August 11, 2006

Securities and Exchange Commission
Washington, DC 20549
Attention:    Mr. Eric McPhee, Staff Accountant
              Mail Stop 4561

                           Re: Pharma-Bio Serv, Inc.
                               Item 4.01 Form 8-K, Filed 8/3/06
                               File No. 000-50956

Ladies and Gentlemen:

      Pharma-Bio Serv, Inc. (the "Company"), is filing a Form 8-K/A in response
to the questions raised by the Commission in its letter of comments dated August
8, 2006. Set forth below is the Company's response to Commission's comments.

Form 8-K filed August 3, 2006

      1.    Please revise the Form to comply with Item 304 (a) (1) (iii) of
            Regulations S-B which requires a statement indicating whether the
            board of directors recommended or approved the decision to change
            accountants.

      Kevane Soto Pasarell Grant Thornton LLP ("Kevane") informed the Company,
without prior consultation, that it was resigning from the account. The
Company's board of directors did not recommend the decision. Because Kevane has
resigned, the Company's board of directors will have no alternative except to
select a replacement auditor for the Company's financial statements.

      2.    In addition, Item 304 (a)(1)(iv) of Regulations S-B requires a
            statement whether during the registrant's two most recent fiscal
            years and any subsequent interim period through the date of
            resignation, declination or dismissal there were any disagreements
            with the former accountant on any matter of accounting principals or
            practices, financial statement disclosure, or auditing scope or
            procedure, which disagreement (s), if not resolved to the
            satisfaction of the former accountant, would have caused it to make
            reference to the subject matter of the disagreement (s) in
            connection with its reports. In the event of disagreement (s) and/or
            reportable event(s), provide the specific disclosures required by
            Item 304 (a)(1) (iv) and (v) of Regulation S-B.

            The requested language has been included.

      3.    Please file an amended item 4.01 Form 8-K upon Kevane Soto Pasarell
            Grant Thornton's final resignation date. Also, the amended Form 8-K
            must include updated disclosures to reflect the actual date of
            registration. To the extent that you make changes to the Form 8-K to
            comply with our comments, please obtain and file an updated Exhibit
            16 letter from the former accountants stating whether the accountant
            agrees with the statements made in your revised Form 8-K. Refer to
            Item 304 (a) of Regulation S-B.



      As stated in the Form 8-K/A, Kevane's resignation will become effective
upon completion of its review for the third quarter of fiscal 2006, which is the
quarter ended July 31, 2006. The Company will file a further amendment, and will
include an updated Exhibit 16.1, upon the effectiveness of Kevane's resignation.

      In connection with our response to the comments of the staff, the Company
acknowledges that:

      o     The Company is responsible for the adequacy and accuracy of the
            disclosure in the filing;

      o     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

      o     The Company may not assert staff comments as a defense in any
            proceeding initiated by the Commission or any person under the
            federal securities law of the United States.

                                           Very truly yours,

                                           s/  Manuel O. Morera
                                           Chief Financial Officer