 Hello everyone. Thank you for attending today's webinar, the Poison Prevention Packaging Act. My name is Stefan Lee. I'm with the Small Business Ombudsman team and I will be presenting the information today. A couple of things before we get started here. The webinar is being recorded and a copy of the video will be available on YouTube. PDF of the slides will be distributed via email to all registrants, not just attendees, and a link to download the slide deck will be available on the Business Guidance page. If you have any questions, please ask them through the GoToWebinar interface so that we can keep track of them. If there are any unanswered questions, they will be addressed in the days following the webinar. Throughout this presentation, there are a few polling questions where you can gauge your knowledge of the requirements, so I highly encourage you to participate. With that, let's get started. Today, we're going to be going over the special packaging requirements certification related to the Poison Prevention Packaging Act, section 15b reporting, and then we'll go over any questions and answers that may have been asked. These are a couple of pieces of information, cpsa.gov slash pppa. That is the short link for our Business Guidance page. It has all the staff information about the Poison Prevention Packaging Act, and 16 CFR part 1700 is where the Poison Prevention Packaging Act requirements are codified. Throughout this presentation, I will be referencing CFR a lot. There's a lot of citations to kind of jump back and forth through, so I highly recommend, if you haven't already, to go check out ecfr.gov. This search bar right here, you can type in the CFR reference and it'll take you to that particular text. Special packaging is required for certain household substances. The specific list of substances that require the special packaging is at 16 CFR section 1700.14a. If it's not on this list, it is technically not subject to the pppa. The requirements can be amount and form specific. We'll see examples of that later in this presentation. And cpsa regulates the package and not the substance, so that's kind of important to consider when we're talking about things like drugs that require special packaging. Because cpsa doesn't regulate the drug, that would fall under the Food and Drug Administration. The special package requirement applies to the immediate package, not any kind of secondary packaging or another package outside of that immediate package. The responsible party is going to be the domestic manufacturer or the importer record. For the purposes of the pppa, the manufacturer would be the entity placing the regulated substance in the packaging. So here we're going to be defining a household substance. That's going to be any substance that is customarily produced or distributed for sale for consumption or use or customarily stored by individuals in or about the household and which is a hazardous substance per the Federal Hazardous Substances Act, a food drug or cosmetic per the Federal Food Drug and Cosmetic Act, or a fuel stored in portable container used in the heating, cooking, or refrigeration system of a house. This definition is available at 16 CFR section 1700.1B2. And we'll define a package which is going to be the immediate container or wrapping in which the substance is contained for consumption use or storage by the consumers. This would exclude bulk packaging or any kind of shipping or outer packaging unless that is the only package for the substance. Getting into a little finer detail here, what is special packaging and that's going to be packaging that is difficult for children under five years of age to open but is not difficult for adults to open. This is commonly referred to as child resistant and senior friendly or simply child resistant packaging or CRP which stands for child resistant packaging. A lot of people will erroneously refer to it as child proof packaging. It is very important to note that this is child resistant, not child proof. It's not a guarantee that it's going to prevent all children from accessing. Under the PPPA, special packaging has four provisions. These are going to be found at 16 CFR section 1700.15. The first is going to be general requirements. The special packaging, namely the closure, has to function for the lifetime of the package and the substance must not affect the closure mechanism. So for example, if you have a high volatile liquid and it starts melting the plastic of the closure and now the closure starts either gumming up or the special packaging function no longer works, that would not be allowed. The effective specifications, that's going to be the child test and the senior adult or the younger adult test. The reuse of special packaging, basically that substances that are subject to the provision may not reuse the special package. And then there's the restricted flow provision, where no more than two milliliters of a substance is dispensed when the package is inverted, opened and taken, squeezed or activated once. All right, so we're coming up on our first polling question here. I only sell products to businesses. Are my products subject to the PPPA? I'm going to give you guys a few seconds to answer here. All right, and it looks like most people here have voted yes. So the answer actually is going to be, well, it really depends on a variety of factors. So it's a bit of a trick question here. This is based on the updated guidance on substances not intended for household use. This letter was issued February 18th, 2022. It is available under the enforcement guidance section at the PPPA business guidance page. It was published as a result or rather posted as a result of marketplace changes, namely increase in online sales, where the manufacturer or repackager may sell products intended for commercial use, but downstream distributors may resell to consumers. The letter effectively states that there's no institutional use exception