April 1, 2020 Jay Rembolt Chief Financial Officer WD 40 CO 9715 Businesspark Avenue San Diego, CA. 92131 Re: WD 40 CO Form 10-K for the year ended December 31, 2019 Filed on October 22, 2019 File No. 000-06936 Dear Mr. Rembolt: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Life Sciences