Subject: File No. S7-16-98

Date:    8/20/98 2:34 PM
     
     
To:  Jonathan G. Katz,
Secretary, Securities and Exchange Commission
     
     
     
I am writing regarding the SEC's proposed amendment to rule 102(e) of 
its Rules of Practice.  It is my opinion that the discipline of 
accountants rests primarily with state boards of accountancy and 
professional organizations.  I do not believe that a single act of 
simple negligence - which the proposed amendment may well be 
interpreted to encompass - should ever constitute "improper 
professional conduct" for purposes of Rule 102 (e).
     
Furthermore, I am concerned that the proposed rule adopts a standard 
that could result in an enforcement proceeding against the 
professional, even where no misstatement has occurred, since the 
proposed rule would only require the presence of a "substantial risk."
 Also, the SEC would be able to utilize a rule which has a threshold
for imposing discipline much lower than the requirement imposed by 
Congress.  A rule that would allow the SEC to bypass already stringent 
and explicit guidelines set up by Congress for disciplining 
accountants who are officers and directors of SEC registrants is 
unacceptable.
     
Sincerely,
     
     
     
Gary W. Roberson CPA
Vice President, Finance
Oil States Industries, Inc.