United States Prevention, Pesticides February 1994
Environmental Protection And Toxic Substances EP A 7 3 5-F- 9 4 - 0 0 2
Agency (H7506C)
&EPA Questions & Answers
Pesticides and Child-Resistant Packaging
Q. Who has the authority for child-resistant packaging (CRT) for pesticide
products?
A. EPA has the authority for CRP for pesticides; however, EPA's CRP standards are
consistent with those of the Consumer Product Safety Commission (CPSC).
Q. Are EPA's CRP regulations similar to CPSC's?
A. Yes, EPA's and CPSC's CRP standards are similar. However, there are some
differences in the regulations, which are:
• The registrant must comply with EPA's CRP regulations before they can
register residential use pesticides for sale and distribution in the United States;
• The pesticide manufacturer (not the Agency) bears the burden of proof
regarding compliance with the CRP regulations;
• Residential use pesticides meeting one or more of six toxicity criteria (not just
acute oral toxicity) must be in CRP;
• The pesticide manufacturer must certify to the EPA that their product, as
packaged, will meet certain standards of effectiveness, compatibility, and
durability. The manufacturer must have data on file to substantiate their
certification;
• EPA requires CRP for all sizes of packaging for pesticides that are subject to
the CRP regulations with the exception of certain large sizes. EPA does not
have a noncomplying size provision for the elderly and handicapped.
Q. Will EPA use the new CRP protocol test being developed by CPSC?
A. Yes, FIFRA mandates that EPA's CRP standards be consistent with those of the
CPSC.
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Q. How long has EPA required CRT?
A. Since 1979.
Q. What types of products must be contained in CRP?
A. Some of the types of pesticides that must be contained in CRP are toilet bowl
cleaners, mildewicides, rodenticides, insecticides, flea and tick products for cats and
dogs, ant and roach products, lawn and garden products, weed killers, fungicides,
marine paints, herbicides, pool chemicals, disinfectants, and laundry bleaches.
Q. What else is EPA doing to prevent injuries and promote child safety?
A. EPA is monitoring compliance with the CRP regulations by reviewing consumer
complaints as well as injury incidents. The consumer complaints which do not
involve injuries may be referred to the pesticide manufacturer for investigation and
follow-up with the Agency regarding their findings.
EPA is concerned that some of the pesticide use patterns present exposure hazards
that CRP alone cannot address. Consequently, the Agency has adopted numerous
auxiliary safety measures to reduce exposures to these pesticides.
Ready-to-use bait stations or other devices that have the pesticide in a contained
"package" that is accessible to children for prolonged periods of time must
demonstrate that the pesticide will not come out of the package if the child handles
the package (abuses, bites, sucks, etc.).
EPA has developed testing protocols to protect children from ready-to-use bait
stations that may be in prolonged use in the home. If the package is considered small
enough that a child might swallow it, certain tests are requested to demonstrate that
the child cannot swallow, choke, or bite off a piece of the package.
Q. What size packages are exempt from CRP?
A. The pesticide package sizes exempt from CRP include products that are 50 pounds or
greater for non-liquid products, 5 gallons or greater for liquids products, except for
liquid swimming pool chemicals, which must be greater than 7:5 gallons to be
exempt.
Q. Are there any CRP exemptions based on a lack of toxicity or technical factors?
A. Not at this time. There were two technical factor exemptions .in 1981 based on CRP
availability, which have long since expired.
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Q. What is EPA doing about bittering agents?
A. EPA currently permits bittering agents to be added to rodenticide baits provided the
bait continues to meet palatability and mortality requirements (rodents still eat it and
die), and the pesticide manufacturer makes no claims of safety for the product.
Pesticide manufacturers are permitted to indicate on the label that a bittering agent is
in the product. However, the pesticide manufacturer may not use the presence of the
bittering agent as a basis for stating or implying that the bait is safer than others,
and/or that users need not take bait protection requirements seriously. The EPA is
currently monitoring the CPSC's regulatory approach to bittering agents, as well as
state legislation.
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