August 8, 2019

Via E-mail
Joseph C. Papa
Chief Executive Officer and
       Chairman of the Board
Bausch Health Companies Inc.
2150 St. Elz ar Blvd. West
Laval, Qu bec H7L 4A8, Canada

       Re:    Bausch Health Companies Inc.
              Form 10-K for the Fiscal Year Ended December 31, 2018
              Filed February 20, 2019
              File No. 1-14956

Dear Mr. Papa:

       We have limited our review of your filing to your contacts with
countries that have
been identified as state sponsors of terrorism, and we have the following
comment. Our
review with respect to this issue does not preclude further review by the
Assistant
Director group with respect to other issues. At this juncture, we are asking
you to
provide us with information so we may better understand your disclosure.

        Please respond to this letter within ten business days by providing the
requested
information, or by advising us when you will provide the requested response. If
you do
not believe our comment applies to your facts and circumstances, please tell us
why in
your response.

      After reviewing the information you provide in response to this comment,
we may
have additional comments.

General

   1. In its letter dated August 10, 2016, Valeant Pharmaceuticals
International, Inc.
      stated that it had sold products into Sudan and Syria. As you know, Sudan
and
      Syria are designated by the U.S. Department of State as state sponsors of
      terrorism, and are subject to U.S. economic sanctions and/or export
controls. You
      do not include disclosure about Sudan and Syria in the Form 10-K. Please
      describe to us the nature and extent of your past, current and
anticipated contacts
 Joseph C. Papa
Bausch Health Companies Inc.
August 8, 2019
Page 2

      with Sudan and Syria since the August 2016 letter, including contacts
with their
      governments, whether through subsidiaries, distributors, or other direct
or indirect
      arrangements. Please also discuss the materiality of the contacts, in
quantitative
      terms and in terms of qualitative factors that a reasonable investor
would deem
      important in making an investment decision. Tell us the approximate
dollar
      amounts of any revenues, assets and liabilities associated with Sudan and
Syria for
      the last three fiscal years and the subsequent interim period. Address
the potential
      impact of the investor sentiment evidenced by divestment and similar
initiatives
      that have been directed toward companies that have operations associated
with
      U.S.- designated state sponsors of terrorism.

       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.

      Please contact Pradip Bhaumik, Special Counsel, at (202) 551-3333 or me
at (202)
551-3470 if you have any questions about the comment or our review.

                                                       Sincerely,

                                                       /s/ Cecilia Blye

                                                       Cecilia Blye, Chief
                                                       Office of Global
Security Risk

cc:   Suzanne Hayes
      Assistant Director
      Division of Corporation Finance