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                             April 27, 2023

       Christopher DelOrefice
       Chief Financial Officer
       BECTON DICKINSON & CO
       1 Becton Drive
       Franklin Lakes, NJ 07417

                                                        Re: BECTON DICKINSON &
CO
                                                            Form 10-K filed
November 22, 2022
                                                            Response dated
April 19, 2023
                                                            File No. 001-04802

       Dear Christopher DelOrefice:

              We have reviewed your April 19, 2023 response to our comment
letter and have the
       following comments. In some of our comments, we may ask you to provide
us with information
       so we may better understand your disclosure.

              Please respond to these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

             After reviewing your response to these comments, we may have
additional
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       March 21, 2023 letter.

       Form 10-K for the Fiscal Year Ended September 30, 2022

       Managment's Discussion and Analysis
       Critical Accounting Policies - Contingencies, page 45

   1.                                                   We have reviewed your
response to comment 1. We continue to believe that additional
                                                        expanded disclosures
are necessary for a reader's full understanding of the factors that
                                                        impacted and/or could
impact your product liability accrual. Please address the following
                                                        additional comments:
                                                            Expand your
disclosures to provide the information you presented under the Changes
                                                            in Estimates
section of your response letter as it provides meaningful information that
                                                            would assist
readers in understanding why, even though the number of claims
                                                            increased, your
accrual decreased. This information would also be appropriate within
                                                            your discussion of
your results of operations;
 Christopher DelOrefice
BECTON DICKINSON & CO
April 27, 2023
Page 2
                We note that you provided quantitative context regarding
ongoing claim activity in
              Note 6 Commitments and Contingencies of the 2022 Form 10-K by
disclosing the
              outstanding number of hernia repair device claims as of the
reporting date. However,
              this information provides limited insight into your product
liability contingencies
              without the comparative information for the prior period and a
discussion of the
              underlying reason for the change in outstanding claims period to
period. Please
              expand your disclosures to provide this information;
                We note your belief that your product liability claims are
nonhomogeneous and that
              specific information regarding claim activity would not be useful
to investors as such
              information may not necessarily be indicative of your ultimate
liability under a mass
              tort matter. However, given the nature of this contingency and
magnitude of the
              claims outstanding, we continue to believe this information is
meaningful. Also, see
              our additional comments below regarding Question 3 to SAB Topic
5Y; and
                With regard to impact of bellwether trials on your product
liability, we note that
              while you disclose such trials you do not address whether or not
these trials impact
              your accrual. Expand your proposed disclosures to address whether
or not the
              discussed bellwether trials impacted your accrual and if not, why
not.
2.       We note your response to comment 2. Notwithstanding your response, we
believe that the
         disclosures set forth in Question 3 of SAB Topic 5Y relevant to a
reader's understanding
         of your hernia product liabilities and therefore reissue this comment.
To the extent certain
         settlement data is confidential as per the contractual terms of the
settlement agreements,
         disclose as such. To the extent factors such as the nonhomogeneous
nature of claims
         affect your consideration of the claims, appropriate textual
disclosures can supplement the
         rollforward.
       You may contact Jeanne Baker at 202-551-3691 or Terence O'Brien at
202-551-3355 if
you have questions regarding comments on the financial statements and related
matters.



                                                               Sincerely,
FirstName LastNameChristopher DelOrefice
                                                               Division of
Corporation Finance
Comapany NameBECTON DICKINSON & CO
                                                               Office of
Industrial Applications and
April 27, 2023 Page 2                                          Services
FirstName LastName