SecProbe.io

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                                [S&K LETTERHEAD]

                                                                 August 23, 2007

United States
Securities and Exchange Commission
Division of Corporation Finance
100F Street, N.E
Washington, D.C. 20549

Attention:     Linda Cvrkel

Re:    Nordic American Tanker Shipping Ltd.
       Form 20-F for the year ended December 31, 2006
       Filed June 29, 2007
       File No. 1-13944

Dear Ms. Cvrkel,

We represent Nordic American Tanker Shipping Limited (the "Company").  By letter
dated August 9, 2007, the Staff of the Securities and Exchange  Commission  (the
"Staff")  provided  comments to the Company's Annual Report on Form 20-F for the
fiscal year ended December 31, 2006.

The  Company's  responses,  together  with the Staff's  comments,  are set forth
below.

1.  Statements of Shareholders' Equity

We note from the disclosures in the Company's statements of shareholders' equity
for 2004 and 2005  that the  Company  recognized  compensation  expense  of $9.2
million and $3.6 million during 2004 and 2005 in connection with the issuance of
restricted shares. We also note from the disclosure provided in Note 2 that this
expense related to shares issued to the Manager,  Scandic American Shipping Ltd.
Please  tell us and  explain  in  notes  to your  financial  statements  how you
calculated or determined the amount of expense recognized in connection with the
issuance of restricted shares to the Manager during all periods presented in the
Company's  financial  statements.  Please  note  that  Note 7 to  the  Company's
financial  statements  currently only disclose the amount of expense  recognized
during fiscal 2006.

As the Staff has pointed out, the Company  issued  restricted  shares to Scandic
American Shipping Ltd. ("Scandic") under the Management Agreement dated June 30,
2004, as amended.  Restricted  shares were issued during each of the  respective
years ended December 31, 2004,  2005 and 2006.  The restricted  shares issued to
Scandic, a non-employee, are fully vested on the grant date and are not attached
to future performance under the Management Agreement.  The Company accounted for
these shares in accordance  with EITF Issue No. 00-18,  "Accounting  for Certain
Transactions  Involving  Equity  Instruments  Granted to Other Than  Employees",
which states that the measurement date for an award that is  nonforfeitable  and
that  vests  immediately  should be the date the award is  issued,  even  though
services have not yet been performed.  Accordingly the compensation  expense for
each of the  respective  issuances  was  measured  at fair value on the date the
award was issued, or the grant date, and expensed immediately as performance was
deemed to be complete. The fair value was determined using the stated par value,
the number of shares  issued,  and the average fair value,  or  Company's  stock
price on the date of grant.

Note 7 to the  Company's  financial  statements  specifically  disclosed the par
value,  number  of  shares  issued,  average  stock  price,  and the  applicable
compensation  expense for the year ended December 31, 2006. The Company  advises
the Staff that Note 12 to the Company's financial  statements  discloses that in
the year ended  December  31,  2006 the Company  had two public  offerings.  The
number of shares  issued and the average stock price as disclosed in Note 7, are
the total shares issued related to both offerings and the average stock price is
the weighted  average of the stock price at the two grant  dates,  respectively.
The Company acknowledges that this information has not been explicitly disclosed
for the years  ended  December  31,  2004 and 2005,  respectively.  The  Company
undertakes  to  include  this  information  within  the body of the Form 20-F in
future filings.

The  Company  supplementally  advises  the  Staff  that the  amount  of  expense
recognized  during fiscal 2004 and 2005, as well as 2006, is disclosed in Note 5
to the Company's financials statements.  The Company further advises that Note 2
to the Company's  financial  statements  discloses the expense recognized during
fiscal year 2004,  2005 and 2006, as well as the  classification  as general and
administrative   expense.   The  Company   recognizes  the  usefulness  of  this
information and undertakes to improve with more centralized disclosure in future
filings.

