SecProbe.io

July 29, 2011
 Via Facsimile

Ms. Turid M. Sorensen Chief Financial Officer Nordic American Tanker Shipping Limited LOM Building 27 Reid Street Hamilton HM 11, Bermuda
Re: Nordic American Tanker Shipping Limited
 Form 20-F
Filed April 21, 2011 File No. 001-13944

Dear Ms. Sorensen:
 We have reviewed your response letter dated July 20, 2011 and have the following
comments.  In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
 Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.
            Risk Factors, page 5

 If our vessels call on ports located in countries that are subject to rest rictions imposed by the
U.S. or other governments, that could adversel y affect our reputation and the market for our
common stock, page 12.

1. You state in your response to comment 2 in our letter dated June 9, 2011 that your vessels
which have called on Marsa Bashayer, Sudan, “do not employ U.S. citizens and did not
carry U.S.-origin cargoes.”  Please tell us wh ether this statement also applies to your
vessels that have called on Kh arg Island and/or Sirri Island in Iran.  Also, tell us the
nature of cargoes your vessels loaded and/or unloaded when  they called on the ports in
Iran.

Ms. Turid M. Sorensen Nordic American Tanker Shipping Limited July 29, 2010 Page 2

 2. In your responses to comments 2 and 3 in our letter dated June 9, 2011 you provide us
with information related to the contacts of your vessels with Sudan and Iran covering the
period through December 31, 2010.  As we reque sted in those comments, please provide
us with information that is current through June 30, 2011.
 Critical Accounting Estimates – Long-lived assets and impairments, page 40

3. We note from your response to our prior comme nt eight that you have provided us with
proposed disclosure which discusses the market  value of your vessels as compared to the
carrying value of your vessels.  However, it does not appear from your response that you
plan on including this disclosure in the Crit ical Accounting Estimat es section of MD&A
in future filings.  As previously noted, due to your continued decr ease in operating and
net income coupled with your operating losses experienced in the la st fiscal year and
recent interim period as well as the highly mate rial amount of vessels that represent in
excess of 90% of your total cons olidated asset value, we belie ve that the disclosure in
critical accounting estimates  should be significantly expand ed to describe the specific
factors and conditions where you would record an impairment loss for such vessels.  Please confirm that you will revise future fili ngs to include the proposed disclosure and
illustrative table in the Critical Accounting Estimates section of MD&A.  Also, we note from the introductory paragraph to the il lustrative table you have provided in your
response, that the table indi cates which of your vessels has a market value below its
carrying value.  However, it does not appear that this distinction has been made in the
table which lists all of your vessels and thei r carrying values.  Please advise or revise
accordingly.

Audited Financial Statements

 Note 1. Business and Summary of  Significant Accounting Policies

 – Drydocking, page F-8

4. We note that your response to our prior comm ent 11 includes detail of  the nature of the
costs deferred as drydocking costs.  Howe ver, we do not believe that your response
adequately responds to our prior comment.  Please confirm to us that you will provide a
detailed description of the types of drydoc king costs included in deferred drydocking
costs and an affirmative statement that the t ypes of costs deferred are consistent in all
periods presented, in the notes to the financial statements and in the Critical Accounting
Estimates section of MD&A.
 - Revenue and Expense Recognition, page F-8

Ms. Turid M. Sorensen Nordic American Tanker Shipping Limited July 29, 2010 Page 3

 5. We note from your response to our prior comme nt 12, that you believe that based on the
terms of the agreement with th e customer, it is appropriate to recognize revenue from the
completion of discharge of the vessel’s previ ous cargo to the completion of discharge of
the current cargo.  Please revise your revenue recognition policy in the notes the financial
statements to  include a disclosure that indicat es that “based on the terms of the customer
agreement, a voyage is deemed to commen ce upon the completion of discharge of the
vessel's previous cargo and is deemed to e nd upon the completion of discharge of the
current cargo.”

You may contact Claire Erla nger at (202) 551-3301 or Joe Foti at (202) 551-3816 if you
have questions regarding comments on the fina ncial statements and related matters.

Sincerely,
   /s/ Linda Cvrkel
Linda Cvrkel Branch Chief

 Via Facsimile 011 47 33 42 73 01