in halves 
 of a unit and indicated at the appropriate 
 position on the resistance to smoldering 
 scale on Labels. 
 
 11.2 When tests to determine if insula- 
 tion is mislabeled are conducted in accord- 
 ance with § 11.1 of this Specification and 
 the resistance to smoldering so determined 
 is found to be less than the resistance to 
 smoldering shown on the Label by more 
 than one-half unit, the insulation shall be 
 considered mislabeled. 
 
 12.0 Testing and Rating for FSC Number 
 
 12.1 For loose fill, blanket, batt. and 
 board type insulation, FSC number (Flame 
 Spread Classification) shall be determined 
 In accordance with ASTM E 84, Standard 
 Test Method for Surface Burning Charac- 
 teristic of Building Materials. However, the 
 following requirements shall apply to the 
 testing of insulation having a vapor barrier 
 or other membrane: Insulation having a 
 vapor barrier or other membrane shall be 
 tested both with the membrane exposed and 
 with the membrane either removed from 
 the insulation or intact but not exposed, 
 and the higher of the resulting FSC num- 
 bers shall be shown on Labels: Except, That 
 Insulation that is clearly and conspicuously 
 marked on the membrane that an exposed 
 membrane may present a fire hazard and 
 should not be installed so as to expose said 
 membrane may be tested only with the 
 membrane intact but not exposed and the 
 resulting FSC number show on Labels. FSC 
 number shall be determined at the density 
 used in the determination of R value under 
 §8.1, 8.2, or 8.3 of this Specification. FSC 
 numbers (Flame Spread Classification) shall 
 be expressed in whole numbers evenly di- 
 visible by five on Labels. 
 
 12.2 When tests to determine if insula- 
 tion is mislabeled are conducted in accord- 
 ance with §12.1 of this Specification and 
 the FSC number so determined is found to 
 be more than five numbers greater than the 
 FSC number shown on the Label, the insu- 
 lation shall be considered mislabeled. 
 
 13.0 Testing and Rating for Corrosiveness 
 
 13.1 For loose fill, blanket, batt, and 
 board type insulation, corrosiveness shall be 
 determined in accordance with both § 4.5.5 
 of Proposed Federal Specification HH-I- 
 515D, Insulation, thermal (Loose Fill for 
 Pneumatic or Poured Application): Cellulo- 
 sic or Wood Fiber; as proposed November 4, 
 1977, and § 4.5.6 of Proposed Federal Speci- 
 fication HH-I-1030B, Insulation, Thermal 
 (Mineral Fiber, for Pneumatic or Poured 
 Application), as proposed November 4, 1977, 
 with the further provision that all metal 
 specimens shall be degreased before testing 
 by washing with 1.1.1 trichloroethane or 
 trichlorethylene until completely free of 
 water breaks. (See §3.11 of this Specifica- 
 tion.) Degreased specimens shall be handled 
 only with clean forceps. In making tests in 
 accordance with HH-I-1030B, contact be- 
 tween the metal specimen and the stainless 
 steel woven wire cloth shall be avoided. Cor- 
 rosive effects to be noted shall be those 
 listed in §3.1.9 of Proposed Federal Specifi- 
 cation HH-I-515D and §3.2.6 of proposed 
 
 Federal Specification HH-I-1030B. When 
 the specified corrosive effects are noted 
 with respect to the aluminum, copper, steel, 
 or galvanized steel corrosion test specimens, 
 the affected metals shall be checked on 
 Labels. If the specified corrosive effects are 
 not noted, the phrase "none of these" shall 
 be checked on Labels. 
 
 13.2 When tests to determine if insula- 
 tion is mislabeled are conducted in accord- 
 ance with § 13.1 of this specification and the 
 affected metals so determined are found to 
 be not checked on the Label, the insulation 
 shall be considered mislabeled. 
 
 14.0 Product Labeling 
 
 14.1 The size and design of Labels shall 
 be as shown in figure 1 for loose fill type in- 
 sulation and Figure 2 for batt, blanket, and 
 board type insulation, except that propor- 
 tional reproductions of Labels from a mini- 
 mum size of one half the Indicated dimen- 
 sions to a maximum size of 1.5 times the in- 
 dicated dimensions may be used. The size of 
 the Label shall be such as to clearly and 
 conspicuously display the labeled informa- 
 tion. Ail information and ratings called for 
 in Figure 1 or 2 shall be shown on Labels, 
 and no information or marks other than 
 those indicated in Figures 1 and 2 shall be 
 shown within the borders of Labels. 
 
