A NUSY OF LEGIB'ELWY FACFQRS FQR $TATEMENTS Cl? CQN'F'EN'ES ON CQNSUMER 60095 FQQE PACKAGES “tests for flu: Degree of M. S. MICHIGAN STATE UNIVERSITY Neii I. Giib-ert 1967 ". C‘rfiYY‘ “fl , , 1"‘m ".F‘ h L) l UJ)Y kjil‘ “a4 vahlkfi.‘ AJ-L A. 4 1 3V .LO;\‘I r v. * *=*r Tan-v ‘* I 7», .- Cf“ l‘ m .\.- ‘ ‘y’mr' "‘ ,st'f') -. "V‘I: nu: F“T ‘ y‘.w - 1‘ OA{ 01.11; LAKLJULA) Of Vu.\!l:u\ LA: \Jl! CJ.‘!LJIJ .';LL{ GOODS ETIX) PnCKnGES by Neil I. Gilbert Prompted by such ambiguous reg“latory terms of the Fair Packaging and Labeling Act as ”conspicuous” and ”easily legible" for statements of contents on consumer commodity package labels, the author compiled a list of legioility fac- tors which contains specific recommendations for improvin the legibility of printed material. The list, a compilation #6) of results of many earlier studies in the area of type-ace legibility, contains some factors which are supported by only one study or investigator, but contains many factors given support by several different investigations or investigators. ‘3 Next is presented a discussion of the Fair Packsc ms; U and Labeling Act and the Federal Food, Drug, and Cosmetic Act proposed modifications affecting net weight statements on consumer food packages. The two areas of concern were: (l) the required size of type in relation to the area of the pack- ge principal display panel, and (2) the required placement ‘ p of the net weight statement in the lower twenty per cent of the principal display panel area. Were these requirements fair and just to not only the consumer but also to the manu- facturer of a product? Through a process of visually analyzing seven pack- Neil I. Gilbert age display panels, determining the time required for sub- jects to locate and orally read tne net weight statements on each, it was concluded that the above-mentioned regulations did not create significant differences in the ease with which a consumer could "obtain accurate information as to the cuan- tity of contents." Therefore, it was concluded that the regu- lations were fair to both consumer and manufacturer. Also included, as Appendix II, is a list of sixty-six sources pertaining to studies conducted in the area of visual analy- sis of typographic material. It was felt these sources would prove useful to someone interested in this work. A STUDY OF LEGIBZLITY FACTORS FOR STATEHENT" or CONTENTS on com 3x33 GOODS FOOD PACKaGES By Neil I. Gilbert Submitted to Michigan State University in partial fulfillment of the requirements for the degree of MASTER OF SCILNCE School of Packaging Department of Forest Products 1967 ACKNOWLEDGEENTS Dr. Harold J. Raphael and Dr. Hugh E. Lockhart of the School of Packaging, Michigan State University, furnished valuable suggestions and guidance throughout this study. Their contributions are greatly appreciated. The author also wishes to thank his wife and fami‘y without whose continuing encouragement, understanding, and patience this work would not have been possible. ii F3 “1* LT! t“ [13 O *1 O O ./ F] t: d U) ACKNOWLEDGMENTS . . . . . . . . . . . . . . . . . . . . LIST OF TABLES. . . . . . . . . . . . . . . . . . . . . LIST OF ILLUSTRATIONS . . . . . . . . . . . . . . . . . LIST OF APPENDIXES. . . . . . . . . . . . . . . . . . . INTRODUCTION. . . . . . . . . . . . . . . . . . . . . . Chapter I. LEGIBILITY OF PRINTED NATTER. . . . . . . . . . Typography's Role in Package Design . . . . . Legibility Factors and Requirements of Each for Legible Printed Material. . . . . . . . II. CONSUMER PACKAGE LABELING LEGISLATION . . . . . General Discussion. . . . . . . . . . . . . . Fair Packaging and Labeling Act (Net Weight Statement Labeling Requirements). . . . . . Federal Food, Drug, and Cosmetic Act (Net Weight Statement Labeling Requirements) . . Summary and Comparison of the Acts. . . . . . III. PRINCIPAL DISPLAY PANEL VISUAL ANALYSIS . . . . Introduction. . . . . . . . . . . . . . . . . In-Store Study. . . . . . . . . . . . . . . . Size of Net Weight Statement Type in Relation to the Area of the Package Principal Dis- play Panel. . . . . . . . . . . . . . . . . Placement of Contents Statement in Lower Twenty Per Cent of Display Panel Area . . . IV. CONCLUSIONS AND RECOMMENDATIONS . . . . . . . .. LIST OF REFEREI:CES . o o o o o o o o o o o o o o o o o o APPENDIXES. .'. . . . . . . . . . . . . . . . . . . iii Page ’J. tJ- 9 O\ . 22 Table Net Weight Statement Compliance with the 3 Food, Drug, and Cosmetic Act Proposed Modiiica- ‘ v-1 ('3 c deral tions (Minimum Type Size and Placement) . . . . . Specifications of Display Panels Analyzed (Panel Size and "Net Weight” Type Size). Times Required for Subjects to Locate and Read the Net Weight Statements on the Various Display Panels. 0 C O O O O O O O O O O 0 Mean Times Required for Subjects to Locate and Various Read the Net Weight Statements on the Display Panels. . . . . . . . . . . . T-Test Results Between Kean Times for StUdied a o o o o o o o o o 0 Times Required for Subjects to Locate Net Weight Statement on Panel iv G O Page Figure 1. Panel Panel Panel A--With B--With C--Nith D--With E—-With F--With G--With LIST OF ILLUSTRAT Specifications. Specifications. Specifications. Specifications. Specifications. Specifications. Specifications. IONS m \u n) Cu C ) \O m \N H '53 35 37 50 LIST OF APPENDIXES Appendix . Page I. Definition of Terms. . . . . . . . . . . . . . . . 62 II. Visual Testing Bibliography. . . . . . . . . . . . 53 vi INTRODUCTION Nrs. Esther Peterson, a past Advisor to the President on Consumer Affairs, referred to 1966 as the "Year of the Consumer."1 Mrs. Peterson's statement was undoubtedly prompted by the then-current boom in consumer protection leg- islation. The most recent examples were the National Traf- Ific and Motor Vehicle Act-~the first federal law to order compulsory safety standards for new and used automobiles and for automobile tires, and the_§EEEME§353§22§~E§quab¢Linfli593:” éesigned to protect the shopper from deceptive packaging prac- tices such as hard-to-find net weight statements, and such misleading and often meaningless terms as "jumbo poundi> The Fair Packaging and Labeling Act, signed into law November 3, 1966, was the culmination of proposals and hearings before the Congress which began in 1961. The Act requires that consumer products in interstate commerce be_h3n§§tly*and_ infgrmatively labeled, to enable_a_shoppegmtgueasily_and quickly determine the best value for her_money1 Fair Packaging and Labeling Act Declaration of Policy Sec. 2. Informed consumers are essential to the 1"Consumer: King or Vassal of the Economy?” Senior Scholastic, February 10, 1967, p. 13. l'\) fair and efficient functioning of a free market econ- omy. Packages and their labels should enable con- sumers to obtain accurate information as to the quan- tity of the contents and should facilitate value com- parisons. Therefore, it is hereby declared to be the policy of the Congress to assist consumers and manu- facturers in reaching these goals in the marketing of consumer goods. Briefly, what the Act requires on a consumer product package is the following: 1. Product identification. 2. Name and place of the manufacturer or distrib- utor. 3. Net quantity of contents in terms of weight, meas- ure, or numerical count. 