Comment from Steven Marcus

i am the medical director of the regional poison center for the state of NJ. i am also a pediatrician and medical toxicologist. perhaps more important, I am also the grandfather of 6 wonderful, vulnerable grandchildren. from my experiences in my above roles, I have a perspective on the safety of children and believe that your potential rule to require the packaging of lamp oil products (also called tiki oil, parrifin oil, kerosene, petrolleum distillate, etc) in opaque containers is an important first step in making these products safer. Currently, i see the product as te "perfect stor," the substance looks like a fruit juice, is package in an identical container as fruit juice, and the substance seems to orevent a child-resistant cap from functioining in such a way as to avoid a child from opening it. Further, the larger container sold with this substance is intended to refill backyard torches and it is near impossible to pour the substance into the much smaller opening of the torches, thus forcing individuals to transfer substance into some convenient container which can be squeezed to form a spout to refill the torch. More often than not, the intermediarry container is a plastic drinking cup, putting the finisahing touches on the perfect storm. I have seen serious illness and death result from the unintentional ingestion of these products and applaud your efforts, albeit insufficient as I see it, to help protect the innocent children and adults who happen to come across this product.