Child Resistant

Package Testing

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Information resource for the testing, classification,
and regulation of child resistant products

Product Types, Protocols, & Regulations

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Packages

Summary of Regulations

In order for a package to be considered child resistant, it must be tested with children ages 42-51 months using the protocol detailed in 16 CFR 1700.  Testing is performed to ensure that young children are unable to access potentially dangerous substances.  Each package is tested with at least 50 children (and a maximum of 200 children) to determine the effectiveness of the package.

In addition, the package must also be tested with senior adults (ages 50-70 years) to make sure it is not too difficult to use.  For this portion of testing, at least 90% of the adults tested must be able to successfully open and, if applicable, re-close the package two sequential times within the allotted test periods.

Summary of Testing Protocol

A full description of the package testing protocol summarized below is in 16 CFR 1700.

Child Testing Protocol

  • Each test is made up of 1 to 4 panels of 50 children between the ages of 42 and 51 months.
  • Panels are divided into 3 groups according to age:
  • 30% between the ages of 42 and 44 months
  • 40% between the ages of 45 and 48 months
  • 30% between the ages of 49 and 51 months
  • The number of boys and the number of girls in each group must be approximately 50%/50% (regulation allows for +/-10% variation).
  • No more than 20% of the children in each group may be obtained or tested at a single site.
  • All children must be healthy with no disabilities or injuries that could potentially affect their ability to test the package.
  • Each child may test up to two package types. If a child tests two packages, the packages must be different designs.
  • Children are tested in pairs in a room that is well-lit, free of distractions, and is familiar to them, or in a central location in which they feel comfortable, by a tester who administers the test to no more than 30% of the sample.
  • To begin, the tester gives each child a package containing a placebo and asks them to try to open it without any instruction. Each child has 5 minutes to try to open the package. The tester uses a stopwatch to document the amount of time it takes for the child to open the package.
  • If a child opens the package, the test is counted as a failure and he or she is not tested further. If the second child has not been able to open the package successfully at this point, they are allowed to continue for the remainder of the allotted test period.
  • If a child (or children) does not open the package within the allotted 5 minutes, the tester demonstrates how to open the package and mentions that it is okay for them to use their teeth (if they have not done so already). The child is then given an additional 5 minutes to try to open the package. If the child is able to open the package within this period, this is also counted as a failure.

    Pass/Fail Criteria:

  • A test is determined a failure if a child opens or gains access to the contents of the package.
  • For a package to pass in the first panel of 50 children, three or fewer must be able to open the package during the first 5 minutes (before the tester demonstrates how to open the package), and 5 or fewer during the second 5 minutes (after the demonstration). Conversely, if 11 or more children open the package in the first 5 minutes, or if 15 or more open the package within the full 10 minutes, the package fails. In both cases, no further testing is necessary.
  • In the first panel of 50 children, if 6-14 open the package within the allotted 10 minutes, a second panel of 50 children must be tested. Depending upon the results of the second round of testing, the package may pass, fail, or require another panel. Testing stops after the 4th panel regardless of the passing rate.

Senior Adult Testing Protocol

  • For this test, one panel of 100 senior adults between the ages of 50 and 70 years old is used.  Each participant is required to sign a consent form prior to testing.
  • Panels are divided into 3 groups according to age:
  • 25% between the ages of 50 and 54 years
  • 25% between the ages of 55 and 59 years
  • 50% between the ages of 60 and 70 years
  • 70% of those in each age group must be female.
  • No more than 24% of participants may be obtained or tested at a single site.
  • Participants must have no obvious physical or mental disabilities.
  • Each adult is tested individually by a tester who administers the test to no more than 35% of the sample.
  • To begin, the tester gives the participant a package with printed instructions (instructions may be on the package or accompany it on a sheet of paper). The participant is allotted 5 minutes to open and, if applicable, re-close the package correctly. The tester uses a stopwatch to document the amount of time it takes for the participant to open and re-close the packages.
  • If the participant is able to open/close the package within this time period, he or she must be able to do so a second time with another identical package during a subsequent 1 minute time period.
  • If a participant is unable to open the first package in the allotted 5 minutes, he/she is asked to open and, if applicable, close two non-child-resistant packages. The participant is allotted 1 minute per package. Those who are unable to open/close the non-child-resistant packages are excluded from the panel and replaced by additional participants.

Pass/Fail Criteria:

  • A test is determined a failure if the adult is unable to open or gain access to the contents of the package.
  • For a package to pass, at least 90% of the adults tested must be able to properly open and close the package during the first 5 minutes and open and close the package again in the subsequent 1 minute.those 

Summary of ASTM D3475-17

Child resistant packages are classified according to thirteen types.  These classifications are defined based on the specific motion, skill, or tool required to open a particular package.  Detailed descriptions and examples of each type and sub-type are in ASTM D3475-17.

