Mail Stop 6010


      October 18, 2005


Via U.S. Mail and Facsimile to (631) 761-0969

Richard G. Satin
Vice President of Operations and General Counsel
Medical Action Industries Inc.
800 Prime Place
Hauppauge, NY 11788


	Re:	Medical Action Industries Inc.
		Form 10-K for the Fiscal Year Ended March 31, 2005
		Filed June 13, 2005
Form 10-Q for the Fiscal Quarter Ended June 30, 2005
      File No. 000-13251

Dear Mr. Satin:

      We have reviewed your filing and have the following
comments.
We have limited our review of your filing to those issues we have
addressed in our comments.  Where indicated, we think you should
revise your document in response to these comments.  If you
disagree,
we will consider your explanation as to why our comment is
inapplicable or a revision is unnecessary.  Please be as detailed
as
necessary in your explanation.  In some of our comments, we may
ask
you to provide us with information so we may better understand
your
disclosure.  After reviewing this information, we may raise
additional
comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We
look forward to working with you in these respects.  We welcome
any
questions you may have about our comments or any other aspect of
our
review.  Feel free to call us at the telephone numbers listed at
the
end of this letter.





Form 10-K for the Fiscal Year Ended March 31, 2005

Item Nine (A) - Controls and Procedures, page 19

1. We note your disclosure that your principal executive officer
and
principal financial officer have evaluated your disclosure
controls
and procedures as of a date within 75 days of the filing date of
your
annual report.  Please revise to disclose management`s conclusion
regarding the effectiveness of your disclosure controls and
procedures
as of the end of the period covered by the annual report.  Refer
to
Item 307 of Regulation S-K and Part III.F of Management`s Reports
on
Internal Control Over Financial Reporting and Certification of
Disclosure in Exchange Act Periodic Reports, Release No. 33-8238.

2. We also note that management has concluded that your disclosure
controls and procedures are effective "in alerting them on a
timely
basis to material information relating to the company required to
be
included in y(our) reports filed or submitted under the Exchange
Act."
Revise to clarify, if true, that your officers concluded that
disclosure controls and procedures are also effective to ensure
that
information required to be disclosed in the reports filed or
submitted
under the Exchange Act is recorded, processed, summarized and
reported
within the time periods specified in the rules and forms of the
Securities and Exchange Commission and is accumulated and
communicated
to management to allow timely decisions regarding required
disclosure.
Refer to Exchange Act Rule 13a-15(e).

3. We see your disclosure that there have been no significant
changes
in your internal controls or other factors that could
significantly
affect these controls subsequent to the date of the evaluation.
Please
revise your disclosure to indicate whether there was any change in
your internal control over financial reporting that occurred
during
the fourth quarter that has materially affected or is reasonably
likely to materially affect your internal control over financial
reporting, as required by Item 308(c) of Regulation S-K.

Exhibit 99.2

4. We note that the certifications filed as part of this exhibit
were
not in the proper form. The required certifications must be in the
exact form prescribed. We note that the certification that refers
to
the certifying officers` responsibility for establishing and
maintaining internal control over financial reporting for the
company,
as well as paragraph 4(b), must be provided in the first annual
report
required to include management`s internal control report and
thereafter. Accordingly, please file an amendment to your Form 10-
K
that includes the entire filing together with the certifications
of
each of your current CEO and CFO in the form currently set forth
in
Item 601(b)(31) of Regulation S-K. This comment also applies to
your
quarterly filing.
Management`s Discussion and Analysis of Financial Condition, page
6

Critical Accounting Policies, page 8

Goodwill and Other Intangibles, page 9

5. We note that you operate in one industry, disposable medical
products, and appear to conclude that you are comprised of one
operating segment as defined by paragraph 10 of SFAS 131. We also
note
your disclosure that "goodwill is tested for impairment at the
reporting unit level."  Please tell us and expand your disclosure
in
future filings to explain the concept of reporting units, as
defined
by paragraph 30 of SFAS 142, and to identify yours including the
amount of goodwill allocated to each.

6. In this regard, please discuss why your reporting units are not
considered operating segments under SFAS 131.  Revise future
filings
to explicitly state that the chief operating decision maker does
not
review disaggregated segment information, if true.

	As appropriate, please amend your filing and respond to these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the
amendment to expedite our review.  Please furnish a cover letter
with
your amendment that keys your responses to our comments and
provides
any requested information.  Detailed cover letters greatly
facilitate
our review.  Please understand that we may have additional
comments
after reviewing your amendment and responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing
includes all information required under the Securities Exchange
Act of
1934 and that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have
made.

	In connection with responding to our comments, please
provide, in
writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and
* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal
securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division
of Corporation Finance in our review of your filing or in response
to
our comments on your filing.

      You may contact Kevin Kuhar, Staff Accountant, at (202) 551-
3662
or me at (202) 551-3554 if you have questions regarding these
comments
on the financial statements and related matters.  In this regard,
do
not hesitate to contact Martin James, Senior Assistant Chief
Accountant, at (202) 551-3671.




								Sincerely,



								Angela Crane
								Branch Chief

Richard G. Satin
Medical Action Industries Inc.
October 18, 2005
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