under the PPPA, so firms can't simply label their products as out of scope or use a statement like for institutional use only. What that basically means is that manufacturers who do strictly B2B or business to business sales may need to take a look at their distribution, their distribution model and chain to see how the products or if the products are going to be diverted into the consumer marketplace and take steps to prevent that. All right, our second question here. Can you use the same cap on a different bottle than the one that was tested, right? And it looks like a large majority have said no. And the answer here, well, that's going to depend. Testing has to adequately reflect the final product. So glass bottles may be inherently easier to open due to a lower coefficient of friction between the bottle and the closure threading, different plastic material or even different sizes may make it easier to grip and open the bottle. So effectively what this means is that you need to make sure that whatever was tested adequately represents the product that is being manufactured. Another question here. If the type of plastic use is changed, let's say from high density polyethylene to polypropylene, do I need to retest my package? All right, and it looks like a majority of you have said, yes, it does need retesting. And that's generally going to be correct. Different types of plastics can behave differently during the protocol testing, you know, whether the plastic is going to be softer or harder, whether it has a higher friction or lower friction. So therefore retesting would be required for different plastic types. All right, so here is a list of substances or rather a list of drugs that require special packaging under the PPPA. The regulation does specify whether this is going to be an oral dose or a general use consumption. The regulation will also specify any kind of prerequisites or exemptions. For example, there are petitions for exemption of the PPPA packaging requirements that are submitted as part of 16 CFR Part 1702. You'll see a lot of those under the prescription drugs. So under that specific regulation, there's a list of specific prescription drugs that are exempt from the special packaging requirements. If you look over here over the counter drug is also included. This is based on when the drug was switched from prescription only to over the counter. And that is going to be based on the application that was submitted to the FDA on or after January 29, 2002. It is going to be substance specific, so not necessarily firm specific. So let's say one firm submitted their petition first for a particular substance. So now that substance is considered an over the counter drug based on this regulation or rather that is subject to this regulation. And here's a list of other substances that are not necessarily drugs. Again, the regulation is going to specify any kind of form or prerequisites or exemptions and same with the drugs. There can be petitions submitted for exemptions from the special packaging requirements. Here's an example of one of the regulatory texts, aspirin, which is going to be the first substance. If you notice here, it does say dosage form intended for oral administration. There's a couple of exemptions that are listed under this regulation. The one thing I do want to kind of call out is these three provisions under 1700.15. It says that aspirin needs to be in package that meets A, B, and C. So that's going to be the first three provisions. And then if you look at this next one, which is going to be for sodium and potassium hydroxide, you'll notice that it has a specific requirement, depending on whether it's dry form or all other types of forms. It's going to be either 10% or 2%. And then if you look at the provisions here, it's only going to be the first two provisions compared to the aspirin one. So C is missing from this particular substance. And that's going to be for all of the regulated substances. Each one will have its own set of provisions that it is subject to. All right. Next question here. Are cannabis and similar products subject to the special packaging requirements of the PPPA? All right. And it looks like most people have said yes, it is required. So this is going to be a bit of a trick question. So 16 CFR section 1700.14A4 does have a requirement for controlled drugs that are in dosage form intended for oral administration that are also subject to the comprehensive drug abuse prevention and control act to require special packaging. So since marijuana is a schedule one drug under this act, it technically requires special packaging if it is in a dosage form intended for oral administration. Having said all of that, individual states do sometimes incorporate 16 CFR parts 1700 as part of their state laws. And responsible parties should contact the agency overseeing the state requirements for more information. That is not something that CPSC is enforcing. It is not a CPSC requirement. The question here. Can equivalent standards such as an ISO EN or CSA standard be used to certify compliance with the PPPA? Right. And it looks like just about half, a little more than half has said no. And that's largely going to be correct. There are differences between the various standards and the PPPA, such as deviations in the testing protocol and even what's considered a pass fail for the overall test. There's a big asterisk here to consider. There was an enforcement discretion from the CPSC during the height of COVID period. So packages tested between June 25th 2020 to June 30th 2022 were allowed to use these equivalent standards or these other international standards to comply with the special packaging requirements. There is an FAQ on this. I highly recommend you look at the extension letter dated November 12th 2020 on the PPPA business guidance page for more information. All right. So we're going to get into some exemptions and exceptions here. So bulk drugs intended to be