  1. Reclosable Packaging – Continuous Thread Closure
  2. Reclosable Packaging – Lug Finish Closure
  3. Reclosable Packaging – Snap Closure
  4. Unit Non-Reclosable Packaging – Flexible (strip/pouch)
  5. Unit Non-Reclosable Packaging – Rigid
  6. Unit Reclosable Package
  7. Aerosol Packages
  8. Non-Reclosable Packaging – Semi-Rigid (blister)
  9. Dispensers (not intended to be removed)
  10. Box or Tray Package
  11. Reclosable Packaging – Flexible
  12. Dispenser (may be removed)
  13. Reclosable Packaging – Semi-Rigid (blister)

Links & Documents

16 CFR 1700 – Standard for Packaging used by CPSC

ASTM D3475-17 – Standard Classification of Child-Resistant Packages

ISO 8317 – International Standard for Reclosable Packaging

ISO 14375 – International Standard for Non-reclosable Pharmaceutical Packaging                 

EN 862 – International Standard for Non-reclosable Non-Pharmaceutical Packaging   

 

Lighters

Summary of Regulations

Safety regulations for lighters fall into two categories: cigarette lighters, which includes disposable and novelty lighters, and multi-purpose lighters.  These regulations refer to flame-producing products that operate on fuel and do not include matches.  

Cigarette lighters are intended to ignite cigarettes, cigars, and pipes, although it may be used to light other materials as well. A disposable lighter is one that uses a gas such as butane, isobutane, propane, or another form of liquefied hydrocarbon under pressure and cannot be refilled.  These lighters typically have a Customs Valuation or ex-factory price of under $2.25 (this price is adjusted every 5 years to the nearest $0.25).  A novelty lighter refers to lighters that have visual and/or audio features that might make them appealing to a child under 5 years of age.  These lighters depict or resemble things such as cartoon characters, toys, guns, watches, musical instruments, vehicles, animals, food, or beverages, and may also produce sound or feature flashing lights.  Novelty lighters can operate on any fuel, including butane and liquid fuel.  

A multi-purpose lighter is typically used to light items such as candles, fireplaces, grills, camp fires or stoves, lanterns, and pilot lights, or for other applications such as soldering or brazing.  These lighters also operate on fuel and use an ignition mechanism.

In order for a cigarette or multi-purpose lighter to be considered child resistant, at least 85% of the children tested must be unable to successfully operate the lighter.

To ensure safety while testing lighters with children, surrogate lighters are used.  A surrogate lighter has the same function, size, weight, and appearance as a real lighter, but it does not contain fuel.  Instead of igniting, the surrogate lighter will produce a sound or visual signal to let the tester know that it was operated correctly and would have caused a real lighter to produce a flame.    

Summary of Testing Protocol

A full description of the cigarette and multi-purpose lighter testing protocol summarized below and additional manufacturer requirements can be found in 16 CFR 1210 and 16 CFR 1212.

Child Testing Protocol

  • Each test is made up of 1 to 2 panels of 100 children between the ages of 42 and 51 months.
  • Panels are divided into 3 groups according to age:
  • 30% between the ages of 42 and 44 months
  • 40% between the ages of 45 and 48 months
  • 30% between the ages of 49 and 51 months
  • Approximately 2/3 of the children in each of the age groups must be boys.
  • All children must be healthy with no disabilities or injuries that could potentially affect their ability to test the lighter.
  • Children may not participate in both cigarette and multi-purpose lighter testing or package testing in the same day.
  • Children are tested in pairs in a room that is well-lit, free of distractions, and is familiar to them, or in a central location in which they feel comfortable, by a tester who administers the test to no more than 20% of the sample.
  • To begin, the tester operates a surrogate lighter in the presence of the children who are to be tested without letting them see how it was operated so they will know what sound or visual signal the lighter makes when operated correctly.  Each child is then given a surrogate lighter and asked to try to make the same sound or visual signal.  The children are allotted 5 minutes to try to operate the lighter correctly.  The tester uses a stopwatch to keep track of the time.
  • If a child is able to operate the lighter successfully, the test is counted as a failure and he or she is not tested further.  If the second child has not been able to operate the lighter successfully at this point, they are allowed to continue for the remainder of the allotted test period.
  • If a child (or children) is unable to correctly operate the lighter within the allotted 5 minutes, the tester demonstrates how to do so.  The child is then given an additional 5 minutes to try again.  If the child is able to operate the lighter within this period, this is also counted as a failure.

Pass/Fail Criteria:

  • A test is determined a failure if the child is able to produce the sound or visual signal by correctly operating the surrogate lighter.
  • For a lighter to pass in the first panel of 100 children, 10 or fewer must have been able to operate the surrogate lighter.  Conversely, if 19 or more children operate the surrogate lighter successfully, the lighter fails.  In both cases, no further testing is necessary.
  • In the first panel of 100 children, if 11-18 operate the surrogate lighter successfully, a second panel of 100 children must be tested.  In the event that the second panel is tested, the lighter fails if 31 or more of the 200 children tested are able to operate the surrogate lighter successfully.

