Mail Stop 7010

      December 2, 2005

Via U.S. mail and facsimile

Mr. Rodney L. Underdown
Chief Financial Officer, Compass Minerals Group, Inc.
8300 College Boulevard
Overland Park, Kansas 66210

	RE:	Form 10-K for the fiscal year ended December 31, 2004
		Form 10-Q for the period ended September 30, 2005
			File No. 333-82700

Dear Mr. Underdown:

		We have reviewed these filings and your response letter
dated October 13, 2005 and have the following comments.  If you
disagree with a comment, 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 for the Year Ended December 31, 2004

Prior Comment 3
1. We note your response to prior comment 3.  In future filings,
please revise your proposed disclosures to fully comply with the
guidance in our response to question 8 of "Frequently Asked
Questions
Regarding the Use of Non-GAAP Financial Measures" (FAQ).  It
appears
to us that the disclosures you proposed do not adequately address
the
material limitations associated with the non-GAAP measure you
present
or how you compensate for those material limitations.  It appears
to
us that the material limitations associated with the non-GAAP
measure
you present include:
* It excludes interest expense. Since you borrow money to finance
your operations, interest expense is a necessary element of your
costs and ability to generate revenue. Therefore any performance
measure that excludes interest expense has material limitations;
* It excludes depreciation and amortization. Because you use
capital
assets, depreciation and amortization are necessary elements of
your
costs and ability to generate revenue. Therefore any performance
measure that excludes depreciation and amortization has material
limitations; and
* It excludes taxes. Because the payment of taxes is a necessary
element of your operations, any performance measure that excludes
tax
expense has material limitations.

Prior Comments 5 and 9
2. We note your responses to prior comments 5 and 9.  Please
provide
us the following additional information:
* Explain your accounting policy related to tax valuation
allowances,
including how you determined the amounts you recorded at each
balance
sheet date;
* Explain your accounting policy related to tax contingency
accruals,
including how you determined the amounts you recorded at each
balance
sheet date.  If you don`t accrue tax contingencies in accordance
in
SFAS 5, please explain how your accounting is appropriate;
* Provide us proposed disclosures, to be included under critical
accounting policies in future filings, that adequately address the
material estimates, assumptions and uncertainties related to your
determination of tax valuation allowances and tax contingency
accruals;
* Tell us if there material differences in the assumption you and
your parent use to determine tax valuation allowances and tax
contingency accruals.  If there are, please explain the reasons
for
the differences.

Form 10-Q for the Quarter Ended September 30, 2005

Prior Comment 6
3. We note the disclosures you provided in your September 30, 2005
Form 10-Q.  As previously requested, please revise future annual
and
quarterly filings to disclose that each guarantor subsidiary is
"100%
owned" as required by Rule 3-10(i)(8) of Regulation S-X and
defined
in Rule 3-10(h)(1) of Regulation S-X.  Please be advised that the
term "wholly-owned" is defined in Rule 1-02(aa) of Regulation S-X
and
is not the same as the term "100% owned".  If each guarantor
subsidiary is not "100% owned", please explain to us how your
current
disclosures comply with Rule 3-10 of Regulation S-X.

*    *    *    *

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

      If you have any questions regarding these comments, please
direct them to Marie Trimeloni, Staff Accountant, at (202) 551-
3734
or, in her absence, to Anne McConnell, Review Accountant, at (202)
551-3709.

							Sincerely,



							John Cash
							Accounting Branch Chief

Mr. Rodney L. Underdown
December 2, 2005
Page 3 of 3




UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

         DIVISION OF
CORPORATION FINANCE