Mail Stop 3561
April 19, 2006

Via U.S. Mail and Facsimile

Walter T. Bromfield
Chief Financial Officer
Maritrans Inc.
Two Harbour Place
302 Knights Run Avenue
Tampa, FL 33602


RE:	Maritrans Inc. (the Company)
Form 10-K for the Fiscal Year Ended December 31, 2005
File No. 1-09063

Dear Mr. Bromfield:

      Based upon an examination restricted solely to
considerations
of the Financial Statements, Management`s Discussion and Analysis,
and Selected Financial Data, the staff has the following comments
on
the above-referenced documents.  We think you should revise all
future filings in response to these comments.  If you disagree, we
will consider your explanation as to why our comments are
inapplicable or a revision is unnecessary.  Please be as detailed
as
necessary in your response.  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.

Please respond to confirm that such comments will be complied
with,
or, if certain of the comments are deemed inappropriate by the
Company, advise the staff of the reason thereof.
      Pursuant to Rule 101(a)(3) of Regulation S-T, your response
should be submitted in electronic form, under the label "corresp"
with a copy to the staff.  Please respond within ten (10) business
days.

Form 10-K for the Fiscal Year ended December 31, 2005

Consolidated Statements of Income, page 38

1. Please revise your presentation of total operating expense in
future filings to include Gain on sale of assets.  Refer to
footnote
68 of SAB Topic 13 which states "Gains or losses from the sale of
assets should be reported as "other general expenses" pursuant to
Regulation S-X, Article 5-03(b)(6)."

Note 1 - Organization and Significant Accounting Policies, page 41
Maintenance and Repairs, page 42

2. Reference is made to the disclosure regarding your provision of
costs for upcoming major periodic overhauls of vessels and
equipment
made in advance of performing the related maintenance and repairs.
Please explain to us in greater detail how you determine or
calculate
the provision for accrued shipyard costs and the period over which
such costs are being amortized.  Please note that if you are
accruing
in advance for dry docking costs over the period to the next dry
docking, it is staff position that this is no longer an acceptable
accounting method within your industry.  The accrual method
assumes
you have incurred a liability at the balance sheet date; however,
if
you are accruing in advance we do not believe that an obligation
has
been incurred at the balance sheet date under the definition set
forth in paragraph 35 of CON 6.  We note that EITF Topic D-88 does
not provide guidance on how to account for dry docking costs;
rather
it discusses methods currently being used in the industry and
states
that SEC staff would not object to a conclusion that a change from
accruing in advance to another method is preferable.  The
discussion
in EITF Topic D-88, in March 2000, was in anticipation that a
planned
SOP project would prohibit accruing in advance.  The SOP project
was
discontinued in April 2004 and it has been staff position that
this
method is not an acceptable method within your industry.
Currently,
the only acceptable methods include expensing maintenance costs as
incurred or the deferral method under which costs incurred are
capitalized and amortized to expense over the period until the
next
major overhaul or drydocking.  Please revise your accounting for
major overhauls and drydocking costs to comply with the guidance
noted above.


Note 7.  Income Taxes, page 48

3. Please tell us in further detail the nature of the "other"
matters
that reduced your effective income taxes by $7,561,000 from the
statutory rate during 2003.

Other

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  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 filing;

* staff comments or changes to disclosure in response to staff
comments 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 Jean Yu at (202) 551-3305 or Linda
Cvrkel
at (202) 551-3813 if you have questions regarding the comments
above.


	Sincerely,



	Linda Cvrkel
	Branch Chief
Walter T. Bromfield
Maritrans Inc.
April 19, 2006
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