Patrick H. Quinn The Accord Group 1455 Pennsylvania Ave., NW Suite 452 Washington, D.C

 “Safe for use on (surface)” statements were routinely approved by OPP prior to  Examples include: ◦ “safe on cotton” ◦ “safe for septic tanks” ◦ “safely cleans porcelain, ceramic tile”  Frequently, for many CPG companies, the product compatibility question users most want asked is: “Is the product safe for use on _____?” 2

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 OPP (Jones) letter to CSPA (1/2/06) on “Surface Safety Claims.” 1)EPA concerned that consumers would misinterpret the “safe for use on…” claim believing “that the product itself had achieved some elevated level of safety.” 2)“EPA agrees that consumers need to know what products are compatible for use on various surfaces.” 4

 Consumers regularly confront and understand surface safety messages.  Millions of non-FIFRA cleaning products contain “safe for use” statements including: ◦ Laundry Detergents ◦ Floor Polishes ◦ Oven Cleaners ◦ Carpet Cleaners ◦ Pet Stain Removers  These products are similar in formulation, packaging and use pattern to FIFRA registered antimicrobial products.  There is no evidence that consumers misunderstand the surface safety statements contained on these products. 5

July 2015 Prepared by: Meredith Lind Arun Venkataraman Safe Surface Claims Study Results

Online Survey with Nationally Representative Sample Includes 1517 Category Users – defined as being involved in household cleaning and have purchased and/or have on-hand any of the following household product types:  Multipurpose surface cleaners  Toilet surface cleaners  Toilet bowl and toilet tank pouches/hanging tablets  Dishwashing detergents (both manual and automatic)  Laundry detergents  Robust sample of 2,002 US Adults 18+  Representative by gender, age, ethnicity, US Census region, and income  No restrictions imposed on types of products or brands used – allowed to fall out naturally  Margin of error = + 2.2%  Survey respondents were recruited using YouGov’s acclaimed panel, sponsorship was not revealed Data collection: February 18 to 27, 2015 Interview Length: Up to 20 minutes Includes Both Open-Ended & Structured Questions Safe Surface Claims Study: In a Nutshell 7

8 Findings Executive Summary  Overall, an overwhelming majority (98% or more) of respondents did NOT interpret the “safe on multiple surfaces” claim to imply that the product had achieved some enhanced level of personal safety.  Respondents were shown images of a product with the “safe on…” message.  When asked to elaborate on what the claim meant in an open-ended question, 2% or fewer indicated that the multi-purpose cleaner was “safe” for humans, children or pets.  Furthermore, for toilet cleaners, no respondents perceived the “safe on…” message to imply personal safety.  Approximately 90 percent of respondents agree that these two claims inform them where to safely use the product or how to use the product or that the product will not damage surfaces – meeting our pre-specified threshold.  The phrase “safe on multiple surfaces” appears to be more effective in conveying the claim that the product is safe for the surface than the phrase “suitable for use on multiple surfaces.” Most respondents believed that a “suitable” product may not necessarily be “safe” for the surface.  There is no evidence that individuals would use multipurpose cleaners or toilet cleaners in an unusual manner upon hearing the “safe on…” or “suitable for use on…” claim. Most reported that they would use the product to safely clean the recommended surfaces, thus eliminating the need for multiple products to clean different types of surfaces

9 Majority of respondents did not interpret the “safe on multiple surfaces” claim to imply that the product had achieved some enhanced level of personal safety 1 Q16. Now if you saw the multipurpose surface cleaner you use most often, with the phrase “safe on multiple surfaces” on the label, what would this mean to you? Please tell us in your own words what you think this phrase means? Q21. Now if you saw the toilet cleaner you use most often, with the phrase “safe on stainless steel, white and colored ceramic toilets” on the label, what would this mean to you? Please tell us in your own words what you think this phrase means? What “Safe On Multiple Surfaces” Means For Multipurpose Surface Cleaner Users/Non-users (n=954) What “Safe On Stainless Steel, White And Colored Ceramic Toilets” Means For Toilet Cleaner Users/Non-users (n=887) “It means I can use it on wood, glass, plastic, etc. Meaning I could go from washing windows, to cleaning wooden tables, to cleaning the toilet without it staining, streaking, removing finishes, etc.” “That it is safe to use on stainless steel, white, colored ceramic toilets and it wont damage those surfaces”  When asked to elaborate on what the claim meant in an open-ended question, 1% or fewer indicated that the product was “safe” for humans, children or pets.