4. Net quantity of each serving if the label indi- cates a particular number of servings is contained. The Fair Packaging and Labeling Act is administered by two governmental agencies: the Secretary of Health, Edu- cation, and Welfare--regarding foods, drugs, and cosmetics; and the Federal Trade Commission--regarding other consumer products. Each has the authority to promulgate additional regulations--according to Sec. 5 of the Fair Packaging and Labeling Act-~with respect to the consumer products over which it has regulatory authority. Such regulations will take the form of modifications of existing regulations covering the 2U.S., Congress, Fair PackagingAand Labeling Act, Public Law 89-755, 89th. Cong., s. 985, 1966, p. 1. affected products; for the Act is not intended to repeal, in- validate, or supersede: l. The Federal Trade Commission Act or any statute defined therein as an antitrust Act. 2. The Federal Food, Drug, and Cosmetic Act. 3. The Federal Hazardous Substances Labeling Act.3 The scope of this thesis shall be restricted to a study of net weight statements on packages--classified as con- sumer food packages-~for the following reasons: 1. A very large percentage of the consumer products affected by the Fair Packaging and Labeling Act are food products. - 2. In today's giant impersonal supermarket--as much or more than in any other type of retail outlet-- the shopper must rely almost totally on the pack- age to give him the basic product information-he once received from the salesman. 3. Price-value relationships are becoming apparently more important to the grocery shopper, who is quite frankly often confused by the barrage of ad- vertising claims for a given product category. First, a brief discussion of typography, specifically a discussion of factors that contribute to the legibility of 3Ibid., Sec. 11. printed matter is presented. This is done in the hepe of making a meaningful contribution to those in the packaging industry J directly concerned with the Fair Packaging and Labeling Act and subsequent regulations, and who are faced with such am— biguous regulatory labeling terms as "conspicuous” and ”easily legible." Next is presented a discussion of the Fair Packaging and Labeling Act regulations and the Federal Food, Drug, and Cosmetic Act proposed modifications affecting net weight statements on consumer food packages. The two areas of con- cern were: (1) the required size of type in relation to the area of the package principal display panel, and (2) the re- quired placement of the net weight statemen in the lower.20% of the principal display panel area. The question to be an- swered was whether these regulations were fair and just to not only the consumer but also the manufacturer of a pro- duct. The approach taken to answer this question was not that of personal opinion nor sentiment, but rather a process of factual investigation and visual testing. I. LEGIBILITY OF PRINTED MATTER Typography's Role in Package Design ”Typography" is defined by Webster's New International Dictionary as the "act or art of expressing by types or sym- hbols; emblematic representation."# Clearly therefore, the typographer's main goal is communication.5 This communication should be clear with as little interference as possible. The medium for conveying the message is the printed matter--the type. Therefore, type becomes an integral part of the mes- sage; and every attempt should be made to employ legible type. Prompted by such statement of contents regulatory terms as "easily legible" and "in distinct contrast," the author felt that some form of guidelines should be established to assist the package label designer in determining what in- deed does constitute "legible” type and "distinct contrast" of printed material. The Federal Food, Drug, and Cosmetic Act proposed mod- ifications list several requirements which must be met in or- "Typography," Webster's New International Dictionary (Springfield, Nass.: G. & C. Nerriam Co., 1957), p. 2751. 5John Lewis, Typography: Basic rincipals — Influ- ences and Trends Since the 19th. Century (New York: Rein- hold Publishing Corporation, l96h), p. 42. O\ der for the net weight statement to qualify as ”conspicuous” and "legible" in the legal sense. Not included in this list, however, is a discussion of type face characteristics which enhance the legibility of the type, nor any mention of what brightness gradient differentials between the symbol and the background are necessary to produce "distinct contrast.” Therefore, a list of legibility factors was compiled from a study of many reports of earlier investigators in the field of visual analysis of typographic matter. These factors are intended to aid the package designer in developing a label which will clearly communicate all mandatory printed infor- mation. Legibility Factors and Requirements of Each For Legible Printed Material "Legibility" was defined by one investigator as "the total amount of characteristics of symbols which determine the visual ability to recognize and read them correctly." The specific means for measuring type face legibility are dictated by the particular study involved. Burtt and Basch7 listed five general methods for measuring legibility of type 6Curt Berger, "Some Experiments on the Width of Sym- bols as Determinantof Legibility," Acta Qphthalmologia, XXVI (1948). pp- 517-550. 7Harold E. Burtt and Coryne Basch, "The Legibility of Bodoni, Baskerville Roman, and Cheltenham Type Faces," Journal of Applied Psychology, VII (1923), pp. 237-245. face: 1. haximum distance at which the type can be read. 2. Time taken to read a passage. 3. Number of letters read in a tachistoscope or min- imum exposure at which they can be seen. A. Minimum illumination under which type can be seen. 5. Extent to which letters can be thrown out of focus and still be legible. Regardless of the specific method employed, the conclusions of the various investigators studied were in general agreement. Most of the legibility factors listed below were sup- ported by more than one investigation, and therefore shall not be individually footnoted. A few, however, were conclu- sions of only one study or one investigator. These are indi- vidually credited. I. The FORM or CONFIGURATION of the letter. There is a distinct difference in the legibility of printed material printed in different type faces, and between different characters of the same type face. Suggestions for contributing to more legible form are: A. Simple outlines should be employed whenever pos- sible. B. The use of a type face having few hairlines is 07) recommended. C. Characteristic parts of each symbol should be em- phasized in the type face design. let— 9. D. Regular letter width rather than condense ter width should be utilized wh never possible. (Breadth of the character is more important than H, character height because breadth allows or‘ greater visibility of the letter's internal spaces.)9 a. The use of caps and lower case letters in combi- nation (first letter of each word capitalized) is better than the use of all upper case letters for tasks such as headline reading. (Visually grasping the net weight statement on a packag G) principal display panel is similar to the headline reading task.) F. A symbol width-to—height ratio of 5:5 is recom- mended.10 8Miles A. Tinker, ”The Relative Legibility of the Let- ters, the Digits, and of Certain hathematical Signs,” Journal of General Psychology, I (1928), pp. 472-496. 9E.C. Sanford, "The Relative Legibility of the Small Letters," American Journal of Psychology, I (1888), pp. AC2- 435. lO,. ' , .. . Charles A. Baker and halter F. Grether, "Visual Presentation of Information," WADC Technica Report 54-160 United States Air Force, Wright Air Development Center, August, 1954, p. 57. ' II. The SIZE of the letter. F" orinted matter is about 28 inches A. When the p rom the observer's eye, the recommended minimum let- ter height is 0.10 inches when the level 01 mination is above one foot-candle. ing constant. C. Distance recognition is better for capitals than for lower case letters. (This is due to the ap- parent larger size of an upper case character.) III. The STROKE WIDTH of the letter. A. Light strokes are poor. B. There is generally an increase in the legibilitv of printed matter with increased stroke width. C. The stroke width should be uniform. D. The stroke width should be approximately 25% of the mean letter width.12 E. The optimum height to stroke-width ratio appeared to vary with the particular type face involved, 11Ibid., p. 57. 