Stephen Lee Compliance Officer, Chemical Hazards Team

The views expressed in this presentation are those of the CPSC staff, have not been reviewed or approved by, and may not necessarily reflect the views of, the Commission.

Child Test

Senior-Adult Test

Adult-Resecuring Test

Additional Information

Frequently Asked Questions

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Test specified at 16 CFR § 1700.20(a)(2)

Panels of 50 children, up to 4 panels Age range: 42-51 months old ◦ 30% from 42 to 44 months ◦ 40% from 45 to 48 months ◦ 30% from 49 to 51 months

Panel make-up: 50% girls, 50% boys Tester restriction: 30% of children per tester Site restriction: 20% of children per site

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Children tested in pairs ◦ Testing must be done in a location that is familiar

to the children

5 minutes to open package

If unopened within 5 minutes, demonstration provided by tester

Additional 5 minutes to open package after demo ◦ Children instructed they may use their teeth

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Failure is defined as child opening package or gaining access to its contents through ANY means.

Test Panel

Cumulative # of Children

Packaging Openings First 5 Minutes Full 10 Minutes

Pass Continue Fail Pass Continue Fail 1 50 0-3 4-10 11+ 0-5 6-14 15+ 2 100 4-10 11-18 19+ 6-15 16-24 25+ 3 150 11-18 19-25 26+ 16-25 26-34 35+ 4 200 19-30 -------- 31+ 26-40 ------- 41+

Table specified at 16 CFR § 1700.20(a)(2)(iii)

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Test specified at 16 CFR § 1700.20(a)(3)

100 adult panel Age range: 50 to 70 years old ◦ 25% from 50 to 54 years ◦ 25% from 55 to 59 years ◦ 50% from 60 to 70 years

Panel make-up: 70% women, 30% men Tester restriction: 35% of adults per tester Site restriction: 24% of adults per site

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Consent form 5 minutes to open and reclose first package 1 minute to open and reclose second,

identical package Screening procedure if adult cannot open

package ◦ Give participant 2 non-CR packages to try to open ◦ Allow 1 minute to open and close each package ◦ If adults cannot complete both tasks, results of

their test is not included in the panel

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Test specified at 16 CFR § 1700.20(d)(2)

Required when an objective determination (visual or mechanical) that a package is properly resecured cannot be made

Packages that have been opened and appear to be resecured by adults from Senior Test are used and given to children to open ◦ Follow test instructions outlined in Child Test

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Children ◦ Packages are presented in the form in which they

will enter or be stored in the home ◦ Tools only provided if included with the packaging

Seniors ◦ Any required tools ◦ Provide only instructions on how to open and

properly resecure the package as it will appear on or accompany the package in the manner that it is delivered to the consumer

Worst-case scenario should be simulated

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16 CFR § 1700.15(a)

Substance that is packaged must not compromise or interfere with the function of the special packaging

Special packaging is required to continue to function so that it meets the PPPA effectiveness specifications for the life of the product

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If the packages are of the same material, but different sizes, multiple testing may be required ◦ Bracket testing for different closure/bottle size

If the packages use the same closure, but the bottles are different materials, testing both packages is necessary ◦ Plastic and glass bottles using the same closure

require two separate tests

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There are no provisions in the law or in the regulations that restrict who can perform the testing.

Testing is valid as long as the protocols outlined in 16 CFR § 1700.20 are followed.

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Change in the package manufacture ◦ Change in raw package materials ◦ Change in manufacturing process ◦ Developing/designing new package

Using a tested closure on a new or different bottle

When you receive incident reports or complaints

When you become aware of a manufacturing or materials defect

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