From: Bob Wr ight/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@EPA, Conniesue Oldham/RTP/USEPA/US

Mcalister.Gary@epamail.epa.g ov, Michael Papp/RTP/USEPA/US@EPA, Patricia Embrey/DC/USEPA/US@EPA, Sara Schneeberg/DC/USEPA/US@EPA Date: 06/25/2008 04:04 PM Subject: Tony Kovar's 2005 Thoughts regarding ISO 17025 Accreditation

The attached file contains an interesting discussion ab out Scott Specialty Gases' attitude in January 2005 regarding ISO 17025 accreditation. It might be useful in future discussions with Air Liquide. Bob Wr ight



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

ISO 1702 5 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 I SO 17025 standard, registered at least 1 failure in the recent blind audit. The high cost of accreditation to the I SO 17025 standard would create an economic inequity among gas manufacturers, creating a competitive advantage favoring large manufacturers.

Technicall y, one of the core concepts of the ISO 17025 standard is the manner b y which uncertaint y is propagated. I n order to assert accreditation of a laboratory to the I SO 17025 standard as a requirement, the protocol would need to be changed so the calculation of uncertaint y 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 W right/RTP/USEPA/US on 03/27/2008 03:20 PM

-----

akovar@scottgas.com

01/28/2005 02:23 PM To Bob Wr ight/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 Contro l Division U.S. Environmental Protection Agency Mail Code E343

- 03, Room E330L Research Triangle Park, NC 27711E

- 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 pro posed 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 fo r 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 wi th regards to our responses, please let me know.

Tony Kovar Corp Dir. of Mfg. Scott Specialty Gases 267

- 980

- 0168