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    515 Broadhollow Road

    Suite 1000

    Melville, NY 11747

    516.812.2000

March 24, 2023

Office of Trade & Services

Division of Corporation Finance

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

 Re: MSC Industrial Direct Co., Inc.

Form 10-K for the Fiscal Year Ended September
3, 2022

Filed October 20, 2022

Earnings Release on Form 8-K

Furnished January 5, 2023

Form 10-Q for the Fiscal Quarter Ended December
3, 2022

Filed January 5, 2023

File No. 001-14130

Dear Sir or Madam:

On behalf of MSC Industrial Direct Co., Inc.
(the “Company” or “MSC”) this letter shall serve as an addendum to the Company’s previous letter dated March
16, 2023, which was sent in response to the Staff’s comment letter dated March 6, 2023. Further to the telephone discussion between
the Staff and representatives of the Company, in this letter we are providing draft disclosures we expect to include in future filings
beginning with our earnings release for the fiscal quarter ended March 4, 2023.

 1. Enhanced Disclosure of Operating Cash Flow Conversion

The Company has considered the guidance
set forth in SEC Release No. 33-10751 and how the guidance set forth therein applies to the Company’s disclosure of Operating
Cash Flow Conversion. After consideration of such guidance, the Company believes Operating Cash Flow Conversion is a financial metric
describing the performance of the Company’s business. In future filings and public communications where the Company discusses Operating
Cash Flow Conversion, the Company will include the following disclosure:

The Company defines Operating Cash Flow Conversion as Net
cash provided by operating activities as a percentage of Net income. The Company’s management uses Operating Cash Flow Conversion
to evaluate the Company’s operating performance, in particular how efficiently the Company turns its sales and profits into cash,
and to assess the efficiency of the Company’s use of working capital. The Company believes Operating Cash Flow Conversion is useful
to investors for the foregoing reasons and as a measure of the rate at which the Company converts its net income reported in accordance
with GAAP to cash inflows, which helps investors assess whether the Company is generating sufficient cash flow to provide an adequate
return.

    Office of Trade & Services

United States Securities and Exchange Commission

Page 2

March 24, 2023

 2. Reconciliation of Adjusted Incremental Margin to Incremental Margin

As noted in our prior response to the
Staff’s comment regarding the Company’s use of Incremental Margin and Adjusted Incremental Margin, the Company believes Incremental
Margin is a ratio or statistical measure calculated using exclusively financial measures calculated in accordance with GAAP and that Adjusted
Incremental Margin is a non-GAAP financial measure because it is a ratio or statistical measure calculated using a non-GAAP financial
measure as one of its inputs. In addition to more clearly titling such measures “Incremental Operating Margin” and “Adjusted
Incremental Operating Margin,” in future filings with the SEC or public communications subject to Item 10(e) of Regulation S-K and/or
Regulation G, as applicable, the Company will include narrative disclosure regarding the use of Incremental Margin and Adjusted Incremental
Margin as well as a reconciliation as set forth below (which illustrative reconciliation is prepared using the financial information from
our earnings release for the fiscal quarter ended December 3, 2022 and comparative prior year period):

The Company defines Incremental Operating
Margin as the change in year-over-year Income from Operations as a percentage of the change in year-over-year Net Sales and Adjusted
Incremental Operating Margin as Incremental Operating Margin adjusted to exclude restructuring and other costs, impairment loss and related
costs, and acquisition-related costs by excluding such items from Income from Operations. The Company’s management believes that
Incremental Operating Margin is useful because it shows the direction that operating profit margins are moving as a result of changes
in net sales between periods, and that, by excluding the aforementioned items, Adjusted Incremental Operating Margin helps to more clearly
show, on a comparable basis between periods, trends in the Company’s underlying business and results of operations. The Company
believes that investors benefit from seeing results from the perspective of management in addition to seeing results presented in accordance
with GAAP for the same reasons and purposes for which management uses such non-GAAP financial measures.

    Office of Trade & Services

United States Securities and Exchange Commission

Page 3

March 24, 2023

See the table below for reconciliation
of Adjusted Incremental Operating Margin, a non-GAAP financial measure, to Incremental Operating Margin, the most closely related financial
measure calculated in accordance with financial measures defined by GAAP.

MSC INDUSTRIAL DIRECT CO., INC.

Reconciliations of GAAP and Non-GAAP Financial
Information

(In thousands, except percentages)

    GAAP Financial Measure
    Items Affecting Comparability
    Non-GAAP Financial Measure

    Total MSC Industrial
    Restructuring and Other Costs
    Acquisition-Related Costs
    Adjusted Total MSC Industrial

    Net Sales - thirteen weeks ended December 3, 2022
    $ 957,745
    $ -
    $ -
    $ 957,745

    Net Sales - thirteen weeks ended November 27, 2021
    $ 848,547
    $ -
    $ -
    $ 848,547

    Income from Operations - thirteen weeks ended December 3, 2022
    $ 116,010
    $ (2,094 )
    $ (154 )
    $ 118,258

    Income from Operations - thirteen weeks ended November 27, 2021
    $ 90,732
    $ (5,283 )
    $ -
    $ 96,015

    Incremental Operating Margin - thirteen weeks ended December 3, 2022
      23.1 %
      -2.9 %
      0.2 %
      20.4 %

    GAAP Financial Measure
    Items Affecting Comparability
    Non-GAAP Financial Measure

    Total MSC Industrial
    Restructuring and Other Costs
    Impairment Loss
    Legal Costs (Impairment Loss)
    Adjusted Total MSC Industrial

    Net Sales - thirteen weeks ended November 27, 2021
    $ 848,547
    $ -
    $ -
    $ -
    $ 848,547

    Net Sales - thirteen weeks ended November 28, 2020
    $ 771,904
    $ -
    $ -
    $ -
    $ 771,904

    Income from Operations - thirteen weeks ended November 27, 2021
    $ 90,732
    $ (5,283 )
    $ -
    $ -
    $ 96,015

    Income from Operations - thirteen weeks ended November 28, 2020
    $ 53,908
    $ (3,979 )
    $ (26,726 )
    $ (293 )
    $ 84,906

    Incremental Operating Margin - thirteen weeks ended November 27, 2021
      48.0 %
      1.7 %
      -34.9 %
      -0.3 %
      14.5 %

Thank you for your attention to this matter. Please contact me at (704)
987-5750 should you have any questions or require further information.

Very truly yours,

/s/ Kristen Actis-Grande

Kristen Actis-Grande

Executive Vice President and Chief Financial Officer