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                            April 20, 2023

       Stefano Gaggini
       Senior Vice President and Chief Financial Officer
       Schnitzer Steel Industries, Inc.
       299 SW Clay Street, Suite 350
       Portland, OR 97201

                                                        Re: Schnitzer Steel
Industries, Inc.
                                                            Form 10-K for the
Fiscal Year Ended August 31, 2022
                                                            Filed October 24,
2022
                                                            File No. 000-22496

       Dear Stefano Gaggini:

               We have reviewed your April 14, 2023 response to our comment
letter and have the
       following comment. In our comment, we may ask you to provide us with
information so we may
       better understand your disclosure.

              Please respond to the comment 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
       comment applies to your facts and circumstances, please tell us why in
your response.

              After reviewing your response to the comment, we may have
additional
       comments. Unless we note otherwise, our reference to prior comment to
comments in our March
       31, 2023 letter.

       Form 10-K for the Fiscal Year Ended August 31, 2022

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Non-GAAP Financial Measures, page 51

   1.                                                   We note your response
to comment 1. Since you are adjusting your various Non-GAAP
                                                        measures for changes in
legal and environmental charges, net of recoveries, for legacy
                                                        environmental matters,
please tell us how you considered the guidance in Question 100.04
                                                        of the Compliance and
Disclosure Interpretations Regarding Non-GAAP measures in
                                                        determining that the
inclusion of these adjustments is appropriate. Please note that
                                                        Question 100.04
indicates that changing the basis of accounting for revenues and expenses
                                                        in a Non-GAAP
performance measure from an accrual basis would not be appropriate.
 Stefano Gaggini
Schnitzer Steel Industries, Inc.
April 20, 2023
Page 2




       You may contact Keira Nakada at 202-551-3659 or Linda Cvrkel at
202-551-3813 with
any questions.



FirstName LastNameStefano Gaggini                      Sincerely,
Comapany NameSchnitzer Steel Industries, Inc.
                                                       Division of Corporation
Finance
April 20, 2023 Page 2                                  Office of Trade &
Services
FirstName LastName