STESteris

Based on the disclosures in financial statement Notes 8 and 11, it appears that your operations in Ireland comprised 40% of your 2023 consolidated pre-tax income even though the revenue from these operations comprised less than 2% of consolidated revenue. Consequently, it appears that an expanded disclosure about your operations in Ireland is necessary to an understanding of your operating results.

Rest of the question

Please disclose why the operations in Ireland appear to comprise a disproportionate share of your consolidated pre-tax income. Identify the specific economic, geographic, and business factors that have enabled your operations in Ireland to generate levels of pre-tax income that exceeded 83%, 107%, and 101% of corresponding Irish revenues in 2023, 2022 and 2021 respectively. Explain how these profit margins are possible given that less than 4% of your reported property, plant and equipment is in Ireland. Explain why your Irish pre-tax income has increased from 4% of your consolidated pre-tax income in 2019 to 40% in 2023. Explain how your allocation of interest expense impacts an understanding of the reported pre-tax income amounts for your operations in Ireland. Please address any material unusual or nonrecurring items that have had, or are expected to have, an impact on the profitability of your Irish operations. The disclosure should enable readers to accurately assess the correlation between your reported Irish revenues and pre-tax income amounts. See Item 303 of Regulation S-K.

STERIS plc 70 Sir John Rogerson’s Quay Dublin 2 Ireland April 9, 2024 CORRESPONDENCE FILING VIA EDGAR U.S. Securities and Exchange Commission Division of Corporation Finance Office of Industrial Applications and Services 100 F Street, N.E. Washington, D.C. 20549 Attention: Nudrat Salik Al Pavot Re: STERIS plc Form 10-K for the Year Ended March 31, 2023 File No.

