From: Bob Wright/RTP/USEPA/US

To: Ragan Tate/DC/USEPA/US@EPA

Cc: James Drummond/DC/USEPA/US@EPA, John Schakenbach/DC/USEPA/US@EPA, Justina Fugh/DC/USEPA/US@E

Mcalister.Gary@epamail.epa.gov, Michael Papp/RTP/USEPA/US@EPA, Patricia Embrey/DC/USEPA/US@EPA, Sara 

Date: 06/25/2008 04:04 PM

Subject: Tony Kovar's 2005 Thoughts regarding ISO 17025 Accreditation

The attached file contains an interesting discussion about Scott Specialty Gases' attitude in January 2005 

regarding ISO 17025 accreditation. It might be useful in future discussions with Air Liquide. Bob Wright

1. Require ISO 17025 accreditation for producers of environmental calibration gases:. 

ISO 17025 is an extremely expensive certification and does not guarantee that a better 

protocol product will be manufactured. In fact, a gas manufacturer, holding certification 

to the ISO 17025 standard, registered at least 1 failure in the recent blind audit. The high 

cost of accreditation to the ISO 17025 standard would create an economic inequity

among gas manufacturers, creating a competitive advantage favoring large 

manufacturers.

Technically, one of the core concepts of the ISO 17025 standard is the manner by which 

uncertainty is propagated. In order to assert accreditation of a laboratory to the ISO 

17025 standard as a requirement, the protocol would need to be changed so the 

calculation of uncertainty would match the conventions dictated by ISO 17025. As 

previously stated (see item 2), we do not view this as a valuable change to the existing 

protocol.

----- Forwarded by Bob Wright/RTP/USEPA/US on 03/27/2008 03:20 PM -----

akovar@scottgas.com

01/28/2005 02:23 PM To Bob Wright/RTP/USEPA/US@EPA

cc rdavis@scottgas.com, sanderson@scottgas.com, 

smiller@scottgas.com, Joe Elkins/RTP/USEPA/US@EPA, 

Conniesue Oldham/RTP/USEPA/US@EPA, 

jkraus@scottgas.com

Subj

ect

EPA Protocol comments

 Robert S. Wright

 Air Pollution Prevention and Control Division

 U.S. Environmental Protection Agency

 Mail Code E343-03, Room E330L

 Research Triangle Park, NC 27711
 E-mail: wright.bob@epa.gov

 Dear Bob,

 Thank you very much for giving us another opportunity to provide you

 with input on changes to the Green Book for producing EPA Protocols.

 We at Scott Specialty Gases value your efforts with regards to the

 Protocol document and are eager to provide you with our input on the

 current document and the proposed changes that you presented in your

 email. Our attached response takes the suggestions presented in your

 email, and addresses each one individually. In addition, where

 appropriate, we have inserted additional ideas that were not

 specifically called out in your email.

 Our objective at Scott Specialty Gases has been to produce the best

 Protocol calibration mixtures possible, because we understand the

 significant impact that these mixtures have on the end users. If they

 are off specification by as little as 2%, the impact on the power

 companies is in the hundreds of millions of dollars. As a result, we

 want to make sure that the protocol document helps improve the

 product, while allowing for the greatest of technical freedom, so

 that producers like Scott Specialty Gases, can continue to innovate

 and improve the product offering.

 (See attached file: EPA Protocol Revisions 01-28-2005.doc)

 If there are any questions with regards to our responses, please let

 me know.

 Tony Kovar

 Corp Dir. of Mfg.

 Scott Specialty Gases

 267-980-0168