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Correspondence dated October 28, 2005

                                    LAW FIRM
                       BLACKWELL SANDERS PEPER MARTIN LLP
                4801 MAIN STREET SUITE 1000 KANSAS CITY, MO 64112
                   P.O. BOX 219777 KANSAS CITY, MO 64121-6777
                     TEL: (816) 983-8000 FAX: (816) 983-8080
                        WEBSITE: www.blackwellsanders.com

Greg S. Steinberg                                     DIRECT FAX: (816) 983-8080
DIRECT: (816) 983-8387                   E-MAIL: gsteinberg@blackwellsanders.com

                                October 28, 2005

VIA EDGAR TRANSMISSION

Ms. Linda Crvkel
Branch Chief
Securities and Exchange Commission
Division of Corporation Finance
100 F. Street, N.E.
Washington, D.C. 20549

         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, 2005
                  (File No. 0-12619)

Dear Ms. Crvkel:

     On behalf of Collins Industries, Inc. (the "company"), I am writing to
respond to the comments of the staff (the "staff") of the Division of
Corporation Finance of the Securities and Exchange Commission (the "Commission")
set forth in your letter dated October 11, 2005 with respect to the
above-referenced filings (the "comment letter"). This letter is being filed with
the Commission today.

     We are also providing a copy of this letter to Timothy P. Davis, Trial
Counsel for the Commission in the Ft. Worth, Texas office.

     For ease of reference, each of the staff's comments is reproduced below in
its entirety in bold, followed by the corresponding response.

Form 10-K for the year ended October 31, 2004

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

  KANSAS CITY, MISSOURI•ST. LOUIS, MISSOURI•OVERLAND PARK, KANSAS•OMAHA, NEBRASKA
SPRINGFIELD, MISSOURI•EDWARDSVILLE, ILLINOIS•WASHINGTON, D.C.•LONDON, UNITED KINGDOM

                           AFFILIATES: LEEDS•MANCHESTER
                        MEMBER OF THE WORLD SERVICES GROUP

                                    LAW FIRM
                         BLACKWELL SANDERS PEPER MARTIN
                                      LLP

Ms. Linda Crvkel
October 28, 2005
Page 2

          properly classified in cost of sales and quantity 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.

     Response: The Form 10-K narrative discusses day-to-day operations, process
     improvements, and customer directed and paid-for specifications. The
     company performs customer-directed research and development work under
     contract, which is why these amounts were included in cost of sales. In the
     future, we propose to revise the disclosure to note that the company
     performs customer-directed research and development work under contract.
     The research and development costs were $137,515, $23,123, and $26,561 for
     fiscal years 2002, 2003, and 2004, respectively. The research and
     development costs were not a material component of cost of sales and,
     therefore, did not materially impact the company's 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.

     Response: The company will revise future filings (i) to reflect any gains
     or losses on the disposal of such property as a component of income from
     operations and (ii) to include the disclosures outlined in 47 of SFAS No.
     144 with respect to assets sold during the periods presented in the
     company's 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

                                    LAW FIRM
                         BLACKWELL SANDERS PEPER MARTIN
                                      LLP

Ms. Linda Crvkel
October 28, 2005
Page 3

          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.

     Response: A "chassis" is basically a truck frame, engine, and driver
     compartment supplied by a large manufacturer, such as General Motors or
     Ford.

     Consigned inventory refers to chassis units that have been delivered by the
supplier to the company and stored on company facilities. However, the consigned
chassis are not the property of the company and the company has no obligation to
pay for these chassis unless and until the company determines to purchase the
chassis and use it in the production process.

     Chassis inventory is comprised of any chassis that the company has
purchased and taken title from the manufacturer. Chassis inventory is valued on
the balance sheet at cost.

(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.

     Response: Wheeled Coach dealer terms are cash on delivery. There are no
     return, exchange, or price protection agreements. Collins Bus and Mid Bus
     dealer terms require payment prior to delivery. Title passes upon payment
     for each unit. Dealers have no return or exchange rights and no price
     protection.