10 Approximately 90 percent of respondents agree that the “safe on…” claims inform them where to safely use the product or how to use the product or that the product will not damage surfaces – meeting our pre-specified threshold Response To “Safe On Multiple Surfaces”/ “Safe On Stainless Steel, White And Colored Ceramic Toilets” Q17. Again, if you saw this multipurpose surface cleaner with the phrase “safe on multiple surfaces” on the label, which of the following statements do you feel would be true? Select all that apply. Q22. Again, if you saw this toilet cleaner with the phrase “safe on stainless steel, white and colored ceramic toilets” on the label, which of the following statements do you feel would be true? Select all that apply. Q26. Again, if you saw this multipurpose surface cleaner with the phrase “suitable for use on multiple surfaces” on the label, which of the following statements do you feel would be true? Select all that apply. Q30. Again, if you saw this toilet cleaner with the phrase “suitable for use on stainless steel, white and colored ceramic toilets” on the label, which of the following statements do you feel would be true? Select all that apply. 2

11 The phrase “safe on multiple surfaces” appears to be more effective in conveying the claim that the product is safe for the surface than the phrase “suitable for use on multiple surfaces” How Do The Claims Differ? “The first term, safe, makes me feel better about using it on other surfaces. The latter, suitable, gives me more hesitance” Q50. In your opinion, how do the two claims differ? Q51. Which of the two claims below would best meet your expectations of the product’s intended use? Please select any one response “Safe On Multiple Surfaces” Vs. “Suitable For Use On Multiple Surfaces” (n=711) 3 Safe on multiple surfaces Suitable for use on multiple surfaces Not Sure Claim That Best Meets Expectations Of Product’s Intended Use (n=2002) “Safe on multiple surfaces means it can be used almost anywhere without fear of damaging the surfaces. Suitable for multiple surfaces means to me that there is a chance that it could damage some surfaces”  Most respondents believed that a “suitable” product may not necessarily be “safe” for the surface.

12 Use Product Differently If Phrase Was Included Multipurpose Surface Cleaners (n=954) Toilet Cleaners (n=887) There is no evidence that individuals would use multipurpose cleaners or toilet cleaners in an unusual manner upon hearing the “safe on…” or “suitable for use on…” claim How “Safe/Suitable for Use On Multiple Surfaces” Would Make Multipurpose Surface Cleaners Be Used Differently [ASKED AS OPEN-END QUESTION] Q18B. [Multipurpose Surface Cleaner: “safe on multiple surfaces” claim] How would you use it differently? Q26B. [Multipurpose Surface Cleaner: “suitable for use on multiple surfaces” claim] How would you use it differently? Q22B. [Toilet Cleaner: “safe on stainless steel, white and colored ceramic toilets” claim] How would you use it differently? Q30B. [Toilet Cleaner: “suitable for use on stainless steel, white and colored ceramic toilets” claim] How would you use it differently? “Safe…” (n=501) “Suitable for Use…” (n=526) 4 Yes, I wouldNo, I would not  Most reported that they would use the product to safely clean the recommended surfaces, thus eliminating the need for multiple products to clean different types of surfaces.  Respondents were asked if they would use the cleaner differently, in order to determine whether the “safe on…” claim would cause consumers to use the product in a manner that would impact personal safety. However, the responses provided below clearly indicate a lack of misunderstanding that might result in harm.