In order for a bait station to be considered child resistant, it must be tested with children ages 42-51 months using to the protocol detailed in 16 CFR 1700. Testing is performed to ensure that young children are unable to access potentially dangerous substances. Each bait station is tested with at least 50 children (and a maximum of 200 children) to determine the effectiveness of the station.

The child-resistant packaging used for bait stations must meet the following standards:

Effectiveness Standard  Packaging must be tested according to the requirements detailed in 16 CFR 1700.

Compatibility Standard  Packaging must remain effective when the bait station/pesticide when is in active use.

Durability Standard  Packaging must be able to meet the effectiveness and compatibility standards throughout the expected lifetime of the product.

These standards apply to pesticides that are labeled for, or can be reasonably interpreted as being labeled for, residential use and meet the following toxicity criterion:

Acute oral LD50 of 1.5g/kg or less

Acute dermal LD50 of 2,000mg/kg or less

Acute inhalation LC50 of 2mg/L or less

Products that are specifically classified for restricted use and products packaged in large sizes are exempt from these requirements.  More detailed information regarding the requirements, standards, and exemptions for pesticides and bait stations can be found in 40 CFR 157(b).

Summary of Testing Protocol

A full description of the pesticide and bait station testing summarized below can be found in 16 CFR 1700.

Child Testing Protocol

Each test is made up of 1 to 4 panels of 50 children between the ages of 42 and 51 months.

Panels are divided into 3 groups according to age:

30% between the ages of 42 and 44 months

40% between the ages of 45 and 48 months

30% between the ages of 49 and 51 months

The number of boys and the number of girls in each group must be approximately 50%/50% (regulation allows for +/-10% variation).

No more than 20% of the children in each group may be obtained or tested at a single site.

All children must be healthy with no disabilities or injuries that could potentially affect their ability to test the bait station.

Each child may test up to two bait station types.  If a child tests two bait stations, the stations must be different designs.

Children are tested in pairs in a room that is well-lit, free of distractions, and is familiar to them, or in a central location in which they feel comfortable, by a tester who administers the test to no more than 30% of the sample.

To begin, the tester gives each child a bait station containing a placebo and asks them to try to open it without any instruction.  Each child has 5 minutes to try to open the station.  The tester uses a stopwatch to document the amount of time it takes for the child to open the station.

If a child opens the bait station, the test is counted as a failure and he or she is not tested further.  If the second child has not been able to open the station successfully at this point, they are allowed to continue for the remainder of the allotted test period.

If a child (or children) does not open the bait station within the allotted 5 minutes, the tester demonstrates how to open the station and mentions that it is okay for them to use their teeth (if they have not done so already).  The child is then given an additional 5 minutes to try to open the station.  If the child is able to open the station within this period, this is also counted as a failure.

Pass/Fail Criteria:

A test is determined a failure if a child opens or gains access to the contents of the bait station.

For a bait station to pass in the first panel of 50 children, three or fewer must be able to open the station during the first 5 minutes (before the tester demonstrates how to open the station), and 5 or fewer during the second 5 minutes (after the demonstration).  Conversely, if 11 or more children open the station in the first 5 minutes, or if 15 or more open the station within the full 10 minutes, the station fails.  In both cases, no further testing is necessary.

In the first panel of 50 children, if 6-14 open the bait station within the allotted 10 minutes, a second panel of 50 children must be tested.  Depending upon the results of the second round of testing, the station may pass, fail, or require another panel.  Testing stops after the 4th panel regardless of the passing rate.

40 CFR 157(b) – Packaging Requirements for Pesticides and Devices

16 CFR 1700 – Standard for Packaging used by CPSC

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