2.  Business and Summary of Significant Accounting Policies

In your revenue  recognition  policy,  you state that voyage revenues and voyage
expenses are  recognized on a pro rata basis based on the relative  transit time
in each period.  This policy is appropriate  under the guidance of EITF 91-9 for
revenues,  but not for  expenses.  Please note that  pursuant to the guidance in
EITF 91-9,  voyage expenses  should be expensed as incurred.  Please revise your
financial  statements  to  recognize  voyage  expenses as incurred or explain in
detail why you do not believe this is required.

The Company  respectfully  advises the Staff that all revenues and expenses from
voyage charters are recognized on a percentage of completion method. The Company
utilizes a discharge-to-discharge  basis in determining percentage of completion
for all spot voyages,  whereby it recognizes  revenue rateably from when product
is discharged (unloaded) at the end of one voyage to when it is discharged after
the next voyage.

Voyage expenses are all expenses unique to a particular voyage, including bunker
fuel expenses,  port expenses,  canal tolls,  agency fees and  commissions.  The
bunker fuel expenses and commissions are incurred evenly for the duration of the
voyage. Port expenses, canal tolls and agency fees are incurred at the load port
and at the discharge port. The impact of recognizing  voyage  expenses  rateably
over the length of each voyage is not  materially  different on a quarterly  and
annual basis from recognizing such costs as incurred.

The Company  performed an analysis and concluded  that it has recorded an excess
of  approximately  $30,000  and  $105,000  in port  expenses  for the year ended
December  31, 2006 and 2005,  respectively,  as compared to the method set forth
under EITF 91-9. The Company  advises the Staff that there was no impact for the
year ended  December  31,  2004.  The  vessels  owned by us during 2004 were all
employed  under bare boat or long term  charters,  for which the Company was not
responsible for voyage expenses.

The Company  performed a SAB 99 analysis and  concluded  that the impact of this
excess  expense  on its  financial  statements  as of and  for the  years  ended
December  31,  2006 and 2005,  in the  light of  surrounding  circumstances  and
considering both quantitative and qualitative factors, is immaterial. The impact
of the  potential  misstatement  to the  financial  statements as of and for the
years ended December 31, 2006 and 2005 are less than 0.04% and 0.2% respectively
of net profit and shareholders' equity. As stated above, there was no impact for
the year ended December 31, 2004.

In  response  to  this  comment,  the  Company  will  continue  to  monitor  the
materiality and impact of its applied policy as compared to the method set forth
under EITF 91-9. Furthermore, the Company undertakes to expand its disclosure in
future filings.

3.  Note 7. Share-Based Compensation

We note from the disclosure provided in Note 7 that compensation cost related to
stock  options and  restricted  shares  issued to employees is based on the fair
value of the stock  options  or  restricted  shares at the grant  date while the
expense related to stock options and restricted  shares issued to  non-employees
is measured at fair value at the balance sheet date.  Please tell us and explain
in the notes to your financial  statements why you are  recognizing  the expense
associated  with non- employee  stock-options  and restricted  shares as of each
balance  sheet  date  rather  than on the basis of the fair  value of options or
restricted shares at the date of grant. As part of your response, please explain
why you believe the treatment  used is  appropriate  and in accordance  with the
guidance in SFAS  No.123R,  EITF 96-18 or other  relevant  technical  accounting
literature. We may have further comment upon receipt of your response.

The Company measures compensation expense for its non-employee stock options and
non-employee  restricted shares, granted under the 2004 Stock Incentive Plan, in
accordance with EITF Issue No. 96-18,  "Accounting for Equity  Instruments  that
are  Issued to Other  Than  Employees  for  Acquiring,  or in  Conjunction  with
Selling, Goods or Services".  The restricted shares granted under the 2004 Stock
Incentive  Plan does not include the  non-employee  restricted  shares issued to
Scandic American, which were measured at the grant date and further discussed in
the Company's  response to Comment #1 above. The fair value of the option issued
is used to measure the  transaction,  as it is more reliable than the fair value
of the  services  received.  The fair  value  is  measured  at the  value of the
Company's  common stock on the date that the commitment  for  performance by the
counterparty has been reached or the counterparty's performance is complete. The
counterparty's  performance  had  not  yet  been  completed,  and a  performance
commitment  has not yet been  achieved  (as  there is not a  sufficiently  large
incentive for non-performance by the non-employee),  and therefore a measurement
date has not yet  occurred  as defined by Issue 1 of EITF  96-18.  As such,  the
options should be accounted for as variable under Issue 3 of EITF 96-18.

