SecProbe.io

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                        FOOD TECHNOLOGY SERVICE, INC.
                           502 PRAIRIE MINE ROAD
                            MULBERRY, FL 33860
                              (863)425-0039

                               April 22, 2005

Mr. Jose Forgione
Staff Accountant
Division of Corporation Finance
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C.  20549

    Re:       Form 10-KSB for the year ended December 31, 2004
              Food Technology Service, Inc.
              File No.:  0-19047

Dear Mr. Forgione:

     This will acknowledge receipt of your letter of April 8, 2005 regarding
the Company's Form 10-KSB Report for the year ended December 31, 2004.  Please
be advised as follows:

     1.       Item 8(a) Controls and Procedures:  The following is the
         language which would have been included hereunder after giving
         affect to the staff's comment.

              "The Company's principal executive officer and principal
         financial officer evaluated the effectiveness of the design
         and operation of the Company's disclosure controls and procedures
        (as defined in Rule 13a-14(c) and 15d-14(c) under the Securities
         Exchange Act of 1934, as amended) as of December 31, 2004 (the
         "Evaluation Date"). Based on that evaluation, the principal
         executive officer and principal financial officer of the Company
         concluded that, as of the Evaluation Date, the disclosure controls
         and procedures, established by the Company, were effective to
         ensure that information required to be disclosed by the Company in
         reports that the Company files under the Exchange Act, is
         recorded, processed, summarized and reported on a timely basis in
         accordance with applicable rules and regulations.

                There were no changes in the internal controls over
         financial reporting during the fourth quarter ended December 31,
         2004 that has materially affected, or is reasonably likely to
         materially affect, the Company's internal controls over financial
         reporting."

Mr. Jose Forgione
April 22, 2005
Page Two

     2.       Please be advised that product is irradiated for customers at
         an agreed upon price prior to processing.  Some contracts are in
         writing and some are oral.  Perishable food products are placed on
         the customer's truck immediately after processing.  A minor amount
         of other customer product is stored on premises from time to time.
         Such product is adequately covered by insurance.  The Company's
         performance obligation is completed when the product is processed
         in accordance with the customers' specifications at which time
         revenue is recorded.

     3.       Please be advised that the depreciable basis for Cobalt
         includes the entire amount recorded on the balance sheet.

This letter will acknowledge that:

         *The Company is responsible for the adequacy and accuracy of the
         disclosure in the filings;

         *Staff comments or changes to disclosure in response to staff
         comments do not foreclose the Commission from taking any action
         with respect to the filings; 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.

                                                 Yours truly,

                                                 /S/  Richard G. Hunter

                                                 Richard G. Hunter, Ph.D.

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