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
March  31,  2005 (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:  May 13, 2005

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