SecProbe.io

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Mail Stop 7010

						September 26, 2005

via U.S. mail and Facsimile

Mary Beth Gustafsson
Senior Vice President, General Counsel and Secretary
American Standard Companies Inc.
One Centennial Avenue
P.O. Box 6820
Piscataway, New Jersey 08855-6820

	Re:	American Standard Inc.
Form S-4/A filed September 16, 2005
File No. 333-124857

Form 10-K for Fiscal Year Ended December 31, 2004
Form 10-Q for Fiscal Quarters Ended March 31, 2005 and June 30,
2005
File No. 001-11415

Dear Ms. Gustafsson:

      We have reviewed your filing and have the following
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 may ask you to provide us with
supplemental 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 on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

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

Notes to Financial Statements
Note 14. Warranties, Guarantees, Commitments and Contingencies,
page
66

1. We read your responses to our comment 50 from our letter dated
June 10, 2005 and comment 11 from our letter dated August 18,
2005.
You disclosed that costs associated with claims that might be
filed
against you in the future were not recorded because you did not
believe your history and experience with asbestos-related
litigation
was sufficient to allow it to make a reasonable estimate of this
liability.  You also disclosed that because claims are frequently
filed and settled in large groups, the amount and timing of
settlements, as well as the number of open claims, can fluctuate
significantly from period to period.  You also indicated that
approximately 40% of all claims filed against you were filed in a
20-
plus year period prior to 2002, 40% were filed in the 16-month
period
from January 2002 through April 2003, and the remaining 20% were
spread relatively evenly over the next 20 months through December
2004. You disclosed that you believed the dramatic increase in
filings in the 16-month period from January 2002 through April
2003
was influenced by the bankruptcy filings of numerous asbestos
defendants in asbestos-related litigation and the prospect of
various
forms of state and federal judicial and legislative reforms.
Based
on your responses and current disclosure it is still unclear how
you
determined you could not reasonably estimate a liability for
future
claims prior to the fourth quarter of 2004.  Please tell us how
you
determined the activity related to the portion of your claims
filed
prior to 2002 did not provide a substantial enough basis for you
to
estimate your liability for future potential asbestos-related
claims,
with an adjustment to this estimate for any abnormality in the
trend,
which you attribute to be influenced by the bankruptcy filings of
numerous asbestos defendants in asbestos-related litigation and
the
prospect of various forms of state and federal judicial and
legislative reforms.  Your disclosure related to retaining the
assistance of Dr. Rabinovitz of HR&A indicates that Dr. Rabinovitz
is
a respected expert in performing complex calculations such as this
and that she has been involved in a number of asbestos-related
valuations of current and future liabilities, and her valuation
methodologies have been accepted by numerous courts.  Please tell
us
what factors lead you to seek the assistance of HR&A in
calculating
your estimate of your total liability for pending and unasserted
potential future asbestos-related claims in the fourth quarter
2004,
rather than in an earlier period.

2. We read your responses to our comment 52 from our letter dated
June 10, 2005 and comment 11 from our letter dated August 18,
2005.
As of December 31, 2004, your total receivable for probable
asbestos-
related insurance recoveries was $406 million.  You also stated
that
approximately $292 million of your recorded asbestos receivable is
in
litigation in New Jersey.  Please supplementally provide us with
the
following information related to the period 1999 through the
present:
* historically, the total amount of claims from insurance
companies
you have received related to previously recorded asbestos
receivables
and
* historically, the amount of asbestos receivables previously
recorded, for which you later determined were uncollectible.

Closing Comments

      As appropriate, please amend your registration statement in
response to these comments.  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 filings 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.

	Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that:

?	should the Commission or the staff, acting pursuant to
delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;
?	the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and
?	the company may not assert this action 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 connection with our review of
your
filing or in response to our comments on your filing.

      We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

      Please direct accounting comments to Meagan Caldwell, Staff
Accountant, at (202) 551-3754 or, in her absence, to Rufus Decker,
Branch Chief, at (202) 551-3769.  Direct questions on disclosure
issues to Tamara Brightwell, Staff Attorney, at (202) 551-3751 or,
in
her absence, to Lesli Sheppard, Senior Staff Attorney, at (202)
551-
3708, or the undersigned at (202) 551-3760.

Sincerely,

Pamela A. Long
Assistant Director

cc: 	Neal J. White, Esq.
	David A. Cifrino, Esq.
	McDermott Will & Emery LLP
	227 West Monroe Street
	Chicago, Illinois 60606-5096

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Mary Beth Gustafsson
American Standard Inc.
September 26, 2005
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

         DIVISION OF
CORPORATION FINANCE

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