Are TricorBraun ANZ's Child Resistant Caps CR-Certified?

Seeking to launch a new pack with a child resistant closure? Do you understand your legal obligations? Do not be complacent, not all child resistant closures are the same. If you export your filled packs to Europe or China then you must meet the ISO 8317:2015 standard and for the USA their 16 CFR 1700 standard.

The code changed several times since 2007 and it is no longer simply the closure that must be certified. Its now the total pack that must be certified. Legal responsibility now rests with the sponsor, which is the finished filled pack owner. Don’t expose yourself to a legal risk, please read the below attachment that gives you comprehensive information on your responsibilities once you use a Child Resistant Closure.

We Often Get Asked the Above Question. It's a Valid Question - But is It the Right Once to Ask Though? (Hot Tip: It's Not)

The Therapeutic Goods Administration (TGA), in their latest Therapeutic Goods Order (TGO) 95 specifies that it is the sponsor’s (i.e. brand owner’s) responsibility to ensure that the whole PACK (cap AND bottle) passes Child-Resistant testing. This means that testing should be done on the full pack the sponsor plans to use. Both the cap and the exact bottle. It requires a separate testing for each bottle material used (generally Glass, HDPE and PET). TGO 95 goes on to specify the guidelines around how to conduct the tests and which bottle to use if there are, for example, three different bottle sizes that use the same CR cap. This is very different to the old TGO 65 that focused only on the cap. This was phased out in 2008.

Most importantly, it is up to the brand owner to ensure that the whole pack is CR-tested and certified. Factors like specific application torques and the removal torque the consumer will experience must also be considered before getting these tests done.

Child-Resistant vs Child-Proof

TGO95 further stipulates that the term ‘child-resistant’ is not synonymous with ‘child-proof’. “Child-resistant packaging is only the last in a series of protective measures, and does not release parents or guardians from their duty to keep hazardous products out of the reach of children.

“Child-resistant packages provide only the safeguard of delay in access, in the protection of children against accidental poisoning. Other precautions need to be taken by parents, legislators, educators and marketers to ensure the safety of children where these products are kept.

Child-Resistant & Elderly-Friendly Packaging

Wrap-rage is real. It is the common term for the extreme levels of frustration one can experience while trying open or unseal hard to open packaging. This is why industry bodies like Arthritis Australia have an Accessibility Design Division. Among other things, they help identify and even score packaging based on criteria such as Ease of Use and Easy to Open.

TGO 95 not only ensures CR caps are child-resistant. It also factors in the 50 to 70 year age group during testing, “to better reflect the age group that may experience difficulties in opening child-resistant packages”.

“While this group is not intended to represent the population as a whole, it covers adults who can read the instructions and would be expected to implement them with a high likelihood of success. Older people may be perceived to be more likely to need help in opening such packages.

Getting Your Pack Certified

We can provide testing for packs our caps will be used for:

ISO 8317:2015 - This is the global standard and is required if you intend to export your filled packs to Europe and China. For this we need 300 sample bottles and the approximate cost is $11,500 subject to our review of your exact packs (Please note we no longer test to AS1928-2007). For the USA market we now test to the US 16 CFR 1700 standard.

With both these tests your goods will be independently submitted to both a child’s panel and a senior adult’s panel as per the requirements of TGO90 and a certificate provided to you stipulating your exact pack has been confirmed to pass the guideline.

These are generally accepted application torques. Specific closures may require specific application torques which differ from those listed above. Check with your closure manufacturer for specific information.

Note: Immediate removal torque values are approximately 40-80% of application torque values. Production capping equipment should be adjusted to produce similar immediate removal torque values. It is important you test packs 30 days after application as this will be more indicative of the removal force the consumer will experience opening your finished pack. This is very critical for any torque dependent child resistant package.