April 8, 2005


Mail Stop 0409

VIA U.S. MAIL AND FAX (863) 425-5526

Mr. Richard G. Hunter, Ph. D.
Chief Executive Officer and
   Chief Financial Officer
Food Technology Service, Inc.
502 Prairie Mine Road
Mulberry,  FL  33860

Re:	Food Technology Service, Inc.
Form 10-KSB for the year ended December 31, 2004
File No. 000-19047

Dear Mr. Hunter:

      We have reviewed your filing and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and will make no further review of your
documents.  As such, all persons who are responsible for the
adequacy
and accuracy of the disclosure are urged to be certain that they
have
included all information required pursuant to the Securities
Exchange
Act of 1934.  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-KSB for the year ended December 31, 2004

Item 8(a) Controls and Procedures

1. We note your statement that your chief executive officer and
chief
financial officer have concluded that "disclosure controls and
procedures, established by the Company, were adequate to ensure
that
information required to be disclosed by the Company in reports
that
the Company files under the Exchange Act, is recorded, processed,
summarized and reported on a timely basis in accordance with
applicable rules and regulations."  It does not appear that your
certifying officers have reached a conclusion that your disclosure
controls and procedures are effective.  Please revise to address
your
officers` conclusions regarding the effectiveness of your
disclosure
controls and procedures.

Financial Statements and Notes

Note A, Summary of Significant Accounting Policies

4. Revenue Recognition

2. We note that you recognize revenue when the customer`s product
has
been processed.  In a supplemental response, and in future
filings,
please tell us how you meet the delivery and performance criteria
of
SAB 101, as amended by SAB 104.  In this regard, please describe
your
performance obligations under your customer arrangements.  In
addition, tell us whether you retain any risk prior to pick-up by
or
shipment to your customer.

6.  Depreciation

3. In a supplemental response, and in future filings, please tell
us
whether your depreciable basis for Cobalt includes the entire
amount
recorded on your balance sheet or one-half of this amount.  If the
depreciable basis does not represent the entire amount, explain to
us
your basis in accounting for excluding this residual amount.


*  *  *  *

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings 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 filings;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; 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 filings or
in
response to our comments on your filings.

	You may contact Josh Forgione, at (202) 824-5464, or me, at
(202) 824-5222, if you have questions. Please respond to the
comments
included in this letter within ten business days or tell us when
you
will provide us with a response.  Please file your response on
EDGAR.

							Sincerely,



Steven Jacobs
      Accounting Branch Chief

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Food Technology Service, Inc.
April 8, 2005
Page 1