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CORRESP
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October 28, 2005

VIA EDGAR

United States Securities and Exchange
Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549

ATTN:
Pamela A. Long, Assistant Director

  Re:

  West Pharmaceutical Services, Inc.:

  Registration Statement on Form S-3
  filed September 20, 2005

  Commission File No. 333-128438

Dear Ms. Long:

On behalf of West Pharmaceutical Services, Inc.
(the “Company”), we are hereby responding to comments by the staff (the “Staff”)
of the Securities and Exchange Commission contained in your letter dated October 6,
2005 (the “Comment Letter”), in connection with the above-captioned
registration statement (the “Registration Statement”).  Exhibit references contained in the
response are to the form of prospectus contained in Pre-Effective Amendment No. 1
to the Registration Statement, which is being filed simultaneously with this
response.  For convenience of reference,
the Staff comment is reproduced below in italics under the Staff’s topic
headings followed by the related Company response.

1.                                       We
are not making any determination whether the disclosure, including, for example
cautionary language or the disclosure’s placement, satisfies the sections’
requirements if the registration statement states that it:

•                                                  Includes
forward-looking statements within the meaning of section 27A of the
Securities Act and section 21E of the Exchange Act.

•                                                  Otherwise
makes reference to those provisions.

•                                                  Makes
reference to the Private Securities Litigation Reform Act of 1995 generally.

The Staff’s comment is duly noted.

Exhibit 5(a)

2.                                       Item 601(b)(5)(i) of Regulation S-K requires an
opinion of counsel on the legality of the securities being registered to
indicate whether the securities will, when sold in the registered offering, be
legally issued, fully paid, and non-assessable.
Thus, revise the opinion’s third paragraph to comply with this
requirement.

As requested,
we have revised the third paragraph of the opinion to indicate that the
securities will, when sold in the registered offering, be legally issued, fully
paid, and non-assessable.

*                                         *                                         *

We thank you for your prompt attention to
this letter responding to the Staff’s Comment Letter and look forward to
hearing from you at your earliest convenience.
Please direct any questions concerning this filing to the undersigned at
610.594.3319 or to John Duke at 610.640.7839.

  Very truly yours,

  /s/ John R. Gailey III

  John R. Gailey III, Esq.

  cc:

  Edward M. Kelly, Esq., Senior Counsel

  John P. Duke, Esq.

  Thomas A. Kennedy, Esq.

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