TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo May 19, 2022 Anshooman Aga Chief Financial Officer Harsco Corporation 350 Poplar Church Road Camp Hill, PA 17011 Re: Harsco Corporation Form 10-K for the Year Ended December 31, 2021 Filed February 24, 2022 File No. 001-03970 Dear Mr. Aga: We have limited our review of your filing to the financial statements and related disclosures 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 these comments 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 comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 10-K for the Year Ended December 31, 2021 Management's Discussion and Analysis of Financial Condition and Results of Operations Results of Operation, page 27 1. We note in your discussion of results of operations that some of the facts, circumstances, or events cited as contributory to a change are quantified while others are not. For example, in your discussion of factors impacting the Environmental segment's operating income, employee termination cost changes and the impact of Brazil's sales and use tax are quantified, while improved overall steel production and higher contributions from eco- products are not. Please review and revise your entire discussion of results of operations to quantify each factor cited as a reason for variation. Refer to the guidance in Item 303(b)(2)(i). 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 Anshooman Aga Harsco Corporation May 19, 2022 Page 2 absence of action by the staff. You may contact Amy Geddes at 202-551-3304 or Lyn Shenk at 202-551-3380 with any questions. FirstName LastNameAnshooman Aga Sincerely, Comapany NameHarsco Corporation Division of Corporation Finance May 19, 2022 Page 2 Office of Trade & Services FirstName LastName