SecProbe.io

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Mail Stop 3561

October 11, 2005

Via U.S. Mail

Mr. Donald Lynn Collins
Chief Executive Officer
Collins Industries, Inc.
15 Compound Drive
Hutchinson, Kansas 67502

	RE:	Collins Industries, Inc.
		Form 10-K for the fiscal year ended October 31, 2004
		Filed March 3, 2005
		Form 10-Q for the fiscal quarter ended July 31, 2004
		File No. 0-12619

Dear Mr. Collins:

We have reviewed your filings and have the following comments.  We
have limited our review to only your financial statements and
related
disclosures and do not intend to expand our review to other
portions
of your documents.  Where indicated, we think you should revise
your
document in future filings in response to these comments.  If you
disagree, we will consider your explanation as to why our comments
are inapplicable or a revision is unnecessary.  Please be as
detailed
as necessary in your explanation.  In some of our comments, we may
ask you to provide us with information so we may better understand
your disclosure.  After reviewing this information, we may raise
additional comments.

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.  We look
forward to working with you in these respects.  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.

Item 1.  Business, page 1
Research and Development Costs, page 5

1. We note that you have included in costs of sales research and
development work performed on the production line.  Please clarify
for us why these amounts are properly classified in cost of sales
and
quantify amounts for each year presented.  Include in your
response,
if the research and development costs were a material component of
cost of sales, the impact on your profit margin.

Financial Statements, page 30
Consolidated Statements of Income and Comprehensive Income, page
31

2. We note from the discussion in MD&A that you have reflected
gains
on sales of land and buildings as a component of other income
(expense) in your consolidated statements of income.  In future
filings, please revise to reflect any gains or losses on the
disposal
of such property as a component of income from operations.  Refer
to
the requirements of footnote 68 to SAB Topic 13 and paragraph 45
of
SFAS No.144.  In addition, revise the notes to your financial
statements to include the disclosures outlined in 47 of SFAS
No.144
with respect to assets sold during the periods presented in your
consolidated statements of income.

Notes to Consolidated Financial Statements, page 35
Note 1. Summary of Significant Accounting Policies, page 35
(d) Inventories, page 35

3. Please clarify for us your accounting for the consigned
chassis.
We note from page 3 that you take title to the chassis when you
select an individual item and subsequently become liable for
payment
of the consigned item.  We further note from paragraph (f) on page
49
that "the Company accounts for the chassis as consigned inventory"
and that you have a line item in your inventory breakdown on page
35
for chassis.  Please explain what comprises the line item
"Chassis"
in your inventory breakdown.  Also, please clarify if you have
title
to the items included and explain how value the chassis reflected
in
your inventory balances.

(h) Revenue Recognition, page 37

4. We note from page 2 that you sell products through both direct
sales and distributors.  Please describe the significant terms of
your agreements with resellers or distributors, including payment,
return, exchange, price protection and other significant matters.
Also address your accounting for any of the referenced items that
are
applicable to you.  Consider the need to revise future filings to
address our concerns.

5. In a related matter, please expand your discussion in future
filings to explain your revenue recognition policies concerning
all
customers that are offered return or price protection rights.
This
would include addressing whether end users are offered rights of
return and your need for an allowance, if any, related thereto.
Finally demonstrate your compliance with SFAS 48 for all such
transactions.  We may have further comments after reviewing your
response.

6. You disclose that you recognize revenue "at the earlier of
completion of the vehicle and receipt of full payment or shipment
or
delivery to the customer."  Please clarify for us how the four
revenue recognition criteria of SAB 104 are met prior to
recognizing
revenue in each of these circumstances.

Note 6. Capital Stock, page 46
Stock-based Compensation Plans, page 46

7. We note from the disclosures provided in Note 6 that the
Company
has issued restricted stock awards to its officers, employees, and
directors during all periods presented in the Company`s financial
statements.  In future filings, please revise the notes to the
Company`s financial statements to disclose the weighted-average
grant
date fair value of the restricted shares issued each period as
well
as the amount of compensation expense recognized in the Company`s
financial statements in connection with these awards.  Refer to
the
requirements of paragraphs 47c and 47e of SFAS No.123.

Note 8. Commitments and Contingences, page 48
(b) Repurchase Agreements, page 48

8. We note the disclosure indicating that the Company may be
required
to repurchase its products in the event one of its dealers
defaults
under their floor plan financing arrangements.  Please tell us and
clarify in your footnote disclosures whether any accruals for
potential losses in connection with these arrangements have been
reflected in your financial statements, including the methods and
significant assumptions used in estimating the accruals.  If no
accruals have been recognized, please explain why.  In addition,
please explain why your contingent obligations with respect to
these
arrangements have increased from approximately $1.1 million at
October 1, 2004 to approximately $3.7 million at July 31, 2005.

 General

9. In future filings please provide Schedule II or tell us why you
are not required to do so.

Form 10-Q for the quarter ended July 31, 2005
Management`s Discussion and Analysis of Financial Condition and
Results of Operations, page 15
Results of Operations, page 16
Bus Segment, page 18
Nine months ended July 31, page 18

10. We refer you to the last sentence of the first paragraph on
page
19.  Please clarify what is meant by "sales policy allowances" and
why these amounts are classified in selling, general and
administrative expenses.  Your response should explain how these
allowances are recognized in your financial statements and why you
believe classification in selling, general and administrative
expense
is appropriate.

Item 4.  Controls and Procedures, pages 25 and 26

11. We note that per the evaluation carried out by the CEO and
CFO,
controls were deemed effective for the first time in several
fiscal
quarters.  However, the disclosure does not include specific
changes
in controls made to address the material weaknesses previously
identified.  Please tell us and explain in future filings what
measures you took to ensure that the material weaknesses were
remediated in order to conclude that controls were effective.
Revise
future filings to provide the proper disclosures concerning
changes
in internal controls.  Please note that ANY changes in internal
controls which have materially affected or are reasonably likely
to
affect the Company`s internal control over financial reporting
should
be reported in your disclosures.  Refer to SEC Release No. 33-
8238,
Section II.F.

*    *    *    *

As appropriate, please respond to these comments within 10
business
days or tell us when you will provide us with a response.  Please
furnish a cover letter that keys your responses to our comments
and
provides any requested information.  Detailed cover letters
greatly
facilitate our review.  Please understand that we may have
additional
comments after reviewing your responses to our comments.

We urge all persons who are responsible for the accuracy and
adequacy
of the disclosure in the filings to be certain that the filings
include all information required under the Securities Exchange Act
of
1934 and they have provided all information investors require for
an
informed investment 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 comments, 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 filings;

* 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 Heather Tress at (202) 551-3624 or me at (202)
551-
3813 if you have questions.

Sincerely,

Linda Cvrkel
Branch Chief

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Mr. Donald Lynn Collins
Collins Industries, Inc.
October 11, 2005
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