Issue 3 of EITF 96-18 states in part:

     "The Task  Force  reached a  consensus  that when it is  appropriate  under
     generally  accepted  accounting  principles for the issuer to recognize any
     cost of the transaction  during  financial  reporting  periods prior to the
     measurement date, for purposes of recognition of costs during those periods
     the equity instruments should be measured at their then-current fair values
     at each of those interim financial  reporting dates.  Changes in those fair
     values  between  those  interim  reporting  dates should be  attributed  in
     accordance with the methods illustrated in Interpretation 28."

In response  to the  Staff's  comment,  the  Company  undertakes  to enhance the
disclosure in the notes to the financial statements on a prospective basis.

4.  Note 7

Also,  please  revise Note 7 to disclose the activity with regards to your stock
options during each period presented in your financial statements.  Refer to the
disclosure requirements outlined in paragraph 47 of SFAS No.123 and A240 of SFAS
No.123R.  Also, please ensure that your financial  statements include all of the
disclosures required by paragraph A240 of SFAS No. 123R, as applicable.

The  Company   respectively   advises  that  Staff  that   certain   disclosures
requirements  as outlined in paragraph  A240 SFAS No. 123R were not set forth in
Note 7 to the Company's financial  statements as they were not applicable to the
Company.  Specifically,  there were no employee or non-employee  options granted
during  2004,  and  therefore  a  description  of  the  method  and  significant
assumptions  utilized to estimate fair value,  the  weighted-average  grant date
fair  value of  options  granted  during  the year  and the  cash  flow  effects
resulting from share-based payment arrangements were not required. Additionally,
taxes are not imposed on the Company and  therefore a disclosure  regarding  the
total  recognized  tax  benefit for each year for which an income  statement  is
presented is deemed  unnecessary.  Further,  there have been no exercise nor any
payments  related to the options in 2005 and 2006, and therefore no related cash
flow  effects.  The Company  supplementally  advises the Staff that the non-cash
effect of the share based  compensation  expense is separately  disclosed in the
Statement of Cash Flows. Lastly, there has been no significant  modification for
any of the years for which an income statement is presented.

For all remaining  disclosures,  the Company undertakes to revise future filings
to include all of the disclosures for all of the periods required by A240 - A242
of SFAS 123(R),  including,  without limitation,  (i) the weighted-average grant
date fair value of options  granted  during the year ended December 31, 2005 and
(ii) the total fair value of shares  vested  during the year 2006.  The  Company
advises the Staff that it believes that the information is implicitly  disclosed
as the weighted  average fair value and total number of shares vested during the
year is  included in Note 7;  however,  the  Company  undertakes  to enhance the
disclosure in response to this comment.

5.  Other

The Company  understands that it is responsible for the adequacy and accuracy of
the  disclosure in its filing;  Staff comments or changes to disclosure 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.

Please feel free to contact the  undersigned  at (212)  574-1223,  or  Christine
Westbrook of this office at (212) 574-1371, with any questions or comments.

                                                  Very truly yours,

                                                  SEWARD & KISSEL LLP

                                                  /s/ Seward & Kissel LLP
                                                  -----------------------

                                                  By:  Gary J. Wolfe
cc: Herbjorn Hannson
    Chief Executive Officer
    Nordic American Tanker Shipping Limited

    Ingebret Hisdal
    Partner, Deloitte AS

SK 01318 0002 805148
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