Links & Documents

Lighter Application – https://www.cpsc.gov/cgibin/lighterstart/
Lighter Application User Guide – https://www.cpsc.gov/cgibin/lighterstart/LighterSubmissionUserGuide.pdf
CPSC Notice Re: Multi-Purpose Lighters – Extension of Approval of Information 
16 CFR 1210 – Safety Standard for Cigarette Lighters
16 CFR 1212 – Safety Standard for Multi-Purpose Lighters
EN 13869 – International Standard for Lighters

Additional Contact Information

Address to send surrogate lighters and production units (without fuel):

Joseph F. Williams
U.S. Consumer Product Safety Commission
Office of Compliance and Field Operations
4330 East West Highway
Bethesda, MD 20814

CPSC Contact:

Joseph F. Williams
Compliance Officer – Division of Regulatory Enforcement
U.S. Consumer Product Safety Commission/Office of Compliance and Field Operations
JFWilliams@cpsc.gov www.cpsc.gov

fuel
containers

Summary of Regulations

Fuel containers and closing components must first meet the requirements outlined in CARB CP-501, TP-501, TP-502, and EPA regulation 40 CFR 59.623.

Prior to testing, each container must be subjected to:

  • Low temperature exposure (0°F or -17.8°C) for 8 hours
  • High temperature exposure (140°F or 60°C) for 8 hours
  • 250 opening and closing cycles
  • Inspection to ensure that there are no leaks or damage to the container

In order for a fuel container to be considered child resistant, it must be tested with children ages 42-51 months according to the protocol detailed in ASTM F2517.  Testing is performed to ensure that young children are unable to access potentially dangerous substances.  Each container is tested with a minimum of 50 children and a maximum of 200 children to determine the effectiveness of the container and the closures on the container (see Summary of Testing Protocol for further details).

Conversely, the container and its closures must also be tested with adults (ages 18-70 years) to make sure it is not too difficult for them to use.  For this portion of testing, at least 90% of the adults tested must be able to successfully open and re-close all of the closures and use the fuel container two sequential times within the allotted test period.

Summary of Testing Protocol

A full description of the fuel container testing protocol summarized below can be found in ASTM F2517.

Child Testing Protocol

  • A child panel is needed for each closure.
  • Each test is made up of 1 to 4 panels of 50 children between the ages of 42 and 51 months.
  • Panels are divided into 3 groups according to age:
  • 30% between the ages of 42 and 44 months
  • 40% between the ages of 45 and 48 months
  • 30% between the ages of 49 and 51 months
  • The number of boys and the number of girls in each group must be approximately 50%/50% (regulation allows for +/-10% variation).
  • No more than 20% of the children may be from a single test site.
  • All children must be healthy with no disabilities or injuries that could potentially affect their ability to test the container.
  • Each child may test up to two containers.  If a child tests two containers, the containers must have different closure types.
  • Children are tested in pairs in a room that is well-lit, free of distractions, and is familiar to them, or in a central location in which they feel comfortable, by a tester who administers the test to no more than 30% of the sample.
  • To begin, the tester gives each child a container that is one-quarter full of water and asks them to try to open it without any instruction.  Each child has 5 minutes to try to open the container.  The tester uses a stopwatch to document the amount of time it takes for the child to open the container.
  • If a child opens the container, the test is counted as a failure and he or she is not tested further.  If the second child has not been able to open the container successfully at this point, they are allowed to continue for the remainder of the allotted test period.
  • If a child (or children) does not open the container within the allotted 5 minutes, the tester demonstrates how to open the container.  The child is then given an additional 5 minutes to try to open the container.  If the child is able to open the container within this period, this is also counted as a failure.  Each closure is tested with a panel of children.

Pass/Fail Criteria:

  • A test is determined a failure if a child is able to access the liquid in the container through any of the openings, whether the opening procedure was demonstrated to the child or not.
  • For a container to pass in the first panel of 50 children, three or fewer must be able to open the container during the first 5 minutes (before the tester demonstration), and 5 or fewer during the second 5 minutes (after the demonstration).  Conversely, if 11 or more children open the container in the first 5 minutes, or if 15 or more open the container within the full 10 minutes, the container fails.  In both cases, no further testing is necessary.
  • In the first panel of 50 children, if 6-14 open the container within the allotted 10 minutes, a second panel of 50 children must be tested.  Depending upon the results of the second round of testing, the container may pass, fail, or require another panel.  Testing stops after the 4th panel regardless of the passing rate.

