Mail Stop 3561


									February 10, 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 responses in your letter dated
February 2, 2006 and have the following additional comment.

		We welcome any questions you may have about our comment
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


Notes to Consolidated Financial Statements



Note 2.  Summary of Significant Accounting Policies, page 46

Accounts Payable, page 48

1. We read your response to comment 2 in our letter dated January
19,
2006.  In future filings, to the extent material, please ensure
your
disclosure adequately describes the nature of the credits you have
reclassified out of cash and cash equivalents to accounts payable
similar to what you disclosed to us in your supplemental
responses.

		As appropriate, please respond to this comment within 10
business days or tell us when you will provide us with a response.
Please ensure the response letter provides any requested
supplemental
information.  Please file your response letter on EDGAR.  Please
understand that we may have additional comments after reviewing
your
response to our comment.

		If you have any questions regarding this comment, 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
??

??

??

??

Mr. Paul M. Montrone
Fisher Scientific International Inc.
February 10, 2006
Page 2