2Mason N. Crook, J.A. Hanson, and A. fieisz, "The Legi- bility of Type as Determined by the Combined Effects of Typo- graphical Variables and Reflectance of Background," WADC Technical Report 55-4Al United States Air Force, Wright Air Development Center, March, 1954, p. 12. IO and differed slightly from upper to lower case 'ght to stroke-width ratios 0 :3 93 *1 m 0 d (D H U) 0 r—3 :5 (D :3 (D ’J J F" discovered ranked 5 row 4.6:1 to 8.0:1, with the U IV. The SPACING between characters. Optimum spacing appeared to be about 50% of mean let- ter width.13 V. The SIZE of the CRITICAL DETAIL. As mentioned earlier, the critical detail can be im- proved by expanding the letters. Such increased breadth gives more visibility to the internal spaces of the Characters. VI. The CONTRAST between FIGURE and BACKGROUND. Concerning the relative legibility of black charac- ters on a white background versus white characters on a black background, differing conclusions w re dis- covered: A. Three studies indicated that black printing on a white background proved more legible. B. Two studies reported no apparent difference in the legibility of the two combinations. l- 13, ‘.N. Crook, J.A. Hanson, and A. Weisz, "Th Le bility of Type as a Function of Stroke Width, Letter ”i and Letter Spacing Under Low Illumination," TADS Techni Report 53-A40 United States Air Force, Wright Air DeveIOp- ment Center (Submitted to Aero Medical Laboratory, march, 1954), p0 190 :Lm ‘n ‘T .— LI 2'] \‘.~ () 11 ’9 C. Only one study indicated that-~under nigh illu- mination--wlite printing on a blaCA background q was more 1e ble than black printing on a white gi - , .14 baCAground. VII. The BRIGHTNESS CONTRAST between S'KBOL AREA and BACKGROUND The studies agreed generally that the greater the brightness contrast between syn pool area and back kgr ound the greater is the legibility of the material. Spe- cifically, one study reported the relative le egi bility 15 of several color combinations. The following list, taken from that study, is in descending order of legi— bility. . GOOD FAIR POOR- Blue on White Green on Red Orange on Black Black on Yellow Red on Yelldw Black on Purple Green on White Red on White Orange on Lhite Black on White Red on Green These combinations are but a few of the possible com- binations of color employed in package label design; ng. Dunlap, Report of the Highway Rese are 0“ (National Research Council, Division Office, 1952), apne.- dix E, Article 4, p. 3. - l . H . 5Katherine Preston, Howard P. Schwankl, and -iles n. Tinker "The Effect of Variations in Color of Print and Back- 9 ground on Legibility,” Journal of General Psychology, VI (1932). pp. 459-461. b-J 12 and there is room for question concerning what value of each hue the researchers employed. The list does provide, however, a point from which to start when considering what color combinations could be employed to create the desired design effect and still be con- sidered "in distinct contrast." The most unfavorable combination of the above-listed factors of legibility is: (1) condensed letters, (2) close- er should bear in I). spaced, 'ith (3) narrow strokes. The rea mind, however, that what may be optimally legible in one in- stance may prove much less so in another.) Frederic W. Goudy, designer of more type faces than any other type creator in history, was quoted as saying, "I feel that too few (design- ers) realize that a type amply legible for one purpose may not prove so for another--there is no universal type--there is no universal quality of legibility for types of all pur- poses."1 However, if a package designer considers the above- mentioned legibility factors when planning the printed mes— sage on his package, and employs combinations yielding what is generally accepted as legible print in contrasting colors, he should encounter little difficulty in developing copy l6Earl English, "Study of Readability of Four Newc- paper Headline Types," Journalism Quarterly, XXI (l9h4), pp. 217-229. *4 \J.‘ which will be considered ”legible" and ”in distinct contrast” by the governmental regulatory bodies. II. CONSUMER PACKAGE LABELING LE~ISLATI X H) The legislation applicable to th area 0 net weigh .11 91 .11. *1 statements for food packages and herein discussed is the Packaging and Labeling Act, and 21 CFR Part 1 of the Federal Food, Drug, and Cosmetic act as proposed ammended by the Commissioner of Food and Drugs. Section 201 (f) of the Federal Food, Drug, and Cos- metic Act defines "food” as ”(1) articles used for food or drink for man or other animals, (2) chewing gum, and (3) ar- ticles used for components of any such article." Such items account for a very large percentage of the products found on supermarket shelves-~those commodities purchased for house- hold consumption or expenditure. There are a few product categories which the reader might normally consider to be a "food” product but which are exempt from the Fair Packaging and Labeling Act. These in- clude meat and meat products, and poultry and poultry pro- ducts. These items are subject to regulations under other laws, and the exemptions are in accord with those of the Fed- eral Food, Drug, and Cosmetic Act. lfl (Net 15 *‘.. ‘ "‘. 1 v. ' , . ‘ . J ”u full" HdCJ’Zufflf‘u‘: c.1215}. Ic'bn1.infll “‘Ct .4' weight Statement Labeling Requirements) Th e ’31 air Packaging and Labeling Act requires that the net quantity of contents be expressed: 1. In a uniform location upon the principal dis- play panel of the label. In ounces (with identification as to avoirdupois) and, if applicable, in pounds, with any remainder in terms of ounces or common or decimal fractions of the pound, if the product weighs less than four pounds. In ounces (with identification as to fluid) and, if applicable, in the largest whole unit (quarts, quarts and pints, or pints, as appropriate) with any remainder in terms of fluid ounces or common or decimal fractions of the pint or quart, if the product is less than one gallon. In inches and the largest whole unit (yards, yards and feet, or feet, as appropriate) with any remainder in terms of inches or common or decimal fractions of the foot or yard for a pack- age labeled in terms of linear measure. In square inches and the largest whole square unit (square yards, square yards and square feet, or square feet, as appropriate) with any remain- 16 der in terms of square inches or common or deci- mal fractions of the square foot or square yard for packages labeled in terms of measure of area. 5. In conspicuous and easily legible type in dis- tinct contrast (by typography, layout, color, embossing, or molding) with other matter on the package. 