Senior Adult Testing Protocol

  • For this test, one panel of 100 adults between the ages of 18 and 70 years old is used.  Each participant is required to read and sign a consent form and attest to having used a gas can in the preceding two years.
  • Panels are divided into 3 groups according to age:
  • No more than 20% of the adults may be from a single ZIP code, city, or town to allow for geographical diversity.
  • Participants must have no obvious physical or mental disabilities.
  • Each adult is tested individually by a tester who administers the test to no more than 35% of the sample.
  • To begin, the tester gives the participant a container that is filled 15% to 35% of its rated capacity with water, the closures are secured, and have been inverted to check for leakage.  At any time during the test, an adult test panel participant is allowed to consult instructions provided with the container and digitally available as indicated on the container. The participant is allotted 5 minutes to open and re-close all of the closures on the container correctly. The tester uses a stopwatch to document the amount of time it takes for the participant to open and re-close the container.
  • If the participant is able to open and close all of the closures on the container within this time period, he or she must be able to do so a second time with another identical container during a subsequent 1 minute dispensing closure phase; and ending with a 1 minute filling closure phase.  In each phase the participant is given tasks to complete.
  • If a participant is unable to open the first container in the allotted 5 minutes, he/she is asked to open and close two non-child-resistant containers. The participant is allotted 1 minute per container. Those who are unable to open/close the non-child-resistant containers are excluded from the panel and replaced by additional participants.

Pass/Fail Criteria:

  • A test is determined a failure if the adult is unable to open and reclose all of the closures on the container within the allotted test period.
  • For a container to pass, at least 90% of the adults tested must be able to properly open and re-close the container during the first 5 minutes and open and close the container again in the subsequent 1 minute dispensing closure phase; and 1 minute closure phase.filled 

Links & Documents

ASTM F2517 – Standard Specification for Determination of Child Resistance of Portable Fuel Containers for Consumer Use
16 CFR 1500 – Federal Hazardous Substance Act
CARB CP-501 – Certification Procedure for Portable Fuel Container Systems
CARB TP-501 – Test Procedure for Determining Integrity of Portable Fuel Container Systems
CARB TP-502 – Test Procedure for Determining Diurnal Emissions of Portable Fuel Container Systems
EPA 40 CRF 59.623 – What Must I Include in My Application?

Pesticides & bait stations

Summary of Regulations

In order for a bait station to be considered child resistant, it must be tested with children ages 42-51 months using to the protocol detailed in 16 CFR 1700.  Testing is performed to ensure that young children are unable to access potentially dangerous substances.  Each bait station is tested with at least 50 children (and a maximum of 200 children) to determine the effectiveness of the station.

The child-resistant packaging used for bait stations must meet the following standards:

  • Effectiveness Standard  Packaging must be tested according to the requirements detailed in 16 CFR 1700.
  • Compatibility Standard  Packaging must remain effective when the bait station/pesticide when is in active use.
  • Durability Standard  Packaging must be able to meet the effectiveness and compatibility standards throughout the expected lifetime of the product.

These standards apply to pesticides that are labeled for, or can be reasonably interpreted as being labeled for, residential use and meet the following toxicity criterion:

  • Acute oral LD50 of 1.5g/kg or less
  • Acute dermal LD50 of 2,000mg/kg or less
  • Acute inhalation LC50 of 2mg/L or less

Products that are specifically classified for restricted use and products packaged in large sizes are exempt from these requirements.  More detailed information regarding the requirements, standards, and exemptions for pesticides and bait stations can be found in 40 CFR 157(b).

Summary of Testing Protocol

A full description of the pesticide and bait station testing summarized below can be found in 16 CFR 1700.

Child Testing Protocol

    • Each test is made up of 1 to 4 panels of 50 children between the ages of 42 and 51 months.
    • Panels are divided into 3 groups according to age:
    • 30% between the ages of 42 and 44 months
    • 40% between the ages of 45 and 48 months
    • 30% between the ages of 49 and 51 months
    • The number of boys and the number of girls in each group must be approximately 50%/50% (regulation allows for +/-10% variation).
    • No more than 20% of the children in each group may be obtained or tested at a single site.
    • All children must be healthy with no disabilities or injuries that could potentially affect their ability to test the bait station.
    • Each child may test up to two bait station types.  If a child tests two bait stations, the stations must be different designs.
    • Children are tested in pairs in a room that is well-lit, free of distractions, and is familiar to them, or in a central location in which they feel comfortable, by a tester who administers the test to no more than 30% of the sample.
    • To begin, the tester gives each child a bait station containing a placebo and asks them to try to open it without any instruction.  Each child has 5 minutes to try to open the station.  The tester uses a stopwatch to document the amount of time it takes for the child to open the station.
    • If a child opens the bait station, the test is counted as a failure and he or she is not tested further.  If the second child has not been able to open the station successfully at this point, they are allowed to continue for the remainder of the allotted test period.
    • If a child (or children) does not open the bait station within the allotted 5 minutes, the tester demonstrates how to open the station and mentions that it is okay for them to use their teeth (if they have not done so already).  The child is then given an additional 5 minutes to try to open the station.  If the child is able to open the station within this period, this is also counted as a failure.

Pass/Fail Criteria:

  • A test is determined a failure if a child opens or gains access to the contents of the bait station.
  • For a bait station to pass in the first panel of 50 children, three or fewer must be able to open the station during the first 5 minutes (before the tester demonstrates how to open the station), and 5 or fewer during the second 5 minutes (after the demonstration).  Conversely, if 11 or more children open the station in the first 5 minutes, or if 15 or more open the station within the full 10 minutes, the station fails.  In both cases, no further testing is necessary.
  • In the first panel of 50 children, if 6-14 open the bait station within the allotted 10 minutes, a second panel of 50 children must be tested.  Depending upon the results of the second round of testing, the station may pass, fail, or require another panel.  Testing stops after the 4th panel regardless of the passing rate.

