April 13, 1999

Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C.  20549

                  Advanced Polymer Systems, Inc.
          Registration Statement on Form S-3 (No. 333-69815)
          --------------------------------------------------

Ladies/Gentlemen:

Pursuant to Rule 477 of the Securities Act of 1933, Advanced 
Polymer Systems, Inc. ("Registrant") hereby applies to have the 
above-referenced Registration Statement (the "Registration 
Statement") withdrawn.  Pursuant to the Registration Statement, 
the Registrant proposed to register an aggregate of 200,000 
shares of common stock (the "Shares") for resale by Biosource 
Technologies, Inc. ("Biosource") pursuant to a Settlement 
Agreement and Release between the Registrant and Biosource dated 
as of December 22, 1998 (the "Settlement Agreement and Release").  
The Registrant intends to exercise its right under the Settlement 
Agreement and Release to pay Biosource in cash, eliminating the 
reason for filing the Registration Statement.

No securities have been sold under the Registration Statement and 
all activity pursuant to the Registration Statement has been 
discontinued.

Accordingly, we hereby request that an Order granting the 
withdrawal of the Registration Statement be issued by the 
Commission as soon as possible.

Please contact Richard Peers of Heller Ehrman White & McAuliffe 
at (650) 324-7025 if you have any questions regarding the 
withdrawal of the Registration Statement. 

Very truly yours,

Advanced Polymer Systems, Inc.


/s/ Michael P.J. O'Connell
Executive Vice President and Chief Financial Officer