6. In letters or numerals in a type size which shall be (a) established in relationship to the area of the principal display panel of the package, and (b) uniform for all packages of substantially the same size. 7. In lines parallel to the base on which the pack- age rests as it is designed to be displayed. Federal Food, Drungand Cosmetic Act (Net Weight Statement Labeling Requirements) The Federal Food, Drug, and Cosmetic Act - 21 CFR [Part 1 (as proposed ammended by the Commissioner of Food and Drugs) lists the following labeling requirements for the net weight statements: 1. The declaration shall be located on the principal display panel of the label, and with respect to packages bearing alternate principal panels, it shall be duplicated on each principal display 17 panel. The declaration shall appear as a distinct item son the principal display panel, separated (by a space at least equal to the-height of the letter- ing used in the declaration) from other print d (b matter appearing above the declaration, and shall be void of any qualifying words or phrases. ‘It shall be placed on the principal display -anel '(5 within the bottom twenty percent of the area of the panel in lines generally parallel to the base on which the package rests as it is designed to be displayed. No label information shall appear below or to either side of the declaration on the principal display panel. The declaration shall accurately reveal the quan- tity of food that may be delivered from the pack- age exclusive of wrappers, propellants, and other material packed therewith. The declaration shall appear in conspicuous and easily legible boldface type in distinct contrast (by typography, layout, color, embossing, or molding) to other matter on the package. Require- ments of conspicuousness and legibility shall in- clude the following specifications: A. No decorative or ornamental letters shall be used. (T is is in accord with the first el smpli City of typeface.) FJ. ment of good form-- B. The ratio of height to width 0: the letter shall not ex ceed a differential of 3 units 1 unit. (This w; ll prohibit the use of ex- tremely condensed letters, which were repor to be less legible than regular vidth lette v. Letter heights pertain to upper case (cap- ital) letters. When pper and lo."er case te or all lower case letters are used, it is the lower case "x” or its equivalent that shoul meet the minimum standards. D. Vhen fractions are used, each c mponent nu- meral shall meet the mini: um heigh stand- ards. (This will increase the legibility, other factors remaining constant.) 5. The declaration shall be in letters and numeral in a type size established in relationship to the area of the principal displa ay panel of the (1‘ J O U) . l . . pacnage7 and shall be uniform for all pecn d S 17The Federal Food, Drug, and Cosmetic ict proposed modifications define "area of the prinCi pal display panel" as the area of the side or surface tha bears the principal display panel, which area shall be: (1) In the case of a rectangular package wh entire side properly can be considered to be the pri L on a Cipé; m (D ’3 display panel side, the product of the height tines the width of substantially the same size complying with the following type specifications: \ \' ’ f ‘ ‘ q A. not less than l/lo inch in “eight on pacn- ages the principal display panel of which has an area of 5 square inches or less. B. Not less than 1/8 inch in height on pack- ages the principal display panel of which has an area of more than 5 but not more than 15 square inches. C. Not less than 3/16 inch in height on pack- ages the principal display panel of which has an area of more than 15 but not more than 75 square inches. D. Not less than 1/4 inch in height on packages the principal display panel of which has an area of more than 75 square inches, except not less than l/2 inch in height if the area is more than 400 square inches. The Federal Food, Drug, and Cosmetic Act 21 CFR Part 5 l (as proposed modified), contains additional labeling regu- of that side. (2) In the case of a cylindrical or nearly cylin- drical container, 40 percent of the product of the height of the container times the circumference. (3) In the case of any other shaped container, the total actual area of the surface of the principal display panel. lations for net weight statements; but merely a repetition of the Fair Packaging and act regulations concerning methods of including the units of measure to be allowed and abbreviations for different quantities. Therefore, further explanation of them is not here in order. .0 Summary and Comparison Ol the Acts Below in brief outline form is shown what the above- discussed legislation requires for net weight statements on consumer food packages. Also exhibited is the relationship of the Federal Food, Drug, and cosmetic Act statement of con- tents.labeling requirements (as proposed ammended) to those of the Fair Packaging and Labeling Act. Fair Packaging and Labeling Act Federal Food, Drug, and Cosmetic Act 1. Statement must appear in 1. Statement must appear a uniform location on in the lower 20% of the the display panel. display panel area. 2. Measurement units to 2. Same (somewhat more be used. explicit). 3. Statement must appear 3. Same (four requirements in "conspicuous and of conspicuousness and easily legible type..." legibility). h. Type size established in Q. Bxplicitly lists five relation to panel area. groupings of panel areas and related minimum re- quired type size. 5. "In lines parallel to 5. Same. the base...." The requirements of items (2) and (5) of the above list do not materially affect the legibility of the net weight statement; and shall therefore not be further dis- cussed. Items (l). (3), and (4) do, however, relate very closely to the legibility of the net weight statement. The requirements of item (3) were discussed at some length ear- lier in this paper. Therefore, the net weight statement labeling requirements of items (1) and (4) constitute the basis for the remainder of this work. III. PRINCIPAL DISPLAY PANEL VISUAL ANALYSIS The first area of concern was the Food and Drug Ad- ministration proposed minimum type size requirements for the ackage ’6 net weight statement in relation to the area of the F" principal display panel. It appeared unreasonable, or ex- ample, to require a package having a principal display panel area of 15.01 square inches to have the net weight statement minimum type size equal to the net weight statement minimum type size on a package the principal display panel of which had an area of 75.00 square inches. This reasoning involved the apparent disproportionate type size relationship between I the net weight statement and other typographic matter on the 15.01 square inch panel and the net weight statement and other typographic matter on the 75.00 square inch panel. The second area in question was the Food-and Drug Ad- ministration proposed regulations requiring the net weight statement to appear in the lower 20% of the principal dis- play panel area. Was this requirement based on an already established pattern? And could the consumer locate the state- ment quicker if positioned in the lower 20% of the panel area than if positioned elsewhere on the panel? It was felt these 22 23 two questions needed answering. In—Store Study Before any visual testing was performed, an in-store 'investigation was made to determine: 1. What was the general height to width ratio for existing package primary display panels; and which dimension was parallel to the base on which the package normally rested when displayed for sale? Based on the location of the net weight statements, what percentage of the food packages investigated would conform to the F&DA proposed regulations regarding placement of the statement in the lower 20% of the principal display panel area? Based on the type size of the net weight state- ments, what percentage of the food packages studied would conform to the F&DA proposed regu- lations regarding the required minimum type size in relation to the area of the primary display panel? Which of the five ranges of display panel area (and accompanying minimum required statements of contents type size) merited investigation? The ranges, with respectively required minimum type The 24 size for the net weight statements (as found on page (19) of this paper) are: a) Five or less square inches . . . .1/16" type. b) Over five to fifteen sq. in. . . . 