1. Product Recalls: Working Towards Increased Consumer Participation Edward J. Heiden, Ph.D. President, Heiden Associates May 19, 2005

2. Product Safety & Risk Analysis –Evaluate company data to determine if reportable hazard –Determine impact of recalls on future product liability claims –Quantify risk reduction benefits of safety devices and instructions

3. Product Recall Work –Develop effectiveness projections for proposed recalls: initial and second-round –Design effective ways of notifying “hard-to- reach” product owners –Conduct research on recall issues –Continuing effort to dialogue with CPSC on recall effectiveness issues

4. Explore Product Registration Options –Public Forum on Purchaser Identification (March 1999) –CFA CP-01-1 Petition and Comments –Consumer Recall Database Task Force (December 2001) FY 2003 Recall Effectiveness Initiative –Three Workshops (May-September 2003)

5. Heiden Associates/XL Associates Research Study (July 2003)

6. Advertising Cognitive Psychology Communication Theory & Media Studies Consumer Motivation & Compliance Human Factors & Design Research Marketing Recall Management Risk Perception Social Psychology Wide Ranging Search for Insights

7. 5 Not-So-Easy Steps to Participation Receive and Recognize a Recall Message Read & Understand the Message Store & Remember the Message Evaluate Benefits & Costs of Participating Take Action Required to Participate

8. Step 1: Initial Receipt & Recognition of Safety-Related Message Recall Notification Techniques Initial Decision to Pay Attention Message Filtering

9. Step 2: Message Reading & Comprehension Use of Pictures, Pictographs & Symbols Text Content, Clarity, Wording & Form of Address Extent of Processing Required Impact of User Characteristics

10. Step 3: Storage & Recollection of Instructions Memory Limitations & Recall Decay Rates Facilitating Encoding of Messages

11. Step 4: Evaluation of Benefits & Costs of Compliance Formulation of Risk Perceptions: –Hazard-Related Factors –Product-Related Factors “Acceptable” Level of Risk Impact of Compliance Costs

12. Step 5: Actual Compliance with Message Role of Motivation & Social Influence Task Overload Impact of Stress & Time Pressure

13. Falling Off the Steps 88% Noticed Warning 46% Read It 27% Followed the Instructions Source: 1988 Friedmann study of drain opener and wood cleaner

14. Implications for Actual Recalls Some Practical Results from the Heiden/XL Literature Review

15. Implication #1: Try to Get the Message “Closer” in Time and Space to Product Use Placing the message in a manner that causes temporal interruption of the task being performed may stimulate user attention… a warning about proper loading of a file cabinet was noticed by none of the participants when it was placed on the shipping carton, but by nearly all of those who were presented with a cardboard bridge placed across the width of the top drawer.

16. Implication #2: Try to Make the Message Stand Out from the Clutter Presenting hazard information in a hierarchical fashion (i.e., with a one or two sentence summary at the top of the label) outperformed other label designs…There are potential benefits to placing the proactive information (i.e., what you should do to reduce the risk of exposure) before the information relating to the nature of the hazard (the “reactive” information).

17. Implication #3: Try to Mitigate even Minor Inconvenience & Time Costs Warning signs placed on the door to the racquetball court as well as on the front wall instructed users to “wear eye protection”. While 60 percent complied when goggles were provided in a box just outside the door to every court, no one wore them when goggles were only available at a checkout booth 60 feet away from the court.

18. Putting the Report into Practice A 2004 Lawn & Garden Tool Outreach Program

19. The Task: Locating and Motivating Owners of a “Hard to Find” Product Outreach Program Message Delivered through Activity/Interest-Specific Channels: –Store Posters in Garden Equipment Sections –Newspaper Gardening Section Writers/Editors –Gardening Magazine Publishers –Gardening Site Webmasters

20. Specialty Magazine/Web Ads

21. Adding an Incentive to Participate

22. Program Achievements More consumer participation than in first round of recall. Extensive tracking data on outreach coverage and response.

23. Recall Participation by Source of Notification

24. Where Do We Go from Here? Develop Action Plans to Increase Consumer Notification & Participation Based on Research & Workshops Develop Quantitative Assessment of what makes Recalls Effective

25. Recall Outreach Actions Plans Systematic Compilation and Evaluation of Strategies Develop Outreach Options Tailored to Specific Recall Characteristics: –Type of Product –Nature of Hazard –User Demographics

26. New Quantitative Study of Recall Effectiveness No New Studies since Early 1980s New Analysis Needed to Incorporate: –New Types of Products Being Recalled –New Notification Methods –Changes in Consumer Motivation & Behavior