Child resistance is a critical requirement for many cannabis packaging systems, but brands and manufacturers don’t have to reinvent the wheel to achieve it.

Packaging professionals say cannabis companies can turn to the 1970 Poison Prevention Act and the Consumer Product Safety Commission for guidance, even if the markets in which they operate don’t require child-resistant packaging.

Cannabis Products Insider recently spoke with Shar Puskala, director of program management and operations at Berlin Packaging, and Charles Haverfield, packaging expert at U.S. Packaging and Wrapping, about different child resistance systems, the role of testing in compliance, and how to encourage child resistance in packaging without barring seniors from consuming cannabis products.

CPI: Can you describe how child-resistant components and closures are applied to jars, boxes and pouches?

SP: Many methodologies are used to balance the requirements of a child-resistant system while remaining “friendly” to seniors. Most of these methods take advantage of a child’s inability to perform multiple functions simultaneously but are still straightforward and easy for seniors. A classic example of a child-resistant closure is the “push and turn” variety. This system works well because, while most young children may be able to “push” something and they may be able to “turn” something, they likely do not yet know how to combine those movements into one dexterous motion.

The smartest applications are simple to understand but hard for little ones to execute – like multiple buttons that must be pressed simultaneously to open a component or a pouch with a hidden flap. A complete list of child-resistant packaging formats, as well as a list of companies that sells them, is available on the Consumer Product Safety Commission (CPSC) website.

CH: Push and turn caps demand motor skills children under the age of 5 don’t yet have, making it difficult for them to open a bottle or jar. This packaging can also feature foil seals at the openings. Seals are difficult to remove for small hands with limited strength, as you need a strong pulling force to remove it, or a sharp object to puncture it. 

Safety locks on boxes have become popular because these locks limit the reach and safeguard children from harm. To open the boxes, these locks must be opened following an exact pattern. One of the most used locks in this regard is the press lock. Small children are not yet able to understand these patterns, making them an effective choice to enhance child safety.

Children can easily shred or perforate thinner, low-quality material, so choosing sturdy and long-lasting packaging for products like cardboard is also a top priority.   

Pouches can be child-resistant with the use of child resistant films and the addition of a certified child-resistant zipper. Some will offer a child-resistant press-to-close zipper for safe and convenient pouch resealability. You can make pouches with high vapor barriers that block moisture, oxygen and aroma from entering or exiting the package too and use materials that are puncture and tear-resistant to improve child safety. Many child-resistant containers and bags also provide an oxygen barrier to help preserve the products.

CPI: How would you describe the requirements cannabis manufacturers and brands must adhere to for child-resistant packaging?  

SP: When child-resistant and senior-friendly (CRSF) packaging is required, the rules are relatively straightforward. While cannabis is not yet legal at the federal level in the U.S., states still leverage the federal protocol established by Congress as a part of the 1970 Poison Prevention Act. However, in some states where cannabis is sold in restricted markets (e.g., only for medicinal use or through a prescription), the requirements may be looser and allow a non-CR system. In this case, it is essential to check with local requirements to ensure full compliance since the requirements change frequently. That said, it’s always safest for cannabis products to be sold in CRSF systems, especially THC-infused edibles like chocolates and gummies. These products may be especially attractive to children and not easily distinguishable from traditional candies.

CH: The requirements are complex, but highly necessary and vary from state to state, so it is always worth any business double-checking regulations. However, every state requires that the packaging of cannabis products be child resistant. The general approach taken by states is to incorporate the pre-existing federal standards established by the Poison Prevention Packing Act of 1970 (PPPA)

Another critical element in child protection is printing and labeling to meet local guidelines. Labelling will help notify the product is not for underage consumption.

Every state except Connecticut, Illinois and Nevada has general language that prevents cannabis packaging from appealing to children. Many require the packaging to be plain and disallow specific imagery that appeals to children.

CPI: What role does testing play in ensuring compliance?

SP: Testing is a required part of compliance and was codified in Title 16 of the Code of Federal Regulations. While lab-built and engineered products may work in an isolated environment, the best way to validate them for intuitiveness and ease of use for seniors — and deterring children — is to test the parts with real people. The testing protocol prescribes the number of participants, gender and age to ensure the test subjects represent the actual users. There is also a limit to the number of systems each person can test to ensure there are no “expert” testers.

