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March 21, 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
File No. 001-04802
Dear Christopher DelOrefice:
            We have limited our review of your filing to the financial statements and related
disclosures 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.
Form 10-K for the Fiscal Year Ended September 30, 2022
Managment's Discussion and Analysis
Critical Accounting Policy -- Contingencies, page 45
1.As of September 30, 2022, you are defending approximately 31,445 product liability
claims involving your line of hernia repair devices. You have accruals of $2.1 billion and
$2.5 billion as of September 30, 2022 and 2021, and recorded pre-tax charges of
approximately $21 million, $361 million, and $378 million during 2022, 2021 and 2020,
respectively. While you disclose a list of “additional information obtained during fiscal
years 2022, 2021 and 2021,” you do not provide the specific factors that impacted your
accrual. For example, your claims significantly increased from 25,030 product liability
claims as of September 31, 2021, but your accrual decreased and your pre-tax charge in
2022 was significantly less than in 2021. Given the significance of the recorded liability
and your cautionary disclosures that you could incur material charges in excess of
currently established accruals, please provide a fuller description of your critical
accounting estimates that considers key judgments made in applying ASC 450 and more

 FirstName LastNameChristopher DelOrefice
 Comapany NameBECTON DICKINSON & CO
 March 21, 2023 Page 2
 FirstName LastNameChristopher DelOrefice
BECTON DICKINSON & CO
March 21, 2023
Page 2
specifically explains the volatility of the assumptions and changes in the recorded liability.
For example:
•Explain why your estimates and assumptions bear risk of change. To this end,
consider disclosing the information you evaluate as part of your legal review and the
approach you apply to develop your estimates. Address the potential impact on your
accrual of changes in significant qualitative factors and material underlying
quantitative assumptions, including changes in the number of estimated new claim
filings, the time period over which claims may be asserted, average settlements per
claim, average costs per claim, and stage of litigation. Include quantification where
possible;
•Explain the specific reasons for changes in estimates that materially impact the
financial statements.  Clarify whether your accrual and related charges have been
impacted by claims related to your line of inferior vena cava filter products and/or
pelvic mesh products;
•Address the impact the three bellwether trials you discuss in Note 6 had on your
accrual, with particular emphasis on the $4.8 million verdict in August 2022;
•Please quantify the extent of your insurance coverage and disclose and discuss the
impact of any insurance proceeds on your results of operations; and
•Explain the basis for the significant assumptions you use in any sensitivity analysis
you provide and address how the assumptions compare with both your historical
experience and the broader approach you use to estimate your accrual.
2.Please provide herein, or elsewhere in MD&A, a roll forward of your outstanding hernia
repair device claims, including the number of claims pending at each balance sheet date,
the number of claims filed each period presented, the number of claims dismissed, settled,
or otherwise resolved for each period, and the average settlement amount per claim. See
Question 3 to SAB Topic 5Y.  To the extent material, address this comment as it relates to
your line of pelvic mesh products and inferior vena cava filter products.
Financial Statements
Note 6 Contingencies, page 71
3.To the extent material, please disclose how you account for your liability insurance.
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.

 FirstName LastNameChristopher DelOrefice
 Comapany NameBECTON DICKINSON & CO
 March 21, 2023 Page 3
 FirstName LastName
Christopher DelOrefice
BECTON DICKINSON & CO
March 21, 2023
Page 3

            You may contact Jeanne Baker at 202-551-3691 or Terence O'Brien at 202-551-
3355 with any questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services