 14.2 The Secretary shall provide each 
 participant with camera-ready art suitable 
 for use in printing Labels, except that such 
 art will not contain numerical product rat- 
 ings or other individualized Information 
 that is to be developed and provided by par- 
 ticipants. Labels shall be based on accurate 
 reproductions of the camera-ready art pro- 
 vided. However, participants may apply for 
 permission to make minor variations in 
 Label appearance, such as variations made 
 necessary by the use of special printing 
 techniques. Permission for such variations 
 may be requested by application to the As- 
 sistant Secretary for Science and Technol- 
 ogy, Room 3862, U.S. Department of Com- 
 merce, Washington, D.C. 20230. Applica- 
 tions shall be accompanied by an example 
 of the proposed variation. 
 
 14.3 Labels may be printed separately, 
 printed on a container or wrapping that 
 contains insulation and is conveniently visi- 
 ble to consumers before sale, or may be 
 printed directly on the insulation if the in- 
 sulation is clearly visible to consumers 
 before sale. The Label lettering and the 
 Label background shall be of contrasting 
 colors. Separately printed Labels may be 
 fastened with adhesive, attached as hang- 
 tags, or affixed by any other secure means 
 that does not detract from their visibility. 
 
 14.4 Labels shall be printed on or affixed 
 to a conspicuous portion of each insulation 
 package or other sales unit of insulation of- 
 fered for sale to consumers. When Labels 
 are printed or affixed along with other in- 
 formation, the Labels shall appear clearly 
 distinct from the other information so that 
 the Department of Commerce Mark on the 
 Label cannot reasonably be considered to be 
 associated with the other information. 
 
 14.5 Except for those packages or other 
 sales units of insulation exported from the 
 United States, every package or other sales 
 unit of a labeled brand name of insulation 
 that is listed in accordance with §4.1 of this 
 Specification shall carry a Label. However, 
 participants utilizing more than one brand 
 name may label some or all of those brand 
 names of insulation in accordance with this 
 Specification. 
 
 15.0 Use of Program Information in Adver- 
 tising 
 
 15.1 Participants may reproduce Labels, 
 Including the Department of Commerce 
 
 1-4 
 
Mark, in the advertising of insulation la- 
 beled under the Program: Provided, That 
 entire Labels, complete with all information 
 required to be displayed at the point of 
 retail sale, are shown legibly and are not 
 combined or associated directly with any 
 other mark or logo. However, the use of 
 such reproductions, which may be of any 
 legible size, shall not be a substitute for la- 
 beling of insulation in accordance with this 
 Specification. 
 
 15.2 Participants may authorize non-par- 
 ticipants, such as retail sales organizations, 
 to reproduce Labels, including the Depart- 
 ment of Commerce Mark, in the advertising 
 of insulation labeled under the Program: 
 Provided, That the requirements in § 15.1 of 
 this Specification are satisfied. 
 
 16.0 Amendment 
 
 This Specification is subject to amend- 
 ment or revision as provided in § 16.11 of the 
 Procedures, except that new descriptive 
 terms may be provided by the Secretary and 
 published in the Federal Register as pro- 
 vided in §6.4 of this Specification without 
 first publishing notice of the proposed 
 change in the Federal Register. Amend- 
 ments and revisions shall not apply to insu- 
 lation manufactured prior to the effective 
 date of the amendment or revisions. 
 
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 1-7 
 
Performance Information Labeling 
 
 Specification for Thermal Insulation for 
 
 Homes 
 
 appendix a.— form for notification of 
 desire to participate in program 
 
 Assistant Secretary for Science and Tech- 
 nology, 
 Room 3862, 
 
 U.S. Department of Commerce, 
 Washington, D.C. 20230. 
 
