United States              Prevention, Pesticides       February 1994
            Environmental Protection       And Toxic Substances       PDA  Jin c QA  nni
            Agency                  (7506C)               hPA-/3t>-F-94-003

            FOR   YOUR   INFORMATION
     In 1972, regulations requiring child-resistant packaging (CRP) for pesticides were
      first proposed by the Federal Drug Administration (FDA).

     In 1976, EPA was given the sole jurisdiction for CRP for pesticides.

     In 1979, EPA published regulations requiring child-resistant packaging (CRP) for
      residential use pesticides.


     All residential use pesticides meeting certain toxicity criteria 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. Furthermore, the registrant must have data
      on file to substantiate their certification.

     EPA has over 4,000 pesticides products with CRP certifications on file.

Summary of Regulations

     EPA requires registrants to comply with its CRP regulations before they can
      register residential use pesticides for sale and distribution in the United States.

     All residential use pesticides meeting one or more of six toxicity criteria
      must be in CRP. The pesticide manufacturer must certify to the EPA that
      the product, as packaged, will meet certain standards of effectiveness,
      compatibility, and durability. Furthermore, the registrant must have data
      on file to substantiate the certification.

     The six toxicity criteria are acute oral toxicity, acute dermal toxicity, dermal
      irritation, acute inhalation toxicity, eye irritation, and human experience data
      (lexicological data, use history, or injury data).
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      For pesticides that meet the CRP toxicity criteria, all sizes of products must be
       packaged in CRP with the exception of certain large sizes.  EPA does not have a
       noncomplying size provision for the elderly and handicapped.

      In addition to the large size exemptions, exemptions are provided for pesticides
       classified for restricted use,  or based on a lack of toxicity or technical factors.
       Restricted use pesticides are exempted because they must be used by or in the
       presence of a certified applicator.

Pesticides Requiring CRP. Types of CRP. and Use Patterns

      Some of the types of pesticides that require CRP are toilet bowl cleaners,
       mildewicides,  rodenticides, insecticides, flea and tick products for cats,  dogs, ant
       and roach products, lawn and garden products, weed killers, fungicides, marine
       paints, herbicides, pool chemicals, disinfectants, and laundry bleaches.

      Some of the types of CRP used for pesticides can involve a 31/2 gallon pail of
       swimming pool chemical, a 12 ounce bottle of toilet bowl cleaner, a 35 pound bag
       of weed killer, a gallon paint can, a 2 ounce stick of insect repellent, a  flea and
       tick collar, an insect repellent strip, a gallon plastic bottle, or a small bait station
       for a mouse or ants.

      Some of the pesticides requiring CRP are designed  for use by removing the
       product and reclosing the package.  There are others that involve using the
       package as the applicator (toilet bowl squirt type packages), and still others
       involve having the pesticide in use and around children (although reportedly out of.
       sight and reach)  for prolonged periods of time.  For example, flea and tick collars
       may be on the pet for 30 days.

Deaths and Injuries

      In 1968-70, the three years preceding the enactment of the Poison Prevention
       Packaging Act, there were 23 deaths per  year to children under 5 years  of age due
       to pesticides.  In  1989 (the last year for which data are available), there was one
       death to a child under 5 years  of age from pesticides.

Future Actions

      EPA has a requirement under the Federal Insecticides, Fungicides, and
       Rodenticides Act (FIFRA)  that pesticide  manufacturers must report to EPA any
       adverse effects from pesticides (FIFRA 6(a)(2)).  A data base of incidents from
       pesticide exposures has recently  been developed, and may enable EPA to ascertain
       patterns of problems with certain pesticides.

       EPA is monitoring compliance with the CRP regulations by reviewing consumer
       complaints as well as injury incidents.  Consumer complaints, which do not
       involve injuries may be referred to the pesticide manufacturer for investigation and
       follow-up with the Agency.

       EPA agrees with the Consumer Product Safety Commission (CPSC) in
       encouraging "elderly friendly" packages, especially since our regulations do not
       allow the elderly to get a nonchild-resistant size of a pesticide.

       EPA will have CRP protocol testing changes consistent with those of the CPSC,
       as FIFRA mandates.
Related Measures
      EPA is concerned that use patterns which leave the pesticide in areas where
       children play may present exposure hazards that CRP alone cannot address.
       Consequently, the Agency  has adopted numerous auxiliary safety measures  to
       reduce exposure to these pesticides.

      EPA has begun to require more explicit information regarding bait protection to
       be printed on labels for rodenticide baits that are not sold in ready-to-use, tamper-
       resistant bait stations.

Testing Strategies

      Ready-to-use bait stations or other devices that have the pesticide in a contained
       "package" which children could come in contact with must demonstrate that the
       pesticide will not come out of the package if the child handles the package,
       abuses, bite;;, or sucks it, etc.

      EPA has developed testing standards to protect children  from access to
       ready-to-use bait stations.

      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.