Buy a full case and the price per unit drops automaticallyRequest a sample
AccountCart0
All ContainersBottlesJarsCaps & ClosuresPumps & SprayersTubs & PailsJugsDroppersTinsTubesAccessories
Industries
Learn
Growing the operation

What you have to write down

Updated

On this page5

More records here than anywhere else in this estate, because more regimes reach the product.

Four record sets

Batch records, one per batch.

Raw material records: supplier, lot, certificate of analysis, safety data sheet.

Stability and test records: container compatibility, freeze-thaw, challenge test.

The compliance file, which is the set that distinguishes this category.

The batch record

Batch code and date. Formula with the actual weights. Lot number of every raw material. Order of addition and any deviation. pH before and after adjustment, and the adjuster used. Viscosity. Appearance and odor. Batch weight. Units filled, units rejected, where they went.

The batch code goes on the bottle, or the record cannot be connected to a product in somebody's hand.

The compliance file

The current label artwork for each product, dated, with a note of what changed and when.

The hazard classification and the basis for the cautionary labeling.

The calculation showing where each listed substance sits against the child-resistant packaging thresholds, recalculated on every reformulation. This is the one nobody keeps and the one that answers the hardest question.

Safety data sheets, yours and your suppliers'.

The ingredient disclosure as published, with dates.

And a record of the claim review: what the label, the listings and the marketing say, checked against the claim rules, with a date.

The retrieval test

Hand yourself a bottle with a code on it. How long to produce the formula as made, the lots of every material, the pH and viscosity on release, the label version, the hazard basis and the list of who received the batch?

Under an hour is a working system. Run it on a quiet afternoon rather than on the day it matters.

References

Poison Prevention Packaging Act, 16 CFR 1700.14, Substances requiring special packaging. Thresholds relevant to household cleaners include sodium and/or potassium hydroxide at 2 percent or more in liquid (10 percent dry), methyl alcohol at 4 percent, sulfuric acid at 10 percent, turpentine at 10 percent, and nonemulsion liquid furniture polish with 10 percent or more petroleum distillates below 100 SUS. ecfr.gov
Federal Hazardous Substances Act and 16 CFR Part 1500, which require cautionary labeling on household products containing hazardous substances: the signal word, the hazard, precautionary measures, first aid and the instruction to keep out of reach of children. ecfr.gov
OSHA Hazard Communication Standard, 29 CFR 1910.1200, which requires a safety data sheet and GHS labeling for hazardous chemicals supplied for workplace use. osha.gov
California Cleaning Product Right to Know Act of 2017 (SB 258). Designated products — air care, automotive, general cleaning, and polish or floor maintenance products — must disclose ingredient information on the product website from January 1, 2020 and on the label from January 1, 2021. leginfo.ca.gov
Written from the federal regulation and agency guidance named on each page, not from a laboratory or a legal practice. Whether a particular product and a particular label make a cleaner or a pesticide is a determination about your product, and this is not that determination.