Securities and Exchange Commission         December 18, 2001
Washington, D.C. 20549

Ladies and Gentlemen:

We were previously principal accountants for A.P. Pharma,
Inc., and, under the date of February 16, 2001, we reported
on the consolidated financial statements of the Company and
subsidiary as of and for the years ended December 31, 2000
and 1999.  On December 12, 2001, our appointment as
principal accountants was terminated. We have read the
Company's statements included under Item 4 of its Form 8-K
dated December 12, 2001, and we agree with such statements,
except that we are not in a position to agree or disagree
with the Company's statements that the decision to change
independent accountants was recommended by the Company's
audit committee and approved by the Company's board of
directors. We also are not in a position to agree or
disagree with the Company's statement that on December 12,
2001, it engaged Ernst & Young LLP as its independent
accountants for the year ending December 31, 2001, and that
the Company did not consult with Ernst & Young LLP regarding
Items which concerned the subject matter of a disagreement
or reportable event as described in Item 304 (a)(2)
Regulation S-K.

Very truly yours,

/s/ KPMG LLP
- ----------------
KPMG LLP