     It is customary practice for companies in the specialty vehicle industry to
enter into repurchase agreements with financing institutions to provide floor
plan financing for dealers. In the event of a dealer default, these agreements
generally require the repurchase of products at the original invoice price net
of certain adjustments. The risk of loss under the agreements is limited to the
risk that market prices for these products may decline between the time of
delivery to the dealer and time of repurchase by the company. The risk is spread
over numerous dealers and the company has not incurred significant losses under
these agreements. In the opinion of management, any future losses under these
agreements will not have a material adverse effect on the company's financial
position or results of operations. The company's repurchase obligation under
these agreements is limited to vehicles which are in new condition and as to
which the

                                    LAW FIRM
                         BLACKWELL SANDERS PEPER MARTIN
                                      LLP

Ms. Linda Crvkel
October 28, 2005
Page 4

dealer still holds title. The company's contingent obligation under such
agreements was approximately $1,188,000 at October 31, 2004.

     The company will revise future filings to reflect these additional
disclosures.

     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.

     Response: The company does not currently offer any return or price
     protection rights to its customers. In future filings, the company will
     expand its discussion to explain its revenue recognition policies
     concerning all customers, if any, that are offered return or price
     protection rights, including addressing whether end users are offered
     rights of return and the company's need for an allowance, if any, related
     thereto by describing the general return or price protection rights.

     The company meets all of the requirements of SFAS 48, which allows the
company to recognize revenue when the right to return exists if all of the
following conditions are met:

     •    Price to buyer is substantially fixed at the date of sale.
     •    Buyer has or is obligated to pay seller, and it is not contingent on
          product resale.
     •    Buyer obligation not changed in event of theft or product damage.
     •    Buyer acquiring the product for resale has economic substance apart
          from that provided by the seller.
     •    Seller does not have significant obligations for future performance to
          bring about resale of the product by the buyer.
     •    Amount of future returns can be reasonably estimated.

     In future filings, the company will demonstrate its compliance with SFAS 48
for all such transactions by listing the requirements of SFAS 48.

     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.

                                    LAW FIRM
                         BLACKWELL SANDERS PEPER MARTIN
                                      LLP

Ms. Linda Crvkel
October 28, 2005
Page 5

     Response: Staff Accounting Bulletin No. 104 states: "The staff believes
     that revenue generally is realized or realizable and earned when all of the
     following criteria are met:

     •    Persuasive evidence of an arrangement exists;
     •    Delivery has occurred or services have been rendered;
     •    The seller's price to the buyer is fixed or determinable; and
     •    Collectibility is reasonably assured."

     The company does not recognize revenue until each of the four criteria
listed above are met. In most cases, revenue is recognized upon delivery of the
company's product to the buyer.

     In a small number of cases, the company will recognize revenue when
physical delivery has not occurred when the following criteria are met:

     •    Risk of ownership has passed to the buyer;
     •    The buyer has made a fixed commitment to purchase the goods;
     •    The buyer has requested the transaction be on a bill and hold basis
          and the buyer has a substantial business purpose for ordering the
          goods on a bill and hold basis;
     •    There is a fixed schedule for delivery of the goods;
     •    The company does not retain any specific performance obligations such
          that the earnings process is not complete;
     •    The goods are segregated from the company's inventory and are not
          subject to being used to fill other orders; and
     •    The goods are complete and ready for shipment.

The value of the bill and hold units at October 31, 2004, was $2.3 million.

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.

                                    LAW FIRM
                         BLACKWELL SANDERS PEPER MARTIN
                                      LLP

Ms. Linda Crvkel
October 28, 2005
Page 6

     Response: In future filings, the company will revise the disclosure in the
     notes to the company's financial statements to meet the requirements of
     paragraphs 47c and 47e of SFAS No. 123.

Note 8.  Commitments and Contingencies, 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.

     Response: There is no accrual reflected in the financial statements because
     the company has no evidence or expectation of a dealer default. Since 2000,
     the company has only had one event of default by a dealer under the floor
     plan financing arrangement in which the company was required to repurchase
     units. This event represents 8 units of the approximately 14,000 units that
     the company has delivered since 2000. The company honored the arrangement
     and sold the units to another buyer. In this case, the proceeds from the
     defaulting dealer and the ultimate buyer were such that no loss was
     recognized on this transaction. Lastly, the increase in the amount of the
     contingent obligation is due to the seasonality of the School Bus market.

General

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

     Response: As of October 31, 2004, the company's allowance for doubtful
     accounts was $174,000. The company's Valuation and Qualifying Accounts are
     not material and therefore, Schedule II is not currently required. In
     future filings, the company will