 (Insert name of prospective participant) 
 desires to participate in the Department of 
 Commerce Voluntary Consumer Product In- 
 formation Labeling Program (Program) 
 with respect to thermal insulation for 
 homes. If accepted as a participant in the 
 Program. (Insert name of prospective par- 
 ticipant) intends to label thermal insulation 
 offered for sale under the brand name(s) 
 (Insert name or names of brands to be la- 
 beled), effective (Insert date on which label- 
 ing will start). 
 
 If accepted as a participant in the Pro- 
 gram, (Insert name of prospective partici- 
 pant) agrees to: 
 
 (1) Abide by all conditions imposed by the 
 Procedures for a Voluntary Consumer 
 Product Information Labeling Program, 
 15 CPR Part 16; 
 
 (2) Abide by all conditions imposed by the 
 Performance Information Labeling 
 Specification for Thermal Insulation for 
 Homes; 
 
 (3) Desist from using the Department, of FR 8254 dated March 1, 1978) (Proce- 
 
 Commerce Label and Mark if its partici- dures). Under section 16.6 of the Pro- 
 
 pation in the Program is terminated. cedures the Secretary must announce 
 
 simultaneously with the publication of 
 
 (Date) the notice of the proposed Specifica- 
 tion her intention with respect to fees 
 
 (Signature) and charges for participation in the 
 
 •■ • program for thermal insulation for 
 
 (Signer's title) homes. 
 
 [FR Doc. 78-14921 Filed 5-26-78; 8:45 am] Accordingly, pursuant to § 16.6(d) of 
 
 the Procedures notice is hereby given 
 
 that the Secretary intends, at such 
 [3510-13] time as a final Performance Informa- 
 
 tion Labeling Specification for ther- 
 VOLUNTARY CONSUMER PRODUCT mal insulation for homes is issued, to 
 
 INFORMATION LABELING PROGRAM suspend all fees and charges for par- 
 
 ticipation in the program with respect 
 Suasion of Fees for Participation to thermal insulation for homes 
 
 This notice is furnished for lnforma- 
 In a separate notice appearing in tion and guidance purposes only in 
 this issue of the Federal Register the order that the public may evaluate the 
 Department of Commerce announces proposed Specification in light of the 
 for public comment a proposed Per- Secretary's intention announced 
 formance Information Labeling Speci- above, 
 fication for thermal insulation for 
 homes (Specification) under the proce- 
 dures for a Voluntary Consumer Prod- 
 uct Information Labeling Program, as 
 amended (15 CFR Part 16; 42 FR 
 26647, dated May 25, 1977; 42 FR 
 57686, dated November 4, 1977; and 43 
 
 Issued: May 23, 1978. 
 
 Jordan J. Baruch, 
 Assistant Secretary for 
 Science and Technology. 
 
 [FR Doc. 78-14922 Filed 2-26-78; 8:45 am] 
 
Appendix J 
 
 19222 
 
 Federal Register / Vol. 44, No. 64 / Monday, April 2, 1979 / Notices 
 
 Office of the Secretary 
 
 Consumer Product Information Labeling 
 Program 
 
 AGENCY: Assistant Secretary of 
 
 Commerce for Science and Technology, 
 
 Commerce. 
 
 ACTION: Suspension of the Consumer 
 
 Product Information Labeling Program. 
 
 summary: Due to the current 
 Government-wide effort to limit 
 expenditures, particularly for new 
 programs, the Consumer Product 
 Information Labeling Program (CPILP) 
 has been suspended, and the proposed 
 CPILP labeling specification for thermal 
 insulation for homes (43 FR 23488) has 
 been withdrawn. This notice also is 
 intended to serve as the annual report 
 required by the CPILP procedures. A 
 more comprehensive report of the CPILP 
 experience is planned which will 
 provide a useful basis for making 
 decisions regarding future Federal 
 Government plans or programs to 
 provide performance-type labeling 
 information on consumer products. 
 FOR FURTHER INFORMATION CONTACT: 
 Dr. Howard I. Forman, Deputy Assistant 
 Secretary for Product Standards, Room 
 3876, U.S. Department of Commerce, 
 Washington, D.C. 20230, 202-377-3221. 
 SUPPLEMENTARY INFORMATION: On May 
 25, 1977, the Department of Commerce 
 announced in the Federal Register (42 
 FR 26647] procedures under which a 
 voluntary Consumer Product 
 Information Labeling Program (CPILP) 
 would be administered by the 
 Department. The goal of this program 
 was to make available to consumers at 
 the point of sale information about 
 consumer product performance to 
 facilitate the making of more accurate 
 consumer purchasing decisions and 
 enhance consumer satisfaction. 
 