repackaged by pharmacists aren't subject to the special packaging requirements. Prescription drugs at the request of the patient or physician basically if a consumer or a doctor basically says they don't want the special package, those don't have to be in special packaging. Prescription drug samples also don't require it. There is an FR notice related to this. Aftermarket drug organizers like pill minders or a little containers where you put the pills in to remind you to take it every day or every morning, something like that. Those are aftermarket products that aren't subject to the special packaging requirements. And then finally we have products that are not used in or around the household. Again, bear in mind that updated guidance on substance is not intended for household use. There are some FAQs there and some additional information that may provide a little more information on this particular area. The PPPA has something what we like to call the non-compliant package provision that's going to be found at 16 CFR section 1700.5. Basically allows one non-popular size to use conventional packaging. So basically any package that doesn't use special package closure that assumes that all other sizes are using special packaging. It has to be labeled using one of these two statements. Liquid drain cleaners that contain 10% or more of sodium or potassium hydroxide are not allowed this particular exemption. That is because under that CFR reference there any such products that don't use special packaging are a ban hazard substance. And this does not apply to prescription drugs. So there's just no way that prescription drugs can kind of comply with these particular provisions. So I did mention that it has to be a non-popular size. So if the sale volume changes, firms are expected to switch packaging in a timely manner. This one size exemption also does apply to different doses. So for example, let's say you have an 81 milligram product and a 200 milligram product. Each of those would be allowed a non-compliant package. It's also form dependent. So let's say you have a gel cap and a tablet. So each of those different forms would also be provided a non-compliant package size. Next we're going to go over the child test protocol. It is a lot of information but it is found all at 16 CFR section 1700.20a2. So the child test protocol is essentially up to four panels of 50 children that are tested in pairs. The age range is anywhere between 42 and 51 months old distributed in the percentages that you see listed there. There is a gender restriction which basically means that 50 percent has to be boys and 50 percent has to be girls. There is a 10 percent difference allowed between the genders for each of the three age categories. There's a tester restriction. So no more than 30 percent of the children can be tested by a single tester. And also a site restriction which basically means no more than 20 percent of the children can be from a single site. Continuing along, the child test protocol consists of a five minute period where the children are given the package to try and open. The package is then taken away from them and there's a demonstration to show the opening of the package, just normal opening, no exaggerated movements or repeats or anything like that. And then the children are given another five minute period to try and open the package again. During the second five minute period, if neither of the children were using their teeth, the testers are instructing the children then that they may use their teeth. For it to be a special package, it has to be effective at least 85 percent pre-demonstration and then 80 percent post-demonstration. And a failure is going to consist of a leaking package, a package that's opened or gained access through any means, like chewing a hole through the packaging or just normal opening. For unit dose packaging, that's going to be gaining access to a number of units, maximum of nine, which produces a serious personal injury or illness to a 25 pound child. This is commonly referred to as an F value, which is discussed later on. So I mentioned earlier that it's four panels of 50 children. So that effectively is to try and reduce the number of children that are going to be tested at any given time. So with the first panel of 50 children, if you have zero to three failures in the first five minutes and then zero to five failures in the full 10 minutes, that's automatically going to be a pass. You don't have to test the next panel of children. If you fall into the continue column and on either side, so for example, let's say you have four failures before the first five minutes or during the first five minutes and then five failures total, one of them still falls into the continue column, therefore you would need to test another 50 panel of children. Here's our unit dose example. So this is just a mock example of how many children access however many unit doses or how many blisters rather. The data is provided in two different ways. The first table at the top shows however many children were able to access that many units specifically, whereas the second table shows a consecutive number of failures. So the first column that says one plus, so that's any number of children that were able to open at least one unit and then two units, three units, so on and so forth. The data is kind of easier to look at for the second half or the second set because depending on what you're putting into the actual blister pack, you may have different F values. So compliance of the package can depend on that F value, which is why it's generally recommended to run the test all the way up to nine plus in case the package is suitable for other substances. This is bearing in mind that whatever what you're putting into that package may affect the children's ability to open it. So let's say the shape of the pill is very different or it's a softer pill, which means they can't kind of poke it through the actual