Rest of the letter

001-38848 Ladies and Gentlemen: STERIS plc (the “Company,” “we” or “our”) is submitting this letter in response to the comment letter from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”), dated March 22, 2024, with respect to the Company’s Annual Report on Form 10-K for the fiscal year ended March 31, 2023, filed May 26, 2023 (“Fiscal 2023 Form 10-K”). Below are the Company’s responses. For the convenience of the Staff, the Company has repeated the Staff’s comment before the corresponding response. Form 10-K for the Year Ended March 31, 2023 Results of Operations, page 31 1. Based on the disclosures in financial statement Notes 8 and 11, it appears that your operations in Ireland comprised 40% of your 2023 consolidated pre-tax income even though the revenue from these operations comprised less than 2% of consolidated revenue. Consequently, it appears that an expanded disclosure about your operations in Ireland is necessary to an understanding of your operating results. Please disclose why the operations in Ireland appear to comprise a disproportionate share of your consolidated pre-tax income. Identify the specific economic, geographic, and business factors that have enabled your operations in Ireland to generate levels of pre-tax income that exceeded 83%, 107%, and 101% of corresponding Irish revenues in 2023, 2022 and 2021 respectively. Explain how these profit margins are possible given that less than 4% of your reported property, plant and equipment is in Ireland. Explain why your Irish pre-tax income has increased from 4% of your consolidated pre-tax income STERIS plc 70 Sir John Rogerson’s Quay Dublin 2 Ireland in 2019 to 40% in 2023. Explain how your allocation of interest expense impacts an understanding of the reported pre-tax income amounts for your operations in Ireland. Please address any material unusual or nonrecurring items that have had, or are expected to have, an impact on the profitability of your Irish operations. The disclosure should enable readers to accurately assess the correlation between your reported Irish revenues and pre-tax income amounts. See Item 303 of Regulation S-K. Response: The Company respectfully acknowledges the Staff’s comment. The comment addresses several disclosures found in Item 7, Management’s Discussion and Analysis of Financial Condition and Results of Operation, and the footnotes to the consolidated financial statements. However, we believe the Staff’s core question relates to the drivers of pre-tax income attributable to Ireland, the Company’s country of domicile. The Company provides disclosures of pre-tax income and income tax expense by tax jurisdiction, domestic and foreign, in accordance with S-X 4-08(h). Pre-tax income is attributed to tax jurisdictions based on entities’ country of domicile. Therefore, pre-tax income attributed to Ireland is the sum of pre-tax income generated by our entities domiciled in Ireland. Since March 28, 2019, when the Company changed its domiciliation from the United Kingdom to Ireland, STERIS Irish FinCo Unlimited Company (“Irish FinCo”), a wholly owned, indirect subsidiary incorporated under the laws of Ireland, has been the primary source of intercompany financing for the Company and its consolidated subsidiaries. Irish FinCo has continued to expand its borrowing and intercompany lending activities to fund acquisitions, capital investments, and working capital needs of the consolidated group. As a result, the majority of pre-tax income in Ireland for the fiscal year ended March 31, 2023 (“Fiscal 2023”) is derived from net interest income earned through the intercompany financing activities of Irish FinCo and therefore does not correlate to the Ireland portions of consolidated revenue or property, plant and equipment. The Company does not allocate interest expense. Interest expense is instead recorded at the entity that incurred the expense. The interest income earned by Irish FinCo is accounted for as intercompany interest income. While eliminated in consolidation, the intercompany interest income earned by Irish Finco is attributable to the Ireland tax jurisdiction. The expanded activities of Irish FinCo, and resulting increase in net interest income, is the primary driver of the overall increase in pre-tax income attributable to the jurisdiction of Ireland from $13.7 million (4% of total) for the fiscal year ended March 31, 2019 to $62.7 million (40% of total) in Fiscal 2023. We recognize that our disclosures should provide readers insight into the drivers of our overall pre-tax income, income tax expense, and effective tax rate. While we believe that our disclosures in Item 7, Management’s Discussion and Analysis, appropriately highlight the most significant drivers of the variances when comparing Fiscal 2023 results to Fiscal 2022 results, we also acknowledge that enhanced disclosures could STERIS plc 70 Sir John Rogerson’s Quay Dublin 2 Ireland provide additional clarity for readers regarding the impact of our Irish domicile and internal financing structure on our jurisdictional pre-tax income, income tax expense, and total effective tax rate. Therefore, we will enhance our disclosures in the Company’s Annual Report on Form 10-K for the year ended March 31, 2024 (“Fiscal 2024 Form 10- K”) with additional narrative disclosure. Below is the Company’s proposed additional disclosure for the Staff’s review. Proposed additional disclosure in both Results of Operations in Management’s Discussion and Analysis and Footnote 8 of the consolidated financial statements: The effective tax rate is affected by i) the fact that our parent entity is an Irish resident taxpayer, ii) the tax rates in Ireland and other jurisdictions in which we operate, and iii) the relative amount of income before taxes earned by jurisdiction, which is impacted by our internal financing structure. The majority of income before income taxes attributed to Ireland is the result of the intercompany financing activities of a wholly-owned Irish financing company, which are driven by funding needs for acquisitions, capital investments, and working capital of the consolidated group. Business Segment Results of Operations, page 34 2. Please disclose the