 The program was instituted after 
 considering the written statements and 
 oral testimony received from 97 private 
 citizens, consumer organizations, 
 retailers, manufacturers, trade 
 associations, testing laboratories, 
 consulting organizations, educators, and 
 government agencies. Although a 
 majority of the commentors favored 
 
 initiation of the program, there was 
 sufficient opposition, particularly from 
 trade associations and manufacturers, 
 that the Department of Commerce 
 decided to institute the program on a 
 one year pilot project basis. At the end 
 of the year, the Department was to 
 decide whether the program merited 
 continuance. 
 
 Immediately after initiation of CPILP, 
 consultations were held with groups of 
 consumers and consumer 
 representatives, manufacturers, 
 retailers, and other Government officials 
 to select appropriate products for 
 labeling during the pilot phase. 
 Suggestions and comments concerning 
 CPILP were solicited from the public 
 through the news media and via 
 program pamphlets made available to 
 the public through state and local 
 Government consumer affairs offices, 
 private consumer organizations, and 
 some public libraries. During the period 
 June 24, 1977 through June 30, 1978, 1,375 
 letters and postcards concerning CPILP 
 were received from the public, a 
 preponderance of them in support of the 
 program. A total of 145 different 
 products or product categories (e.g. 
 automotive accessories, food, 
 appliances, etc.) was suggested for 
 inclusion in the program. Only 17 letters 
 expressed opposition to the program. 
 
 Three factors were important in 
 product selecton for CPILP by the 
 Department of Commerce: (1) the degree 
 of interest expressed by consumers and 
 consumer representatives in having 
 more performance information for a 
 particular product at the point of sale; 
 (2) the degree of interest shown by 
 manufacturers and retailers of that 
 product in participating in the voluntary 
 labeling program; and (3) the time and 
 money required to solve the technical 
 difficulties in testing the product for 
 important performance characteristics 
 and to design a label which accurately 
 expresses the resulting information 
 about the product in a manner 
 understandale to consumers. 
 
 This last factor turned out to be more 
 important during the pilot program than 
 had been anticipated. No products of 
 more than minimal interest to 
 consumers could be identified that were 
 essentially free of the technical 
 difficulties mentioned above. 
 Accordingly, an extension of the CPILP 
 pilot period until September, 1979 was 
 authorized by the Secretary. Questions 
 of funding, however, were left unsettled. 
 
 Thermal insulation for homes was 
 selected as the first product for which a 
 CPILP label was to be developed. The 
 Department of Commerce published a 
 finding of need to label thermal 
 
 insulation, and set out the basis for such 
 finding in the December 14, 1977 Federal 
 Register (42 FR 62946). Consumer groups 
 generally supported this product 
 selection. As indicated below, not all 
 insulation manufacturers were 
 supportive. Technical questions also 
 existed concerning the appropriate test 
 methods for determing fire and 
 corrosion characteristics of insulation. 
 There was the further complication 
 that other Government agencies are 
 considering issuing or have promulgated 
 information disclosure requirements for 
 thermal insulation attributes of interest 
 to them. For example, the Federal Trade 
 Commission has published a proposed 
 Trade Regulation Rule (42 FR November 
 18, 1977, 59678) which would require 
 labeled information in insulation 
 packages for R value (thermal 
 resistance) and area coverage. A 
 revision of this proposed Trade 
 Regulation Rule is contained as 
 Appendix A in a Federal Trade 
 Commission Staff Report which was 
 announced in the Federal Register of 
 July 25, 1978 (43 FR 32142). The 
 Consumer Product Safety Commission 
 has issued (42 FR August 8, 1978, 35240) 
 an interim mandatory safety standard 
 which requires a statement of 
 compliance with the applicable Federal 
 flammability standard on cellulose 
 insulation labels. A proposed 
 amendment to this interim standard was 
 published in the Federal Register of 
 September 6, 1978 (43 FR 39720). CPILP 
 labeling specifications cannot take 
 precedence over mandatory labeling 
 requirements. However, the Department 
 of Commerce believed it would be 
 desirable to provide on a single label, of 
 uniform format, mandated information 
 and other information that would assist 
 consumers to make an informed 
 purchase. CPILP labels thereby were 
 envisioned as a means for consolidating 
 the various labeling requirements of 
 different Federal agencies with other 
 information which would help simplify 
 product comparison at the point of sale. 
 To this end, an amendment to the CPILP 
 procedures was published in the March 
 1, 1978 Federal Register (45 FR 8254) 
 Authorizing the inclusion on CPILP 
 labels of information about performance 
 characteristics which are included in the 
 labeling programs of other Federal 
 agencies, provided the other agencies 
 agreed. On April 11, 1978 the Secretary 
 of Commerce wrote to the heads of five 
 other Government agencies requesting 
 that, where information required by 
 these agencies was shown on a CPILP 
 label in a form acceptable to the 
 requiring agency, the CPILP label be 
 accepted as meeting disclosure 
 
