American Bio Medica Corporation
                                 122 Smith Road
                           Kinderhook, New York 12106

                                                              August 19, 2004

Mr. Oscar M. Young, Jr. Staff Accountant
Division of Corporation Finance
United States Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549

         Re:      American Bio Medica Corporation Form 8-K
                  Filed August 10, 2004, amended August 19, 2004
                  File No. 000-28666

Dear Mr. Young:

      On behalf of American Bio Medica Corporation (the "company"), this letter
and Form 8-K/A-1 filed on August 19, 2004 with the Securities and Exchange
Commission (the "Commission") serves as the company's response to the items
raised in your letter, dated August 11, 2004, furnishing the comments of the
Commission relating to the company's Form 8-K Current Report filed on August 10,
2004.

      Comment 1:

            (a)The company acknowledges that it is responsible for the adequacy
      and accuracy of the disclosure in the Form 8-K, filed on August 10, 2004
      and the form 8-K/A-1, filed on August 19, 2004.

            (b)The company acknowledges that staff comments or changes to
      disclosure in response to staff comments in the filings reviewed by the
      staff do not foreclose the Commission from taking any action with respect
      to the filing.

            (c) The company acknowledges that it 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.


      Comment 2:

            The company's Form 8-K/A-1 filed on August 19, 2004 states the
      specific date (August 10, 2004) that the company's former accountant
      ultimately resigned and updates the disclosures required by Item
      304(a)(1)(iv)(A) and (B).

      Comment 3:

            The company's Form 8-K/A-1 filed on August 19, 2004 states that the
      decision to dismiss the former accountant was not recommended or approved
      by the audit committee or board of directors because the former accountant
      resigned.

      Comment 4:

            The company will file a letter from the former accountant addressing
      the revised disclosures within ten days of filing its Form 8-K/A-1, filed
      on August 19, 2004.

      Please direct any additional questions or comments to our counsel, Richard
L. Burstein, Esq. at 518-463-3990, who would welcome the opportunity to discuss
any such questions or comments in advance of the preparation of any written
response by the Commission. Thank you.

                                        Very truly yours,

                                        AMERICAN BIO MEDICA CORPORATION


                                        By: /s/ Keith E. Palmer
                                            ------------------------------------
                                                Keith E. Palmer
                                                Chief Financial Officer