<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
<PAGE>
January 10, 2005

Mr. Michael Fay
Branch Chief
U.S. Securities and Exchange Commission
Division of Corporate Finance
450 Fifth Street, N.W.
Washington, D.C. 20549

RE:  SIFCO INDUSTRIES, INC.
     FILE NO. 1-5978
     SEPTEMBER 30, 2004 FORM 10-K

Dear Mr. Fay:

This letter is written in response to the SEC's letter to SIFCO Industries, Inc.
dated January 4, 2005.

In response to the SEC's comments, SIFCO responds as follows:

     -    RESPONSE TO COMMENT 1 - SIFCO's September 30, 2004 Form 10-K notes in
          "Item 1. Business; B. Principal Products and Services; 1. Turbine
          Component Services and Repair Group -

               -    In the Operations discussion (Page 2), SIFCO notes that it
                    is required to obtain licenses that certify its ability to
                    repair specific turbine engine components. The discussion
                    states that SIFCO has elected to obtain licenses primarily
                    from the OEM. This is because, although FAA licenses are
                    more easily obtained than OEM approvals, FAA approvals may
                    have a marketability issue associated with them.

               -    In the Competition discussion (Page 4), SIFCO notes that
                    with the entry of the OEM into the (turbine engine repair
                    and overhaul) market, there has been reluctance on the part
                    of the OEM to issue, to independent component repair
                    companies (like SIFCO), additional licenses authorizing
                    repairs to newer model aerospace turbine engine components.
                    In that same section SIFCO describes that it has been able
                    to partially overcome this trend through close collaboration
                    between itself and the OEM. Such collaboration, in certain
                    circumstances, also involves the commercial airline(s) that
                    purchase and operate the engines produced by the OEM because
                    commercial airlines are motivated to ensure that alternative
                    sources for turbine engine component repairs exist to
                    provide them with a competitive source for such component
                    repair services. To clarify this further, SIFCO will expand
                    its discussion in future filings to include the involvement
                    of commercial airlines in such collaboration.

          Based on the above noted items, SIFCO believes that its disclosure in
          Operations (Pg. 2) and Competition (Pg. 4)" provides the appropriate
          level of discussion to enable the reader to understand the state of
          the repair approval environment in which SIFCO currently operates. To
          the extent that the environment may change in the future, SIFCO will
          revise this discussion accordingly.

     -    RESPONSE TO COMMENT 2:

               -    SIFCO will include a discussion of its policy for
                    receivables and inventory allowances in its "Summary of
                    Significant Accounting Policies" financial statement
                    footnote in its future filings. At the SEC's request, SIFCO
                    provides the attached supplemental Schedule


<PAGE>

                    II that has been expanded to reflect all of SIFCO's reserve
                    accounts that are deemed to be material.

               -    SIFCO provides manufacturing and repair products and
                    services that are generally required to meet product
                    specifications that have been established by parties other
                    than SIFCO and, therefore, SIFCO only warranties that its
                    manufacturing and repair products and services will meet
                    such established (third party) specifications. SIFCO
                    evaluates its warranty obligation based on historical claim
                    activity and the existence of any known outstanding warranty
                    claims. SIFCO has historically not had any significant
                    warranty claims and therefore at September 30, 2004 (and in
                    recent prior periods) its warranty claim reserve level was
                    immaterial.

     -    RESPONSE TO COMMENT 3 - SIFCO's revolving credit agreement has not
          become due as a result of a material adverse change. SIFCO will make a
          similar disclosure in future filings.

At the SEC's request, SIFCO makes the following statements acknowledging its
understanding that:

     -    The Company is responsible for the adequacy and accuracy of the
          disclosure in the (September 30, 2004) filing;

     -    Staff comments or changes to disclosure in response to staff comments
          do not foreclose the Commission from taking any actions 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.

SIFCO will be pleased to discuss these matters further with you, and to provide
additional information in response to specific questions that may arise upon the
SEC's review of this response. If you have any questions regarding this
response, please feel free to contact me directly at (216) 432-6278 at your
earliest convenience.

Sincerely,


/s/ Frank A. Cappello
---------------------
Frank A. Cappello
Vice President - Finance
and Chief Financial Officer


Cc:   J. Robinson (Grant Thornton)
      M. Lipscomb (SIFCO Audit Committee)



<PAGE>
                     SIFCO INDUSTRIES, INC. AND SUBSIDIARIES
       Schedule II - Valuation and Qualifying Accounts For the Years Ended
                        September 30, 2004, 2003 and 2002
                             (amounts in thousands)


<TABLE>
<CAPTION>
                                                                ADDITIONS
                                                               (REDUCTIONS)
                                                  BALANCE AT    CHARGED TO     CHARGED TO                            BALANCE
                                                 BEGINNING OF   COSTS AND         OTHER                             AT END OF
                       DESCRIPTION                  PERIOD       EXPENSES       ACCOUNTS           DEDUCTIONS         PERIOD
                       -----------                  ------       --------       --------           ----------         ------
<S>                                                 <C>            <C>               <C>            <C>                <C>
YEAR ENDED SEPTEMBER 30, 2004
 Deducted from asset accounts:
     Allowance for doubtful accounts                1,045          (104)             0              (311)(a)           630
     Return and allowance reserve                     334          (193)             0                (5)(b)           136
     Inventory obsolescence reserve                 1,479           173              0              (366)(c)         1,286
     Inventory LIFO reserve                         3,230           288              0                 0             3,518
     Asset impairment reserve                       1,772             0              0              (219)(d)         1,553
     Valuation allowance for deferred taxes         3,430           699              0                 0             4,129
 Accrual for estimated liability
     Workers' compensation reserve                  1,099           344              0              (326)(e)         1,117


YEAR ENDED SEPTEMBER 30, 2003
 Deducted from asset accounts:
     Allowance for doubtful accounts                1,250           115              0              (320)(a)         1,045
     Return and allowance reserve                     428           321              0              (415)(b)           334
     Inventory obsolescence reserve                 2,655           279              0            (1,455)(c)         1,479
     Inventory LIFO reserve                         3,114           116              0                 0             3,230
     Asset impairment reserve                         756         1,309              0              (293)(d)         1,772
     Valuation allowance for deferred taxes         1,723         1,707              0                 0             3,430
 Accrual for estimated liability
     Workers' compensation reserve                  1,029           311              0              (241)(e)         1,099


YEAR ENDED SEPTEMBER 30, 2002
 Deducted from asset accounts:
     Allowance for doubtful accounts                1,422           481             (1)(f)          (652)(a)         1,250
     Return and allowance reserve                     272           175              0               (17)(b)           428
     Inventory obsolescence reserve                 1,888         3,936              0            (3,169)(c)         2,655
     Inventory LIFO reserve                         2,884           230              0                 0             3,114
     Asset impairment reserve                           0         1,168              0              (412)(d)           756
     Valuation allowance for deferred taxes           161         1,562              0                 0             1,723
 Accrual for estimated liability
     Workers' compensation reserve                  1,497           182            (55)             (595)(e)         1,029
</TABLE>


(a) Accounts determined to be uncollectible, net of recoveries
(b) Actual returns received
(c) Inventory sold or otherwise disposed
(d) Equipment sold or otherwise disposed
(e) Payment of workers' compensation claims
(f) Exchange rate changes


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