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    North American Salt Company

Great Salt Lake Minerals

Sifto Canada, Inc.

Salt Union Ltd.

October 13, 2005

Mr. John Cash

Accounting Branch Chief

United States Securities and Exchange Commission

Washington, D.C. 20549

    RE:

    Compass Minerals Group, Inc.

          Form 10-K for the fiscal year ended December 31, 2004

          Form 10-Q for the quarter ended June 30, 2005

                    File No. 333-82700

Dear Mr. Cash:

This letter is in reference to your inquiry dated September 28, 2005 concerning Compass Minerals
Group, Inc. (the “Company” or “CMG”). Our responses have been numbered to match the comments in
your letter. We have addressed both filings in the same response.

    1.

    Where a comment below requests additional disclosures or other revisions, please
provide us your intended disclosure. These disclosures should be included in future
filings.

The Company acknowledges the comment and agrees, as further described below, to revise its
disclosures in future filings.

    2.

    Specifically state whether any of CMI’s debt is guaranteed by you. If it is, provide
all the disclosures required by FIN 45 in the notes to your financial statements. In
addition, please revise MD&A to more fully address the expected impact on your future cash
flows of CMI’s subordinated discount debentures and subordinated discount notes beginning
to require cash interest payments and disclose the term of each debt.

CMG has not guaranteed the debt of CMI and has no legal obligation to service the debt. We have
therefore concluded that the measurement and disclosure requirements of FIN 45 are not applicable.
However, to provide clarity and additional information with regard to CMI’s debt service
requirements and its potential impact to CMG, which is CMI’s likely source of funds, we will
include additional disclosures about the terms of CMI’s debt and provide information in the notes
to the Contractual Cash Obligation table disclosing the timing of CMI’s principle and interest
payments. Our proposed additional disclosure for future 10-K filings is included below.

Parent Company Obligations

In 2002, CMI issued $123.5 million in aggregate principal amount at maturity of senior discount
notes due 2012. No cash interest will accrue on the senior discount notes prior to December 15,
2007. The accreted value of the senior discount notes will increase from the date of issuance until
December 15, 2007 at a rate of 123/4% per annum, reflecting the accrual of non-cash interest, such
that the accreted

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value will equal the principal amount at maturity on December 15, 2007. Cash interest will accrue
on the senior discount notes at a rate of 123/4% per annum, beginning December 15, 2007 through
maturity. The first cash interest payment will be made by CMI on June 15, 2008.

In 2003, CMI issued $179.6 million in aggregate principal amount at maturity of subordinated
discount notes due 2013. No cash interest will accrue on the subordinated discount notes prior to
June 1, 2008. The accreted value of the subordinated discount notes will increase from the date of
issuance until June 1, 2008 at a rate of 12% per annum, reflecting the accrual of non-cash
interest, such that the accreted value will equal the principal amount at maturity on June 1, 2008.
Cash interest will accrue on the subordinated discount notes at a rate of 12% per annum, beginning
June 1, 2008 through maturity. The first cash interest payment will be made by CMI on December 1,
2008. The proceeds from the sale of the subordinated discount notes were distributed to CMI
stockholders in the form of a common stock dividend.

CMG has not guaranteed and has no legal obligation to service CMI’s debt. Accordingly, CMI’s
senior discount notes and subordinated discount notes are not a part of our consolidated financial
statements. Further, the restrictive covenants applicable to our parent’s debt are no more
restrictive than CMG’s debt covenants discussed in Note 8 to the Consolidated Financial Statements.
However, our operations are currently the main source of cash that is expected to service the
senior discount notes, subordinated discount notes and any future dividends on CMI common stock.

Our contractual cash obligations and commitments as of December 31, 2005 are as follows (in
millions):

Payments Due by Period

    Less than

    2–3

    4–5

    After 5

    Contractual Cash Obligations

    Total

    1 Year

    Years

    Years

    Years

    Long-term Debt(a)

    Interest(b)

    Operating Leases(c)

    Unconditional Purchase Obligations(d)

    Estimated future pension benefit payments(e)

    Total Contractual Cash Obligations

Amount of Commitment Expiration per Period

    Less than

    2–3

    4–5

    After 5

    Other Commitments

    Total

    1 Year

    Years

    Years

    Years

    Revolver

    Letters of Credit

    Performance Bonds(f)

    Total Other Commitments

    (a)

    Amounts exclude CMI’s scheduled principal payments on its
senior discount notes and subordinated discount notes
discussed above totaling $___, with all scheduled maturities
after 5 years.

