April 27, 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 April 22, 2005 response letter and
have
the following 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 any other aspect of our review.  Feel free to call
us
at the telephone numbers listed at the end of this letter.

1. We read your response to comment 2.  Please further explain to
us
how your recognition of revenue at the time of processing meets
the
delivery and performance criteria in SAB 101, as amended by SAB
104.
Do you retain any risk after the product is processed but prior to
pick-up by or shipment to your customer?

2. In a supplemental response, please confirm to us that you will
revise your disclosure in future filings in response to our prior
comments 2 and 3.


*  *  *  *






	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 27, 2005
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