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The check, before the blend is final

Updated

On this page8
Four questions, answered off your own formula sheet. Three of them are arithmetic.

One: what is in it, by weight?

Component by component, as percentages by weight of the finished product. Every threshold in 16 CFR 1700.14 is expressed that way, and a formula recorded in drops cannot be tested against any of them.

Two: does it cross a named threshold?

Over 5 percent methyl salicylate. Ten percent or more hydrocarbons, summed across components, at under 100 SUS. Ten percent turpentine. Ten percent petroleum distillates if it is sold to be burned. Write down the figure you computed, not the conclusion.

Three: can the format carry the answer?

A refill can take a child-resistant closure. A reed diffuser in service cannot, and it has no spray device to claim the exemption with. If a threshold is crossed and the format is open, the formula is what has to move.

Four: will the closure still perform in a year?

Cap, liner and reducer, all in contact with an oil that attacks polymers, across the openings and closings customary for the size. 1700.15(a) asks for that explicitly, and only a filled unit left standing can answer it.

Then check the labeling separately

Hazard labeling lives in 16 CFR 1500 and has its own triggers, including specified words for products at 10 percent or more petroleum distillates. Clearing the packaging question says nothing about that one.

Re-run it on every change

A new note, a cheaper carrier, a concentration change, a new size or a new closure supplier. The check costs an afternoon and the failures it catches cost a production run and a recall conversation.

Keep the answers, not just the conclusions

The computed percentage, the paragraph you checked it against, the format decision and the closure you tested. A conclusion with no working behind it cannot be rechecked after a reformulation, which means in practice it gets taken on trust.

References

16 CFR 1700.14, Substances requiring special packaging, under the Poison Prevention Packaging Act regulations. Paragraph (a)(3) covers liquid preparations over 5 percent methyl salicylate; (a)(7) illuminating preparations at 10 percent petroleum distillates; (a)(31) and (a)(32) hazardous substances, and drugs and cosmetics, at 10 percent or more hydrocarbons by weight and under 100 SUS at 100 F, each with an exemption for packages whose only non-child-resistant access is a spray device. law.cornell.edu
16 CFR 1700.15, Poison prevention packaging standards. Paragraph (a) requires the packaging to keep working in actual contact with the substance and across the openings and closings customary for its size and contents; (b) sets child-resistant effectiveness at not less than 85 percent without a demonstration and 80 percent after one; (c) forbids reuse; (d) restricts flow to 2 milliliters per activation. law.cornell.edu
16 CFR 1500.14, Products requiring special labeling under section 3(b) of the act. Paragraph (a)(3) covers products at 10 percent or more petroleum distillates such as kerosine, mineral seal oil, naphtha and mineral spirits; (b)(3)(ii) requires the signal word "danger", the statement "Harmful or fatal if swallowed" and "Call physician immediately", because such products may be aspirated into the lungs. law.cornell.edu
Written from federal regulation, not from a formulation bench. Whether a given formula crosses a threshold in 16 CFR 1700.14 is a question about your formula, and the percentages here are the test rather than the answer. Anything on these pages is a starting point and not clearance for a specific product.