foil package. So these are all things that need to be considered if you plan on using a different substance for that unit dose package. Same thing is going to apply for the failures and the number of panels that need to be used. So if you look at here, if you have an F value of one, that's going to be 15 children that opened it, so that's going to be an automatic failure. If you had 10 or if you have an F value of three, that's going to be 10 children that that opened it. So you have 10 failures. So that falls into the continue column. And then finally, if you have an F value of six, that during this test, only five children had gained access. So that's probably going to be a pass. If you need assistance with F value determinations, you can send an email to regulatory enforcement at cpsc.gov with all of your data. CPSC staff will not determine the F value for you. They'll only indicate if the firms propose F value is appropriate based on whatever data that they're submitting. Next, we're going to be going over the senior adults test protocol. So that's always going to be 100 adults that are tested individually. Like the child test, there is an age range from 50 to 70 split into three different age categories. There's also a gender restriction, but is more biased towards females. So that's going to be 30% male and 70% females. There's also a tester restriction, which is going to be 35%. And then a site restriction, which is going to be 24%. This does differ from the child test. So that is something to keep in mind. There's also a consent form that's associated with the senior adult test protocol. They're given five minutes to open and close one package and then one minute to open and close a second package. Seniors that are not able to actually do this test are given a screening procedure for their ability to open a conventional package. So that's typically going to be a regular threaded closure and then a snap closure. If they're able to open both of them, that just means that they can open normal packages, but they can't use this special package. So their data is basically kept in as a failure. If they're not able to complete the screening procedure, then their data is just not counted. So the senior test protocol has to be effective at least 90%, which basically means 90% have to be able to complete and pass this test, which is going to be opening and closing both packages as applicable. And then it also includes any failures during an applicable re-securing test. The re-securing test is going to be visible, sorry, is going to be required when an objective determination, anything that's visual or mechanical, that a package is properly re-secured cannot be made. So for example, there's a lot of these closures that when the special package is re-engaged, you'll hear a little click. So that's going to be a mechanical determination or another package like a snap top where you have to line up the arrows before opening it. If the arrows are misaligned, then you know that the re-securing was completed. So those don't have to undergo this re-securing test. All right, so here's an example for the senior adults test. So let's say you have 100 out of 100 packages, 92 of them passed the senior adult test, which basically means you have eight failures. You have to pre-calculate 20% acceptable child failures. That is because during the normal child protocol test, 20% of the children can open a special package. It accounts for that. So that means of the 92 packages, 18.4 is going to be acceptable failures. So let's say when you do the re-securing test, you have 10 children that are able to open the package. So during the calculation here, 10 minus the 18.4 is going to be zero additional failures because you have a negative number. So your SAUE, which is your senior adult use effectiveness, is going to be 100, which is the number of packages you started with, minus eight, which is the eight failures from the senior adult test, minus zero, which is the additional failures from the re-securing test. So that's going to be 92%, so this is going to pass. So let's say you have 20 child failures instead. So now you have 20 minus 18.4, which now means you have 1.6 additional failures. So your SAUE is going to be 100 minus eight minus 1.6, which is 90.4. This is still going to pass because it's still above that 90% rate. Once you get to 21 child failures, now you have 2.6 additional failures. Your SAUE all calculated dips below 90 to 89.4. So now this package fails the senior adult test. There is a younger adult test protocol. This is 100 adults tested individually, an age range of 18 to 45 years old. There is also a gender restriction, a tester restriction, and a site restriction, which both the tester and site restriction, I believe, differ from the senior adult test. The reason why we have that, this is applicable for products in aerosol form and require metal containers. Firms have to show a need for such a container. It is used in lieu of the senior adult test. Same things apply. You have five minutes to open and close the package, and it has to be effective at least 90%, including failures during an applicable resecuring test. That was the PPPA testing requirements. We're now going to go to the certification requirements. Section 14A of the Consumer Product Safety Act basically requires that certificates are available for products subject to a Consumer Product Safety Rule, Standard, Ban, or Regulation. It is going to be the responsibility of the domestic manufacturer or importer to generate and maintain a GCC. Testing for compliance with the PPPA does not need to be conducted by a third-party CPSC accepted laboratory. Technically, that means that testing can be done in-house by the manufacturer, but there are some issues with potentially having access to the number of children required, beating all those different restrictions and criteria. Typically, a lot of firms will just work with some kind of laboratory or