September 9, 2019

Brian L. Koopman
Principal Financial Officer
Utah Medical Products, Inc.
7043 South 300 West
Midvale, Utah 84047

       Re: Utah Medical Products, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2018
           Filed March 31, 2019
           Form 10-Q for the Fiscal Quarter Ended June 30, 2019
           Filed August 9, 2019
           File No. 001-12575

Dear Mr. Koopman:

       We have limited our review of your filings 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-Q for the Fiscal Quarter Ended June 30, 2019

Item 2. Management's Discussion and Analysis of Financial Condition and Results
of Operations
f) Income Before Taxes (EBT), page 14

1.    You present and discuss the measure called "adjusted consolidated EBITDA"
in this
      section without identifying it as non-GAAP and providing the
reconciliation and other
      disclosures required by Item 10(e) of Regulation S-K. Please revise your
presentations of
      non-GAAP measures in future filings to fully comply with that guidance.
Refer also to
      our Compliance & Disclosure Interpretations on non-GAAP financial
measures.
General

2.    We note that you rely very heavily on defined terms throughout the filing
and, especially
      so, in the Analysis of Results of Operations. When preparing your future
filings, consider
 Brian L. Koopman
Utah Medical Products, Inc.
September 9, 2019
Page 2
         using defined terms sparingly in your discussions and disclosures so
that investors can
         more easily read and comprehend the information. Refer to Staff Legal
Bulletin 7. See
         also the guidance provided in the SEC's Plain English Handbook found
at
         www.sec.gov/pdf/handbook.pdf.
       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 Gary Newberry at 202 551-3761 or Martin James, Senior
Assistant
Chief Accountant, at 202 551-3671 with any questions.



FirstName LastNameBrian L. Koopman                            Sincerely,
Comapany NameUtah Medical Products, Inc.
                                                              Division of
Corporation Finance
September 9, 2019 Page 2                                      Office of
Electronics and Machinery
FirstName LastName