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CORRESP
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    gem_corr-050508.htm

          VIA
EDGAR

          May 5,
2008

          Securities
and Exchange Commission

          100 F
Street, N.E.

          Judiciary
Plaza

          Washington,
D.C.  20549

          Attn: Division of Corporation
Finance,

          Re:    General Environmental Management,
Inc.

File
No. 333-148100

          Dear
Ladies and Gentlemen:

          At the
request of General Environmental Management, Inc., (the “Company”), we are
responding to the comments raised by the Staff of the Securities and Exchange
Commission (the “Commission”) in the comment letter dated March 10, 2008 from
Pamela A. Long of the Commission to Timothy J. Koziol, Chief Executive Officer
of the Company, relating to Amendment # 2 to the registration statement on
Form S-1 of the Company filed with the Commission on April 17, 2008 (the
“Registration Statement”).  We have filed simultaneously Amendment
No. 3 to the Registration Statement and have attached a marked copy of such
Amendment No. 3 indicating the changes that the Company has made to the
Registration Statement.

          In
compliance with release number 33-8876 the Registration Statement is filed on
form S-1A.  Further, in accordance with the SEC’s guidance dated
January 25, 2008 the Company elects to keep form SB-2 disclosure
format.

           The
numbered paragraph below corresponds to the paragraph in which the comment was
made.  For your convenience, we have included above our response a copy of
the comment to which we are responding.

          Grant of Plan—Base Awards,
page 7

          1. Refer
to prior comments 7 and 8.  The grants of plan-based awards during the
year ended December 31, 2007 table is not required by the amendments to the
disclosure requirements adopted by the Commission on November 7,
2006.  In addition, some of the numerical information in that table
does not appear to be consistent with disclosures in the table depicting
outstanding equity awards at fiscal year end.  Please see Item 402 of
Regulation S-B and Release No. 33-8732A, and revise.

          Response

          The
grants of plan-based awards during the year ended December 31, 2007 has been
removed from the registration statement.  Registrant has confirmed
that the information contained in the table depicting outstanding equity awards
at fiscal year end is correct.

          Selling Stockholders, page
47

          2. Refer
to prior comment 9. We note that you have removed the footnote to the table
indicating that the amounts in the table represent the maximum number and
percentage of shares that the selling stockholders can own at one time due to
their 4,99% limitation.  If any of the selling shareholders have the
right to acquire additional shares not shown in the table because of the 4.99%
limitation, please revise your footnotes to clarify this and to disclose the
amounts of shares such shareholders could acquire without regard to the 4.99%
limitation.

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          Response

          The only
selling stockholders that have a percentage limitation on the amount of shares
they may hold are the Laurus Funds and the information describing such
limitation is set forth in Footnote number 12.  No other selling
shareholders have a right to acquire additional shares except as set forth in
the table.

          3.  Based
on footnote number (8) next to the name of John Hakopian in the selling
stockholder table included in the pre-effective amendment1 to the registration
statement, footnote number (13) is also next to the name of Liebling Living
Trust in the selling stockholder table. Please revise.

          Response

          The
Registration Statement has been revised in compliance with the Staff’s
comment.

          Exhibit
5.1

          4.  Refer
to prior comment 19. As noted previously, counsel must consent also to being
named in the registration statement. See Rule 436 of Regulation C under
Securities Act, and revise.

          Response

          Exhibit
5.1 has been revised in compliance with the Staff’s comment

          On behalf
of the Company, we have arranged for delivery to the attention of Edward M.
Kelley of the Commission via Federal Express for overnight delivery three copies
of this response letter together with marked copies of Amendment No.2, and the
supplemental information listed above.

          We hope
that the Staff will be able to accommodate the Company by responding to this
response letter as soon as practicable. In the meantime, should members of the
Commission Staff have any questions or comments, or require any additional
information regarding any of the responses or the attached filing, please
contact the undersigned at 619-702-8690 or Stanley M. Moskowitz, who is Of
Counsel to this firm at 858 523-0100.

          Very
truly yours,

          de Castro
P.C.

              By:

                /s/
      Audie J. de Castro

                Audie
      J. de Castro

                .

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