January 30, 2020

Thomas P. McCaffrey
Senior Vice President & Chief Financial Officer
KLX Energy Services Holdings, Inc.
3040 Post Oak Blvd
15th Floor
Houston, TX 77056

       Re: KLX Energy Services Holdings, Inc.
           Form 10-K for the Fiscal Year Ended January 31, 2019
           Form 10-Q for the Fiscal Quarter Ended October 31, 2019
           Form 8-K filed December 5, 2019
           File No. 001-38609

Dear Mr. McCaffrey:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments. In some of our comments, we may
ask you to
provide us with information so we may better understand your disclosure.

       Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in your

       After reviewing your response to these comments, we may have additional

Form 10-Q for the Fiscal Quarter Ended October 31, 2019

Item 1. Condensed Consolidated Financial Statements (Unaudited)
Note 5. Goodwill and Intangible Assets, Net, page 11

1.    We note you did not record an impairment to long-lived assets based on
your assessment
      as of October 15, 2019 because the sum of undiscounted cash flows of the
      Rocky Mountains and Northeast/Mid-Con long-lived assets exceeded their
carrying value
      by approximately 20.7%, 64.4% and 32.9%, respectively. Please tell us the
extent to
      which assets were grouped and the basis for any such grouping in your
      assessment. Please refer to ASC paragraph 360-10-35-23.
 Thomas P. McCaffrey
KLX Energy Services Holdings, Inc.
January 30, 2020
Page 2
Form 8-K filed December 5, 2019

Exhibit 99.1, page 1

2.       We note you reconcile the non-GAAP measure Adjusted EBITDA to
operating earnings
         (loss) on a consolidated basis and for each of your segments. Please
revise your
         presentation to reconcile to net earnings (loss), the most directly
comparable GAAP
         measure. Refer to Item 10(e) of Regulation S-K and Question 103.02 of
the Compliance
         and Disclosure Interpretations on Non-GAAP Financial Measures.
       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

      You may contact Brian McAllister at (202) 551-3341 or Myra
Moosariparambil at (202)
551-3796 with any questions.

FirstName LastNameThomas P. McCaffrey                      Sincerely,
Comapany NameKLX Energy Services Holdings, Inc.
                                                           Division of
Corporation Finance
January 30, 2020 Page 2                                    Office of Energy &
FirstName LastName