September 11, 2018

William Dockman
Interim Chief Financial Officer
W R GRACE & CO
7500 Grace Drive
Columbia, MD 21044

       Re: W R GRACE & CO
           Form 10-Q for the period ended March 31, 2018
           Filed May 9, 2018
           File No. 1-13953

Dear Mr. Dockman:

       We have completed our review of your filing. We remind you that the
company and its
management are responsible for the accuracy and adequacy of their disclosures,
notwithstanding
any review, comments, action or absence of action by the staff.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of
Manufacturing and
                                                          Construction