Certifying the package is the responsibility to the filler/end user. A trigger with a ratchet cap and a CR nozzle will likely pass the CPSC, but there isn’t a sprayer out there already considered “child resistant”

Different pump or sprayer manufacturers may have different measuring methods. Always send a sample of the container being used to the sprayer manufacturer, and let them determine the proper dip tube length. Have the manufacturer provide a sample with their dip tube length recommendation, and have the customer test, and approve it.