This document summarizes the testing protocols specified in 16 CFR § 1700.20 for determining whether child-resistant packaging is effective. It outlines the child test using panels of 50 children aged 42-51 months, the senior-adult test using 100 adults aged 50-70 years, and an additional adult-resecuring test. It provides details on panel composition, time limits for opening packages, and failure criteria. The document also addresses additional testing scenarios and retesting requirements.

1. Stephen Lee
Compliance Officer, Chemical Hazards Team
The views expressed in this presentation are those of the CPSC staff, have not been
reviewed or approved by, and may not necessarily reflect the views of, the Commission.

2.  Child Test
 Senior-Adult Test
 Adult-Resecuring Test
 Additional Information
 Frequently Asked Questions
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3. Test specified at 16 CFR § 1700.20(a)(2)
 Panels of 50 children, up to 4 panels
 Age range: 42-51 months old
◦ 30% from 42 to 44 months
◦ 40% from 45 to 48 months
◦ 30% from 49 to 51 months
 Panel make-up: 50% girls, 50% boys
 Tester restriction: 30% of children per tester
 Site restriction: 20% of children per site
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4.  Children tested in pairs
◦ Testing must be done in a location that is familiar
to the children
 5 minutes to open package
 If unopened within 5 minutes, demonstration
provided by tester
 Additional 5 minutes to open package after
demo
◦ Children instructed they may use their teeth
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5. Failure is defined as child opening package or
gaining access to its contents through ANY means.
Test
Panel
Cumulative
# of Children
Packaging Openings
First 5 Minutes Full 10 Minutes
Pass Continue Fail Pass Continue Fail
1 50 0-3 4-10 11+ 0-5 6-14 15+
2 100 4-10 11-18 19+ 6-15 16-24 25+
3 150 11-18 19-25 26+ 16-25 26-34 35+
4 200 19-30 -------- 31+ 26-40 ------- 41+
Table specified at 16 CFR § 1700.20(a)(2)(iii)
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6. Test specified at 16 CFR § 1700.20(a)(3)
 100 adult panel
 Age range: 50 to 70 years old
◦ 25% from 50 to 54 years
◦ 25% from 55 to 59 years
◦ 50% from 60 to 70 years
 Panel make-up: 70% women, 30% men
 Tester restriction: 35% of adults per tester
 Site restriction: 24% of adults per site
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7.  Consent form
 5 minutes to open and reclose first package
 1 minute to open and reclose second,
identical package
 Screening procedure if adult cannot open
package
◦ Give participant 2 non-CR packages to try to open
◦ Allow 1 minute to open and close each package
◦ If adults cannot complete both tasks, results of
their test is not included in the panel
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8. Test specified at 16 CFR § 1700.20(d)(2)
 Required when an objective determination
(visual or mechanical) that a package is
properly resecured cannot be made
 Packages that have been opened and appear
to be resecured by adults from Senior Test
are used and given to children to open
◦ Follow test instructions outlined in Child Test
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9.  Children
◦ Packages are presented in the form in which they
will enter or be stored in the home
◦ Tools only provided if included with the packaging
 Seniors
◦ Any required tools
◦ Provide only instructions on how to open and
properly resecure the package as it will appear on
or accompany the package in the manner that it is
delivered to the consumer
Worst-case scenario should be simulated
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10. 16 CFR § 1700.15(a)
 Substance that is packaged must not
compromise or interfere with the function of
the special packaging
 Special packaging is required to continue to
function so that it meets the PPPA
effectiveness specifications for the life of the
product
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11.  If the packages are of the same material, but
different sizes, multiple testing may be
required
◦ Bracket testing for different closure/bottle size
 If the packages use the same closure, but the
bottles are different materials, testing both
packages is necessary
◦ Plastic and glass bottles using the same closure
require two separate tests
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12.  There are no provisions in the law or in the
regulations that restrict who can perform the
testing.
 Testing is valid as long as the protocols
outlined in 16 CFR § 1700.20 are followed.
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13.  Change in the package manufacture
◦ Change in raw package materials
◦ Change in manufacturing process
◦ Developing/designing new package
 Using a tested closure on a new or different
bottle
 When you receive incident reports or
complaints
 When you become aware of a manufacturing
or materials defect
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