Packaging
Consumer Research
Great
Lakes Marketing is a full-service marketing research firm
consulting in the area of package closure evaluations and
package design. A distinct area of expertise is the
development of effective opening and usage instructions and
package usability. We answer such questions as:
-
Does
the package hold up during normal, in home use.
-
Do
the instructions correctly communicate how to use the
package and product effectively.
-
Does
the label create interest?
-
Does
it have shelf appeal?
-
Does
the package support the market position?
Video
Taping: Great
Lakes Marketing provides quality videotapes of child and
senior panel testing to help our clients understand how
children access packages or why seniors have trouble opening
packages.
Interviews:
Questions can be added at the end of a standard protocol test,
or an independent survey can be conducted to evaluate: package
designs, ease of understanding directions, tools or skills
needed to open packages, etc.
Focus
Groups: To help clients make design changes or develop
opening and closing instructions, Great Lakes Marketing has
developed a mini-focus group program. We conduct several
mini-sessions with small groups of seniors to evaluate
packages and instructions. By making revisions
throughout the sessions, we are able to create and test the
revisions in a one- or two-day program.
Consulting:
Great Lakes Marketing has been testing CR packaging for the
CPSC throughout the years. This experience translates
into helpful information for our clients. We enjoy
helping you answer questions about your package and giving you
the benefit of our testing experience.
Senior
Events: Great
Lakes Marketing has access to test 10,000-30,000 seniors at
events throughout the country.
For
More Information, Request a Cost Quote or to Initiate Package
Evaluations
Please
contact us when you need assistance in designing or evaluating
your CR package or if you have questions about the testing
protocol. It would be a pleasure for our Child-Resistant
Packaging Team at Great Lakes Marketing to send cost
quotations, time frames and project initiation forms.
Lori
Mitchell Dixon, PhD, Principal
Phone:
419-534-4710 (direct)
Email:
ldixon@GreatLakesMarketing.com
Phyllis
Korte, Coordinator of Child-Resistant Protocol Evaluations
Phone:
419-481-1052 (direct)
Email:
phyllis@GreatLakesMarketing.com
Great
Lakes Marketing
3103
Executive Pkwy, Ste 106,
Toledo,
Ohio 43606-1311
Phone:
419-534-4700
(main)
Fax:
419-531-8950
General
Email: info@GreatLakesMarketing.com
Child-resistant
Lighters Protocol Testing Program
Thank
you for your interest in our Child-Resistant Lighter Protocol
Testing program. We have tested thousands of children
since the U.S. Consumer Product Safety Commission (CPSC)
began considering regulations for disposable and novelty
lighters. We are in contact with the CPSC and have the
knowledge and ability to supply the information that the
agency requires when the testing is completed.
To
begin the testing you need to:
·
Provide 6 surrogate lighters that are identical to the product
that will be on the market, that do not create a flame.
They must make some indication that the lighter has been
activated (usually a tone). At the end of our testing
with the children, the surrogates must be stored so they can
be made available to the CPSC if they are requested. The
surrogates must all be the same color and permanently
numbered.
·
Take force measurements of the surrogates and submit that
information to us, and we will include it in the final report.
(The maker of the surrogate lighters will take these
measurements for you.)
·
Additional information is required from you to include in the
report. This information will be required from you along
with the initial force measurements before testing can begin
(i.e., manufacturing sites, lighter identification such as
model name, model number, description of ignition mechanism,
description of child resistant feature, fuel used, dimensions
& tolerance of production lighter, and dimensions of
surrogate lighter). We will also need you to send us one
production unit (empty) to be included with the report.
The
regulations require the lighter to pass at 90% with a panel of
100 children and 85% with a panel of 200 children. If
the lighter does not pass at 90% using one 100-panel*, an
additional panel of 100 children is required with an overall
85% pass rate.
It
takes about 6 to 8 weeks to complete a test and submit the
report AFTER the surrogates have been made. We send a
report to the CPSC for you. They will send you a letter
saying they received the report. You may not hear
anything else from them; however, you should assume you might
begin importing 30 days from the submission of the report.
Please note that the CPSC does not “certify” your
lighters and nor does Great Lakes Marketing.
In
some cases, you may want to test a small number of children to
learn if the lighter system will work. We recommend that
you make two surrogates and we test 10 older, male children.
This is only done if you are not sure if your lighter will
pass and want a pre-test.
Costs:
We require 50% of the invoice to be paid upon project
authorization (before we begin testing) and the final 50%
after the first 50 children are completed. Please be
advised that you will be charged on a per child basis for any
additional children tested due to the malfunction or repairs
required on the surrogates.
If
two or more different lighters are submitted for testing at
the same time, the cost for each test is reduced by 10%.
We do not experience any economies in testing unless the
lighters are submitted at the same time. No child can
test more than one lighter.
Consulting:
Great Lakes Marketing has been testing child-resistant (CR)
lighters and packaging for the CPSC throughout the years.
