EXHIBIT 16.1


MCGLADREY & PULLEN
Certified Public Accountants




Securities and Exchange Commission
Washington, DC 20549

We were previously engaged as the Registered Public Accountants for Spectrum
Laboratories, Inc. for the two most recent fiscal years and interim periods
through November 12, 2004. On November 12, 2004 we resigned and we notified the
Registrant's Audit Committee that our client/auditor relationship had ceased as
the Registered Public Accountants of Spectrum Laboratories, Inc. The termination
of our relationship with Spectrum Laboratories, Inc. occurred prior to the
completion of our SAS No. 100 review engagement as of and for the period ended
September 25, 2004.

We have read Item 4.01 of Spectrum Laboratories, Inc. Form 8-K dated November
18, 2004 and have the following comments: We agree with the statements made in
paragraphs 1, 2, 3, 4 and 6.

We have no basis on which to agree or disagree with the statement made in
paragraph 5.

We agree with the statements made in paragraph 7 except for the first sentence
for which we have no basis on which to agree or disagree with the statement.




McGladrey & Pullen, LLP


/s/ McGLADREY & PULLEN, LLP
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November 22, 2004