SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE

Mail Stop 6010

October 12, 2007

Mr. Leonard Osser
Chairman and Chief Executive Officer
Milestone Scientific, Inc.
220 South Orange Avenue
Livingston Corporate Park
Livingston, New Jersey 07039

 RE: Milestone Scientific, Inc.
  Form 10-KSB for the fiscal year ended December 31, 2006
  Filed April 2, 2007
  File No. 1-14053

Dear Mr. Osser:

We have reviewed your filing and have the following comments.  Where
indicated, we think you should revise your document in future filings in response to these
comments.  If you disagree, we will consider your explanation as to why our comment is
inapplicable or a revision is unnecessary.  Pl ease be as detailed as necessary in your
explanation.  In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.  After reviewing this information, we may
raise additional comments.

 Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  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.

Leonard Osser
Milestone Scientific, Inc.
October 12, 2007 Page 2

FORM 10-KSB for the Fiscal Year Ended December 31, 2006

Management’s Discussion and Analysis, page 15

Summary of Significant Accounting Policies and Significan t Judgments and Estimates,
page 21

1. We note your discussion of critical accounti ng policies, but the disclosures either
do not disclose why they are considered  critical accounting policies or they
merely repeat the policies from your  significant accounting policies footnote
without elaboration.  Accordingly, your  disclosure does not conform to our
expectations for the criti cal accounting policies disc losure. For each identified
critical accounting policy, please expand to describe the specific factors that in
your view makes each critical.  Discuss the nature of estimates  and uncertainties
about those estimates inhere nt to each individual po licy, including how you make
those estimates.  Discuss how different assumptions, methods or conditions might effect your financial statements.  Revise future filings to comply.

Liquidity and Capital Resources, page 23

2. Please revise future filings to discuss significant changes to the components of
working capital – i.e., individually significant changes in line items.  For example, we note that accounts payable increased $688 thousand over the past year while
inventories show a decline.   Please address the impact  on your working capital.
When you cite changes in components of working capital, explain the reasons for
the changes.
3. In your liquidity discussion you note th e Company experienced in 2006 negative
cash flows of $1.6 million from operating activities.  You conclude by indicating management believes the Company has suffici ent resources to meet its obligations
over the next twelve months.  This statement is too general and needs to be more specific.  Tell us and in future filings pr ovide details of expected liquidity needs
over the next year.  For example, future filings should disclose
• the expected additional costs to obtain a CE mark and U.S. patent protection,
which you deem necessary to re-intro duce your teeth whitening products;
• the planned reductions in operations e xpenses and/or the impact technology
rights will have on liquidity and

Leonard Osser
Milestone Scientific, Inc.
October 12, 2007 Page 3
• the existing internal and external capita l sources and the circumstances that
are reasonably likely to affect those sources of liquidity.
Also, consider discussing other so urces that the Company is pursuing.

Notes to Financial Statements, page F-7

Note B – Summary of Significant Accounting Policies, page F-7

4. In future filings please consider the need to include in your Summary of Significant Accounting Policies your acc ounting policy for allowances for
doubtful accounts receivable.

Note B8 – Revenue Recognition, page F-8

5. We note your revenue recognition policy disclo sure is very generic.  Refer to your
response letter dated May 11, 2005, specifica lly your responses to comments 1, 2
and 3.  In future filings, please revise your revenue recognition policy disclosure
to include the more salient points addr essed in your prio r responses to us.

Note H – Stockholders’ Equity, page F-12

Other Issuances of Common Stock, page F-13

6. Please provide us with a schedule re conciling the fiscal 2006 common stock
issuances as disclosed in the footnote to the amounts presented in  the Statement of
Changes in Stockholders’ Equity an d the Statement of Cash Flows.

7. To this regard, tell us and in future filings please explain how each issuance of
equity instruments was valued.

Form 10-QSB for the quarterly period ended June 30, 2007

Item 3 Controls and Procedures, page 18
8. Please expand the first paragraph of the disclosure to incorporate language encompassing the entire two-sentence de finition of disclosure controls and
procedures as set forth in Exchange Act Rule 13a-15(e).  That is, you should also clarify, if true, that your disc losure controls and procedur es are designed to ensure

Leonard Osser
Milestone Scientific, Inc.
October 12, 2007 Page 4
that information required to be disclosed in reports filed or submitted under the Exchange Act is accumulated and communicated to management to allow timely decisions regarding required disclosure.  Apply in future filings.
9. In future filing, please revise the first pa ragraph to state whether the disclosure
controls and procedures were effective, as of the end of the fiscal quarter . It is not
sufficient to say “as of the date of th eir evaluation”.  Refer to Item 307 of
Regulation S-B.

As appropriate, please respond to these co mments within 10 business days or tell
us when you will provide us with a response.  Please furnish a cover letter with your
response that keys your responses to our  comments and provides any requested
information.  Detailed cover letters greatly facilitate our  review.  Please submit your
cover letter on EDGAR.  Pleas e understand that we may ha ve additional comments after
reviewing your responses to our comments.

 We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.

 In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:

‚ the company is responsible for the adequacy  and accuracy of the disclosure in the
filings;

‚ staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and

‚ the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal secu rities laws of the
United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.

You may contact Dennis Hult, Staff Accountant, at (202) 551-3618 or myself if
you have questions regarding comments on the financial statements and related matters.

Leonard Osser
Milestone Scientific, Inc.
October 12, 2007 Page 5
Please contact me at (202) 551-3603 with any other questions.  In this regard, do not
hesitate to contact Angela J. Crane, Accounting Branch Chief, at (202) 551-3554.

        S i n c e r e l y ,

        J a y  W e b b
        Reviewing Accountant