something that is able to do the package test for them. There's no requirement to pre-submit any kind of certificates to CPSC. Staff may request it as part of a compliance case. There's no template or format to follow as long as the required elements are present. We're going to go into those elements later on in the presentation. Another question here. I was provided a test report or a certificate from my bottle supplier. Do I need to create a GCC? And it looks like an overwhelming majority of you have said yes. And that's correct. If you are the entity introducing the regulated substance to the packaging, you're considered the manufacturer, therefore you need to create the GCC. Under 16 CFR Part 1109, the manufacturer of the finished product can rely on a supplier's test report or certificate if certain requirements are met. However, those firms still need to create their own GCC for the finished product. They can't just forward whatever certificate was provided to them by the pack bottle supplier. So here are the seven elements that's required on a GCC. A couple of misunderstandings here. Numbers one and five, they talk about identification of the product and the date and place of manufacture for the product. These are related to the finished product and not the actual empty bottle. So we're not talking about identification of what kind of bottle you have. It's the specific finished product. We'll see an example of that. And then number three here, identification of the importer or domestic manufacturer. As reiterated many times here, that's going to be the entity introducing the regulated substance to the package and not the manufacturer of the empty bottle. So a bit of a disclaimer here, the following slides portray a fictitious example for a GCC. Any resemblance or similarity to actual persons or other real life entities is purely coincidental. All right, so identification of the product. This first example is going to have this 28-400 white PPP, a white PPP continuous threaded closure with HDPE bottle. That is the description of the bottle. So this is not allowed for the finished product GCC. We would want to see the actual product. So one, two, three, pain be gone aspirin, in specific dosages and in specific counts. We do ask that it be as specific as possible, list all the different types of forms that's going to require that special package. The second element is going to be the citation to the safety rule. So for PPPA, that's going to be pretty simple. That's just 16 CFR part 1700 poison prevention packaging. There is additional regulations that may reference 1700 or have similar requirements to the PPPA. Those are kind of discussed later. Those should cite that specific safety rule instead of 16 CFR part 1700. We'll see examples of what that looks like. Number three is the identification of the importer or domestic manufacturer. Again, that's going to be the entity that's placing the regulated substance in the package. So it's not going to be your bottle supplier. It's going to be your company, your company name, your company address, and a phone number. Number four is going to be contact information for individuals maintaining test results. So in this instance, the contact information from the package supplier is acceptable if they're the ones actually maintaining copies of the test results. However, the responsible party must be able to facilitate CPSD staff obtaining copies of those test results. Contact information does have to be to a specific person and have direct email or direct phone number. General box information or general email boxes or general phone numbers are probably not going to work here unless they're always going to be manned and someone is going to be able to readily reply. Number five is the date and place of manufacture. So here's an example here. You can use a date range if you'll note that the place of manufacture is going to be the part of the firm that actually made the aspirin and not the empty bottle supplier. The date is going to require a month and year at minimum. Ranges are acceptable as long as the tested product continues to adequately represent whatever is still being manufactured. Place is going to require something more than countries. So city, state, province is applicable. Number six is going to be date and place of testing. So that's pretty straightforward. Again, month and year for the date of testing and then place is going to be something more specific than just a country. And then finally, you'll have the identification of the testing laboratory. So just put the laboratory's information here, their name, address, and some contact information. All right. So as discussed previously, there are other standards that reference special packaging. Here's a few of them. So liquid nicotine packaging under 15 USC section 1472 A references back to 1700.15 or the PPPA. However, the certificates for liquid nicotine products should cite 15 USC section 1472 A instead of 16 CFR part 1700. Same with the other two here, portable gasoline, kerosene, and diesel fuel containers. They're subject to 16 CFR part 1460, which actually incorporates by reference STM F 2517. That has its own test protocol, whereas the other two on this list actually reference the test protocol under the PPPA. So that's something to consider there. And then recently, we had Reese's law, which is public law 117-171. Section 3A of Reese's law does require special packaging for button cell or coin batteries. So again, if your products fall under these requirements, please list those citations instead of 16 CFR parts 1700. All right. There's a question here. My testing was done 10 years ago. Is it still valid? Sorry about that. Okay. And it looks like a little more than half said maybe. And the answer is pretty much the same there, maybe. It's, yes, assuming that there are no material changes since the original test. Having said that, there may be a larger question of whether or not there