Section 1500.121 - Labeling requirements; prominence, placement, and conspicuousness

1 Analyses of this regulation by attorneys

  1. CPSC Issues “Unofficial” COVID-19 Guidance on Personal Protective Equipment, Disinfectants

    McGuireWoods LLPDiane FlanneryNovember 3, 2020

    l outside the jurisdiction of CPSC, and guidance from the National Institute for Occupational Safety and Health (NIOSH) and the Occupational Safety and Health Administration (OSHA) should be considered instead.Disinfectant and Cleaning ProductsAs authorized by the Federal Hazardous Substances Act (FHSA) and Poison Prevention Packaging Act (PPPA), the CPSC regulates certain household cleaning products and soaps. A household cleaning solution/soap falls under the FHSA if: “(1) the substance or mixture of substances may cause substantial personal injury or substantial illness during customary or reasonably foreseeable handling or use, including reasonably foreseeable ingestion by children; and (2) the substance or a mixture of substances is toxic, corrosive, an irritant, a strong sensitizer, is flammable or combustible, or generates pressure through decomposition, heat or other means.”If the product falls within the scope of the FHSA, the label must conform with the requirements found at 16 CFR §1500.121. The CPSC website offers additional guidance on the FHSA.The webpage also notes that the PPPA requires “certain household products containing any of the substances listed in 16 CFR §1700.14 to have special packaging to protect children from serious injury or illness from handling, using, or ingesting such substances.”