 J-l 
 
Federal Register / Vol. 44, No. 64 / Monday, April 2, 1979 / Notices 
 
 19223 
 
 requirements of those agencies. The 
 CPILP staff conferred frequently with 
 the technical staffs of other agencies to 
 coordinate label requirements for 
 thermal insulation. Efforts to avoid 
 undue multiplicity of Federal labeling 
 requirements would have been 
 continued if CPILP had not been 
 suspended. Despite the suspension of 
 CPILP, the Department of Commerce 
 will cooperate with other agencies to 
 facilitate the use of information and 
 expertise gathered during the operation 
 of CPILP. 
 
 The Department of Commerce 
 published a proposed specification for 
 labeling thermal insulation in the May 
 30, 1978 Federal Register (43 FR 23488). 
 Interested parties were invited to 
 comment. Forty-five letters were 
 received. Whereas a few of the 
 comment letters expressed only support 
 for or opposition to the program, a large 
 majority of the comments suggested 
 changes to the proposed specification. 
 Some of the proposed changes and the 
 context in which they were presented 
 suggested that many of the 
 manufacturers which control much of 
 the insulation market would be reluctant 
 to participate in the program. Other 
 letters from suppliers, who also 
 proposed changes, were supportive in 
 tone. On balance, it seemed probable 
 that the proposed specification could 
 readily be modified so that sufficient 
 manufacturers would have participated 
 in the program and thereby warrant 
 continance of the effort to develop 
 lables for thermal insulation. However, 
 this likelihood will remain conjectural 
 as budgetary pressures have forced 
 suspension of the program. 
 
 Due to the currently severe stresses 
 upon the economy, and the Government- 
 wide efforts to reduce Federal 
 expenditures, FY-1979 CPILP funding 
 had to be dreastically reduced. These 
 reduced funds would no have been 
 adequate to: complete development of 
 product labels; work with manufacturers 
 in implementing the program; inform the 
 public of the availability and proper use 
 of the labels; monitor the program 
 properly and conduct a meaningful 
 evaluation of its merits. Therefore, the 
 Department of Commerce decided to 
 suspend the pilot program without 
 publishing the final labeling 
 specification for thermal insulation, 
 which would have been the last 
 procedural step prior to accepting 
 insulation suppliers as participants in 
 the program. A comprehensive report of 
 the CPILP experience is planned which 
 will provide a useful basis for making 
 any decisions regarding future 
 
 Government programs for performance 
 labeling of consumer products. 
 
 The Department of Commerce hereby 
 suspends the Consumer Product 
 Information Labeling Program and 
 withdraws the proposed specificatwai 
 for Labeling of Thermal Insulation for 
 Homes (43 FR 23488). 
 Issued; March 27, 1979. 
 
 Jordan |. Baruch, 
 
 Assistant Secretory for Science end Technology. 
 [FR Doc. 79-10043 Filed 3-30-7% 8:*5 am] 
 BILLING CODE 3510-13 
 
 J-2 
 
 atxmmttesrr miihting office: 
 
 1979 0-281-067/221 
 
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