really weren't any material changes in those 10 years. So a couple of things to consider when it's being retested. So changes in the manufacturing process. So that's going to be any kind of raw material changes. So the source of where you get your plastic pellets, the actual manufacturing process, if you're switching out your plastic injectors, or when you have a new package design, all of these would trigger some kind of retesting. If you swap out the package type, size, or shape, that would also probably require retesting. Anytime there's a receipt of incident reports or complaints, and then if there's any kind of manufacturing defects to try and figure out where those defects are occurring. Speaking of incident reports and manufacturing defects, we'll segue here into section 15b reporting. So under section 15b of the Consumer Product Safety Act, firms are required to report defective products that pose a substantial risk of injury, products that create an unreasonable risk of serious injury or death, or products that fail to comply with a consumer product safety rule, or any other rule regulation standard or banned enforced by the commission. So that third bullet point there is going to be if you know your product fails to meet the special packaging requirements, you are obligated to report. Initial reports need to be submitted immediately upon receipt of information related to the product issue or incidents. So immediate is going to be within 24 hours of knowledge. The questions for initial support are available at 16 CFR section 1115.13c. And then after the submission of initial report, full reports are generally going to be required unless informed otherwise by CPSC staff. Those questions are available at 16 CFR section 1115.13d. Section 15b reports can be submitted online through SafeForProducts.gov. We generally recommend it. This is a very easy way to get all the information. It'll tell you which specific piece of information you need to submit. You can also submit them via email to section15.cpsc.gov. Generally recommend including section 15b report or something similar in the subject line. Reporting does not mean that a case will be opened or that additional corrective actions will be required. It's just your obligation to submit that report. Submissions are treated as confidential as allowed by law. And that sums up the requirements under the PPPA. And so let's see if there's any questions that were submitted. Looks like there's one here asking, does the PPPA apply to button and coin cell batteries either open stock or as packaged with a consumer product? For example, flashlight with batteries not installed rather provided in a zip block style bag. So as we had discussed previously, this is going to fall under Reese's law, not the PPPA. So it's very important to keep that in mind. That's going to be this third bullet point here, public law 117-171 section 3a. So if you have loose button cell or coin batteries in the package or in the finished product, that's going to require special packaging, but only because it's referenced under Reese's law, not because it is a regulated substance under the PPPA. Essentially it means that you're still going to require special packaging that meets the PPPA requirements. But the difference is going to be what you put on your citation. This is going to apply whether those batteries are included with the product or being sold separately. So if you go to a grocery store and you go to that battery aisle, all the button cell or coin batteries there would need the special packaging if they were manufactured or imported after March 19th, 2024, which was the effective date. There's another question here. What happens if I get a report of a child who managed to get into one of our packages, got hurt, but the package passed special packaging requirements? Do I need to make a section 15 report? I definitely recommend that you start an initial report for 15b just to kind of cover your reporting obligation for receiving an incident. The firms are provided some time to do their own investigation to figure out the actual source of the problem if there was a problem and then they can follow up with the CPSC staff to conclude and close out their case. Here's another question here. What would you recommend as the best way to monitor updates to the PPPA to ensure that we have the most up-to-date information? The best way to do that is going to be a couple of several ways. One thing that I highly recommend you do is you subscribe to the Small Business Ombudsman's Business Education Newsletter, so that's going to be cpsc.gov slash email, and then check the box for business education. For the regulatory rulemaking stuff, I recommend that you go to the federalregister.gov, look up Consumer Product Safety Commission, and then you can subscribe to any kind of notices of proposed rulemaking or final rules or anything like that, and you'll get an email notification anytime CPSC posts something along those lines. All right, another question here. My product passed child testing but failed senior testing. Can I still use it? Unfortunately, you're not able to use that package. One of the provisions under the special packaging requirements is that it is both child-resistant and senior-friendly, or rather, and adult-friendly, so you would need to pass both test protocols in order for it to be considered special packaging. All right, I think that's all the questions we have. Here's, again, our SBO's contact information. Feel free if you have any questions to just reach out to us directly. We'll hopefully be able to answer your questions. If not, we can facilitate getting you the answers to your specific questions. You can reach us through the contact form cpsc.gov slash SBO contact. You can call and leave a voicemail at the toll-free number there, or you can email us at SBO at cpsc.gov. All right, thank you for attending our webinar today, and I hope you have a good rest of your day.