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Child-resistant packaging: One of the noblest assignments

Keeping the little ones safe is one of the noblest assignments of packaging.

Child-resistant (C-R) packaging is familiar to most of society; however, it behooves packaging professionals to have more than a passing familiarity with it for at least several reasons. One is that although C-R packaging has been federally mandated since the 1970s, the supplier industry is not static and new designs regularly appear. Another is that companies whose products don’t fall under the federal mandates nonetheless are free to voluntarily use C-R packaging. Yet another is that the self-suggesting purpose of C-R packaging can obscure the many intricacies that determine how well a particular design fulfills the purpose.

The regulators of C-R packaging

The Poison Prevention Packaging Act (1972) grants regulatory authority to the U.S. Consumer Product Safety Commission (CPSC), as covered in 16 CFR (Code of Federal Regulations). The Environmental Protection Agency (EPA) also regulates C-R packaging, as covered in 40 CFR.

For each agency, specifics such as definitions, products subject to the regulations, packaging performance criteria, and testing protocols are contained in the respective CFR. Much of the two CFRs are harmonized, and in general, their main difference is with products: 16 CFR pertains to pharmaceuticals, cosmetics, and household chemicals, while 40 CFR covers pesticides. Another way to generalize is to say that not all of the products regulated by the CPSC are inherently toxic (mouthwash, for example), but all of the products regulated by the EPA are.

Protection of which children and to what extent?

Children younger than five are the group that C-R packaging regulations are meant to protect. It’s an arbitrary cut-off, for a six-year-old is certainly capable of not appreciating a hazard residing in a certain product. The regulations further require that the packaging be “significantly difficult” to open and access the contents, within a “reasonable time.”

The tender years of the targeted group notwithstanding, there’s bound to be those who possess the precociousness, dexterity, or experimental luck that enable them to defeat the purpose of C-R packaging. The regulations don’t require that “all children” within the targeted group be unable to open and access. For that reason, care should be exercised to not refer to the packaging as child-proof.

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