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@EPA, Conniesue Oldham/RTP/USEPA/US@EPA, Joe
Elkins/RTP/USEPA/US@EPA, Mcalister.Gary@epamail.epa.gov, 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 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

Subject

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

