Before starting a test, you should review the test protocol carefully to make sure that you comply with all of the testing requirements. If you choose not to test a package yourself, we recommend that you find a qualified child-testing laboratory in the United States to perform the test. A list of test firms known to CPSC staff is available from the Office of Compliance.
The test uses at least one, and up to four, test panels of 50 children between the ages of 42 and 51 months to test child-resistant packages. Each panel is divided into three groups–30 percent of the children will be of age 42 through 44 months old; 40 percent of the children will be of age 45 through 48 months old; and 30 percent of the children will be of age 49 through 51 months old. Approximately one-half of the children in each group must be boys. The test procedure allows a 10 percent variation in the number of boys and girls in each group.
Each child in the test panel must have no illness, injury, or disability that would interfere with the child’s ability to test the package. No child may test more than two packages. If a child tests two packages, the packages cannot have the same design. This keeps the child from learning how to open the package.
Two children at a time participate in the test in a well-lighted room that is familiar to them and is free from distractions. The tester gives each child an empty child-resistant package and asks the children to try to open it. Each child has 5 minutes to try to do this.
If a child opens the package, he or she is not tested further and that child’s test is counted as a failure of the package to be child resistant. The tester shows any child who does not open the package in the first 5 minutes how to do so and also tells any child who has not tried to use his or her teeth to try to open the package that it is all right to do so. The child then has 5 more minutes to try to open the package. Any child who succeeds in opening the package in the second 5 minutes is also counted as a failure of the package.
For a package to pass, at least 85 percent of the children tested must be unable to open the package before the children receive the demonstration of how the package works and 80 percent after the demonstration. For the first 50-child test panel, if five or fewer children open the package, the package passes. If 15 or more children open the package, the package fails. In either case, no further testing is necessary. If six through 14 children in the first panel open the package, a second test panel of 50 children needs to be tested. Depending upon the results of that test, the package may pass, fail, or require more testing. Please refer to the regulation for more detail. Testing stops after a fourth panel of children, if the test goes that far.