March 8, 2019 David Grzebinski President and Chief Executive Officer Kirby Corporation 55 Waugh Drive, Suite 1000 Houston TX 77007 Re: Kirby Corporation Form 10-K for the Year Ended December 31, 2017 Filed February 26, 2018 File No. 001-07615 Dear Mr. Grzebinski: 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 Transportation and Leisure