It is always the most conservative stance to test the final system for safety and efficacy and to ensure that the CRSF is maintained until the end of the package’s life. This starts with selecting a system most appropriate for the type of product, including assessing needs and requirements like dose size and quantity, the number of openings and closings, material compatibility and more. 

It’s also worth noting that a system is child-resistant, not a component. For example, companies will try to promote a child-resistant “closure,” but this is a false or misleading claim. They really mean that the closure is capable of CR as a part of the full system, but that closure is only compliant if the entire system — the closure, container, branding, and contents of the package — together meets the CRSF requirements per the Poison Prevention Packaging Act. 

Additionally, most closure manufacturers who claim CR are testing limited bottles and materials. Diverting from their default tests could impact the system’s ability to maintain child resistance (e.g., using a larger bottle that could be flipped upside-down and could engage the “push” portion of a push and turn, or using a glass bottle where the CR closure was tested with HDPE). Companies should take the time to understand the testing methods and context around any CR claim before accepting them.

As another reminder, the system is only intended to be child-resistant — not child “proof” or child “safe.” The protocol is written as a timed test and intended to keep children at bay until a caretaker can intervene and remove the dangerous product. It’s not intended to prevent access to a child indefinitely.

CH: For businesses wanting to ensure that their printing and packaging materials meet legal requirements, products need to be tested for the following by lab testing professionals:

  • Label review
  • Tear and perforation testing
  • Abrasion resistance
  • Vehicle transportation simulation
  • Altitude testing
  • UV/sunlight exposure
  • Drop and impact testing

CPI: How can brands make sure child-resistant packaging still works for seniors who consume cannabis?

SP: There are a lot of successful products and mechanisms already in the market that brands can take advantage of. There is no reward for designing “clever,” never-before-seen or complicated multi-step systems if it confuses or irritates seniors, especially in a regulated environment. Children can more easily figure out intuitive designs and simple instructions that they can overcome within 5-10 minutes of trial and error, so the best systems are straightforward to explain but not easy or intuitive to execute.  

Interestingly, studies show that children (4-year-old boys and girls) demonstrate a similar rotational strength (torque) as adult males and females, so strength alone is not a good indicator of CRSF design, and it can be harder for seniors. It’s better to consider a child’s development as it relates to performing multiple functions intuitively and minimize the “strength” requirements. In my opinion, the most reliable CR systems rely on multiple-dexterous moves rather than strength.

CH: To get packages opened, these designs should accommodate certain qualities that seniors have but children do not. This involves reading comprehension, the capacity to follow a multistep process, and, to a lesser degree, dexterity. Directing seniors to the precise area of a package which requires interaction is also a useful strategy. Wording accompanied with arrows makes instructions more obvious and can reduce opening failure rates but is still too complex for children to decipher.

CPI: What are some strategies for designing on-pack branding around child-resistant systems?

CH:  Since cannabis edible firms are tasked with developing unique brand identities and personalities, it can be tempting to use brightly colored packaging, unique typography and creative images. However, maintaining a simple and clean design limits the likelihood of a child being drawn to the packaging. Brands can rely on their unique edibles’ logo design and packaging ingenuity to promote their goods. Subsequently, this guarantees a strong brand identity to pique people’s interests and increase customers.

CPI: Are there any trends or movements you’re seeing in CR packaging, such as improving recyclability?

SP: New York, Vermont, and some Canadian provinces have sustainability requirements for cannabis packaging, pushing the entire industry to find alternatives to the first generation of packaging. From incorporating post-consumer resins (PCR) and bio-resins in plastic packaging to moving manufacturing closer to the point of distribution, cannabis packaging will continue to evolve to meet these new sustainability requirements. However, Berlin Packaging strongly believes that any push for sustainability or any other performance requirement should first and foremost ensure the design meets the product lifecycle in its entirety. 

CPI: Is there anything else you’d like to add?

SP: Cannabis companies should know that developing new, innovative systems takes time and patience. The best choice in this volatile, quickly changing environment may not always be the “fanciest.” The most effective solution is what meets the needs of consumers and showcases the product itself.

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