Mail Stop 3561


									January 19, 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
January 17, 2006 and have the following additional comments.

		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


Notes to Consolidated Financial Statements


General

1. We read your response to comment 2 in our letter dated January
3,
2006.  Product line revenue disclosures should identify products
from
which each reportable segment derives its revenue and should
mirror
the financial information used to prepare your general-purpose
financial statements.  Please tell us the product categories
reported
to senior management in daily, weekly or monthly sales reports for
purposes of managing the business.  Please note that if providing
disclosure of product line revenue information is impracticable
you
should so state in accordance with paragraph 37 of SFAS 131.
Also,
refer to Section II.J.3. of the Current Accounting and Disclosure
Issues in the Division of Corporation Finance updated March 4,
2005
and available on our website at www.sec.gov.

Note 2.  Summary of Significant Accounting Policies, page 46

Accounts Payable, page 48

2. We read your response to comment 2 in our letter dated January
3,
2006.  Please provide us with a copy of your quarterly and annual
materiality analysis of the change in accounting policy.  Please
ensure your analysis shows the impact the amounts had on the
specific
line items in your balance sheets.  Also, tell us the amount of
bank
overdrafts that existed as of December 31, 2004 and 2003.

		As appropriate, please respond to these comments 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 comments.

		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 19, 2006
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