    (b)

    Based on maintaining existing debt balances to maturity.
Estimated interest on the Term Loan was based on a rate of
4.85%. Amounts exclude CMI’s interest payments totaling $___
of which $___, $___and $___will be paid in 2-3 years, 4-5
years and thereafter, respectively.

    (c)

    We lease property and equipment under non-cancelable
operating leases for varying periods.

    (d)

    We have long-term contracts to purchase certain amounts of
electricity and steam.

    (e)

    Note 9 to our audited consolidated financial statements
provides additional information.

    (f)

    Note 10 to our audited consolidated financial statements
provides additional information under Sales Contracts.

    3.

    We note that you present certain non-GAAP financial measures, however it is not clear to
us why you believe these measures are useful. Please be advised that:

    •

    If you present these measures because they are helpful in describing your
ability to satisfy debt service, capital expenditures, working capital requirements
and dividend payments, revise your disclosures to fully comply with Item 10(e) of
Regulation S-K. In this regard, it appears to us that you should reconcile these
measures to cash flows from operating activities and you should not adjust them for
items that require cash payments.

    •

    If you present these measures because they are tied to your financial covenants,
revise your disclosures to fully comply with the guidance set forth in our response
to question 10 of the “Frequently Asked Questions Regarding the Use of Non-GAAP
Financial Measures” (FAQ).

    •

    If you present these measures because they are helpful in analyzing your
operating results, revise your disclosures to fully comply with the guidance set
forth in our response to question 8 of the “Frequently Asked Questions Regarding
the Use of Non-GAAP Financial Measures” (FAQ).

Management uses EBITDA as a measure to evaluate the operating performance of the Company. Because
the Company’s resource allocation, income tax positions and borrowing activities are managed at the
corporate level outside the control of the operating units, management believes EBITDA provides a
useful measure of operating performance. In our future filings, we will expand our discussion to
more fully explain management’s evaluation and reasons for using EBITDA as a performance measure.
However, in future filings we will omit any discussion of EBITDA as a measure of liquidity, and
eliminate the reconciliation to Adjusted EBITDA and the related reference to our debt covenants.

Our proposed disclosure for future 10-K filings is presented below.

Sensitivity Analysis Related to EBITDA

Management uses a variety of measures to evaluate the performance of CMG. While the consolidated
financial statements provide an understanding of our overall results of operations, financial
condition and cash flows, management also uses EBITDA as a useful measure to evaluate operating
performance of our core business operations. Because our resource allocation, income tax positions
and cost of capital are managed at a corporate level outside the control of the operating units,
management believes EBITDA also provides a useful measure to evaluate our operating performance.
EBITDA is not calculated under GAAP and should not be considered in isolation or as a substitute
for net income, cash flows or other income or cash flow data prepared in accordance with GAAP or as
a measure of our overall profitability or liquidity. While EBITDA is frequently used as a measure
of operating performance, this term is not necessarily comparable to similarly titled captions of
other companies due to the potential inconsistencies in the method of calculation. The calculation
of EBITDA as used by management is set forth in the table below.

    For the year ended December 31,

    2005

    2004

    2003

    Net income

    $

    $
    56.5

    $
    43.5

    Interest expense

    37.4

    39.1

    Income tax expense

    24.6

    10.2

    Depreciation and amortization

    41.3

    42.1

    EBITDA

    $

    $
    159.8

    $
    134.9

EBITDA does however include other items, both cash and non-cash in nature, which management
believes are not indicative of the ongoing operating performance of our core business operations.
During 2004, Apollo elected to terminate the amended management consulting agreement resulting in a
final payment of $4.5 million for all services rendered under the agreement. EBITDA for 2003
includes costs of amending our senior credit facilities of $1.4 million and a gain from the early
extinguishment of debt totaling $1.9 million. EBITDA also includes other non-operating income and
expenses, primarily foreign exchange losses resulting from the translation of intercompany debt,
totaling $      million, $7.8 million and $6.1 million, for 2005, 2004 and 2003, respectively.

    4.