1/8" type. 0) Over fifteen to seventy-five square inches. . . . . . . . . . .3/16" type. 5 d) Over seventy-five to four hundred square inches. . . . . . . . . . . 1/4" type. :i e) Over four hundred square inches. . 1/2" type. results of this study were: I The average height to width ratio for the pack- ages analyzed was 1.55:l. There was about a 2:1 ratio of packages having the short display panel dimension parallel to the base of the package to those having the longer dimension parallel to the base of the package. On 65.5% of the packages inspected, the net weight statement was found in the lgwep portion of the primary display panel. (This wasn't necessarily within the lower 29% of the panel area, for the distance each statement was from the bottom of the panel was not measured; but it would have been very close to the lower 20% of the panel area if not within it.) Only 51.2% of the packages inspected would con- 25 form to the F&DA proposed regulations regarding the required minimum type size in relation to the area of the principal display panel. The results of (2) and (5) for each range are illus- trated in TABLE 1. It TABLE 1 NET WEIGHT STATEMENT COMPLIANCE NIT: THE f FEDERAL FOOD, DRUG, AND COSEBTIC ACT i PROPOSED MODIFICATIONS ‘ MINIMUM TYPE SIZE AND PLACEKENT a Group No. of Packages Per Cent Compliance Inspected Min. Type Size Placement a) 2 100.0 50.0 ' b) 21 19.0 1.4 c) 3# 20.5 6A.6 d) 6 100.0 ‘ 50.0 e) 1 100.0a 100.0 aThe digit type size was well in excess of the mini- mum standards, but the words "Net Wt." were less than the proposed minimum allowed type size. Because of the 100% compliance with the regulations for minimum type size within groups (a) and (d), and because only one package could be found in the store having an area greater than 400 in.2--Group (e)--it was decided to inves- tigate further only packages of which the size of the display panel would fall within Groups (b) and (c). Further support 26 for this decision was the fact that packages having a primary display panel area of between five and seventy-five souare inches account for by far the great majority of all consumer food packages normally displayed on supermarket shelves. and, as indicated in TABLE 1, there was only about 20% compliance with the F&DA proposed modified net weight minimum required I“ type'sizes for packages within these groups. Size of Net Weight Statement Type in Re- lation to the Area of the Package Principal Display Panel El Testing Procedure The first step in the visual testing was to evaluate several package display panels the areas of which were within the limits of Groups (b) and (c). The purpose was to test in one way the "fairness" of the Federal Food, Drug, and Cosmetic Act proposed modifications concerning the required minimum type size for the statement of contents in relation to the area of the package principal displapranel. The test specimens consisted of six package display panels, the areas of which corresponded to the lower and upper limits of each of the two groups investigated, with one panel in each size group having an area equal to the mean panel area of the packages analyzed in the supermarket falling with- in each of the respective groups. The ratio of the height to width of each panel tested 27 was 1.55:1. This ratio was based on the packages evaluated in the supermarket (See page 24). The size of the panels tested with the corresponding net weight type size can be seen in TABLE 2. TABLE 2 SPECIFICATIONS OF DISPLAY PANELS ANALYZED PANEL SIZE AND "NET WT." TYPE SIZE I.“ r“ 1. Statement of Contents Group Panel Area Type Size Inches Points . 2 b) 5.01 in. 1/8 9 b) 9.20 in.2 " " . 2 b) 15.00 in. " " . 2 c) 15.01 in. 5/16 14 c) h0.80 in.2 " " c) 75.00 in.2 n " The panels were made of white clay-coated bending board stock; and the printing was accomplished by use of transfer lettering. Inc. of Crystal Lake, Ill. was employed.) (TRANS-ARTYPE manufactured by Artype, The typographic materia1-—design, layout, and type face-~of each panel was identical and in direct size proportion to the height of each panel. The type size of the net weight statements, however, F.‘ was the same for the three panels within each group. An ex- act replica--with specifications-~0f each packare display panel visually analyzed is found on the following pages. FIGURE 1 PANEL A ”13 'jD T? f‘ F“ [M 5 Lu : Hthfiotmn i NUTRFHOUS . "BREAKFAST CEREAL ; . :6.» NE! WI. 8.6 02; t l | D f I L SPECIFICATIONS 1. PANEL SIZE: 5.01 in.2 2. TYPE SPECIFICATIONS: Points18 Style HI-PRO 56 Franklin Gothic Extra Condensed G 10 News Gothic Condensed NEW! _ " n High Protein " H NUTRITIOUS .. n 'BREAKFAST CEREAL 14 n NET WEIGHT 8.6 oz. 1# Futura Bold Because of a problem in securing the same type face for the elements on each of the six different panels, it was not always possible to obtain a type size which was exactlv in direct proportion to the height of the corresponding panel height. Any discrepancies, however, were very slight, and would not affect the results of the study. A "point" is 1/72 of an inch. 1. 50 FIGURE 2 PANEL B ‘33 NEW: HP? High Protein NUTRHWOUS EBREAKFAST CEREAL. 3‘ NE'I' WI. 8.6 oz. SPECIFICATIONS PANEL SIZE: 9.20 in.2 TYPE SPECIFICATIONS: Points Style HI-PRO 48 Franklin Gothic Extra Condensed G 12 News Gothic Condensed NEW! ‘ " " High Protein- " " NUTRITIOUS " " BREAKFAST CEREAL 18 " NET WT. 8.6 oz. 14 Futura Bold , ‘3 N ,,‘ a I?! 2. PANEL SIZE: 15.00 in. TYPE SPECIFICATIONS: HI-PRO G NEW! High Protein NUTRITIOUS BREAKFAST CEREAL NET WT. 8.6 OZ. 31 FIGURE 3 1k 2# la Eh PANEL C 5 SPECIFICATIONS 2 Points tyle 60 Franklin Gothic Extra Condensed News Gothic Condensed Futura Bold } i 52 FIGURE 5 PANEL C NUTRITIOUS BREAKFAST CEREAL NET WT. 8.6 OZ. FIGURE 5 PANEL C High Protein NUTRITIOUS :BREAKFAST CEREAL NET WT. 8.6 OZ. l. 2. 33 SPECIFICfiTIONS PANEL SIZE: 15.01 in.2 TYPE SPECIFICATIONS: Points Style HI-PRO 60 Franklin Gothic Extra Condensed G 1# News Gothic Condensed NEW! N n High Protein " u NUTRITIOUS " n BREAKFAST CEREAL 24 " NET WT. 8.6 oz. . 24 Futura Bold 3h FIGURE # PANEL D High Protein NUTRITIOUS EBREAKFAST CEREAL : NE? WV. 6.6 ©Z. i L_....__._____.‘-HM..,,fi~, 6 “v-4“--6, ,, ,..‘-_ _, , 4;? l. PANEL SIZE: 40.80 In. 35 FIGURE 5 ,6 PANEL E L Ev SPECIFICATIONS 2 TYPE SPECIFICATIONS: Points HI-PRO G NEW! High Protein NUTRITIOUS BREAKFAST CEREAL NET WT. 8.6 oz. 96 2k 48 2h Style » Franklin Gothic Extra Condensed News Gothic Condensed Futura Bold High Protein NUTRITIOUS BREAKFASE CEB 6E NE? ‘W'E'. 8.: Z. I. o PANEL SIZE: 75.00 TYPE SPECIFICATIONS HI-PRO G NEW! High Protein NUTRITIOUS BREAKFAST CEREAL NET WT. 8.6 oz. PANEL F SPECIFICATIONS . 2 in. : Points Style 1 120 Franklin Gothic Extra Condensed 36 News Gothic Condensed H H H H H H 60 .. 24 Futura Bold 39 Each panel was positioned in a vertical plane BC inches from the observers' eyes, with the flat-grey area sur- rounding the display panel void of any distracting elements. Three General Electric 40-watt Cool White fluorescent bulbs provided an illumination level of 200 foot-candles for the area surrounding the panel (measured on a horizontal plane r. directly in front of the panel). Although most supermarkets' illumination levels are below 200 foot-candles, this is the level recommended by the Illuminating Engineering Society for . 