After analyzing the comments, the FDA concluded that the absorbency test methodology and sampling procedures in the proposed rule were appropriate.[91] The FDA had received more than 250 comments arguing that the existing absorbency terms should be standardized.[92] However, the FDA determined that while there remained a question as to the appropriateness of the use of a system of letters to represent absorbency ranges, it was not going to propose standardizing currently used terms of absorbency (i.e., regular, super, and super plus).[93] Thus, the reproposed rule would require that manufacturers of menstrual tampons express absorbency on tampon labeling by using one of six specified absorbency terms.[94] Instead of using the letters A-F, the rule would establish a new set of standardized terms of absorbency, each of which corresponded to a range of absorbency specified in grams: low absorbency (less than or equal to 6 grams); medium absorbency (6-9 grams); medium-high absorbency (9-12 grams); high absorbency (12-15 grams); very high absorbency (15-18 grams); and highest absorbency (above 18 grams).[95] These terms would be required to be more prominent than, and separate from, any other information on the principle display panel except the corresponding numerical range of absorbency.[96]
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