SecProbe.io

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      July 6, 2005

Via Fax & U.S. Mail

Mail Stop 3561

Mr. Frank J. Drohan, Chief Executive Officer
Alfa International Corporation
350 Fifth Avenue, Suite 1103
New York, NY 10118

Re: 	Alfa International Corporation (the "Company")
      Form 10- K for the year ended December 31, 2004
      File No. 1-16419

Dear Mr. Drohan:

      We have reviewed your filing 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.  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 may ask you to provide us with
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not 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.

Accounting Comments

Management`s Discussion & Analysis

Liquidity and Capital Resources
1. Please disclose the existence of the factoring arrangement,
here
and in the footnotes to the financial statements.  Describe the
significant contractual terms of the arrangement, the extent to
which
you have used it and, if applicable, how you accounted for any
such
transactions.

Notes to the Consolidated Financial Statements

Revenue Recognition

2. We note that you recognized revenue on product sales upon
shipment. Please supplementally tell us when title to the shipped
goods is transferred to a 3rd party, whether there are return
rights
associated with these shipments and how you record these returns,
and
how you determine that collectibility is probable. Please refer to
SAB No. 104 when preparing your response.

3. As a related matter, in MD&A you refer to management service
revenue from an affiliate.  Tell us about these activities,
identify
the affiliate and indicate whether you expect such revenues to
continue.  Supplementally and, as applicable in your filings,
please
describe your related revenue recognition policies.

* * * * *

       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 supplemental 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 reviewed by the staff to
be
certain 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 Rob Perdue at (202) 551-3303 or Margery Reich
at
(202) 551-3347 if you have questions regarding comments on the
financial statements and related matters.  Please contact me at
(202)
551-3816 with any other questions.

Sincerely,

							Joseph A. Foti
							Senior Assistant Chief
Accountant

Via Facsimile: Mr. Frank J. Drohan
		(212) 563-3355

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