extent to which segment revenue variances were attributable to changes in prices or to changes in volume. In this regard, the existing disclosures attribute the variances to "increases in volume and pricing" so it is not clear whether the price and volume changes had equal or disproportionate impacts. See the related guidance in Item 303(b)(2)(iii) of Regulation S-K. Response: The Company respectfully acknowledges the Staff’s comment. The Company sells a wide range of products, including capital equipment and consumables, and services to Customers, as described in Item 1. Business in our Fiscal 2023 Form 10-K. These products and services vary so greatly in terms of pricing structures and unit volumes at which they are sold that the Company cannot precisely quantify the impact that changes in prices or volume of products and services sold has on the change in segment revenue from period to period. However, for managerial purposes, we estimate these impacts at a higher level to understand changes in revenue and will enhance our disclosures to provide clarity for the reader regarding the relative significance of referenced key drivers on the material changes in segment revenues in the Company’s Fiscal 2024 Form 10-K. For illustrative purposes, below is the Company’s proposed disclosure using the abovereferenced Fiscal 2023 Form 10-K as a model. Revisions have been marked to facilitate the Staff’s review. STERIS plc 70 Sir John Rogerson’s Quay Dublin 2 Ireland The following table compares business segment revenues as well as impacts from acquisitions, divestitures, and foreign currency movements for the year ended March 31, 2023 to the year ended March 31, 2022. Note: Organic revenue growth and constant currency organic revenue growth are non- GAAP financial measures of revenue performance. Organic revenue growth is calculated by removing the impact of acquisitions and divestitures for one year following the respective transaction from the GAAP revenue growth. Constant currency organic revenue growth is subject to a further adjustment to eliminate the impact of foreign currency movements. Healthcare revenues increased 8.4% in fiscal 2023, as compared to fiscal 2022, reflecting growth in capital equipment, service, and consumable revenues of 14.6%, 7.5%, and 4.6% respectively. This increase reflects The constant currency organic growth of 10.8% is primarily due to increased volume and, impacting revenues by a high single digit percentage, as well as increased pricing, partially offset by unfavorable fluctuations in currencies. The Healthcare segment’s backlog at March 31, 2023 amounted to $494.7 million. Excluding Cantel, the Healthcare segment's backlog at March 31, 2022 was $423.6 million. In addition to the added volume from Cantel, the increase is primarily due to built up demand and supply chain disruptions. AST revenues increased 7.2% in fiscal 2023, as compared to fiscal 2022. The increase wasconstant currency organic growth of 11.6% is primarily due to increases in volume and pricing, partially offset by unfavorable fluctuations in currenciesboth contributing mid-single digit percentage increases. Life Sciences revenues increased 2.2% in fiscal 2023, as compared to fiscal 2022 reflecting growth in capital equipment, service, and consumable revenues of 3.6%, 3.4%, and 0.7% respectively. This increase wasThe constant currency organic growth of 5.3% is driven by increasedlow-single digit percentage increases in both volume and pricing, partially offset by divestiture activity and unfavorable fluctuations in currency. The Life Sciences backlog at March 31, 2023 and 2022 amounted to $104.9 million and $104.7 million, respectively. Dental segment revenues increased 16.6% to $421.6 million in fiscal 2023, as compared to $361.7 million from the Cantel acquisition date of June 2, 2021 through STERIS plc 70 Sir John Rogerson’s Quay Dublin 2 Ireland March 31, 2022. The increase was driven primarily On a constant currency organic basis, Dental revenues were about flat with price favorably impacting revenues by the timing of the Cantel acquisition.mid-single digits to offset a decline in volume. Note 8, page 80 3. Please provide us with a quantified analysis that explains how you calculated the reported $62,664 Ireland operations 2023 pre-tax income amount. Please explain whether there are any material differences in how this amount was derived versus how the $74,463 Irish revenue amount on page 94 was derived. Please quantify the impact of such differences. Tell us whether the reported amounts for 2022 and 2021 were determined in the same manner. We may have further comment. Response: The Company respectfully acknowledges the Staff’s comment. Fiscal 2023 pre-tax income attributable to the tax jurisdiction of Ireland is the sum of pre-tax income associated with entities domiciled in Ireland. Unlike pre-tax income, the disclosure of revenues by geography on page 94 is based on geographic market of the Customer regardless of the legal domicile of the subsidiary. The following provides additional detail regarding the sources of revenue and pre-tax income attributable to Ireland. 1. Consolidated revenues from operations derived from commercial operating subsidiaries, regardless of where domiciled, delivering products and services to Customers in Ireland totaled $74.5 million. 2. Commercial operating entities domiciled in Ireland generated approximately $16.3 million of pre-tax income and hold the property, plant and equipment attributed to Ireland. 3. Irish FinCo generated none of the consolidated revenue from operations and approximately $62.6 million of pre-tax income. 4. Holding companies domiciled in Ireland generated none of the consolidated revenue from operations and a pre-tax loss of approximately $16.3 million. Amounts reported for Fiscal 2022 and Fiscal 2021 were derived in the same manner. * * * * * * * * STERIS plc 70 Sir John Rogerson’s Quay Dublin 2 Ireland If you have any questions regarding these matters, please do not hesitate to contact me at +1(440) 392-7134. Very truly yours, /s/ Michael J. Tokich Michael J. Tokich Senior Vice President and Chief Financial Officer cc: Karen L. Burton Vice President, Chief Accounting Officer