9 i» self-service stores-~such as today's supermarket.l The subjects were college students with normal vision or corrected-to-normal vision with glasses. Fifteen different students viewed each display panel. Each student viewed only 225 panel. The subjects were told the study consisted of an evaluation of legibility factors for net weight statements on package primary display panels. They were informed they would be looking at a display panel of a package. They were fur- ther informed that the panel they would be viewing had no color nor illustration, but did have some design and the words one would normally expect to find on a package primary dis- play panel. The observers were positioned behind a shield with a slide opening, measuring 5" x 2", through which they were in- 19"Recommended Practice for Lighting Nerchandising Areas," Reprinted from Illuminating Engineering, June, 1963, p. In. #0 structed to view the panel. The slide opening was operated manually by the experimenter. With the subject positioned in front of the shield with his eyes directly in front of the slide opening, the slide was opened; and the subject was shown a blank panel the exact size of the display panel and posi- tioned exactly where the display panel under study would be positioned when he viewed it. The subject was instructed to adjust his line of vision to enable him to look directly at the panel when the slide was next opened. This pre-exposure was intended to reduce the subject's uncertainty of: (l) the size of the panel he would be viewing, and (2) the location of the panel behind the shield. The subjects were instructed to locate and to immedi- ately read aloud the net contents statement exactly as it ap- peared on the panel. For example, on the packages studied this statement appeared as ”NET WT. 8.6 OZ.” The subjects were instructed to read this as "Net weight eight point six ounces," or "Net weight eight and six-tenths ounces." If the subject omitted the words "Net weight," the time was not re- corded. The subjects were asked to locate and read the state- ment as rapidly as possible when the slide was drawn away from the opening in the shield. When the experimenter drew back the slide with one hand, he started the timer with the other; and immediately upon the verbal completion of the net Al contents statement by the subject, the experimenter stopped . 2O . . . . . the timer. This time (in minutes) for each subject for the respective panels is shown on the following pages. 20A GraLab micro-timer, manufactured by the Eeylan Stopwatch Co. of New York City, was employed. The timer was accurate to the nearest one-thousandth of a minute. The timer switch was a two-way switch, which the experimenter held in his hand when operating the instrument. 42 ThBLE 3 TIMES REQUIRED FOR SUBJECTS TO LOCATE AND READ THE KET WEIGHT STATEME'TS ON THE VARIOUS DISPLAY PANELS Panel A Panel B ‘ Panel c Subject Time Subject Time Subject Time 1 B .041 (min) 16 .0“? (min) 31 .048 (min) 2 .056 k 17 .075 52 .054 3 .042 18 .046 55 .061 4 .054 19 .064 34 .039 5 .054 20 .046 55 .062 6 .055 21 .050 56 .056 7 .060 22 .052 57 .059 8 .058 25 .045 58 .045~ 9 .054 24 .045 39 .047 10 .042 25 .058 40 ' .065 ' 11 .041 26 .046 41 .058 12 .061 27 .044 42 .060 15 .059 28 .044 45 .060 14 .060 29 .047 ' 44 .073 I 15 .056 50 .056 45 .064 43 TABLE 3—-Continued Panel D Panel E ‘ Panel F Subject Time Subject Time Subject Time 46 .064 (min) 61 .058 (min) 76 .042 (min) 47 .056 y 62 .055 ' 77‘ .041 48 .044 65 .048 78 .059 49 .055 64 .055 79 .058 50 .048 65 .046 80 .050 51 .050 66 .055 81 .047 52 .055 67 .039 82 '.060 53 '.047 68 .053 83 .043 54 .037 69 .045 84 .051 55 .055 70 .047 '85 .055 56 .049 71 .047 86 .047 57 .048 72 .047 87 .048 58 .044 73 .049 88 .051 59 .046 74 .047 B9 .058 60 .046 75 .041 90 .041 A summarization of these data is shown in TABLE 4. The times are the means of the fifteen subjects' times for each panel. 44 MEAN TIMES REQUIRED FOR SUBJECTS TO LOCATE AND READ THE NET WEIGHT STATEMENTS ON THE VARIOUS DISPLAY PANELS Panel Panel grea Time Type Sizea (In. ) (Min.) (In.) A 5.01 .047 1/8 B 9.20 .051 l/8 C 15.00 .057 1/8 D 15.01 .050. 3/16 E 40.80 .047 5/16 F 75.00 .049 , 3/16 aNet Weight Statement. Discussion of Results The reader will note that for the three display panels having 1/8" net weight statement type the time required to locate and read aloud the net weight statement increased from Panel A to Panel C. This was as expected because as all the other typographic matter became larger, it appeared rea- sonable that more effort would be required to find the rela- tively "smaller" net contents statement. It is interesting to note, however, when examining' the times required to locate and read the net contents state- ment on each of the three panel sizes having 3/16" net weight statement type, that this pattern does not exist. 45 Rather the shortest mean required time was for Panel B (40.80 . 2 g . p 1, i a , . 2. in. ). The second shortest time was .or Panel 2 (75.00 in. 1; and the longest time was for Panel D (15.01 in. The reason for this partial reversal of expected re- sults can probably be attributed to the difference in type size contrast between the net contents statement and the ad- Eh jacent words "BREAKFAST CEREAL." Because of the greater type : size contrast the net weight statement probably appeared more conspicuously, and thus was recognized sooner on the two larger panels. £5 The greatest time difference recorded within one group was between Panel A and Panel C. Between these two panel sizes there was a mean time difference of 0.01 minutes or 0.60 seconds. The remainder of the panel sizes, when con- trasted against other panels within their respective groups (i.e. 1/8" 93 3/16" type) or even against panels of the other group (where there existed a statement of contents type size difference), all yielded results within 0.004 minutes (0.24 sec.) of each other. Employing the statistical t-test21 to determine if these time differences were statistically significant at the 0.05 level of significance, the results shown in TABLE 5 were 21John E. Freund and Frank J. Williams, Nodern Busi- ness Statistics (Englewood Cliffs, N.J.: Prentice Hall, Inc., 1958), pp. 240-241. 46 obtained. TABLE 5 T-TEST RESULTS BETWEEN MEAN TIME FOR EACH PANEL STUDIED Panels A B C D E Panels B Not sig.a t=105l C Sig. Sig. t=3.33 t=2050 D Sig. t=3018 E Sig. t=2 030 F Not sig. Not sig. t=0.06 t=1.08 a"Significant." Four of the seven relationships did yield a statisti- cally significant time difference. The question which re- mained, however, was how significant were these absolute time differences in the practical sense. Based on the fore- going results, even when considering the statistically sig- nificant time differences between four of the panels, there was very little absolute difference in the time required for persons to locate and orally read the net weight statement on typographically identical display panels of varying scale, each having the same size type for the statement of contents. o 47 For it is most unlikely that a shopper would be consciously aware of a time difference no greater than 0.60 seconds when searching for a packaged food product‘s net weight.