SecProbe.io

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Mail Stop 0306

      January 18, 2005

VIA U.S. MAIL and FACSIMILE (314) 771-0650

Daniel C. Dunn
Vice President and Chief Financial Officer
Allied Healthcare Products, Inc.
1720 Sublette Avenue
St. Louis, MO  63110

	RE:	Allied Healthcare Products, Inc.
		Form 10-K/A for the fiscal year ended June 30, 2004
		Filed October 1, 2004
		Form 10-Q for the quarter ended September 30, 2004
		File No. 000-19266

Dear Mr. Dunn:

      We have reviewed your response letter dated November 24,
2004
and related filings and have the following comments.  We have
limited
our review to only your financial statements and related
disclosures
and will make no further review of your documents. Where
indicated,
we think you should revise your filings 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 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 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 June 30, 2004

Critical Accounting Policies - Page 13

1. Refer to your response to previous comment 2.  We note that
during
2004 you recorded an adjustment to your reserve for excess and
obsolete inventory to reflect the current replacement cost of
inventory.  You recorded this adjustment as an increase to the
reserve and decrease to inventory, having a net zero impact on net
inventory or income.  SAB 5BB indicates an impairment charge to
inventory creates a new cost basis for that inventory and,
therefore,
cannot be subsequently revalued.  As such, it appears as thought
this
charge represents additional impairment that should be recognized
currently in income.  Please clarify or provide details of the
basis
for this accounting treatment.
2. As a related matter, you state that when obsolete inventory has
been sold for less than cost, the loss on the sale has been
charged
to the inventory reserve.  Again, this appears to be additional
impairment in your inventory that should be recognized currently
in
income. Please tell us in detail the basis for your accounting
treatment.
Exhibits 31.1 and 31.2

3. Refer to previous comment 17.  We see that you filed an
amendment
on October 1, 2004 to correct the text of your certifications.
However, the certifications included in that amended filing are
still
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.  Refer to Part II.B.4 of Release
No.
8124.  Accordingly, please file an amendment to your Form 10-K
that
includes the entire filing together with currently dated
certifications of each of your current CEO and CFO in the form
currently set forth in Item 601(b) (31) of Regulation S-K.

Form 10-Q for the quarter ended September 30, 2004

Consolidated Financial Statements

Note 7.  Agreement with Abbott Laboratories - Page 10
4. We see that you are recognizing $600,000 for costs incurred in
connection with the withdrawal of Baralyme(R) from the market as
net
sales with a corresponding cost of sales for the estimated cost of
the suspended operations at your Stuyvesant Falls, New York,
facility.  You disclose that the estimated amount of severance and
benefit payments will total $138,000.  Tell us and disclose in
future
filings the nature of the remainder of these costs. Additionally,
tell us how you have considered whether these costs are exit costs
under SFAS 146 and the related disclosure requirements. In
addition,
clarify the basis for recognizing the $600,000 payment in net
sales
rather than as a reduction (reimbursement) of costs incurred.  Is
there any obligation to repay any of these amounts?  More details
should also be provided of the basis for recognition of amounts
over
the term of the agreement and any additional obligations or other
factors that could impact this treatment.

Management`s Discussion and Analysis of Financial Condition and
Results of Operations

5. Please revise future filings to explain significant changes in
your operating trends.  For example, you state that international
business was down 17% but do not provide an explanation.
Item 4. Controls and Procedures - Page 16
6. In future filings, please revise your disclosure concerning
changes in internal controls over financial reporting to indicate
whether there was any change in your internal control over
financial
reporting that occurred during the fiscal quarter, not subsequent
to
period end, that has materially affected or is reasonably likely
to
materially affect your internal control over financial reporting,
as
required by Item 308(c) of Regulation S-K as amended effective
August
13, 2003.

*    *    *    *

      As appropriate, please amend your Form 10-K and respond to
these comments within 10 business days or tell us when you will
provide us with a response.  Please furnish a cover letter with
your
response that keys your responses to our comments and provides any
requested supplemental information.  Detailed cover letters
greatly
facilitate our review.  Please file your cover letter on EDGAR.
Please understand that we may have additional comments after
reviewing your 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.
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 filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff 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 Kristin Brooks Lochhead, Staff Accountant, at
(202)
942-8972 or me at (202) 942-1791 if you have any questions.

							Sincerely,

							Brian Cascio
							Accounting Branch Chief

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Mr. Dunn
Allied Healthcare Products, Inc.
January 18, 2005
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