SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE

                                                              March 14 , 2013

Via E -mail
Mr. Russell Chenu
Chief  Financial Officer
James Hardie Industries plc
Europa House, Second Floor,  Harcourt Center
Harcourt Street, Dublin 2, Ireland

RE: James Hardie Industries plc
Form 2 0-F for the  Year Ended March  31, 2012
Filed July 2 , 2012
Form 6 -K
Filed November 16, 2012
Form 6 -K
Filed March 1, 2013
Response dated February 25, 2013
File No. 1-15240

Dear Mr. Chenu :

We have reviewed your response letter dated February 25, 2013  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 providing the requested
information, or by advising us when you will provide the requested response.  If you do not
believe our comments apply to your facts and circumstances, please tell us why in your response.

  After reviewing the information you provide in response to these comments, we may
have additional comments.

Form 20 -F for the Year Ended March 31, 2012

General

1. Where a comment below requests additional disclosures or other revisions to be made, please
show us in your supplemental response what the revisions will look like.  These revisions
should be included in your future filings, including your interim filings, if applicable.

Mr. Russell Chenu
James Hardie Industries plc
March 14 , 2013
Page 2

 Management’s Discussion and An alysis, page 83

Year Ended 31 March 2012  Compared to Year Ended 31 March 2011, page 89

Income tax benefit (expense), page 93

2. We note your response to comment two from our letter dated January 9, 2013.  In your
proposed disclosure, you indicate that the U.S. GAAP effective tax rate is not meani ngful as
it was favorably impacted by RCI’s successful appeal of the ATO’s disputed 1999 amended
tax assessment.  Please ensure that you discuss your U.S. GAAP effective tax rate in the
same manner as your comparable non -GAAP financial measure and that you r corresponding
disclosures do not place more prominence on the non -GAAP financial measures.  Refer to
Item 10(e) of Regulation S -K.

Form 6 -K Filed November 16, 2012

Exhibit 99.2
3. We note your response to comment five from our letter dated January 9, 20 13.  With regard
to the quantitative reconciliation of non -GAAP financial measures that are forward -looking,
Regulation G requires a schedule or other presentation detailing the differences between the
forward -looking non -GAAP financial measure and the app ropriate forward -looking GAAP
financial measure.  If the GAAP financial measure is not accessible on a forward -looking
basis, you should  disclose that fact and provide reconciling information that is available
without an unreasonable effort.  Furthermore, you should identify information that is
unavailable and disclose its probable significance.   Please revise your disclosures
accordingly.  Refer to SEC Release No. 33 -8176.
Exhibit 99.3

4. We note your response to comment six from our letter dated January 9, 2013.  Given that the
description operating profit before income taxes could be viewed to be confusingly similar to
your operating income line item presented in your  US GAAP financial st atements and Rule
5-03 of Regulation S -X would imply that items such as interest expense and interest income
would not generally be included in the determination of operating income or profit, please
help us better understand how you determined your curren t presentation of operating profit
before income taxes is appropriate.  Please also tell us what consideration you gave to
changing the description of the line item currently described as EBIT to operating income to
be consistent with the financial stateme nts provided in your Form 20 -F for the year ended
March 31, 2012 as well as the financial statements provided in Exhibit 99.5 of this Form 6 -K.

5. We note your response to comment seven from our letter dated January 9, 2013.  We
continue to have difficulty u nderstanding how you determined it was appropriate to present
full non -GAAP financial statements for purposes of reconciling non -GAAP measures to the
most directly comparable U.S. GAAP measures.  Please revise your presentation to provide
relevant informat ion to investors without providing full non -GAAP financial statements.

Mr. Russell Chenu
James Hardie Industries plc
March 14 , 2013
Page 3

 Alternatively, you may consider including summary financial information rather than full
non-GAAP financial statements.  For additional guidance, please refer to Compliance and
Disclos ures Interpretation 102.10 which is available on our website at
http://www.sec.gov/divisions/corpfin/guidance/nongaapinterp.htm .

Form 6 -K Filed March 1, 2013

Exhibit 99.5

6. During the nine months ended December 31, 2012, you recorded a provision related to New
Zealand product liability claims of $13.2 million which represented approximately 10% of
your operating income for this period.  You are becoming exposed to liability f or a greater
proportion of these claims due to the insolvency of co -defendants and the expiration of some
of your rights of recovery from third -parties.  In this regard, please address the following:
 You disclose the amount of provision for product liabili ty claims, net of estimat ed third -
party recoveries, is $16.5 million at December 31, 2012 .  Please also disclose the
corresponding gross asset and liability amounts recorded for your provision for product
liability claims and estimated th ird-party recoveri es; and
 If there is at least a reasonable possibility that a loss exceeding amounts already
recognized may have been incurred, please either disclose an estimate (or, if true, state
that the estimate is immaterial in lieu of providing quantified amounts) o f the additional
loss or range of loss, or state that such an estimate cannot be made.   Please refer to ASC
450-20-50.  If you conclude that you cannot estimate the reasonably possible additional
loss or range of loss, please supplementally: (1) explain to  us the procedures you
undertake on a quarterly basis to attempt to develop a range of reasonably possible loss
for disclosure and (2) what specific factors are causing the inability to estimate and when
you expect those factors to be alleviated.  We recog nize that there are a number of
uncertainties and potential outcomes associated with loss contingencies.  Nonetheless, an
effort should be made to develop estimates for purposes of disclosure, including
determining which of the potential outcomes are reaso nably possible and what the
reasonably possible range of losses would be for those reasonably possible outcomes.

You may contact Ernest Greene , Staff Accountant , at (202) 551 -3733 or Nudrat Salik,
Staff Accountant , at (202) 551 -3692 if you have q uestions regarding these comments.

       Sincerely,

/s/ Rufus Decker

        Rufus Decker
       Accounting Branch Chief