SecProbe.io

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Mail Stop 6010

October 12, 2005

Via U.S. Mail and Facsimile 408.262.9042

Mr. Gordon Arnold
Chief Financial Officer
Sierra Monitor Corporation
1991 Tarob Court
Milpitas, California 95035

      Re:	Sierra Monitor Corporation
		Form 10-KSB for the Fiscal Year Ended December 31, 2004
Forms 10-QSB for the Fiscal Quarters Ended
March 31, 2005 and June 30, 2005
File No. 0-07441

Dear Mr. Arnold:

      We have reviewed your filings and have the following
comments.
We have limited our review of your filings to those issues we have
addressed in our comments.  Where indicated, we think you should
revise your document in response to these comments.  If you
disagree,
we will consider your explanation as to why our comment is
inapplicable or a revision is unnecessary.  Please be as detailed
as
necessary in your explanation.  In some of our comments, we 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 filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 10-KSB for the Fiscal Year Ended December 31, 2004

Financial Statements, page F-1

Note 1 - Summary of the Company and Significant Accounting
Policies,
page F-6

Revenue Recognition, page F-8

1. Please tell us and revise future filings to disclose how you
recognize revenue from each type of product and service you
provide
to customers, identifying in each instance those events that would
indicate that each criterion outlined in SAB Topic 13.A has been
met.

2. Tell us and revise future filings to discuss the types of
discounts and allowances you offer as well as your terms for
returns,
refund rights and any other post delivery obligations you have and
how they impact the amount and timing of revenue recognized.

3. We note from your website that sales relating to your
FieldServers
actually include software, hardware, training and technical
support.
You make mention that you offer free software in certain
instances.
Please tell us then, why you believe that you do not enter into
multiple-element arrangements related to the sales of
FieldServers.
Specifically, please tell us and revise future filings to address
how
you allocate total consideration for multi-element transactions
and
how you determine fair value, particularly when there are
undelivered
elements such as installation and training.

Note 11 - Segment Reporting, page F-17

4. We noted your discussion of the three main products groups,
consisting of gas detection devices, environmental controllers and
communications bridges, in the business section and in the
management`s discussion and analysis section. We also noted that
each
group contributed more than 10% of total revenues in each of the
years presented.  Furthermore, we note you have a fourth product
group or "business unit` which you refer to as the OEM
Coprocessors,
on your website but not mentioned in your filing. Based on this
information, please tell us why you believe that you only operate
in
one operating segment.  Also tell us why these product groups or
business units do not represent separate operating and reporting
segments of your company in accordance with SFAS 131.

Note 7 - Warrants, page F-14

5. Please tell us why you deferred $30,800 of expense relating to
the
fair value of a warrant granted to a consultant in 2004.

Exhibit 31

6. We note that the certifications filed in Exhibit 31 were not in
the proper form. The required certifications must be in the exact
form prescribed; the wording of the required certifications may
not
be changed in any respect, except for the modifications
temporarily
permitted to be made to the fourth paragraph of the certification
required to be filed as Exhibit 31 pursuant to Part III.E of
Release
No. 8238. Accordingly, please amend your Form 10-KSB to comply
with
Item 601(b)(31) of Regulation S-B.

Forms 10-QSB for the quarters ended March 31, and June 30, 2005

Notes to the Unaudited Interim Condensed Financial Statements,
page 5

a) Revenue Recognition, page 5

7. We note that you have expanded your footnote to now include
government contracts.  Please tell us further the nature of your
government contracts and why you believe that accounting for them
using the percentage of completion method is appropriate.

Item 3 - Controls and Procedures, page 12

8. We note your disclosure that management has concluded that your
disclosure controls and procedures are effective "to ensure that
information we are required to disclose in reports that we file or
submit under the Securities and Exchange Act of 1934 is recorded,
processed, summarized and reported within the time periods
specified
in SEC rules and forms." The language that is currently included
after the word "effective" in your disclosure appears to be
superfluous, since the meaning of "disclosure controls and
procedures" is established by Rule 13a-15(e) of the Exchange Act.
However, if you do not wish to eliminate this language, please
revise
future filings so that the language that appears after the word
"effective" is substantially similar in all material respects to
the
language that appears in the entire two-sentence definition of
"disclosure controls and procedures" set forth in Rule 13a-15(e).

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment 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 amendment and responses to our
comments.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and 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 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 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 Praveen Kartholy, Staff Accountant at
202.551.3778 or me at 202.551.3604 if you have questions regarding
these comments and related matters.  You may also contact Michele
Gohlke, Branch Chief at 202.551.3327.

      Sincerely,

      Kate Tillan
Assistant Chief Accountant

Gordon Arnold
Sierra Monitor Corporation
October 12, 2005
Page 5

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