Links & Documents

40 CFR 157(b) – Packaging Requirements for Pesticides and Devices
16 CFR 1700 – Standard for Packaging used by CPSC

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Child Resistant

Package Testing

Information resource for the testing, classification,
and regulation of child resistant products

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Product Types, Protocols, & Regulations

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Packages

In order for a package to be considered child resistant, it must be tested with children ages 42-51 months using the protocol detailed in 16 CFR 1700.  Testing is performed to ensure that young children are unable to access potentially dangerous substances.  Each package is tested with at least 50 children (and a maximum of 200 children) to determine the effectiveness of the package.

In addition, the package must also be tested with senior adults (ages 50-70 years) to make sure it is not too difficult to use.  For this portion of testing, at least 90% of the adults tested must be able to successfully open and, if applicable, re-close the package two sequential times within the allotted test periods.

A full description of the package testing protocol summarized below is in 16 CFR 1700.

Child Testing Protocol

    • Each test is made up of 1 to 4 panels of 50 children between the ages of 42 and 51 months.
    • Panels are divided into 3 groups according to age:
    • 30% between the ages of 42 and 44 months
    • 40% between the ages of 45 and 48 months
    • 30% between the ages of 49 and 51 months
    • The number of boys and the number of girls in each group must be approximately 50%/50% (regulation allows for +/-10% variation).
    • No more than 20% of the children in each group may be obtained or tested at a single site.
    • All children must be healthy with no disabilities or injuries that could potentially affect their ability to test the package.
    • Each child may test up to two package types. If a child tests two packages, the packages must be different designs.
    • Children are tested in pairs in a room that is well-lit, free of distractions, and is familiar to them, or in a central location in which they feel comfortable, by a tester who administers the test to no more than 30% of the sample.
    • To begin, the tester gives each child a package containing a placebo and asks them to try to open it without any instruction. Each child has 5 minutes to try to open the package. The tester uses a stopwatch to document the amount of time it takes for the child to open the package.
    • If a child opens the package, the test is counted as a failure and he or she is not tested further. If the second child has not been able to open the package successfully at this point, they are allowed to continue for the remainder of the allotted test period.
    • If a child (or children) does not open the package within the allotted 5 minutes, the tester demonstrates how to open the package and mentions that it is okay for them to use their teeth (if they have not done so already). The child is then given an additional 5 minutes to try to open the package. If the child is able to open the package within this period, this is also counted as a failure.

Pass/Fail Criteria:

  • A test is determined a failure if a child opens or gains access to the contents of the package.
  • For a package to pass in the first panel of 50 children, three or fewer children be able to open the package during the first 5 minutes (before the tester demonstrates how to open the package), and 5 or fewer during the second 5 minutes (after the demonstration). Conversely, if 11 or more children open the package in the first 5 minutes, or if 15 or more open the package within the full 10 minutes, the package fails. In both cases, no further testing is necessary.
  • In the first panel of 50 children, if 6-14 open the package within the allotted 10 minutes, a second panel of 50 children must be tested. Depending upon the results of the second round of testing, the package may pass, fail, or require another panel. Testing stops after the 4th panel regardless of the passing rate.

Senior Adult Testing Protocol

    • For this test, one panel of 100 senior adults between the ages of 50 and 70 years old is used.  Each participant is required to sign a consent form prior to testing.
    • Panels are divided into 3 groups according to age:
    • 25% between the ages of 50 and 54 years
    • 25% between the ages of 55 and 59 years
    • 50% between the ages of 60 and 70 years
    • 70% of those in the 50-59 year and 60-70 year age groups must be female, and 17 or 18 of those in the 50-54 year age group must be female.
    • No more than 24% of participants may be obtained or tested at a single site.
    • Participants must have no obvious physical or mental disabilities.
    • Each adult is tested individually by a tester who administers the test to no more than 35% of the sample.
    • To begin, the tester gives the participant a package with printed instructions (instructions may be on the package or accompany it on a sheet of paper). The participant is allotted 5 minutes to open and, if applicable, re-close the package correctly. The tester uses a stopwatch to document the amount of time it takes for the participant to open and re-close the packages.
    • If the participant is able to open/close the package within this time period, he or she must be able to do so a second time with another identical package during a subsequent 1 minute time period.
    • If a participant is unable to open the first package in the allotted 5 minutes, he/she is asked to open and, if applicable, close two non-child-resistant packages. The participant is allotted 1 minute per package. Those who are unable to open/close the non-child-resistant packages are excluded from the panel and replaced by additional participants.

Pass/Fail Criteria:

    • A test is determined a failure if the adult is unable to open or gain access to the contents of the package.
    • For a package to pass, at least 90% of the adults tested must be able to properly open and close the package during the first 5 minutes and open and close the package again in the subsequent 1 minute.