- Therefore, it was concluded that the Federal Food, Drug, and Cosmetic Act regulations (as proposed modified) regarding required statement of contents type size in re- lation to the area of the package principal display panel are fair and just to not only the consumer but also to the manufacturer of a product. It was clearly shown, in this instance, that the required type size—panel area relation- ships did not create significant differences in the ease with which a consumer could "obtain accurate information as to the quantity of contents" to enable him to easily and quickly determine the best price-value relationship for his money. Because no such difference existed, it was con- cluded that the regulations were indeed fair and just. 48 Placement of Contents Statement in Lower Twenty Per Cent of Display Panel Area General Discussion The second area of concern regarding the Fair Pack- aging and Labeling Act regulations and the Federal Food, Drug, and Cosmetic Act proposed modifications affecting net weight statements on consumer food packages was the required place- ment of the statement of contents in the lower 20% 0f the principal display panel area. Two questions were in need of _an answer: (1) was this requirement based on an already es- tablished pattern, and (2) could a person locate the statement quicker if it were positioned in the lower 20% of the panel area than if positioned elsewhere on the panel? The results of the in-store investigation (see pp. 24-25) indicated that there was a 1.9:1 ratio of packages having the statement in the lower portion of the panel (al- though not necessarily within the lower 29% of the panel area-- see p. 24) to those having it elsewhere on the panel. This indicated that the F&DA regulation was based, at least to some extent, on an already established consumer food package labeling pattern. Testing Procedure To more firmly substantiate this position, however, it was decided to perform additional visual testing. The pro- 49 cedure was identical to that employed in the analysis of Panels A-F. Fifteen students were used, none of whom had had previous exposure to the study or to the other display panels. Panel G was identical in copy elements and size to Panel E. The differences were the use of "4.3 OZ." instead of "8.6 OZ." in the net weight statement, and the placement of the elements. The "4.3" difference was due only to a problem of type supply. An exact replica--with specifications-~of the panel is found in FIGURE 7. The principal difference between Panel C and Panel E was that the typographic elements of Panel E were lowered a respective distance to enable placement of the net contents statement in the 22233 20% of the "new" panel. The words "BREAKFAST CEREAL" were moved to the upper portion of this panel to provide the same type size contrast with the net weight statement as existed on Panel E. The only other significant typographic difference was that on Panel G the trademark remained in the 20% of the panel area with the net weight statement. The trademark was not moved in order to more realistically represent a package display panel than if it had been repositioned in the lower area of the panel. It was felt that the proximity of the trademark alone would not affect the legibility of the net contents statement. 6 The time required for each subject to locate and read aloud the statement of contents can be seen in TABLE 6. 50 FIGURE 7 PANEL G SPECIFICATIONS Panel Size: 40.80 in.2 Type Specifications: Points Style, HI-PRO 96 Franklin Gothic Extra Condensed G 24 News Gothic Condensed NEW! vv n High Protein " " NUTRITIOUS " " BREAKFAST CEREAL 48 " NET WT. 4.3 OZ. 24 Futura Bold | c I u I NET WI. 6.3 oz. BREAKFAST Chen W "39/“ IE 3:1 J U High Protein L/ NUTRITIOUS NEW! 52 ('11-. hr 1'" 6 .LADLJZ'J TIMES REQUIRED FOR SUBJECTS TO LOCATE AND READ THE NET WEIGHT STATEMENT 0N PANEL G Subject . Time 1 .047 (min.) 2 .059 3 .058 4 » .047 5 ' -.045 6 .047 7 .044 8 .061 9 .060 10 .054 11 .041 12 .058 13 .044 14 .040 15 .049 Discussion of Results The mean time for the fifteen subjects was 0.050 min- utes. Employing the t-test earlier mentioned there was indi- cated a statistically significant time difference (t=2.5) be- tween Panel G and Panel E. However, the absolute required 53 time was 0.00} minutes (0.18 sec.) longer than the time re- quired for subjects to locate and read the statement on Panel E. This appeared to substantiate the position that there was a slight tendency on the part of the viewer to look near the bottOm of the display panel area when searching for the statement of contents. Again the question arose as to whether this absolute time difference was significant when considering the consumer in the market place. It is most unlikely that a shopper would be consciously aware of a time difference no greater than 0.18 seconds when searching for a packaged food product. How- ever, when considering the intent of the legislation--to en- able a shopper to easily and quickly determine the best price- value for her money--and the existing consumer food pac.age labeling pattern of placing the statement in the lower por- tion of the panel (see p. 24), it was concluded that this re- quirement of the legislation was also fair and just to not only the consumer but also to the manufacturer. These conclusions do not tend to support the senti- ments of Mr. Harry Schroeter, National Biscuit Company's vice president for packaging.. Mr. Schroeter was quoted as Hm' having said--regarding some of the type regulations-- The public may think we have a new brand called 'Net Weight'."22 22"Packagers Wait for the New Rules," Business Neck. May 13, 1967, p. 180. IV. CONCLUSIONS AND RECOMMENDATIONS It was not the intent of this author to consider the appropriateness or the need for the packaging legislation here- in discussed. Rather than assume a position on one side of this issue and attempt to gather all possible information to shore-up that position, the author attempted to determine the "fairness" of the legislation to not only the consumer but also to the manufacturer of a product. As discussed earlier, the two areas investigated were: (1) the minimum required type size for the statement of con- tents in relation to the area of the package principal dis- play panel, and (2) the required placement of the statement in the lower 20% of the display panel area. Through a proc- ess of visually analyzing seven package display panels, it was concluded that: I. Although there existed a statistically significant time difference for persons to locate and read the net weight statement on packages of different surface area (i.e. 15.01 sq. in. panel area vs. 75.00 sq. in. panel area), this time dif- ference was not significant when considering a shopp r in a supermarket looking for the net weight of a packaged product. [This indicated that, all other factors remaining constant (elements, layout, color, and size of type in relation to pan- ‘ Sh 55 e1 area), a consumer should find it no more difficult to lo- “ _ g. , ,. cate the net weight statement on the larger panel than on the smaller one within a respective group. Which conclusion tends to dilute the import of Mr. Schroeter's statement that "The public may think we have a new brand called 'Net Weight'."' For on none of the panels studied did the statement of con- tents attract initial attention due to exaggerated type size in relation to other elements on the panel. II. Placement of the contents statement in the lower 20% of the panel area proved to yield faster recognition by 'the subjects than when the statement was placed in the upper 20% of the panel area. Again the time difference was slight; but nonetheless the results did tend to support the In-Store Investigation finding that there was a greater percentage of M.- packages on the supermarket shelves today with the statement \W 4 ___ '_of contents positioned in the lower portion of the principal iE\h_flx_a~__~v£__wfl___x_afl~__:::::f,,,i_____~___ J display panel than in thefiuppgrtportioniiapprox. 2:1). There~ \M“‘ ..