AMERICAN SAFETY INSURANCE HOLDINGS, LTD.

January 18, 2007

Mr. Jim B. Rosenberg
Ms. Ibolya Ignat
Securities & Exchange Commission
Division of Corporate Finance
Mail Stop 6010
Washington, DC 20549

Re: American Safety Insurance Holdings, Ltd. File No. 001-14795

Ladies & Gentlemen:

On behalf on American Safety Insurance Holdings, Ltd. (the “Company”), we are providing responses to the Staff’s comments received orally on January 11, 2007. The comments relate to the Company’s Form 10-K for the year ended December 31, 2005 and Form 10-Q for the quarters ended March 31, 2006 and June 30, 2006. In this letter, references to “we” refer to the Company. To facilitate your review the Staff’s comments have been reproduced, with the Company’s responses following each comment.

1. Comment: We believe that the unrealized losses from December 31, 2005, and at June 30, 2006, on investments are material to net income and as such including additional disclosures in future filings will be beneficial to the investors. Will you please confirm to us that you will include in future filings the information requested by our original Comment 2c1. And can you please provide to us your revised proposed disclosure.

Response. In future Form 10-K filings, we will provide disclosure comparable to the following wherever unrealized losses are material to net earnings:

We note that should we conclude that securities carrying an unrealized loss have been other than temporarily impaired, our future earnings would be reduced by the carried unrealized loss on fixed maturity investments, which was $6.0 million at December 31, 2005. As mentioned previously, these unrealized losses resulted from of rising interest rates and not from credit issues with the issuer. As a result, management concluded that

Mr. Jim B. Rosenberg
Ms. Ibolya Ignat
Securities and Exchange Commission
January 18, 2007
Page 2

the recoverability of the principal and interest is reasonably assured and no impairment needed to be recognized.

2. Comment: We would like you in addition, to disclose your conclusion of whether any concentrations in any non-investment grade securities exist as requested in Comments 2c2 and 2c3.

Response: In future Form 10-K filings, we will disclose concentrations in our investment portfolio and non-investment grade securities comparable to the following:

We note the following at December 31, 2005: Mortgage backed securities were the largest class of investments in the portfolio, representing 30.1% of the entire portfolio. All mortgage backed securities are insured by the U.S. Government. The single largest security in this class is a Fannie Mae investment with a $6.6 million par value. U.S. Government securities were the second largest class at 19.7%, with the largest security having a par value of $8.4 million. Corporate fixed maturities were the third largest class at 19.2% of the total portfolio, with the largest single security being Praxair, Inc. with a par value of $2.5 million. In the corporate sector, the Company has concentrations in the banking area with $16.8 million invested, or 3.8% of the total portfolio, with the largest single security being Bank of America with a par value of $2.0 million. The Company also has a concentration in the consumer-non cyclical area with $11.6 million invested, or 2.7% of the total portfolio, with the largest single security being Bottling Group, LLC with a par value of $2.4 million. The Company had $2.8 million, or 0.8% of its investment portfolio, in below investment grade securities. The unrealized loss on these securities was $153,000 at December 31, 2005.

3. Comment: In response to Comment 3 you included a table in your response letter. We would like you to revise the table to reconcile the disclosure in the table to the amounts included in the financial statements. It appears that the tables should be presented on a gross basis consistent with the balance sheet. If your table excludes some of your lines of business, can you please include those in the table?

Response: In future Form 10—K filings we will include a table detailing our loss reserves on a gross basis. The table in the 2005 Form 10-K would have been as follows:

Mr. Jim B. Rosenberg
Ms. Ibolya Ignat
Securities and Exchange Commission
January 18, 2007
Page 3

Gross Loss Revenues:


	December 31, 2005
	Loss					Loss Adjustment
										Total
	Case			IBNR		Case		IBNR		Case and IBNR
On-Going:
Environmental		14,141			27,193		2,596		15,716		59,646
Construction		17,992			96,250		4,950		64,165		183,357
Surety		(2,181	)		134		1,065		711		(271	)
Programs		32,612			21,317		34,362		25,499		113,790

		62,564			144,894		42,973		106,091		356,522

Run-Off:		17,426			1,772		16,096		3,057		38,351


Total		79,990			146,666		59,069		109,148		394,873


	December 31, 2004
	Loss					Loss Adjustment
										Total
	Case			IBNR		Case		IBNR		Case and IBNR
On-Going:
Environmental		11,079			3,256		20,380		13,645		48,360
Construction		19,882			5,070		65,123		43,417		133,492
Surety		(899	)		265		650		433		449
Programs		30,432			5,943		46,287		22,552		105,214

		60,494			14,534		132,440		80,047		287,515

Run-Off:		13,327			1,185		16,651		2,946		34,109


Total		73,821			15,719		149,091		82,993		321,624

4. Comment: Can you please confirm in your response letter that you will disclose the methods used to calculate IBNR reserves for each material line of business similar to the information included in your letter in response to Comment 3c3.

Response: In future Form 10-K filings we will provide disclosure comparable to the following:

As the Company writes long-tail business, the current year ultimate loss reserve is developed using the expected loss ratio method. The method is appropriate because there are very few claims reported from the most recent accident year for long-tail lines of business. The expected loss ratio is determined based on the review of the projected ultimate loss ratios for the prior accident years. At December 31 2005, the carried loss and loss adjustment reserves for accident years prior to 2005 were determined largely based on the indications produced by the Bornhuetter-Ferguson method because of the additional claims experience gained as the line matures.


	Sincerely, W. Brinkley Dickerson, Jr.