Columbus McKinnon Corporation
                         140 John James Audubon Parkway
                          Amherst, New York 14228-1197




Securities and Exchange Commission
450 Fifth Street, N.W.
Judiciary Plaza
Washington, D.C.  20549

                                         Re: Columbus McKinnon Corporation
                                             Registration Statement on Form S-1
                                             (File No. 333-90284)



Ladies and Gentlemen:

         Pursuant to Rule 477 of Regulation C of the  Securities Act of 1933, as
amended (the "Act"), Columbus McKinnon Corporation,  a New York Corporation (the
"Registrant"),  hereby applies for an order granting the immediate withdrawal of
its Registration  Statement on Form S-1 (File No. 333-90284) (The  "Registration
Statement"). The Registration Statement was originally filed with the Securities
and Exchange Commission on July 12, 2002.

         In  light  of  the  current  market  conditions,   the  Registrant  has
determined not to proceed at this time with the public offering  contemplated by
the Registration  Statement.  The Registrant  hereby confirms that no securities
have  been  sold  pursuant  to the  Registration  Statement,  and  all  activity
regarding the proposed  public  offering has been  discontinued.  The Registrant
hereby informs the Staff that it may undertake a subsequent  private offering in
reliance  on the safe harbor  sets forth in Rule 155 (c)  promulgated  under the
Act.

         Accordingly,  the Registrant  respectfully requests that the Commission
issue an order granting the withdrawal of the Registration  Statement as soon as
possible.  The Registrant  also requests that all fees paid to the Commission in
connection  with the filing of the  Registration  Statement  be  credited to the
Registrant's account with the Commission for future use.

         Please  provide  the  Registrant  with a  facsimile  copy of the  order
consenting  to the  withdrawal  of the  Registration  Statement as soon as it is
available.  The Registrant's  facsimile number is (716) 689-5598.  Also,  please
forward a  facsimile  copy of such order to Robert J.  Olivieri,  counsel to the
Registrant,  at  (716)  849-0349.  If you  have  any  questions  regarding  this
application for withdrawal, please contact Mr. Olivieri at (716) 848-1244.


                                     COLUMBUS MCKINNON CORPORATION



                                     By: /s/ Timothy T. Tevens
                                         ----------------------------------
                                             Timothy T. Tevens, President
                                                and Chief Executive Officer