Mail Stop 3561


									January 3, 2006




Mr. Paul M. Montrone
Chief Executive Officer
Fisher Scientific International Inc.
Liberty Lane
Hampton, New Hampshire 03842


		RE:	Fisher Scientific International Inc.
			Form 10-K for Fiscal Year Ended December 31, 2004
Filed March 16, 2005
			File No.  1-10920

Dear Mr. Montrone:

		We have reviewed your filing and have the following
comments.  We have limited our review to only your financial
statements and related disclosures and do not intend to expand our
review to other portions of your documents.  Where indicated, we
think you should revise your disclosures in response to these
comments.  If you disagree, we will consider your explanation as
to
why our comment is inapplicable or a revision is unnecessary.
Please
be as detailed as necessary in your explanation.  In some of our
comments, we may ask you to provide us with information so we may
better understand your disclosure.  After reviewing this
information,
we may raise additional comments.

		Please understand that the purpose of our review process
is
to assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your
filings.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 10-K for Fiscal Year Ended December 31, 2004

Statement of Operations, page 42

1. Please disclose your product sales and cost of sales separately
from your service revenue and cost of service revenue.  See Rule
5-03
of Regulation S-X.

Notes to Consolidated Financial Statements

General

2. We note that you sell several types of products and services
based
on your discussion of products and services in Item 1.  Business,
Item 7.  Management`s Discussion and Analysis of Financial
Condition
and Results of Operations and the product line references on your
website.  Please provide the product line revenue disclosures
required by paragraph 37 of SFAS 131.  In particular, we assume
that
would require revenue disclosures for each period presented for
the
following:

- - Laboratory Supplies, Chemicals & Equipment
- - Clinical Lab Instruments & Supplies
- - Diagnostic Kits & Controls
- - Personal Protection & Equipment
- - Organic & Custom Syntheses Products
- - Cell Culture Supplies & Protein Assay Kits and Reagents
- - Services & Support for Clinical Trials
- - Procurement Solutions
- - Service & Calibration of Instruments and Equipment
- - Design & Construction of Laboratory Workstations

      If you believe that other categories are more appropriate,
please advise.

Note 2.  Summary of Significant Accounting Policies, page 46

Accounts Payable, page 48

3. Please tell us your basis in GAAP for recording amounts in
accounts payable that we assume were for checks mailed at December
31, 2004 and 2003 that did not clear the bank.  Tell us how your
method is consistent with the principles of accrual accounting of
recording the financial effects of transactions and other events
and
circumstances that have cash consequences for you in the periods
in
which those transactions, events, and circumstances occur rather
than
only in the periods in which cash is received or paid by you.
Refer
to paragraphs 134-152 of FASB Concept Statement 6 and SFAS 140.

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please understand that we may have additional comments after
reviewing your responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filings includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

		In addition, please be advised that the Division of
Enforcement has access to all information you provide to the staff
of
the Division of Corporation Finance in our review of your filing
or
in response to our comments on your filing.

		If you have any questions regarding these comments,
please
direct them to Anthony Watson, Staff Accountant, at (202) 551-3318
or, in his absence, to me at (202) 551-3843.

									Sincerely,



									George F. Ohsiek, Jr.
									Branch Chief
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Mr. Paul M. Montrone
Fisher Scientific International Inc.
January 3, 2006
Page 3