From:	"Bob Davis (AMI)" <Bob.Davis@Airgas.com>

To:	John Schakenbach/DC/USEPA/US@EPA

Date:	04/11/2008 09:42 AM

Subject:	RE: Comments received on the PGVP and Cost of 17025



Hello John:

After a discussion with Doug King (our QA / QC manager) concerning ISO
17025 the cost per facility for Airgas would be $60,000 for initial
accreditation and it would cost another $10,000 to $20,000 per year for
annual costs associated with ISO blends.   Since Airgas has more plants
that produce EPA protocols than any other vendor it would cost us well
over $1,000,000 in combined labor and consulting fees within the next
few years.   The Protocol Gas Verification Program would be much more
cost effective and would give an actual representation of the quality of
EPA protocol gas cylinders.  As you know one of our Airgas companies
(Royal Oak Michigan) was ISO 17025 yet in the 2003 audit they still
failed.   The designation of ISO 17025 makes sure the proceedures are in
place (by guidance) but it does not insure that they are followed (the
results).

Please do not hesitate to call me if you need further clarification.

Thank you

Bob Davis

610-675-6854

-----Original Message-----

From: Schakenbach.John@epamail.epa.gov
[mailto:Schakenbach.John@epamail.epa.gov]

Sent: Tuesday, April 08, 2008 1:56 PM

To: Bob Davis (AMI)

Subject: Fw: Comments received on the PGVP and Cost of 17025

Bob,

I appreciate your offer to help.  I sent these comments to Steve Mandel

yesterday; you are welcome to respond to them as well.  Also, since

Airgas is ISO 17025 accredited, I'm wondering if you could give me an

estimate for the initial and annual costs for being ISO 17025 accredited

for producing EPA Protocol gases, for single component, bi-blends and

tri-blends for common concentration ranges used by utility power plants.

Thanks

John Schakenbach

U.S. Environmental Protection Agency

Clean Air Markets Division

schakenbach.john@epa.gov

Phone: 202-343-9158

Fax: 202-343-2359

