As a mother of 2, I am grateful for the laws that require household products to have child-resistant packaging. Unlike most 4-year-olds, my daughter loves to help clean the bathroom. But like most 4-year-olds, she loves to use the spray bottle.
Child resistant packaging can be cumbersome, and until I had children I didn’t understand its importance. I would not hesitate to make cynical remarks about politicians and “how they try to control everything.”
Although it may not always seem like it, lawmakers have good reason for child-resistant packaging. Products that are required to use child-resistant packaging and labeling include products and substances that have the potential to poison children. For this reason, Federal law requires these items to be specially packaged to help prevent that from happening.
This law is known as the Poison Prevention Packaging Act, administered by the Federal Consumer Product Safety Commission (CPSC). CPSC is tasked with protecting the public from unreasonable risks of injury and death from consumer products.
The law defines this kind of packaging as “packaging that is designed or constructed to be significantly difficult for children under five years of age to open or obtain a toxic or harmful amount of the substance contained therein within a reasonable time.” However, the law contains a caveat that it “does not mean packaging which all such children cannot open or obtain a toxic or harmful amount within a reasonable time.”
According to the Consumer Healthcare Products Association (CHPA), Child-Resistant (or C-R) packaging must meet a number of performance specifications outlined in 16 CFR §1700.15. Information regarding performance specifications is available at the CPSC website.
Products are tested with panels of 50 children (42-51 months) are tested sequentially following division into three age categories . Children are instructed on how to open the package and are given 10 minutes to try. They are also permitted to use their teeth. The parameters required for passing the C-R test are outlined in 16 CFR § 1700.20(a)(2)(iii). If test results are inconclusive, additional testing involving one or more groups of 50 children each is required. A maximum of 200 children may be tested. Still, to meet the requirements packaging must only be inaccessible to 85% of participants of the study. This means that approximately 15% of children can still open child-resistant packaging within a few minutes.
Requirements for this type of packaging also test adult ability to open the packages. In fact, 90% of adults must be able to access its contents before the packaging is approved. Since child-resistant packaging can also end up inadvertently becoming ‘elderly-resistant’ or ‘disabled-resistant’, pharmacies are permitted to sell medications without the child-resistant packaging, provided that no children reside in the home where the medication is kept.
Despite best efforts, child-resistant packaging is never “child proof.” Many of the calls received by the Poison Control Center every year are the result of children accidentally ingesting pharmaceuticals, including those in child-resistant packaging. Pharmaceutical companies are urged to think of their packaging as a ‘last defense’ – not a ‘first defense’ – and continue to educate their customers on proper care and storage of medications as well as the potential dangers that can occur with improper usage of their pharmaceuticals.