Mail Stop 4561
      April 12, 2006

Mr. George B. Sundby
Chief Financial Officer
ABM Industries Incorporated
160 Pacific Avenue, Suite 222
San Francisco, CA 94111

	Re:	ABM Industries Incorporated
		Form 10-K for the Fiscal Year Ended October 31, 2005
		File No. 1-08929

Dear Mr. Sundby:

      We have reviewed your filing and have the following comment.
We have limited our review to only the issue addressed below and
will
make no further review of your document.  In our comment, we ask
you
to provide us with information so we may better understand your
disclosures.  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 on 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 October 31, 2005

Note 18 - Quarterly Information, page 60

1. We note that you restated your financial statements for the
quarterly periods ending in 2005 due to the material weaknesses
relating to Security Services of America, LLC, whose operating
assets
you acquired on March 15, 2004.  Please tell us in detail if these
material weaknesses affected, and to what extent, your 2004
financial
statements and if not tell us how they were only related to the
2005
financial statements.


      Please respond to this comment within 10 business days or
tell
us when you will provide us with a response.  Please file your
response on Edgar.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filings include all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment 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 comment, 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 filings;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; 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 filings or
in
response to our comments on your filings.

      You may contact Thomas Flinn, Staff Accountant, at (202)
551-
3469 or the undersigned at (202) 551-3414 if you have questions.
      			Sincerely,


      Jorge Bonilla
Senior Staff Accountant





Mr. George B. Sundby
ABM Industries Incorporated
April 12, 2006
Page 1