EXHIBIT 31.2

  CERTIFICATION OF CHIEF FINANCIAL OFFICER PURSUANT TO SECURITIES EXCHANGE ACT
       RULES 13A-14 AND 15D-14 AS ADOPTED PURSUANT TO SECTION 302 OF THE
                           SARBANES-OXLEY ACT OF 2002

      In connection with the Form 10-QSB of Biomoda,  Inc. for the quarter ended
September 30, 2004 (the  "quarterly  report") as filed with the  Securities  and
Exchange  Commission on the date hereof, I John J Cousins as President and Chief
Financial Officer of the Company, certify that:

      1. I have reviewed this quarterly  report on Form 10-QSB of Biomoda,  Inc.
(the "registrant");

      2. Based on my  knowledge,  this  quarterly  report  does not  contain any
untrue  statement of a material fact or omit to state a material fact  necessary
to make the  statements  made,  in light of the  circumstances  under which such
statements  were made, not misleading  with respect to the period covered by his
quarterly report;

      3. Based on my knowledge,  the financial  statements  and other  financial
information  included in this quarterly  report,  fairly present in all material
respects the financial  condition,  results of operations  and cash flows of the
registrant as of, and for the periods presented in this quarterly report;

      4. I am responsible for establishing and maintaining  disclosure  controls
and procedures (as defined in Exchange Act rules 13a-15(e) and 15d-15(e) for the
registrant  and have:

      a.  Designed  such  disclosure  controls  and  procedures  or caused  such
disclosure  controls and  procedures to be designed  under our  supervision,  to
ensure that  material  information  relating to the  registrant,  including  its
consolidated  subsidiary  is made known to us by others  within those  entities,
particularly during the period in which this quarterly report is being prepared;

      b. Evaluated the effectiveness of the registrant's disclosure controls and
procedures  and presented in this  quarterly  report our  conclusions  about the
effectiveness  of the  disclosure  controls and  procedures as of the end of the
period covered by this report based on such evaluation; and

      c.  Disclosed  in this  report  any  change in the  registrant's  internal
control over financial  reporting  that occurred  during the  registrant's  most
recent fiscal quarter (the registrant's  fourth fiscal quarter in the case of an
annual  report)  that  has  materially  affected,  or is  reasonably  likely  to
materially affect, the registrant's internal control over financial reporting;

      5. I have  disclosed,  based on our most  recent  evaluation  of  internal
control  over  financial  reporting,   to  the  registrant's  auditors  and  the
registrant's   board  of  directors  (or  persons   performing   the  equivalent
functions);

      a. All  significant  deficiencies  in the design or  operation of internal
controls  which  could  adversely  affect  the  registrant's  ability to record,
process, summarize and report financial information; and

      b. Any fraud,  whether or not material,  that involves management or other
employees who have a significant role in the registrant's  internal control over
financial reporting.

Dated: November 15, 2004

BY:/s/John J. Cousins
   -----------------------------------
   John J Cousins
   President & Chief Financial Officer