March 10, 2006


United States Securities and Exchange Commission
Division of Corporation Finance
Washington. D.C. 20549-0510

Re:  Dynamic Materials
     Form 10-K for the year ended December 31, 2004
     File No. 1-14775

Dear Mr. Cash:

We acknowledge receipt of your letter dated February 21, 2006, which included
additional comments that resulted from your review of our February 9, 2006
response letter relating to your review of the above-referenced filing. We have
considered your additional comments and provide you with the following revised
response.

FORM 10-K FOR THE FISCAL YEAR ENDED DECEMBER 31, 2004
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Financial Statements for the Year Ended December 31, 2004
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Note 8- Discontinued Operations, page 53
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     1.   We note your response to comment 3 from our letter dated November 10,
          2005. Based on the additional information that you provided to us, we
          will not object to the classification of the divestiture of your Spin
          Forge division as discontinued operations. However, we believe that
          you should provide a more robust discussion of your agreements with
          Aerojet, and how you concluded that these agreements qualified for
          treatment as discontinued operations, in your future Exchange Act
          filings. Given that you retained ownership of your manufacturing
          equipment and are leasing that equipment to Aerojet under an operating
          lease, we also believe it would be useful to your readers if you
          clarified that you do not intend to operate the leased equipment
          again, and that you plan to liquidate this equipment if Aerojet does
          not exercise their purchase option to buy the equipment.


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          Response
          --------

          In our future Exchange Act filings, including our December 31, 2005
          Form 10-K that we will file on or before March 16, 2006, we will
          include a more robust discussion of our agreements with Aerojet
          (without specifically naming this third party) and the basis for our
          conclusion that these agreements qualified for treatment as
          discontinued operations. We will also clarify that we do not intend to
          ever again operate the leased equipment and that we plan to
          immediately liquidate any leased manufacturing equipment to the extent
          that Aerojet does not exercise its purchase option on all or a portion
          of the leased equipment when the lease term expires on January 1,
          2007.

FORM 10-Q FOR THE PERIOD ENDED SEPTEMBER 30, 2005
- -------------------------------------------------

Note 9 - Stock Split
- --------------------

     2.   Please confirm to us that you will give retroactive effect to your
          October 2005 2-for-1 stock split on your balance sheet, statement of
          stockholders' equity, and EPS calculations in your upcoming December
          31, 2005 Form 10-K. Refer to SAB Topic 4:C.

          Response
          --------

          We hereby confirm that we will give retroactive effect to our October
          2005 2-for-1 stock split on our balance sheets and statements of
          stockholders' equity, and in our EPS calculations, in our upcoming
          December 31, 2005 Form10-K as required by SAB Topic 4:C.


                                      * * *

          We hope that our responses adequately address the additional comments
          made in your February 9, 2006 letter. Please let us know if you
          require additional clarification with respect to our responses or have
          any additional questions.

          Sincerely,

          /s/ Richard A. Santa

          Richard A. Santa
          Vice President and Chief Financial Officer


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