SEC Company Response from SIFCO INDUSTRIES INC (SIF) (CIK 0000090168) (SIF) — Mar 28, 2005
SIFCO INDUSTRIES INC (SIF) (CIK 0000090168)
Date: March 28, 2005 · CIK: 0000090168 · Accession: 0000950152-05-002607
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March 24, 2005
Ms. Nancy Bonham
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 Ms. Bonham:
In response to the SEC's letter to SIFCO Industries, Inc. dated March 22, 2005,
SIFCO replies as follows:
o The aerospace portion of SIFCO's Turbine Component Services and Repair
Group requires the procurement of licenses/authority, which certify
that the Company has obtained approval to perform certain proprietary
repair processes. Such approvals generally take the form of (i) a
process to repair a turbine engine component or (ii) an inspection
process to determine whether a turbine engine component is repairable.
o SIFCO management, as a matter of practice in conducting its internal
communications relative to business performance, does not
measure/monitor the number of repair approvals that it may have
procured during a particular period, or the change in the number of
such approvals from one period to the next.
o SIFCO management does not consider the change (either increase or
decrease) in the number of repair approvals that it may have procured
from one period to the next to necessarily be (i) an accurate
indicator of the repair volume/demand in its business or (ii) an
indication of a trend regarding its ability to procure repair
approvals. The life cycle of an aerospace turbine engine, and
consequently the life cycle of a related aerospace turbine engine
component repair license/authority, is long. Therefore procurement of
repair approvals does not need to occur annually.
SIFCO will be pleased to discuss this information further with the SEC. If you
have any questions regarding this information, please contact me directly at
(216) 432-6278 at your earliest convenience.
Sincerely,
/s/ Frank A. Cappello
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Frank Cappello
V.P.Finance and CFO
CC: M. Lipscomb (SIFCO Audit Committee)
J. Robinson (Grant Thornton)
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