This experience translates into helpful information for our
clients. We enjoy answering questions about your lighter
or package evaluation and giving you the benefit of our
testing experience.
Call
or email for more Information, to request a Cost Quote or to
Initiate CR Protocol Evaluations.
Contact
either:
Lori
Mitchell Dixon, PhD, Principal
Phone:
419-534-4710 (direct)
Email:
ldixon@GreatLakesMarketing.com
Phyllis
Korte, Coordinator of Child-Resistant Protocol Evaluations
Phone:
419-481-1052 (direct)
Email:
phyllis@GreatLakesMarketing.com
Great
Lakes Marketing
3103
Executive Pkwy, Ste 106,
Toledo,
Ohio 43606-1311
Phone:
419-534-4700
(main)
Fax:
419-531-8950
General
Email: info@GreatLakesMarketing.com
Child-resistant
Lighters Protocol Testing Regulations
Certification
Requirements Recordkeeping and Reporting (§1212.17)
(a)
Every manufacturer and importer of lighters subject to the
standard shall maintain the following records in English on
paper, microfiche, or similar media and make such records
available to any designated officer or employee of the
Commission in accordance with section 16(b) of the Consumer
Product Safety Act, 15 U.S.C. 2065(b). Such records must
also be kept in the United States and provided to the
Commission within 48 hours of receipt of a request from any
employee of the Commission, except as provided in paragraph
(a)(3) of this section. Legible copies of original
records may be used to comply with these requirements.
(1)
Records of qualification testing, including a description of
the tests, photograph(s) or a video tape for a single pair of
children from each 100-child test panel to show how the
lighter was held in the tester’s hand, and the orientation
of the tester’s body and hand to the children, during the
demonstration, the dates of the tests, the data required by §1212.4(d),
the actual surrogate lighters tested, and the results of the
tests, including video tape records, if any. These
records shall be kept for a period of 3 years after the
production of the particular model to which such tests relate
has ceased. If re-qualification tests are undertaken in
accordance with §1212.14(c), the original qualification test
results may be discarded 3 years after the re-qualification
testing, and the re-qualification test results and surrogates,
and the other information required in this subsection for
qualification tests, shall be kept in lieu thereof.
(2)
Records of procedures used for production testing required by
this subpart B, including a description of the types of tests
conducted (in sufficient detail that they may be replicated),
the production interval selected, the sampling scheme, and the
pass/reject criterion. These records shall be kept for a
period of 3 years after production of the lighter has ceased.
(3)
Records of production testing, including the test results, the
date and location of testing, and records of corrective
actions taken, which in turn includes the specific actions
taken to improve the design or manufacture or to correct any
non-complying lighter, the date the actions were taken, the
test result or failure that triggered the actions, and the
additional actions taken to ensure that the corrective action
had the intended effect. These records shall be kept for
a period of 3 years following the date of testing.
Records of production testing results may be kept on paper,
microfiche, computer tape, or other retrievable media.
Where records are kept on computer tape or other retrievable
media, however, the records shall be made available to the
Commission on paper copies upon request. A manufacturer
or importer of a lighter that is not manufactured in the
United States may maintain the production records required by
this paragraph (a)(3) outside the United States, but shall
make such records available to the Commission in the United
States within 1 week of a request from a Commission employee
for access to those records under section 16(b) of the CPSA,
15 U.S.C. 2065(b).
(4)
Records of specifications required under §1212.15 shall be
kept for 3 years after production of each lighter model has
ceased.
(b)
Reporting. At least 30 days before it first imports or
distributes in commerce any model of lighter subject to the
standard, every manufacturer and importer must provide a
written report to the Office of Compliance, Consumer Product
Safety Commission, 4330 East-West Highway, Room 610, Bethesda,
Maryland 20814-4408. Such report shall include:
(1)
The name, address, and principal place of business of the
manufacturer and importer,
(2)
a detailed description of the lighter a model and the
child-resistant feature(s) used in that model,
(3)
a description of the qualification testing, including a
description of the surrogate lighters tested (including a
description of the point in the operation at which the
surrogate will signal operation – e.g., the distance by
which a trigger must be moved), the specification of the
surrogate lighter required by §1212.15, a summary of the
results of all such tests, the dates the tests were performed,
the location (s) of such tests and the identity of the
organization that conducted the tests,
(4)
an identification of the place of places that the lighters
were or will be manufactured,
(5)
the location(s) where the records required to be maintained by
paragraph (a) of this section are kept, and
(6)
a prototype or production unit of that lighter model.
(c)
Confidentiality. Persons who believe that any
information required to be submitted or made available to the
Commission is trade secret or otherwise confidential shall
request that the information be considered exempt from
disclosure by the Commission, in accordance with 16 CFR
1015.18. Requests for confidentiality of records
provided to the Commission will be handled in accordance with
section 6(a)(2) of the CPSA, 15 U.S.C. 2055(a)(2), the Freedom
of Information Act as amended, 5 U.S.C. 552, and the
Commission’s regulations under that act, 16 CFR part 1015.