    The estimated useful lives for land improvements, buildings and improvements, machinery
and equipment and mineral interests have large ranges. Please separately disclose the
ranges of useful lives for your various land, buildings, machinery and mineral interests.
For categories that still have broad useful lives, please separately discuss the types of
assets that fall in each part of the range and disclose the weighted average useful life.

CMG’s land improvements consist primarily of transportation and utility infrastructure (including
roads and barge docks) and evaporation ponds which are depreciated over 10 to 20 years. A few
additional assets have shorter or longer lives, but those assets are immaterial to this category,
and stating the shorter or longer life as a matter of policy is not useful to a reader in assessing
the longevity of the asset category. Noting that immaterial items are not required to be
disclosed, management proposes to adjust the life range of this category to 10 to 20 years as
management believes this range is more representational of this asset group.

Buildings consist of permanent and moveable structures with lives primarily ranging from 20 to 40
years depending on the type of building. Building and leasehold improvements are depreciated over
the lesser of the asset’s useful life or the remaining life of the building or lease term. In
future filings, we will disclose separately the depreciable lives of the buildings from the
improvements and discuss the types of structures and improvements included in each category.

Machinery and equipment includes light and heavy construction vehicles with lives ranging from 3 to
10 years, and other mining and production equipment which are depreciated over 10 to 15 years with
an immaterial amount depreciated over 20 years. In future filings, we will disclose the lives of
the vehicles separately from other mining and production assets.

Our proposed disclosure for future 10-K filings is presented below.

h. Property, Plant and Equipment: Property, plant and equipment are stated at cost and include
interest on funds borrowed to finance construction. The costs of replacements or renewals which
improve or extend the life of existing property are capitalized. Maintenance and repairs are
expensed as incurred. Upon retirement or disposition of an asset, any resulting gain or loss is
included in operations.

Property, plant and equipment also includes mineral interests. The Company leases probable mineral
reserves at several of its extraction facilities. These leases have varying terms, and many
provide for a

royalty payment to the lessor based on a specific amount per ton of mineral extracted or as a
percentage of revenue. The Company’s rights to extract minerals are contractually limited by time.
However, the Company believes it will be able to continue to extend lease agreements as it has in
the past, at commercially reasonable terms, without incurring substantial costs or material
modifications to the existing lease terms and conditions, and therefore, believes that assigned
lives are appropriate. The Company’s leased mineral interests are amortized on a
units-of-production basis over the respective estimated lives of mineral deposits not to exceed 99
years. The weighted average amortization period for these probable mineral reserves is XX years as
of December 31, 2005. The Company also owns other mineral properties. The weighted average life
for these probable owned mineral reserves is XX years as of December 31, 2005.

Buildings and structures are depreciated over lives generally ranging from 20 to 40 years.
Portable buildings generally have shorter lives than permanent structures. Leasehold and building
improvements have shorter estimated lives of 10 to 20 years or lower based on the life of the lease
to which the improvement relates.

The Company’s owned mineral interests and all other asset classes or groups are amortized on a
straight-line basis over the following estimated useful lives:

    Land improvements

    10 to 20 years

    Buildings and structures

    20 to 40 years

    Leasehold and building improvements

    10 to 20 years

    Machinery and equipment — vehicles

    3 to 10 years

    Machinery and equipment — other mining and production

    10 to 15 years

    Furniture and fixtures

    3 to 10 years

    Mineral interests

    20 to 99 years

    5.

    Please provide us additional information regarding the specific facts and circumstances
related to the change in the tax valuation allowance on deferred tax assets and the change
in the tax contingency accrual during the year ended December 31, 2004. In addition,
please provide us additional information regarding the impact and terms of the tax
indemnification agreement with Mosaic and your accounting for the agreement.

The Company has a deferred tax asset valuation allowance for net operating loss carryforwards
(“NOLs”). The annual utilization of the NOLs is limited by tax law due to changes in ownership of
the Company. Additionally, the NOLs are subject to expiration since there are prescribed
carryforward periods allowed by tax law which existed in the periods the NOLs were generated.
Based on these factors and consistent with the principles for accounting for income taxes found in
FASB Statement No. 109, the Company has recorded a valuation allowance on its NOL deferred tax
asset for the portion that the Company does not believe will, more likely than not, be utilized
given the carryforward expiration periods and annual utilization limitations.

After the recapitalization of the Company in 2001, the Company determined that there were certain
tax positions it could assert which would increase the Company’s ability to utilize more N