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It would be nice if ballots could be out for at least 30 days to provide adequate time for review.
The proposed change includes detailed specifics on how the evaluation of products to the standard shall be carried out. This goes beyond the requirements of a product standard and is proposing a level of detail which just recently was deemed to be not necessary due to the fact that so few cases exist that would affect the resultant levels of toxin and not be cost effective. This reference is to the summation of organics which one certification body did not feel was necessary. Yet the proposal now being considered goes to even finer levels of review that have not been proven to be cost effective. There are acceptable ways to carry out formulation reviews which to not need the detail being proposed.
This proposal will put an unnecessary burden on manfacturers affecting both timely and costly evaluations of products and require testing agencies to acquire large numbers of standards that presently are not required.

The standard should only add product requirements where needed and leave the methods by which the requirements are evaluated up to those in the business of testing. That is why there are ISO standards to evaluate testing laboratories and certification bodies. Product standards should not encroach on the business activities of these bodies, who, once accredited, have been proven to carry out these functions adequately.