SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-4631

       DIVISION OF
CORPORATION FINANCE

Mail Stop 4631
November 16, 2009

via U.S. mail and facsimile

Timothy J. Koziol, Chief Executive Officer  General Environmental Management, Inc.  3191 Temple Ave., Suite 250 Pomona CA   91768
 RE: General Environmental Management, Inc.
  Form 10-K for the Fiscal Year Ended December 31, 2008
  Filed April 15, 2009   File No. 033-55254-38
Dear Mr. Koziol:

We have reviewed the above referenced filings and have the following comments.
Where indicated, we think you should revise your  disclosures in future filings in response
to these comments. If you disagree, we w ill consider your explanation as to why our
comment is inapplicable or a revision is unneces sary.  Please be as detailed as necessary
in your explanation.  In some of our comme nts, we may ask you to provide us with
supplemental information so we may better understand your disclosure.  After reviewing
this information, we may or may not 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.
   Form 10-K for the Fiscal Year Ended December 31, 2008

 Management’s Discussion and Analysis, page

1. In future annual and quarterly filings pl ease ensure the discussion of results and
operations quantifies the impact of the various underlying factors mentioned in
your analysis and discusses the underlying causes.  For example:

Mr. Timothy J. Koziol
General Environmental Management, Inc  November 16, 2009 Page 2
• On page 25 you state total revenues in creased 15% from fiscal year 2007
to 2008 and you attribute this change  to increased revenues for GEM’s
mobile treatment business and ac quisition of Island Environmental
Services.  However, you do not quantif y or address the underlying reasons
driving the increased sales for GEM’s mobile treatment business.
• On page 25 you state the decrease in operating expenses is attributed to
general expense reductions made in 2007 and decrease in non-cash
charges for consulting and advisory fees.  However, you do not provide a
discussion of the expense reductions  made in 2007, the reason why
consulting and advisory fees decrease d or whether you expect the trend in
lower operating expenses to continue in future periods.
• On page 29 of your March 31, 2009 Form 10-Q you state the increase in
revenue was offset by a decrease in  revenues in the Enviroconstruction
market sector.   However, you do not quantify the decrease or provide an
analysis of the underlying reas on for the decline in sales.
• On page 31 of your June 30, 2009 Form 10-Q you state cost of revenues as
a percentage of revenue as compared to the same period in 2008 increased
primarily due to negative margins at Island Environmental Services.  However, you do not quantify the negative margins or provide a discussion of the underlying reasons for the negative margins.

These are examples and are not intended to be a comprehensive list.  For additional guidance, please refer to Section 501.04 of the Financial Reporting
Codification and SEC Release 33-8350.
2. You state on page 34 that you expect to  begin to operate profitably due to
improved operational results and cost reduc tions made in late 2008.  In future
filings please disclose when you expect this turn around to occur and provide a
discussion of actions management is taking to improve operations.

Liquidity, page 26

3. Given that you received a going concern opinion from your auditors and reported
negative working capital and cash flows from operating activities since 2005,
please revise future filings to include a more robust discussion and analysis of
liquidity.  Specifically, please provide a discussion of your cash needs and sources
of cash and whether you have sufficient cas h to continue opera tions for the next
twelve months.  Refer to SEC Release 33-8350 for guidance.

Revenue Recognition, page 31
4. We note from your disclosure that you pr ovide bundled service packages.  Please
describe the types of services included in this package, your revenue recognition
policy and whether this package has multiple deliverables as contemplated by

Mr. Timothy J. Koziol
General Environmental Management, Inc  November 16, 2009 Page 3
EITF 00-21.   Please also tell us what you mean by “when the service is billed,
expected costs are accumulated and accrued”.

Financial Statements

5. The purchase price of $3.5 million for the Island acquisition in August 2008
appears to be significant pur suant to Rule 8-04 of Regula tion S-X.   If any of the
conditions set forth in Rule 8-04 exc eed 20%, but none exceeds 40%, audited
financial statements should be furnishe d for the most recent fiscal year and
unaudited financial statements for any inte rim periods. Please pr ovide us your test
of significance.

 Forms 10-Q for the Fiscal Quarters Ended March 31, 2009 and June 30, 2009

 Controls and Procedures

6. Please tell us whether there have been changes to your internal controls over
financial reporting during your quarter s ended March 31, 2009 and June 30, 2009
and provide disclosure in future filings th at address this issue.  Refer to Item 308
(c) of Regulation S-K for guidance.

*    *    *    *

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 letter that keys your
responses to our comments and provides any requested supplemental information.
Detailed response letters  greatly facilitate our  review.  Please file your response letter on
EDGAR.  Please understand that we may ha ve additional comments after reviewing
responses to our comments.
We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filings reviewed by the sta ff to be certain that they have provided all
information investors require.  Since the co mpany and its management are in possession
of all facts relating 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 their
filings;

Mr. Timothy J. Koziol
General Environmental Management, Inc  November 16, 2009 Page 4
• 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 advi sed that the Division of En forcement 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 Tracey McKoy, Staff A ccountant, at (202) 551-3772 or, in her
absence Al Pavot at (202) 551-3738 or th e undersigned Accounting Branch Chief at
(202) 551-3355 if you have questions regard ing comments on the financial statements
and related matters.
Sincerely,
           T e r e n c e  O ’ B r i e n          A c c o u n t i n g  B r a n c h  C h i e f