November 1, 2018 Bill Backus Interim Chief Financial Officer Balchem Corporation 52 Sunrise Park Rd. New Hampton, NY 10958 Re: Balchem Corporation Form 10-Q for Fiscal Quarter Ended June 30, 2018 Filed August 3, 2018 Form 10-K for Fiscal Year Ended December 31, 2017 Filed March 1, 2018 File No. 001-13648 Dear Mr. Backus: We have completed our review of your filings. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Sincerely, Division of Corporation Finance Office of Manufacturing and Construction