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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) 308-7368, 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.
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) 308-7368, 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:
- ASTM Type (primary file - contains descriptions and photos)
* The ASTM type index is the only listing that contains photographs and descriptions of the various CRPs. Users who are not familiar with the ASTM classification of CRP should use one of the other three indices to locate the package and its ASTM classification. Once a particular package with its ASTM classification is chosen, the user should go to the ASTM index for a description and photograph.
- CRP Manufacturer
- Package ASTM type (e.g. aerosol overcap) with a secondary sort by ASTM type
- Package Manufacturer Type (e.g. aerosol overcap) with a secondary sort by CRP manufacturer
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
Disclaimers
The ASTM classifications are extracted, with permission, from D3475-06, Standard Classification of Child-Resistant Packages, copyrighted:
ASTM International
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: service@astm.org, Web site: www.astm.org.
Additions/Corrections
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)
Registration Division
1200 Pennsylvania Ave., N.W.
Washington, DC 20460
Telephone: 703-308-7368
Fax: 703-308-7368
E-mail: Gross.Rosalind@epa.gov
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: Perry Sharpless
U.S. Consumer Product Safety Commission
Directorate for Laboratory Sciences
10901 Darnestown Rd.
Gaithersburg, MD 20878
301-424-6421 ext. 129
Fax: 301-413-7107
Email:psharpless@cpsc.gov
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