__i###- e- fore, it does not appear unreasonable to establish this re- quirement to assist the shopper to "easily and quickly deter- mine the best price-value relationship for his money." The discussion of legibility factors for printed material was presented to give the label designer some guid- 'ance in developing or utilizing type which by all evidence to date wOuld be considered."legible." There still exists, how- ever, the need to more precisely define the ' . WW- ___ f _ _ ambiguous area of \ _ . _.._. 56 typographic legibility. One of the specific needs in this area is to determine what brightnggsmgradient_diffgrg.tials __._ between the symbol andubackgroundflepnstitutefihgigtanct con- trast." Perhaps a minimum brightness gradient differential yielding "legible type" in "distinct contrast" could be estab- lished. More ideally, would be the establishing of a means to analyze agy package primary display panel graphic layout to determine if--in this case the net weight statement--was "legible," regardless of the colors employed, the size of the type utilized, or the location of the statement on the panel. One such means to accomplish this would be to assemble a great variety of packages that meet the present (and proposed) labeling requirements, and determine the ease with which a consumer could "obtain accurate information as to the quan- tity of the contents" (possibly based on a time factor similar to that utilized in this study). Such analysis would yield a range of times (effort) required to locate and read the statement. Using the minimum time value as a standard, a manufacturer could subject any display panel layout, regard- less of color, type size, or placement of the elements to analysis; and if it met the established minimum standard, the packqm would be acceptable. This is only one possible approach to the problem, and it obviously has some drawbacks, the major one being the means 57 whereby the government could effectively assure adherence to the minimum standard. The point to be made, however, is that there is more than one approach to regulating "deceptive pack- aging practices;" and investigation of alternative approaches should not be overlooked. VLIST OF REFERENCES LIST OF REFERENCES Public Documents U.S. Congress, Fair Packaging and Labeling Act. Public Law 89-755. 89th. Cong. s. 985, i966. U.S. Congress, Federal Foodi Drug, and Cosmetic Act, 21 CF: Part li Labels of Foods, Drugs, Devices, and Cos- metics (as proposed ammended by the Commissioner of Food and Drugs), "Proposed Rule Making," Federal Register, March 17, 1967. Books Freund, John E., and Williams, Frank J. Modern Business Sta- tistics. Englewood Cliffs, N.J.: Prentice Hall, Inc., 1958. Lewis, John. Typography: Basic Principals - Influences and Trends Since the 19th. Centugy. New York: Reinhold Publishing Corporation, l96h. Articles and Periodicals Berger, Curt. "Some EXperiments on the Width of Symbols as Determinant of Legibility," Acta Ophthalmologia, XXVI, l9h8. Burtt, Harold E., and Basch, Coryne. "The Legibility of Eo- doni, Baskerville Roman, and Cheltenham Type Faces," Journal of Applied Psychology, VII, 1923. "Consumer: King or Vassal of the Economy?" Senior Scholastic, February 10, 1967. English, Earl. "Study of Readability of Four Newspaper Head- . line Types," Journalism Quarterly, XXI, 1944. "Packagers Wait for the New Rules,” Business week, may 13, 1967. Preston, Katherine, and Schwankl, Howard P., and Tinker, Miles 59 60 A. "The Effect of Variations in Color of Print and Background on Legibility," Journal of General Psy— choIOEz, VI, 1932. "Recommended Practice for Lighting Merchandising Areas," Re- printed from Illuminating Engineering, June, 1963. Sanford, E.C. "The Relative Legibility of the Small Letters," American Journal of Psychology, I, 1888. Tinker, Kiles A. "The Relative Legibility of the Letters, the Digits, and of Certain Mathematical Signs,“ Jour- nal of General Psychology, I, 1928. Reports Baker, Charles A., and Grether, Walter, F. "Visual Presenta- tion of Information," WADC Technical Report 54-160. United States Air Force, Wright Air Development Cen- ter, August, 1954. Crook, M.N., Hanson, J.A., and Weisz, A. "The Legibility of Type as a Function of Stroke Width, Letter Width, and Letter Spacing Under Low Illumination,” WADC Technical Report 53-440. United States Air Force, Wright Air Development Center (Submitted to Aero Medical Labo- ratory, March, 1954). Crook, Mason N., Hanson, J.A., and Weisz, A.. ”The Legibility of Type as Determined by the Combined Effects of Typographical Variables and Reflectance of Background," WADC Technical Repprt 53-hhl. United States Air Force, wright Air Development Center, March, 1954. Dunlap, K. Report of the Highway Research Board. National Research Council, Division Office, 1932. Other Sources "Typography," Webster's New International Dictionary: Springfield, Mass.: G&C Merriam Co., 1957. APPENDIXES ‘APPENDIX I DEFINITION OF TERMS For purposes of clarification of some of the terms in this paper the following list of definitions is provided: 1.» 5. 6. 7. BOLDFACE TYPE: type having a heavy face. CAPS (UPPER CASE): capital letters (A,B,C, etc.).. CONSUMER PRODUCTS (COMMODITY): any food, drug, device, or cosmetic (as those terms are defined by the Federal Food, Drug, and Cosmetic Act), and any other article, product, or commodity of any kind or class which is customarily produced or distributed for sale through retail sales agencies or instrumentalities for consumption by individuals or use by individuals for purposes of personal care or in the performance of services ordinarily rendered within the household, and which usually is consumed or expended in the course of such consumption or use. (Fair Packaging and La- beling Act p. 5). FOOT-CANDLE: unit of illumination. LOWER CASE: non-capital letters (a,b,c, etc.). PRINCIPAL DISPLAY PANEL: that part of a label that is most likely to be displayed, presented, shown or examined under normal and customary conditions of display for retail sale. (Fair Packaging and Label- ing Act p. 6). TACHISTOSCOPE: an instrument which presents an image in brief flashes of equal or increasing duration. After each flash the respondent describes what was seen. TYPEFACE: the complete dimensional and configurational characteristics of a set of letters.or digits as specified by the original designer. Some of the de- tails might vary among different point sizes. 62 APPENDIX II VISUAL TESTING BIBLIOGRAPHY 7“ Books Handbook of Human Engineering Data for Design Engineers. Tufts College, l9h9. McCormick, E.J. Human Engineering. New York: McGraw Hill, 1957. Patterson, D.G., and Tinker, M.A. How to Make Type Readable. New York: Harper & Bros., 19HO. Stevens, S.S. (Ed.) Handbook of Experimental Psychology. New York: Wiley & Sons, Inc., 1951. Woodson, W.E. Human Engineering Guide for Equipment Designers. Berkley: University of California Press, 195k. Articles and Periodicals Baird, J.W. "The Legibility of a Telephone Directory," Jour- nal of Applied Psychology, I (1917) pp. 30-37. Berger, Curt. "Experiments on the Legibility of Symbols of Different Width and Height," Acta Ophthalmoloaia, XXVIII (1950) pp. 423-434. Berger, Curt. "Grouping, Number, and Spacing of Letters as Determinants of Word Recognition," Journal of General Psychology. Lv (1956) pp. 215-228. Berger, Curt. "Some Experiments on the Width of Symbols as Determinant of Legibility," Acta Ophthalmologia, XXVI (19“8) PP- 517-550- Berger, Curt. ”Stroke Width, Form & Horizontal Spacing of Numerals as Determinants of the Threshold of Recog- nition," Journal of Applied Psychology, XXVIII, (1944) pp. 536-546. - Berger, Curt. "The Influence of Stroke Width Upon Legibil- ity," Acta Ophthalmologia, XXX (1952) pp. 409-A20. 63 64 Breland, Keller, and Breland, Marion. 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