CPP Regulatory Compliance & Legal Framework 2 — Questions and Answers
Question 1: Which U.S. federal agency enforces the Poison Prevention Packaging Act (PPPA) for household substances?
- FDA
- CPSC (Correct answer)
- EPA
- OSHA
Correct answer: CPSC
The Consumer Product Safety Commission (CPSC) enforces the PPPA, which requires child-resistant packaging for certain hazardous household products.
Question 2: Under the Resource Conservation and Recovery Act (RCRA), packaging that contacts hazardous waste is typically classified as:
- Municipal solid waste
- Industrial solid waste
- Hazardous waste (Correct answer)
- Universal waste
Correct answer: Hazardous waste
Packaging that contacts RCRA-listed or characteristic hazardous waste is regulated as hazardous waste itself and must be managed accordingly.
Question 3: The FDA's 21 CFR Part 177 primarily governs:
- Drug labeling requirements
- Indirect food additives including polymers (Correct answer)
- Pesticide residue limits on food contact materials
- Nutritional content labeling
Correct answer: Indirect food additives including polymers
21 CFR Part 177 covers indirect food additives — specifically resins and polymeric coatings used in food contact articles.
Question 4: California's Proposition 65 requires packaging companies to provide 'clear and reasonable warnings' when a product exposes consumers to chemicals above:
- The OSHA permissible exposure limit
- No significant risk levels (NSRL) or maximum allowable dose levels (MADL) (Correct answer)
- EPA's reference dose (RfD)
- FDA's acceptable daily intake (ADI)
Correct answer: No significant risk levels (NSRL) or maximum allowable dose levels (MADL)
Prop 65 warnings are triggered when exposures exceed NSRL for carcinogens or MADL for reproductive toxicants established by OEHHA.
Question 5: The FTC Green Guides primarily regulate which aspect of packaging?
- Recycled content verification testing methods
- Environmental marketing claims to prevent deceptive advertising (Correct answer)
- Mandatory minimum recycled content percentages
- State bottle deposit program compliance
Correct answer: Environmental marketing claims to prevent deceptive advertising
The FTC Green Guides provide guidance on making truthful, non-deceptive environmental marketing claims such as 'recyclable,' 'compostable,' and 'recycled content.'
Question 6: Under DOT regulations (49 CFR), a packaging marked 'UN 4G' indicates it is:
- A fiber drum tested for solids and liquids
- A fiberboard box tested for solid hazardous materials (Correct answer)
- A steel drum for liquid hazardous materials
- A composite packaging with a plastic inner
Correct answer: A fiberboard box tested for solid hazardous materials
UN code 4G designates a fiberboard box; the '4' indicates box type and 'G' indicates fiberboard material.
Question 7: Which labeling requirement is mandated by the Fair Packaging and Labeling Act (FPLA) for consumer commodities?
- UPC barcode placement standards
- Identity of commodity, net quantity, and responsible party (Correct answer)
- Country of origin disclosure
- Allergen declaration
Correct answer: Identity of commodity, net quantity, and responsible party
The FPLA requires consumer commodity labels to disclose the product identity, net quantity of contents, and the name and place of business of the manufacturer or distributor.
CPP Regulatory Compliance & Legal Framework 2
Which U.S. federal agency enforces the Poison Prevention Packaging Act (PPPA) for household substances?