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Nutrilite completely agrees with the statements and points made by Michael Bradley of Perrigo. Additionally, Disintegration in the USP is 30 minutes. This ballot refers to 60 minutes. Maybe it would be better to just reference meets USP-NF requirements and leave out the specific time. Also, we recommend the addition of equivalent, validated methods for milk, soy and gluten.

Dear Ms. Arnold: 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.