Mail Stop 0306

      February 8, 2005

VIA U.S. MAIL and FACSIMILE (314) 771-0650


Daniel C. Dunn
Vice President and Chief Financial Officer
Allied Healthcare Products, Inc.
1720 Sublette Avenue
St. Louis, MO  63110

	RE:	Allied Healthcare Products, Inc.
		Form 10-K/A for the fiscal year ended June 30, 2004
		Filed October 1, 2004
		File No. 000-19266

Dear Mr. Dunn:

      We have reviewed your response letter dated January 28, 2005
and related filings and have the following comments.  We have
limited
our review to only your financial statements and related
disclosures
and will make no further review of your documents. Where
indicated,
we think you should revise your filings 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 supplemental
information
so we may better understand your disclosure.  After reviewing this
information, we may or may not 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/A for the year ended June 30, 2004

Critical Accounting Policies - Page 13

1. We note your response to comment 1.  Tell us whether your
auditors
identified any internal control weakness related to the
limitations
in your accounting software that precludes a direct reduction of
obsolete inventory.  Additionally, tell us whether you currently
have
any plans to enhance your accounting software so that inventory
impairments can be tracked by item.
2. As a related matter, tell us why you did not have a similar
charge
to the valuation allowance in the previous two periods for
adjustments to standard cost.  We note that you had a significant
write-down in fiscal 2002.

Exhibits 31.1 and 31.2

3. Please file an amendment to your Form 10-K including the
certification text as included in the appendix to your response
letter dated January 28, 2005.

*    *    *    *

      As appropriate, please amend your Form 10-K and respond to
these comments within 10 business days or tell us when you will
provide us with a response.  Please furnish a cover letter with
your
response that keys your responses to our comments and provides any
requested supplemental information.  Detailed cover letters
greatly
facilitate our review.  Please file your cover letter on EDGAR.
Please understand that we may have additional comments after
reviewing your responses to our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require.
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 filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff 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 Kristin Lochhead, Staff Accountant, at (202) 942-
8972
or me at (202) 942-1791 if you have any questions.

							Sincerely,



							Brian Cascio
							Accounting Branch Chief


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Mr. Dunn
Allied Healthcare Products, Inc.
February 8, 2005
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