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<SEC-DOCUMENT>0000000000-05-000567.txt : 20100922
<SEC-HEADER>0000000000-05-000567.hdr.sgml : 20100922
<ACCEPTANCE-DATETIME>20050104141636
<PRIVATE-TO-PUBLIC>
ACCESSION NUMBER:		0000000000-05-000567
CONFORMED SUBMISSION TYPE:	UPLOAD
PUBLIC DOCUMENT COUNT:		1
FILED AS OF DATE:		20050104

FILED FOR:		

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			SIFCO INDUSTRIES INC
		CENTRAL INDEX KEY:			0000090168
		STANDARD INDUSTRIAL CLASSIFICATION:	AIRCRAFT ENGINES & ENGINE PARTS [3724]
		IRS NUMBER:				340553950
		STATE OF INCORPORATION:			OH
		FISCAL YEAR END:			0930

	FILING VALUES:
		FORM TYPE:		UPLOAD

	BUSINESS ADDRESS:	
		STREET 1:		970 E 64TH ST
		CITY:			CLEVELAND
		STATE:			OH
		ZIP:			44103
		BUSINESS PHONE:		2168818600

	MAIL ADDRESS:	
		STREET 1:		970 EAST 64TH STREET
		CITY:			CLEVELAND
		STATE:			OH
		ZIP:			44103

	FORMER COMPANY:	
		FORMER CONFORMED NAME:	STEEL IMPROVEMENT & FORGE CO
		DATE OF NAME CHANGE:	19690520
PUBLIC REFERENCE ACCESSION NUMBER:		0000950152-04-009016
</SEC-HEADER>
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>






      January 4, 2005


Via Fax & U.S. Mail

Mr. Frank A. Cappello
SIFCO Industries, Inc.
Chief Financial Officer
970 East 64th Street
Cleveland, OH  44103

Re:	SIFCO Industries, Inc.
	File No.  1-5978
 	September 30, 2004 Form 10-K

Dear Mr. Cappello:

      We have reviewed your September 30, 2004 Form 10-K and have
the
following comments.  We have limited our review to the financial
statements and related disclosures within your Form 10-K.  Please
understand that the purpose of our review process is to assist you
in
your compliance with the applicable disclosure requirements, and
to
enhance the overall disclosure in your filings.

      Where we have asked you to provide us with supplemental
information, please be as detailed as necessary in your
explanation.
After reviewing this information, we may or may not raise
additional
comments.  Where expanded or revised disclosure is requested, you
may
comply with these comments in future filings.  If you disagree, we
will consider your explanation as to why our comments are
inapplicable or a revision is unnecessary.

      We welcome any questions you may have about our comments or
on
any other aspect of our review.  Feel free to call us at the
telephone numbers listed at the end of this letter.

Business
Turbine Services and Repair Group, page 2

1. We note that you are required to obtain licenses that certify
your
ability to repair specific turbine engine components.  In future
filings, disclose any trends regarding your ability to procure
both
OEM and FAA approvals, e.g., whether there has been a decrease in
the
number of approvals you have procured, and the resulting short-
and
long-term impact on your business.

Management`s Discussion and Analysis
Critical Accounting Policies and Estimates, page 17

2. We note that the company believes that its critical accounting
policies include estimating the amounts for your receivable and
inventory allowances.  In future filings, please expand your
"Summary
of Significant Accounting Policies" financial statement footnote
to
include your policy for these reserve amounts.  In this regard,
expand Schedule II - Valuation and Qualifying Accounts to include
all
of your reserve accounts, e.g., obsolete and excess inventory,
LIFO
reserve, workers` compensation, and any other reserves.  Refer to
Rule 5-04 of Regulation S-X, and the schedule information
prescribed
by Rule 12-09 of Regulation S-X.  Please also supplementally
provide
this information to us at this time.  Specifically address whether
you provide any warranties, and, if so, the related accounting
policy
for your warranty obligations.  We may have additional comments
after
reviewing your response.

Financial Statements
Note 5.  Long-Term Debt, page 31

3. We note that your revolving credit agreement contains a
material
adverse change clause that allows the lender to require the loan
to
become due if the lender determines that there has been a material
adverse change in your operations, business, etc.  Supplementally
tell us, and in future filings disclose, whether a loan has become
due as a result of a material adverse change.

      Please file your response to our comments via EDGAR within
ten
business days from the date of this letter.  Please understand
that
we may have additional comments after reviewing your response.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	In connection with responding to our comment, please provide,
in
writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.


      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      You may contact Nancy Bonham at (202) 942-1854, or James E.
Campbell, Review Accountant, at (202) 942-1914 if you have
questions
regarding the above comments.  Please call me at (202) 942-1907
with
any other questions.

      Sincerely,



      Michael Fay
      Branch Chief



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Mr. Cappello
SIFCO Industries, Inc.
Page 3




</TEXT>
</DOCUMENT>
</SEC-DOCUMENT>
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