WASTEQUIP INC
RW, 2000-01-24
FABRICATED PLATE WORK (BOILER SHOPS)
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<PAGE>   1
                                December 9, 1999


Mr. Don Cavern
Securities and Exchange Commission
450 5th Street, NW
Washington, DC  20549

         Re:      Wastequip, Inc. (the "Company")
                  Registration Statement on the Form S-1
                  File No. 333-59741

Dear Mr. Cavern:

         The above captioned Form S-1 registration statement was filed with the
Commission on July 23, 1998. After a several month process, the Company was
recently sold to a private buyer. Consequently, it will not be going forward
with its initial public offering. Therefore, on behalf of the Company, pursuant
to Rule 477 of Regulation C under the Securities Act of 1933 I am applying for
withdrawal of that registration statement.

         I wish to advise the staff that while the registration statement was on
file the Company did not make any security offerings for which general
solicitation or general advertising would be prohibited. Therefore, it is the
Company's belief that the withdrawal would be consistent with the public
interest and the protection of investors.

         Thank you for your anticipated cooperation in this matter. Please
direct any inquiries to the undersigned.


                                              Sincerely,


                                              Richard L. Garcia


Cc:      Edward W. Moore


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