March 27, 2019

Peter Beaven
Chief Financial Officer
BHP Group Ltd
171 Collins Street, Melbourne
Victoria 3000 Australia

       Re: BHP Group Ltd
           Form 20-F for the Fiscal Year Ended June 30, 2018
           Filed September 18, 2018
           File No. 001-09526

Dear Mr. Beaven:

       We have reviewed your filing and have the following comments. In some of
our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.

       Please respond to these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 20-F for the Fiscal Year Ended June 30, 2018

Additional Information
Reserves
FY 2018 Reserves, page 296

1.    Expand your discussion of the changes in the net quantities of total
proved reserves to
      include an appropriate narrative explanation of the significant changes
for each of the
      annual periods presented, e.g. including the fiscal years ending December
31, 2016 and
      2017, respectively. Refer to Instruction 1 to Paragraph (b) of Item 302
of Regulation S-K
      and FASB ASC 932-235-50-5.
Proved Undeveloped Reserves, page 301

2.    Expand your discussion of the changes in the net quantities of proved
undeveloped
      reserves to include an appropriate narrative explanation of the changes
related to such
      factors as revisions of the previous estimates, improved recovery,
extensions and
 Peter Beaven
FirstName LastNamePeter Beaven
BHP Group Ltd
Comapany2019
March 27, NameBHP Group Ltd
March 27, 2019 Page 2
Page 2
FirstName LastName
         discoveries, and the purchase and/or sale of minerals in place. To the
extent that two or
         more unrelated factors are combined to arrive at a change in the net
quantities, your
         disclosure should separately identify and quantify each individual
factor so that the
         change in net quantities of reserves between periods is fully
explained. In particular,
         disclosure relating to revisions in previous estimates should identify
such underlying
         factors as changes caused by commodity prices, well performance,
improved recovery,
         uneconomic proved undeveloped locations or changes resulting from the
removal of
         proved undeveloped locations due to changes in a previously adopted
development plan.
         Refer to Item 1203(b) of Regulation S-K. This comment also applies to
the comparable
         discussion of the changes in net quantities of total proved reserves
for each of the annual
         periods presented.
3.       Expand your disclosure of the capital spent during the fiscal year on
development
         activities to quantify the portion of that amount incurred to convert
proved undeveloped
         reserves to proved developed reserves. Refer to Item 1203(c) of
Regulation S-K.
Supplementary Oil and Gas Information-Unaudited
Standardized Measure of Discounted Future Net Cash Flows Relating to Proved Oil
and Gas
Reserves (Standardized Measure), page F-109

4.       Tell us if the costs associated with the abandonment of your proved
properties, including
         the costs related to your proved undeveloped locations, have been
included as part of the
         development costs used in the calculation of the standardized measure
for each of the
         annual periods presented. If such costs have been omitted, explain to
us your basis for
         excluding these costs from your calculation of the standardized
measure.
Drilling and Other Exploratory and Development Activities, page F-112

5.       Expand your disclosure to discuss your present activities, such as the
number of wells in
         the process of being drilled (including wells temporarily suspended),
waterfloods in
         process of being installed, pressure maintenance operations, and any
other related
         activities of material importance subsequent to the fiscal year-end.
Refer to Item 1206 of
         Regulation S-K.
Oil and Gas Properties, Wells, Operations, and Acreage, page F-113

6.       If there are material quantities of net proved undeveloped reserves
assigned to locations
         which are currently scheduled to be drilled after lease expiration,
expand the disclosure
         under this section to explain the steps and related costs which would
be necessary to
         extend the time to the expiration of such leases.
        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.
 Peter Beaven
BHP Group Ltd
March 27, 2019
Page 3

       You may contact John Hodgin, Petroleum Engineer, at 202-551-3699 with
any questions
regarding the above noted comments.



                                                        Sincerely,
FirstName LastNamePeter Beaven
                                                        Division of Corporation
Finance
Comapany NameBHP Group Ltd
                                                        Office of Beverages,
Apparel and
March 27, 2019 Page 3                                   Mining
FirstName LastName