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The package

Buying a compliant package

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If your product requires special packaging, the question to ask a supplier is which combination was tested, and may I see it.

Ask about the combination, not the cap

The useful question is which closure on which container was tested together, by whom and when. A supplier who answers with a closure part number alone has not answered it, and that is the most common response.

Ask which standard and which protocol

The child-resistant effectiveness and senior adult use effectiveness figures, and the protocol used. Those numbers are the output of the test and a supplier who has had it done will have them.

Get it in writing, against a part number

A general assurance that a range is child resistant is marketing. Documentation naming the combination you are ordering is evidence, and it is the thing you will want if anybody ever asks.

Check it covers reclosure and repeated use

The senior requirement includes properly resecuring, and the standard expects the package to keep functioning over its customary number of openings. A test result that covers only first opening is incomplete for a product taken daily.

Changing anything restarts the question

A different liner, a different fill, a label that stiffens the wall, or a second source for the same nominal bottle. Any of those is arguably a different package, and a supplier change is the usual moment this gets forgotten.

Keep the documentation with the product record

In the same place the batch records live, so that proving it later is a lookup. A certificate nobody can find is a certificate you do not have, which is the same lesson every property in this library reaches.

A tested package costs more and that is the product

Panels of children and older adults are a real laboratory service, and the price of a certified combination carries that. A supplier offering certified packaging at component prices is worth a second question rather than an order.

References

16 CFR 1700.15, Poison prevention packaging standards: child-resistant effectiveness of not less than 85 percent without a demonstration, and senior adult use effectiveness of not less than 90 percent. Special packaging must continue to function for the number of openings and closings customary for its size and contents. law.cornell.edu
16 CFR 1700.20, the test protocol. Children aged 42 to 51 months in three bands; panels of 50 rising to 200. Senior adults: 100 participants, 25 percent aged 50-54, 25 percent 55-59, 50 percent 60-70, 70 percent female, with a five minute and then a one minute period, and the package must be opened and properly resecured. law.cornell.edu
16 CFR 1700.14, the list of substances required to be in special packaging. law.cornell.edu
Written from the Poison Prevention Packaging Act regulations, not from a test laboratory. Child-resistant packaging is certified by testing a specific package as a system, and nothing here certifies anything. If you need a compliant package, the testing is the route and a matching closure is not a substitute for it.