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Child resistance

The remover, and which paragraph it is under

Updated

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Polish remover sits on the largest shelf here and its classification depends on what you sell it as.

The shelf it uses

The industrial chemical archetype: 191 containers from 100 to 4,731 mL, 149 HDPE and 42 glass, with 236 closures. Far larger than the polish or treatment shelves, because a remover is bought in quantity.

The solvent paragraph

Prepackaged liquid solvents for paints or other similar surface-coating materials containing 10 percent or more benzene, toluene, xylene or petroleum distillates, with a viscosity under 100 SUS at 100 F, require special packaging.

Whether it reaches you depends on the framing

The paragraph is about solvents for paints and similar surface-coating materials. A cosmetic nail polish remover is not obviously that, and a product sold as a general thinner is. So the positioning is part of the classification.

Which is a reason not to blur the two

Selling one bottle as both a nail polish remover and a general-purpose solvent invites the harder reading. If the product is a cosmetic remover, describing it as one consistently is both honest and simpler.

And the labeling rules are separate

At 10 percent or more petroleum distillates, 16 CFR 1500.14(b)(3)(ii) requires the signal word "danger", "Harmful or fatal if swallowed" and "Call physician immediately", because such products may be aspirated into the lungs.

Acetone is the common base and is not on those lists

Which does not make it harmless, and hazard communication still applies to a shipped container of a hazardous chemical. The point is that the named paragraphs name specific substances, so the specification decides rather than the category.

Material compatibility, on the largest shelf

Acetone and the other common remover solvents attack several polymers and most liners. HDPE handles much of it and glass handles all of it, and the liner is the part to put to the supplier in writing.

References

16 CFR 1700.14(a)(15) on solvents for paint or other similar surface-coating material at 10 percent or more benzene, toluene, xylene or petroleum distillates under 100 SUS, and 16 CFR 1700.15, the poison prevention packaging standards: the packaging must keep working in actual contact with the substance and across the openings and closings customary for its size, at not less than 85 percent child-resistant effectiveness without a demonstration and 80 percent after one. law.cornell.edu
16 CFR 1500.14, Products requiring special labeling, whose paragraph (b)(3)(ii) requires the signal word "danger", the statement "Harmful or fatal if swallowed" and "Call physician immediately" for products at 10 percent or more petroleum distillates, because they may be aspirated into the lungs. law.cornell.edu
29 CFR 1910.1200, Hazard Communication, which sets what a shipped container of a hazardous chemical carries and requires a safety data sheet. law.cornell.edu
Written from federal regulation and from measured catalog data, not from a salon. Whether a formula crosses 5 percent methacrylic acid or 500 mg of acetonitrile is a question about your formula and your container size, and the percentages here are the test rather than the answer. Nothing on these pages certifies a package as child-resistant.