Over the last twelve months, we have seen a significant uptick in Consumer Product Safety Commission (CPSC) recalls of products that do not have required child-resistant closures. Under the Poison Prevention Packaging Act (PPPA), child-resistant packaging is required for prescription drugs, over-the-counter drugs, dietary supplements, and cosmetics that contain chemicals listed in CPSC's regulations
. Since 1992, CPSC has conducted 28 recalls for PPPA violations. Six of these recalls occurred since November of last year, and five were of products that contained lidocaine with concentrations of 4-5%. (The only other recall of a product containing lidocaine that failed to use child-resistant packaging was in 2015.) The increase in such recalls suggests that CPSC's Office of Compliance and Field Operations has been conducting a targeted enforcement effort of PPPA requirements, focusing, at least initially, on products containing lidocaine.
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