October 6, 2005


By facsimile to (610) 594-3013 and U.S. Mail


John R. Gailey III, Esq.
Vice President, General Counsel and Secretary
West Pharmaceutical Services, Inc.
101 Gordon Drive
Lionville, PA 19341

Re:	West Pharmaceutical Services, Inc.
	Registration Statement on Form S-3
	Filed September 20, 2005
File No. 333-128438

Dear Mr. Gailey:

	We reviewed the registration statement only for the legality
opinion filed as exhibit 5(a) and have the comments below.  No
further review of the registration statement has been or will be
made.

	We urge all persons by statute responsible for the
registration
statement`s adequacy and accuracy to make certain that all
information required under the Securities Act has been included.
We
remind you to consider applicable requirements for the preliminary
prospectus` distribution.

	Where indicated, we think that you should revise the document
in
response to the comments.  If you disagree, we will consider your
explanation why a comment is inapplicable or a revision is
unnecessary.  Be as detailed as necessary in your explanation.

	Our review`s purpose is to assist you in your compliance with
applicable disclosure requirements and to enhance the overall
disclosure in your document.  We look forward to working with you
to
achieve these objectives.  We welcome any questions that you may
have
about the comments or any other aspect of our review.  You may
call
us at the telephone numbers listed at the end of this letter.

1. We are not making any determination whether the disclosure,
including, for example, cautionary language or the disclosure`s
placement, satisfies the sections` requirements if the
registration
statement states that it:

* Includes forward-looking statements within the meaning of
section
27A of the Securities Act and section 21E of the Exchange Act.

* Otherwise makes reference to those provisions.

* Makes reference to the Private Securities Litigation Reform Act
of
1995 generally.

Exhibit 5(a)

2. Item 601(b)(5)(i) of Regulation S-K requires an opinion of
counsel
on the legality of the securities being registered to indicate
whether the securities will, when sold in the registered offering,
be
legally issued, fully paid, and non-assessable.  Thus, revise the
opinion`s third paragraph to comply with the item`s requirement.

Closing

	File an amendment to the S-3 in response to the comments.  To
expedite our review, West Pharmaceutical Services, Inc. may wish
to
provide us three marked courtesy copies of the amendment.  Include
with the filing any supplemental information requested and a cover
letter tagged as correspondence that keys the responses to the
comments.  If West Pharmaceutical Services, Inc. thinks that
compliance with any of the comments is inappropriate, provide the
basis in the letter.  We may have additional comments after review
of
the amendment, the responses to the comments, and any supplemental
information.

	We urge all persons responsible for the accuracy and adequacy
of
the disclosure in the registration statement reviewed by us to
ensure
that they have provided all information investors require for an
informed decision.  Since West Pharmaceutical Services, Inc. and
its
management are in possession of all facts relating to the
disclosure
in the registration statement, they are responsible for the
adequacy
and accuracy of the disclosures that they have made.

      If West Pharmaceutical Services, Inc. requests acceleration
of
the registration statement`s effectiveness, West Pharmaceutical
Services, Inc. should furnish a letter at the time of the request,
acknowledging that:

* Should the Commission or the staff acting by delegated authority
declare the registration statement effective, it does not
foreclose
the Commission from taking any action on the filing.

* The action of the Commission or the staff acting by delegated
authority in declaring the registration statement effective does
not
relieve West Pharmaceutical Services, Inc. from its full
responsibility for the adequacy and accuracy of the registration
statement`s disclosures.

* West Pharmaceutical Services, Inc. may not assert our comments
or
the declaration of the registration statement`s effectiveness as a
defense in any proceedings initiated by the Commission or any
person
under the United States` federal securities laws.

	The Commission`s Division of Enforcement has access to all
information that West Pharmaceutical Services, Inc. provides us in
our review of the registration statement or in response to our
comments on the registration statement.

	We will consider a written request for acceleration of the
registration statement`s effectiveness under Rule 461 of
Regulation C
under the Securities Act as confirmation that those requesting
acceleration are aware of their responsibilities under the
Securities
Act and the Exchange Act as they relate to the proposed public
offering of the securities specified in the registration
statement.
We will act on the request and by delegated authority grant
acceleration of the registration statement`s effectiveness.

	You may direct questions on comments and disclosure issues to
Edward M. Kelly, Senior Counsel, at (202) 551- 3728 or me at (202)
551-3760.

Very truly yours,





Pamela A. Long

Assistant Director

cc:	Thomas A. Kennedy, Esq.
	Pepper Hamilton LLP
	400 Berwyn Park
	899 Cassatt Road
	Berwyn, PA 19312



John R. Gailey III, Esq.
October 6, 2005
Page 1








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

         DIVISION OF
CORPORATION FINANCE