As of February 28, 2006, the Agency is requesting that electronic submission of CRP protocol test data made available to Agency per PR Notice 97-9 be submitted on a CD-R rather than a 3.5-inch floppy disk (per PR Notice 97-9). This change to a CD-R is necessary because the Agency is replacing the 3.5-inch floppy disk drives with CD/DVD readers on its computers. Any questions not covered in PR Notice 97-9 should be addressed to Rosalind L. Gross by telephone at (703) 308-7368, fax (703) 308-9382, or e-mail Gross.Rosalind@epa.gov.
To protect children from poisonings around the home, the law requires that certain household pesticides be in child-resistant packaging (Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) section 25 (c)(3), (PDF, 743KB, 106 pages, About PDF)). EPA's pesticide regulations for Child-Resistant Packaging (CRP) are located at 40 CFR 157 subpart B.
Does your pesticide product require Child-Resistant Packaging (CRP)?
If a pesticide product triggers the CRP toxicity criteria and is used in a residential setting, then it is subject to CRP. A pesticide product triggers the CRP toxicity criteria when, based upon testing with an appropriate test species, it meets anyone of the following:
- Acute oral LD50 of 1.5 g/kg or less;
- Acute dermal LD50 of 2000 mg/kg or less;
- Acute inhalation LC50 of 2 mg/ liter or less;
- Is corrosive to the eye (causes irreversible destruction of ocular tissue) or causes corneal involvement or irritation persisting for 21 days or more;
- Is corrosive to the skin (causes tissue destruction into the dermis and/or scarring) or causes severe skin irritation (severe erythema or edema) at 72 hours; or
- The pesticide or device has such characteristics that, based upon human toxicological data, use history, accident data or such other evidence as is available, the Agency determines there is serious hazard of accidental injury or illness which child-resistant packaging could reduce.
What is necessary if your product requires CRP?
- Certify to CRP per 40 CFR 157.34 and PR Notice 96-2
- Comply with the CRP Standards per 40 CFR 157.32 – Effectiveness Standard - CRP tested by the protocol in 16 CFR 1700.20 shall meet the effectiveness specifications in 16 CFR 1700.15(b); Compatibility Standard; Durability Standard
- Recordkeeping per 40 CFR 157.36
Some frequently asked questions and answers:
- What is CRP?
CRP is defined in 40 CFR 157.21(b) as packaging that is designed and constructed to be significantly difficult for children under 5 years of age to open or obtain a toxic or harmful amount of the substance contained therein within a reasonable time, and that is not difficult for normal adults to use properly.
- Can CRP be voluntarily used?
Yes, per 40 CFR 157.30, but all the requirements for CRP must be met.
- What happens if I want to change the CRP?
You must submit to EPA an application to amend the product registration and you must submit a new CRP certification.
- What CRP does EPA require for unit dose packaging?
The CRP generally may be either the outer retail package or the individual unit package. However, prefilled, nonrefillable insecticide bait stations not designed or intended to be opened or activated in a manner that exposes the contents to human contact must be in CRP rather than the outer package (PR 97-9).
- What does “opened” in the Senior Adult Use Effectiveness (SAUE) mean to EPA?
EPA will consider a package successfully “opened” in SAUE testing only if the contents of the package can be removed in a condition suitable for their intended use, and the process of opening and removing the contents would not result in significant exposure to the pesticide.
Submitting Data Electronically
EPA requests that CRP protocol test data be made available to Agency on a CD-R rather than a 3.5-inch floppy disk (per PR Notice 97-9), as the Agency is replacing the 3.5-inch floppy disk drives with CD/DVD readers on its computers. Any questions not covered in PR Notice 97-9 should be addressed to Rosalind L. Gross by telephone at (703) 308-7368, fax (703) 308-9382, or e-mail Gross.Rosalind@epa.gov.
Quick Reference Guide to Child-Resistant Packaging
This Quick Reference Guide to Child-Resistant Packaging is intended for use by pesticide registrants, product manufacturers, and others who are legally required to meet the EPA standards for child-resistant packaging of pesticide products. It describes various types of child-resistant packaging, along with their photographs, and how to obtain them.
You may search for a child-resistant package by one of the following indices, each of which contains the child-resistant packaging descriptions and photographs:
- ASTM Type
(1) The ASTM Type Index lists the various packages by their ASTM classification of the package type (e.g. reclosable packaging – continuous thread closure). Once a particular package is chosen, the user should click on the package name to view the package description and photographs. Users who are not familiar with the ASTM classification of CRP should use one of the other three indices to locate the package.
- CRP Manufacturer
The CRP Manufacturer Index lists the various packages alphabetically by their manufacturer. Once a particular package is chosen, the user should click on the package name to view the package description and photographs.
- Package ASTM type (e.g. aerosol overcap)
The Package ASTM Type Index lists the various packages alphabetically by their package type with a secondary sort by their ASTM type. Once a particular package is chosen, the user should click on the package name to view the package description and photographs.
- Package Manufacturer Type (e.g. aerosol overcap)
The Package Manufacturer Type Index lists the various packages alphabetically by their package type with a secondary sort by CRP manufacturer. Once a particular package is chosen, the user should click on the package name to view the package description and photographs.
In addition to the CRP indices, three additional lists are provided:
- CRP Manufacturers - contact information for questions concerning specific child-resistant packaging
- CRP Testing Firms - contact information for package testing to ascertain if a package is child-resistant, and thus be included in the guide
- CRP Consultants - contact information for consultants with experience in child-resistant packaging
The ASTM classifications are extracted, with permission, from D3475-12, Standard Classification of Child-Resistant Packages, copyrighted:
100 Barr Harbor Drive
West Conshohocken, PA 19428-2959
Copies of the complete standard may be purchased from ASTM International (telephone: 610-832-9585, fax: 610-832-9555, e-mail: firstname.lastname@example.org, Web site: www.astm.org.
If an error or omission is found in the CRP guide, list of CRP consultants, list of CRP manufacturers, or list of CRP testing firms, please notify EPA in writing. Describe the error, list what corrections are necessary, and state why. Additionally, please note that, for inclusion in the CRP guide, two samples of the entire CRP along with the manufacturer's permission are required. Corrections and/or additions to the list of CRP consultants, the list of CRP manufacturers, the list of CRP testing firms, or the CRP guide must be verified with the company involved before any action is taken. Please address corrections for EPA to:
Attention: Rosalind L. Gross
Environmental Protection Agency
Office of Pesticide Programs (7505P)
1200 Pennsylvania Ave., N.W.
Washington, DC 20460
Note: This guide is a joint undertaking of the U.S. Consumer Product Safety Commission (CPSC) and EPA. Non-pesticidal products requiring child-resistant packaging are under the jurisdiction of the CPSC. A version of this guide is also posted on CPSC's Web site at www.cpsc.gov. The CPSC maintains its own lists of CRP consultants, CRP manufacturers, and CRP testing firms. Please address corrections to the CPSC list to:
Attention: Gregory K. Rea
Directorate for Laboratory Sciences
U.S. Consumer Product Safety Commission
National Product Testing and Evaluation Center
5 Research Place
Rockville, MD 20850