With the increasing legalization of cannabis products, child-resistant packaging is increasingly essential for protecting children from accidental ingestion. This article explores eight key components of child-resistant packaging under requirements codified in the U.S. Code of Federal Regulations, 16 CFR Part 1700, via the Poison Prevention Packaging Act of 1970 regulations (PPPA).
1. Opening mechanism of Child-Resistant Packaging
For cannabis packaging to be child-resistant, it must have an opening mechanism that children under five years of age find hard to open or obtain a toxic or harmful amount of the substance contained within it while allowing adults to open the package quickly.
Child-resistant packaging can use different opening mechanisms, including squeeze-and-turn caps, push-and-turn caps, and lift-and-turn caps. These mechanisms must undergo testing to ensure they can effectively prevent access to children while still being easy enough for adults to open.
2. Tamper-evident features
A child-resistant packaging must include features that make it evident if the package has been tampered with or opened. According to the Poison Prevention Packaging Act (PPPA), tamper-evident packaging must be designed and constructed in a way that children find difficult to open or tamper with but can still be opened easily by adults.
Child-resistant packaging can use different tamper-evident features to meet the PPPA requirements. Some examples of these tamper-evident features include:
- Tear-resistant Seals: These are seals or bands attached to the packaging in a way that is difficult to remove without causing visible damage to the packaging.
- Breakaway Seals: These seals break or snap when the packaging is open or leaves a visible indicator if it has been opened.
- Tabs or levers: These features must be pressed or pulled in a specific way to open the packaging. When the packaging is open, the levers or tabs are visibly displaced, indicating that it has been opened.
3. Opacity of Child-Resistant Packaging
Child-resistant packaging must be made with opaque or light-blocking materials to prevent children from seeing the contents of the package. Children are often attracted to brightly colored or visually appealing objects or substances and may be more likely to try to access them if they can see them. Hence, opaque packaging helps to reduce their attractiveness to children.
Some examples of these types of packaging include:
- Solid-colored containers: These are containers made of solid-colored materials, such as plastic or metal, that do not allow the contents of the package to be visible.
- Foil pouches: These are made of metallic foil materials such as mylar and do not allow the contents of the package to be visible.
- Coated paperboard boxes: These are boxes made of paperboard with a layer of material, such as wax or plastic, that makes them opaque.
4. Child-Resistant Packaging Label
Child-resistant packaging must bear labeling that identifies the product contained within it and includes any necessary warning statements to alert adult users of the hazards it poses if ingested by children.
The packaging must also include warnings to keep the product out of the reach of children and instructions for its safe disposal, such as returning the package to a licensed retailer or disposing of it securely and sustainably.
Some of the information that PPPA and child-resistant regulations in other countries insist must be the label of child-resistant packaging includes:
- A warning that the product is for adult use only and should be kept out of reach of children.
- A warning that the product contains cannabis and should not be used by children or women who are pregnant or nursing.
- A warning that the product should not be used while operating a motor vehicle or heavy machinery.
- A warning that the product should be stored in a secure location out of reach of children.
- The name and physical address of the product manufacturer or distributor.
In addition to these requirements, the label of child-resistant cannabis packaging must also have a design and be placed in a way that is easy for users to read and understand the information printed on it. It must be visible and legible and placed in a location on the packaging that is easy for users to see and access.
5. Inner and Outer Child-Resistance Packaging
The PPPA requires that some products have inner and outer packaging of child-resistant materials designed to better protect them from being accessed by children. The inner packaging should surround and protect the product itself, while the outer packaging should surround and protect the inner packaging.
The inner packaging of child-resistant materials must be sturdy enough to keep children from accessing the contents of the package, even if the outer packaging is damaged. It should also be able to protect the product from potential harm, such as spills or contamination. The outer packaging must also be strong enough to withstand handling and transportation and protect the inner packaging from damage.
6. Reclosable (or Resealable)
Child-resistant packaging should allow users to close the packaging after they have accessed the contents of the package. It helps to ensure that the contents remain fresh and safe to use. It also helps to prevent children from accessing the contents when not in use.
With that said, not all child-resistant packaging may be reclosable throughout the life of the package. Depending on the cannabis product the packaging is made for, it can be a Single Use (or Initial CRP”). It means that it is initially child-resistant but once opened, it becomes no longer child-resistant. If used, the package label must have the message “This package is not child-resistant after opening.”
It could also be a Multiple Use ( or Lifetime CRP) packaging that stays child-resistant throughout its lifetime. This type of child-resistant packaging can be opened and closed or reclosable but remain child-resistant.
7. Durability of Child-Resistant Packaging
A child-resistant packaging must be durable enough to maintain its child resistance throughout its lifetime, including its internal temperature, humidity, and other environmental conditions till its contents have been exhausted. It must also withstand the rigors of normal handling conditions through repeated opening and closing.
Furthermore, the durability of the child-resistant packaging ensures that it is resistant to tampering and prevents the accidental release of the contents during storage and transportation. It guarantees the packaging can withstand the rigors of these conditions without becoming ineffective before it reaches the end consumer.
In addition, the packaging must be composed of materials that cannot interact with the contents of the package in a way that could make them more hazardous.
8. Testing is an Important Component of Child-Resistant Packaging
According to the standards set out in the Poison Prevention Packaging Act (PPPA) in 16 CFR 1700.20, child-resistant packaging requires testing to ensure it is effective in preventing children from accessing the contents of the package. They should also still allow adults to open it easily.
The regulations specify the specific methods and criteria required to test the packaging and the minimum levels of effectiveness it must achieve to be considered child-resistant.
Some of the elements of the child resistance testing requirements for child-resistant cannabis packaging include:
- Testing the packaging using a panel of 1 – 4 groups of 50 children aged 42-51 months and a panel of 100 senior adults aged 50-70 years and young adults aged 18-45 years.
- Testing the packaging to guarantee it is difficult for children to open but easy to open for adults.
- Testing the packaging to ensure it is resistant to tampering and prevents the accidental release of the contents.
- Testing the packaging to ensure that it maintains its effectiveness over time, including through repeated opening and closing.
Specifications The Child-resistant Packaging Testing Must Meet
The packaging tested by these methods must meet the specifications described in 16 CFR 1700.15(b). The major ones include:
- The packaging must maintain a child-resistant effectiveness of 85% before demonstrating the proper means of opening and 80% after doing so. In the case of unit packaging, it must be 80 percent.
- Ease of adult opening for senior and young adults. The packaging must have a senior adult use effectiveness (SAUE) of 90% and an effectiveness of 90% for younger adults.
Manufacturers and distributors of cannabis products must ensure that their packaging meets the required standards for child resistance to help protect children from the potential risks associated with these products.
Conclusion
By understanding these key components of child-resistant packaging, you can ensure that the packaging you choose for your cannabis products is compliant with the regulatory standards of the Poison Prevention Packaging Act (PPPA). This involves working with a packaging manufacturer that understands the importance of these regulations and can produce packaging that complies with them.