RICHARDSON & PATEL LLP
                            10900 WILSHIRE BOULEVARD
                                    SUITE 500
                          LOS ANGELES, CALIFORNIA 90024
                            TELEPHONE (310) 208-1182
                               FAX (310) 208-1154

                               September 21, 2004

VIA EDGAR CORRESPONDENCE & FACSIMILE

Division of Corporate Finance
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Attn: Jason Wynn


                  RE:      EFOODSAFETY.COM, INC.
                           REGISTRATION STATEMENT ON FORM SB-2
                           FILE NO. 333-68008

Dear Mr. Wynn:

          On  behalf  of  eFoodSafety.com,   Inc.,  a  Nevada  corporation  (the
"Company"),  we hereby transmit via Edgar Correspondence pursuant to Rule 101(a)
of Regulation S-T, our responses to the  Commission's  letter dated September 9,
2004.

         The Commission  issued a comment  letter dated  September 9, 2004 based
upon the Commission's  review of the Company's  Registration  Statement filed on
August 20,  2004.  The  following  consists of the  Company's  responses  to the
Commission's  comment  letter.  For the  convenience  of the staff,  the Staff's
comment is repeated verbatim with the Company's response immediately following.

ITEM 14.  CONTROLS AND PROCEDURES, PAGE 18

1. The second full  paragraph of this section  indicates that "[t]here have been
no SIGNIFICANT  changes in the Company's  internal  controls or in other factors
since the date of the Chief Executive  Officer's and Chief  Financial  Officer's
evaluation that could  significantly  affect these internal controls,  including
any  corrective  actions with regards to significant  deficiencies  and material
weaknesses."  Revise this  disclosure  to comply with Item 308(c) of  Regulation
S-K.  Specifically,  provide  disclosure  as to  whether  there  have  been "any
changes," as opposed to  "significant  changes."  Consult the last  paragraph of
section II.J. found in Release No. 33-8238 for additional guidance.  Revise this
language in the Forms 10-QSB cited above.


Division of Corporate Finance
Securities and Exchange Commission
Attn: Jason Wynn
September 21, 2004
Page 2


         RESPONSE: The Form 10-KSB and the 10-QSBs cited above have been amended
to reflect that there have been NO CHANGES in the Company's internal controls or
in other  factors  since the date of the  Chief  Executive  Officer's  and Chief
Financial Officer's  evaluation that could  significantly  affect these internal
controls,   including  any  corrective   actions  with  regards  to  significant
deficiencies and material weaknesses.


         If you have any questions or further  comments,  please do not hesitate
to contact the undersigned at (310) 208-1182 or via fax at (310) 208-1154.


                                           Very truly yours,

                                           RICHARDSON & PATEL, LLP


                                           By:      /s/ Ryan S. Hong
                                              ----------------------------------
                                                 Ryan S. Hong

cc:      Mr. Clarence W. Karney, Chief Executive Officer