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Please disclose the extent to which segment revenue variances were attributable to changes in prices or to changes in volume. In this regard, the existing disclosures attribute the variances to "increases in volume and pricing" so it is not clear whether the price and volume changes had equal or disproportionate impacts. See the related guidance in Item 303(b)(2)(iii) of Regulation S-K.

See the reply above.

Please provide us with a quantified analysis that explains how you calculated the reported $62,664 Ireland operations 2023 pre-tax income amount. Please explain whether there are any material differences in how this amount was derived versus how the $74,463 Irish revenue amount on page 94 was derived. Please quantify the impact of such differences.

Rest of the question

Tell us whether the reported amounts for 2022 and 2021 were determined in the same manner. We may have further comment.

See the reply above.

We note your response to comment 1 and reissue in part. Please expand your proposed disclosure to also clarify the extent to which intercompany net interest income impacted the reported United States and Other Locations pre-tax income amounts you disclose in Note 8.

STERIS plc 70 Sir John Rogerson’s Quay Dublin 2 Ireland May 15, 2024 CORRESPONDENCE FILING VIA EDGAR U.S. Securities and Exchange Commission Division of Corporation Finance Office of Industrial Applications and Services 100 F Street, N.E. Washington, D.C. 20549 Attention: Nudrat Salik Al Pavot Re: STERIS plc Form 10-K for the Year Ended March 31, 2023 File No.