Child resistant packages are classified according to thirteen types.  These classifications are defined based on the specific motion, skill, or tool required to open a particular package.  Detailed descriptions and examples of each type and sub-type are in ASTM D3475-17.

  1. Reclosable Packaging – Continuous Thread Closure
  2. Reclosable Packaging – Lug Finish Closure
  3. Reclosable Packaging – Snap Closure
  4. Unit Non-Reclosable Packaging – Flexible (strip/pouch)
  5. Unit Non-Reclosable Packaging – Rigid
  6. Unit Reclosable Package
  7. Aerosol Packages
  8. Non-Reclosable Packaging – Semi-Rigid (blister)
  9. Dispensers (not intended to be removed)
  10. Box or Tray Package
  11. Reclosable Packaging – Flexible
  12. Dispenser (may be removed)
  13. Reclosable Packaging – Semi-Rigid (blister)

16 CFR 1700 – Standard for Packaging used by CPSC
ASTM D3475-17 – Standard Classification of Child-Resistant Packages
ISO 8317 – International Standard for Reclosable Packaging
EN 14375 – International Standard for Non-reclosable Pharmaceutical Packaging
CAN/CSA Z76.1 – Canadian Standard for Reclosable Packaging

Lighters

Safety regulations for lighters fall into two categories: cigarette lighters, which includes disposable and novelty lighters, and multi-purpose lighters.  These regulations refer to flame-producing products that operate on fuel and do not include matches.  

Cigarette lighters are intended to ignite cigarettes, cigars, and pipes, although it may be used to light other materials as well. A disposable lighter is one that uses a gas such as butane, isobutane, propane, or another form of liquefied hydrocarbon under pressure and cannot be refilled.  These lighters typically have a Customs Valuation or ex-factory price of under $2.25 (this price is adjusted every 5 years to the nearest $0.25).  A novelty lighter refers to lighters that have visual and/or audio features that might make them appealing to a child under 5 years of age.  These lighters depict or resemble things such as cartoon characters, toys, guns, watches, musical instruments, vehicles, animals, food, or beverages, and may also produce sound or feature flashing lights.  Novelty lighters can operate on any fuel, including butane and liquid fuel.  

A multi-purpose lighter is typically used to light items such as candles, fireplaces, grills, camp fires or stoves, lanterns, and pilot lights, or for other applications such as soldering or brazing.  These lighters also operate on fuel and use an ignition mechanism.

In order for a cigarette or multi-purpose lighter to be considered child resistant, at least 85% of the children tested must be unable to successfully operate the lighter.

To ensure safety while testing lighters with children, surrogate lighters are used.  A surrogate lighter has the same function, size, weight, and appearance as a real lighter, but it does not contain fuel.  Instead of igniting, the surrogate lighter will produce a sound or visual signal to let the tester know that it was operated correctly and would have caused a real lighter to produce a flame.    

Additional details regarding the requirements described above are in 16 CFR 1210 (cigarette lighters) and 16 CFR 1212 (multipurpose lighters).

A full description of the cigarette and multi-purpose lighter testing protocol summarized below and additional manufacturer requirements can be found in 16 CFR 1210 and 16 CFR 1212.

Child Testing Protocol

    • Each test is made up of 1 to 2 panels of 100 children between the ages of 42 and 51 months.
    • Panels are divided into 3 groups according to age:
    • 30% between the ages of 42 and 44 months
    • 40% between the ages of 45 and 48 months
    • 30% between the ages of 49 and 51 months
    • Approximately 2/3 of the children in each of the age groups must be boys.
    • All children must be healthy with no disabilities or injuries that could potentially affect their ability to test the lighter.
    • Children may not participate in both cigarette and multi-purpose lighter testing or package testing in the same day.
    • Children are tested in pairs in a room that is well-lit, free of distractions, and is familiar to them, or in a central location in which they feel comfortable, by a tester who administers the test to no more than 30% of the sample.
    • To begin, the tester operates a surrogate lighter in the presence of the children who are to be tested without letting them see how it was operated so they will know what sound or visual signal the lighter makes when operated correctly.  Each child is then given a surrogate lighter and asked to try to make the same sound or visual signal.  The children are allotted 5 minutes to try to operate the lighter correctly.  The tester uses a stopwatch to keep track of the time.
    • If a child is able to operate the lighter successfully, the test is counted as a failure and he or she is not tested further.  If the second child has not been able to operate the lighter successfully at this point, they are allowed to continue for the remainder of the allotted test period.
    • If a child (or children) is unable to correctly operate the lighter within the allotted 5 minutes, the tester demonstrates how to do so.  The child is then given an additional 5 minutes to try again.  If the child is able to operate the lighter within this period, this is also counted as a failure.


