Is a Child Resistant Cap Required for Bike Chain Lubricants?
My company is developing a bike chain lubricant. We are trying to determine if we need a Child Resistant (CR) cap. In reading the CR laws, it seems like we would need a CR cap because the lube contains a fair percentage of hydrocarbons. However, when I go into the bike dealers, 90-95% of the lubricants on the shelf do not have CR caps. What is the reason that hydrocarbon car and bike lubricants do not widely have CR caps?
Under the Poison Prevention Packaging Act of 1970 (PPPA), the U.S. Consumer Product Safety Commission (CPSC) can establish standards requiring special packaging (also referred to as child-resistant packaging) for any household substance if it finds that the product presents a risk of serious injury or serious illness to children under five and if the special packaging required by such standard is technically feasible. A list of substances requiring special packaging under the PPPA can be found in the Code of Federal Regulations (See 16 C.F.R. §1700.14). Included in the list are hazardous substances containing low-viscosity hydrocarbons, or substances that “contain 10 percent or more hydrocarbons by weight and have a viscosity of less than 100 SUS at 100 °F.” Products with a higher viscosity, or that meet other listed exceptions, do not require a CR cap. Each formula, and the specific packaging used, should be evaluated individually. We would suggest that you consult legal counsel with respect to your specific product.