Rest of the letter

001-38848 Ladies and Gentlemen: STERIS plc (the “Company,” “we” or “our”) is submitting this letter in response to the comment letter from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”), dated April 17, 2024, with respect to the Company’s Annual Report on Form 10-K for the fiscal year ended March 31, 2023, filed May 26, 2023 (“Fiscal 2023 Form 10-K”) and Correspondence filed April 9, 2024. Below are the Company’s responses. For the convenience of the Staff, the Company has repeated the Staff’s comment before the corresponding response. Correspondence filed April 9, 2024 Form 10-K for the Year Ended March 31, 2023 Results of Operations, page 31 1. We note your response to comment 1 and reissue in part. Please expand your proposed disclosure to also clarify the extent to which intercompany net interest income impacted the reported United States and Other Locations pre-tax income amounts you disclose in Note 8. Response: The Company respectfully acknowledges the Staff’s comment. In the Results of Operations discussion of consolidated income tax expense and effective tax rate in the STERIS plc 70 Sir John Rogerson’s Quay Dublin 2 Ireland Company’s Annual Report on Form 10-K for the year ended March 31, 2024 (“Fiscal 2024 Form 10-K”), we will reference Note 10, Income Taxes, for additional information as we believe the additional disclosure at the geographic level will be best understood if presented with the tabular data by geography in that footnote. In Note 10, Income Taxes, of the Fiscal 2024 Form 10-K, we will enhance our proposed disclosures that accompany the tabular presentations of income before income taxes by geography and the components of the provision for income taxes. These enhancements will provide readers with additional information regarding key drivers of fluctuations in income before income taxes in the three geographies presented and the resulting tax provision. We will also clarify that the values include the transfer of income before income taxes that results from transactions between entities within our group that involve the sale of goods and services, loans and related interest, intellectual property and related royalties, and shared costs. The disclosure will specifically highlight the significant impact of our global financing structure on the results of our Ireland and United States operations. For illustrative purposes, following all our responses to the Staff's comments, is the Company’s proposed disclosure using the above referenced Fiscal 2023 Form 10-K as a model. Revisions have been marked to facilitate the Staff’s review. 2. Please expand your discussion of income tax expense variances to also clearly address any material variances in the effective tax rates within the jurisdictions that you operate. For example, it is not clear why the Other Locations effective tax rate appeared to change from 28% in 2022 to 34% in 2023. Response: The Company respectfully acknowledges the Staff’s comment. The effective tax rate variances between Fiscal 2023 and Fiscal 2022 for the United States and Other locations noted were predominately driven by the impairment of goodwill. Our consolidated effective tax rate was also favorably impacted in Fiscal 2023 by changes in U.S. state and local tax rates applied to existing deferred tax assets and liabilities. In the Results of Operations discussion of consolidated income tax expense and effective tax rate in the Fiscal 2024 Form 10-K, we will reference Note 10, Income Taxes, for additional information as we believe the additional disclosure at the geographic level will be best understood if presented with the tabular data by geography in that footnote. We will enhance our disclosures in Note 10, Income Taxes, of the Fiscal 2024 Form 10-K to give readers insight into the geographies impacted by material drivers of changes in our consolidated effective tax rate. For illustrative purposes, following all our responses to the Staff’s comments, is the Company’s proposed disclosure using the above referenced Fiscal 2023 Form 10-K as a model. Revisions have been marked to facilitate the Staff’s review. STERIS plc 70 Sir John Rogerson’s Quay Dublin 2 Ireland Note 8, page 80 3. We note your response to comment 3 and reissue in part. You state that the amount reported in your financial statements as pre-tax income attributable to Ireland is the sum of pre-tax income associated with entities domiciled in Ireland. The instruction to Article 4-08(h)(1) of Regulation S-X states that the amount of domestic and foreign pretax income should be measured based on the geographic location of the operations that generated the pre-tax income. Please clarify for us the extent to which your reported amount of 2023 Ireland pre-tax income includes any income that was generated by operations geographically located outside of Ireland. Also, please clarify for us whether your commercial operations located in Ireland effectively generated zero pre-tax income in 2023 given that the $16.3 million of earnings cited in your response was completely offset by the $16.3 million of pre-tax loss generated by your Irish holding companies. If the entire $62.3 million of your reported 2023 Ireland pre-tax income is comprised of intercompany financing income from loans to foreign entities then that information should be clearly disclosed in MD&A so that readers can fully understand your reported domestic and foreign pre-tax income amounts and assess any favorable or adverse trends in the operating results of your domestic and foreign operations. Response: The Company respectfully acknowledges the Staff’s comment. We interpret the requirement under Article 4-08(h)(1) of Regulation S-X to measure domestic and foreign pre-tax income based on geographic location of the operations. The entities, including branches of entities, are subject to tax in Ireland because the operations of those entities are located in Ireland. Our reported Ireland pre-tax income does not include any income generated by operations geographically located outside of Ireland. In Fiscal 2023, our commercial operations geographically located in Ireland did, in fact, generate pre-tax income through the delivery of products and services to Customers. The Fiscal 2023 $16.3 million of pre-tax earnings for the commercial operating entities cited in our response was offset by the $16.3 million of pre-tax loss from operations of our Irish holding companies. This is not the case every year. In Note 10, Income Taxes, of the Fiscal 2024 Form 10-K, we will enhance our proposed disclosures that accompany the tabular presentations of Income before income taxes by geography and the components of tax expense. These enhancements will provide readers with additional information regarding key drivers of fluctuations in income before income taxes in the three geographies presented and resulting tax provision. We will also clarify that the values include the transfer of income before income taxes that results from transactions between entities within our group that involve the sale of goods and services, loans and related interest, intellectual property and related royalties, and shared costs. The disclosure will specifically highlight the significant impact of our global financing structure on our Ireland and United States operations. STERIS plc 70 Sir John Rogerson’s Quay Dublin 2 Ireland For illustrative purposes, following all our responses to the Staff’s comments, is the Company’s proposed disclosure using the above referenced Fiscal 2023 Form 10-K as a model. Revisions have been marked to facilitate the Staff’s review. 4. Please disclose in the filing what your accounting policy is regarding the measurement of amounts presented as Ireland, United States, and Other Locations pre-tax income (loss). Please explain which intercompany items are eliminated and which are not eliminated i.e. intercompany revenues, expenses, equity investment items, etc. Response: The Company respectfully acknowledges the Staff’s comment. We comply with the requirement under Article 4-08(h)(1) of Regulation S-X by measuring domestic and foreign income before income taxes based on geographic location of the operations. This measure is inclusive of the transfer of income that results from transactions between entities within our group that involve the sale of goods and services, loans and related interest, intellectual property and related royalties, and shared costs. We will provide this clarity for readers in our enhanced proposed disclosure. For illustrative purposes, below is the Company’s proposed disclosure using the abovereferenced Fiscal 2023 Form 10-K as a model. Revisions have been marked to facilitate the Staff’s review. As noted in response to each comment above, below are our proposed and enhanced disclosures to be included in Note 10, Income Taxes, of the consolidated financial statements in our Fiscal 2024 Form 10-K. The proposal is presented using Fiscal 2023 Form 10-K disclosures as a model with revisions marked to facilitate the Staff’s review. ILLUSTRATIVE PROPOSED DISCLOSURE 8. INCOME TAXES The total provision for income taxes can be reconciled to the tax computed at the Ireland statutory tax rate as follows: STERIS plc 70 Sir John Rogerson’s Quay Dublin 2 Ireland Our effective tax rate is affected by i) the tax rates in Ireland (our country of domicile), the United States, and other jurisdictions in which we operate, and ii) the relative amount of income before income taxes by geography. Income before income taxes by geography are based on the geographic location of our operations to which such earnings are attributable. Transactions between two or more of the entities within our group occur routinely and involve the sale of goods and services, loans and related interest, intellectual property and related royalties, and shared costs. The pricing used in these transactions is consistent with the prices that would be charged between unrelated parties in accordance with our interpretation of current tax regulations. Income before income taxes by geography includes the transfer of income before income taxes that results from these transactions. We operate a global financing structure using a wholly-owned financing company domiciled in Ireland, STERIS Irish FinCo, which has a material impact on the relative amount of income before income taxes by geography. In each of the years presented, STERIS Irish FinCo contributed more than 90% of the pre-tax income of Ireland operations. Its activities are driven by funding needs for acquisitions, capital investments, and working capital. A significant majority of STERIS Irish FinCo’s income before income taxes during the years presented was driven by loans to our operations in the United States in response to such funding needs. Significant transactions not indicative of operating trends that impacted the amount of income before income taxes by geography and resulting provision for income tax and effective tax rate include: • In fiscal 2023, the impairment of goodwill impacted the operations in the United States and Other locations by $441,643 and $48,922, respectively. Approximately $207,367 of this impairment was non-deductible. • In fiscal 2022, income in the United States was affected by costs associated with the completion of the Cantel Medical acquisition. These include $205,788 of acquisition and integration related expenses and the negative impact of a fair value adjustment of $27,806 related to the premium liability associated with the Cantel Medical convertible debt. Approximately $67,000 of these costs were non-deductible. • In fiscal 2021, income in the United States was affected by over $35,634 of acquisition costs incurred in the United States, of which approximately $16,000 were non-deductible. Additionally, we reached a partial settlement associated with the United States Internal Revenue Service (“IRS”) related to audits of prior fiscal years incurring approximately $12,000 in additional tax. Income before income taxes of our domestic and foreign operations based on the geographic location of our operations was as follows: STERIS plc 70 Sir John Rogerson’s Quay Dublin 2 Ireland The components of the provision for income taxes consisted of the following: NO CHANGES IN THE REMAINDER OF THE FOOTNOTE * * * * * * * * If you have any questions regarding these matters, please do not hesitate to contact me at +1(440) 392-7134. Very truly yours, /s/ Michael J. Tokich Michael J. Tokich Senior Vice President and Chief Financial Officer cc: Karen L. Burton Vice President, Chief Accounting Officer