    Pass/Fail Criteria:

    • A test is determined a failure if the child is able to produce the sound or visual signal by correctly operating the surrogate lighter.
    • For a lighter to pass in the first panel of 100 children, 10 or fewer must have been able to operate the surrogate lighter.  Conversely, if 19 or more children operate the surrogate lighter successfully, the lighter fails.  In both cases, no further testing is necessary.
    • In the first panel of 100 children, if 11-18 operate the surrogate lighter successfully, a second panel of 100 children must be tested.  In the event that the second panel is tested, the lighter fails if 31 or more of the 200 children tested are able to operate the surrogate lighter successfully.
    •  


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16 CFR 1210 – Safety Standard for Cigarette Lighters
16 CFR 1212 – Safety Standard for Multi-Purpose Lighters
EN 13869 – International Standard for Lighters

Fuel Containers

Fuel containers and closing components must first meet the requirements outlined in CARB CP-501, TP-501, TP-502, and EPA regulation 40 CFR 59.623.

Prior to testing, each container must be subjected to:

  • Low temperature exposure (0°F or -17.8°C) for 8 hours
  • High temperature exposure (140°F or 60°C) for 8 hours
  • 250 opening and closing cycles
  • Inspection to ensure that there are no leaks or damage to the container

In order for a fuel container to be considered child resistant, it must be tested with children ages 42-51 months according to the protocol detailed in ASTM F2517.  Testing is performed to ensure that young children are unable to access potentially dangerous substances.  Each container is tested with a minimum of 50 children and a maximum of 200 children to determine the effectiveness of the container and the closures on the container (see Summary of Testing Protocol for further details).

Conversely, the container and its closures must also be tested with senior adults (ages 50-70 years) to make sure it is not too difficult for them to use.  For this portion of testing, at least 90% of the adults tested must be able to successfully open and re-close all of the closures and use the fuel container two sequential times within the allotted test period.

A full description of the fuel container testing protocol summarized below can be found in ASTM F2517.

Child Testing Protocol

    • A child panel is needed for each closure.
    • Each test is made up of 1 to 4 panels of 50 children between the ages of 42 and 51 months.
    • Panels are divided into 3 groups according to age:
    • 30% between the ages of 42 and 44 months
    • 40% between the ages of 45 and 48 months
    • 30% between the ages of 49 and 51 months
    • The number of boys and the number of girls in each group must be approximately 50%/50% (regulation allows for +/-10% variation).
    • No more than 20% of the children may be from a single test site.
    • All children must be healthy with no disabilities or injuries that could potentially affect their ability to test the container.
    • Each child may test up to two containers.  If a child tests two containers, the containers must have different closure types.
    • Children are tested in pairs in a room that is well-lit, free of distractions, and is familiar to them, or in a central location in which they feel comfortable, by a tester who administers the test to no more than 30% of the sample.
    • To begin, the tester gives each child a container that is one-quarter full of water and asks them to try to open it without any instruction.  Each child has 5 minutes to try to open the container.  The tester uses a stopwatch to document the amount of time it takes for the child to open the container.
    • If a child opens the container, the test is counted as a failure and he or she is not tested further.  If the second child has not been able to open the container successfully at this point, they are allowed to continue for the remainder of the allotted test period.
    • If a child (or children) does not open the container within the allotted 5 minutes, the tester demonstrates how to open the container and states that it is okay for them to use their teeth (if they have not done so already).  The child is then given an additional 5 minutes to try to open the container.  If the child is able to open the container within this period, this is also counted as a failure.

    Pass/Fail Criteria:

    • A test is determined a failure if a child is able to access the liquid in the container through any of the openings, whether the opening procedure was demonstrated to the child or not.
    • For a container to pass in the first panel of 50 children, three or fewer must be able to open the container during the first 5 minutes (before the tester demonstration), and 5 or fewer during the second 5 minutes (after the demonstration).  Conversely, if 11 or more children open the container in the first 5 minutes, or if 15 or more open the container within the full 10 minutes, the container fails.  In both cases, no further testing is necessary.
    • In the first panel of 50 children, if 6-14 open the container within the allotted 10 minutes, a second panel of 50 children must be tested.  Depending upon the results of the second round of testing, the container may pass, fail, or require another panel.  Testing stops after the 4th panel regardless of the passing rate.

Senior Adult Testing Protocol

    • For this test, one panel of 100 senior adults between the ages of 50 and 70 years old is used.  Each participant is required to sign a consent form prior to testing.
    • Panels are divided into 3 groups according to age:
    • 25% between the ages of 50 and 54 years
    • 25% between the ages of 55 and 59 years
    • 50% between the ages of 60 and 70 years
    • 70% of those in the 50-59 year and 60-70 year age groups must be female, and 17 or 18 of those in the 50-54 year age group must be female.
    • No more than 20% of the adults may be from a single ZIP code, city, or town to allow for geographical diversity.
    • Participants must have no obvious physical or mental disabilities.
    • Each adult is tested individually by a tester who administers the test to no more than 35% of the sample.
    • To begin, the tester gives the participant a container that is one quarter full of water with printed instructions (instructions may be on the container or accompany it on a sheet of paper). The participant is allotted 5 minutes to open and re-close all of the closures on the container correctly. The tester uses a stopwatch to document the amount of time it takes for the participant to open and re-close the container.
    • If the participant is able to open and close all of the closures on the container within this time period, he or she must be able to do so a second time with another identical container during a subsequent 1 minute time period.
    • If a participant is unable to open the first container in the allotted 5 minutes, he/she is asked to open and close two non-child-resistant containers. The participant is allotted 1 minute per container. Those who are unable to open/close the non-child-resistant containers are excluded from the panel and replaced by additional participants.

