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We believe that the section as rewritten is strong, but should have provisions to allow for reduced testing after a history of compliance and through verification of the formula by the NSF review process. For example, if a product makes a "Gluten Free" claim, the product should be tested to verify that it does not contain any Gluten; hwoever, once a testing history has been established and the formula clearly does not contain any raw materials that would likely be known sources of Wheat, Rye, Barley, etc., then reduced testing is a practical solution.

Section 7.5.4 Other Food Allergens: If a Food Allergen claim is made and there is no test method known, is it possible to substantiate a claim based on a formula review and a process inspection? The formula review could confirm the absence of the ingredient or by-products of the ingredient that is the subject of the claim and the process inspection can confirm that there is no potential for cross-contamination such as would be the case if the ingredient that is the subject of the allergen claim were not used in the facility.

Modify the wording to allow NSF to apply reduced testing principles and also to allow for alternative means of compliance where no method exists.

Dear Mr. Bradley: Thank you for your comments on the Joint Committee ballot of Standard 173 (173i18r2) regarding the assessment of allergen-free claims. Attached are your comments on this issue and the response of the issue proponent, Kerri LeVanseler of NSF International. I hope the above addresses your concerns. Thank you for your comments. If you have additional comments, or wish to discuss these points further, please contact Ms. LeVanseler.