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Please expand your discussion of income tax expense variances to also clearly address any material variances in the effective tax rates within the jurisdictions that you operate. For example, it is not clear why the Other Locations effective tax rate appeared to change from 28% in 2022 to 34% in 2023.

See the reply above.

We note your response to comment 3 and reissue in part. You state that the amount reported in your financial statements as pre-tax income attributable to Ireland is the sum of pre-tax income associated with entities domiciled in Ireland.

Rest of the question

The instruction to Article 4-08(h)(1) of Regulation S-X states that the amount of domestic and foreign pre-tax income should be measured based on the geographic location of the operations that generated the pre-tax income. Please clarify for us the extent to which your reported amount of 2023 Ireland pre-tax income includes any income that was generated by operations geographically located outside of Ireland. Also, please clarify for us whether your commercial operations located in Ireland effectively generated zero pre-tax income in 2023 given that the $16.3 million of earnings cited in your response was completely offset by the $16.3 million of pre-tax loss generated by your Irish holding companies. If the entire $62.3 million of your reported 2023 Ireland pre-tax income is comprised of intercompany financing income from loans to foreign entities then that information should be clearly disclosed in MD&A so that readers can fully understand your reported domestic and foreign pre-tax income amounts and assess any favorable or adverse trends in the operating results of your domestic and foreign operations.

See the reply above.

Please disclose in the filing what your accounting policy is regarding the measurement of amounts presented as Ireland, United States, and Other Locations pre-tax income (loss). Please explain which intercompany items are eliminated and which are not eliminated i.e. intercompany revenues, expenses, equity investment items, etc.

See the reply above.