    Pass/Fail Criteria:

    • A test is determined a failure if the adult is unable to open and reclose all of the closures on the container within the allotted test period.
    • For a container to pass, at least 90% of the adults tested must be able to properly open and re-close the container during the first 5 minutes and open and close the container again in the subsequent 1 minute.

ASTM F2517 – Standard Specification for Determination of Child Resistance of Portable Fuel Containers for Consumer Use
16 CFR 1500 – Federal Hazardous Substance Act
CARB CP-501 – Certification Procedure for Portable Fuel Container Systems
CARB TP-501 – Test Procedure for Determining Integrity of Portable Fuel Container Systems
CARB TP-502 – Test Procedure for Determining Diurnal Emissions of Portable Fuel Container Systems
EPA 40 CRF 59.623 – What Must I Include in My Application?

Pesticides & Bait Stations

In order for a bait station to be considered child resistant, it must be tested with children ages 42-51 months using to the protocol detailed in 16 CFR 1700.  Testing is performed to ensure that young children are unable to access potentially dangerous substances.  Each bait station is tested with at least 50 children (and a maximum of 200 children) to determine the effectiveness of the station.

The child-resistant packaging used for bait stations must meet the following standards:

  • Effectiveness Standard  Packaging must be tested according to the requirements detailed in 16 CFR 1700.
  • Compatibility Standard  Packaging must remain effective when the bait station/pesticide when is in active use.
  • Durability Standard  Packaging must be able to meet the effectiveness and compatibility standards throughout the expected lifetime of the product.

These standards apply to pesticides that are labeled for, or can be reasonably interpreted as being labeled for, residential use and meet the following toxicity criterion:

  • Acute oral LD50 of 1.5g/kg or less
  • Acute dermal LD50 of 2,000mg/kg or less
  • Acute inhalation LC50 of 2mg/L or less

Products that are specifically classified for restricted use and products packaged in large sizes are exempt from these requirements.  More detailed information regarding the requirements, standards, and exemptions for pesticides and bait stations can be found in 40 CFR 157(b).

A full description of the pesticide and bait station testing summarized below can be found in 16 CFR 1700.

Child Testing Protocol

    • Each test is made up of 1 to 4 panels of 50 children between the ages of 42 and 51 months.
    • Panels are divided into 3 groups according to age:
    • 30% between the ages of 42 and 44 months
    • 40% between the ages of 45 and 48 months
    • 30% between the ages of 49 and 51 months
    • The number of boys and the number of girls in each group must be approximately 50%/50% (regulation allows for +/-10% variation).
    • No more than 20% of the children in each group may be obtained or tested at a single site.
    • All children must be healthy with no disabilities or injuries that could potentially affect their ability to test the bait station.
    • Each child may test up to two bait station types.  If a child tests two bait stations, the stations must be of different designs.
    • Children are tested in pairs in a room that is well-lit, free of distractions, and is familiar to them, or in a central location in which they feel comfortable, by a tester who administers the test to no more than 30% of the sample.
    • To begin, the tester gives each child a bait station containing a placebo and asks them to try to open it without any instruction.  Each child has 5 minutes to try to open the station.  The tester uses a stopwatch to document the amount of time it takes for the child to open the station.
    • If a child opens the bait station, the test is counted as a failure and he or she is not tested further.  If the second child has not been able to open the station successfully at this point, they are allowed to continue for the remainder of the allotted test period.
    • If a child (or children) does not open the bait station within the allotted 5 minutes, the tester demonstrates how to open the station and mentions that it is okay for them to use their teeth (if they have not done so already).  The child is then given an additional 5 minutes to try to open the station.  If the child is able to open the station within this period, this is also counted as a failure.

Pass/Fail Criteria:

  • A test is determined a failure if a child opens or gains access to the contents of the bait station.
  • For a bait station to pass in the first panel of 50 children, three or fewer children be able to open the station during the first 5 minutes (before the tester demonstrates how to open the station), and 5 or fewer during the second 5 minutes (after the demonstration).  Conversely, if 11 or more children open the station in the first 5 minutes, or if 15 or more open the station within the full 10 minutes, the station fails.  In both cases, no further testing is necessary.
  • In the first panel of 50 children, if 6-14 open the bait station within the allotted 10 minutes, a second panel of 50 children must be tested.  Depending upon the results of the second round of testing, the station may pass, fail, or require another panel.  Testing stops after the 4th panel regardless of the passing rate.

40 CFR 157(b) – Packaging Requirements for Pesticides and Devices
16 CFR 1700 – Standard for Packaging used by CPSC