Not for Kids: EPA's Pesticide Packaging Requirements

Posted on 3/11/2019 by Anthony Cardno, CHMM

Child-resistant Packaging. We all know what that is: It’s the package that the five-year-old can get into, but the fifty-year-old cannot. With respect to regulatory compliance, the term has a distinct definition, at least in terms of pesticides.

Section 25(c)(3) of the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) authorizes the Environmental Protection Agency to establish standards for packaging pesticides in order to protect children and adults from serious illness or injury. The EPA specifically issues standards for child-resistant packaging (CRP) in 40 CFR 157.

How EPA Defines Child-resistant Packaging (CRP) 

Child-resistant packaging “means packaging that is designed and constructed to be significantly difficult for children under 5 years of age to open or obtain a toxic or harmful amount of the substance contained therein within a reasonable time, and that is not difficult for normal adults to use properly.” [40 CFR 157.21]

Which Pesticides Need CRP?

A pesticide must be distributed in child-resistant packaging if it meets two criteria:
  1. Use Criterion – the product is either directly recommended for, or could be reasonably interpreted as intended for, residential use.

  2. Toxicity Criterion
    1. Has an acute oral LD50 of ≤ 1.5 mg/kg
    2. Has an acute dermal LD50 of ≤ 2000 mg/kg
    3. Has an acute inhalation LC50 of ≤ 2 mg/L
    4. Is corrosive to the eye (irreversible ocular tissue destruction) or causes corneal involvement or irritation persisting for ≥ 21 days
    5. Is corrosive to the skin (tissue destruction into the dermis and/or scarring) or causes severe erythema or edema at 72 hours
    6. Has such characteristics that, based upon human toxicology data or other such evidence, the EPA determines there is a serious hazard that child-resistant packaging could reduce

Standards for Pesticide Manufacturers 

The manufacturer of the pesticide must meet the following standards, per 40 CFR 157.32:
  • Effectiveness – tested to per the Consumer Product Safety Commission’s (CPSC) standards at 16 CFR 1700.20 to meet specifications at 16 CFR 1700.15(b)
  • Compatibility – the child-resistant packaging must be compatible with the pesticide being placed in it, determined through appropriate scientific evaluation
  • Durability – continue to meet the effectiveness and compatibility standards for the reasonably expected lifetime of the package, taking the customary number of openings and closures for that type of package into account

CRP Certification

As part of registering a pesticide for use in the United States, the manufacturer must submit a certification to the EPA that the package meets the child-resistant packaging standards. The certification must include:
  • The name and EPA registration number of the product
  • The manufacturer’s name and address
  • The date of submission of the certification
  • The name, title, and signature of the company official making the certification
  • A statement that the product meets the standards at 40 CFR 157.32

Recordkeeping for Manufacturers 

For as long as the registration of a pesticide required to be in child-resistant packaging is in effect, the manufacturer must retain detailed documentation about the package, the testing of the child-resistant portion of same, the certification, and compatibility and durability data. The manufacturer must also be prepared to share such documents with the EPA when requested [40 CFR 157.36]

In Chicago: Complete Environmental Regulations Training, April 11–12

Are you the go-to person for all things EHS at your facility? Join us in Chicago on April 11–12 for the nationally trusted Complete Environmental Regulations Workshop.

Understanding the air, water, and chemical regulations that apply to your facility will help you communicate clearly and confidently within your organization and better defend your business against costly fines, penalties, and future liability. This workshop covers the critical elements of major EPA programs that impact industrial facilities every day.
Can’t attend live? Check out the Complete Environmental Regulations Online Course , The online course is packed with training content, tutorials, resources, and FAQs that clarify and simplify the complex, overlapping EPA rules you must know. 

Tags: environmental compliance, EPA, FIFRA, pesticides, toxic chemicals

Find a Post

Compliance Archives

Lion - Quotes

The price was reasonable, the time to complete the course was manageable, and the flexibility the online training allowed made it easy to complete.

Felicia Rutledge

Hazmat Shipping Professional

The course was very well structured and covered the material in a clear, concise manner.

Ian Martinez

Hazmat Shipping Professional

The instructor was excellent. They knew all of the material without having to read from a notepad or computer.

Gary Hartzell

Warehouse Supervisor

Best instructor ever! I was going to take my DOT training w/a different provider, but based on this presentation, I will also be doing my DOT training w/Lion!

Donna Moot

Hazardous Waste Professional

You blew the doors off the competition!

Stephen Bieschke

Facilities Manager

The instructor was very knowledgeable and provided pertinent information above and beyond the questions that were asked.

Johnny Barton

Logistics Coordinator

Convenient; I can train when I want, where I want.

Barry Cook

Hazmat Shipping Professional

I tried other environmental training providers, but they were all sub-standard compared to Lion. I will not stray from Lion again!

Sara Sills

Environmental Specialist

I was able to present my scenario to the instructor and worked thru the regulations together. In the past, I attended another training firm's classes. Now, I have no intention of leaving Lion!

Diana Joyner

Senior Environmental Engineer

Lion is easily and consistently the best option for compliance training. I've learned new information from every instructor I've had.

Rachel Mathis

EHS Specialist

Download Our Latest Whitepaper

Find out what makes DOT hazmat training mandatory for employees who sign the hazardous waste manifest, a “dually regulated” document for tracking shipments.

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.