SecProbe.io

November 21, 2019
Anne Lloyd
Interim Chief Financial Officer
James Hardie Industries plc
Europa House, Second Floor
Harcourt Centre
Harcourt Street, Dublin 2, D02 WR20, Ireland
Re:James Hardie Industries plc
Form 20-F for the Year Ended March 31, 2019
Filed May 21, 2019
Form 20-F/A for the Year Ended March 31, 2019
Filed August 8, 2019
File No. 001-15240
Dear Ms. Lloyd:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.  In our comment, we may ask you to provide us
with information so we may better understand your disclosure.
            Please respond to this comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this comment, we may have additional comments.
Form 20-F/A for the Year Ended March 31, 2019
Controls and Procedures, page 1
1.We note that you amended your Form 20-F to include additional disclosures to indicate
the scope of your assessment of the effectiveness of internal control over financial
reporting for the fiscal year ended March 31, 2019 did not include the operations of
Fermacell.  Given the revisions to your Form 20-F, please address the following:
•Please help us understand why Management's Report on Internal Control Over
Financial Reporting and the Opinion on Internal Control Over Financial Reporting
from your independent auditor in your Form 20-F filed on May 21, 2019 did not
include this disclosure;
•Please help us understand the specific facts and circumstances that occurred after

 FirstName LastNameAnne Lloyd
 Comapany NameJames Hardie Industries plc
 November 21, 2019 Page 2
 FirstName LastName
Anne Lloyd
James Hardie Industries plc
November 21, 2019
Page 2
your initial filing that resulted in you amending your Form 20-F on August 8, 2019,
including how you identified the omission of this disclosure in your Form 20-F;
•In your amended Form 20-F you conclude that your disclosure controls and
procedures were effective as of March 31, 2019.  Please explain to us how you
considered the definition of disclosure controls and procedures provided in Rule 13a-
15(e), which indicates that effective controls and procedures would ensure that
information required to be disclosed by the issuer is recorded, processed, summarized
and reported within the time periods specified in the Commission’s rules and forms.
Please explain to us how and why you concluded your disclosure controls and
procedures are effective in light of the previously omitted disclosures; and
•Please explain to us how you re-evaluated whether your internal control over
financial reporting was effective as of March 31, 2019.

            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            You may contact Jeffrey Gordon at 202-551-3866 or Anne McConnell at 202-551-
3709 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing