keeping the little ones safe is one of the noblest assignments of packagingby sterling anthony, cpp, contributing editorchildresistant cr 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 cr 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&rsquot fall under the federal mandates nonetheless are free to voluntarily use cr packaging. yet another is that the selfsuggesting purpose of cr packaging can obscure the many intricacies that determine how well a particular design fulfills the purpose.the regulators of cr packagingthe 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 cr 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 extentchildren younger than five are the group that cr packaging regulations are meant to protect. it&rsquos an arbitrary cutoff, for a sixyearold is certainly capable of not appreciating a hazard residing in a certain product. the regulations further require that the packaging be &ldquosignificantly difficult&rdquo to open and access the contents, within a &ldquoreasonable time.&rdquothe tender years of the targeted group notwithstanding, there&rsquos bound to be those who possess the precociousness, dexterity, or experimental luck that enable them to detect the purpose of cr packaging. the regulations don&rsquot require that &ldquoall children&rdquo within the targeted group be unable to open and access. for that reason, care should be exercised to not refer to the packaging as childproof.quantifying successthe fact that 100 effectiveness is not a requirement imposes the need for a minimum requirement to designate cr packaging&rsquos performance as acceptable, implying the need for testing. both the testing and the passfail criteria are detailed in the aforementioned cfrs.basically, panels consisting of 50 children, divided into three age groups, are told to open the packaging. the testing time is 10 minutes, during which a child&rsquos attempts can include use of the teeth. a child who fails to open the packaging within the initial 5 minutes is given a demonstration followed by an additional 5 minutes. the package fails an individual test whether opened during the first or second 5 minutes. in order for the packaging to pass overall, no less than 85 of the children must be unable to open it prior to demonstration and no less than 80 after the demonstration. when results prove inconsistent, additional panels of 50 children must be used however, the total number of children testing should not exceed 200.who should conduct the testingend users should note that neither the cpsc nor the epa endorses a particular cr packaging. an end user, by its choice, implicitly warrants that the cr packaging is fit for its intended use. such a stance should be supported by testing, but performed by whom no end user should undertake inhouse testing without the requisite knowhow for, as this space has noted in other articles, the testing of children is not child&rsquos play.there are laboratories whose services include the testing of cr packaging. those laboratories should be conversant not only with the regulatory language that deals with testing but also with the related protocols from organizations such as astm. a capable laboratory also would give regard to certain particulars, for example assuring an even malefemale division striving for an environment with minimum distractions since children are easily distracted and, assuring that all test subjects appear free from signs of illness or other conditions that might negatively affect their participation.then again, suppliers of cr packaging are known to promote their offerings by citing testing results. before an enduser relies on those results consideration should be given to whether the supplier conducted its own testing, in which case, a certain amount of objectivity might be missing. it&rsquos more convincing when a supplier can cite independent testing results.closures don&rsquot bring closurecr packaging is associated most commonly with closures, the various styles of caps that top various bottles nonetheless, the need for cr packaging derives from the characteristics of the product and not just from a packaging category. that&rsquos why cr packaging includes unitofdose, blisters being the prime example. owing to the nature of unitofdose, cfr 16 modifies its performance requirements the packaging must prevent the child from opening and obtaining 8 units of the product or a toxic amount, whichever is less.youth wasted on the youngit&rsquos an ageold divide what favors the young sometimes disfavors the notsoyoung. acknowledging that truth, the regulations additionally require that cr packaging not be difficult to open for &ldquonormal adults&rdquo the regulations include criteria for the testing of adults. there&rsquos more relief in that marketers of certain products that require cr packaging are permitted to also market the product in conventional packaging, provided that it carries the written warning that the packaged product is not for households with young children.in summary, companies that currently use cr packaging should stay apprised of the regulatory changes in addition to new offerings from suppliers. in a similar vein, companies not currently mandated to use cr packaging should not assume that the exemption is permanent. those companies should look across horizons for trends so as to be able to get in front of them after all, cr never should stand for companyresistant. 
